648 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, DERSHOWITZ, Defendant. VIDEOTAPE CONTINUED DEPOSITION OF ALAN M. DERSHOWITZ VOLUME 5 Pages 648 through 781 Wednesday, January 13, 2016 9:04 a.m. - 11:59 a.m. Tripp Scott 110 Southeast 6th Street Fort Lauderdale, Florida Stenographically Reported By: Kimberly Fontalvo, RPR, CLR Realtime Systems Administrator www.phippsreporting.com (888) 811-3408 EFTA00602439

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APPEARANCES: ‘On behalf of Plaintiffs: SEARCY, DENNEY, SCAROLA BARNHART & SHIPLEY, P_A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33402-3626 BY: JACK SCAROLA, ESQ. jsx @searcylaw.com On behalf of Defendant: COLE, SCOTT & KISSANE, P.A. Dadeland Centre Il - Suite 1400 9150 South Dadeland Boulevard Miami, Florida 33156 BY: THOMAS EMERSON SCOTT, JR., ESQ. thomas.scot@ecsklegal.com BY: STEVEN SAFRA, ESQ. (Via phone) steven.safra@csklegal.com ~and-- SWEDER & ROSS, LLP 131 Oliver Street Boston, MA 02110 BY: KENNETH A SWEDER, ESQ. ksweder @sweder-ross.com ~and-- WILEY, REIN 17769 K Street NW Washington, DC 20006 BY: RICHARD A. SIMPSON, ESQ. RSimpson@wileyrein.com Examination Page VOLUME 5 (Pages 648 - 781) Certificate of Oath 778 Certificate of Reporter 719 Read and Sign Letter to Witness 780 Errata Sheet (forwarded upon execution) 781 PLAINTIFF EXHIBITS No. Page 25 Transcript from Don Lemon Interview 689 APPEARANCES (Continued): On behalf of Jeffrey Epstein: DARREN K. INDYKE, PLLC 575 Lexington Ave., 4th Fl. New York, New York BY: DARREN K. INDYKE, ESQ. (Via phone) On behalf of BOIES, SCHILLER & FLEXNER, LLP 401 E. Las Olas Blvd., Ste. 1200 Fort Lauderdale, Florida 33301 BY: SIGRID STONE MCCAWLEY, ESQ. smecawley @bsfllp.com ALSO PRESENT: Edward J. Pozzuoli, Special Master Sean D. Reyes, Utah Attomey General Office Marcy Martinez, Videographer Oa & wre NNNHAKHKRERRR RRB RRB VUbBwnr OCHUOBDARH SWHeH Ow ‘Thereupon, the proceedings continued at 9:04 a.m. VIDEOGRAPHER: Are now on the video record. This is the 13th day of January, 2016. The time is 9:04 a.m. This is the videotaped deposition of Alan Dershowitz in the matter of Bradley Edwards and Paul Cassell versus Alan Dershowitz. My name is Marcy Martinez. [| am the videographer representing Above & Beyond Reprographics. Will the attorneys please announce their appearances for the record. MR. EDWARDS: Sure. On behalf of the plaintiff today Brad Edwards, Jack Scarola, Brittany Henderson and Paul Cassell. MR. SIMPSON: On behalf of the defendant and the witness, Richard Simpson, and Thomas Scott will be joining. He just walked in. MS. McCAWLEY: On behalf of nonparty HE EE. Sissi MeCawicy and my colleague Meredith Schultz from Boies, Schiller & Flexner. MR. INDYKE: On behalf of Jeffrey Epstein, Darren Indyke. SPECIAL MASTER POZZUOLE: Ed Pozzuoli as the special master. 2 (Pages 649 to 652) www.phippsreporting.com (888) 811-3408 EFTA00602440

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653 MR. SIMPSON: Is there anyone else on the phone? MR. MAISEL: Yeah, this is Nicholas Maisel. THE COURT REPORTER: Would you raise your right hand, please? Do you swear or affirm that the testimony you are about to give will be the truth, the whole truth, and nothing but the truth? THE WITNESS: I do. MR. SCAROLA: Nick, would you announce the capacity in which you're appearing, please. MR. MAISEL: Special research assistant for Alan Dershowitz. MR. SCAROLA: Thank you. MR. EDWARDS: Are we ready? SPECIAL MASTER POZZUOLE: Go ahead. BY MR. EDWARDS: Q. Mr. Dershowitz, in January of 2015, when you made the statements that Paul Cassell and Brad Edwards participated in the fabricating of the allegations that were made against you, what information or evidence did you have in your Possession at that time to support those statements? MR. SIMPSON: Object to the form as overly Oa HH whe RNNAHNHKHRRFRERP RRR BRB BB VUebwnr OH MRAKRN SwWHH OW 655 And I knew, of course, that | had never met -- had no contact with I knew that she was lying. | read her deposition, and as an experienced lawyer with 50 years of experience, it was absolutely clear to me that no lay person with her lack of education could have written that deposition. I sought the advice of friends and others with experience who confirmed the view that that affidavit clearly had to have been written by lawyers and certainly drafted by lawyers: the level of detail, the structure of the sentences, all of which led me conclusively to the belief that the lawyers had written this affidavit. I suspected from the very beginning that this was part of an extortion plot in order to obtain money. | later learned many, many, many facts. MR. EDWARDS: | object and move to strike as nonresponsive and that the question calls for information in his possession in January of 2015. 1 would ask for a ruling on that. A. I'm providing that, but I'm giving the context. SPECIAL MASTER POZZUOLE: Denied. Move 654 general. You may answer. A. As soon as the allegations were made against me, I received a series of phone calls and people approached me at various events and they warned me about the reputation of Bradley Edwards. They told me that he had, in their view, participated in a major fraud with a man named Rothstein, that he should be in jail for the Rothstein events. I received a phone call saying that he had fabricated evidence when he was a prosecutor and that he had knowingly failed to investigate police fabrication of evidence in a case. Generally was warned about the terrible reputation that Mr. Edwards had. Talso received phone calls telling me that Mr. Cassell was a zealot, that he had used me in class as a Whipping -- as a kind of an object of hate and painted me as a liberal supporter of the exclusionary rule and opponent of the death penalty, and that he had no concem for the truth when it came to his zealotry on behalf of alleged victims. The calls were just -- the people who told me this were just -- there were so many of them that it was amazing to me. OAnM &wWwne NNNNNNP PEER Be ee UerWUnr OVD IYH HM &wWKHe Ow 656 forward. A. Okay. I knew that there was a financial motivation here. [ also knew that Cassell and Edwards had lied when they said they were representing in a pro bono basis. I had been informed repeatedly that they were in it for the money and that they expected to earn a lot of money from representing her and others in this case and that they pretended to be pro bono lawyers when they were, in fact, money-grubbing. money-hungry lawyers who had earned a very substantial amount of money already on these cases and were expecting to ear more money. Let me think of what other information | had. SPECIAL MASTER POZZUOLI: At the time of the question. A. Atthe time of my statements, right. It's just inconceivable to me that this uneducated woman could have come up with this story on her own. T understood the motives of the lawyers, and I was convinced, therefore, it was my opinion based on my experience, in fact, that she could not have done this by herself and that she had to have 3 (Pages 653 to 656) www.phippsreporting.com (888) 811-3408 EFTA00602441

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Orne ewne worked in coordination with ber lawyers. Her lawyers were also at that point claiming that the story should be believed because of who they were. Mr. Cassell, in my view, unethically signed his pleading with the University of Utah imprimatur, suggesting that he was a State actor, suggesting that he acted on behalf of his university, something I would never do and I've stopped clients from doing. When I represent people, I represent them on my own behalf, not on behalf of any university. The very fact that the Attorney General of Utah was here yesterday indicates that he may very well be a State actor and subject to the rules of State action rather than individual action. SPECIAL MASTER POZZUOLI: That portion I will strike. That sentence. A. Sorry. BY MR. EDWARDS: Q. Okay. A. I'mnot finished. SPECIAL MASTER POZZUOLI: Is there any other information that you haven't touched on - THE WITNESS: I'm trying to -- oe ee a ed WnNr Ow 659 no, no, no. No. Respond to the question that was answered and go ahead because I haven't heard any objection yet. MR. EDWARDS: I'm objecting to all of this as being nonresponsive to the question. SPECIAL MASTER POZZUOLI: Is there anything else that you would like to add to the answer? THE WITNESS: Yes. A. When the newspapers called me, they all asked me the following question -- SPECIAL MASTER POZZUOLI: Was this in January? A. This was in January. BY MR. EDWARDS: Q. The question on the table is -- SPECIAL MASTER POZZUOLI: Hang on one second. A. I'm going to tell you. MR. EDWARDS: What information that Mr. Dershowitz had in January 4, 2015, when he made the statement that Paul Cassell and Brad Edwards fabricated the allegations against him. MR. SIMPSON: The question was about in January of 2015. 658 SPECIAL MASTER POZZUOLE: -- as of, what, January? MR. EDWARDS: January of 2015. THE WITNESS: Oh, yes. MR. SCAROLA: January 4. MR. EDWARDS: January 4, 2015. A. Okay, that's the question. But, of course, | made a series of statements that continued beyond January 4, and they always took into account new developments and new information that | had. 1 was also aware that Mr. Cassell was promoting himself as a former federal judge and using his status and imprimatur in a false effort to try to add credibility to the story. And I did not make -- this is very important to this. I did not make a single call to a single newspaper or single television station, to my knowledge, or a single newspaper. | was constantly responding. MR. SCAROLA: That's not responsive. A. Excuse me. In the last deposition -- SPECIAL MASTER POZZUOLE: No, no. A. — there was an interruption by Mr. Scarola that I want to put on the record. SPECIAL MASTER POZZUOLE: No, no, no, no, OI neh &wne NNNNNNP PEE BB ee ee UerwWwnr O’DIYH HM &wWKHe Ow 660 SPECIAL MASTER POZZUOLI: That's what it was. That was the original question, which is why he was afforded a tremendous amount of latitude. MR. EDWARDS: Understood. A. And I got continuing information all through January and amended my statements as consistent with the information that I got. The newspapers called me. They all said to me, why would anybody make a false allegation if he's a former Federal judge, if he's a professor, if he's a distinguished trial lawyer? Clearly the -- on the 4th of December, talking about that day, that's the day on which Mr. Cassell wrote to ABC -- BY MR. EDWARDS: Q. January. A. January 4, 2015, that's the date on which Mr. Cassell wrote to ABC News asking them to publicize his client's story and to — and again making it clear to ABC who he was and what he -- and who he had been and what offices he had held. And so it was clear to me at that point, and through January it became clearer and clearer that she could not have done this on her own, that 4 (Pages 657 to 660) www.phippsreporting.com (888) 811-3408 EFTA00602442

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od nV ewne 661 she had to have sat with her lawyers and concocted this story, added the kind of detail to the story that would make a lie seem plausible and credible. And | think that any reasonable lawyer reading that affidavit would have come to exactly the same conclusion that I came to. SPECIAL MASTER POZZUOLI: Okay. BY MR. EDWARDS: Q. Mr. Dershowitz, when you first made the statement on January 4, 2015 that Mr. Cassell and Brad Edwards had participated in the fabrication of these allegations, did you have before you any affidavit or, as you have repeatedly called it, MR. SIMPSON: Object to the form. It's referring to a specific statement that has not been identified for the witness. A. Affidavit of [IP what 1 haa was the lawyers’ statements that were included in the Complaint, which they then sought to publicize all around the world and got more than a thousand newspupers to cover the story, every television station in the world, every radio station virtually in the world, based on what they themselves had written, actually gives me even a greater basis, MR. EDWARDS: Affidavit. A. —if [hadn't seen it at that point. I don't remember the exact day when her affidavit came in. I referred obviously to the pleadings. ‘That was the allegation, the allegation in the pleadings. So if [ said that you and Cassell sat and helped her make it up, it was based on -- at that point in time, based on you and her, primarily you and Cassell, because she didn't submit -- it wasn't an affidavit at that point. It was your words, you, that were accusing me of these heinous crimes without any basis. So I surely had a basis on January 4th of attributing it to you because it was your signature on the — SPECIAL MASTER POZZUOLI: Hold on a second. So I understand, the question is what did you have on January 4th — MR. EDWARDS: -- 2015 to support that statement. SPECIAL MASTER POZZUOLE: Just answer that question first and then you can explain, but - A. With due respect, Your Honor, [ think the question was, did you have the affidavit in front of you. because it wasn’t at that point based on her affidavit, it was based on whut the lawyers had said. MR. EDWARDS: I object. Can I have the question read back. I'm lost as to what the question is anymore. SPECIAL MASTER POZZUOLE: Ask — reread the question. COURT REPORTER: “Mr. Dershowitz, when you first made the statement on January 4, 2015 that Mr. Cassell and Brad Edwards had participated in the fabrication of these allegations, did you have before you any affidavit or, as you have repeatedly called it, deposition of | BY MR. EDWARDS: Q. Did you? SPECIAL MASTER POZZUOLE: So that’s the question. Answer that question only. MR. SCAROLA: Move to strike everything else he's said. A. On January 4th. to my memory, | did not refer to a deposition or to whatever other word you used -- what was the word? MR. SIMPSON: Affidavit. BY MR. EDWARDS: Q. Right. Okay. Did you have the affidavit or deposition of EE on that day? A. To my recollection, I did not. I had only your characterization of the accusation which you were making against me. Q. And in your experience as an attorney, isn't it common knowledge that attorneys drafting complaints or pleadings take the word of the client to form the basis of that Complaint or pleading? A. No, it's not common knowledge. It's common knowledge that uncthical lawyers of the kind that your reputation told me you were help the clients -- MR. EDWARDS: Lobject. Move to strike as nonresponsive. SPECIAL MASTER POZZUOLI: That, | am going to strike. Try -- try to answer the question. A. But I think the generic answer is cthical lawyers -- let me put it this way, ethical lawyers should not elaborate on what a client tells them in an affidavit. In my experience, there's a continuum. Many, many lawyers, when they see a statement by a client, they'll say, no, no, no, no, could you 5 (Pages 661 to 664) www.phippsreporting.com (888) 811-3408 EFTA00602443

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oan ewne 665 please elaborate on that. You say you had sex with him. Was it one time? Was it two times? Could it have been six times? Could it have been on the airplane? Could it have been -- et cetera. So I think it's a continuum of the way lawyers work with clients. The most ethical lawyers don't change what a client says. They word for word repeat what the client says. ‘The most unethical lawyers will put all of their own thoughts, words, ideas if it strengthens their position and strengthens their case. From what | had been -- from the information | knew at that time, I put you on the extreme unethical end of the continuum. SPECIAL MASTER POZZUOLE That wasn't the question, so | will strike the last sentence. We need to get focused on answering the question, so please try to do that. A. Okay, I will do that. BY MR. EDWARDS: Q. When you first made the statements that Paul Cassell and Brad Edwards fabricated the allegations — A. Would you read me the statement that you say | made on January 4th so I can understand what MR. INDYKE: Instruct Alan not to answer to the extent it would disclose communications of who made those — SPECIAL MASTER POZZUOLI: Objection noted. You can answer it- A. What framework are you giving me in terms of time? SPECIAL MASTER POZZUOLI: In January. BY MR. EDWARDS: Q. You told me that before you made these statements, one of the things that you had in your possession was a series of phone calls, a bunch of people called me" -- A. Thatis right. That's true. Q. -- "and told me Brad Edwards participated in major fraud with Rothstein.” That's the first question I want answered. What are the of those people? A. Anumber of them who called me were ones who volunteered -- MR. SCAROLA: That's not a response to the question. BY MR. EDWARDS: Q. What are the names? SPECIAL MASTER POZZUOLI: Stop, stop, 666 you're saying? Q. Do you deny making the statement that Brad Edwards and Paul Cassell fabricated the allegations against you? A. [remember making a series of statements over time. I do not remember what I said on January 4th. In order to ask me what I had at the time I made the statement, I need to know with precision the exact statement you are referring to and the exact date. I think that's a fair request. Q. We'll get that for you. It would be easier had you made less statements, but we'll sift through them. A. If would be easier if you had called —- MR. SIMPSON: There's no question. Object to the sidebar comments. SPECIAL MASTER POZZUOLI: Yes, let's -- BY MR. EDWARDS: Q. What are the names -- please list for me all of the names of the people who told you that -- in quotes -- Brad Edwards was -- participated in a major fraud with Rothstein. Names of people. MR. INDYKE: Objection based upon attomey-client, work product, common interest. SPECIAL MASTER POZZUOLI: Well, okay. please, please, please. A. I'm invoking the privilege, if you would allow me, please. A number of those who called me called me in tandem to volunteer to be my lawyer. Tl give you an example. SPECIAL MASTER POZZUOLI: No, no, hang on. A. Ican't name this person because he called to give me legal advice, and 1 — he gave me that information as part of his legal advice. BY MR. EDWARDS: Q. I'm not asking if one of the lawyers who represented you and you have an attorney-client privilege with has shared with you some information that they believe to be the case. I'm asking if you are using as support for your statement that certain people told you and you relied upon this -- and the particular "this" at this point is that Brad Edward participated in a major fraud with Scott Rothstein -- I want to know the names of those people that you are relying upon to test veracity of that statement, please. Names of people. A. One of the names was of a person who | was seeking legal representation from, and it was part of my conversation with him regarding legal 6 (Pages 665 to 668) www.phippsreporting.com (888) 811-3408 EFTA00602444

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Orne ewne representation. MR. SCAROLA: That's not a name. MR. EDWARDS: I'm sorry, | object and I ask — A. If 1 give you the name -- SPECIAL MASTER POZZUOLI: I do think you have to give the name. A. Okay. The name of that person would be David Markus. BY MR. EDWARDS: Q. Okay. A. And he told me to check the docket -- MR. SIMPSON: Just the question. BY MR. EDWARDS: Q. When did David Markus call you to tell you that he knew or believed that Brad Edwards participated in a major fraud with Rothstein? A. Within days. Within probably a day or two. Q. Did he tell you what it was that formed the basis for that statement that he made to you that you so relied upon? A. Idon't recall. Q. Was it more than the fact that your client, Jeffrey Epstein, had filed a lawsuit making MR. INDYKE: Same objection, same instruction. SPECIAL MASTER POZZUOLI: He's -- MR. EDWARDS: Calls for a yes or no. SPECIAL MASTER POZZUOLI: He's only asked if you aware that the case was dismissed at that time. A. Idon't think I was. But a case being dismissed does not mean the allegation isn't true. SPECIAL MASTER POZZUOLI: I understand, but -- BY MR. EDWARDS: Q. Okay. In addition to David Markus, can you please complete this list of people that you testified called you to tell you specifically that Brad Edwards participated in a major fraud with Rothstein? A. So, I spoke several times during that period of time at various events. And people — lawyers came over to me and told me -- Q. I'm not asking where. Who? What are the names? A. I can tell you one of them -- SPECIAL MASTER POZZUOLI: He's trying to be -- | would allow him to answer it. He's 670 those allegations? A. I don't think he was aware that Jeffrey Epstein had made an allegation of that kind. Q. At the time when David Markus called you to tell you that Brad Edwards participated in a major fraud with Rothstein, did you already — A. That's not -- Q. -- have or know that Scott Rothstein had testified under oath about that specific subject matter? A. Well, can't imagine that youre relying on Scott Rothstein's credibility. Q. I'm asking, did you know? MR. SIMPSON: Just answer the question. BY MR. EDWARDS: Q. Yes or no? SPECIAL MASTER POZZUOLI: Did you know? A. Idid not know. BY MR. EDWARDS: Q. Did you know at that point in time that the Complaint that was filed by your client, Jeffrey Epstein, against Brad Edwards, making those exact allegations, had been dismissed at the stage -- at the point in time when David Markus was making these statements to you that you so relied upon? trying to be responsive to the question. Please proceed. A. One of them was a former president or chairman or at least member of the Florida Bar committee who warned me about you. BY MR. EDWARDS: Q. Does he have a name? A. I don't remember his name. I don't remember his name, no. Of course he has a name, but 1 don't remember his name. Another was — I mean — just hard to Pinpoint names, but it was something that was clearly in my mind that so many people were telling me -- telling me to look into the case of Rothstein, telling me that you were his protege. Q. Okay. Is it true, then, that you have the name of one person who you can identify told you that Brad Edwards participated in a major fraud with Rothstein? A. Iwas also aware, of course, of the Complaint that had been filed against you. And that was one -- I mean, I can't comment on that because of lawyer-client privilege. SPECIAL MASTER POZZUOLE: Listen to the question, Professor. Go ahead. 7 (Pages 669 to 672) www.phippsreporting.com (888) 811-3408 EFTA00602445

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673 BY MR. EDWARDS: Q. Is it now your testimony that you can only provide me with one name of one human being that called you and told you Brad Edwards participated in a major fraud with Rothstein? A. I will try to think of others. Probably -- I may have some notes of others. I will call around and find out whether my memory is correct or not. MR. SIMPSON: Professor -- A. But I don't want to mention names without being sure. MR. SIMPSON: Just do you recall, as you sit here, the names? A. And right now, I don't recall names, other than a general discussion with my lawyers. And in the general discussion with my lawyers -- and I don't want to get into it -- SPECIAL MASTER POZZUOLE: Then don't do it. BY MR. EDWARDS: Q. Are you relying upon the statements from your lawyers to support this allegation that the basis of your statement that Brad Edwards participated in the fabrication of the allegations oe ee » ow MR. SIMPSON: He did not testify that he -- we went through long questions and answers in response to Mr. Edwards’ questions. He did not say he was relying on what his lawyers told him in this case. SPECIAL MASTER POZZUOLI: I think that there is — let me say this: I think the question was from Mr. Edwards whether he relied on statements from his lawyers. | do think that you have to answer that question. A. I would say that the statements from my lawyers played a small role. The larger role -- BY MR. EDWARDS: Q. I want to know about that small role. SPECIAL MASTER POZZUOLI: Hang on one second. So now proceed. BY MR. EDWARDS: Q. Sure. I would like to know whose statements it was that played a small role in your belief that Brad Edwards fabricated cases based on the statements that they made to you that Brad Edwards participated in a major fraud with Rothstein. What are the name of those individuals? A. It's a complicated question here. So there are three issues that | understand. One, what against you was a list of people told you Brad Edwards participated in a major fraud with Rothstein; and, if so, 1 want to know the names of those lawyers that you are using to support that allegation? MR. SIMPSON: Well, we have asserted privilege as to communications with those who represented you. Please don‘ disclose that. MR. SCAROLA: Respectfully -- pardon me — the witness is the possessor of that privilege. He cannot make a statement disclosing the content of the communications that he is relying on and then he himself assert a privilege to refuse to provide further information with regard to the statement that he has made. We would request a ruling on the record as to whether there has already been a waiver. A. What I said. of course, was that -- SPECIAL MASTER POZZUOLI: Excuse me. Hang on a second. MR. SCAROLA: Were requesting a ruling on the record as to whether there has been a waiver as a consequence of what has already been stated. 676 was the basis for my belief that you had fabricated along with Mr. Cassell — Q. No, I'm asking for names of human beings. SPECIAL MASTER POZZUOLI: No, let me stop you. My understanding of your testimony was that whatever you received — whatever information you received from your lawyers played a small role. That's what you testified to. THE WITNESS: That's right. SPECIAL MASTER POZZUOLI: Correctly, Mr. Edwards then followed up on that question and said, let's go into that small role. THE WITNESS: Okay. SPECIAL MASTER POZZUOLI: So now .. . BY MR. EDWARDS: Q. What are the names of those people that gave you this information that played a small role in -- A. In what? Q. -- in your belief that Brad Edwards had participated in a major fraud with Rothstein which somehow furthered your belief that Brad Edwards and Paul Cassell fabricated the allegations against you? So I'm asking for names of the people. 8 (Pages 673 to 676) www.phippsreporting.com (888) 811-3408 EFTA00602446

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od non hr wn ae 677 A. So my best recollection, and it's now over a year, is that that was a subject of conversation with David Markus. It was also the subject of conversation with -- MS. McCAWLEY: I'm sorry, I didn't hear that. If he's talking about conversations -- MR. EDWARDS: He said Davis Markus. MS. McCAWLEY: I'm sorry. I couldn't hear. A. Another lawyer -- other people sent me newspaper clippings. SPECIAL MASTER POZZUOLI: No, no, no. A. Lawyer. Okay. The other lawyer who told me about that was a lawyer named David Efron. MR. SCAROLA: First of all, make sure the list is complete, and then you want to know every one. BY MR. EDWARDS: Q. Is that it? David Markus, David Efron? A. Those are the two I remember offhand. Plus, as I said, when I spoke -- I spoke at several events in January -- Q. Right now -- A. —and lawyers came -- people — lawyers — orn &wne NNNNNNKHFPPBP HBB BB eee Ubr>WwUnr OUND AKDRU >wWN eH Ow 679 came over to me and told me -- he may have given me a card, which I conceivably may have at home, told me that he was a former official of the Florida Bar and was outraged at what had happened and told me to please look into your background and then told me about your background. Q. Dade Markus, is he a former student of yours? A. Yes, yes. Q. Did he have anything to do with the investigation into the -- Scott Rothstein or any of that? A. I don't know. Q. David Efron, did he have any inside personal information into who was or who was not culpable in any aspect of the fraud with Scott Rothstein? A. I don't know. MR. SCAROLA: You want to know exactly what they said. BY MR. EDWARDS: Q. Before we go to the next statement that apparently formed your basis for believing that Brad Edwards and Paul Cassell fabricated the allegations against you, can you tell me exactly 678 SPECIAL MASTER POZZUOLI: Let me stop you. BY MR. EDWARDS: Q. Let me get to the next question. A. Yes. SPECIAL MASTER POZZUOLE: Let me ask the witness, the question is limited to -- MR. EDWARDS: Yes, the lawyers who played asmuall role. SPECIAL MASTER POZZUOLE: The small role around the lawyers, and I think the followup question was, you've mentioned a second lawyer, is there anybody else on that list? BY MR. EDWARDS: Q. Yes. A. Two lawyers, yes. The lawyers who came over to me at the events that I spoke at- Q. What are their names? A. I don't know. Q. How do you know that they're lawyers? A. Because it was a lawyers’ event. And they were trial lawyers. This was all trial lawyers at the event. Florida trial lawyers. Q. You don't have the names of any of them; is that right? A. I can describe one of them as somebody who Ow~AnMewne RRNRNNKRKRE RE BEBR HBR BBB DeUN Pr OBO IAHR ae WKH Ow 680 word for word as you remember it what David Markus and then what David Efron told you —~ SPECIAL MASTER POZZUOLI: Let's start with the first one. BY MR. EDWARDS: Q. -- what David Markus told you about the participation of Brad Edwards in a fraud with Rothstein? MR. SIMPSON: We assert privilege to the extent that it's someone who he was getting legal advice from. SPECIAL MASTER POZZUOLI: I'm going to allow the question. You can answer over objection. A. All can tell you is what the total information I had at that point. I can't now, as I sit here, separate out what Markus said, what Efron said, what the lawyers who I met at the events said. I can give you a totality of what the conclusion was that was reached. Each of them contributed something. BY MR. EDWARDS: Q. Where were you when you received this communication from David Markus about his understanding or belief that Brad Edwards 9 (Pages 677 to 680) www.phippsreporting.com (888) 811-3408 EFTA00602447

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werIinnewne participated in a major fraud with Rothstein? A. In my apartment, | suspect. Q. Do you remember this? A. remember being in my apartment when the story broke and getting call after call after call from lawyers. Q. Was this a telephone call with David Markus -- A. Probably. Q. -- or an in-person meeting? A. It was -- well, [had both. I had both with him. I had a telephone call and then we had a mecting. Q. And in this, did he describe to you what support he had for this statement that he was making to you regarding the involvement of Brad Edwards in a major fraud with Rothstein? MR. SCOTT: Objection, work product on this whole line of questioning. He has the name. If we're going to go beyond this, we need a judicial ruling from the judge and you. SPECIAL MASTER POZZUOLE: Well, I'm going to allow the witness to answer it at this point and overrule the objection without prejudice. A. What is the question again? orn ewne vw ow the generalities, but I don't remember the particulars of that. I would be happy to try to refresh my recollection. MR. SCAROLA: We're going to take a short break. VIDEOGRAPHER: Going off the record. The time is 9:38 a.m. (Recess was held from 9:38 a.m. until 9:45 a.m.) VIDEOGRAPHER: Going back on the record. The time is 9:45 a.m. BY MR. EDWARDS: Q. Did David Markus say Brad Edwards participated in a major fraud with Rothstein? MR. SCOTT: Objection, work product and privileged. SPECIAL MASTER POZZUOLI: I'll overrule the objection. MR. SCOTT: I have a question. Are we taking the position that he has to answer the question now and pending an appeal to the judge? Is that what we're doing? SPECIAL MASTER POZZUOLI: Or -- I will reserve your right -- MR. SCOTT: Because you reserved on all their stuff yesterday. 682 SPECIAL MASTER POZZUOLE: Well, go back to the question. COURT REPORTER: “And in this, did he describe to you what support he had for this statement that he was making to you regarding the involvement of Brad Edwards in a major fraud with Rothstein?" A. I'm sure he told me some information involving his state of knowledge, but I can't separate out now what different people told me. All I remember is the totality of the conclusion that I reached based on what they told me. BY MR. EDWARDS: Q. What specifically did he tell you, if you remember? MR. SCOTT: Same objection standing. I just wanted to make sure we have a standing objection. SPECIAL MASTER POZZUOLE: I'll give you a standing objection. | understand that piece. If you don't remember, you don't remember or if you can't describe it, rather than going through again the generalities. so try to answer his specific question. A. Sure. Okay. The answer is 1 do remember OAnhM &wWne NNNNP PRP BEB BB eee WNHrF OWMIH HM &WNHer Ow 684 SPECIAL MASTER POZZUOLI: I will reserve on that, but I want him to answer the question at this point. I believe that at this point, given the inquiry and given the witness's answers previously, that they've opened the door, at least to this extent. But I will reserve, but I want him to answer. A. Iwill. Ido not recall precisely what David Markus or David Efron said. I do recall that they -- to the best of my recollection, that they both contributed to my general sense of what your reputation was. BY MR. EDWARDS: Q. I want to only stick with David Markus and then we'll move on to David Efron. A. Okay. Q. Allright. Did David Markus say anything along the lines of, close to, Brad Edwards participated in a major fraud with Rothstein? MR. SCOTT: Same objection. A. My best recollection is that he said something along those lines. He certainly said something that led me to that conclusion. BY MR. EDWARDS: Q. Did he tell you to look into a court file 10 (Pages 681 to 684) www.phippsreporting.com (888) 811-3408 EFTA00602448

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685 or did he tell you Brad Edwards participated in a major fraud with Rothstein? MR. SIMPSON: We have a continuing objection on this, and also object to the form of that one. SPECIAL MASTER POZZUOLE: Yeah, well, the form I'm not going to rule on, but the form is awkward, at best. MR. SIMPSON: We just want in the record we have a continuing objection. SPECIAL MASTER POZZUOLE: Yes. BY MR. EDWARDS: Q. I've heard two statements. One is that David Markus said to look into a court file. And the other I understood you to say is, David Markus told me Brad Edwards participated in a major fraud with Rothstein, which is what gave the support for the statement that | ultimately made about Brad Edwards participating in the fabrication of these allegations. So I'm trying to understand, did David Markus tell you that Brad Edwards participated in a major fraud with Rothstein? SPECIAL MASTER POZZUOLI: You have a continuing objection, but you can answer. 687 assistance and to tell me how outrageous he thought this was. And in the course of the conversation, he mentioned to me that I should be very careful about you, that you had this reputation, and then he told me some things about your reputation that helped form my general impression about who you were and what you would do. Q. With respect to the reputation of Brad Edwards, did he tell you anything beyond describing what he understood to be as facts related to the Scott Rothstein fraud? A. [think he -- others also told me that -- Q. I'm only talking about David Markus. A. Well, I can't separate out completely what David Markus told me and what others told me. 1 formed the holistic impression based on what a large number of people told me. That's the best I can do. Q. When was your first communication with David Markus? A. Oh, probably the day of the allegation or maybe the day after. But very, very soon thereafter. Q. Do you have journal entries indicating the telephone call that you had with David Markus? A. I don't journals entries of that kind, no. A. To the best of my recollection, it's more than a year ago now, he told me facts that led me to conclude that you had participated in a major fraud. He told me, for example, that what Brad Edwards — that what Rothstein was selling were fake Edwards cases made up by people who didn't exist. He told me -- | think it was he who told me, but I can't be sure, that you were a protege, that you had offices that were very close to each other, that the fraud was very similar to what was being alleged against me. That's, again, my best recollection of a conversation that occurred over a year ago. BY MR. EDWARDS: Q.. Did he tell you where he gathered that information that you just described to us? A. He did not. I think he — no, he did not tell me precisely where he got it from, no. Q. Did he share with you his own conclusion that Brad Edwards participated in a major fraud with Rothstein? A. I don't recall that. That's not the nature of the way a conversation happens. I wasn't cross examining him. He was calling me to offer his 688 Q. Do you have phone records that would serve as evidence of the telephone call between yourself and David Markus? A. I suspect -- he called me, I remember that for sure. He called me. Q. Do you have telephone records that support his call to you? A. I don't know if the telephone records show who called you. If they do, probably we do. Q. On the days that you claim that you met with David Markus, do you have journal entries or any other diary notation that would -- that would serve as evidence of such a meeting? A. Till check. [remember where we met. I don’t remember exactly when. And if I paid for it, I may have paid for it by credit card. I'll check. T'll be happy to do that. Q. Did you meet with David Markus before or after appearing on the Don Lemon show on January 5, 2015? A. Ithink I met with him before. I think I met with him before. I certainly communicated with him before. Q. Was it before your appearance on the Don Lemon show when David Markus provided you with 11 (Pages 685 to 688) www.phippsreporting.com (888) 811-3408 EFTA00602449

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OdAnoewWne 689 information that led you to conclude that Brad Edwards participated in a major fraud with Rothstein? A. I never said that publicly, of course, on Lemon or any of the other shows. So, you're asking me a compound question. Was it before I came to that conclusion that then contributed to my belief that you had worked -- that you had created false testimony? It did. MR. EDWARDS: What number exhibit are we up to? COURT REPORTER: Twenty-five. MR. EDWARDS: Twenty-five, okay. I'll go ahead and mark this transcript from the Don Lemon interview as 25. (Thereupon, marked as Plaintiff Exhibit 25.) BY MR. EDWARDS: Q. I'm going to show you the interview and particularly the bracketed paragraph. A. Sure. Q. Do you see the section that we bracketed there? A. Yeah. Yeah, let me just -- SPECIAL MASTER POZZUOLI: I'm going to Soak HM ewn ev BRR w nr ow 691 move to strike. SPECIAL MASTER POZZUOLI: Hang on. Motion to strike is granted. But here's the issue. Let him identify the document first and lay the predicate down and then go back into the document. I don't want to tell you how to do the deposition, but it makes it cleaner. So, Brad, please have him identify the document first and see what he knows about the document and then move forward. MR. SIMPSON: I think it's the portion of it you're asking about, that's what we're trying to identify. BY MR. EDWARDS: Q. Sure. Well, the first question has nothing do with the document. It is, did you appear on the Don Lemon show January 5, 20157 SPECIAL MASTER POZZUOLI: That's an casy question. A. Yes, yes. BY MR. EDWARDS: Q. Okay. In that interview -- can you identify the transcript that you're holding in your hand as a transcript of that interview? A. It seems like it is, yes. 690 look over your shoulder. THE WITNESS: Sure. BY MR. EDWARDS: Q. Is that a statement that you made on January 5, 2015? A. Let me read into the record what I said. Q. I'm asking right now is that a statement that you made? SPECIAL MASTER POZZUOLI: Which statement? BY MR. EDWARDS: Q. The statement that is bracketed. MR. SIMPSON: Can I object? The record doesn't reflect what that is, so the answer will be misleading. You can't ask about a statement that no one knows what it is. BY MR. EDWARDS: Q. You can read the statement into the record, but right now I'm just asking is that -- is that an accurate transcript of your statement that you're holding in your hand? MR. SIMPSON: Object to the form. A. Let me respond to that. Yesterday you read transcripts, and it turned out you left out absolutely critical exculpatory — MR. EDWARDS: Objection, nonresponsive. OA neh &wWwne 692 Q. Okay. And does it seem to accurately have transcribed, to the best of your memory, that interview that you had with Don Lemon? MR. SIMPSON: Object to the form. AL Yes. BY MR. EDWARDS: Q. Can you read for us the portions that are bracketed? A. No, because they're out of context. I refuse to do that. That's what happened yesterday, and you totally read it out of context. I will read it for you in context. I will read the question that was asked me and I will read the entire answer, but I won't read your selected excerpts which mislead everybody in this transcript. No, I won't do that. Q. Okay. A. Because that would be a lie, and I'm under oath. So I'll be happy to read the entire thing. MR. SCOTT: Seems like a fair request. MR. EDWARDS: If we're going to read entire transcripts, not just the defamatory remarks, we're going to be here all day. A. We have time. The truth takes time and in full context. 12 (Pages 689 to 692) www.phippsreporting.com (888) 811-3408 EFTA00602450

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wermIinnewne SPECIAL MASTER POZZUOLE: Okay. MR. SIMPSON: Wait for a question, please. SPECIAL MASTER POZZUOLE: I believe it's fair for the question starting -- the question that starts right above the bracketed where Mr. Lemon asks, "So why are you being targeted? As you mentioned the lawyers, why would someone target you, Alan Dershowitz, with these very serious allegations?" And then from there down, you don't need to read the whole thing, but I think you'll get your point across that way. MR. EDWARDS: Okay. SPECIAL MASTER POZZUOLE: That standpoint would provide some level of context. A. "Don Lemon: So, why are you being targeted? As you mentioned the lawyers, why would someone target you, Alan Dershowitz, with these very serious allegations?" My response: “Well, I fit beautifully into the profile because they want to be able to challenge the plea agreement, and I was one of the lawyers who organized the plea agreement. | got the very good deal for Jeffrey Epstein. I plead guilty to getting him a good deal. That's my job. And if A. I think he called me the day of the event, the day the story was in the newspapers. Q. Would you have calendar entries or telephone records to support the date of that call? A. Idon't know about telephone records. I don't have a calendar entry. Q. Did you meet with David Efron in person or only by telephone? A. Idid. I met with him in person. Q. And what did -- or did David Efron say Brad Edwards participated in a major fraud with Scott Rothstein? A. Again, I can only say that he gave me facts and statements that led me to that conclusion, which I stated in the interview, namely that Rothstein had sold Epstein cases, and that Edwards was his partner, and that his reputation was not good in the community. Q. Did David Efron provide you with the support for his alleged conclusion that Brad Edwards’ reputation is not good? MR. SIMPSON: Object to the form. Do we have the continuing objection, sir? SPECIAL MASTER POZZUOLI: Yes, continuing objection. 694 they can find a lawyer who helped draft the agreement who was also a criminal having sex, wow, that could help them blow up the agreement. So they sat down together, the three of them, these two sleazy, unprofessional, disbarrable lawyers, Paul Cassell, a former federal judge and current professor, and another sleazy lawyer from Florida, Brad Edwards, whose partner is in jail for 50 years to trying to sell Epstein cases fraudulently, they sat down together and they said, who would fit into this description, a lawyer who knows Epstein who helped draft, ha, Dershowitz. So they and the woman got together and contrived and made this up.” ‘That is a truthful statement, and | stand by it. SPECIAL MASTER POZZUOLI: Okay. BY MR. EDWARDS: Q. In January -- on January 5, 2015, when you made the statement that Brad Edwards and Paul Cassell sat down with the woman together and contrived and made this up, had you already spoken with David Efron? A. Yes. Q. Okay. What is the date when you spoke to David Efron? a oe ee NRNNHAKHKRERRPR RRB RBBB VUbwnr OCHUBDARH SWHeH Ow MR. SIMPSON: Thank you. A. [think he — I think he cither brought me or told me about some newspaper articles, which | then read and formed my own conclusion. And he also -- BY MR. EDWARDS: Q. Which newspaper articles did David Efron provide you? A. Idon't remember. But I -- at that point in time, | was not reading the local newspapers, and apparently there was some large coverage of the Rothstein matter. I didn't really know about the Rothstein matter much at all. But when my accusation occurred, | got lots and lots of calls from people telling me about the Rothstein matter and giving me all kinds of information about it. Q. Wasn't it within the context of what you're now describing the Rothstein matter that Jack Scarola attempted to depose you in 2011? A. Idon't recall whether that was the Rothstein matter. But I wasn't following it. Q. When you communicated with Mr. Scarola about whether or not you could be subject or would be subject to deposition, are you saying that you 13 (Pages 693 to 696) www.phippsreporting.com (888) 811-3408 EFTA00602451

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oa ewne 697 had no idea which case -- that the case in which you were being asked for deposition? A. I wasn't following that case. | was only interested in the fact that I was being asked to be deposed on, A, lawyer-client privileged information or, B, facts that weren't true; namely an allegation that I had observed young women in the presence of Jeffrey Epstein. | didn't focus on the nature of the case at all. Q. So did David Efron provide you with newspaper articles about the Rothstein matter or did he say Brad Edwards participated in a major fraud with Rothstein? MR. SIMPSON: Object to the form and -- object to the form. SPECIAL MASTER POZZUOLE: I'm not ruling on the -- those are -- those are reserved for later. But | mean -- you should try to ask one question and give him one question at a time and break that up. BY MR. EDWARDS: Q. Did David Efron do anything more than provide you with newspaper articles on the Rothstein matter? A. Yes. oe ee NNNNNNP KP BP BBB eB ee UeWUNnrF OwOAIHD He Wn Ow instruction. A. Yeah, I mean, obviously -- SPECIAL MASTER POZZUOLI: Short of that. A. I'm not the talking about material, much of which I got from lawyer-client privileged information. But I can't talk about that. So I will talk about another person called me, I don't remember the date, who had sued you, because he said you had —- BY MR. EDWARDS: Q. Wait. We haven't left the Rothstein matter yet we're going to move to that -- A. He told me about the Rothstein matter. Q. Oh, really? Okay. A. Yeah. So he called me and he said, be very careful about this sleazy guy Rothstein [sic], he was sleazy when he represented me, he helped fake evidence, he helped doctor a tape, he was sued, it was dismissed on prosecutorial privilege, but not on the merits. And he was also involved in the Rothstein, and he just gave me also general information about the Rothstein matter, which many, many people gave me. That — you are burdened with that as part of your reputation, for better or worse. Q. Okay. What specifically did he do in addition to providing you with -- do or say in addition to providing you with newspaper articles about the Rothstein matter? A. To the best of my recollection, this is a year-old conversation, he told me that you were all tied up in the Rothstein matter, that this was -~ involved your whole firm, that you were a protege of his, and that the firm was selling Epstein cases and defrauding lots and lots of people. That's the general thrust of what he told me. Q. Just so I'm clear, did he -- are you saying he shared with you his conclusion that Brad Edwards was involved in the Rothstein fraud? MR. SIMPSON: Object to the form. A. IT wouldn't use the term “conclusion.” That's not the way conversations occur. He gave me facts from which I drew my own conclusion. BY MR. EDWARDS: Q. Is there anyone else whose name you can provide us today in addition to David Markus and David Efron that provided you information from which you concluded that Brad Edwards participated in a major fraud with Rothstein? MR. INDYKE: Same objection, same Q. I just want the names of the people who gave it to you. That's all I'm asking. A. I don't remember his name, but you would know his name, the man who sued you. Q. Okay. What facts specifically were you given or were given to you by David Markus or David Efron or anyone else regarding Brad Edwards participating in a major fraud with Rothstein? A. I would like to answer that question. MR. INDYKE: Same objection, same instruction. SPECIAL MASTER POZZUOLI: Let me stop for asecond. You can answer it, but I think we've plowed this ground some. So go ahead. A. Let me answer it. I was told that you were his protege, that you were Rothstein's protege. ‘That the two of you were essentially joined at the hip, or were inseparable. That you had offices near each other. That Rothstein didn’t do anything without conferring with you. That you were "the brains of the operation,” he was the rainmaker, you were the brains of the operation. 1 was told that the case for which he went to jail for 50-something years involved Epstein. That you had kind of jointly worked on Epstein 14 (Pages 697 to 700) www.phippsreporting.com (888) 811-3408 EFTA00602452

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Od nM e&wWne matters. That I was -- let me see what else. ‘That's the thrust of it. That was the thrust of it. BY MR. EDWARDS: Q. Who told you that Scott Rothstein and Brad Edwards were “joined at the hip"? A. [heard that probably from more than one person. Q. Then give me more than one person's name. That's fine. A. I don't remember specifically who told me that, but that certainly came out of my conversations with the various lawyers, that you were very close. Q. Were you aware of my deposition being taken in Mr. Scarola's office on the subject matter of the Jeffrey Epstein suit against me and my countersuit that related to the Rothstein matter you're referring to? MR. INDYKE: Same objection, same instruction. SPECIAL MASTER POZZUOLI: Well, short of that objection, I didn't -- I didn't understand the question. MR. EDWARDS: I'm -- SPECIAL MASTER POZZUOLI: If you Oa HH ewn NNNRRFRFRP RRR BRB BR NDP OW’ DARN SD WHeH Ow testified in your deposition? Q. No, I'm asking you. A. [certainly have absolutely no memory of that. Where would that have been? When would it have been? Q. Just answer, were you sitting at the table? A. [have no memory of that whatsoever. Q. Okay. Okay. Who told you that -- A. But if I was -- Q. -- Scott Rothstein -- A. — I would like to see the transcript. SPECIAL MASTER POZZUOLE: Hang on a second. BY MR. EDWARDS: Q. Who told you that Scott Rothstein didn't do anything without conferring with Brad Edwards? A. Uheard that routinely from a number of people, that you were his brains. Q. Can you please provide the names of those number of people that told you that Scott Rothstein did not do anything without me? A. That would require going into privilege. MR. SCAROLA: We would like a ruling on whether there has been a waiver with respect to understood it, you can answer. But I didn't understand the question. MR. SIMPSON: Object to the form. Nor did 1. BY MR. EDWARDS: Q. So you testified that you were not really aware of the Rothstein matter; is that right? A. Yes. Q. And my question is, when my deposition was taken in that matter, were you aware of the fact that my deposition was taken? A. I think so. I think I was, yes. Q. And how were you aware of the fact that my deposition was taken? MR. INDYKE: Same objection, same instruction. BY MR. EDWARDS: Q. And were you aware of the testimony that I provided at that deposition? A. Not the details of it, certainly. Q. Weren't you sitting at the table as I testified for my deposition? A. No. Q. You weren't? A. I was sitting at the table when you that privilege as a consequence of having disclosed the content of this information. MR. INDYKE: If Mr. Dershowitz is referring to Mr. Epstein, then I would object to-- SPECIAL MASTER POZZUOLI: Did you get that? COURT REPORTER: No. SPECIAL MASTER POZZUOLI: Can you repeat the -- | want to make sure that we get the record clear. Go ahead and repeat your objection on the phone, Darren. MR. INDYKE: If Mr. Dershowitz, by referring to privilege, is referring to anything that he may have learned through his representation of Mr. Epstein or through a common interest agreement with Mr. Epstein, then I would object to disclosure of the contents. MR. SCOTT: We also object on work product because this is whole new area now, and | don't think there's been any waiver. SPECIAL MASTER POZZUOLI: Well, I'm going reserve, consistent with yesterday's rulings, 15 (Pages 701 to 704) www.phippsreporting.com (888) 811-3408 EFTA00602453

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ana nue wn e that we will protect the privilege for now and we'll reserve for a later fuller discussion on this. So we'll mark this and we'll move MR. EDWARDS: Okay. BY MR. EDWARDS: Q. At the time when you were told that Scott Rothstein did not do anything without conferring with Brad Edwards, were you representing Jeffrey Epstein? A. Yes. Q. What were the circumstances of your learning that information that Scott Rothstein did not do anything without conferring with Brad Edwards? MR. INDYKE: Same objection, same instruction. SPECIAL MASTER POZZUOLE: If you can answer outside the privilege. A. There's nothing outside of the privilege. SPECIAL MASTER POZZUOLE: So I would say the following: I'm going to, for now, grant the objection, consistent with yesterday, and I think we need to either -- whether it’s in front of me or in front of Judge Lynch, fully was told. But I was told that by a number of people -- Q. Did - A. —using different phrases. Q. Can you provide me the name of the number of people that are outside of any of the common interest or attorney-client privilege that told you Brad Edwards was the brains behind the Scott Rothstein operation? A. I can't give you a name of somebody who said those precise words outside the privilege. Q. Can you give me the name of somebody who said words similar to that effect outside the privilege? A. As Isit here now, I cannot. But I will try to refresh my recollection. Q. Okay. You also testified that you spoke with somebody that told you Brad Edwards fabricated evidence as a prosecutor. A. That's right. That's right Q. What is the name of that person that told you that information? A. You know that. I don't. As I'm sitting here today, | have no memory. But we can get that for you. You, of course, know the name. 706 explore the timing of what -- the timing of when -- the timetable you're inquiring relative to his representation and the scope of that representation to best determine whether there was a privilege and if it exists. So for now -- MR. INDYKE: I'm sorry, Your Honor, just for the record, as well as any kind of common interest agreement as well. SPECIAL MASTER POZZUOLI: Fine. BY MR. EDWARDS: Q. The last statement that you testified you were told was that Brad Edwards was the brains behind the Scott Rothstein operation. A. That's right. Q. Who outside of the privilege that you have with Jeffrey Epstein told you that information? A. Well, outside the privilege and outside of common interest privilege and joint defense privilege. Q. Outside of the privileges -- A. All those three privileges. Q. Yes. A. Idon't have any distinct -- I can't separate out necessarily the sources of everything I 708 Q. Why do you say that I know the name? A. Because he sued you. SPECIAL MASTER POZZUOLI: This is not — Mr. Dershowitz, answer the question that's been asked and let's not have crosstalk. A. Ido not know the name. BY MR. EDWARDS: Q. Atour next break, can you get us the name of this individual? A. Twill try. Twill try. Q. When did you have a conversation with this individual that told that you Brad Edwards fabricated evidence as a prosecutor? A. Shortly after the allegations in my case, he called me. Q. Did you meet with this person? A. Idid not. But -- I did not. Q. Did you attempt to ascertain the truthfulness -- AL Yes. Q. -- of this -- MR. SCOTT: Listen to the question. SPECIAL MASTER POZZUOLI: Listen to the question. 16 (Pages 705 to 708) www.phippsreporting.com (888) 811-3408 EFTA00602454

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BY MR. EDWARDS: Q. - of this individual's statements that Brad Edwards fabricated evidence as a prosecutor? A. Idid. Q. What did you do to -- A. I-- Q. What did you do to ascertain the truthfulness of this gentleman's statements that Brad Edwards fabricated evidence as a prosecutor? A. Lobtained all of the pleadings that I could in the case, including the tampered videotape. [ obtained the expert analysis of the videotape. I think I personally viewed the videotape. It was a jail videotape. And I came to my own independent conclusion that the videotape had been tampered with, that the defendant had been denied his due process nights, and that he would have prevailed in that lawsuit but for prosecutorial immunity. MR. SCAROLA: Could we inquire as to whether these materials that Mr. Dershowitz contends he relied upon have been disclosed in discovery in this case in response to production requests that clearly would have called for that production? 711 Brad Edwards. | don't -- I didn’t focus on any other people who might have been sued. But I did focus on Brad Edwards and I did get the pleadings, and last year early in the year I read them. I - my research assistant went through all the pleadings. Either he or | or both of us viewed the videotape together. He wrote me some note about it. And | came to the conclusion that the lawsuit was a very valid one. Q. Was that note that you just described a part of that conclusion that you reached? A. No, the note was probably just, here is the video, here is this, here is that. It was just -- my recollection of the note, it was just an inventory of some kind. Q. Did you read the jury trial transcript from the criminal case you're referring to? A. Well, the civil case had no jury, had no trial. It was dismissed. The criminal case, I don't remember if I read the jury trial or if my research assistant did or -- [ just don’t remember that. I do remember reading the pleadings, which included excerpts from the trial. Q. Did you read any of the transcripts from the testimony regarding that defendant's motion for ermIinne wne ed SWNF OW @® ARH SWNHHO MR. SIMPSON: I don't -- I will answer that question at a break. I'm not agreeing whether it's called for or not called, but I don't have a microscopic memory of everything that's been produced in the case. But certainly if it was called for and it was responsive, it was cither produced or is on a privilege log. SPECIAL MASTER POZZUOLE: Let's deal with that at break between you guys. Go ahead. BY MR. EDWARDS: Q.. Is the person you are referring to Donald Baker? A. I don't have his name in my mind, but 1 can find that out. Q. Is this the lawsuit where the person sued Michael Satz, Judge Micheal Gates, the entire Hollywood Police Department, and in that list of defendants included the prosecutors of the case, which was Brad Edwards and some other prosecutor I don't remember the name? A. That's not my recollection. Q. Is your recollection that this is a lawsuit that was filed against Brad Edwards alone? A. My focus was on the lawsuit filed against 712 ineffective assistance of counsel? A. No, not that I can recall. Q. Did you read any of the transcripts from the hearing on that defendant's complaints about misconduct on behalf of the City of Hollywood Police Department or any others? A. Idid - Ido remember reading about the fact that the actual physical tampering was done by the Hollywood Police Department. But the allegation, to my best of my memory, it's been a Jong time now, was that you covered it up or played a role in it. Q. Did you review the criminal record of this individual that provided you with the information that Brad Edwards fabricated evidence as a prosecutor? A. I don't remember reviewing his criminal record. I do recall that the crime itself — no, I just -- I don't remember reviewing his criminal record. I may very well have, but I don't remember it now. Q. When you say you do remember reviewing the crime itself, the crime was a battery on a law enforcement officer. Is that what you remember? A. My recollection is that in the course of 17 (Pages 709 to 712) www.phippsreporting.com (888) 811-3408 EFTA00602455

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Od noewWwne 713 being arrested, he was accused of resisting arrest. That's my best recollection. I may have that wrong. And that he complained that they cut off -- that he was assaulted and he was only defending himself, and that they cut off the video at the point that would show the complete context. That's my best recollection. And it’s, again, a long time ago. Q. Did you or your representative initiate the contact with this individual who -- A. No. Q. -- claimed that Brad Edwards fabricated evidence as a prosecutor? A. No, no. To my knowledge and my recollection, he initiated the contact. Q. Is this -- did this individual's criminal record include a first-degree murder conviction? A. Certainly I was not aware of that, if it did. Q. Did -- in your review of this record -- A. I would find that hard to believe. SPECIAL MASTER POZZUOLI: Listen. A. He was out on the street when he called me. BY MR. EDWARDS: Q. Do you remember whether or not this 715 this gentleman was sentenced to prison after the jury verdict finding him guilty of battery on a law enforcement officer? A. My recollection is that he was offered a plea if he would withdraw his lawsuit, and that he refused to withdraw his lawsuit. | think that was part of his Complaint, that he was coerced, that there was an effort to try to coerce him into pleading guilty. But, again, these were all matters of record, and it's a year ago, so my recollection is not as clear. Q. What documents do you have to support that this gentleman was offered a plea in exchange for him agreeing to withdraw a lawsuit? A. That was my memory. Q. In order for that to be the case, wouldn't you agree that his lawsuit must have preceded his jury trial in order for your logic to be correct? A. Of course not. Of course not, no. Why would that be? A lawsuit almost certainly -- he may have threatened a lawsuit previously and it was part of a -- my understanding, again, it's long time ago, was that there was -- there were plea bargaining efforts after he was convicted and that there were -- this is just my memory of a long time ago -- defendant was sentenced to prison after his conviction? A. I'mconfused. Is the conviction you're referring to after the events at issue? Q. The conviction of battery on a law enforcement officer, the case I prosecuted. A. Did that take place before or after his alleged conviction on a murder charge? Q. Well after. A. So, what you're asking me, if I knew about a prior earlier first-degree murder conviction? Q. Sure. My first question is, did you know about a prior earlier first-degree murder conviction of this person whose word you're accepting that Brad Edwards fabricated evidence as a prosecutor? Did you know about that? A. I was not accepting his word. I'm aware of how to be skeptical about words. I did an independent evaluation of the evidence, then came to my conclusion. Q. Were you aware of this gentleman's prior murder conviction? A. I'm not aware of it as I sit here now, no. I don't think I was. Q. Are you aware as you sit here now whether 716 that the -- that they would give him a consideration in sentencing if he didn't go through with his threat to bring a lawsuit. That was my recollection. Q. In addition to talking to this particular individual who told you that Brad Edwards fabricated evidence as a prosecutor -- A. Right, or participated in the fabrication. Q. -- did you speak to anyone else that was a representative of his or his attorneys that corroborated that allegation? A. Representative of his? Q. Anybody other than — SPECIAL MASTER POZZUOLI: That's the question, yes. A. Not to my recollection, no. BY MR. EDWARDS: Q. Have you -— has anyone other than this particular person you have identified told you that Brad Edwards fabricated evidence as a prosecutor? A. That's a conclusion -- first of all, 1 never, as far as | remember, never publicly stated that. I've told you that that was part of what went into my conclusion about your reputation and record and background. 18 (Pages 713 to 716) www.phippsreporting.com (888) 811-3408 EFTA00602456

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werIinnewne But the question again? Q. Right. A person's name. Tell me what other -- what other individual, if anyone, has ever told you Brad Edwards fabricated evidence as a prosecutor. A. Idid not rely on his statement to me of that. I did my own research, came to my own conclusion about the facts based on my review of the — MR. EDWARDS: Object. Move to strike as Nonresponsive. SPECIAL MASTER POZZUOLE: Stay focused on the question being asked. A. No other name -- no other person told me that. I did it on the basis of my own research. BY MR. EDWARDS: Q. Can you tell me the names of all of the individuals that told you Brad Edwards has a terrible reputation? MR. INDYKE: Objection. Same objection. BY MR. EDWARDS: Q. Outside of the attorney-client privilege, the joint defense privilege and any other privileges that you maintain with Jeffrey Epstein, Ghislaine Maxwell or anyone else a part of that agreement. no to a question that clearly can be answered with a “yes” or "no" or "I dont remember"? SPECIAL MASTER POZZUOLI: Before anybody objects to his answer, let's see what he says. Go ahead, and then we'll work backwards. A. What's the question again? Just repeat — BY MR. EDWARDS: Q. Sure. Did you attempt to contact Brad Edwards or any representative of Brad Edwards to talk to him about any allegation of misconduct on his part before you relied on those allegations from these individuals you have identified? SPECIAL MASTER POZZUOLI: So, I've heard the question. I do think that it's either yes or no, and I'm going to allow you full latitude to explain. So please proceed in that manner. A. It's no with an explanation. SPECIAL MASTER POZZUOLI: Go ahead. A. Because I was not making these allegations public, as you made your allegations against me public without calling me, because I was not making these allegations public, because I was only using them as part of my own internal work product, my own internal dynamic, my own thinking process, 1 didn't think it was necessary for me to call you and ask 718 MR. SIMPSON: Object to the form as becoming very redundant. SPECIAL MASTER POZZUOLI: You can answer. A. Several people who came to me at these Bar meetings told me that, and I just heard it from many, many people who called me. BY MR. EDWARDS: Q. Okay. I'm -- A. But I'm having difficulty coming up with a specific name. | will check to see if I have any notes. Q. I just want the list of those many, many people in response to this question that told you Brad Edwards has a terrible reputation. A. Okay. And I right now, cannot name any person other than the information that I have already provided you. Q. Did you ever attempt to contact Brad Edwards or any representative of Brad Edwards to talk to him about any allegation of misconduct on his part before you relied on these allegations you received? A. This will require — I can't do this yes orno. [can only do this with an explanation. MR. SCAROLA: Could we start with a yes or you about it. And so I did not. BY MR. EDWARDS: Q. Did you attempt to contact Brad Edwards or any agent of Brad Edwards to talk to him before making the allegation that "Brad Edwards and Paul Cassell and sat down together, the three of them, these two sleazy, unprofessional, disbarrable lawyers, they and the woman got together and contrived and made this up"? AL Well -- Q. Yes or no? A. The answer to that is with Brad Edwards, no. With Cassell, it would be a different answer if you want to ask me about that. Q. Allright. Okay. Prior to January 5, 2015, making the statement that they, Brad Edwards and Paul Cassell, and the woman got together and contrived and made this up, did you contact Paul Cassell? A. [tried to reach out to Paul Cassell through a number of mutual acquaintances, and was told that he had no interest in having any conversation with me. Q. Tell me the date that you first reached out to Paul Cassell through anyone. 19 (Pages 717 to 720) www.phippsreporting.com (888) 811-3408 EFTA00602457

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OI neh &Wne A. I don't recall the date. Q. Is it your testimony that the date you tried to reach out to Paul Cassell preceded January 5, 2015, when you made the statement that Brad Edwards and Paul Cassell and this woman got together and contrived and made this up? A. That will require a “no” answer and an explanation. Okay. The explanation is that before you made your false allegation against me, you had months and months and months to reach out and do all the checking. I was in an emergency situation. | was getting calls, probably a hundred a day, from every media in the world asking me to respond immediately. And I had to respond at that point based on the best information I had available to me. | could not hire an investigator. [ could not conduct a massive research operation. [ was being accused of the most heinous crime imaginable, absolutely falsely, and I had to respond immediately. And my response was based on my state of knowledge, my opinion, my professional opinion, and I gave those at the time because I had to give a response immediately. I couldn't say "no comment.” I couldn't say, “I refuse to answer." Others have under seal. And our position is that the individuals who need to be present at that deposition are the parties in this case, so the actual - Brad and Paul, their lawyers, and Mr. Dershowitz and his lawyers. No other individuals; for example, Mr. Dershowitz's wife or anybody else can be present at that deposition. It's a deposition of who we contend is a sex abuse victim. It should be closed and sealed, and nobody else should be present. SPECIAL MASTER POZZUOLI: Do you not want me there? MS. McCAWLEY: I do want you there. MR. SIMPSON: Our position is that Professor Dershowitz's wife should be permitted to attend. They're married. She'll agree to whatever confidentiality. She's worked with him on the case as a paralegal. She's entitled to be there. We have advised -- and I don't know if Darren is still on the line -- counsel for Mr. Epstein that it’s confidential and that non-parties are not permitted to attend, per done that. I was totally, totally innocent. And I had to respond immediately to these false charges, which is what I did. Ineed to take a break. MR. SCOTT: Take recess for a couple of minutes, SPECIAL MASTER POZZUOLI: Let's take a ten-minute break. Lawyers, can you stay for just a second. I want to deal with a secondary matter dealing with a deposition on Saturday. VIDEOGRAPHER: Going off the record. The time is 10:32 a.m. (Discussion held off video record only as follows:) SPECIAL MASTER POZZUOLI: We are off the video, but I wanted to have this on the record. I've reviewed the confidentiality order that's pending that was issued by Judge Lynch, and I just want to be clear as we head into the deposition on Saturday as to get the party's view as to who should be in attendance at that deposition. So, Ms. McCawley, why don't you start. MS. McCAWLEY: Sure. Sure. The deposition is a confidential deposition that is going to be held under seal. It will be filed Od neh &wWwne NNNNNNRHP BBE Be eee UeWUNrF OVBMIKDRH &WNHe Ow 724 Ms. McCawley's position that it's between those folks if they disagree about that. But as to Mrs. Cohen, we're adamant she has a right to be there and there's no legitimate basis for excluding her. SPECIAL MASTER POZZUOLI: Hang on one second. Anything else? MR. SCOTT: No. SPECIAL MASTER POZZUOLI: Mr. Scarola, Mr. Edwards, do you have an opinion on this? MR. SCAROLA: No. MR. EDWARDS: Our opinion is consistent with the opinion of Sigrid McCawley or the argument of Sigrid McCawley. SPECIAL MASTER POZZUOLI: Darren, go ahead. MR. INDYKE: I would like to give this to Florida counsel because this is the first I'm bearing of it. But I would say that at the very least, there's some confidentiality obligations that are applicable to Ms. in connection with the settlement agreement that was signed. And that Mr. Epstein should have counsel there present to protect any disclosures — 20 (Pages 721 to 724) www.phippsreporting.com (888) 811-3408 EFTA00602458

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werIinnewne MR. SCAROLA: We have a very strong opinion on that. MS. McCAWLEY: Right. And I just want to be clear, Mr. Epstein’s counsel has not appeared in this case. | argued this issue before the judge, and | have a confidentiality order from Judge Lynch signed based on my motion to quash. SPECIAL MASTER POZZUOLE: I've rereviewed both your motions and the order. Darren, anything else’? MR. INDYKE: No, that's as far as I understand right now. SPECIAL MASTER POZZUOLE: Mr. Scarola, you wanted to say something? You were -- you had some strong opinion | wanted to hear. MR. SCAROLA: The purpose of the confidentiality motion was to exclude Mr. Epstein from the deposition, among other purposes. But we did not want to be in a position where | || was obliged to give her testimony in front of any of her abusers, but most specifically not in front of the individual accused of having maintained her as a sex slave for an extended 727 record, | mentioned to Rick yesterday I have to leave here at 3:45 this aftemoon, so he made representations that there wouldn't be any testimony with respect to Boies Schiller Flexner or those allegations that have repetitively come up in the deposition outside of counsel's presence. But I do have to leave because | have to catch a plane, so I won't be here this afternoon, and they've agreed to that. MR. SIMPSON: She's correct about the agreement. SPECIAL MASTER POZZUOLI: What we might do, then, is break at that point if we're going to have to come back anyway. MR. EDWARDS: What time is that? MS. McCAWLEY: 3:45. THE WITNESS: If we could finish in a couple of hours, I'd like to do that, if that's possible. SPECIAL MASTER POZZUOLE: It's not my deposition. MR. EDWARDS: At this stage and at this pace, I don't see how that's possible. That was my goal, but I don't sce it happening. period of time. SPECIAL MASTER POZZUOLI: So, I've reviewed both the motion that was filed as well as the order. While the order lacks any real specificity, my view of the order is as follows: That the deposition on Saturday, obviously the named parties and their representatives cun attend. The witness and their counsel can attend. The court reporter and myself. And that will be it. If there is any further clarification from Judge Lynch, I'm happy to consider it. But as of right now, those are the only parties and people that will be allowed to attend the deposition. MS. McCAWLEY: Thank you. MR. SCOTT: You are excluding Ms. Cohen? SPECIAL MASTER POZZUOLI: I'm excluding Ms. Cohen and excluding Mr. Epstein's attorneys. MR. INDYKE: I just want to note my objection, but I will take that up with Florida counsel. (Recess was held from 10:37 a.m. until 10:50 a.m.) MS. McCAWLEY: Just for something for the We'll see where we are. THE WITNESS: I hope we gct to this letter. I spent all night reading it last night at your request. MR. EDWARDS: [ think we'll at least make a dent. SPECIAL MASTER POZZUOLI: Let's go back on and plow forward. VIDEOGRAPHER: Okay. We're going back on the record. The time is 10:50 a.m. BY MR. EDWARDS: Q. So, in addition to the statements that -- or the information that you had in your possession at the time that you made the public statement on January 5, 2015, regarding Brad Edwards, you also indicated initially that you had certain information in your possession with respect to Paul Cassell as well, correct? A. That's nght, yes. Q. One of the things I wrote down is that you were told that Paul Cassell is a zealot. A. Right. Q. When were you told Paul Cassell is a zealot? A. Immediately. 21 (Pages 725 to 728) www.phippsreporting.com (888) 811-3408 EFTA00602459

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oan ewne MR. INDYKE: Same objection, same instruction. A. Shortly there -- shortly after the allegations were made. BY MR. EDWARDS: Q. And who told you that Paul Cassell is a zealot? MR. INDYKE: Same objection, same instruction. MR. SIMPSON: Outside the privilege. A. Numerous people. That was a common term used to describe him. | can tell you the people I spoke to, but, again, I can't identify who precisely would have used that term. BY MR. EDWARDS: Q. You previously said that numerous people -- A. They did. Q. -- told you that Paul Cassell is a zealot, and that assisted in providing the basis for your statement that you made publicly about Paul Cassell. I'm only asking for you to identify by name the individuals that specifically told you Paul Cassell is a zealot. I just want a list of names. MR. SIMPSON: Objection, asked and OA ne ewne NNNNNNNKP BEBE BE BBB ee UeWUNnrF OwDAIHD He Wn Ow led me to the conclusion that he was a zealot. Talso read a great deal of his material. MR. EDWARDS: I move to strike as nonresponsive to this question. A. Okay. I'll give you some descriptions. Q. I want the names of individuals. SPECIAL MASTER POZZUOLI: Listen. BY MR. EDWARDS: Q. The names of individuals who told you that Paul Cassell is a zealot. A. I can't remember names, but I can give you some descriptions, if you want. Q. No, I want names of people. A. Okay. SPECIAL MASTER POZZUOLI: Hang on one second. He's now answered the question. So -- BY MR. EDWARDS: Q. At this stage, you cannot provide me the names of any individuals that told you Paul Cassell is a zealot; is that correct? A. Ican give you descriptions, which would lead you to be able to probably find out the names. Q. Descriptions of people? A. Description of people, yeah. Q. Okay. Not descriptions of the statements; answered. MR. INDYKE: Same objection, same instruction. SPECIAL MASTER POZZUOLE: Ina nonprivileged context. MR. SCAROLA: So that the record is clear, the question does not limit itself to a nonprivileged context because our position is the privilege has been waived. We understand that we may only get a limited response, but the question does not include the limitation. MR. SCOTT: And this is -- our position is that this is the entire area, and that even if you accept, which we don't, that he waived the other conversation, this has not been touched on or waived. MR. INDYKE: My position is that Mr. Epstein waived no such privilege. SPECIAL MASTER POZZUOLE Okay. So with that said, please provide an answer outside of the context of the privilege, which will be reserved for a later argument. A. Right now all I can think of is the number of people who gave me information about Paul Cassell, but I cannot with specificity indicate who 732 descriptions of the people? A. No, description of people. Q. Okay. I'll take right now descriptions of the people who told you that Paul Cassell is a zealot. A. I got a number of calls from people who were in litigation with Paul Cassell. He purports to be an expert on false confessions. Apparently he's not. MR. EDWARDS: Object and move to strike as nonresponsive. SPECIAL MASTER POZZUOLI: I would agree and grant that Motion to Strike. Provide the descriptions of the names pursuant to the question. A. Okay. Soa number of people who were involved in litigation concerning his alleged expertise as a witness on false confessions -- BY MR. EDWARDS: Q. Okay. A. -- called me. Q. Category number one, then, is people involved in litigation currently with Paul Cassell on false confession cases? A. That's right, yes. 22 (Pages 729 to 732) www.phippsreporting.com (888) 811-3408 EFTA00602460

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Od ewWwne Q. And are these people that you are describing lawyers or litigants? A. Lawyers, lawyers. But not in a privilege. Q. Do you remember which party these lawyers that you're describing represent? A. Yes. The party opposed to Paul Cassell, the party that were challenging his expertise. Q. How many different lawyers are you describing that are currently in litigation with Paul Cassell? A. To my best recollection, two. Q. Do these two lawyers work at the same law firm? A. No. Q. Do these two - are these two lawyers, to the best of your understanding, working on separate false confession cases against Paul Cassell? A. [think so, but I'm not absolutely certain. Q. Do you know where it is that these two lawyers that you're describing practice? A. My best recollection, this is just a recollection, one of them is in the midwest, maybe Chicago. And another I think in the mid south, I'm not positive, maybe Atlanta. But those are -- DARN &® wr PRR RR RB NU ewWwhe Ow 735 correct. And I also did my own investigation. MR. SCAROLA: Did those include privileged and nonprivileged communications? BY MR. EDWARDS: Q. Did those communications that led you to the conclusion that Paul Cassell is a zealot include both privileged and nonprivileged communications? A. Yes. Q. And with respect to the privileged communications, are you claiming that the communication that Paul Cassell is a zealot came from people with whom you share an attorney-client privilege because they're your attorneys or with whom you share a joint defense attorney-client privilege because they are attorneys or representatives of Jeffrey Epstein? MR. SCOTT: Wait a minute. I'm objecting to that on work product and we're going to -- SPECIAL MASTER POZZUOLE Go ahead, Darren, get your — MR. INDYKE: Objection. Same objection, same instruction on a number of grounds, including attorney-client privilege as well as common interest. SPECIAL MASTER POZZUOLE: Read the 734 again, I can probably find these names, but I don't have them off the top of my head. Q. Have you provided these names or these descriptions in response to any requests for production in this case? A. I don't provide that. My lawyers do. But I don't think anybody has ever -- these are not -- MR. SIMPSON: Answer the question. A. I don't know the answer to that. BY MR. EDWARDS: Q. Is there anything more that you can provide me in the way of description of the individuals that told you that Paul Cassell is a zealot? A. No, but what I can do is give you names of people who called me and discussed with me Paul Cassell. Q. We'll get there. Different category. Did these other people that called you, did they also tell you Paul Cassell is a zealot? A. Well, Ican only tell you again, as I said previously, on the basis of all the conversations I had with about Paul Cassell, I came to the conclusion, as some people had told me, that the people who told me that he was a zealot were 736 question back. COURT REPORTER: "And with respect to the privileged communications, are you claiming that the communication that Paul Cassell is a zealot came from people with whom you share an attorney-client privilege because they're your attomeys or with whom you share a joint defense attorney-client privilege because they are attorneys or representatives of Jeffrey Epstein?" MR. INDYKE: In doing so, you're not only identifying the people but you're also identifying the contents of the disclosure. MR. SCAROLA: No, we're identifying the nature of the privilege being asserted. SPECIAL MASTER POZZUOLI: The nature of the privilege — hang on a second. MR. SCAROLA: Thank you. I'm sorry. SPECIAL MASTER POZZUOLI: They're trying to identify the nature of the privilege being asserted. And I do think that if the witness does know the answer as opposed to a legal discussion, whoever's going to assert it, I think they're entitled to an answer on that. MR. SCOTT: Without any type of waiver 23 (Pages 733 to 736) www.phippsreporting.com (888) 811-3408 EFTA00602461

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Orne ewne 737 position. SPECIAL MASTER POZZUOLI: Without a waiver, but they're entitled -- because I don't think that waives -- I think it's the nature of what's being asserted. A. So without waiving — MR. SCOTT: Well, wait a minute. So let's ask the question again so we have it again. A. [know the question. MR. SCOTT: I don't. I'm not as smart as you are. THE WITNESS: I'm sorry. SPECIAL MASTER POZZUOLI: Let's go ahead and reread the question back so we get it precisely because that's how I ruled. COURT REPORTER: "And with respect to the privileged communications, are you claiming that the communication that Paul Cassell is a zealot came from people with whom you share an attorney-client privilege because they're your attorneys or with whom you share a joint defense attorney-client privilege because they are attorneys or representatives of Jeffrey Epstein?" MR. SCOTT: Answer that very concisely. record is clear as to which privilege is being asserted. MR. SCOTT: Jack, | totally agree with you. Thank you. SPECIAL MASTER POZZUOLI: Hang on one second. So based upon the correction, the privilege being asserted is both work product and attorney-client. MR. SCOTT: Both. SPECIAL MASTER POZZUOLI: And so the same tuling for now on the reservation. MR. SCOTT: And, Mr. Special Master, I'm objecting on both grounds consistent with what we discussed yesterday. | apologize. And thank you, Mr. Scarola. MR. SCAROLA: No apologies necessary. | just wanted the record to be clear. MR. SCOTT: | appreciate it. SPECIAL MASTER POZZUOLI: Well, I would accept your apology. BY MR. EDWARDS: Q. Mr. Dershowitz, are you willing to waive the attorney-client privilege to provide us the names of the individuals with whom you share a privilege that told you that Paul Cassell -- A. Both. MR. INDYKE: I'm sorry, if there is discussion going on, I can't hear any of the discussion. SPECIAL MASTER POZZUOLI: No, there's -- we've been quiet. BY MR. EDWARDS: Q. With respect to the communications with these individuals where you are the client, can you provide me with the names of those individuals? MR. SCOTT: Objection, work product. SPECIAL MASTER POZZUOLI: Yeah, so I'm going to grant the objection and allow them to assert the privilege at this point pending further review. MR. SCAROLA: I want to -- excuse me. Before we proceed, I want to get a clarification. This privilege that's being asserted is a work product privilege, correct? MR. SCOTT: And attorney-client privilege. MR. SCAROLA: Okay. Well, you said only work product. MR. SCOTT: Okay. I apologize. If I use one, I'm referring to both consistent with — MR. SCAROLA: I wanted to be sure that the a oe ee NRNNHAKRKRERRPR RRB RBBB VUebPwnr OHV’ DARH SWHeH Ow MR. SCOTT: Don't answer the question. BY MR. EDWARDS: Q. -- is a zealot, a fact that you relied upon before making your public statement? MR. SCOTT: Objection. Work product. Do not answer that. He has a right to consult with counsel, and we haven't spoken. MR. INDYKE: Objection. BY MR. EDWARDS: Q. My only question is, are you willing to waive. SPECIAL MASTER POZZUOLE Hang on one second. MR. INDYKE: Are we talking about only as to where Mr. Dershowitz is the client? MR. EDWARDS: Yes. MR. INDYKE: Okay. SPECIAL MASTER POZZUOLE So, now repeat your question so it's clear. BY MR. EDWARDS: Q. Sure. Are you, Alan Dershowitz, willing to waive the attorney-client privilege to provide us the names of the individuals that told you Paul Cassell is a zealot? MR. SCOTT: Objection. Work product, 24 (Pages 737 to 740) www.phippsreporting.com (888) 811-3408 EFTA00602462

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attorney-client privilege, and I'm instructing him not to answer that question. SPECIAL MASTER POZZUOLE Okay. And where he is the client? MR. EDWARDS: Where he is the client. SPECIAL MASTER POZZUOLE Youre instructing him not to answer? MR. SCOTT: Not to answer. I will discuss it with him, and after a break, we can come back to that question. SPECIAL MASTER POZZUOLE: 1 believe the witness has the right to consult with counsel before answering that question. So we'll proceed on that grounds. MR. EDWARDS: Okay. BY MR. EDWARDS: Q. Other than the two lawyers that you have described that told you that Paul Cassell is a zealot, and any attorneys with whom you share a privilege, can you identify or describe any others that you have not yet told us about that told you Paul Cassell is a zealot? A. It's acommon term that has been given to me by numerous lawyers, but I can't right now give you any more specificity. Sometimes it's "zealot," Q. Okay. The communications that Paul Cassell is a zealot -- A. Right. Q. -- outside of the two individuals with whom you do not share privilege that you've described -- A. That's right. Q. -- are the remaining individuals that told you that information and people that you have met with in person, are those people all people with whom you share a privilege? A. No. Q. Okay. What people have you met with in person with whom you do not share a privilege that have told you Paul Cassell is a zealot? A. Itold you I spoke with numerous people. I can't now specify a particular name with the word "zealot." [can give you names of people I spoke to who gave me information about Cassell. MR. SCOTT: If they're not privileged. A. They're not privileged. SPECIAL MASTER POZZUOLI: That was his question. 742 sometimes the term is "true believer," sometimes the term is an "extremist." But I've heard many terms along those lines that would lead to a consistent conclusion. Q. When did you receive these communications from these various individuals that Paul Cassell is a zealot? A. From the beginning up through recently. Q. Is it your testimony that you received that information prior to January 5, 2015? A. Yes, yes. Q. Okay. And what was the form of that communication, written or verbal? A. [don't remember. Well, I have to check. I don't remember anything in writing. I think it's all been — I think it's all been verbal on the phone and in person. Q. Have you met in person with the two individuals that you described? A. No, no. Q. So when you are speaking about in-person communication of the statement that Paul Cassell is a zealot, you're talking about communications that are privileged communications? A. I didn't understand the question. I'm od ne &wWwne BY MR. EDWARDS: Q. Please provide me the names of the individuals you spoke to that provided you information about Paul Cassell. A. Treceived a phone call from Senator Orrin Hatch from whom -- for whom he worked. I received phone call from a lawyer now -- a lawyer who he had a litigation against somewhere in Arizona or somewhere in the southwest whose name I don't right now have on hand. Another name that’s popping into my mind, but it's privileged. I had a conversation with the former President of Ecuador, who had been a student in one of my classes and was a colleague of Mr. Cassell. We spoke -- I think I may have called him or he may have called me, I don't remember exactly. Q. This is the President of Ecuador? A. The former President of Ecuador. Mr. Cassell knows who he is. And -- I can try to think of other names of people who called me. I will check and see if I have any information further. Q. If you think of them while we're talking, then let me know. 25 (Pages 741 to 744) www.phippsreporting.com (888) 811-3408 EFTA00602463

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OI no be wn 745 A. Sure. Q. What did the lawyer in Arizona tell you about Paul Cassell? A. That he was a zealot and that he was a pain in the ass. That was -- I remember that was his exact words. Q. Is this somebody in addition to the other two lawyers that you described? A. Yes. Q. So now we are up to three lawyers that were in litigation with Paul Cassell that told you that Paul Cassell is a zealot? A. At least three, yes. Q. Three that you've been able to describe? A. Yeah. Q. But as you sit here right now, unable to name today? A. Ican't, no. Q. Including this lawyer in Arizona? A. Yeah. I don't remember if it was Arizona or New Mexico or Utah. It was a southw ‘ase that was a long, long -- apparently a lengthy litigation. Q.. Did this lawyer in Arizona telling that you Paul Cassell is a, quote, pain in the ass, unquote, contribute -- constitutionally protected expression of opinion, and it was based on the totality of circumstances that I had available to me at the time. That included reputations of the two people who had made up the story. It included the statements themselves and how they were written and framed. Included the fact that there was no affidavit, that it was written, in fact, by the two lawyers. So of course the lawyers played a role. It was their own words that were being circulated to millions -- hundreds of millions of people around the world. Q. But you were -- you were saying and you said and you conveyed something more than Paul Cassell and Brad Edwards simply listened to their client and put it on paper, you were saying -- A. That's nght. Q. -- you were saying and are still saying Paul Cassell and Brad Edwards and a concocted this story about me together? A. That's nght. Q. Meaning it wasn't just her words; the lawyers came up with these allegations. That's what you were saying, right? A. I'm saying a combination. [I said -- my 746 A. No, no, not that statement. | mean, many lawyers could be described that way. That would not contribute to that. I myself have been described that way. Q. Okay. So is there anything about the communications that you had with this lawyer in Arizona that in any way contributed -- A. Yes. Q. Let me just finish the statement so that we have a clean record. -- contributed to your confidence in making the public statement in January 5, 2015, that Paul Cassell contrived or assisted in making up the allegations? A. First Iet me be very clear that that was an expression of an opinion. Q. What was? Be clearer. A. "So they sat down together, the three of them, these clearly disbarrable, unprofessional lawyers,” when you read it in context, it's clear I wasn't saying | was there, I wasn't saying | was saw it. I was giving a scenario. They profiled me, they did this, so they sat down together and they made up this story. So it was an expression -- 748 exact words were: "MR. DERSHOWITZ: So they and the woman got together and contrived and made this up.” Q. Right. So, when I asked you what formed the basis of your public statement that the lawyers were involved in contriving and making this up, you gave me a list of things, and one is -- A. That's ght. Q. -~ Paul Cassell's reputation -- A. That's nght. Q. - that was supported by various people telling you various things. A. That's nght. Q. One of those things being Paul Cassell is a zealot. And so that's where we are right now in understanding who these people were, when you got this information. And that's what you're describing for me, right? A. That's correct. But I'm saying to you that it was the totality of circumstances. For example, if a very imminent lawyer with a superb reputation had made serious allegations, | would be -- I mean, I knew in this case they were totally false, but if I didn't know, if I didn’t have that 26 (Pages 745 to 748) www.phippsreporting.com (888) 811-3408 EFTA00602464

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Orne ewne 749 personal information, | would be more reluctant to express this opinion. But knowing everything I knew, that the allegations were false, that there had to be financial motive, that there was so much specificity, that it was written by the lawyers themselves, that they didn't put it under seal, that they were trying to get the story out and circulated as widely as possible, all of that combined with their reputation led me to the opinion that this was the scenario. By the way, I think it was partial scenario, I think as I've said before, there were dual motivations. One motivation was to profile me to try to — that was a cover, really. MR. EDWARDS: Object. Move to strike as nonresponsive. SPECIAL MASTER POZZUOLI: Yeah, I think we've gone far afield. So granted. Move forward. BY MR. EDWARDS: Q. What did the former President of Ecuador tell you about Paul Cassell? A. Again, all remember is we had a conversation. You asked me who did I have a 751 confidence in the public statement you made about him on January 5, 2015? AL Yes. Q. Okay. Who are those individuals? A. But I want to be very clear. I'm talking about individuals who I spoke to about Paul Cassell, who gave me information that formed part of the large picture. Q. You've been clear on that. I get that. A. One of them is Akhil Amar, who is a professor at Yale Law School. Q. When did you talk to Akhil Amar? A. Shortly after this happened. Again, my recollection is he called me because he was so shocked. Q. And would that have been some date prior to January 5, 2015? A. I don't remember for sure. But it's — 1 don't remember for sure. Q. Can you tell me what the substance of the conversation was that you had with Akhil Amar about Paul Cassell? A. Well, how shocked he was that Cassell would make a statement like this. And that he would try to talk to Cassell and persuade him that it conversation with about Paul Cassell. My recollection is that he did not use the term “zealot” or anything like that. He just gave me information. Q. What information did he give you? A. That he is stubborn, that he would be difficult to get to change his views, that kind of thing. in general. But all of it contributed to an image. Thad never met Paul Cassell. I didn't know who he was other than having read some of his articles. But then I did a lot of research on him before I made these statements. Q. Okay. My question that's pending is, what did the former President of Ecuador tell you? A. That he was stubborn and probably would be difficult to get him to change his mind. Q. Okay. Is there anyone else other than the people that you have already either identified -- AL Yes. Q. -- by name or described for me that gave you information -- A Yes. Q. -- about Paul Cassell that contributed to your belief about his reputation that gave you a oa HRY & wre NNNRAKHRERFRP RRR BRB BB VUebBwunr OHV RDARYE SWHeH Ow couldn't be true. And that it would be a difficult conversation. That's my basic recollection. Q. Did Akhil Amar tell you that he thought highly of Paul Cassell? A. No. Q. Did he give you positive or negative information about Paul Cassell or Paul's reputation? A. [I would say it was neutral but consistent. You have to know something about Akhil Amar. Akhil Amar is the nicest person in the world. I've never heard him say anything negutive about any human being on the face of the earth, and I would never expect him to say in specific terms anything negative about anybody. But the information he provided me helped form the total picture that I had of Mr. Cassell. Q. Other than telling you that Mr. Cassell was stubborn, what other information did he provide you which helped to form the total picture? A. I think we discussed his views of victimization, his views of false confessions. We had a general discussion about his academic standing, about his general reputation, about -- Q. When you says "his," you're speaking of Paul Cassell's or Akhil Amar's? 27 (Pages 749 to 752) www.phippsreporting.com (888) 811-3408 EFTA00602465

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Od noewWwne A. No, about Paul Cassell's. This is a conversation with Akhil Amar. Q. Okay. What specifically, then, was the substance of that conversation about Paul Cassell's reputation that's helped to form the basis of the big picture? A. The conclusion that I drew from it was that he with a zealot and he was stubborn and that he was an idealogue, and that he was rigid in his views. But, again, this is a conclusion that I reached on the basis of all the conversations I had. T reached out, some people reach out to me, and these are the kinds of things that we discussed. Q. Did Akhil Amar, in speaking about Paul Cassell and his character and his reputation, tell you that he feels Paul Cassell must genuinely believe in the allegations? A. No. Q. Did he tell you or convey to you that Paul Cassell did not believe in the allegations of this claim? A. No. Q. Did Akhil Amar convey to you that Paul Cassell's character or reputation were such that he would place assertions or allegations in pleadings od no &wWwne PPP HPP eB eB Inoue wWnNe Ow 755 you that Paul Cassell's character or reputation were such that he would place assertions or allegations in pleadings in which Paul Cassell did not believe? "My best recollection -- again, this could be him, it could be others, but it was partly from what I spoke to him about is that Paul Cassell does not believe that any woman is capable of lying about sexual assault; that when a woman makes a claim of sexual assault, it must be believed and it must be credited without regard to the evidence. “That was certainly the impression I came away with from my various conversations with a range of people. And that was a pretty uniform view that I got from the people around -- the people I spoke to." BY MR. EDWARDS: Q. Is there anything more about your conversation with Akhil Amar that contributed to your overall perspective on the reputation of Paul Cassell, other than what you've already told me? A. Not that I can now think of. Q. How many times did you speak with Akhil Amar about Paul Cassell? 754 in which Paul Cassell did not believe? A. My best recollection -- again, this could be him, it could be others, but it was partly from what I spoke to him about is that Paul Cassell does not believe that any woman is cupable of lying about sexual assault; that when a woman makes a claim of sexual assault, it must be believed and it must be credited without regard to the evidence. ‘That was certainly the impression I came away with from my various conversations with a range of people. And that was a pretty uniform view that 1 got from the people around -- the people | spoke to. MR. EDWARDS: We're getting a little feedback on the phone. SPECIAL MASTER POZZUOLE: On the phone, there is some background -- VIDEOGRAPHER: We're going off the record. The time is 11:21 a.m. {Recess was held from 11:21 a.m. until 11:27 a.m.) VIDEOGRAPHER: We are back on the record. The time is 11:27 a.m. MR. EDWARDS: Can you read back for me the last question and the last answer? COURT REPORTER: “Did Akhil Amar convey to oOdAne &wne 756 A. [think twice. Q. And are you able to say with any certainty whether or not it was before or after January 5, 2015? A. Tcan't say. Q. Did you ask Akhil Amar to reach out to Paul Cassell? A. Idid. Q. Other than Akhil Amar, is there anyone else that you haven't already described or named that gave you information about Paul Cassell? A. Okay, let me be very clear, I'm not including people with whom I have a privilege, I'm not including people that have a privilege with me. And I want to be very clear about this, I am not now allowed to describe any conversations with the person who Sigrid McCawley is now here on behalf of. So, I don't want a negative inference to be drawn. I would like to comment, if I could, about a person who I'm not allowed to comment about. But I want the record to be -- I don't want -- I have to answer your question completely. Q. Okay. But this is all -- all of these questions are about the basis that gave you the 28 (Pages 753 to 756) www.phippsreporting.com (888) 811-3408 EFTA00602466

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oan ewne 757 confidence to make the January 5, 2015 statement that provided you information on Paul Cassell. A. I misunderstood. [ think your last question said the universe of information about Paul Cassell. That's why I had to put that on the record involving the sealed -- Q. Maybe it did, so let me just say -- let me break this down. SPECIAL MASTER POZZUOLE: That's how I understood it. BY MR. EDWARDS: Q. Let's break this down into the people that you were describing you spoke to prior to making the public statement that we've been talking about, and then we'll expand it beyond that time. A. Okay. Q. Okay. So, in addition to Akhil Amar, who is next on the list? A. You want me to repeat the names I gave you or -- Q. No, no, outside of the people we've already discussed? SPECIAL MASTER POZZUOLE Who is next on the list for what? my view, invade the privilege without identifying the people. And so based on the objection, I will grant the objection pending a reservation to review the entire issue on the privilege, as we've done before. So move on. I think right now, move on on this —- on the question because you specified the question. BY MR. EDWARDS: Q. Did privileged communications assist in forming your opinions about Paul Cassell? MR. SCOTT: Same objection, same instruction. MR. INDYKE: Same objection. SPECIAL MASTER POZZUOLI: And the same tuling as the previous question. BY MR. EDWARDS: Q. Are we clear that I'm not asking what those opinions are or the names of the individuals? Just are there individuals - is there privileged communications that form the basis of your -- that help to form the basis of your opinions? Just yes or no, is there privileged communication -- MR. SCOTT: Same objection, same instruction. BY MR. EDWARDS: Q. Who is next on the list of people that you spoke with about Paul Cassell or his reputation that gave you the confidence to make the public statement that you made about Paul Cassell on January 5, 2015? A. Outside of people within the various privileges we've talked about. Q. Well, | want to know are there people within the privileges that we spoke about -- MR. SCOTT: Objection. BY MR. EDWARDS: Q. Are there people within the privilege that spoke to you that helped to form your opinions or give you confidence to make the public statement that you made in January 5, 2015? MR. SCOTT: Objection, work product — MR. INDYKE: Objection -- MR. SCOTT: -- attomey-client. I'm instructing him not to answer that question. MR. EDWARDS: ['m not even asking for the identities first. I'm asking are there people. MR. SCOTT: I'm not -- objection. MR. INDYKE: Objection. Same objections. SPECIAL MASTER POZZUOLE: Because you've defined the topic so specifically, it would, in MR. INDYKE: Same objection, same instruction. SPECIAL MASTER POZZUOLI: Here's -- let me just — so I'm clear, we may -- it may be me or it may be Judge Lynch who visits this issue, and it may very well be that he will have to -- the witness will have to answer these questions after subsequent argument. However, because the question defines the topic and the matter that you're inquiring so specifically without addressing the individuals, but secking the individuals whom he shares whatever privilege is being asserted, since the topic is so specifically defined in your question, I think it would invade the privilege, as I understand it. And until we reach the overall decision on whether privileged information of this type can be -- to force the witness to answer it — require an answer from the witness, then | would like to move on. MR. SCAROLA: So that our position is clear, there is no legal issue to address unless there are materials over which a privilege is being asserted. 29 (Pages 757 to 760) www.phippsreporting.com (888) 811-3408 EFTA00602467

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Orne e&Wwne We are entitled to know whether there are materials over which a privilege is being asserted, and we are entitled to know the nature of the privilege that is being asserted so that we can make a determination as to whether we even want to raise a legal issue. There's no legal issue to raise unless we've identified whether there is privileged That's what we're attempting to do, to establish for the record whether there is privileged material and the nature of privilege being asserted without getting into the substance of any privileged communication. SPECIAL MASTER POZZUOLI: I -- well taken. But my ruling will stand for now. BY MR. EDWARDS: Q. Did you receive any e-mails about Paul Cassell or his reputation? A. Not that [ remember, but I can check. MR. INDYKE: Same objection. BY MR. EDWARDS: Q. Did you receive any e-mails about the reputation of Brad Edwards? MR. INDYKE: Same objection, same Oa HH ewhn we RNNNHNKHKRRFRER RRR BRB RB Ub wWwnUr OH DARN SWHH OW you Paul Cassell, as a professor, used Alan Dershowitz as an object of hatred in his class? A. Iheard that from some students. Well, no, let me be clear. From a student. And I have no recollection of the name. But a student called me and told me that a friend of his who was in Paul Cassell's class remembered that he went after me on the -- two issues; on the death penalty and on the exclusionary rule, and used me as a kind of object example of, you know, a wrong-headed person. That he seemed to -- at least the student got a perception that he seemed to have an animus towards me. But I have to tell you that did not figure into -- that did not contribute to my conclusions about that. I'm controversial; | know that. Q. Didn't we get here by me asking what did contribute, and you told me, amongst a laundry list of other things, that you were told that Paul Cassell used Alan Dershowitz as an object of hatred? A. I may have thought about that. But as I think about it now, | don't think I really factored that in in any significant way into my assessment. Q. So that I understand the source of that information, as you sit here today, it is a person who you cannot identify told you that a friend of instruction. MR. SCOTT: Again, if they're in the context of privileged materials. A. Outside -- outside all of the privileges, I will have to check. I don't recall. BY MR. EDWARDS: Q. Did you receive any e-mails about the reputation of Jack Scarola? MR. INDYKE: Same objection, same instruction. A. Idon't recall. BY MR. EDWARDS: Q. Did you receive any e-mails about the reputation of Sigrid McCawley? MR. SCOTT: Relevancy. MR. INDYKE: Same objection, same instruction. A. No. I've always had a very high regard for Sigrid McCawley prior to these allegations, which is why I was so shocked that she would lend her name to these false allegations. BY MR. EDWARDS: Q. I don't believe there's any question pending. Who are the individuals by name that told oOAne &wne 764 that person that you cannot identify -- A. That's right. Q. -- told you that -- MR. SCAROLA: Told him. BY MR. EDWARDS: Q. -- told him that Paul Cassell used you as an example on two issues, the death penalty and exclusionary rule, in his class? A. And more generally about my approach to criminal law. That's why I would never make a statement like that publicly. You're asking me what was in my mind. That was a factor in my mind. When you get a phone call about somebody, you don't forget it, it stays in your mind and it becomes a small part. As I now think about it, I think too small a part to even factor into my decision. I don't think I really let that weigh on my decision. It may have weighed on my attitude toward Paul Cassell, but I don't think it would have affected my decision as to whether he would do what I said he did —- what I believe he did. Q. What are the names -- other than those that you have identified or described for us -- what are the other names in addition to those that you 30 (Pages 761 to 764) www.phippsreporting.com (888) 811-3408 EFTA00602468

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Sr HR Ye ewe have described or named for us that gave you information about Paul Cassell? A. As Isit here now, I'm sure there are many, but I can't identify any specific names, and if T can think of any, I will certainly let you know. Q. Can you tell me the additional names other than Akhil Amar that you communicated with and asked to communicate with Paul Cassell’? A. Nancy Gertner, former federal judge. MR. SCOTT: Again, not privileged. A. Well, it's complicated. At the time I asked her to reach out, I did not regard her as my attorney. Since that time, she has offered to help represent me. So we're now in a privileged relationship. But when I called and asked her — 1 think she called me. I had no idea who knew Paul Cassell, but a number of people called and said. what can we do? Can we call Paul? How can he be doing this? This is - even Senator Hatch offered to call Paul Cassell because he couldn't believe -- he said, I cannot believe this allegation against you. I know you. I know you to be a very honorable man. I cannot believe that allegation against you. And I'm od no &wne NNNNNNKHPPBP BEB BP Be ee Ub wnr OwnadI nude Whe Ow 767 here now, but she’s one of my lawyers and she's included on my list of lawyers and I regard her as one of my attorneys. Q. Is there anyone else that is on the list of people other than those that you've either described or named already that provided you information about Paul Cassell? A. I'm sure there are many, but not that I can identify now. Well, I can give you one more. The BBC reporter who interviewed me showed me an e-mail from Paul Cassell in which Paul Cassell gave her a list of questions to ask me, while claiming that he was not speaking to the media. That led me to conclude that he was a liar. And that happened very early on. That he was absolutely a liar because he categorically stated that he had never spoken to the media, never would speak to the media. And here I had an e-mail from him showed to me by BBC that proved he was absolutely lying through his teeth. So I concluded that he is a liar who has no concern for the truth. Q. When did Paul Cassell categorically deny ever speaking to the media? A. In his press releases where he says, we do not speak to the media. we've never spoken to the going to call Paul Cassell. BY MR. EDWARDS: Q. Okay. Going back to Nancy Gertner, when did you establish an attorney-client relationship with Nancy Gertner? A. Sometime thereafter. Q. Sometime? A. After she called Cassell, and Cassell would not do anything to try to resolve the matter. Q. Okay. Do you know when it was that you asked Nancy Gertner to reach out to Paul Cassell? A. Shortly after the allegations. Again, she called me, and she just couldn't believe that anybody would be making these allegutions. Q. Was it before or after the statement that we have discussed that was made by you on the Don Lemon show on January 5, 2015, that you asked Nancy Gertner to reach out to Paul Cassell? A. I don't remember. It could have been before. But it might have been after. I just don't remember. Q. And is there a formal memorialization of the attorney-client relationship between yourself and Nancy Gertner? A. I don't know the answer to that as we sit 768 media, only Dershowitz speaks to the media, lying by omission and by commission, failing to state that he was trying to get publicity through ABC, that he was pleading with ABC and he was trying to sell her story to tabloids. So he was lying by omission, lying by commission, and so were you. Q. Have you produced -- do you have a list from BBC or - reporter or anyone else that indicates a list of questions or whatever it is you're testifying to -- AL Yes. Q. - that came from somebody other than Paul Cassell? A. I don't understand that question. Q. Well, you just threw in "and so were you," and we're only talking about a list of questions that you know about from the BBC. MR. SCOTT: I'm not sure -- can you rephrase the question so we have it clear? MR. EDWARDS: Sure. BY MR. EDWARDS: Q. Lasked for you to identify anyone else that provided you information about Paul Cassell that helped to form your opinions. Your answer was, a BBC reporter. Do you know her name? 31 (Pages 765 to 768) www.phippsreporting.com (888) 811-3408 EFTA00602469

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A. You must, because you know it's a her. Q. I'm asking you, do you know her name? A. I provided it and we have - it's part of the record. Q. As you sit here today, do you know her name? A. No, [dont know the names of reporters. Q. Okay. And the thing that that BBC reporter whose name you do not know right now -- A. But I can get it for you. Q. I'm just describing the reporter since you don't know her name. The reporter whose name you do not recall right now provided you an e-mail -- A. No. Q. Showed you an e-mail? A. No. MR. SCOTT: Let him ask the question. SPECIAL MASTER POZZUOLI; Let him finish. BY MR. EDWARDS: Q. Lunderstood your testimony, and please correct me if I'm wrong, that this BBC reporter showed you an e-mail of questions from Paul Cassell that were requested by Paul Cassell to be directed to you. A. Yes. But it was not done by the reporter. od no &wne NNNNNNKHFPPBP HBB BP Be ee UbrWwUnr OVD AKRU d>wWN eH Ow 771 understand exactly what you're saying to this BBC reporter that you have identified that provided you information that helped to support your opinions about Paul Cassell. A. That's right. Q. Okay. That person provided you an e-mail or you saw through this person an e-mail that Paul Cassell -- that evidenced questions that Paul Cassell wanted you to be asked? A. It was my recollection it was an e-mail from Paul Cassell to the producer is my recollection. Q. Okay. In addition -- so my question that's pending is, in addition to the questions, is there anything in the body of that e-mail or that you were told by this reporter that Paul Cassell spoke or communicated with the BBC beyond the content of those questions? A. Yes, the reporter told me that Paul Cassell had spoken to him, and my recollection is that they had spoken and then he sent him a follow-up e-mail is my recollection. Again, it's a year ago. And this was at the time that Paul Cassell was saying and you were saying through your lawyers and certainly trying to convey the 770 Tt was done by the producer. It was a man producer. And he told me and showed me on his BlackBerry or his iPhone the questions that Paul Cassell had asked him to ask me. Q. In addition to the questions that Paul Cassell had asked him to ask you, is it your testimony that Paul Cassell spoke to the media about the allegations or the facts as Paul understood them in the case? A. Yes, I don't about spoke, but we know that he -- yes, we know he spoke to ABC. I think I can give you the names of the people he spoke to there. Jim Hill. MR. SCAROLA: Pardon me. I think there's a feedback problem again. MR. SIMPSON: On the phone, there seems to be a feedback problem. MR. SCAROLA: Cross talk. MR. INDYKE: Do you know if it's coming from Darren Indyke or another phone? SPECIAL MASTER POZZUOLE: There's no way to know. MR. SIMPSON: It's not there now. BY MR. EDWARDS: Q. I want to limit this so that I can impression that you were trying to keep this case out of the media and that it was | who was putting it into the media, while it tums out that secretly -- MR. EDWARDS: Object. Move to strike as nonresponsive. SPECIAL MASTER POZZUOLI: Are you almost finished? A. Almost done. Sceretly you were communicating with the media and trying very hard to get them to cover this story in a way negative to me. BY MR. EDWARDS: Q. Was this a reporter or a producer that was telling you this information? A. Producer. Q. And what is the name of that producer, if you know? A. We can find that out. But I'm sure you have the e-mail. I'm sure Cassell has the e-mail. SPECIAL MASTER POZZUOLI: Do you know? A. I don't know the name of the producer. BY MR. EDWARDS: Q. And what was it that this producer told you that Paul told him? 32 (Pages 769 to 772) www.phippsreporting.com (888) 811-3408 EFTA00602470

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Od noewWwne A. To please ask me very critical and hard questions. And I assumed -- this is an assumption -- that the reason the BBC may have called me was they were put on to it by Paul Cassell, who urged them to call me. Q. My question, if we back up a few, though, is beyond the substance of the questions from Paul Cassell, do you have information that Paul Cassell spoke to them? A. Yes. Q. Okay. And I think, as you said, yes, because I talked to this reporter. What did the reporter tell you that Paul Cassell said beyond the substance of those questions? A. It's the producer. Q. Producer. A. Not the reporter. The reporter was part of the conversation, too, but I think the conversations had been between Paul Cassell and the producer. The conclusion I drew from our conversation was that Paul Cassell had reached out to BBC and asked to have them ask me hard questions, and the questions were all very critical and hard questions designed to make her story believable. reached that I was guilty. So I can draw a reasonable inference that he was told that by Paul Cassell. Q. Did the producer tell you that he was told anything beyond "ask Alan Dershowitz these questions"? A. The producer told me that he had other communications with Cassell. But beyond that, I had to draw my own inferences. Q. Without you drawing your own inferences, did the producer tell you the substance of those other communications with Paul Cassell beyond "ask Alan Dershowitz these questions"? A No. SPECIAL MASTER POZZUOLI: We're beginning to upproach a break, so as your deposition -- find a time in the next 10 or 15 minutes or so- MR. EDWARDS: I think this is as good a time as any. THE WITNESS: I'm happy to go on. MR. SIMPSON: Take a break. MR. SCOTT: Take a break. SPECIAL MASTER POZZUOLI: I don't want to interrupt a flow. MR. EDWARDS: This is good stopping point, 774 And that the producer then responded to Cassell and said send me an e-mail, and Cassell sent an e-mail with the questions listed. And they, in fact, asked me those questions. Q. Okay. A. But the point of my answer is that at the same time, you, Mr. Scarola, and Mr. Cassell were communicating to the press -- MR. EDWARDS: Object and move to strike as nonresponsive. SPECIAL MASTER POZZUOLE: | would agree with that and grant the motion. Go ahead and ask your next question. BY MR. EDWARDS: Q. Beyond the communication from Paul Cassell to a producer, ask Alan Dershowitz these questions, is it your understanding that Paul Cassell communicated anything further to that producer? A. Yes. Q. Okay. What did the producer tell you that Paul Cassell said to him beyond "ask Alan Dershowitz these questions"? A. Well, the producer certainly came to the interview having been, it seemed to me, briefed by Cassell and came with a conclusion that he had ee oe ee NRNNHAKRKRERRP RRR BR RBBB VUebwnr OCHYOBDARH SWHeH Ow 776 and then we'll take a break and be back. VIDEOGRAPHER: We're going off the record. The time is 11:52 a.m. SPECIAL MASTER POZZUOLE: You can go off the record but stay on the record. With respect to the issues over privilege, and as it appears that this witness may be held over beyond today, I would ask the parties to discuss and see if you can agree among yourselves how you wish, if you wish, to address those issues so that whether it's in front of me or in front of Judge Lynch, so that in several weeks or whenever he's resect, should there need to be a readdressing of questions that were not answered because of that issue, just as I'm not foretelling — don't take anything in it, but just for purposes of scheduling, we probably ought to try to deal with -- I would suggest that the parties try to deal with that issue between now and the next time Mr. Dershowitz sits for deposition. MR. SCAROLA: That absolutely makes sense. And we will be filing, after we have received the transcript, an appropriate Motion to Compel, and I think that it is best that the 33 (Pages 773 to 776) www.phippsreporting.com (888) 811-3408 EFTA00602471

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werIinnewne Court deal with that motion. SPECIAL MASTER POZZUOLE: I'm -- MR. SCAROLA: | think it's beyond the scope of the responsibilities that have been agreed to be resolved by you, and that would be our request. SPECIAL MASTER POZZUOLE: Okay. I wanted to raise that just from the purposes of just an administrative standpoint. MR. SCAROLA: Yes. Thank you very much. (Recess was held from 11:54 a.m. until 1:04 p.m. after which the proceedings continued in Volume 6.) CERTIFICATE OF REPORTER STATE OF FLORIDA COUNTY OF BROWARD L KIMBERLY FONTALVO, Registered Professional Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing videotape continued deposition of ALAN M. DERSHOWITZ; pages 648 through 455; that a review of the transcript was requested; and that the transcript is a true record of my stenogruphic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am [a relative or employee of any of the parties’ attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 14th day of January, 2016. KIMBERLY FONTALVO, RPR, CLR CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF BROWARD I, the undersigned authority, certify that ALAN M. DERSHOWITZ personally appeared before me and was duly sworn on the 13th day of January, 2016. Signed this 17th day of J 2016. IMBERLY FONTALVO, RPR, CLR Notary Public, State of Florida My Commission No. FF 226848 Expires: 7/12/2019 January 14, 2016, COLE, SCOTT & KISSANE PA Dadeland Centre If - Suite 1400 9150 South Dadeland Boulevard Miami, Florida 33156 BY: THOMAS EMERSON SCOTT. JR. ESQ. thomas. scott @ csklegal.com Re: Bradley Edwards, et al., vy. Alan M. Dershowitz Please take notice that on the 12th day of January, 2016, you gave your deposition in the abowe cause At that time, you did not waive your signature. ‘The abowe-addressed attomey has ordered a copy of this transcript and will make arrangements with you to read their copy. Please execute the Errata ‘Sheet, which cam be found at the back of the transcript, and have it returned to us for distribution to all parties. If you do not read and sign the deposition within a reasonable amount of time, the orginal, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your signature now, please sign your name in the blank at the bottom of this letter und return to the address listed below. Very truly yours, KIMBERLY FONTALVO, RPR, CLR Phipps Reporting. Inc 1551 Forum Place Building 200, Suite E West Palm Beach, Florida 33401 Ido hereby waive my signature 34 (Pages 777 to 780) www.phippsreporting.com (888) 811-3408 EFTA00602472

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781 ERRATA SHEET DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE In Re: BRADLEY EDWARDS, ET AL. V. ALAN M. DERSHOWITZ Case No. ALAN M. DERSHOWITZ January 12, 2016 PAGE LINE CHANGE Under penalties of perjury, I declare that I have read the foregomg document and that the facts stated in it are true. Dae ALAN M. DERSHOWITZ 35 (Page 781) www.phippsreporting.com (888) 811-3408 EFTA00602473

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696:2 705:24 781:1 686:25 expert (2) fact (12) 710:7 711:6 ESQ (8) example (6) 709: 12 732:8 656:10,24 719:14 750:19 | 649:5,11,12,15 | 668:5 686:4 expertise (2) 657:12 669:24 767:5 649:19 650:5,9 | 723:6748:22 | 732:18 733:7 697:4 702:10 elaborate (2) 780:4 763:10 764:7 | Expires (1) 702:13 712:8 664:21 665:1 essentially (1) | excerpts (2) 778:17 740:3 747:7,8 emergency (1) 700:17 692:15 711:23 | explain (2) 774:4 721:12 establish (2) exchange (1) 663:21 719:16 factor (2) EMERSON (2) | 761:11 766:4 715:13 explanation (4) | 764:13,17 649:11 780:4 et (3) exclude (1) 718:24719:17 | factored (1) employee (2) 665:4 780:5 725:18 721:8.8 763:21 779:15,16 781:3 excluding (4) explore (1) facts (10) enforcement (3) | ethical (3) 724:5 726:17.18 | 706:1 655:18 686:2 712:24 714:6 664:19,20 665:6 | 726:19 express (1) 687:10 695:14 715:3 evaluation (1) | exclusionary (3) | 749:2 697:6 698:18 ENTER (1) 714:19 654:20 763:9 expression (3) 700:5 717:8 781:2 event (3) 764:8 746:16,25 747:1 | 770:8 781:22 entire (6) 678:20,22 695:1 | exculpatory (1) | extended (1) failed (1) 692:14,19,22 events (7) 690:24 725:25 654:12 710:17 730:13 | 654:4,9 671:19 | excuse (3) extent (3) failing (1) 759:4 677:22 678:16 | 658:21 674:20 | 667:2 680:10 768:2 entitled (5) 680:18 714:4 738:16 684:6 fair (3) 723:20 736:24 everybody (1) execute (1) extortion (1) 666:10 692:20 737:3 761:1,3 | 692:15 780:9 655:16 693:4 entries (4) evidence (19) execution (1) extreme (1) fake (2) 687:23,25 653:23 654:11 | 651:8 665:14 686:6 699:17 688:11 695:3 654:13 688:2 | exhibit (2) extremist (1) false (13) entry (1) 688:13 699:18 | 689:10,17 742:2 658:13 660:10 695:6 707:19 708:13. | EXHIBITS (1) | ————————]_ 6898 721:9 Epstein (27) 709:3,9 712:15 | 651:10 ——_F____]_ 722:2 732:8.18 650:3 652:22 713:12 714:15 | exist (1) fabricated (18) 732:24 733:17 669:25 670:3 714:19716:7 | 686:7 654:11 659:23 748:25 749:4 670:22 693:24 | 716:20717:4 | exists (1) 665:22 666:3 752:21 762:21 694:9,11 754:8 755:12 | 706:5 675:20 676:1 | falsely (1) 695:16 697:8 | evidenced (1) | expand (1) 676:24 679:24 | 721:19 698:9 700:24 | 771:8 757:15 707:18 708:13 | far (3) 700:25 701:16 | exact (6) expect (1) 709:3,9 T1215 | 716:22 725:12 704:4,17,18 663:3 666:9,10 | 752:13 713:11 714:15 | 749:19 705:10 706:17 | 670:22745:6 | expected (1) 716:6,20 717:4 | federal (4) 717:24 723:24 | 748:1 656:7 fabricating (1) | 658:12 660:11 724:23 725:19 | exactly (6) expecting (1) 653:21 694:6 765:10 730:18 735:16 | 661:5 679:19,25 | 656:13 fabrication (6) | feedback (3) 736:10 737:24 | 688:15 744:17 | experience (5) | 654:13 661:11 | 754:15 770:15 Epstein's (2) 7711 655:4,9 656:24 662:12 673:25 | 770:17 725:4 726:19 Examination (1) | 664:7,23 685:19 716:8 | feels (1) Errata (3) 651:3 experienced (1) | face (1) 753:16 651:8 780:9 examining (1) | 655:4 752:12 FF (1) www .phippsreporting.com (888) 811-3408 EFTA00602481

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