Deposition of Paul G. Cassell recounts May 2014 meeting with [REDACTED - Survivor] and Bradley J. Edwards

ooosor 8 ooos01 9 oo.0401 40 00:04:03 11 00:04:08 12 cooa0 13 00:04:16 14 coos 16 oo0ate 16 coos 17 oooats 18 oo04-20 19 00:04:21 20 00:04:21 21 00:04:24 22 00:04:28 23 00:04:28 24 00:04:30 25 00:04:31 60:04:32 00:04:34 00:04:36 00:04:39 00:04:42 00:04:45 On On hwnd = 00:04:47 wo 00:04:47 00:04:48 10 oo:o4aa 11 oooass 12 ooosss 13 oo-os:00 14 ooos00 15 cooso2 16 ooosos 17 oo-s:08 18 oo0513 19 oo-os:17 20 oo-s1e 21 00:05:21 22 00:05:23 23 00.0523 24 0-05-26 25 3 of 46 sheets Thereupon, PAUL G. CASSELL, having been first duly sworn, was examined and testified as follows: THE WITNESS: I do. CONTINUED DIRECT EXAMINATION BY MR. SIMPSON: Q. Good morning -- A. Good morning. Q. -- Mr. Cassell. As of December 30th, 2014, had you ever met with [REDACTED] in person? A. Yes. Q. And how many times had you met with her in person? A. Once. When was that? Approximately May 2014. May of 2014? Yes. Who was present for that meeting? I'm just pausing for a second because I don't -- I think we're -- Q. 1-- I'mnot-- A. -- clearly not trying to get into ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 161 attorney/client communication. Q. I’m not asking you for what was said at this point. I'm just asking you who was present. I'm going to ask you where it was, those kind of questions. A. Sure. Yeah, The main person who was present was Bradley J. Edwards, my Co-Plaintiff in this case. Q. Okay. And Miss Roberts obviously was present? A. Yes. Q. Anyone else present? A. You know, there were -- this was at the Farmer, Jaffee office here, and so persons who were associated with the law firm were assisting, but those were the main people. Q. Okay. Do you remember any of those other people associated with the law firm who were present? A. Present for, you know, coming in and assisting, I believe Brad's assistant, Maria, was there, and perhaps others at the firm, but it was -- it was basically Brad and I. Q. Was there anyone else who attended for the entire meeting or a substantial portion of the meeting? A. No. Q. Okay. How long did the meeting last? A. Approximately all day. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 00:05:28 00:05:31 00:05:32 00:05:33 00:05:38 00:05:40 00:05:41 ON Oh OD 00:05:43 ooosas 9 cosas 10 00:05:53 11 00:05:57 12 oo.0ss7 13 oo0803 14 ooo607 15 00:06:09 16 oo.0609 17 ooos12 18 00:06:18 19 oo0622 20 00:06:23 21 000627 22 00.0631 23 00.0632 24 oo0634 25 00:08:35 00:06:38 00:06:40 00:06:43 00:06:46 00:06:49 00:06:51 ON On kh ON 00:06:52 wo 00:06:54 00:06:59 1 0 00:07:04 1 1 00:07:03 1 2 00:07:03 1 3 00:07:07 1 4 00:07:07 1 5 00:07:07 1 6 00:07:07 1 7 00:07:14 1 8 00:07:13 41 9 00:07:15 20 coors 21 00:07:21 22 00:07:22 23 00:07:24 24 00:07:28 25 Page 160 to 163 of 335 162 Q. And when you say "all day," what time period are you referring to? A. 9:00 to 5:00. Q. 9:00 to 5:00. Okay. And was that through lunch; you just stayed through eight hours; is that -- what's your recollection of that? A. Yeah, I remember we were working very hard on ~~ on it, so I think we had, if I recall correctly, had lunch brought in and worked straight through that. Q. Any other meetings in person with Miss Roberts before December 30th of 2014? A. No. Q. Any telephone calls with her that you -- you had, obviously, before December 30th, 2014? A. I believe there were a couple of -- of telephone calls. Q. And can you tell us when those were? A. Let's see. Roughly September 2014. Give or take a month. I mean, you know, sometime after May and before December 30th. Q. Okay. And were those telephone calls between just you and Miss Roberts, or was anyone else on the line? A. No. It was just the two of -- just Miss Roberts and I. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 163 Q. Okay. And are you able to distinguish the calls in your mind as two separate telephone calls? A. 1I--I think there were either one or two calls. I think there may have been two, but it -- it would not have been more than two that I can recall. Q. Okay. How long did each of the telephone calls last? A. Less than five minutes. Q. I'm going to ask you a question now, but before you answer it, pause, because I believe you will be instructed not to answer it -- A. Okay. Q. -- but want to -- I think -- we disagree on the privilege -- A. Sure. Q. -- we believe it’s been waived. My question is: During the meeting, did you discuss Professor Dershowitz? MS. McCAWLEY: I'm going to object to any discussion of what my client told you during any situation where you were representing her as an -- an attorney. MR. SIMPSON: So -- and I think we had an agreement yesterday, if you follow your own counsel's instruction on not answering, are you ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010843