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A. The ongoing issues --
MR. SCOTT: But nothing about
communications.
A. Right. The ongoing issues relating to the
NPA, which continue to this day. And I regard
myself as his lawyer basically on all those -- all
those issues.
BY MR. SCAROLA:
Q. So, when the pleadings were filed in the
Crime Victims Rights Act regarding your conduct in
relationship to [REDACTED] and Jeffrey
Epstein, you were and still are his lawyer in the
Crime Victim's Rights Act case; is that correct?
A. certainly am bound by lawyer-client
privilege and communications, yes.
Q. Okay. You go on to say in that same
interview: "Only once in my life have I been in
that area," referring to New Mexico.
A. Yes.
Q. "Only once in my life did my travel
records show I was in New Mexico.”
A. Uh-huh.
Q. Is that an accurate statement?
A. To the best of my knowledge. I have no
recollection of being in New Mexico other than
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- the last 10 years?
I would say 15 --
Last 15 --
-- years.
-- how about the last 20 years?
I have -- 1 don't think so.
Okay.
As I stand here today, I have no
recollection of ever being in New Mexico except to
visit the Ashes in January of 2000.
I'm 77 years old. I've lived a long life.
It is certainly possible that at some earlier point
in my life -- I mean, I've been in most of the
states, But I have no recollection of ever being in
New Mexico.
And I can tell you unequivocally the only
time I was ever at Jeffrey Epstein's ranch was that
one time with my wife with the Ashes, with my
daughter. And we only stayed there for an hour and
the house was not completed. it was under
construction. And I certainly did not have any
sexual encounter or any encounter with Virginia
Roberts during that visit.
MR. SCAROLA: Move to strike the
unresponsive portions of the answer.
POPOPOPO
258
during that visit to the Ashes, which was not during
the -- the narrower timeframe.
The narrower timeframe, remember, is
[REDACTED] meets Jeffrey Epstein in the late
summer, the summer just before she’s turning 16, of
1999. She says she didn't comunence having sexual
activities with any of Epstein’s friends until nine
months later. That would put it in March or April
of 2000. This visit occurred in January of 2000.
It's the only time | recall having been in
New Mexico.
Q. Okay. I want to be sure now. You're not
just saying that you were only at Jeffrey Epstein's
ranch in New Mexico once; you are confirming your
statement on national television that you have only
been in New Mexico one time?
A. My recollection right now is that | was
only there once. I have no -- no other recollection
of -- it's conceivable when I was a very young man,
I could have been there. But I have no recollection
of having been there. It certainly -- certainly I
haven't been there recently. And during the
relevant time period, | know [ haven't been there.
Q. "Recently" means —-
A. Fifteen --
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260
MR. SCOTT: We don't agree on that point,
so let's go ahead.
MR. SCAROLA: It's of any help, I can
agree that you don't agree to any of my
objections.
MR. SCOTT: No, that's not true. I mean,
I'm trying to work with you, sir.
I have to tell you, this -- this is
obviously one of the most acrimonious
depositions I've sat through in my 40 plus
years because of the personalities involved
here and because of the personal issues. And
it's quite difficult for everybody in this
room.
MR. SCAROLA: | agree.
MR. SCOTT: And all I'm saying, and my
client is -- who's 77, is trying to defend his
life. And I understand you're trying to
vigorously -- and you're a great lawyer --
represent your clients. And it's -- this is
not the typical deposition. And we're trying
our very best, both ofus.
MR. SCAROLA: Thank you. And you're
right, you and | do agree on something.
MR. SCOTT: As you said yesterday, more
21 (Pages 257 to 260)
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