gov.uscourts.nysd.447706.435.1.pdf

Case 1:15-cv-07433-LAP Document 435-1 Filed 09/15/16 Page 1 of 8 Exhibit O  Case 1:15-cv-07433-LAP Document 435-1 Filed 09/15/16 Page 2 of 8 1 1 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR 2 BROWARD COUNTY, FLORIDA 3 CASE NO. CACE 15-000072 4 5 BRADLEY J. EDWARDS and PAUL G. CASSELL, 6 Plaintiffs/Counterclaim Defendants, 7 vs. 8 9 ALAN M. DERSHOWITZ, 10 Defendant/Counterclaim Plaintiff. 11 _______________________________________________/ 12 13 14 VIDEOTAPED DEPOSITION OF 15 PAUL G. CASSELL 16 TAKEN ON BEHALF OF THE DEFENDANT 17 VOLUME I, PAGES 1 to 151 18 19 20 Friday, October 16, 2015 21 1:33 p.m. - 4:31 p.m. 22 110 Southeast 6th Street 23 110 Tower - Suite 1850 Fort Lauderdale, Florida 33301 24 25 Theresa Tomaselli, RMR ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400  Case 1:15-cv-07433-LAP Document 435-1 Filed 09/15/16 Page 3 of 8 31 1 That is the basis for that particular 2 allegation. 3 Q. Mr. Cassell, does the police report you're 4 referring to, at any point, say Professor Dershowitz 5 abused any of these particular minors -- not were they 6 abused at the mansion -- but did it say anywhere that 7 Professor Dershowitz did that? 8 A. The police report itself does not refer to 9 Professor Dershowitz abusing these girls. However, when 10 you look at the police report, what it shows is a 11 pattern of egregious sexual abuse of approximately 23 to 12 24 young girls over an extended period of time at a 13 mansion that was owned by Jeffrey Epstein, who was one 14 of the closest personal friends, from what I could 15 gather, of Mr. Dershowitz. 16 And so that was -- there -- there's other 17 information. I don't want to filibuster you on that. I 18 would be happy to elaborate on that, but that is the 19 first piece of evidence that I would begin referring to. 20 If you want a more -- if you want -- just so 21 the record is clear, if you want to know all the 22 bases -- all the grounds for which that allegation 23 appears, then I would like to make a more extended 24 presentation. 25 Q. We -- we will get there. But my -- my -- I ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400  Case 1:15-cv-07433-LAP Document 435-1 Filed 09/15/16 Page 4 of 8 36 1 think you will need a standing objection. 2 MR. SIMPSON: Well, I'll just make the 3 objection there and -- 4 MR. SCAROLA: Thank you. 5 MR. SIMPSON: -- I will go back to my 6 question. 7 BY MR. SIMPSON: 8 Q. My question had nothing to do with whether 9 you could identify girls that Jeffrey Epstein abused. 10 My question was: As of December 30th, 2014 -- and you 11 don't have to give me the name right now -- is there any 12 specific girl that you had evidence Professor Dershowitz 13 abused? 14 A. What I had was the police report moving girls 15 and the girls were named in the police report, although 16 the police report that I think has been made public has 17 the names redacted. Those girls were moving through the 18 mansion at the time when, for example, household staff 19 were saying that Mr. Dershowitz was receiving massages. 20 And so, yes, I have 24 names in mind as 21 possible sexual abuse victims that Dershowitz may or may 22 not have abused. And I have not been able to pinpoint 23 exactly what happened, because the people who would be 24 in the best position to help me sort out what the names 25 were, specifically Jeffrey Epstein, among others, have ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400  Case 1:15-cv-07433-LAP Document 435-1 Filed 09/15/16 Page 5 of 8 37 1 refused to cooperate and give me those names. 2 MR. SIMPSON: Move to strike the 3 nonresponsive portion of the answer. 4 THE WITNESS: Can I ask what part of that was 5 nonresponsive in your view? 6 MR. SCAROLA: That -- that's all right. 7 THE WITNESS: Okay. 8 MR. SCAROLA: Professor Cassell, you don't 9 need to do that. 10 THE WITNESS: Okay. 11 BY MR. SIMPSON: 12 Q. If I understood you correctly, you said in 13 that answer, which I think -- strike that. 14 If I understood you correctly, you said in 15 that answer that there was a universe of 24 girls, I 16 believe you said, or approximately, that Professor 17 Dershowitz may or may not have abused; is that your -- 18 your -- your position? 19 A. That's correct. It's been impossible to 20 narrow down exactly what happened because of the lack of 21 cooperation from, for example, Jeffrey Epstein. 22 Q. If as of December 30th, 2014, based on your 23 information, Professor Dershowitz may or may not have 24 abused other minors, why did you allege that he did? 25 A. Your question, as I understood it, was did I ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400  Case 1:15-cv-07433-LAP Document 435-1 Filed 09/15/16 Page 6 of 8 152 1 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR 2 BROWARD COUNTY, FLORIDA 3 CASE NO. CACE 15-000072 4 5 BRADLEY J. EDWARDS and PAUL G. CASSELL, 6 Plaintiffs/Counterclaim Defendants, 7 vs. 8 9 ALAN M. DERSHOWITZ, 10 Defendant/Counterclaim Plaintiff. 11 ______________________________________________/ 12 13 14 VIDEOTAPED DEPOSITION OF 15 PAUL G. CASSELL 16 TAKEN ON BEHALF OF THE DEFENDANT 17 VOLUME II, PAGES 152 to 335 18 19 20 Saturday, October 17, 2015 21 8:32 a.m. - 12:14 p.m. 22 425 North Andrews Avenue 23 Suite 2 Fort Lauderdale, Florida 33301 24 25 Theresa Tomaselli, RMR ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400  Case 1:15-cv-07433-LAP Document 435-1 Filed 09/15/16 Page 7 of 8 205 1 of the flight logs support that proposition? 2 A. The face of the flight logs for the relevant 3 period of time, we can call it the hot period of time or 4 whatever you want, did not reveal the presence of 5 Mr. Dershowitz on those flights, yes. 6 Q. Okay. So during the period -- well, 7 actually, there's no flight log that shows Virginia 8 Roberts and Professor Dershowitz on the same airplane, 9 correct? 10 A. That's my understanding, yes. 11 Q. And -- 12 MR. SCAROLA: By name. You're -- you're -- 13 MS. McCAWLEY: And it -- 14 MR. SCAROLA: -- asking whether she was there 15 identified by name? 16 BY MR. SIMPSON: 17 Q. To your knowledge, isn't it correct that 18 there is no flight log that's been produced in this case 19 by any party that reflects Professor Dershowitz and 20 Virginia Roberts on the same plane, as you read the 21 flight log? 22 MR. SCAROLA: I'm sorry. Are you asking 23 whether those same names appear on the flight log 24 together? 25 MR. SIMPSON: My question, I think, is ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400  Case 1:15-cv-07433-LAP Document 435-1 Filed 09/15/16 Page 8 of 8 233 1 A. Yes. In part. I mean, there are other 2 reasons it's significant, as we have been talking about, 3 names are circled who appear to have relevant 4 information on Jeffrey Epstein's criminal activities. 5 Q. Donald Trump was a friend of Jeffrey Epstein; 6 is that not correct? 7 A. I really don't -- my understanding is, yes, 8 but I -- I don't have a lot of information about Trump. 9 Q. It's true also, is it not, that Mr. Trump was 10 a frequent visitor to Mr. Epstein's residence? 11 A. I -- I know that he visited frequent. I -- I 12 don't have a lot of information about Trump. 13 Q. And his name is circled in this book; is it 14 not? 15 A. I believe it is. 16 Q. Based on him -- assuming he's a frequent 17 visitor to Mr. Epstein's home, and that he's a friend of 18 Mr. Epstein's, and that his name is circled in this 19 book, do you infer that he was engaged in criminal 20 sexual abuse of minors? 21 MS. McCAWLEY: I'm going to object to the 22 extent that your answer would reveal anything 23 that my client has told you. 24 THE WITNESS: No. 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400