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Case 1:17-mc-00025-RWS Document 1-4 Filed 06/13/16 Page 1 of 27 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. _________________ ! VIDEOTAPE CONTINUED DEPOSITION OF ALAN M. DERSHOWITZ VOLUME 4 Pages 462 through 647 Tuesday, January 12, 2016 1:05 p.m. - 4:45 p.m. Tripp Scott 110 Southeast 6th Street Fort Lauderdale, Florida Stenographically Reported By: Kimberly Fontalvo, RPR, CLR Realtime Systems Administrator www.phippsreporting.com (888)811-3408 462 Case 1:17-mc-00025-RWS Document 1-4 Filed 06/13/16 Page 2 of 27 1 Virginia Roberts and things that she has said, was 2 she lying when she said that she has flown on 3 Jeffrey Epstein's airplane? 471 4 5 6 MR. INDYKE: Objection. Work product and common interest. A. I think I can answer that question. Based 7 on material that was produced in discovery, which 8 would not be subject to privilege, there seems to be 9 evidence that she did fly on the airplane with 10 Jeffrey Epstein. 11 BY MR. EDWARDS: 12 Q. Was she lying when she says that she was 13 flown on Jeffrey Epstein's airplane across state 14 lines at a time when she was under the age of 18? 15 16 17 18 19 A. I have no idea. MR. INDYKE: Objection. Same objection. Work product and attorney-client and common interest. A. I have no idea. But, again -- I just have 20 no idea. 21 BY MR. EDWARDS: 22 Q. Is there any nonprivileged information 23 that you could review that would give you an idea to 24 answer that question or that would give you the 25 answer to that question? www.phippsreporting.com (888)811-3408 Case 1:17-mc-00025-RWS Document 1-4 Filed 06/13/16 Page 3 of 27 1 2 3 4 5 6 BY BY MR. Q. and MR. Q. 507 EDWARDS: What we have here - - MR. INDYKE: Attorney-client, work product common interests. EDWARDS: What we have here is only the fraction of 7 flights where Dave Rogers was one of the pilots. 8 Can you help us get the flight logs from Larry 9 Visosky, Larry Morrison, any of the flight logs from 10 the helicopters, et cetera? 11 A. I would love to. It would all show that I 12 wasn't on the plane. 13 14 15 16 17 18 19 MR. INDYKE: Same objection, same instruction. A. I will do everything in my power -- MR. SCOTT: You can make any request you want to through counsel, and we'll take them up. A. But I will do everything in my power to 20 get you every flight manifest. 21 22 23 24 25 SPECIAL MASTER POZZUOLI: Move forward. MR. INDYKE: We do not waive any objection. MR. SCAROLA: And that request has been made. www.phippsreporting.com (888)811-3408 Case 1:17-mc-00025-RWS Document 1-4 Filed 06/13/16 Page 4 of 27 508 A. Is that a question? MR. SCOTT: No. Just Mr. Scarola 1 2 3 MR. EDWARDS: Just that we made a request 4 for production. 5 BY MR. EDWARDS: 6 Q. Was Virginia lying when she says that she 7 was taken to Jeffrey Epstein's home in New York 8 while underage? 9 10 A. I have no idea. MR. INDYKE: Same objection, same 11 instruction. 12 BY MR. EDWARDS: 13 Q. Was Virginia lying when she says she was 14 taken to Jeffrey Epstein's ranch in New Mexico while 15 underage? 16 17 18 MR. INDYKE: Same objection, same instruction. A. I can tell you this. She's lying when she 19 said she met me at the ranch. So I cannot believe 20 anything she says about the ranch. 21 BY MR. EDWARDS: 22 Q. Was she lying when she says Ghislaine 23 Maxwell and Jeffrey Epstein used sex toys on her 24 when she was underage? 25 MR. INDYKE: Same objection, same www.phippsreporting.com (888)811-3408 Case 1:17-mc-00025-RWS Document 1-4 Filed 06/13/16 Page 5 of 27 509 1 instruction. 2 BY MR. EDWARDS: 3 Q. Was she lying when she says Jeffrey 4 Epstein and Ghislaine Maxwell made her dress up in 5 outfits for them? 6 7 8 MR. INDYKE: Same objection, same instruction. A. Well, I can but I do have some material 9 outside of the record on that. 10 BY MR. EDWARDS: 11 12 Q. A. Okay. I know that Sigrid Mccawley said that she 13 said that Leslie Wexner made her dress up -- 14 15 16 17 18 19 20 21 22 23 24 25 MS. McCAWLEY: I am going to object to the extent that you are trying to reveal conversations that were part of a settlement discussion which the judge has already sealed the record on and there is a pending motion for sanctions. And if you're going to start revealing that information, we're going directly to the Judge Lynch. A. I am going to start revealing SPECIAL MASTER POZZUOLI: No, I'm going to stop you THE WITNESS: Let me tell you why. www.phippsreporting.com (888)811-3408 Case 1:17-mc-00025-RWS Document 1-4 Filed 06/13/16 Page 6 of 27 1 2 3 4 5 6 7 Because I didn't get that from Sigrid or from David Boise. I got it from Leslie Wexner's lawyer in a totally nonprivileged communication. 510 SPECIAL MASTER POZZUOLI: Let me stop you. I don't believe it's responsive to the question that's pending, so let's move forward. 8 BY MR. EDWARDS: 9 Q. My question was, was she lying -- was 10 Virginia Roberts lying when she says Jeffrey Epstein 11 and Ghislaine Maxwell made her dress up in outfits 12 for them? 13 A. I can only say that that allegation has 14 been made regarding Leslie Wexner as well. 15 16 17 Q. A. It has nothing to do with my question. MR. SCAROLA: Move to strike. Leslie Wexner's lawyer regards that as a 18 full statement and, therefore, I can only assume 19 that it's a false statement when made about someone 20 else. I think that's relevant. 21 22 23 24 25 SPECIAL MASTER POZZUOLI: So with respect to the -- MR. EDWARDS: I'm moving to strike the nonresponsive portion of that answer. THE WITNESS: He opened the door. www.phippsreporting.com (888)811-3408 Case 1:17-mc-00025-RWS Document 1-4 Filed 06/13/16 Page 7 of 27 1 2 3 511 SPECIAL MASTER POZZUOLI: I do believe it was nonresponsive in its entirety. Move forward. Go ahead. 4 BY MR. EDWARDS: 5 6 7 8 9 10 Q. A. Q. Do you know Jean-Luc Brunel? No. Have you ever met him? MR. INDYKE: Same objection, same instruction. A. I have no memory of ever meeting a man by 11 that name. 12 BY MR. EDWARDS: 13 Q. Do you know what his role was in Jeffrey 14 Epstein's life? 15 16 17 18 19 A. No. MR. INDYKE: Same objection, same instruction. Mr. Dershowitz, if you would let me make my objections before you respond. THE WITNESS: Right. 20 BY MR. EDWARDS: 21 Q. Was Virginia Roberts lying when she said 22 Jeffrey Epstein socialized with Bill Clinton during 23 the relevant time period? 24 25 MR. INDYKE: Same objection, same instructions. www.phippsreporting.com (888)811-3408 Case 1:17-mc-00025-RWS Document 1-4 Filed 06/13/16 Page 8 of 27 512 1 A. My information is that Virginia Roberts 2 was lying when she said that she saw Bill Clinton on 3 Jeffrey Epstein's island. That's all I can comme