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42
Q. I'm asking whether he was aware of I'm not asking about -- well, let me back up.
Are you aware of any witness who could be called who, as of December 30th, 2014, any person who could be called as a witness who would testify, I have knowledge that Alan Dershowitz abused a minor to support the allegation that Alan Dershowitz abused other minors?
MR. SCAROLA: Outside of information gathered through attorney/client or common interest privileged communications; is that correct?
MR. SIMPSON: No. It's not correct.
MR. SCAROLA: Okay. Then, I'm not going to permit him to answer the question to the extent that it includes a request for information within the attorney/client and common interest privilege.
MR. SIMPSON: Is it your position that the name of a person who could be called as a witness is somehow privileged?
MR. SCAROLA: It is my position that any information communicated within the scope of the confidential attorney/client communication is privileged information.
It is my position that any information
including names communicated in the scope of
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021865