MR. SCAROLA: Excuse me. To the extent the

02:54:54 02:54:53 02:54:55 02:84:57 02:54:59 02:54:59 02:55:01 ON OM & WD 02:55:02 c<s] 02:55:03 02:55:03 10 ozssos 14 o2se0e 12 02:55:09 13 02:55:09 14 02:55:09 15 02:55:11 16 02:55:13 17 02:55:44 18 ozssis 19 ozssi7 20 02:55:18 21 02:55:24 22 02:56:23 23 02:55:25 24 02:55:25 25 02:55:25 02:55:27 02:55:27 02:55:28 02:55:33 02:55:33 02:55:34 ont onnh WD = 02:55:34 wo 02:55:35 ozss3e 10 ozssae 14 025530 12 ozss30 13 ozssao 14 ozssa1 15 ozssaa 16 orssa3 17 ossas 18 ozsss2 19 o2sssa 20 o2se02 21 028603 22 028606 23 025610 24 028612 25 35 of 46 sheets 288 MR. SCAROLA: Excuse me. To the extent the question calls for speculation, I object. MR. SIMPSON: No. I'm asking for his state of mind when he filed this document. THE WITNESS: There's no doubt that -- MR. SCAROLA: So the question is: At the time of the filing -- MR. SIMPSON: Please -- please don't coach the witness. MR. SCAROLA: No, I'm not coaching him. I just want to understand the question. You're asking what his state of mind was at the time of filing? MR. SIMPSON: Did he -- did he anticipate -- MR. SCAROLA: Because the other question was: What do you -- what's your position today. MR. SIMPSON: Mr. Scarola, really. MR. SCAROLA: That's -- that's a different question. So I just want to know which one you're asking. Do you want to know his state of mind then, or his state of mind today? MR. SIMPSON: I will take that as an objection to the form of the question. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 289 BY MR. SIMPSON: Q. Asof -- MR, SCAROLA: It's a request fora clarification of an ambiguous question. MR. SIMPSON: It's coaching the witness. BY MR. SIMPSON: Q. As of -- A. Yeah, I don't need any coaching. I mean... Q. Let me ask the question. As of December 30th -- that’s true -- as of -- A. Right -- Q. -- we agree that's coaching. A. -- but that wasn’t coaching. That wasn't coaching, so the suggestion that it’s coaching is -- is not fair. Q. Okay. We disagree. As of December 30th, 2014, did you anticipate that naming Prince Andrew in a public filing as having abused Virginia Roberts would generate substantial publicity? A. "Substantial" is a debatable word, but certainly, it's going to generate publicity, yes. Publicity about the allegations. Q. Yes. And -- and the allegations are that ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 02:56:15 02:56:19 02:56:19 02:56:21 02:56:21 02:56:25 02:56:31 02:56:32 02:56:35 02:56:39 02:56:39 02:56:42 02:56:42 02:56:48 02:56:48 02:56:49 02:56:51 02:56:56 02:56:57 02:56:57 On nn bk WD = 9 10 11 12 13 14 15 16 17 18 19 20 0287-00 21 02:57:05 22 02:57:40 23 o2s71s 24 ozsr1a 25 02:57:20 02:57:21 02:57:22 02:57:28 02:57:30 02:57:32 02:57:32 02:57:34 02:57:35 02:57:37 02:57:39 02:57:42 02:57:44 02:57:48 02:67:52 02:57:55 02:57:58 02:57:59 02:58:01 02:58:04 02:58:07 02:58:10 02:58:14 02:58:18 02:58:24 oon omh WN — 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 288 to 291 of 335 290 Prince Andrew had sexually abused Virginia Roberts, correct? A. That was one of the allegations in here, sure. Q. And the allegations that Professor Dershowitz had sexually abused Virginia Roberts, correct? A. That's right. It was in a -- what we were -- what we were starting to document and allege here was that terrible things that Epstein's criminal organization had done. Q. Let me refer you to page 6 -- A. Okay. Q. -- of your filing. It's the first full paragraph. A. Yep. Q. I'm going to read it. "Epstein also trafficked Jane Doe Number 3 for sexual purposes to many other powerful men.” A. Okay. Q. "Including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known prime minister, and other world leaders. Jane -- Epstein required Jane Doe Number 3 to describe the events that she had with these men so that he could potentially blackmail them." ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 291 Did I read that correctly? A. You did. Q. With respect to blackmail, the ability to blackmail, is that the same potential we talked about a moment ago in your testimony? A. Sure. Q. And you're referring there to -- A. Roughly, yeah. I mean, if there's something that you want clarified, go ahead and clarify it. Q. I just -- I just wanted to make sure I understand correctly that when you refer that -- to Epstein requiring Virginia Roberts to describe these events so that he could potentially blackmail them, what you had in mind was, Epstein wanted to know what Virginia Roberts did with these men so that he had the ability to threaten to disclose it if they didn’t do what he wanted them to do? A. That was -- that was part of it, yes. Q. And isn't it true you could have accomplished -- in terms of furthering Virginia Roberts's legal interests, you could have accomplished exactly the same thing by saying Epstein also trafficked ~- trafficked Jane Doe Number 3 for sexual purposes to other well-known men, period? A. No, I don't think so. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010875