Q. That because he visited, according to

01:53:37 01:53:37 01:53:40 01:53:45 04:53:52 01:53:55 01:53:57 01:53:59 04:54:02 01:54:05 01:54:07 01:54:05 04:54:43 04:54:15 01:54:15 04:54:18 01:54:48 01:54:23 01:54:26 01:54:30 01:54:33 01:54:39 01:54:42 01:54:45 01:54:47 01:54:47 01:54:48 04:54:49 04:54:53 04:54:55 01:54:57 01:54:55 01:54:56 01:54:57 01:54:57 01:54:58 01:54:59 01:55:01 01:55:02 04:55:06 01:55:08 01:55:09 On Aah OND = 9 10 11 12 13 14 15 16 17 18 19 015428 20 orseze 21 01:54:28 22 23 24 orsass 25 ON Dab WON «= wo 10 11 12 13 14 15 16 17 18 19 20 21 oxssi10 22 04:55:43 23 01:55:15 24 01:55:19 10/20/2015 01:08:15 PM 25 244 A. Right. Q. That because he visited, according to Mr. Rodriguez, several times a year in 2004, 2005, he must have visited several times a year in 2000 -- 19- -- middle of 1999 to the middle of 2002. A. Ididn't say must have. I said that that's going to be evidence of the common scheme and plan, and then, in the absence of, you know, some falling out between people or somebody becoming, you know, more associated or less associated with a criminal organization. I mean, if you want to get into the circumstantial evidence, in 2003, there's an article on which, you know, Dershowitz identifies himself -- Q. Let me interrupt you because I'm asking -- A. Okay. QQ. -- about -- my only question is evidence of how -- not anything, whether engaged in conduct or didn't engage in conduct, just how many times he came during this period. A. Right. MR. SCAROLA: Excuse me, counsel. That's the reason why I asked you to clarify whether you want to limit this to direct evidence or whether you want all of the evidence including circumstantial evidence, because as we both know, ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 245 circumstantial evidence is good evidence. A well-connected chain of circumstance can be -- MR. SIMPSON: MR. SCAROLA: MR. SIMPSON: MR. SCAROLA: as compelling proof as direct evidence of a given fact. That's the law. If you don't want -- We really don’t need a speech. -- a well-connected -- We really don't -~ ~- chain of circumstance may be MR. SIMPSON: Really, sir. MR. SCAROLA: -- the circumstantial evidence -- MR. SIMPSON: Mr. Scarola -- MR. SCAROLA: -- tell us that. MR. SIMPSON: -- please don’t make speeches, and please don't coach the witness. MR. SCAROLA: Just tell us that. I'm not coaching the witness. I'm asking you -- you're asking ambiguous questions. MR. SIMPSON: There's nothing ambiquous -- MR. SCAROLA: If you want only direct evidence, we will give you only direct evidence. If you want a full and complete answer, it's got to include circumstantial evidence, so don't cut him off when he's giving you that. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 01:55:20 01:55:23 01:55:26 01:55:27 01:55:27 04:55:27 01:55:27 04:55:32 01:55:37 On Da bP On = 9 oxss43 10 orssaa 11 orsss2 12 0155s 13 orssss 14 015559 15 o1se03 16 orscos 17 orseoo 18 orser2 19 orse-te 20 0156.25 24 ors628 22 018634 23 orsea7 24 orseso 25 01:56:44 01:56:47 04:56:52 01:56:56 01:56:57 01:56:58 01:57:01 01:57:05 04:57:07 On Dah OD ~- 9 oxsr14 10 ors721 114 ors72s 12 os727 13 orsr29 14 ovs730 15 o1s7a1 16 os733 17 ovsras 18 ors7r39 19 ors7320 20 ors7a0 21 ors742 22 orsraa 23 018754 24 orsrsa 25 246 MR. SIMPSON: Really, objecting to the form of the question preserves all of any problems there may be with the question. MR. SCAROLA: No, sir. MR. SIMPSON: We don't need a speech. MR. SCAROLA: It doesn't. It doesn’t. BY MR. SIMPSON: Q. Mr. Cassell, is it your testimony that, from Mr. Rodriguez's testimony about how often he says Professor Dershowitz visited in a 2004/2005 time frame, it's fair to draw an inference about how often he visited in an earlier -- three-year earlier time frame? A. In the circumstances of this case, absolutely. Q. And would it be fair to infer from the number of times that Donald Trump visited three years later, how often he visited at an earlier period? A. I did not investigate the circumstances involving Trump. He wasn't somebody that was coming up. Q. Were you aware on December 30th of 2014 that Donald Trump was quoted in Vanity Fair as saying: "I've known Jeff" -- referring to Epstein -- oh, I'm sorry. It was a New Yorker Magazine, not Vanity Fair, That he was quoted as saying: "I've known Jeff" -~ referring to Epstein -- "for 15 years. Terrific quy. And he's a fot ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 247 of fun to be with.” It even said that: "He likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it, Jeffrey enjoys the social ~~ social life"? Were you aware of that on December 30th, 2014? A. Possibly. I mean that sounds vaguely familiar. Trump has just not been somebody that -- that I’ve paid much attention to in this case. Q. Based on that statement, and the facts we discussed earlier about Mr. Trump visiting and being a friend, and the other circumstances we discussed, are you suspicious about whether he engaged in sexual misconduct with minors? MS. McCAWLEY: I'm going to object to the extent that you can't reveal anything that my client has informed you of, THE WITNESS: Right. If we set aside that information, I'm not -- I'm not suspicious, no, not given the information I have. BY MR. SIMPSON: Q. Okay. So notwithstanding that his name is circled in the address book, he was a good friend, he visited often, and he was quoted as saying that Jeff was a terrific guy who liked young women almost as much as Trump did, you're not even suspicious? ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 Page 244 to 247 of 335 24 of 46 sheets HOUSE_OVERSIGHT_010864