believe, please provide me with any such reason

02:33:52 02:33:55, 02:33:58 02:33:59 02:34:01 02:34:01 02:34:03 On Ooh WO DH = 02:34:04 ozaa0e | 9 ozaa07 10 o23at0 11 o2sat1 12 ozaatra 13 czas 14 0234.21 15 023426 16 o23e31 17 o23435 18 oz3ea1 19 ozaaas 20 or3eas 21 orsaag 22 023451 23 ozaasa 24 oraess 25 02:34:56 02:34:57 02:34:58 02:35:00 02:35:01 02:35:03 02:35:06 On Oooh WH = 02:35:06 © 02:35:06 02:35:08 1 0 02:35:08 1 1 02:36:09 1 2 02:35:10 1 3 02:36:11 1 4 02:35:42 1 5 02:35:14 1 6 02:35:16 1 7 02:35:17 1 8 02:35:20 1 9 02:35:23 20 02:36:26 21 02:35:27 22 02:35:29 23 02:35:31 24 02:35:31 25 10/20/2015 01:08:15 PM 268 believe, please provide me with any such reason. Iam certain I can demonstrate to you that it is false." Is that consistent with your recollection of the response? A. That sounds about right, yeah. Q. So Mr. Dershowitz did not ignore the letter; he responded to it, correct? A. I think that's right. Q. And go back to the first letter. A. But, now, if we are -- if we're talking about -- yeah, there's that one letter and now there's a response letter, right. Q. My question to you is: Does the statement to @ person that "we have reason to believe that you have personally observed another person in the presence of underage females and we would like to ask you about your observations,” put the recipient on notice that you, yourself, are accused of criminal conduct in abusing minors? A. Well, it puts you on notice that you're a potential, obviously, witness to this and then therefore you could have potential involvement. Let me give you a simple iHustration. It'll take about 20 seconds. If somebody says -- ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 269 Q. Well, let me back up. My first question, though, if you can answer the question. MR. SCAROLA: No. I'm sorry. The witness is entitled to complete his response. If you don't -- if you believe it to be unresponsive, you can move to strike it, but he’s entitled to complete it. MR. SIMPSON: He -- MR. SCAROLA: So go ahead and complete your response. MR. SIMPSON: Can we have a -- you can give an explanation, but a yes or no with an explanation. MR, SCAROLA: You already got that. Could we now have the completion of the response? THE WITNESS: Here's the simple illustration I think makes it pretty clear: If somebody says, we have observed you in the presence of a kilo of cocaine, we would like to question you about the presence -- about your observations of this, that doesn't directly state that you are a drug user or a drug dealer, but it certainly puts you on notice that you're associated with that criminal activity and somebody is going to question you about it. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 02:35:33 02:35:35 02:35:37 02:35:41 02:35:45 02:35:45 02:35:49 On Oa kh &W bw = 02:36:52 02:35:54 9 02:35:57 1 0 02:35:57 1 1 02:35:59 1 2 02:36:02 1 3 02:36:05 1 4 02:36:08 1 5 02:36:09 1 6 ozast2 17 02:36:14 1 8 02:36:16 1 9 02:36:18 20 02:36:22 21 02:36:28 22 02:36:34 23 o2zae33 24 02:36:33 25 02:36:37 02:38:39 02:36:39 02:36:41 02:36:44 02:36:47 02:36:50 On aah WH = 02:36:52 ozsese 9 02:36:59 10 oza702 11 ozar0s 12 o2ar09 13 ozs712 14 ozaris 15 02:37:21 16 ozar21 17 oz3723 18 ozsr24 19 ozar2r 20 o23730 21 o2z37:33 22 02:37:36 23 o2ar37 24 ozar3zs 25 Page 268 to 271 of 335 270 In the context of this case, to say, you have been observed in the -- in -- by numerous witnesses in the presence of a convicted sex offender and underage girls, and we would like to talk to you about those observations, I think that puts you on notice that you're in -- in -- in jeopardy of -- of criminal activity, particularly when you combine that with the fact that there is a duty to report child abuse in many states in this country, including the State of Florida. And so that if those observations were such that they would give rise to a reasonable inference that sex abuse was -- of children was going on and you'd be obligated to report it, as I think Mr. Dershowitz conceded yesterday, yes, you -- I think that puts you on notice that -- that those kinds of things are being alleged. BY MR. SIMPSON: Q. So, first, the letter itself, the letter from Mr. Scarola simply says, you were -- you were personally -- you personally observed Jeffrey Epstein in the presence of underaged females, correct? A. Correct. Q. It does not say, you witnessed abuse of any ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 271 minor; we have reason to believe you observed abuse of minors? A. If those words do not appear there, but come on, we -- we know -- we know in the context of this case, when somebody is asking to take a deposition about your observation of young girls, they weren't talking about preparations for birthday parties. They were talking about sexual abuse of children. And that was what Mr. Dershowitz was going to be asked about. And he did not -- he did not take that opportunity to try to clear the record; Instead, we are, you know, here today, because among other reasons, he -- he -- he wasn't deposed then. Q. I want -- I want to comment. I'm just a little bit non -- nonplussed, so I want to come back to this again. A. Well, I'm -- I have to tell you, I'm a little bit nonplussed that somebody would say that letter doesn't put you on notice that you're potentially involved in criminal activity. I mean, come on. Q. 1 -- my question wasn't potentially involved in criminal activity. We disagree about whether it does that. A. Okay. I think it does. Q. I suspect you -- that's how you read it? ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 30 of 46 sheets HOUSE_OVERSIGHT_010870