Case 1:19-cv-03377 Document 1-13 Filed 04/16/19 Page 4 of 4 the July 6, 2015 meeting, Mr. Dershowitz expressed to me that he believed he was making progress in convincing Mr. Boies that the client was mistaken in identifying Mr. Dershowitz as someone with whom she had sex. I told Mr. Dershowitz that I thought he was overly optimistic and reading things into what Mr. Boies was saying and hearing what he wanted to hear. I truly believe this was the case, i.e., that Mr. Boies was making careful and guarded statements consistent with statements lawyers often make in settlement discussions and that Mr. Dershowitz, who urgently wanted the case to go away, was reading things into those statements that weren’t there. 10. My recollection is that, at all times, Mr. Boies remained adamant that the client’s assertions about Mr. Dershowitz represented her best, honest recollection. For example, at one point, Mr. Dershowitz told Mr. Boies that Ms. Roberts could well believe that she had sex with Mr. Dershowitz because she might be confusing Mr. Dershowitz with Nathan Myhrvold who spent a lot of time with Mr. Epstein and who looked a lot like Mr. Dershowitz. Mr. Dershowitz urged Mr. Boies to convince his client that she was mistaken and that she had actually had sex with Mr. Myhrvold. Mr. Boies told Mr. Dershowitz that he obviously did not have personal knowledge as to what had or had not happened, but that he had taken steps to verify that Ms. Roberts was telling the truth as she believed it. Shortly thereafter, | came to understand that Ms. Roberts had taken, and passed, a lie detector test. 11. At no time in my presence, whether in the presence of Mr. Dershowitz or outside of it, did Mr. Boies ever say that he believed or was convinced that Ms. Roberts was mistaken or that Mr. Dershowitz did not have sex with Ms. Roberts. Ms. McCawley said very little at the meetings. Furthermore, I do not recall Ms. McCawley ever expressing any doubt that Mr. Dershowitz had sex with Ms. Rob