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NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO —
36
let him do that.
MR. SIMPSON: That certainly is not privileged. That's fact.
THE WITNESS: I think this is a -- I would be happy to answer the question, but this 1s a very complicated issue that -- that I think I should confer with -- I don't want to inadvertently waive a privilege that my client, Virginia Roberts, has or other persons may potentially have, so I think I would like take to short break and confer with my counsel on that question.
MR. SIMPSON: We will take a short break.
THE VIDEOGRAPHER: We are going off the video record, 2:13 p.m.
(Thereupon, a recess was taken. )
THE VIDEOGRAPHER: We are back on the video record, 2:25 p.m.
MR. SCAROLA: So that the record is clear, we have had an opportunity to consult, and we are asserting both the attorney/client and common interest privilege, and I can tell you that there is no source of information outside of the attorney/client and common interest privilege that relates to the area of your current inquiry.
MR. SIMPSON: Well, and I'll ask the question
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021859