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4l
A. Yes.
Q. Okay. Because of the privilege instruction, I'm going to ask it this way: As of December 30th, 2014, when you put your -- allowed your name to be put on this pleading as --
A. I didn't allow it. I was proud to sign this pleading.
Q. Okay. As of December 30th, 2014, when you were proud to sign this pleading, was there any witness, whether a victim or anyone else, who could be -- person, whether a victim or anyone else, who could be called as a witness who would say, I have knowledge that Alan Dershowitz abused a minor, other than Virginia Roberts?
A. I believe with further discovery we could have identified witnesses, yes.
Q. So is the answer to my question, no, when I ask: As of December 30th, 2014, when you signed this, were you aware of a single witness who would testify, I have knowledge that Alan Dershowitz abused a minor, other than Virginia Roberts?
MS. McCAWLEY: Objection. I just want to be clear. Outside the context of Virginia Roberts, what he learned through the common interest privilege.
BY MR. SIMPSON:
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021864