435-01.pdf

Exhibit O
Case 1:15-cv-07433-LAP     Document 435-1     Filed 09/15/16     Page 1 of 8

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