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every question in the deposition, Mr. Leopold?
MR. LEOPOLD: When you ask improper questions like that without the proper --
MR. TEIN: You're going to stop your speaking objections right now. Okay?
MR. LEOPOLD: Without the proper --
MR. TEIN: You need to stop your speaking objections.
Let's continue.
MR. LEOPOLD: Counsel, you just asked me a question and I'm going to state jit on the
record --
1
MR. TEIN: You need to stop your speaking objections. Check your rules.
MR. LEOPOLD: Excuse me. For the record, Counsel asked me a question. I'1!l state the answer on the record. He asked me the question am | going to be answering that way throughout the deposition. So long as there's improper foundation and predicate asked by the attorney, | will protect my client and | make the record where appropriate. If counsel wishes to ask an appropriate worded question with the proper foundation and predicate, | will certainly allow the client to answer the question.
MR. GOLDBERGER: Why don't you just state attorney/client privilege and just be done with it.
MR. LEOPOLD: | want the record to be
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