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and you can tell me if you'll answer this question. BY MR. SIMPSON:
Q. Who, as your understanding as of December 30th of 2014, with which attorneys did you have a common interest privilege?
A. Brad Edwards from, obviously, the law firm that I've been working with here. Also attorneys from the Boies Schiller law firm who were representing Virginia Roberts at that time.
Q. Anyone else?
A. The -- at that time, on December 30th, I don't know that it's directly responsive to your question, but also the Scarola law firm, Mr. Scarola in connection with litigation he was handling for Brad Edwards.
Q. Any any other law firm lawyers that you had a common interest privilege with?
A. No.
Q. And you're going to refuse to answer questions about communications with Miss Roberts; is that right?
A. Sure. Those are -- well, some -- some communications are public, we will discuss those, I'm
sure as the deposition moves along, but certainly with
ROUGH DRAFT ONLY
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