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confidential common interest privilege communications is privileged. Yes, that's my position.
MR. SIMPSON: Okay. That, we will have to go to the judge on.
BY MR. SIMPSON:
Q. Let me ask you this way: As of December --
A. I'm going to write down your question because this one sounds like it's going to be complicated.
Q. I'm going to ask it again. It's not complicated. It's very simple. This one is going to be very simple.
A. Okay.
Q. As of December 30th, 2014, had you spoken personally with anyone who said, I have knowledge that Alan Dershowitz -- I have personal Knowledge that Alan Dershowitz abused other minors?
MR. SCAROLA: To the extent that that question calls for information conveyed within the scope of either the attorney/client or common interest privilege, I instruct you not to answer.
BY MR. SIMPSON:
Q. Put aside for the moment Virginia Roberts.
I'll ask the question: Did Virginia Roberts tell you
that Alan Dershowitz abused anyone other than her?
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021866