EFTA00615804.pdf

334 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 3 Pages 334 through 461 Tuesday, January 12, 2016 9:46 a.m. - 11:59 a.m. MOM Stenographically Reported By: Kimberly Fontalvo, RPR, CLR Realtime Systems Administrator www.phi sre orting.com EFTA00615804  335 337 1 APPEARANCES: 1 I N D EX 2 2 On behalf of Plaintiffs: 3 3 SEARCY. DENNEY. SCAROLA Examination Page 4 4 5 VOLUME 3 (Pages 334 - 461) 5 6 6 7 ALAN M. DERSHOWITZ 7 8 Direct (continued) By Mr. Edwards 341 a On behalf of Defendam: 9 Certificate of Oath 459 9 COLE. SCOTT & KISSANE. P.A. Certificate of Reporter 460 10 Read and Sign Letter to Witness 461 10 Errata Sheet (forwarded upon execution) 462 11 11 BY: THOMAS EMERSON SCOTT. JR.. kiSQ MIIIIIIIIIIIIIIIIIIMRIIIN= 12 PLAINTIFF EXHIBITS 12 BY: STEVEN SAFRA. FS 4. (Via phcot p • 13 14 No. Page 13 --and-- 15 13 Journal Entries of Alfredo Rodriguez 379 14 SIVEDER & ROSS. UR 16 14 Excerpt -April 1.2015 Transcript of 394 15 Alan Dershowitz at Chabad Coral liallaillit 17 Springs 16 18 15 Excerpt- Transcript dated January 4, 397 17 _an _ 18 2015 Interview of Alan Dershowitz by WILEY. REIN 19 BBC News Breakfast & BBC News 19 20 16 Composite documents 398 it F-SC). 21 17 Composite documents 401 20 22 18 Composite Palm Beach Police Department 438 21 Incident Reports 22 23 23 24 24 25 25 336 338 1 APPEARANCES (Continued): 1 SPECIAL MASTER POZZUOLI: Let's do some 2 2 preliminaries before we start. I'm Ed 3 4 On behalf of Jeffrey Epstein: 3 Pozzuoli. I'm the special master appointed by 4 Judge Lynch. I wanted to make sure that we put 5 5 this on the record. The order that I'm BY: DARREN K. INDYKE. ESQ. ( Via phone) 6 traveling under is Judge Lynch's order of 6 7 114/2016. And originally my partner. Ed 7 On behalf o 8 Curtis. was appointed special master. but 8 ' LP 9 because of health reasons. I've agreed to pitch 10 in and take his place with the consent of the 9 11 parties. If the parties could just affirm and ID STO. • . ESQ. 10 12 confirm that so that we can proceed. 11 13 MR. EDWARDS: We agree. 12 ALSO PRESENT: 14 MR. SCOTT: We agree. 13 Edward J. Pozzuoli. Special Master 15 MS. McCAWLEY: We agree. 14 Sean D. Reyes. Utah Attorney General Office 16 SPECIAL MASTER POZZUOLI: Okay. 15 Travis Gallagher. Videographer 16 17 VIDEOGRAPHER: This is the 12th day of 17 18 January. 2016. and the time is approximately 18 19 9:46 a.m. This is the videotaped deposition of 19 20 Alan Dershowitz in the matter of Bradley J. 20 21 Edwards and Paul G. Cassell versus Alan 21 22 Dershowitz. 22 23 23 This deposition is being held at= 24 24 25 25 My nano is 2 (Pages 335 to 338) www.phi sre orting.com EFTA00615805 EFTA00615806 EFTA00615807 EFTA00615808 EFTA00615809 EFTA00615810 EFTA00615811 EFTA00615812 EFTA00615813 EFTA00615814 EFTA00615815 EFTA00615816 EFTA00615817 EFTA00615818 EFTA00615819 EFTA00615820 EFTA00615821 EFTA00615822 EFTA00615823  41 3 1 BY MR. EDWARDS: 2 Q. And haven't you also said earlier in your 3 testimony today that "I believe nothing in the 4 affidavit lo be true"? 5 A. No. I believe her name is probably true. 6 But no substantive statement -- that there is 7 nothing that she says that should ever be believed. 8 She's one of these people who lies so consistently. 9 and so repeatedly. and so transparently. and so 10 obviously that any lawyer who claims to be believing 11 her statement is acting unprofessionally. 12 Q. Okay. 13 A. And I wish I had the ability to give you 14 some backup to that. but I've been precluded from 15 doing that. 16 Q. µTeen did your representation of Jeffrey 17 Epstein begin? 18 MR. SCOTT: Asked and answered in the last 19 depo. I believe. 20 MR_ EDWARDS: It was asked. not answered. 21 A. At the time when he was first alerted to 22 the fact that he is -- let me amend that. Let me 23 amend that. 24 Over the years since I first met Jeffrey 25 Epstein. he has sought advice front me. 414 1 MR. INDYKE: Objection. Alan. this is 2 Darren Indyke. If you're going to discuss 3 statements that Jeffrey's made to you in 4 connection with requesting legal advice, then I 5 would instruct you not to answer. 6 MR. EDWARDS: I'm asking for the timing. 7 SPECIAL MASTER POZZUOLI: The question is 8 the time. When did your representation of 9 Mr. Epstein start? 10 A. It's not an easy question. My 11 representation in regard to this case suited when 12 he was first accused of improper conduct with one or 13 two women in Palm Beach. But previously. he had 14 sought legal advice from me on a handful of other 15 matters. 16 BY MR. EDWARDS: 17 Q. Is your recollection of the time period 18 when your representation of Mr. Epstein began with 19 respect to the criminal allegations against him in 20 Palm Beach sometime during the year of 2005? 21 A. 2005 to 2006.1just don't have a current 22 recollection. I can check it out. It's easy to 23 find out. 24 Whenever the allegations first surfaced. 25 that's when he called me. 21 (Pages 411 to 414) www.phi sre orting.com EFTA00615824 EFTA00615825 EFTA00615826 EFTA00615827 EFTA00615828 EFTA00615829  2 3 4 S 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 3 4 S 6 7 B 9 10 11 Q, ‘VO.oltliyAllvflidcmc pcut 12 for itself. 13 A. This is not evidence — let me be very 14 clear. This is a police report. I've had 50 ran 15 of experience as a criminal lawyer. and I know what 16 credibility and what weight to give police reports. 17 They are often one-sided. and they are regarded as 18 very rough material. not corroborated. And so. I 19 mean, it's obvious that the State Attorney didn't 20 credit all these reports either. based on the — 21 SPECIAL MASTER POZZUOLI: Mr. Dershowitz. 22 at this point. rm going to ask you to stop. 23 Please ask a specific question about the 24 exhibit or move forward one way or another. 25 27 (Pages 435 to 438) www.phi sre orting.com EFTA00615830  1 2 3 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 4 1 recollection about when they were. Shc remained 2 with him apparently. according to her own account. 3 taking money for prostitution when she was over I8. when she wasMover IS. 5 MR. SCOTT: Do you want to take a break? 6 Are you okay? We've been going for an hour and 7 a half. 8 THE WITNESS: Whichever you think. 9 SPECIAL MASTER POZZUOLI: Another ten 10 minutes. I think we'll break for lunch. Are 11 you good with that? 12 MR. EDWARDS: Absolutely. Thank you. 13 BY MR. EDWARDS: 19 Q. In your statement that police reports are 15 often one-sided and you know what kind of weight to 16 give them are you saying that the other minor 17 victims who gave statements in the police report 18 were also lying? 19 MR. SCOTT: Objection. form. 20 argumentative. 21 MR. SIMPSON: Nonprivileged information. 22 BY MR. EDWARDS: 23 Q. Are you claiming privilege or are you 29 saying you really don't know? 25 MR. SIMPSON: Damn? 28 (Pages 439 to 442) www.phi sre orting.com EFTA00615831  443 445 1 SPECIAL MASTER POZZUOLI: To the extent — 1 communications. 2 MR. INDYKE: Can you hear me? 2 A. That would be privileged. 3 SPECIAL MASTER POZZUOLI: Go ahead. make 3 BY MR. EDWARDS: 4 your objection. 4 Q. Your conversation with Ghislaine Maxwell. 5 MR. INDYKE: To the extent that that 5 somebody who you have just told me you did not 6 question requires Alan to disclose privileged 6 represent, would be a privileged communication? 7 information. attorney-client or common 7 A. It would be. 8 interest. Alan. I would instruct you not to 8 Q. In what ■? 9 answer. 9 A. It would be privileged through -- 10 SPECIAL MASTER POZZUOLI: So qualify that. 10 SPECIAL MASTER POZZUOLI: Counsel, how 11 BY MR. EDWARDS: 11 would that be privileged? 12 Q. Okay. Haven't you in the past said that 12 THE WITNESS: That would be privileged 13 the girls that accused Jeffrey Epstein of engaging 13 because — 14 in sexual massages with them while they n ere minors 14 MR. SIMPSON: Darren. 15 were also lying? 15 SPECIAL MASTER POZZUOLI: Darren. 16 A. I don't believe I said that. What I did 16 Darren, are you there? 17 was -- in at least one instance I remember. I was 17 MR. INDYKE: Can you hear me? You guys 18 provided information about one woman. this is early 18 are cutting out. So I'm sorry. I'm trying to 19 on. who had on her web page or whatever it was at 19 listen, but it's cutting in and out. Can you 20 the time. I don't remember what the web situation 20 hear me? 21 was then. she called herself "pimp juice and she 21 SPECIAL MASTER POZZUOLI: Yes. So the 22 had other terms that would affect her credibility. 22 question is — go back to the question. 23 and I brought that to the attention of the State 23 MR. SCAROLA: Could we first identify 24 Attorney. as any defense lawyer would do. 24 which privileged information is being asserted? 25 And I questioned the credibility of the 25 MR. EDWARDS: I'm going to do that. 444 446 I one or two witnesses. But we never had any 1 SPECIAL MASTER POZZUOLI: Well. I want to 2 conversation about 40 witnesses. And I have no idea 2 hear the argument first. So let -- 3 whether the 40 witness are lying. telling the truth 3 THE REPORTER: "Your conversation with 4 or saying something in between. I just have no 4 Ghislaine Maxwell. somebody who you have just 5 idea. I've never explored that. 5 told me you did not represent, would be a 6 Q. Okay. During the investigation, you 6 privileged communication? 7 represented Jeffrey Epstein, right? 7 SPECIAL MASTER POZZUOLI: Go back up 8 A. I never represented him alone. I 8 further. 9 represented him always with a local counsel, with 9 THE REPORTER: "When the investigation in 10 Roy Black, with two -- 10 2005 was happening. did you speak with Ghalainc 11 Q. I think we're ntiscommunicating. My 11 Maxwell?" 12 question is were you one of the attorneys that 12 MR. INDYKE: That's the question? Sorry. 13 represented Jeffrey Epstein? 13 I didn't hear the question. 14 A. I was one, yes. 14 SPECIAL MASTER POZZUOLI: That is the 15 Q. Did you represent anybody else in 15 question. 16 connection with the investigation Into Jeffrey 16 MR. INDYKE: To the extent that Alan's 17 Epstein? 17 information would invade the attorney-client 18 A. Not that I can think of. 18 privilege and work product. which Jeffrey still 19 Q. It was just Jeffrey Epstein? 19 has a right to object. and common interest. I 20 A. To my knowledge. To my recollection. 20 would object to that — I would object to 21 Q. You know Ghlslaine Maxwell, don't you? 21 Alan's answering that question and instruct 22 A. I do. 22 Alan not to answer. please. 23 Q. When the investigation in 2005 was 23 MR. EDWARDS: There cannot be any 24 happening, did you speak with (autlaine Maxwell? 24 attomey-client privilege in a communication 25 MR_ SCOTT: Don't reveal any privileged 25 between Alan Dershowitz and Ghalainc Maxwell. 29 (Pages 443 to 446) www.phi sre orting.com EFTA00615832  447 449 1 THE WITNESS: Yes. there can. Would you 1 that Alan knows about only because of his 2 like me to explain why? 2 representation of Jeffrey Epstein. then under 3 SPECIAL MASTER POZZUOLI: I would like for 3 those circumstances, that is privileged. That 4 your lawyers to explain why. 4 should not be disclosed. 5 THE WITNESS: They may not know this fact. 5 SPECIAL MASTER POZZUOLI: Let me ask a 6 but my understanding is that there was a joint 6 question. Are you suggesting that the parties 7 defense agreement, and that would therefore 7 to a joint defense agreement. that information 8 allow Jeffrey Epstein to assert the privilege 8 in and of itself is privileged? 9 in relation to Ghislaine Maxwell. That's my 9 MR. INDYKE: Under certain circumstances. 10 understanding. 10 I'm not familiar with the joint defense 11 BY MR. EDWARDS: 11 agreement back then. but it's possible. If 12 Q. (1hislaine Maxwell was never the target of 12 they're mainly parties who are witnesses. 13 the investigation, was she? 13 SPECIAL MASTER POZZUOLI: I'm going to 14 A. You're a criminal lawyer. You know that 14 reserve on this and we're going to move forward 15 you don't need to be the target of an investigation 15 because I want to err on the side of protecting 16 to need a lawyer. 16 the privilege and we can review this. Ill 17 Q. Hasn't she just recently publicly said, I 17 resent for further inquiry. 18 was never the target of an investigation? 18 BY MR. EDWARDS: 19 MR. SCOTT: Objection, argumentative -- 19 Q. Was this joint defense agreement in 20 SPECIAL MASTER POrLUOLI: At this point. 20 writing? 21 I'm going to suggest that based upon what 21 A. I have no recollection at this point. 22 Mr. Dershowitz has said. I certainly don't want 22 Q. When was the joint defense agreement 23 him invading the privilege either through a 23 entered into? 24 direct or joint defense agreement. and so at 24 A. I have no recollection. I only remember 25 this point. I will rule that he's not required 25 that there was at a point in time a joint defense 448 450 1 to answer. but I will reserve for further 1 agreement. And I would have to check. And I also 2 information. 2 don't want to -- I want to err on the side of not 3 We can go back and you can revisit this. 3 revealing privileged information. But if it wasn't 4 assuming that, you know. you have documentation 4 part of a joint defense agreement. I would be 5 or there is no such joint defense agreement. S delighted to answer the question. I would be happy 6 BY MR. EDWARDS: 6 to answer the question. 7 Q. Who were the parties to the joint defense 7 SPECIAL MASTER POZZUOLI: And we're going 8 agreement? 8 to revisit this because we may have to come 9 A. This is a long time ago. My recollection 9 back to the question. 10 is that very early on. there was a joint defense 10 MR. INDYKE: Your Honor, can I add one 11 agreement between several of the people who were of 31 consideration as well? I heard -- I don't know 12 interest to the District Attorney and to the federal 12 which attorney — 13 government. That's my recollection. And I would 13 SPECIAL MASTER POZZUOLI: Speak up. 14 always want to resolve doubts in favor of privilege. 19 MR. INDYKE: I'm going to put my -- I 15 We can check further. I would be happy to answer 15 heard — I don't know which attorney made the 16 the question if it's not privileged. 16 statement -- that work product privilege can be 17 Q. Who are the people that you remember being 17 waived by the attorney even though they're the 18 part of the joint defense agreement? 18 objections of the client. I don't believe 19 A. I'm just trying to think of whether -- 19 that's accurate. &al would also object on 20 MR. SCOTT: Don't answer anything 20 those grounds as well. 21 privileged. 21 To the extent that any kind of information 22 A. I just — I would rely on Darren for that. 22 that Alan has that's asked to be disclosed is 23 MR. INDYKE: If you're asking him who are 23 covered under the work product privilege, that 24 the parties to the joint defense agreement. and 24 should also not be disclosed, and I would 25 that would disclose information about witnesses 25 object on that basis and instruct Alan not to 30 (Pages 447 to 450) www.phi sre orting.com EFTA00615833  451 453 1 answer as well. 1 legal issues there. too. 2 SPECIAL MASTER POZZUOLI: I'm aware of the 2 SPECIAL MASTER POZZUOLI: Well I would 3 argument between counsel. The question that I 3 count on the parties to make their best 4 have is as follows: Is a — was there, in 4 argument. legal or factual. 5 fact, a joint defense agreement? What form did 5 BY MR. EDWARDS: 6 it take? And is it either subject to direct 6 Q. Do you know a person named 7 8 privilege or to work product privilege? And so those questions in that order need 7 8 IIIIIP A. No. I know vaguely who she is. 9 to be answered for me. and wed have to come 9 MR. INDYKE: Objection. To the extent. 10 back and revisit those things. So I 10 Alan. that the only way you know the answer to 11 appreciate -- thank you for the distinction. 11 that question is through your representation of 12 but that's where I am on this issue. 12 Jeffrey Epstein. then I would instruct you not 13 MR. EDWARDS: Can I ask, then. just 13 to answer that question. as it violates the 14 specifically. was Ghislaine Maxwell a party to 14 privilege. 15 the joint defense agreement? 15 SPECIAL MASTER POZZUOLI: Short of that. 16 MR. SCOTT: Asked and answered. 16 the question was straightforward. But outside 17 SPECIAL MASTER POZZUOLI: That goes hack 17 of privileged information. 18 to the question whether or not -- and this is 18 A. The name is familiar. but I don't know — 19 the question I have, is whether or not a 19 I'm sure I've met her. but I don't know her. 20 particular — is it a violation of either the 20 BY MR. EDWARDS: 21 privilege or work product privilege who the 21 Q. Fair to say she was -- 22 particular participants arc of a joint defense 22 A. I don't think I've had a conversation with 23 agreement. if one, in fact, existed? 23 her. 24 MR. EDWARDS: But if wee not able to 24 Q. Fair to say, then, she was not a party to 25 answer that question. then the communications 25 the joint defense agreement? 452 454 1 that he had with Ghislaine Maxwell I should be 1 SPECIAL MASTER POZZUOLI: I'm going to 2 able to get into. 2 stop you. We've talked about this. I'm not 3 SPECIAL MASTER POZZUOLI: I -- well. that 3 going to let you backdoor the conversation 4 assumes that the communications — I would say 4 until we flesh that out. 5 it this. For purposes of right now, that 5 MR. EDWARDS: I understand, but if it's 6 assumes the communications somehow fall outside 6 somebody who clearly was not, meaning he 7 the privilege, either work product or 7 doesn't even know her. If she clearly was not. 8 otherwise. and/or had been waived in some ■ 8 then I want to get into those conversations. 9 so that you can make inquiry. And so -- but 9 That would be the easiest thing to do. I can 10 fm not even there yet. 10 eliminate the people that may have been a part 11 But because of the sensitivity around the 11 of that. Okay. we'll leave those alone. But 12 privilege, at this point. fm going to reserve 12 people that he doesn't even know. I want to get 13 and ask the parties to inquire further as to 13 into what that person knows. 14 the four questions that I had around the joint 14 A. Let me shortcut this. To my knowledge. I 15 defense agreement. And I don't want to impact 15 never had a conversation with this person. 16 your rights to inquire until I understand that. 16 BY MR. EDWARDS: 17 THE WITNESS: I will inquire of es-counsel 17 Q. Okay. So that is somebody in these police 18 in the Epstein case, who would probably know 18 reports, if you review them, is listed as -- is 19 the answer to that, to those series of 19 described as Jeffrey Epstein's sex slave at the 20 questions. 20 time. Are you aware of that? 21 SPECIAL MASTER POZZUOLI: It's a serious 21 A. No. 22 enough issue that I don't want to — 22 Q. Okay. Do ou ever remember the 23 MR. EDWARDS: I understand and I respect 23 allegations' being a sex slave to 24 it. 24 Jeffrey Epstein? 25 MR. SCOTT: We should also look into the 25 A. Not specifically. 31 (Pages 451 to 454) www.phi sre orting.com EFTA00615834  455 4 57 1 Q. Do you ever remember the allegations of 1 A. No. No. I don't think so. My 2 various underage girls that in 2 recollection is there were four names originally. 3 addition to Jeffrey Epstein. engaged in sexual acts 3 and then there was a request by the lawyers of the 4 with minors during the investigation? 4 four named people to eliminate their names. 5 A. I don't have any recollection of that. S MR. INDYKE: Mr. Dershowitz. if you're 6 Q. In trying to ascertain whether the 6 going to go into work product, then I would 7 witnesses who came forward against Jeffrey Epstein 7 rather you —I would instruct you not to 8 then, or coming forward against 8 disclose. 9 Jeffrey Epstein now, arc telling the truth or are 9 SPECIAL MASTER POZZUOLI: At this point. 10 lying, have you gone to to ask her 10 it's 12:00. is this a good place for you to 11 questions about the circumstances of this lawsuit? 11 break? 12 A. I don't know her. 12 MR. EDWARDS: This is fine. 13 MR. INDYKE: Objection on the basis of 13 SPECIAL MASTER POZZUOLI: 1:00? 14 common interest privilege and on the basis of 14 THE WITNESS: fm happy to do 12:30. 15 attorney-client privilege and on the basis of 15 MR. SCOTT: 1:00 is fine. 16 work product privilege. 16 SPECIAL MASTER POZZUOLI: 1:00 start back. 17 SPECIAL MASTER POZZUOLI: He's already 17 We're on break. 18 answered he does not know her. 18 VIDEOGRAPHER: Going off the record. The 19 A. And I have also --I think I can say 19 time is 11:59 a.m. 20 this -- no. I can't. I can't. It's covered by the 20 (A lunch recess was held from 11:59 a.m. until 1:05 21 privilege. 21 p.m.. after which the proceedings continued in 22 BY MR. EDWARDS: 22 Volume 4.) 23 Q. Was considered a 23 24 coconspirator of Jeffrey Epstein's during the 24 25 criminal investigation? 25 456 458 1 A. There are two criminal — CERTIFICATE OF OATH 2 MR. INDYKE: Same objection. 3 BY MR. EDWARDS: 4 Q. The federal criminal investigation? STATE OF FLORIDA 5 MR. SCOTT: Don't reveal any privileged COUNTY OF BROWARD 6 materials. 7 A. No. My recollection is during the federal I. the undersigned authority. certify 8 investigation, there were four named individuals who that ALAN M. DERSHOWITZ duly personally appealed 9 were the subject of the nonprosccution agreement. I sworn on the 12th day of 10 remember two of them -- I remember at least one of January. 2016. 11 their names. I think I remember a second. but I'm Signed this 14th day of January. 2016. 12 not sure. 13 I think she was one of those who was 14 granted immunity. But the immunity was limited to i L 15 four named individuals. all of whom were women. And KIMBERLY FONT CLR 16 you could easily have found that out, and yet you E uilkyleebWjc. State 17 accused me of being one of the people who -- y Commission No. 8 18 MR. EDWARDS: This is not responsive. Expires: 7/12/2019 19 SPECIAL MASTER POZZUOLI: It was up 20 through that point. Let's move forward. 21 BY MR. EDWARDS: 22 Q. Didn't the nonprosecution agreement. 23 though, include as coconspirators -- didn't it say 24 all coconspirators of Jeffrey Epstein, including, 25 and then listed four names; that's how it went? 32 (Pages 455 to 458) www.phi sre orting.com EFTA00615835  459 461 CERTIFICATE OF REPORTER ERRATA SHEET IX/ NOT WRITE. ON IRANSCRIIT - ENTER CHANGES HERE STATE OF FLORIDA In Re. BRADLEY EDWARDS. ET AL. V. ALAN M. COUNTY OF BROWARD DERSHOIMTZ Cain No.: ALAN M. DERSHOWITZ I. KIMBERLY FONTALVO. Registered January 12. 2016 Professional Reporter. do hereby certify that I was authorized to and did stenographically report PAGE UNE CHANGE REASON the foregoing videotape continued deposition of ALAN M. DERSHOWTTZ: pages 334 through 455: that a review of the transcript was requested: and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative. employee, attorney, or counsel of any of the parties. nor am I a relative or employee of any of the panics' attorneys or counsel connected with the action. nor am I financially interested in the action. Dated this 14th day of January. 2016. Lida isarahrts of gentry. I declare that I have KIMBERLY FONTALVO. RPIt CLR read the foregoing document and that the fat stated Mit are true. Date ALAN M. DERSHOWI1t 460 January 14. 2016 COLE scar de ICISSANE P.A. Re: Bradley Edwards. et al.. v. Alan M Ikninninis Please take notice alit on the 12th day of January. 1116. you gave your deposman in the above cause As has rune. you did not waive your signanne Thc abow.addressed attorneyhat ordered a copy of this transcript and %III make an-angenrnu with you to read their ropy. Please execute the Errata SheeL which Can be found at the back of the transcript and have it returned to us for distribution to all panics. If you donor read and sign the deposition within a reasonable amount a lanc. the comma which has already been forwarded to the ordering attorney. may be filed with the Clerk of the Coon. If you wish to waive your signature now. please sign sour name in the blank at the bottom of this letter and return to the address listed below. Very truly yours. KIMBERLY FONTALVO. RPR. MR I do hereby waive my signature MAN %I insiKiv76-7 -- 33 (Pages 459 to 461) www.phi sre orting.com EFTA00615836  1 A acquaintance... agreed (3) 459:10 460:5 380:17 a.m (9) 360:17 338:9 359:3 460:22 461:3,4 Andrew (3) 334:15,15 act (1) 416:25 461:25 394:2 397:6 338:19 374:12 405:18 agreement (23) Alan's (2) 427:11 375:17,17,19 acting (2) 391:19 415:6 446:16,21 announce (1) 457:19,20 403:18 413:11 429:21 447:7 alerted (1) 339:3 ABC (8) action (2) 447:24 448:5,8 413:21 answer (98) 344:17 373:13 459:18,19 448:11,18,24 Alfredo (4) 340:11 342:17 373:21,22,23 acts (1) 449:7,11,19,22 337:15 378:7,25 353:12,23,25 374:5,7 396:25 455:3 450:1,4 451:5 379:13 354:1,3 360:2 ability (2) add (2) 451:15,23 allegation (10) 360:2,4 361:16 409:14 413:13 423:24 450:10 452:15 453:25 355:2 356:10 361:20,23,25 able (17) added (1) 456:9,22 371:24 372:2 362:15,16,22 348:8 353:2 356:24 agrees (2) 372:15 376:8 362:24 363:1,5 2E:8,9,13 addition (1) 369:22 370:2 376:13 377:3,5 363:6,20 •:2 371:15 455:3 ahead (16) 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