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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 753 ~—«~Filed 08/10/22 Page 180 of 264 1618 LC7Cmax6 Carolyn - cross A. Yes. Q. And you also had a lawyer in 2008 named Richard Willits. Do you remember Mr. Willits? A. Yes, I do. Q. The lawsuits that were filed in 2008 were after your first discussion with the FBI in 2007; correct? As Q. I'm not sure. Well, you met with the FBI in 2007 and then there was a lawsuit in 2008; right? filed, you had lawyers; right? but two first. A. Correct. Q. And before the lawsuits were A. Correct. Q. And you had meetings with lawyers about the lawsuits? A» YES. Q. And based on those meetings, you filed not one, civil complaints. Do you recall that? A. I -—- yeah. Q. I want to talk about A. First, you read Do you recall that? I don't recall. MR. PAGLIUCA: the second civil complaint 3505-043, page 41, deposit THE COURT: Okay SOUTHERN D STRICT REPORTERS, P.C. (212) 805-0300 that complaint before it was filed. If we can direct the witness to tion page 157, lines 18 through 25. F we can blow that up for the witness and the Court, please. DOJ-OGR-00018778