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10/20/2015 01:08:15 PM
252
THE VIDEOGRAPHER: 10:38. o2tas: 1
(Thereupon, a recess was taken.) oztess 2
THE VIDEOGRAPHER: We are back on the video ontess 3
record, 10:49 a.m. oztess 4
BY MR. SIMPSON: oasas9 | 5
Q. Back on the record. My question, oxto00 «6
Mr. Cassell, was: Whatis your best estimate of how ozs903 7
much money you have made representing victims of Jeffrey o21903 8
Epstein? coi0s | 9
A. In which case are we talking about? o21906 10
Q. In -- in any case. Combined total. ozsa0a 14
A. Okay. With regard to the CVRA case, that's ozis00 12
pro bono, no money there. With regard to the other o2t912 13
cases, I'd like to answer your question, but due to ozto1s 14
confidentiality obligations that have been imposed upon | 21915 15
me by Jeffrey Epstein, in the course of negotiating ozta21 16
those cases, I'm not permitted to answer that question. | 021927 17
MR. SCAROLA: We are certainly willing to oz1928 18
respond appropriately to a court order in that o2to33 19
regard, but it requires a court order to release ozte3s 20
us from the contractual confidentiality ozt93¢ 21
obligations that we are under. o2rea0 22
BY MR. SIMPSON: ort942 23
Q. Is it your testimony, Mr. Cassell, that there oxtea2 24
are confidentiality agreements with Mr. Epstein that ores 25
(954) 331-4400
253
preclude you from giving the total amount paid without ozteaa 1
breaking it down into particular cases? ozieas | 2
A. I'm sorry. I didn't understand. ozi94a « D
Q. Oh, maybe that wasn't clear. Let me do it orroso 4
this way so we avoid -- oztese 5§
A. Yeah, caress = §
Q. -- the confidentiality issues. oziesa 7
In how many cases have you been counsel for a o22000 B
person suing Mr. Epstein alleging that she was a victim? o22z00 9
A. Counsel of record? 022004 10
Q. Put it this way. How -- weil, start with o22004 11
that, counsel of record. oz2008 12
A. I believe three. oz2008 13
Q. Okay. And in addition to those three, have 02:20:00 14
you assisted other counsel in some way without becoming 22010 15
counsel of record in cases by women suing Mr. Epstein 022013 16
alleging that they had been abused? o22018 17
A. I believe there’s one other case in addition 022023 18
to the counsel of record case. 022028 19
Q. And without telling me -- 022028 20
A. Id--I'd have to go double-check my record. 022020 21
This is an approximate best recollection. 022033 22
Q. All right. 022035 23
A. It's about four. 02:20:38 24
Q. To the best of your recollection, you were 022036 25
(954) 331-4400
Page 252 to 255 of 335
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counsel of record in three cases and you were involved
in another case -- at least one other case in which you
did not appear --
A. That's right.
Q. -- as counsel of record; is that correct?
A. That's -- that's my recollection right now,
yeah.
Q. Allright. How many of those cases have been
resolved at this point?
A. AHL. All -- of the four, I recall all four
have been resolved.
Q. Okay. Without telling me the amount, did you
receive -- all four were settled; is that right?
A. Correct.
Q. Without telling me the amount, is it correct
that in ail four of those cases, you received a legal
fee?
A. I think that starts to call for a question IT
need to consult with my attorney about.
Q. Simply the question of whether in each of
them you received a fee?
A. I just want to...
THE WITNESS: Is -- is there any problem --
MR. SCAROLA: You can respond to that. You
can answer yes or no to that question.
(954) 331-4400
255
THE WITNESS: Yes, I received something.
BY MR. SIMPSON:
Q. Okay. Was the fee -- and if it's different
for the -- the cases, tell me, but was it a contingent
fee or some kind of hourly fee?
MR, SCAROLA: That -- that does get into
attorney/client privileged matters. The terms --
MR. SIMPSON: You're instructing him not to
answer?
MR. SCAROLA:
representation are attorney/client privilege. I
-- the terms of the
instruct him not to answer.
MR. SIMPSON: All right.
BY MR. SIMPSON:
Q. In addition to these four cases that have
been resolved, are you representing any other clients
who are alleging, in a case seeking monetary damages,
that they were abused by Jeffrey Epstein?
A. I--
MS. McCAWLEY: I’m going to object to the
extent that this seeks any information related to
[REDACTED] that could be deemed privileged
or confidential.
THE WITNESS: So what's the...
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