Latest / The Vault: The Epstein Files / Mega Edition: Paul Cassell's Deposition In Cassell/Edwards V. Dershowitz (Part 4-6) (6/21/26)
Transcript
- 0:00Speaker 1: What's up, everyone, and welcome to another episode of the
- 0:03Epstein Chronicles. In this episode, we're going to pick up
- 0:06where we left off with the Paul Cassell deposition in
- 0:10the lawsuit against Alan Dershowitz. Question, mister Cassell, you came
- 0:17here today looking for an opportunity to give that statement?
- 0:20Did you not answer if it was relevant to an
- 0:23answer I was giving? Yes question. The answer to my
- 0:27question is yes, you came here today looking for a
- 0:31question to which you could respond with that prepared statement
- 0:35answer I was prepared to give. I anticipated that a
- 0:38very good attorney for mister Dershowitz might ask a question
- 0:42where that would be relevant, And if that question were
- 0:45asked and I was given opportunity to make a statement,
- 0:48I wanted to be prepared to give it the most
- 0:50accurate way I could. Simpson, I would like the reporter
- 0:54to mark as exhibit. Are we up to four? Exhibit
- 0:58four the document that mister Cassell was referring to. I'll
- 1:01let the reporter do that, mister Simpson. I just wanted
- 1:04to make that part of the record. Simpson. Question, Before
- 1:07Wednesday of this week, you had none of the information
- 1:11that you just described about Professor Dershowitz's testimony. Correct answer.
- 1:15Correct question. I'm trying to look at my notes here
- 1:19of your long answer, but one thing you indicated was
- 1:23the fact that Professor Dershowitz gave long answers. Is somehow
- 1:26indicative the false answers or perjury? Is that? Right? SCROLLA.
- 1:32That is an absolute mischaracterization of the statement that Professor
- 1:36Cassel made. He did not refer to the length of
- 1:38the answers, but rather their non responsiveness. Simpson, let me
- 1:43ask a different question, go back to the flight logs themselves. Answer, okay, question.
- 1:49My initial question that got us going down this line
- 1:51was isn't it true that the flight logs themselves support
- 1:55professor Dershowitz's testimony that he was never on a plane
- 1:58with redacted. The face of the flight log support that proposition. Answer.
- 2:03The face of the flight logs for the relevant period
- 2:06of time we call it the hot period of time
- 2:08or whatever you want, did not reveal the presence of
- 2:11mister Dershowitz on those flights. Yes question. Okay, so during
- 2:15the period, well, actually, there's no flight log that shows
- 2:18redacted and professor Dershowitz on the same airplane. Correct answer.
- 2:23That's my understanding, yes, question, and mister Scola by name McCauley,
- 2:29she pipes in and did Scrolla talks over her though,
- 2:33asking whether she was there identified by name, Simpson, to
- 2:37your knowledge, isn't it correct that there is no flight
- 2:39log that's been produced in this case by any party
- 2:43that reflects Professor Dershowitz and redacted on the same plane
- 2:47as you read the flight log? Scarrolla, I'm sorry, are
- 2:51you asking whether those same names appear on the flight
- 2:53log together? Simpson? My question, I think is perfectly clear.
- 2:59Question question. My question, mister Kassel, is you reviewed the
- 3:04flight logs? Correct answer? Correct question you reviewed them in
- 3:08some detail? Correct answer? Correct question. Is there in any
- 3:13entry on those flight lines or logs that you read
- 3:16as putting professor Dershowitz and redacted on the same plane? Answer?
- 3:20No question. So your testimony about questions about the completeness
- 3:25and accuracy of those flight logs goes to whether the
- 3:28logs are Let me rephrase that the answer that you
- 3:30gave about your question, your views as to the completeness
- 3:34of the flight logs and whether they may or may
- 3:37not have changed in some ways, goes to whether those
- 3:40logs are conclusive not whether they in fact support Professor
- 3:43Dershowitz testimony that he was not on a plane with
- 3:46redacted SCROLLA. I'm going to object to the form of
- 3:50the question as vague and ambiguous. I don't understand it, Witness.
- 3:56I won't give a long answer, but I think, as
- 3:58previously indicated, you can't just look at the face of
- 4:01these documents, you know, against the context of an international
- 4:06sex trafficking ring that's trying to cover up what it's doing.
- 4:10You can't just look at documents and assume that they
- 4:13are one hundred percent accurate without having context in mind.
- 4:16Simpson question, and so am I right that on the
- 4:19face of the flight logs there's nothing showing redacted and
- 4:23Professor Dershowitz on the same plane answer that is correct?
- 4:27Question and go on and so do I understand correctly
- 4:31that your position is that the flight logs you may
- 4:35not complete or may have been changed, but you do
- 4:38not dispute that on their face they support Professor Dershowitz testimony.
- 4:43SCROLLA objection mcaulay objection SCROLLA compound the witness, could you
- 4:49just aggregate that, mister Simpson question, you follow objections very well. Answer.
- 4:55I was thinking of that as well. Question. Let me
- 4:59just ask a different question. Answer, sure, thanks, question. You
- 5:03testified that you at some length about why you questioned
- 5:06the accuracy of the flight logs. Correct answer, correct question.
- 5:11But I may be redundant, but you don't question. That's
- 5:15what they show in their face, supports Professor Dershowitz testimony
- 5:19McAuley objection mister Simpson that he was not on the
- 5:23plane with redacted. Answer. You know the sex trafficking ring
- 5:27run by Jeffrey Epstein has produced Epstein flight logs that
- 5:30appear to show that Dershowitz and redacted are not on
- 5:34the plane. So the answer to my question is yes,
- 5:39scrolla I'm sorry the witness? Which question? Now? Simpson? The question?
- 5:44Could you read back my question and my answer? Simpson?
- 5:47Let me ask it again. Question what were you about
- 5:50to say? Answer? I was about to say that the
- 5:53records that they produced, I'm sorry gets cut off. The
- 5:56records the records that were produced. Answer on their face,
- 6:01I cannot give you a flight log that has redacted
- 6:03and Alan Dershowitz sitting next to each other. Yes. Question,
- 6:07And you also testified a moment ago that Professor Dershowitz
- 6:10in his testimony in the last couple of days, had
- 6:14testified that redacted had been arrested for stealing cash. Do
- 6:17you refer do you recall that? Answer? I recall his
- 6:20testimony to that effect. Yes. Question, and you testified that
- 6:24no support for that had been produced in discovery? Is
- 6:28that correct? Answer? That's my understanding. Yes. Question. Isn't it
- 6:33true that mister Alessi deposition he described that under oath
- 6:36and says that had happened. Answer. I don't have a
- 6:39recollection of criminal charges having been discussed in the Alessie deposition. Question, Well,
- 6:45let me just ask you, is it your testimony that
- 6:48you understand that, in fact, you had been accused of
- 6:52stealing money from her employers? McAuley, I'm going to object
- 6:56to the extent it gets into any conversation that he
- 6:59might have had with redacted on any issues the witness. Yeah,
- 7:03I'm trying to If your question is about Alessi deposition,
- 7:06I don't immediately recall them discussing discussing them. Simpson. Question,
- 7:11If I represent to you that mister Alessi in his
- 7:14deposition referred to a police report and an arrest of redacted,
- 7:18do you have any reason to question that SCROLLA. Could
- 7:21we pull out the deposition and if you have a
- 7:24reference to that deposition, let's take a look, mister Simpson.
- 7:28I'm just asking for his recollection right now. The document
- 7:31will speak for itself. SCROLLA, Yes, it will. Simpson, he
- 7:35made a very serious accusation. I would like to get
- 7:38an answer to my question. Does he recall whether in
- 7:41that deposition that all the parties in the case have
- 7:45mister Alessi said under oath that she had been arrested
- 7:48and charged with stealing from her employer, the witness. The
- 7:53question built in a serious accusation. The statement I was
- 7:57making is that we had propounded in interrogatory to mister
- 8:02Dershwood saying what's the basis for your assertion that redacted
- 8:06had a criminal record? And that answer didn't refer to
- 8:09an Alessi deposition. This is one of the problems that
- 8:12I'm having. You know, when you come into a deposition,
- 8:14both sides are supposed to turn everything over, and then
- 8:18if I get a question about well, what if you
- 8:20know we're relying on this piece of the less depot
- 8:24and it's not in the answers to the interrogatories, It's
- 8:27hard for me to give an answer to that, and
- 8:30so that's the concern that I have. Mister Simpson moved
- 8:33to strike is non responsive question. My question went to weather.
- 8:37Let me back up if unless I'm misunderstanding you, SCROLLA.
- 8:41The question was did he recall the contents? Simpson, I'm
- 8:45asking the question SCROLLA of the less deposition, Simpson, I'm
- 8:50withdrawing it. I will ask a new question. SCROLLA. Okay,
- 8:53thank you, Simpson. I understood you in the long answer
- 8:57that you gave a while ago to suggest that Professor
- 9:00her Dershowitz had either testified falsely or failed to provide
- 9:03relevant information on which he was basing his testimony about
- 9:07redacted's arrest. Is that right answer? Yes, question, and that
- 9:11assertion would be incorrect if there's a deposition in the
- 9:14case that all the parties have that include that information. SCROLLA.
- 9:20Mister Simpson, there was an express reference to an answer
- 9:23to an interrogatory and the absence of any reference to
- 9:26an arrest for theft and your client's sworn answer to
- 9:30the interrogatory. That's exactly what the testimony was, Simpson. If
- 9:35you object to the form, please just object to the form.
- 9:38I think it's a proper question in our discovery response Scrolla,
- 9:43I object to your misrepresentation of the earlier testimony. I'm
- 9:48sure it was not intentional, and that's why I'm calling
- 9:50it to your attention, so that we don't go down
- 9:53a rabbit trail. Simpson. I'm not going down any rabbit trail.
- 9:57Objection to the form will preserve it. Simpson. My question
- 10:02is whether you were aware at the time that Professor
- 10:04Dershowitz testified that, in fact, mister Alessi had also testified
- 10:09previously about the arrest of redacted for stealing from her employer. Answer.
- 10:14I didn't recall that. If that's in there, you're making
- 10:17a representation, and I know you're a fine lawyer, so
- 10:20I'll accept your representation. I didn't recall that when he
- 10:24was testifying a day or two ago on that subject.
- 10:28Mister Scrolla, we've been going for about an hour. Is
- 10:31it time to take a break. Is that convenient for you,
- 10:34mister Simpson. We can take a break now, all right.
- 10:36We're going to wrap up right here as well, and
- 10:38in the next episode we're going to pick up where
- 10:40we left off. All of the information that goes with
- 10:44this episode can be found in the description box. What's up, everyone,
- 10:48and welcome to another episode of the Epstein Chronicles. In
- 10:52this episode, we're going to pick up where we left
- 10:54off with the Paul Cassel deposition in the lawsuit against
- 10:59Alan Dershowitz. The witness. I need to take two minutes,
- 11:03if I may, and just supplement the long answer that
- 11:06I gave about the series of things. By looking over
- 11:09my checklist, I noticed that item five of the twelve
- 11:12items was not given during my testimony. He gets cut
- 11:16off by Simpson. I'm not going to ask about item five.
- 11:20It's in the record as part of your He gets
- 11:22cut off now by mister Kassel. Answer. I would like
- 11:27to just supplement SCROLLA pops in. That's fine, that's fine.
- 11:30If you don't want to hear it, that's okay, just
- 11:33as long as it's noted that there was an inadvert
- 11:37no mission the witness. Yeah, Simpson, I'm going to go
- 11:40back actually to the question. I was asking one question
- 11:44about the flight logs again, answer, okay, question it's true.
- 11:49Is it not that you have no personal knowledge as
- 11:52to whether Professor Dershowitz or some other member of Jeffrey
- 11:55Epstein's defense team prepared those logs for production to the government. Answer.
- 12:01I don't have any personal knowledge of that. That's right question.
- 12:05And you would agree, would you not? That it's the
- 12:08duty of the defense council to represent a client zealously
- 12:11within the bounds of the law. Correct answer, correct question.
- 12:16In fact, I think you testified yesterday about your duty
- 12:19with respect or adacted along those lines. Correct answer. That's
- 12:23right question. And so with respect to Professor dershowitz representation
- 12:27of Jeffrey Epstein, he would have been acting on ethically
- 12:31if he didn't attempt to negotiate the best resolution for
- 12:34his client that he could, consistent with the law. Is
- 12:37that correct answer? Right? Consistent with the law? Yes question,
- 12:42and so you wouldn't he gets cut off now by Kassel.
- 12:45Let me just consistent with the law and with ethical
- 12:48obligations of attorneys. Attorneys cannot make, for example, false representations
- 12:54when they're negotiating those kinds of things. Question right, the
- 12:57duty of a defense council Professor dershowitz duty was to
- 13:00attend to obtain the best resolution that he could for
- 13:04Jeffrey Epstein, consistent with the law and legal ethics. Correct answer,
- 13:08that's correct question. And in fact, if he had not
- 13:12done that he would have not been acting ethically correct
- 13:15Answer correct, question, and you would agree it would be inappropriate,
- 13:20totally inappropriate to infer anything negative about an attorney because
- 13:24the attorney represented someone accused of Hainu's crimes. Answer just
- 13:29the fact of representation alone. Question Yeah, answer, Yeah, that's right. Sure,
- 13:35of course, everyone's entitled to a defense. Question before December
- 13:40thirtieth of twenty fourteen, had you reviewed in the Palm
- 13:43Beach police report? Answer portions of it? Yes, question had
- 13:48you reviewed the entire report? Answer? I think I reviewed
- 13:51most of it, but I think I've gone through it
- 13:53page by page. Question when did you do that? Answer? Well,
- 13:58let's see before December thirtieth, twenty fourteen, Brad, and I
- 14:03filed the case in about July of two thousand and eight,
- 14:06so it was about a six year period of time.
- 14:09But I remember I had been to Florida a couple
- 14:11of times on this case, once in twenty ten, and
- 14:14I think another year or two later, and I remember
- 14:18at least one of those times reviewing the report here.
- 14:21I don't know if I can McCauley, Yeah, I wouldn't
- 14:24go into anything, Cassell, So we just we just want
- 14:29to know McCauley. The location's fine. The location once personally,
- 14:34once here in Florida and then in my office while
- 14:37in Salt Lake City. Mister Simpson, question, and you're able
- 14:41to place in time when you reviewed these portions of
- 14:44the police report other than before December thirtieth of twenty fourteen.
- 14:49Answer not precisely, no question. And do you understand correctly
- 14:53from your testimony yesterday that the police report is one
- 14:57of the things you relied on to support making the
- 14:59alleytions against Professor Dershowitz that are included in the joint
- 15:04your emotion. Answer, that's right. Question. It's also true, is
- 15:09it not that the police report includes an interview with
- 15:12an adult woman who was retained to provide massages at
- 15:16Jeffrey Epstein's residence for guests, among others. Isn't that correct? Answer?
- 15:21I believe that's correct. Question. And based on that, is
- 15:24it your testimony that it's fair to presume that a
- 15:27reference that a guest god a massage is a code
- 15:30word for abusing a minor sexually. Mister Scrolla, I'm sorry,
- 15:34are you isolating? Simpson cuts them off. I don't want
- 15:38to speech, mister Scrolla. If you object to the form,
- 15:41object to the form, and I if it's not proper
- 15:44objection Scrolla. I want clarification of the question. Please, are
- 15:47you isolating Simpson? The question? Scarrolla cuts them off again
- 15:54information Simpson cuts him off. I'm asking a question that's
- 15:59perfectly clear. If you think it's objectionable, it'll stand, mister Scrola.
- 16:04I'm going to object on the basis that it's vague
- 16:06and ambiguous. Simpson, Please don't coach the witness Scrolla to
- 16:11isolate his focus to that single piece of evidence. Simpson.
- 16:15I object on the coaching of the witness. Simpson. My
- 16:19question is is it reasonable considering that the police report
- 16:23on its face shows evidence? Let me back this up
- 16:26ask another question to you. Are you aware that the
- 16:29police report reflects that a woman I refer to who
- 16:32was hired to give massages told them that she never
- 16:35touched anyone inappropriately. Answer? I think that there is information
- 16:40along those lines in the police report. Yes. Question okay,
- 16:45And so do you acknowledge that the police report on
- 16:47its face reflects both reports of massages that involved improper
- 16:52sexual contact contact and massages that were perfectly legitimate. Answer, yes,
- 16:58but not in the same proportion question. My question, wasn't
- 17:02a proportion the report, on its face, you understand, reflected
- 17:06that there were massages given at mister Epstein's residence that
- 17:09were perfectly legitimate. Answer some, It was basically a few
- 17:14isolated examples from what I could see. Question, So you
- 17:18would characterize that and what was said in the police
- 17:21report as a few isolated examples? Answer? Well, given the
- 17:25backdrop question No, my question it's a yes or no question.
- 17:30Is that how you would characterize it? Scrolla excuse me,
- 17:34the witness is not confirmed to answering yes or no.
- 17:36If yes or no would be misleading Simpson, It's a
- 17:40different position that was taken previously. But Cassell pipes in,
- 17:44I mean, I was just going to give one sentence,
- 17:47and the one sentence would be in the context of
- 17:49this whole police report where they had twenty four approximately
- 17:53minor girls who were being sexually abused. The references to
- 17:57legitimate massages I would view as isolated. Question. So you're
- 18:03coming to the conclusion looking at the police report that
- 18:05they are isolated? Is that right? Answer? Yes? Question? And
- 18:10do you think a fair minded reader of the police
- 18:12report would reach that conclusion? Answer absolutely? Question And were
- 18:17you aware that the police report, to give a bit
- 18:20more detail, reflected that a woman who was described as
- 18:23having tattoos was hired to give deep tissue Swedish massages.
- 18:27Do you recall that being in the police report? Answer
- 18:31something along those lines, yes. Question and she also the
- 18:35woman also told the police that she was not Jeffrey
- 18:38Epstein's type, that she wasn't thin, had tattoos, didn't fit
- 18:41his type. Answer that sounds accurate with the information I have. Yes,
- 18:46she doesn't sound like she would fit his type. Question
- 18:49and so do you agree with me? He gets cut
- 18:52off by cassel, And she's over the age of eighteen,
- 18:55which is another reason why she wouldn't fit his type. Question,
- 18:59But you acknowledge that this woman that the police report
- 19:02reflects a woman over well over the age of eighteen
- 19:05being hired to give perfectly legitimate massages. Correct answer, Yeah,
- 19:10that was cover for the sex trafficking that was going on.
- 19:14Question Okay, so now does the police report say it
- 19:17was cover for the sex trafficking? Answer? That was my
- 19:21conclusion when I reviewed the material. Question Okay, So your
- 19:25inclusion is that a fair minded reader of the police
- 19:29report would come to that conclusion. Answer December thirtieth of
- 19:32twenty fourteen, knowing what we know now, Yes. Question do
- 19:38you consider yourself a very suspicious person? Answer no. Question
- 19:43do you consider yourself a conspiracy having a conspiratorial view?
- 19:49Answer absolutely not. Question do you consider yourself a crusader?
- 19:53Answer well, crusader for justice, I would say yes. Question,
- 19:58let me put it this way. In your view, is
- 20:01evidence that a person, any person, any guest at mister
- 20:04Epstein's house had a massage, evidence that that person engaged
- 20:08in criminal sexual conduct contact with minors because of the
- 20:12fact of having a massage. Answer you'd have to look
- 20:16at the context. Question on its own, Is it any evidence?
- 20:20Doesn't it? Is it any evidence at all? In your view?
- 20:24Answer it would be some evidence. Yes. Question withstanding that
- 20:28the report on its face reflects both legitimate and illegitimate massages.
- 20:33Answer The report on its face, let's be clear, reflects
- 20:37a lot of illegitimate massages and sporadic or isolated, you know,
- 20:41legitimate massages. So the fact that somebody gets a massage
- 20:45in that context, I think it raises, you know, the
- 20:48concerns we've been talking about. Question did you before December
- 20:53thirtieth of twenty fourteen yourself personally review what I think
- 20:57you referred to in your testimony yesterday as the Holy
- 21:01grill an address book of mister Epstein. Answer pieces of it, Yes,
- 21:06question did you review the entire document? Answer no. Question
- 21:10Did I understand yesterday that you testified? Did I understand
- 21:14correctly yesterday that you testified that the fact that the
- 21:17names were circled indicated that those persons likely engaged in
- 21:21a legal sexual contact with minors? Answer? My impression is
- 21:26the names that were circled were circled by Alfredo Rodriguez
- 21:29when he was busted by the FBI for involvement and
- 21:32was asked to testify and identify those who would have
- 21:35information about the sex trafficking organization. And based on all
- 21:40the evidence I have, I believe the names that were
- 21:42circled were the ones that kind of had that information. Question,
- 21:47so it's your testimony that if the name is circled,
- 21:50it indicates that they had information or that they are criminals.
- 21:53Answer that they would have information about the sex trafficking
- 21:57organization and that they would probably mean that they were
- 22:00art of the organization. It may mean that there are
- 22:03witnesses to what the organization was doing, but they would
- 22:06have information that the FBI, among other law enforcement agencies,
- 22:10should be following up on, and if they're trying to
- 22:12piece together that the sex trafficking organization was doing. Question
- 22:18would you agree that a fair minded person with that
- 22:20background that you just described would not go to the
- 22:23conclusion that the fact a name is circled indicates that
- 22:26the person has engaged in criminal conduct. Answer? What it
- 22:32would indicate is that they had information relevant to criminal activity.
- 22:36Now would they, on the just the facts that a
- 22:39name was circled standing alone, reach that conclusion. Well, that's
- 22:43a hypothetical question because obviously in this case there's a
- 22:46lot of other information. Question is it true is it
- 22:51not that mister Rodriguez was trying to sell that book? Answer?
- 22:54That's true. Question, And is it not also true that
- 22:57the people who are circled are famous people? Answer? I'd
- 23:01have to refresh my recollection as to exactly who was circled,
- 23:05but I know some famous people were circled and some
- 23:08famous people were not circled. Question would it be a
- 23:12reasonable inference or a possible reasonable inference to draw that
- 23:16mister Rodriguez was trying to highlight people who would be
- 23:18of interest to the free press for purpose of selling
- 23:21the book. Answer no, because he was talking. He was
- 23:24not talking to the press. He was talking to an
- 23:26FBI agent who had busted him for criminal activity, and
- 23:30so I was assuming that he was trying to do
- 23:32as so many criminals do when they're apprehended, was give
- 23:35information to law enforcement agency that would be helpful so
- 23:39that they can catch other big fishes is a phrase
- 23:41that sometimes is used, so the little fish would would
- 23:44get off or get cooperational deal from law enforcement agency.
- 23:50Let's be clear, he was talking to somebody he understood
- 23:53was an FBI agent at the time, and so it
- 23:56was in the context of that conversation. Question do you
- 23:59have any personal knowledge that it's in the context of
- 24:01talking to the FBI that mister Rodriguez circled those names? Answer?
- 24:06I've reviewed. I know I could refresh my recollection here,
- 24:09but there's an FBI three oh two report of the
- 24:11interview of the circumstances surrounding mister Rodriguez's arrest, and I
- 24:15believe I reviewed that three oh two. Question do you
- 24:19know whether the FBI at any point contacted Professor Dershowitz
- 24:22to discuss any evidence he might have after his name
- 24:25was circled on this document. Answer. I don't have any
- 24:29personal knowledge of what the FBI did to follow up
- 24:32after that. All right, folks, we're gonna wrap up right here,
- 24:35and in the next episode dealing with the topic, we're
- 24:37gonna pick up where we left off. All of the
- 24:40information that goes with this episode can be found in
- 24:43the description box. What's up, everyone, and welcome to another
- 24:47episode of the Epstein Chronicles. In this episode, we're gonna
- 24:51dive right back in to the Paul Cassel deposition in
- 24:54the lawsuit against Alan Dershowitz. Question, Okay, one of the
- 25:01names circled in the book is Courtney Love? Do you
- 25:04know who she is? Answer? Not off the top of
- 25:06my head. No question if I mentioned to you, or
- 25:10if I represent that she's a famous actress, any reason
- 25:14to question that? Answer? No. Question in your review? Was
- 25:18Courtney Love involved in sex trafficking? Answer? I don't know.
- 25:22Question in your view? Was Courtney Love a witness to
- 25:25sex trafficking? Answer? Are you representing her name as circled? Question?
- 25:32Her name is circled on the book In fact, we
- 25:34can show it. Answer okay, yeah, question it circled on
- 25:38the book answer, Okay, yeah, sure, I mean my understanding
- 25:42would be that this is your I could ask a
- 25:45question about the circling or your representation. Is the circling
- 25:49the same type of circling that's done for mister Dershowitz,
- 25:52for example, is it the same you know, handwriting, same ink,
- 25:56same same appearance, you know, if it's consistent with the circle?
- 26:01Are you representing it's consistent with the circling? Question? Mister Cassell,
- 26:06we have a document produced in discovery that has various
- 26:09names circled. Looking at that document, I don't see any
- 26:12difference among the circles. Are you aware of any document
- 26:17scrolla pipes in? Could we have a look? Could we
- 26:20see the document? And then to do that they go
- 26:23off the record for a moment and then they come
- 26:25back on mister Simpson, Okay, back on the record. I'm
- 26:29going to ask the reporter to mark as Cassel exhibit five,
- 26:34a multi page document. It's a copy of the address
- 26:37book that we've been speaking about, and ask mister Cassell
- 26:41to take a look at this. And I'm going to
- 26:43ask them about certain entries. Mister Simpson, and I will
- 26:47note I put a few flags on here. The witness. Sure,
- 26:50mister Simpson to direct your attention, which we can. I'll
- 26:54note the pages for the record, just so we have
- 26:57time or we have them thirty eight, seventy six and
- 27:01eighty five Cassell, Okay, I just want to take two minutes.
- 27:07He gets cut off by Simpson. Yeah, take a moment
- 27:10to look at it. Casell Okay, I want to make
- 27:14a few notes, if that's all right, just to get
- 27:17them in. Question you're going to mark? Answer no, not
- 27:21on the exhibit. I'm just going to make notes to
- 27:23refresh my recollection so we don't have to take time.
- 27:27I'm just making notes of the context here. This will
- 27:30just take another minute, is all? Question? Take as long
- 27:34as you want to to look at the document? Answer super,
- 27:37thank you. Okay. Yeah, I think I'm oriented now, but
- 27:41I haven't looked at the Love entry. Question. My first
- 27:47question is is this a copy of the address book
- 27:50that you referred to in your testimony? Answer? Yes, question okay.
- 27:55And if you would take a look at I've marked
- 27:58the entries for Courtney Love. Take a look at that one.
- 28:02Answer all right, I see it. Question okay. And then
- 28:05if you look at the last entry, there's an entry
- 28:08for Professor Dershowitz. That's also circled. It should be on
- 28:11the flag. It's two sided. Answer yeah. Question do you
- 28:15see it? Answer? I see it? Question? And then also
- 28:20the other one I marked is Donald Trump? Answer? Yes,
- 28:23got it? I see those entries circled. Question? So am
- 28:27I right? I'm right? Am I not that among others
- 28:31circled our Courtney Love, Donald Trump, and Alan Dershowitz correct?
- 28:37Answer correct, among many others. Yes. Question, and they're all
- 28:41circled in the same way, are they not? Answer? Yeah,
- 28:44It's kind of a box, is what I would say
- 28:47some yes. Question, Is there anything on the face of
- 28:50that document that leads you to conclude that the circling,
- 28:53the significance of the circling, is any different for one
- 28:57person than another. Answer? No. Question. So, based on the document,
- 29:03do you infer that Courtney Love was involved in some
- 29:06kind of sexual abuse of miners? Answer? I would infer
- 29:10that if I were running a criminal investigation through the
- 29:13FBI and I'm trying to find people who would have
- 29:16relevant information, she would be one of the people that
- 29:19I talked to. I mean, the names that are circled here.
- 29:22Gleainne Maxwell, one of the identified traffickers. Epstein circled the pilot.
- 29:27One of the pilots is circled. So it's these people
- 29:31that all seem to be connected that are all being
- 29:34marked here. And the number of people that are circled
- 29:37is I would say, you know five to ten percent
- 29:40of the names Ballparking in the dark. Question do you
- 29:44know whether this address book was Jeffrey Epstein's address book
- 29:48or Glene Maxwell's address book? Answer? I'm not certain exactly
- 29:52whose book it is. I actually thought it was Alfredo
- 29:56Rodriguez maintaining a copy of records in case he was
- 29:59worth that Epstein might try to have him killed at
- 30:02some point, and so this was his insurance policy. I
- 30:05think he said against that happening. Mister Simpson, object to
- 30:10the non responsive portion of the answer. Question is the
- 30:15answer to my question, you don't know whether it was
- 30:17Jeffrey Epstein or Glenn Maxwell's address book? Answer? I don't know.
- 30:22And the reason I don't know is because actually I
- 30:25believe it's neither of theirs, that it's one of the other. Actually,
- 30:30I think it's a third possibility. I think that this
- 30:33was Alfred or rodriguez insurance policy against getting knocked off
- 30:37by Jeffrey Epstein. Question, So that's the view you have
- 30:42of the significance of the document. Answer? Yeah, in part,
- 30:46I mean there are other reasons it's significant, as we've
- 30:49been talking about names or circle to appear to have
- 30:52relevant information on Jeffrey Epstein's criminal activity. Question donald Trump
- 30:58was a friend of Jeffrey Epstein? Is that not correct? Answer?
- 31:03My understanding is yes, But I don't have a lot
- 31:05of information about Trump. Question it's true. Also, is it
- 31:10not that mister Trump was a frequent visitor to mister
- 31:13Epstein's address? Answer? I know that he visited frequent. I
- 31:18don't have a lot of information about Trump. Question and
- 31:21his name is circled in the book, is it not? Answer?
- 31:25I believe it is. Question based on him, assuming that
- 31:30he's a frequent visitor to mister Epstein's home, and that
- 31:33he's a friend of mister Epstein's, and that his name
- 31:36is circled in this book, do you infer that he
- 31:39was engaged in criminal sexual abuse of minors? McAuley, I'm
- 31:44willing to object to the extent that your answer would
- 31:47reveal anything that my client has told you. The witness No,
- 31:52mister Simpson, question, but based on your testimony previously, you
- 31:56would consider all of those facts to be evidence that
- 31:59he may have been. Answer, there are you know, certainly
- 32:03things that I would want to follow up on question
- 32:06and answer if I were running we were in the context.
- 32:12I take it of your question. You know, if somebody
- 32:14is running an investigation into an organization, he gets cut off. Question,
- 32:20did you, in the course of your representation of redacted
- 32:23or any of the other Jane Doe clients you have
- 32:26had who have had claims against mister Epstein, make any
- 32:29effort to find out whether mister Trump had abused any
- 32:33of them. Mister Edwards, I would just object to this
- 32:36being work product privilege as it relates to the other
- 32:39cases that I'm working on with Paul that Jack is
- 32:42not involved in, mister Simpson, Okay, Edwards, with respect to
- 32:47what we did during our investigation on behalf of other clients,
- 32:50Simpson okay, McCauley right, And I object on that extent
- 32:55and that it reveals anything you did on behalf of redacted.
- 32:59Mister Edwards, I don't think that Jack would know to
- 33:02object to this, but because I know of another case
- 33:05that we work on that's protected by our work product
- 33:08privilege who I talked to and who I did not
- 33:12scrolla In that case, I instruct you not to answer.
- 33:16Cassel all right, Simpson, all right, you're here, mister Edwards
- 33:20as a client, not an attorney. Correct, mister Edwards. Yes,
- 33:24that's my primary role in being here. But I'm going
- 33:27to protect the privilege to the extent that it's not
- 33:30being protected by others who don't recognize that the privilege
- 33:34needs to be protected on other matters. Mister Simpson, Okay.
- 33:38Question mister Cassel, as of December thirtieth, twenty fourteen, were
- 33:43you aware that Professor Dershowitz had visited mister Epstein's home
- 33:48and state as a guest for a week in the
- 33:50company of his grandchildren, among other family members. Answer, I'm sorry,
- 33:56which residents? Which Palm Beach residents? Question? Pombe answer can
- 34:02your estate question? Yes? Well, let me rephrase it. I'll
- 34:07be clear. Question were you aware as of December thirtieth,
- 34:11twenty fourteen. Let me back up a moment. You indicated
- 34:16yesterday that part of the basis for your conclusion that
- 34:19this pleading it was appropriate to file this pleading accusing
- 34:23Professor Dershowitz of misconduct was that he was a guest
- 34:27at the pom Beach House. Correct answer, No, it was
- 34:31more than that. He was a frequent guest, a frequent
- 34:34overnight guest. Question My question is, as of December thirtieth,
- 34:39twenty fourteen, were you aware that Professor Dershowitz had spent
- 34:44a week at the pom Beach House with family members,
- 34:47including his grandchildren. Answer no, question Okay. Do you think
- 34:51it's reasonable? Would it be reasonable to believe that someone
- 34:55who is committing criminal sexual abuse of minors at a
- 34:57home wears such abuse as as you understand it is
- 35:01a daily occurrence, would bring his grandchildren to stay for
- 35:04a week. Answer, It would depend on the circumstances. I mean,
- 35:09you know it would depend on circumstances. Scarrola. Are you
- 35:12representing that Jeffrey Epstein was there at the time, mister Simpson,
- 35:16I'm not answering questions, I'm asking questions. Scrolla. Oh okay,
- 35:22mister Simpson, So in your view, let me rephrase that
- 35:26you say it would depend on the circumstances. Answer sure, question,
- 35:31that's your answer? Answer yes, question okay, So that you
- 35:36don't find it odd that someone who knows that a
- 35:39particular home is a scene of ongoing criminal abuse of minors?
- 35:43And who himself has engaged in that criminal abuse would
- 35:46bring his grandchildren to stay there for a week. Answer?
- 35:50It would depend on the circumstances. Question And when you
- 35:53say that Professor Dershowitz was a regular guest at the mansion,
- 35:57at the Palm Beach House, it's correct? Is it not
- 36:00that you're referring to a period after redacted had left
- 36:03for Thailand? Answer no, question are you aware of any evidence?
- 36:10Let me back that up during the period that redacted
- 36:13contends she was sextually abused, which I understand to be
- 36:16middle of nineteen ninety nine to middle of two thousand
- 36:20and two. Is that consistent with your understanding? Answer approximately yes.
- 36:25Question How many times did Professor Dershowitz visit the Palm
- 36:29Beach mansion during that period? Answer? Am I understanding is
- 36:33in the neighborhood? What was it three to five times
- 36:36a year, staying two to three nights at a time.
- 36:40Question and was that your understanding as of December thirtieth,
- 36:43twenty fourteen. Answer yes. Question what was the basis for
- 36:49your understanding? What pieces? What documents or testimony? Answer right?
- 36:54The information you know? I gave a long presentation yesterday,
- 36:58so that was my information question. I want to focus
- 37:01now specifically. I'm not looking for a full answer on
- 37:05your entire views of the case. I just want to
- 37:08say you've testified that you understood as of December thirtieth,
- 37:12twenty fourteen, that Professor Dershowitz was a visitor at the
- 37:16Palm Beach mansion three to five times during this relevant
- 37:20period of ninety nine to the middle of two thousand
- 37:23and two. What was the basis on December thirtieth, twenty
- 37:27fourteen for just that fact? Answer right. I'll take about
- 37:32a minute here because there are a few things. He
- 37:35gets cut off by Simpson, Okay, and I want to
- 37:38make sure my question is clear. Answer. Sure question. I'm
- 37:42not asking you about any of your inferences about anything else.
- 37:46Just what's the basis for your belief that he visited
- 37:50three to five times during that two year period? SCROLLA,
- 37:54Could I ask for a clarification? Are you looking only
- 37:57for direct evidence and you want to exclude the circle
- 38:00substantial evidence? Is that the way you want to do this, Simpson?
- 38:04I'm asking you can object to the form. Simpson. My
- 38:07question is what was what were you? What did you
- 38:11have in mind in supporting your conclusion or belief that
- 38:15Professor Dershowitz visited three to five times during the relevant period. McCauley,
- 38:21and I'm sorry, Can I just place an objection on
- 38:23the record. I'm going to object to the extent that
- 38:27you do not have to reveal attorney client privilege communication
- 38:31unless it's something that's already public that she's revealed. Simpson. Okay, right,
- 38:37so I'm not going to just exclude. I take it
- 38:40your question isn't asking about communication question. My question is
- 38:45asking about that. But I understand you're going to refuse
- 38:48to provide it McCauley unless it's already public Cassell. Okay, So,
- 38:54as of December thirtieth, I'm going to exclude any communications
- 38:58from redacted from he gets cut off by SCROLLA, except
- 39:02to the extent that they have already been made public.
- 39:05That is, if she has given express permission to make disclosures.
- 39:09These were not confidential communications, but communications intended to be
- 39:14communicated to third parties, then you are permitted to include
- 39:18information from redacted in your response to that extent, mister Simpson,
- 39:23as of December thirtieth, twenty fourteen, any public statements by
- 39:27her after December thirtieth, twenty fourteen would not be included
- 39:32in the answer. Answer, okay McAuley, But let me be clear.
- 39:37Let me be clear about my objection to the extent
- 39:40that she revealed something to you in a non privileged context.
- 39:43In other words, information that was going to be disclosed,
- 39:47not for advice, but factual information that she intended to disclose.
- 39:52That's not privileged. But if it's something that she communicated
- 39:55to you in confidence with respect of getting legal advice,
- 39:59then that would be privileged. The witness, right, Okay, So
- 40:02wanna Lessi's deposition, Alfredo Rodriguez deposition, and then considerable circumstantial
- 40:08evidence which we don't have to rehash involving the close
- 40:12personal association between Epstein and Dershowitz. I mean again, we
- 40:17can rehash all of that, but those are the kind
- 40:21of the quick because I know you want to get
- 40:24a lot of questions. That's the quick sort of highlight.
- 40:28All right, folks, we're gonna wrap up right here, and
- 40:30in the next episode we're gonna pick up where we
- 40:32left off. All of the information that goes with this
- 40:35episode can be found in the description box.