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Q. Okay. I want to put then aside Virginia Roberts.
Had anyone else as of December 30th, 2014, told you that Professor Dershowitz had abused any minor, other than Virginia Roberts?
A. No one -- no other -- no other person, no other person had spoken to me and told me that directly, no.
Q. And when you say no other person, I'm including not just any -- any victims of Mr. Epstein, but anyone else, no one had said to you, I have knowledge that Alan Dershowitz abused a minor, other than Virginia Epstein -- Virginia Roberts; is that correct?
MR. SCAROLA: Let me ask you for clarification if I could. Are you asking whether any person made that statement based upon the direct personal Knowledge of that person? And the purpose for my clarification is to the extent information was conveyed to Professor Cassell by co-counsel, or anyone within the joint representation or common interest privilege, I'm not going to permit him to answer that question. If it's anybody outside that, he clearly can. So
if you're looking for someone with direct
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021857