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Q. Let me ask this way: We have talked somewhat about the basis for this allegation about other minors. Putting aside information as to what you're claiming privilege, tell me what you knew as of December 30th, 2014, that formed the factual basis for your -- for that allegation about other minors?
MR. SCAROLA: And I'11 instruct you not to answer that question for the same reason that when the same question was asked earlier, I instructed you not to answer.
MR. SIMPSON: I'm -- maybe we are not being clear, Jack. I'm asking him to put aside -- I mean, certainly, he filed a pleading. You've asserted privilege as to certain aspects. I'm simply asking him, putting aside whatever you're Claiming privilege for, right, so I'm not asking you right now to tell me anything you're claiming as privilege.
BY MR. SIMPSON:
Q. Tell me whatever is not privileged that supports that allegation.
A. Okay. The privileged information obviously you're asking me not to reveal at this point.
Q. I'm asking you to tell me the nonprivileged
information -- and I'm not agreeing with your privilege
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021879