34 1 Q. Okay. I want to put then aside Virginia 2 Roberts. 3 Had anyone else as of December 30th, 2014, 4 told you that Professor Dershowitz had abused any minor, 5 other than Virginia Roberts? 6 A. No one -- no other -- no other person, no 7 other person had spoken to me and told me that directly, 8 no. 9 Q. And when you say no other person, I'm 10 including not just any -- any victims of Mr. Epstein, 11 but anyone else, no one had said to you, I have 12 knowledge that Alan Dershowitz abused a minor, other 13 than Virginia Epstein -- Virginia Roberts; is that 14 correct? 15 MR. SCAROLA: Let me ask you for 16 clarification if I could. Are you asking whether 17 any person made that statement based upon the 18 direct personal knowledge of that person? And 19 the purpose for my clarification is to the extent 20 information was conveyed to Professor Cassell by 21 co-counsel, or anyone within the joint 22 representation or common interest privilege, I'm 23 not going to permit him to answer that question. 24 If it's anybody outside that, he clearly can. So 25 if you're looking for someone with direct ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021857