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168 spoken with any other lawyers at Mr. Boies' firm?
A. My recollection is, no.
Q. And after December 30th of 2014, have you spoken with Mr. Boies about Virginia Roberts's allegations against --
MS. McCAWLEY: Again, I'm going to object.
BY MR. SIMPSON:
Q. -- Professor Dershowitz?
MS. McCAWLEY: Sorry. I will let you finish.
I'm objecting to this. I think it gets into the substance of conversations under the common-interest privilege, whether there was a conversation, but you're getting into the substance of what the conversation was about, and I think that is a violation of her -- her privilege.
MR. SCAROLA: And just so that I can clarify our position on the record, I think that we can identify the general subject matter in order to support our position that it falls within the common-interest privilege. So we are willing to answer the question about the general subject matter to support our assertion of common-interest privilege, but not get into the substance of the communications beyond that.
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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169 MR. SIMPSON: And I believe it's the same question that was answered a moment ago for a different time period, and again, I'm not asking for any substance. I'm just asking whether, since December 30th, 2014, you have discussed the allegations by Virginia Roberts against Professor Dershowitz. THE WITNESS: I would like to confer with my counsel on that question. It gets into a complicated legal issue that I'm not sure I can -- MR. SIMPSON: You want to confer on a privilege issue; is that right? THE WITNESS: I want to confer with my counsel before answering that question anyway. MR. SIMPSON: I just want to clarify -- MR. SCAROLA: With respect to privilege. MR. SIMPSON: All right. As long as it's with respect to privilege, you're entitled to do that. THE WITNESS: Okay. THE VIDEOGRAPHER: We are going off the video record, 8:45 a.m. (Thereupon, a recess was taken.) THE VIDEOGRAPHER: We are back on the video ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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170
record, 8:47 a.m.
MR. SCAROLA: As it turns out, while we may reach some issue of privilege at some point in this discussion, the answer to your pending question is, no, so there's no privilege concern.
MR. SIMPSON: All right. I'll -- I'll ask the witness for the --
MR. SCAROLA: Sure.
MR. SIMPSON: -- the -- the answer. I'll move to -- I'll reask the question.
THE WITNESS: Sure, That will be good.
BY MR. SIMPSON:
Q. My question is: I believed you had already answered the question as to before December 30th, 2014, you had discussed Miss Roberts’ allegations against Professor Dershowitz, and you said, no; is that right?
MR. SCAROLA: David Boies,
MR. SIMPSON: David Boies. I'm sorry.
THE WITNESS: Before December 30th, no discussions that I can recall with David Boies.
BY MR. SIMPSON:
Q. After December 30th, 2014, did you have any discussions with David Boies about Professor Dershowitz?
A. CanI--
MR. SCAROLA: You can answer yes or no.
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 171 THE WITNESS: Yes. BY MR. SIMPSON:
Q. You did.
A. Yes.
Q. What was the substance of those communications?
MS. McCAWLEY: I'm going to object to that. You -~ it's under the common-interest privilege and it's Virginia's privilege to waive, and she's not waiving it.
MR. SIMPSON: Okay,
MR. SCAROLA: We -- we assert the common-interest privilege with regard to the substance as well.
MR, SIMPSON: All right. And that -- that will be -~ that will be asserted as to all questions about the substance of the discussions with Mr. Boies; is that right?
MR. SCAROLA: I can't say that for sure.
MR. SIMPSON: All right. Let me ask my question then.
MR. SCAROLA: And let -- maybe this -- maybe this will help you and maybe it won't. But, obviously, there have been some public statements with regard to this general area. If the
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