111 1 would be the benefit of asking him. Well, I thought the 2 benefit would be zero. What I thought we would get was 3 zero, because in 2009, an effort to depose him had been 4 made unsuccessful. 2011, an effort had been made to 5 depose him unsuccessfully. In 2013 -- 6 MR. SIMPSON: Was there an objection on the 7 phone? 8 MR. INDYKE: No. 9 MR. SIMPSON: Okay. I didn't think so. 10 BY MR. SIMPSON: 11 Q. Please continue. 12 A. In 2013, an effort had been made to depose 13 him unsuccessfully, and I mentioned a moment ago this 14 manner of people involved in Epstein's organization that 15 had been evading efforts to get information. So it 16 wasn't just that something hadn't been received in the 17 mail. It appeared to me that Dershowitz fit into a 18 pattern of not providing information and, indeed, he had 19 been party to making, supposedly, Mr. Epstein available 20 to the Palm Beach Police Department and then pulling -- 21 pulling him back. And that seemed to be a stall tactic. 22 So I didn't think we were going get any 23 information. On the other hand, now we had to waive a 24 cost of calling Mr. Dershowitz and saying, we are 25 preparing to file a pleading that identifies you. And I ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021934