IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA¶
J. CASSELL, and PAUL G.¶
CASE NO.: CACE 15-000072¶
Plaintiffs,¶
vs.¶
ALAN M. DERSHOWITZ,¶
Defendant.¶
/¶
VIDEOTAPE CONTINUED DEPOSITION OF¶
ALAN M. DERSHOWITZ¶
VOLUME 4 Pages 462 through 647¶
Tuesday, January 12, 2016 1:05 p.m. - 4:45 p.m.¶
Tripp Scott 110 Southeast 6th Street Fort Lauderdale, Florida¶
Stenographically Reported By: Kimberly Fontalvo, RPR, CLR Realtime Systems Administrator 1 and things that she has said, was 2 she lying when she said that she has flown on 3 Jeffrey Epstein's airplane?¶
4 MR. INDYKE: Objection. Work product and 5 common interest.¶
6 A. I think I can answer that question. Based 7 on material that was produced in discovery, which 8 would not be subject to privilege, there seems to be 9 evidence that she did fly on the airplane with 10 Jeffrey Epstein.¶
11 BY MR.¶
12 Q. Was she lying when she says that she was 13 flown on Jeffrey Epstein's airplane across state 14 lines at a time when she was under the age of 18?¶
15 A. I have no idea.¶
16 MR. INDYKE: Objection. Same objection. 17 Work product and attorney-client and common 18 interest.¶
19 A. I have no idea. But, again -- I just have 20 no idea.¶
21 BY MR.¶
22 Q. Is there any nonprivileged information 23 that you could review that would give you an idea to 24 answer that question or that would give you the 25 answer to that question?¶
1 BY MR.¶
2 Q. What we have here --¶
3 MR. INDYKE: Attorney-client, work product 4 and common interests.¶
5 BY MR.¶
6 Q. What we have here is only the fraction of 7 flights where Dave Rogers was one of the pilots. 8 Can you help us get the flight logs from Larry 9 Visosky, Larry, any of the flight logs from 10 the helicopters, et cetera?¶
11 A. I would love to. It would all show that I 12 wasn't on the plane.¶
13 MR. INDYKE: Same objection, same 14 instruction.¶
15 A. I will do everything in my power --¶
16 MR. SCOTT: You can make any request you 17 want to through counsel, and we'll take them 18 up.¶
19 A. But I will do everything in my power to 20 get you every flight manifest.¶
21 SPECIAL POZZUOLI: Move forward.¶
22 MR. INDYKE: We do not waive any 23 objection.¶
24 MR. SCAROLA: And that request has been 25 made.¶
1 A. Is that a question?¶
2 MR. SCOTT: No. Just Mr. Scarola --¶
3 MR. : Just that we made a request 4 for production.¶
5 BY MR. :¶
6 Q. Was Virginia lying when she says that she 7 was taken to Jeffrey Epstein's home in New York 8 while underage?¶
9 A. I have no idea.¶
10 MR. INDYKE: Same objection, same 11 instruction.¶
12 BY MR.¶
13 Q. Was Virginia lying when she says she was 14 taken to Jeffrey Epstein's ranch in New Mexico while 15 underage?¶
16 MR. INDYKE: Same objection, same 17 instruction.¶
18 A. I can tell you this. She's lying when she 19 said she met me at the ranch. So I cannot believe 20 anything she says about the ranch.¶
21 BY MR.¶
22 Q. Was she lying when she says Ghislaine 23 Maxwell and Jeffrey Epstein used sex toys on her 24 when she was underage?¶
25 MR. INDYKE: Same objection, same¶
1 instruction.¶
2 BY MR.¶
3 Q. Was she lying when she says Jeffrey¶
4 Epstein and Ghislaine Maxwell made her dress up in 5 outfits for them?¶
6 MR. INDYKE: Same objection, same¶
7 instruction.¶
8 A. Well, I can but I do have some material 9 outside of the record on that.¶
10 BY MR.¶
11 Q. Okay.¶
12 A. I know that Sigrid McCawley said that she 13 said that Leslie Wexner made her dress up --¶
14 MS. McCAWLEY: I am going to object to the 15 extent that you are trying to reveal 16 conversations that were part of a settlement 17 discussion which the judge has already sealed 18 the record on and there is a pending motion for 19 sanctions. And if you're going to start 20 revealing that information, we're going 21 directly to the Judge .¶
22 A. I am going to start revealing¶
23 SPECIAL POZZUOLI: No, I'm going to 24 stop you --¶
25 THE WITNESS: Let me tell you why.¶
1 Because I didn't get that from Sigrid or from 2 David Boise. I got it from Leslie Wexner's 3 lawyer in a totally nonprivileged 4 communication.¶
5 SPECIAL POZZUOLI: Let me stop you.¶
6 I don't believe it's responsive to the question 7 that's pending, so let's move forward.¶
8 BY MR.¶
9 10 11 12 Q. My question was, was she lying -- was lying when she says Jeffrey Epstein and Ghislaine Maxwell made her dress up in outfits for them?¶
13 14 A. I can only say that that allegation has been made regarding Leslie Wexner as well.¶
15 Q. It has nothing to do with my question.¶
16 MR. SCAROLA: Move to strike.¶
17 A. Leslie Wexner's lawyer regards that as a 18 full statement and, therefore, I can only assume 19 that it's a false statement when made about someone 20 else. I think that's relevant.¶
21 SPECIAL POZZUOLI: So with respect 22 to the --¶
23 MR. : I'm moving to strike the 24 nonresponsive portion of that answer.¶
25 THE WITNESS: He opened the door.¶
1 SPECIAL POZZUOLI: I do believe it 2 was nonresponsive in its entirety. Move¶
3 forward. Go ahead.¶
4 BY MR.¶
5 Q. Do you know Jean-Luc Brunel?¶
6 A. No.¶
7 Q. Have you ever met him?¶
8 MR. INDYKE: Same objection, same 9 instruction.¶
10 A. I have no memory of ever meeting a man by 11 that name.¶
12 BY MR.¶
13 Q. Do you know what his role was in Jeffrey 14 Epstein's life?¶
15 A. No.¶
16 MR. INDYKE: Same objection, same 17 instruction. Mr. Dershowitz, if you would let 18 me make my objections before you respond.¶
19 THE WITNESS: Right.¶
20 BY MR.¶
21 Q. Was lying when she said 22 Jeffrey Epstein socialized with Bill Clinton during 23 the relevant time period?¶
24 MR. INDYKE: Same objection, same 25 instructions.¶
1 A. My information is that 2 was lying when she said that she saw Bill Clinton on 3 Jeffrey Epstein's island. That's all I can comment 4 about with that. And she's lying about that. And 5 she's lying about how Bill Clinton got to the 6 island.¶
7 MR. : I move to strike the¶
8 Nonresponsive portion of the answer.¶
9 SPECIAL POZZUOLI: No, it's 10 relevant to what you asked. Move forward. I'm 11 not going to strike it.¶
12 BY MR.¶
13 Q. I'm going to go back to the question until 14 I get an answer, though.¶
15 SPECIAL POZZUOLI: Go ahead.¶
16 BY MR.¶
17 Q. That is, when said that 18 during the relevant time period, which we defined as 19 1999 through 2002 --¶
20 A. Let's be clear. Around August of both of 21 those years, right?¶
22 Q. I think August of '99 through October of 23 2002.¶
24 A. September, I think it is.¶
25 Q. Okay. Was she lying -- was Virginia¶
1 lying when she said Jeffrey Epstein 2 socialized with Bill Clinton during that time 3 period?¶
4 A. I don't know.¶
5 MR. INDYKE: Same objection, same 6 instruction.¶
7 BY MR.¶
8 Q. And you have no nonprivileged information 9 that would provide you the answer to that?¶
10 11 12 13 14 15 16 was in the period or outside the period. You may 17 know that; I don't. A. I have nonprivileged information that provides me that they socialized together at some point. I don't know whether it was within that timeframe at all. I know they went to Africa together on a mission of goodwill, but I don't know the date of that. So I can't tell you whether it¶
18 Q. Well, if Jeffrey Epstein and Bill Clinton 19 associated, but only at some time period either 20 before or after the relevant time period, it would 21 immediately disprove her statement that Bill Clinton 22 and Jeffrey Epstein socialized during that time 23 period?¶
24 A. I don't understand that question.¶
25 Q. No?¶
1 SPECIAL POZZUOLI: I don't 2 understand the question either. If you can 3 rephrase the question, that would be helpful.¶
4 MR. : Sure.¶
5 BY MR.¶
6 Q. If you -- do you know from nonprivileged 7 information whether Jeffrey Epstein and Bill Clinton 8 ever socialized?¶
9 A. Yes.¶
10 Q. Do you know the beginning -- when their 11 relationship began?¶
12 MR. INDYKE: Objection. Same objection, 13 same instruction.¶
14 SPECIAL POZZUOLI: Again, under 15 nonprivileged.¶
16 MR. : Under nonprivileged 17 information.¶
18 MR. SCOTT: Do you have any nonprivileged 19 information about that?¶
20 A. I remember having dinner at the home of 21 Caroline Kennedy and Ed Schlossberg with President 22 Clinton, and he basically asked me how Jeffrey was 23 doing, and led me to believe that he had some 24 relationship with Jeffrey. I don't remember whether 25 that dinner -- when that dinner was. I can probably 1 find out. But that would be nonprivileged.¶
2 BY MR.¶
3 Q. Was he still President at the time that 4 conversation was taking place?¶
5 A. I don't remember.¶
6 Q. Have you ever been, yourself, together 7 with Jeffrey Epstein and Bill Clinton?¶
8 A. No.¶
9 Q. Have you ever talked to Jeffrey Epstein 10 about Bill Clinton?¶
11 MR. INDYKE: Objection. Same objection, 12 same instruction.¶
13 SPECIAL POZZUOLI: Nonprivileged.¶
14 MR. : Yeah, nonprivileged.¶
15 A. It's hard to sort out the privileged and 16 the nonprivileged.¶
17 SPECIAL POZZUOLI: So based upon 18 the objection, I would ask that you -- unless 19 it's obvious, then no, until we sort that out.¶
20 A. I shouldn't answer that probably.¶
21 SPECIAL POZZUOLI: I'm going to 22 grant his objection at this point, again, as a 23 continuum because I want to make sure that we 24 preserve this issue for later on.¶
25¶
1 BY MR.¶
2 Q. In a previous previously in this 3 deposition, you indicated your representation of 4 Jeffrey Epstein on this subject matter began in 5 2005, right?¶
6 A. It began, I think I said, when the first 7 allegations were. I don't have an exact date in 8 mind.¶
9 Q. The relevant time period for as we've defined, is 1999 through 2002.¶
11 A. That's correct, yes.¶
12 Q. So I'm asking if you know from Jeffrey 13 Epstein, in a time period prior to your 14 representation, whether he was socializing with Bill 15 Clinton.¶
16 MR. INDYKE: Same objection, same 17 instruction.¶
18 A. Yes, yes.¶
19 MR. SCOTT: As long as it's a 20 nonprivileged situation.¶
21 A. He was.¶
22 BY MR.¶
23 Q. He was?¶
24 A. He was.¶
25 Q. So prior --¶
1 A. During the whole period of time up through 2 2005, you're saying? Yes.¶
3 Q. Right.¶
4 A. Yes, I think this dinner occurred before 5 2005, so I would -- yes.¶
6 Q. So what did Jeffrey Epstein tell you about 7 his relationship with Bill Clinton?¶
8 MR. INDYKE: Same objection, same 9 instruction.¶
10 BY MR.¶
11 Q. Prior to 2005, obviously.¶
12 A. That they knew each other and that they 13 were doing some charitable work together.¶
14 Q. Had Bill Clinton ever been to Jeffrey 15 Epstein's home?¶
16 A. I'm not aware.¶
17 MR. INDYKE: Same objection, same 18 instruction.¶
19 BY MR.¶
20 Q. What kind of charitable work was Jeffrey 21 Epstein --¶
22 A. I can tell you Donald Trump has been to 23 Jeffrey Epstein's home, and I've seen him there.¶
24 Q. Okay. What question do you think that 25 you're answering?¶
1 A. Well, you're asking about general things 2 people --¶
3 SPECIAL POZZUOLI: Let's move 4 forward.¶
5 so I mean, I gave you an example of one 6 who has been there.¶
7 BY MR.¶
8 Q. Okay. I'm specifically talking about 9 when we started with was Virginia lying when she 10 said that Jeffrey Epstein socialized with Bill 11 Clinton during the relevant time period. And now 12 I'm drilling it.¶
13 A. I don't know the answer to that.¶
14 Q. Okay. Did you understand -- did Bill 15 Clinton travel with Jeffrey Epstein?¶
16 A. My understanding from newspaper -- 17 MR. INDYKE: Same objection, same 18 instruction.¶
19 A. My understanding from newspaper accounts 20 is that they went to Africa together with some other 21 famous people, and I think maybe went to Asia 22 together as well. So the answer is yes, I am aware 23 through nonprivileged sources that they traveled 24 together, yes.¶
25 MR. SCOTT: Can we take a break in a few¶
1 minutes? I would like -- in the afternoon, he 2 gets a little tired, so I would like to, every 3 hour or so, take -- an hour and ten minutes, 4 take a couple-minute break.¶
5 SPECIAL POZZUOLI: You tell me when 6 is a good --¶
7 MR. : Maybe 15 minutes and we'll 8 switch topics, and we can take a break. Good, 9 Tom?¶
10 MR. SCOTT: Yes.¶
11 MR. : Okay.¶
12 BY MR.¶
13 Q. Was lying when she says 14 she was introduced to Prince Andrew through Jeffrey 15 Epstein?¶
16 MR. INDYKE: Same objection, same 17 instruction.¶
18 SPECIAL POZZUOLI: Under 19 non-privileged information.¶
20 A. I have seen a photograph of Prince Andrew 21 and and Ghislaine Maxwell. I have 22 myself met Prince Andrew. He came to my class at 23 Harvard Law School and there was a dinner for him, 24 and he asked about Jeffrey Epstein. We discussed 25 Jeffrey Epstein.¶
1 BY MR.¶
2 3 Q. I don't know if this was -- I believe it was attached to the deposition last time.¶
4 A. That's the photograph.¶
5 MR. SCOTT: I think it was.¶
6 MR. SCAROLA: It was.¶
7 MR. : I think it was, too.¶
8 MR. SCOTT: It was.¶
9 BY MR.¶
10 Q. So you're familiar with this photograph?¶
11 12 A. Yes, and I'm also familiar there's no comparable photograph with me in it.¶
13 Q. Okay.¶
14 MR. SCAROLA: That's not responsive.¶
15 SPECIAL POZZUOLI: Move forward.¶
16 MR. SCAROLA: Move to strike.¶
17 BY MR.¶
18 19 Q. And in this photograph, this is Prince Andrew over here on the left?¶
20 A. That's true, yeah.¶
21 22 Q. And this is in the middle?¶
23 A. I've never seen -- I've never met¶
24 , never seen her.¶
25 Q. So are you saying that she is lying when 1 she says that's her?¶
2 A. No, I just don't -- I've never seen her.¶
3 MR. SCOTT: Objection, argumentative.¶
4 A. Those are photographs I've seen¶
5 photographs --¶
6 SPECIAL POZZUOLI: Hang on one¶
7 second. Reask -- rephrase the question.¶
8 BY MR.¶
9 Q. And who is this over here on the --¶
10 SPECIAL POZZUOLI: No, rephrase the¶
11 question, the previous question about who the¶
12 young lady is next to Prince Andrew.¶
13 BY MR.¶
14 15 Q. Sure. Do you know who this lady is in the middle of this photograph?¶
16 A. On the basis of newspaper accounts, it is¶
17 reported that she is . I wouldn't¶
18 be able -- if you had shown me that picture a year¶
19 and 16 days ago, I would not have been able to tell¶
20 you that that's because I didn't¶
21 know who she was.¶
22 23 Q. And who is the other person that's in this photograph?¶
24 A. Ghislaine Maxwell.¶
25 Q. And that's somebody else that you know, 1 correct?¶
2 A. I do.¶
3 Q. And you know her through Jeffrey Epstein, 4 right?¶
5 MR. INDYKE: Same objection, same 6 instruction.¶
7 A. I wrote an article about her father's 8 death years ago, and I don't remember if I met her 9 independently. I do remember meeting her through 10 her -- I remember that the Lady Rothschild asked me 11 to meet Jeffrey Epstein, and when Jeffrey Epstein 12 came to meet me, he was with Ghislaine Maxwell.¶
13 BY MR.¶
14 Q. And when was that?¶
15 A. The first time I Jeffrey Epstein, which 16 would have been in the summer of Leslie Wexner's 17 59th birthday. That's all I can tell you is the 18 summer of his 59th birthday because I then flew with 19 Jeffrey Epstein to Leslie Wexner's 59th birthday. I 20 was presented to Leslie Wexner. Leslie would like 21 to get as birthday gifts interesting people that his 22 friends had met during the year, and so I was 23 Jeffrey Epstein's intellectual gift to Leslie 24 Wexner. And it was that year that I met Jeffrey 25 Epstein. That's the best I can date it.¶
1 Q. Okay. And Ghislaine Maxwell, you are 2 aware, is involved in litigation with right now, correct?¶
4 A. She is being sued by for 5 defamation, not for the underlying offenses, which 6 are beyond the statute of limitations, as I 7 understand it, correct.¶
8 Q. And have you spoken with Ghislaine Maxwell 9 about the allegations against her and her denials?¶
10 MR. INDYKE: Same objection, same 11 instruction.¶
12 MR. SCOTT: Don't answer it. It's 13 privileged.¶
14 BY MR.¶
15 Q. I'm asking about your conversations with 16 Ghislaine Maxwell, who's in a separate litigation, 17 civil litigation for defamation. Have you 18 personally spoken with Ghislaine Maxwell since these 19 allegations?¶
20 A. If there's no objection, I will answer.¶
21 MR. INDYKE: There was an objection. Same 22 objection, same instruction.¶
23 BY MR.¶
24 Q. Is there a joint defense agreement related 25 to the civil allegation -- actions regarding the¶
1 defamation actions that involve Ghislaine Maxwell 2 and yourself?¶
3 MR. INDYKE: Same objection.¶
4 SPECIAL POZZUOLI: What's the 5 basis -- can you explain to me what the basis 6 of the objection is -- and what was the 7 question?¶
8 MR. : Has Mr. Dershowitz spoken 9 with Ghislaine Maxwell since the allegations 10 since this defamation suit came about as well 11 as the defamation suit with Ghislaine Maxwell.¶
12 BY MR.¶
13 Q. Let me ask it cleaner. Have you spoken 14 with Ghislaine Maxwell since January 2015?¶
15 MR. INDYKE: Same objection, same 16 instruction.¶
17 BY MR.¶
18 Q. So that I'm clear, there is a joint 19 defense of the allegations regarding Ghislaine 20 Maxwell that's New York litigation and this 21 defamation case?¶
22 MR. INDYKE: There's a common interest 23 agreement in effect with respect to the 24 New York case and a common interest agreement 25 with respect to this case.¶
1 BY MR.¶
2 Q. Okay. Was lying when she¶
3 says that she was taken by Ghislaine Maxwell and¶
4 5 MR. SCAROLA: Who negotiated the agreement and when?¶
6 BY MR.¶
7 8 9 10 Q. Is there a common interest agreement in existence with respect to the allegations that have arisen since January of 2015 or that you contend covers that?¶
11 12 MR. INDYKE: Same objection, same instruction.¶
13 BY MR.¶
14 15 Q. If there is, who negotiated this agreement?¶
16 17 MR. SCAROLA: Can we have a ruling on propriety?¶
18 19 pushed me, so I let you go. SPECIAL POZZUOLI: You haven't¶
20 MR. SCAROLA: Can 21 whether we get to know 22 is a party to a common 23 Ghislaine Maxwell? we have a ruling as to whether Mr. Dershowitz interest agreement with¶
24 SPECIAL¶
25 II. McCAWLEY: Also, just this is Sigrid 1 McCawley, if any of the individuals on the 2 phone are representing Ghislaine Maxwell, my 3 understanding is the person on the phone is 4 representing Jeffrey Epstein, not Ghislaine 5 Maxwell. That needs to be clarified.¶
6 MR. INDYKE: Correct. Correct.¶
7 SPECIAL POZZUOLI: The answer is 8 correct?¶
9 MR. INDYKE: With respect to Mr. Epstein, 10 I can tell you there's a common interest 11 agreement with respect to this matter and a 12 common interest agreement with respect to the 13 Ghislaine Maxwell suit in New York.¶
14 SPECIAL POZZUOLI: Is 15 Mr. Dershowitz party to that?¶
16 MR. INDYKE: Mr. Dershowitz is party to a 17 common interest agreement with Jeffrey in this 18 case. And I believe -- I'd have to check, but 19 I believe that that would extend --¶
20 MR. SCAROLA: We want an answer from the 21 witness as to whether the witness is a party to 22 a common interest agreement with Ghislaine 23 Maxwell.¶
24 SPECIAL POZZUOLI: Then ask the 25 question, because I haven't seen the question 1 asked yet.¶
2 BY MR.¶
3 Q. Are you a party to a common interest 4 agreement with Ghislaine Maxwell?¶
5 A. If there's no objection, I'll answer it.¶
6 MR. INDYKE: I apologize. I thought we 7 were still operating under the original set of 8 objections. So I will repeat it. Same 9 objection, same instruction.¶
10 SPECIAL POZZUOLI: With respect to 11 that question, you can answer.¶
12 A. My understanding is that I am still 13 Jeffrey Epstein's lawyer. Jeffrey Epstein, I 14 understand, has a common interest or joint defense 15 agreement with Ghislaine Maxwell, so I have -- my 16 understanding is that I am bound by a common 17 agreement.¶
18 BY MR.¶
19 Q. Is this the same common interest agreement 20 that we were talking about from 2005, or is this a 21 separate common interest agreement that has been 22 signed as a consequence of the lawsuits that have 23 been filed since January 2015?¶
24 MR. INDYKE: If this is a new question, 25 I'll assert the same objection and the same¶
1 instruction.¶
2 SPECIAL POZZUOLI: And I'm going to 3 overrule the objection. And you can answer 4 that.¶
5 A. My understanding is that it's a 6 combination; that is, it reflects the previous 7 agreement and that there is a new agreement that 8 supplemented the previous agreement.¶
9 BY MR.¶
10 Q. When you say it's your understanding, is 11 this understanding in writing; meaning, is there a 12 written common interest agreement that has been put 13 in place since January of 2015?¶
14 A. I don't know.¶
15 MR. INDYKE: Same objection, same 16 instruction.¶
17 MR. SCOTT: Can we take a recess when we 18 get a chance?¶
19 SPECIAL POZZUOLI: Yes, but I'm 20 going to instruct you --¶
21 A. I don't know. I don't know the answer to 22 that, whether there's additional writing or not.¶
23 BY MR.¶
24 Q. Last question, then we take a break. Have 25 you signed any such agreement --¶
1 MR. INDYKE: Same objection, same 2 instruction.¶
3 BY MR.¶
4 Q. -- since January 2015?¶
5 A. Since January? Not to my recollection.¶
6 MR. : We can take a break.¶
7 VIDEOGRAPHER: Going off the record. The 8 time is approximately 2:09 p.m.¶
9 (Recess was held from 2:09 p.m. until 2:26 p.m.)¶
10 VIDEOGRAPHER: Going back on the record.¶
11 Time is approximately 2:26 p.m.¶
12 BY MR.¶
13 Q. Going back to the photograph, was¶
II lying when she says that she was taken to 15 London where this photograph was taken?¶
16 A. I have no idea.¶
17 MR. INDYKE: Same objection, same 18 instructions.¶
19 BY MR.¶
20 Q. Was lying when she says 21 that she was paid to have sex with Prince Andrew?¶
22 MR. INDYKE: Same objection, same 23 instructions.¶
24 A. Can you tell me what age she was when that 25 happened?¶
1 BY MR.¶
2 Q. The photograph is printed in March of 3 2001, which is when she's 17, which just means that 4 the photograph was taken sometime before that date. 5 So she was at least as young as 17 is the best that 6 I can tell you.¶
7 A. Under the age of consent, that would be an 8 act of prostitution. If she was paid $15,000 to 9 have sex with Prince Andrew at the age of 17 in 10 England, she would be guilty of prostitution.¶
11 Q. My question is, was she lying when she 12 says that she was paid to have sex with Prince 13 Andrew?¶
14 A. I have no idea.¶
15 Q. You have met Prince Andrew, right?¶
16 A. I have.¶
17 Q. He sat in the back of your classrooms?¶
18 MR. SCOTT: Objection, asked and answered 19 twice.¶
20 A. Once, yes.¶
21 BY MR.¶
22 Q. I think we went to Jeffrey Epstein sitting 23 in your classrooms, but now I'm talking about Prince 24 Andrew sat in your classroom as well, right?¶
25 A. Yes, once.¶
1 MR. SCOTT: I thought we went through¶
2 Andrew before; maybe I'm wrong.¶
3 BY MR.¶
4 Q. Have you, since the -- since January of¶
5 2015, have you contacted Prince Andrew?¶
6 A. No. I got a Christmas card from him.¶
7 Q. Have you spoke with him about the¶
8 allegations that were alleged against Prince Andrew?¶
9 A. Not to him, but to -- not to him.¶
10 Q. Have you spoke to some representative of 11 his, of Prince Andrew?¶
12 A. I need to know whether --¶
13 MR. INDYKE: Guy, sorry, I was just cut 14 off for some reason.¶
15 SPECIAL POZZUOLI: Hold on a 16 second. Go ahead and restate your question 17 so -- Darren, can you hear now?¶
18 MR. INDYKE: Yes, I can.¶
19 BY MR.¶
20 Q. My question is, have you spoken with 21 Prince Andrew or any representative of or for Prince 22 Andrew since January of 2015?¶
23 MR. SCOTT: If any of that involved work 24 product on our part, I am instructing you not 25 to answer.¶