Datasets:
title: 'House Oversight: Estate Documents (Nov 12) (HOUSE_OVERSIGHT_010865)'
source: 'House Oversight: Estate Documents (Nov 12)'
sourceUrl: https://www.justice.gov/epstein
date: '2026-01-01'
category: House Oversight
eftaNumber: HOUSE_OVERSIGHT_010865
ocrPages: 1
ocrChars: 5331
ocrElapsed: 0
parseTier: external-legacy
engine: engine undisclosed (ep-nov-12.greg.technology mirror)
externalSource: greg-ep-nov-12
externalLicense: not granted
externalCredit: ep-nov-12.greg.technology
externalUrl: https://ep-nov-12.greg.technology
248 01:58:01 1 A. Not - you know, let's break that down in a 01:58:05 2 couple pieces. 01:58:06 3 The fact that his name is circled, if I were 01:58:08 4 01:58:10 5 running an FBI investigation, I'd go send somebody to see what he knew about it, but no, it would take a lot 01:58:13 6 more for me to become suspicious that somebody is 01:58:16 7 involved in -- in sexual activity like that. 01:58:19 8 Q. Okay. So you would agree with me then, that 01:58:21 9 the fact that a person often visited the mansion, the 01:58.24 10 person -- the fact that a person was a friend of 01:58:27 11 Mr. Epstein for 15 years, the fact that the person had 01:58.32 12 stated publicly that: "Mr. Epstein liked young women 01:58:36 13 almost as much as I do myself," and the fact that the 01:58:40 14 name is circled in the address book is not sufficient to 01:58:43 15 raise a suspicion that that person engaged in sexual 01:58:47 16 misconduct? 01:58:47 17 A. So.. 01:58:48 18 Q. Yes or no. It's a yes or no question. 01:58:51 19 A. It requires - 01.58:51 20 MR. SCAROLA: You're not required to answer 01:58:53 21 yes or no, if a yes or no response alone would be 01:58:55 22 misleading. 01:58:56 23 THE WITNESS: The problem is the word 01:58:57 24 "suspicion." I'm not particularly suspicious on 01:58:59 25 those facts, but it -- you know, what do you mean ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 249 01:59:03 1 by "suspicion"? If I -- if I were running an FBI 02:00:56 1 01:59:04 2 investigation and somebody circled a name as -- 02:00.57 01.50,06 3 as saying, look, this fellow may have some 02:00,58 3 01:50:09 4 information, I'd go follow up on that. 02.01.01 4 01:59:10 5 If you say that's suspicion, then the answer 0201.02 5 01:59:13 6 would be, yes. But I - you know, based on that 0201:03 6 01:59:15 7 information alone, no. I mean that -- that 020105 7 01:59:18 8 wouldn't -- wouldn't be enough for me to, you 020100 8 01:59:22 9 know, invest time and energy into that particular 0207:08 g 01:59.26 10 possibility. 02-01.09 10 01:59:26 11 BY MR. SIMPSON: 0201.10 11 01:59.27 12 Q. Okay. So none of those facts are sufficient 020111 12. 01:59:31 13 even to justify spending time and energy, correct? 0201:11 13 01:59:34 14 A. Unless -- if I'm running -- this is - again, 0201:11 14 01:59.37 15 what do you mean by "suspicion"? Time and energy in the 02.01.13 15 01:59:42 16 context of somebody who is running a pro bono case with 02.01:13 16 0150:4 17 limited resources to try to figure out what the sex 020118 17 01:59:47 18 trafficking ring's going to do, I'm not going to chase 020116 18 01:59:49 19 after that rabbit. It seems farfetched. 0201.20 19 01:59:53 20 I'm going to focus my efforts on the people 02.01.22. 20 01:59:53 21 who appear to be more directly involved. 020121 21 01:59:56 22 Q. Okay. So based on the facts that I gave you 02:01:26 22 01.50.59 23 a moment ago, you think it's farfetched that Donald 02:01.28 23 02:00:04 24 Trump was engaged in abusing minors? 020120 24 02:00:07 25 A. If that's all I had, I would not invest time 02.0132 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 25 of 46 sheets Page 248 to 251 of 335 250 02:00:11 1 and energy in that, right. 02.00.12 2 Q. And you referred to your pro bono case. What 02:00:16 3 is your best estimate of how much money you have made 02:00.21 4 representing victims of Jeffrey Epstein? 02:0024 5 A. In which case are we talking about now? 02:00.26 6 Q. Any -- any case representing a victim of 02.:00.28 7 Jeffrey Epstein. 02:00:29 8 A. I need to confer with -- 02:00:33 9 MS. MCCAWLEY: Yeah. I'm going to object. 02:00:33 10 BY MR. SIMPSON: 02:00:34 11 Q. And that -- that's a fact -- that's not a 02.:00.36 12 privileged question. That's a factual question. 02:00:37 13 A. Factual. Well, there are -- there are -- 02:00.38 14 Q. Just how much money? You don't have to tell 02:00:41 15 me who the clients are. Just how much money? 02.00.44 16 • Okay. I need to -- 02:00.46 17 MR. SIMPSON: There's a question pending. I 02:00:47 18 object to a break. There's no possible 0200.48 19 02:00.48 20 privilege. MR. SCAROLA: He has a privilege -- he has a 02:00:50 21 privilege question. He wants to consult with 02.00:51 22 counsel. 02:0051 23 MR. SIMPSON: Well, really? My question is 02:00:53 24 how much money, and that's privileged? 02:00:55 25 MR. SCAROLA: It may be. I don't know. We ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 251 need to talk. THE WITNESS: That's why I need to -- MR. SCOTT: There's no federal law or state law that supports that financial information and fees is privileged. MS. MCCAWLEY: We can argue about that because that's in my motion, so we can argue about that. MR. SIMPSON: Well, can -- can -- MR. SCOTT: That one, I know all about. MR. SCAROLA: You're objecting to our taking a break -- MR. SIMPSON: I am objecting -- MR. SCAROLA: -- while this question is pending? MR. SIMPSON: That's correct. MR. SCAROLA: It is our position that the witness has a legal question about privilege. We are going to take a break. We are going to talk about it. It may turn out that it's not a problem at all. I don't know. THE VIDEOGRAPHER: We are going off the video record, 10:38. MR. SIMPSON: With my note, we are taking a break over my objection. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010865