THE VIDEOGRAPHER: 10:38. o2tas: 1

02:01:34 02:01:44 02:15:10 02:46:42 02:16:42 02:16:44 02:16:46 on Oak OO bw = 02:16:50 02:16:56 9 02:16:56 1 0 oztess 14 o21701 12 o2s704 13 o2z1707 14 oxi710 15 ozi713 16 27s 17 o21723 18 ozt72s 19 o2t727 20 021730 21 o21733 22 021733 23 021735 24 021741 25 02:17:45 02:17:51 02:47:53 02:97:54 02:47:58 02:18:00 02:18:00 aN Oar Wn = 02:18:01 is) 02:18:07 oziere 10 oatasa 14 over? 12 ozreta 13 ortese 14 or1a26 15 o21820 16 o21a3e 17 o21838 18 oztear 19 021842 20 02:48:44 21 ors 22 oztaas 23 o21848 24 ozieas 25 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 ESQUIRE DEPOSITION SOLUTIONS (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 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 Page 252 to 255 of 335 254 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. ESQUIRE DEPOSITION SOLUTIONS (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 Virginia Roberts that could be deemed privileged or confidential. THE WITNESS: So what's the... ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 26 of 46 sheets HOUSE_OVERSIGHT_010866