MR. SIMPSON: I'm -- I think I get to ask the

02:41:34 02:14:34 02:11:36 02:11:38 02:11:39 02:11:40 02:11:40 ON Oa kh WH = 02:11:44 02:11:43 9 02:11:44 1 0 02:11:44 1 1 02:11:46 1 2 02:11:46 1 3 02:11:48 1 4 oztiaa 15 02:44:54 4 6 02:14:54 1 7 02:41:54 1 8 02:41:55 1 9 02:41:56 20 02:11:59 21 02:12:04 22 021201 23 02:12:02 24 02:12:02 25 02:42:04 02:12:06 02:12:07 02:12:10 02:42:13 02:12:13 02:12:15 ONO ah WOH = 02:42:15 oxrate 9 oatare 10 021222 11 oz1224 12 oz1226 13 on1z27 14 ozt230 15 02:12:30 16 02:12:30 17 02:12:30 18 02:12:33 49 021233 20 oziz3s 21 02:12:39 22 ori 23 ozteae 24 coxa 25 27 of 38 sheets 105 everything. MR. SIMPSON: I'm -- I think I get to ask the questions, but I was going to ask the same question. MR. SCAROLA: Wonderful. We are on the same page. BY MR. SIMPSON: Q. Mr. Cassell, you -- you mentioned that you had something that you had prepared -- A. Yes. Q. -- that would summarize -- A. Right. QQ. -- your knowledge. A. Right. Q. And now that you have exhausted your recollection, could you produce that and let's just mark it -- A. Yeah, sure. QQ. -- as an exhibit? MR. SIMPSON: We are up to Exhibit 3, 1 believe. Cassell 3. THE WITNESS: Right. Now, there -- there are two parts to this -- MR. SIMPSON: Can we mark it first and then -- ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 106 THE WITNESS: Yeah. I just want the record to be clear, that I'm only looking -- there’s -- there's a pre-December 30th section and a post-December 30th section, so the top part is the -- is what I was working off of. BY MR. SIMPSON: Q. Okay. A. Now, underneath this is -- you know, if you have questions about what happened after December 30th. Q. So you're -- you're prepared to produce the entire document, but you're clarifying? I don't -- I don't want to ask you -- if you're going to use it in your testimony, then we will mark the whole thing. MR. SCAROLA: Mark the whole thing. You can use it. MR. SIMPSON: Mark the whole thing and I'll ask you about it. THE WITNESS: That would be great. Absolutely. MR. SIMPSON: All right. I'm going to ask the court reporter to mark as Cassell Exhibit 3, a one-page document that the witness has just handed to me. It's mostly typed. It has some handwriting on it. (Cassell I.D. Exhibit No. 3 - one-page ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 02:12:45 02:12:45 02:13:10 02:13:11 02:13:13 02:13:13 02:13:13 OonN Oa kh WD fh = 02:13:16 02:13:18 9 02:43:21 10 021327 11 021327 12 o21327 13 oz13a28 14 021330 15 oz13:34 16 oztaae 17 021337 18 02:13:39 19 ozis42 20 021342 21 021344 22 02:13:46 23 oz1a4a 24 ontas2 25 02:13:53 02:13:56 02:13:57 02:13:58 02:14:02 02:14:05 02:14:07 SON Oa Rh WOH = 02:14:14 © 02:14:17 o2t417 10 021420 11 021428 12 oz1428 13 ozta20 14 oztaas 15 oztaag 16 021452 17 o2z14s3 18 oztass 19 0215.00 20 02:15:06 21 ozt508 22 ors 23 o21515 24 oasis 25 Page 105 to 108 of 151 document produced by the witness was marked for identification.) THE WITNESS: All right. So let me -- if 1 could lock at this to see if it -- the top portion of it to see if it refreshes my recollection about -- BY MR. SIMPSON: Q. Could I just see it for one second? A. Sure. Absolutely. Q. Allright. Yeah. Let me just clarify one point before you do that. A. Yes, sir. Q. In your answer, were you referring to the evidence you could recall or the information you could recall that supported your allegations as to both Virginia Roberts and other minors, or were you treating those separately? A. No, I was not treating those separately. I was -- for me, there's a common -- what -- what the law refers to as a common scheme or plan in a -- Q. Okay. A. -- acriminal conspiracy for international trafficking that involved not just a single girl, but multiple girls. So the answer was -- was with respect to -- to multiple girls. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 Q. Okay. Sol may have some questions to distinguish further between those two -- A. Yes. Q. — -- but is it fair to say that -~ and I realize you're going to refresh your recollection, but that you had exhausted your recollection of the basis for the allegation in this Exhibit 2, the motion to join as to both Miss Roberts and other minors? A. Yes. Q. Okay. So then, now, take a look at that and tell me if there's anything there that refreshes your recollection as to something that you have not yet told me about. A. So this refreshes my recollection. Sarah Kellen, I think I referred to her as Miss Kellen. Sarah Kellen was the first name. Nadia Marcinkova, Nadia was the first name there. Adrianna Mucinska was the full name of those -- that's the second echelon of the -- of the -~ of the criminal conspiracy. Oh, this refreshes my recollection that Jeffrey Epstein had answered some questions in the civil litigation. He provided, for example, names of -- of some people who were involved, but he took the Fifth when asked -- he took -- he provided names of some ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:07:28 PM HOUSE_OVERSIGHT_010836