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316 There is an intermediate category of background information as well, and I have spoken to some reporters in that capacity, yes.
Q. And -- and -- and background means that it's not for attribution, correct?
A. Right. The background means the reporter can use the information, but shouldn't attribute it to a particular person.
Q. And, in fact, you have --
A. Or let me -- let me just clarify. Some time -- well, background, I think, you know, we are now talking about sort of -- when I use the term "background," it would generally mean that this is something maybe that you want to investigate and see if you can confirm in other ways, but it shouldn't be sourced to ~- that I shouldn't be quoted directly because they are going to have to find other -~ other sources that confirm that same information.
Q. Okay. And so my question is that it is true that you have spoken with a number of reporters on background about Virginia Roberts's allegations in this case, correct?
A. Well, a number -- a few, I would say, is probably a more accurate characterization.
Q. Andin any of those background conversations,
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 317 did you ever identify Miss Roberts as someone who had been sexually abused by Mr. -- Professor Dershowitz?
A. I tried to identify myself as the attorney representing someone who said that she had been sexually abused by Dershowitz. I think you've received -- you know, we can go through -- you know, we have produced, I think, 2,500 pages of discovery. Many of those pages are media communications. And, you know, we can go through, and I think you know that there are a number of examples, many examples, where I have said, I represent a woman who has alleged that... Some verbal formulation along those lines.
I mean, attorneys represent victims all the time and -- and I don't think people generally understand when an attorney makes a statement, that the attorney is adopting and vouching for that statement. They are -- they are serving in a representative capacity.
Q. Have you finished your answer?
A. TI have.
Q. Okay. Do you -- are you a party to any fee agreement of any kind that would relate to a possible recavery from Les Wexner?
MS. McCAWLEY: Objection to the extent that it reveals any confidential communications with ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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Page 316 to 319 of 335
318 your client, my client, or any joint defense communications. You can't reveal that.
THE WITNESS: Allright. So I'm going to follow that instruction and not answer. BY MR. SIMPSON: Q. With respect to the -- what's now still Exhibit 2, the motion for limited intervention -- MR. SCAROLA: Let me just observe for the record that it's 12:02. I don't think we used the three minutes that I said I was going to give you, but we will go to 12:03 anyway. MR. SIMPSON: This line of questioning will take a little -~ a little time, so -- MR. SCAROLA: Well, what's a "little"? Oh, sO you -- MR. SIMPSON: MR. SCAROLA: MR, SIMPSON: few questions here. THE WITNESS: BY MR. SIMPSON: Q. I'm going to keep going. On the -- this is
Five minutes. So you prefer to wait then? Let me ask -- I can ask you a
Sure.
your brief actually -- A. Which -- Q. ~~ Exhibit 1. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 319
A. Which -- let me just make sure which one is it. I have Exhibit 2, but I don't think I have Exhibit 1.
Q. Oh, I probably have Exhibit 1. Let me give you Exhibit 1, I will give you 2 back so we don't lose it --
A. Okay.
QQ. -- or keep it in front of you with the others.
A. Okay. So, now, let's see. Okay. Yeah. I have it.
Q. In preparing this brief, did you personally review the citations to the record that were given to support the factual assertions?
A. As opposed to somebody else on the legal team?
Q. Yes. I'm trying to ascertain whether you, yourself, reviewed citations -- I'm going to be asking you about a deposition transcript -- citations to the record evidence that are cited as representing to the court as supporting the factual assertions?
A. Imean, I reviewed some, and others. You
know, maybe I need to -- this is starting to get into
work product. If you're asking, you know, what did Brad
do, what did you do, what did the paralegals do -- ESQUIRE DEPOSITION SOLUTIONS
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