Q. I'm -- I'm trying to close a loop here

02:20:36 02:20:38 02:20:40 02:20:40 02:20:44 02:20:47 02:20:52 On ah WH = 02:20:53 wo 02:20:58 02:20:59 1 0 o2r02 14 or2102 12 o22103 13 o22t0 14 erates 15 oz2t09 16 ozarte 17 oz2t11 18 czars 19 ozaris 20 oz2ii9 21 022120 22 o22121 23 oz2t21 24 oz2125 25 02:24:30 02:21:33 02:21:37 02:21:41 02:21:45 02:21:47 02:21:50 SON Oah SD 02:24:51 wo 02:21:55 ozerss 10 azerss 11 oz2202 12 022204 13 oz2208 14 oz 15 o2ze14 16 02:22:18 17 a22220 18 o2z2224 19 oz2225 20 oz2226 21 ozez2 22 022233 23 az2239 24 ozezat 25 27 of 46 sheets 256 BY MR, SIMPSON: Q. I'm -- I'm trying to close a loop here. A. Yeah. Q. I'm asking whether you were involved in any other cases in which claims have been made against Jeffrey Epstein for damages that are still active; they have not been resolved? A. So we are talking civil cases, unresolved civil cases against Jeffrey Epstein right now? Q. Unresolved cases seeking money from Jeffrey Epstein. MR. SCAROLA: And to the extent that that question calls for matters that are of public record, then, obviously, you can respond. THE WITNESS: Right. Yeah. None. BY MR. SIMPSON: Q. Are there -- and I'm not asking for the name. Are there any not of public record that -- A. What would bea "not"? Q. Well, if you had made a claim that's not in suit, for example. A. Oh, against Jeffrey Epstein? Q. Yes. A. Yeah. No, I don't -- I don't think there's anything. Yeah, no -- no claims against Epstein, right. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4460 257 Q. And -- and it's true, is it not, that if you're successful in the CVRA case, in setting aside the nonprosecution agreement, you expect to get other clients who will have claims against Jeffrey Epstein? A. If we -- in civil claims? Q. Claims for damages, claims for money from Jeffrey Epstein. A. That -- I mean, that starts to -- if the nonprosecution agreement is set aside? Q. Yes, if you're successful. A. haven't really -- that sounds pretty speculative. I haven't really thought about the civil -- the focus of the CVRA case is criminal. I haven't thought about, you know, whether, civil claims could somehow arise out of that. I mean, we are talking about, you know, events that took place long ago. There would be statute of limitations issues, you know. Whether they are viable civil claims at this point has not been something that I have, you know, given much thought to. Q. Sos it your testimony then that you have not thought about the question of whether success in the CVRA case may or result in you obtaining additional clients with claims for money damages against Jeffrey Epstein? ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 02:22:42 02:22:44 02:22:46 02:22:49 02:22:53 02:22:58 02:23:04 On OO & WH = 02:23:03 wo 02:23:07 oz23a07 10 o22300 11 022309 12 o2e3t0 13 oze3at1 14 oz2a12 15 02:23:15 16 o2231a 17 022323 18 oz2a24 19 02:23:26 20 02:23:26 21 022330 22 022334 23 022338 24 022340 25 02:23:43 02:23:43 02:23:45 02:23:48 02:23:50 02:23:52 02:23:55 ON Dak WH 02:23:57 o22400 9 o22402 10 o22a05 11 022400 12 o22¢10 13 oz2013 14 oz2415 15 022017 16 create 17 022423 18 o22027 19 022423 20 022430 21 o22434 22 022438 23 oz2saa 24 ozzaas 25 Page 256 to 259 of 335 258 A. Yeah. That hasn't been something that I have focused on, no. I mean... Q. tis -- it is correct, is it not, that you anticipate that if you are successful in setting aside the nonprosecution agreement, that the names of additional victims will become known; didn't you testify to that yesterday? A. I-- I'm not -- I must be confused here. I don't remember. Q. Well, wait -- I don't want to -- you know, let me ask the question -- A. Yeah. Q. _-- rather than my recollection. A. Yeah, yeah. That's what I'm not... Q. My question is: Do you anticipate that if you're successful in setting aside the nonprosecution agreement, that the names of additional victims will become known? A. Additional Epstein victims at this point? Q. Yes. A. Again, it's pretty speculative. The -- the issue -- you know, the case, you know, the events were roughly a decade ago. I mean, we are always hoping that there might be somebody additional that would come forward, but that hasn't been the focus of the ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 259 litigation. Q. Whether -- A. And you always hope that there are -- yeah, I mean, any time you file a case, ah, I hope some more, you know, witnesses will come forward to support that case, but that hasn't been the focus, trying to secure additional -- additional witnesses. Thatis a possibility, though. I mean, I think in fairness to your question, that is a possibility that, you know, if -- if the case attracts attention and -- and somebody, you know, says, you know, gosh, now that I -- I -- I -- you know, I moved away to escape Epstein and now it's safe for me to come back, or -~ or now I realize I have a claim, that's always a possibility. I certainly wouldn't want to suggest that, you know, we are ruling that possibility out. Q. And for the same reason that additional witnesses might become available -- known, additional clients might become known, correct? A. That is a theoretical possibility, yes. Q. In these four cases that you mentioned, the three that were, which you were counsel of record and one in which you were not, did you meet at any time in person with the clients? And if it's different as to some than others, tell me that, but -- ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010867