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respect to confidential communications that were part of providing legal services to Miss Roberts, yes, I will be asserting -- well, she's -- let me be a little more precise.
She will be asserting attorney/client privilege and I'm not at liberty to waive that for her. Q. And we will make a proffer later as to questions we would ask about your communications with Miss Roberts as we believe those are not privileged,
but -- MR. SCOTT: As well as the others. MR. SIMPSON: As well as the others that have -- MR. SCOTT: Attorney/client. MR. SIMPSON: -- attorney/client the privilege has been asserted. BY MR. SIMPSON:
Q. Let me go back to the common interest group. Is there any written agreement memorializing a common interest agreement?
MS. McCAWLEY: I'm going to object to the extent that it seeks details of an agreement. You're allowed to know the existence of the agreement; he testified to that. The details,
you're not entitled to.
ROUGH DRAFT ONLY
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