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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.: CACE 15-000072

BRADLEY J. EDWARDS and PAUL G.
CASSELL,

Plaintiffs,

vs.

ALAN M. DERSHOWITZ,

Defendant.

VIDEOTAPE CONTINUED DEPOSITION OF

ALAN M. DERSHOWITZ

VOLUME 4
Pages 462 through 647

Tuesday, January 12, 2016
1:05 p.m. - 4:45 p.m.

Tripp Scott
110 Southeast 6th Street
Fort Lauderdale, Florida

Stenographically Reported By:
Kimberly Fontalvo, RPR, CLR
Realtime Systems Administrator

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Virginia Roberts and things that she has said, was she lying when she said that she has flown on Jeffrey Epstein's airplane?

MR. INDYKE: Objection. Work product and

common interest.

A. I think I can answer that question. Based on material that was produced in discovery, which would not be subject to privilege, there seems to be evidence that she did fly on the airplane with Jeffrey Epstein.

BY MR. EDWARDS:

Q. Was she lying when she says that she was flown on Jeffrey Epstein's airplane across state lines at a time when she was under the age of 18? A. I have no idea.

MR. INDYKE: Objection. Same objection.

Work product and attorney-client and common

interest.

A. I have no idea. But, again -- I just have

no idea.

BY MR. EDWARDS:

Q. Is there any nonprivileged information that you could review that would give you an idea to answer that question or that would give you the answer to that question?

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BY MR. EDWARDS:

Q. What we have here

MR. INDYKE: Attorney-client, work product

and common interests.

BY MR. EDWARDS:

Q. What we have here is only the fraction of flights where Dave Rogers was one of the pilots. Can you help us get the flight logs from Larry Visosky, Larry Morrison, any of the flight logs from the helicopters, et cetera?

A. I would love to. It would all show that I wasn't on the plane.

MR.  INDYKE: Same objection,  same 

instruction.

A. I will do everything in my power -- MR. SCOTT: You can make any request you want to through counsel, and we'll take them up.

A. But I will do everything in my power to get you every flight manifest.

SPECIAL MASTER POZZUOLI: Move forward.

MR. INDYKE: We do not waive any

objection.

MR. SCAROLA: And that request has been

made.

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A. Is that a question?

MR. SCOTT: No. Just Mr. Scarola

MR. EDWARDS: Just that we made a request

for production.

BY MR. EDWARDS:

Q. Was Virginia lying when she says that she was taken to Jeffrey Epstein's home in New York while underage?

A. I have no idea.

MR. INDYKE: Same objection, same

instruction.

BY MR. EDWARDS:

Q. Was Virginia lying when she says she was taken to Jeffrey Epstein's ranch in New Mexico while underage?

MR.  INDYKE: Same objection,  same 

instruction.

A. I can tell you this. She's lying when she said she met me at the ranch. So I cannot believe anything she says about the ranch.

BY MR. EDWARDS:

Q. Was she lying when she says Ghislaine Maxwell and Jeffrey Epstein used sex toys on her when she was underage?

MR. INDYKE: Same objection, same

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instruction.

BY MR. EDWARDS:

Q. Was she lying when she says Jeffrey Epstein and Ghislaine Maxwell made her dress up in outfits for them?

MR.  INDYKE: Same objection,  same 

instruction.

A. Well, I can but I do have some material outside of the record on that.

BY MR. EDWARDS:

Q. Okay.

A. I know that Sigrid McCawley said that she

said that Leslie Wexner made her dress up

MS. McCAWLEY: I am going to object to the extent that you are trying to reveal conversations that were part of a settlement discussion which the judge has already sealed the record on and there is a pending motion for sanctions. And if you're going to start revealing that information, we're going directly to the Judge Lynch.

A. I am going to start revealing SPECIAL MASTER POZZUOLI: No, I'm going to stop you THE WITNESS: Let me tell you why.

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Because I didn't get that from Sigrid or from David Boise. I got it from Leslie Wexner's lawyer in a totally nonprivileged communication.

SPECIAL MASTER POZZUOLI: Let me stop you. I don't believe it's responsive to the question that's pending, so let's move forward.

BY MR. EDWARDS:

Q. My question was, was she lying was Virginia Roberts lying when she says Jeffrey Epstein and Ghislaine Maxwell made her dress up in outfits for them?

A. I can only say that that allegation has been made regarding Leslie Wexner as well.

Q. It has nothing to do with my question.

MR. SCAROLA: Move to strike.

A. Leslie Wexner's lawyer regards that as a full statement and, therefore, I can only assume that it's a false statement when made about someone else. I think that's relevant.

SPECIAL MASTER POZZUOLI: So with respect

to the

MR. EDWARDS: I'm moving to strike the nonresponsive portion of that answer. THE WITNESS: He opened the door.

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SPECIAL MASTER POZZUOLI: I do believe it was nonresponsive in its entirety. Move forward. Go ahead.

BY MR. EDWARDS:

Q.  Do you know Jean-Luc Brunel?

A.  No.

Q.  Have you ever met him?

MR. INDYKE: Same objection, same

instruction.

A. I have no memory of ever meeting a man by

that name.

BY MR. EDWARDS:

Q. Do you know what his role was in Jeffrey

Epstein's life?

A. No.

MR. INDYKE: Same objection, same instruction. Mr. Dershowitz, if you would let me make my objections before you respond.

THE WITNESS: Right.

BY MR. EDWARDS:

Q. Was Virginia Roberts lying when she said Jeffrey Epstein socialized with Bill Clinton during the relevant time period?

MR. INDYKE: Same objection, same

instructions.

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A. My information is that Virginia Roberts was lying when she said that she saw Bill Clinton on Jeffrey Epstein's island. That's all I can comment about with that. And she's lying about that. And she's lying about how Bill Clinton got to the island.

MR. EDWARDS: I move to strike the Nonresponsive portion of the answer.

SPECIAL MASTER POZZUOLI: No, it's

relevant to what you asked. Move forward. I'm

not going to strike it.

BY MR. EDWARDS:

Q. I'm going to go back to the question until I get an answer, though.

SPECIAL MASTER POZZUOLI: Go ahead.

BY MR. EDWARDS:

Q. That is, when Virginia Roberts said that

during the relevant time period, which we defined as

1999 through 2002 --

A. Let's be clear. Around August of both of

those years, right?

Q. I think August of 199 through October of 2002.

A. September, I think it is.

Q. Okay. Was she lying was Virginia

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Roberts lying when she said Jeffrey Epstein socialized with Bill Clinton during that time period?

A. I don't know.

MR. INDYKE: Same objection, same

instruction.

BY MR. EDWARDS:

Q. And you have no nonprivileged information that would provide you the answer to that?

A. I have nonprivileged information that provides me that they socialized together at some point. I don't know whether it was within that timeframe at all. I know they went to Africa together on a mission of goodwill, but I don't know the date of that. So I can't tell you whether it was in the period or outside the period. You may know that; I don't.

Q. Well, if Jeffrey Epstein and Bill Clinton associated, but only at some time period either before or after the relevant time period, it would immediately disprove her statement that Bill Clinton and Jeffrey Epstein socialized during that time period?

A.  I don't understand that question.

Q.  No?

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SPECIAL MASTER POZZUOLI: I don't understand the question either. If you can rephrase the question, that would be helpful.

MR. EDWARDS: Sure.

BY MR. EDWARDS:

Q. If you -- do you know from nonprivileged

information whether Jeffrey Epstein and Bill Clinton

ever socialized?

A. Yes.

Q. Do you know the beginning -- when their

relationship began?

MR. INDYKE: Objection. Same objection,

same instruction.

SPECIAL MASTER POZZUOLI: Again, under

nonprivileged.

MR. EDWARDS: Under nonprivileged

information.

MR. SCOTT: Do you have any nonprivileged information about that?

A. I remember having dinner at the home of Caroline Kennedy and Ed Schlossberg with President Clinton, and he basically asked me how Jeffrey was doing, and led me to believe that he had some relationship with Jeffrey. I don't remember whether that dinner -- when that dinner was. I can probably

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find out. But that would be nonprivileged.

BY MR. EDWARDS:

Q. Was he still President at the time that

conversation was taking place?

A. I don't remember.

Q. Have you ever been, yourself, together

with Jeffrey Epstein and Bill Clinton?

A. No.

Q. Have you ever talked to Jeffrey Epstein about Bill Clinton?

MR. INDYKE: Objection. Same objection,

same instruction.

SPECIAL MASTER POZZUOLI: Nonprivileged.

MR. EDWARDS: Yeah, nonprivileged.

A. It's hard to sort out the privileged and

the nonprivileged.

SPECIAL MASTER POZZUOLI: So based upon the objection, I would ask that you -- unless it's obvious, then no, until we sort that out. A. I shouldn't answer that probably.

SPECIAL MASTER POZZUOLI: I'm going to grant his objection at this point, again, as a continuum because I want to make sure that we preserve this issue for later on.

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BY MR. EDWARDS:

Q. In a previous previously in this

deposition, you indicated your representation of

Jeffrey Epstein on this subject matter began in

2005, right?

A. It began, I think I said, when the first allegations were. I don't have an exact date in mind.

Q. The relevant time period for Virginia

Roberts, as we've defined, is 1999 through 2002.

A. That's correct, yes.

Q. So I'm asking if you know from Jeffrey Epstein, in a time period prior to your representation, whether he was socializing with Bill Clinton.

MR.  INDYKE: Same objection,  same 

instruction.

A. Yes, yes.

MR. SCOTT: As long as it's a

nonprivileged situation.

A. He was.

BY MR. EDWARDS:

Q. He was?

A. He was.

Q. So prior

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A. During the whole period of time up through

2005, you're saying? Yes.

Q. Right.

A. Yes, I think this dinner occurred before

2005, so I would -- yes.

Q. So what did Jeffrey Epstein tell you about his relationship with Bill Clinton? MR. INDYKE: Same objection, same instruction.

BY MR. EDWARDS:

Q. Prior to 2005, obviously.

A. That they knew each other and that they

were doing some charitable work together.

Q. Had Bill Clinton ever been to Jeffrey Epstein's home?

A. I'm not aware.

MR. INDYKE: Same objection, same

instruction.

BY MR. EDWARDS:

Q. What kind of charitable work was Jeffrey Epstein A. I can tell you Donald Trump has been to Jeffrey Epstein's home, and I've seen him there. Q. Okay. What question do you think that 25 you're answering?

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A. Well, you're asking about general things

people

SPECIAL MASTER POZZUOLI: Let's move

forward.

A. so I mean, I gave you an example of one

who has been there.

BY MR. EDWARDS:

Q. Okay. I'm specifically talking about

when -- we started with was Virginia lying when she

said that Jeffrey Epstein socialized with Bill

Clinton during the relevant time period. And now

I'm drilling it.

A. I don't know the answer to that.

Q. Okay. Did you understand did Bill --

Clinton travel with Jeffrey Epstein?

A. My understanding from newspaper

MR. INDYKE: Same objection, same

instruction.

A. My understanding from newspaper accounts is that they went to Africa together with some other famous people, and I think maybe went to Asia together as well. So the answer is yes, I am aware through nonprivileged sources that they traveled together, yes.

MR. SCOTT: Can we take a break in a few

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minutes? I would like -- in the afternoon, he gets a little tired, so I would like to, every hour or so, take -- an hour and ten minutes, take a couple-minute break.

SPECIAL MASTER POZZUOLI: You tell me when is a good --

MR. EDWARDS: Maybe 15 minutes and we'll switch topics, and we can take a break. Good, Tom?

MR. SCOTT: Yes.

MR. EDWARDS: Okay.

BY MR. EDWARDS:

Q. Was Virginia Roberts lying when she says she was introduced to Prince Andrew through Jeffrey Epstein?

MR.  INDYKE: Same objection,  same 

instruction.

SPECIAL MASTER POZZUOLI: Under

non-privileged information.

A. I have seen a photograph of Prince Andrew and Virginia Roberts and Ghislaine Maxwell. I have myself met Prince Andrew. He came to my class at Harvard Law School and there was a dinner for him, and he asked about Jeffrey Epstein. We discussed Jeffrey Epstein.

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BY MR. EDWARDS:

Q. I don't know if this was -- I believe it

was attached to the deposition last time.

A. That's the photograph.

MR. SCOTT: I think it was.

MR. SCAROLA: It was.

MR. EDWARDS: I think it was, too.

MR. SCOTT: It was.

BY MR. EDWARDS:

Q. So you're familiar with this photograph?

A. Yes, and I'm also familiar there's no

comparable photograph with me in it.

Q. Okay.

MR. SCAROLA: That's not responsive.

SPECIAL MASTER POZZUOLI: Move forward.

MR. SCAROLA: Move to strike.

BY MR. EDWARDS:

Q. And in this photograph, this is Prince

Andrew over here on the left?

A. That's true, yeah.

Q. And this is Virginia Roberts in the

middle?

A. I've never seen I've never met

Ms. Roberts, never seen her.

Q. So are you saying that she is lying when

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she says that's her?

A.

No, I just don't

I've never seen her.

MR. SCOTT:

Objection, argumentative.

A. Those are photographs I've seen

photographs --

SPECIAL MASTER POZZUOLI: Hang on one

second. Reask rephrase the question.

BY MR. EDWARDS:

Q. And who is this over here on the -- SPECIAL MASTER POZZUOLI: No, rephrase the question, the previous question about who the young lady is next to Prince Andrew. BY MR. EDWARDS:

Q. Sure. Do you know who this lady is in the middle of this photograph?

A. On the basis of newspaper accounts, it is reported that she is Virginia Roberts. I wouldn't be able -- if you had shown me that picture a year and 16 days ago, I would not have been able to tell you that that's Virginia Roberts because I didn't know who she was.

Q. And who is the other person that's in this

photograph?

A.  Ghislaine Maxwell.

Q.  And that's somebody else that you know,

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correct?

A. I do.

Q. And you know her through Jeffrey Epstein,

right?

MR.  INDYKE: Same objection,  same 

instruction.

A. I wrote an article about her father's death years ago, and I don't remember if I met her independently. I do remember meeting her through her -- I remember that the Lady Rothschild asked me to meet Jeffrey Epstein, and when Jeffrey Epstein came to meet me, he was with Ghislaine Maxwell.

BY MR. EDWARDS:

Q. And when was that?

A. The first time I Jeffrey Epstein, which would have been in the summer of Leslie Wexner's 59th birthday. That's all I can tell you is the summer of his 59th birthday because I then flew with Jeffrey Epstein to Leslie Wexner's 59th birthday. I was presented to Leslie Wexner. Leslie would like to get as birthday gifts interesting people that his friends had met during the year, and so I was 23 Jeffrey Epstein's intellectual gift to Leslie Wexner. And it was that year that I met Jeffrey Epstein. That's the best I can date it.

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Q. Okay. And Ghislaine Maxwell, you are

aware, is involved in litigation with Virginia

Roberts right now, correct?

A. She is being sued by Virginia Roberts for defamation, not for the underlying offenses, which are beyond the statute of limitations, as I understand it, correct.

Q. And have you spoken with Ghislaine Maxwell

about the allegations against her and her denials?

MR. INDYKE: Same objection, same

instruction.

MR. SCOTT: Don't answer it. It's

privileged.

BY MR. EDWARDS:

Q. I'm asking about your conversations with Ghislaine Maxwell, who's in a separate litigation, civil litigation for defamation. Have you personally spoken with Ghislaine Maxwell since these allegations?

A. If there's no objection, I will answer.

MR. INDYKE: There was an objection. Same

objection, same instruction.

BY MR. EDWARDS:

Q. Is there a joint defense agreement related to the civil allegation -- actions regarding the

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defamation actions that involve Ghislaine Maxwell

2 and yourself?

MR. INDYKE: Same objection. SPECIAL MASTER POZZUOLI: What's the basis -- can you explain to me what the basis of the objection is -- and what was the question?

MR. EDWARDS: Has Mr. Dershowitz spoken with Ghislaine Maxwell since the allegations since this defamation suit came about as well as the defamation suit with Ghislaine Maxwell. BY MR. EDWARDS:

Q. Let me ask it cleaner. Have you spoken

with Ghislaine Maxwell since January 2015?

MR. INDYKE: Same objection, same

instruction.

BY MR. EDWARDS:

Q. So that I'm clear, there is a joint defense of the allegations regarding Ghislaine Maxwell that's New York litigation and this defamation case?

MR. INDYKE: There's a common interest agreement in effect with respect to the New York case and a common interest agreement with respect to this case.

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BY  MR.  EDWARDS: 

Q.  Okay. Was Virginia Roberts lying when she

says  that  she was taken by Ghislaine Maxwell and

MR. SCAROLA: Who negotiated the agreement

and  when? 

BY  MR.  EDWARDS:

Q. Is there a common interest agreement in existence with respect to the allegations that have arisen since January of 2015 or that you contend covers that?

MR. INDYKE: Same objection, same

instruction.

BY MR. EDWARDS:

Q. If there is, who negotiated this

agreement?

MR. SCAROLA: Can we have a ruling on propriety? SPECIAL MASTER POZZUOLI: You haven't pushed me, so I let you go.

MR. SCAROLA: Can we have a ruling as to whether we get to know whether Mr. Dershowitz is a party to a common interest agreement with Ghislaine Maxwell? SPECIAL MASTER POZZUOLI: Counsel MS. McCAWLEY: Also, just this is Sigrid

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Mccawley, if any of the individuals on the phone are representing Ghislaine Maxwell, my understanding is the person on the phone is representing Jeffrey Epstein, not Ghislaine Maxwell. That needs to be clarified.

MR. INDYKE: Correct. Correct.

SPECIAL MASTER POZZUOLI: The answer is

correct?

MR. INDYKE: With respect to Mr. Epstein, I can tell you there's a common interest agreement with respect to this matter and a common interest agreement with respect to the Ghislaine Maxwell suit in New York.

SPECIAL MASTER POZZUOLI: Is

Mr. Dershowitz party to that?

MR. INDYKE: Mr. Dershowitz is party to a common interest agreement with Jeffrey in this case. And I believe -- I'd have to check, but I believe that that would extend --

MR. SCAROLA: We want an answer from the witness as to whether the witness is a party to a common interest agreement with Ghislaine Maxwell.

SPECIAL MASTER POZZUOLI: Then ask the question, because I haven't seen the question

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asked yet.

BY MR. EDWARDS:

Q. Are you a party to a common interest agreement with Ghislaine Maxwell?

A. If there's no objection, I'll answer it. MR. INDYKE: I apologize. I thought we were still operating under the original set of objections. So I will repeat it. Same objection, same instruction.

SPECIAL MASTER POZZUOLI: With respect to that question, you can answer.

A. My understanding is that I am still Jeffrey Epstein's lawyer. Jeffrey Epstein, I understand, has a common interest or joint defense agreement with Ghislaine Maxwell, so I have my understanding is that I am bound by a common agreement.

BY MR. EDWARDS:

Q. Is this the same common interest agreement that we were talking about from 2005, or is this a separate common interest agreement that has been signed as a consequence of the lawsuits that have been filed since January 2015?

MR. INDYKE: If this is a new question, I'll assert the same objection and the same

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instruction.

SPECIAL MASTER POZZUOLI: And I'm going to overrule the objection. And you can answer that.

A. My understanding is that it's a combination; that is, it reflects the previous agreement and that there is a new agreement that supplemented the previous agreement.

BY MR. EDWARDS:

Q. When you say it's your understanding, is this understanding in writing; meaning, is there a written common interest agreement that has been put in place since January of 2015?

A. I don't  know.

MR.  INDYKE: Same objection,  same 

instruction.

MR. SCOTT: Can we take a recess when we get a chance?

SPECIAL MASTER POZZUOLI: Yes, but I'm

going to instruct you

A. I don't know. I don't know the answer to

that, whether there's additional writing or not.

BY MR. EDWARDS:

Q. Last question, then we take a break. Have you signed any such agreement

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MR. INDYKE: Same objection, same

instruction.

BY MR. EDWARDS:

Q. -- since January 2015?

A. Since January? Not to my recollection.

MR. EDWARDS: We can take a break.

VIDEOGRAPHER: Going off the record. The

time is approximately 2:09 p.m.

(Recess was held from 2:09 p.m. until 2:26 p.m.) VIDEOGRAPHER: Going back on the record. Time is approximately 2:26 p.m.

BY MR. EDWARDS:

Q. Going back to the photograph, was Virginia Roberts lying when she says that she was taken to London where this photograph was taken?

A. I have no idea.

MR. INDYKE: Same objection, same

instructions.

BY MR. EDWARDS:

Q. Was Virginia Roberts lying when she says that she was paid to have sex with Prince Andrew? MR. INDYKE: Same objection, same instructions. A. Can you tell me what age she was when that happened?

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BY MR. EDWARDS:

Q. The photograph is printed in March of 2001, which is when she's 17, which just means that the photograph was taken sometime before that date. So she was at least as young as 17 is the best that I can tell you.

A. Under the age of consent, that would be an act of prostitution. If she was paid $15,000 to have sex with Prince Andrew at the age of 17 in England, she would be guilty of prostitution.

Q. My question is, was she lying when she says that she was paid to have sex with Prince Andrew?

A.  I have no idea.

Q.  You have met Prince Andrew, right?

A.  I have.

Q.  He sat in the back of your classrooms?

MR. SCOTT: Objection, asked and answered

twice.

A. Once, yes.

BY MR. EDWARDS:

Q. I think we went to Jeffrey Epstein sitting

in your classrooms, but now I'm talking about Prince

Andrew sat in your classroom as well, right?

A. Yes, once.

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MR. SCOTT: I thought we went through Andrew before; maybe I'm wrong. BY MR. EDWARDS:

Q. Have you, since the -- since January of

2015, have you contacted Prince Andrew?

A. No. I got a Christmas card from him.

Q. Have you spoke with him about the allegations that were alleged against Prince Andrew? A. Not to him, but to -- not to him.

Q. Have you spoke to some representative of

his, of Prince Andrew?

A. I need to know whether

MR. INDYKE: Guy, sorry, I was just cut off for some reason.

SPECIAL MASTER POZZUOLI: Hold on a second. Go ahead and restate your question so -- Darren, can you hear now?

MR. INDYKE: Yes, I can.

BY MR. EDWARDS:

Q. My question is, have you spoken with Prince Andrew or any representative of or for Prince Andrew since January of 2015?

MR. SCOTT: If any of that involved work product on our part, I am instructing you not to answer.

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court-records/Edwards v. Maxwell, No. 117-mc-00025 (S.D.N.Y. 2016)/001-04.pdf
{"year":"2016","court":"S.D.N.Y","people":["bradley edwards","paul g. cassell","alan dershowitz","virginia giuffre","jeffrey epstein","darren indyke","dave rogers","larry visoski","larry morrison","jack scarola","ghislaine maxwell","sigrid s. mccawley","les wexner","david boies","jean-luc brunel","bill clinton","caroline kennedy","ed schlossberg","donald trump","prince andrew","kimberly fontalvo"]}