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are Claiming privilege as -- as to, are you aware of any person who, as of December 30th, 2014, had said, I have knowledge that Professor Dershowitz abused other minors?
MR. SCAROLA: I'm sorry. I need to have that question repeated.
(Thereupon, a portion of the record was read
by the reporter.)
MR. SCAROLA: That's fine. You can answer that. Were there any nonprivileged communications of that?
BY MR. SIMPSON:
Q. My question is -- for purposes of this question, I'm putting aside what you're claiming is scope of privilege. Were you aware of anyone who made the assertion that Alan Dershowitz had abused other minors?
A. I didn't have a named person, but I had a pool of persons that I understood would be potentially available to provide that kind of information.
Q. So the answer to the question is, no, you did not have a person who had said to you that Alan Dershowitz abused other minors?
A. I think that is slightly different than what I just said. I didn't have a named person. I had a
pool of people in mind, the names of whom I didn't, you
ROUGH DRAFT ONLY
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