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sor & Associates Reporting and Transcription, Inc. clear where we stand thus far. Is there a recording taken of this deposition? THE COURT REPORTER: Yes. MR. LEOPOLD: Just make sure that's preserved. BY MR. TEIN: o. Go to Exhibit 20-01 -- well, before you do that are you aware that a lawyer named Jeffrey Herman filed a lawsuit on your behalf, yes or no? MR. LEOPOLD: Objection. Any conversations that you and I have had regarding that, if that is the only way by which you understand how to answer that question, do not answer. It's attorney/client privilege, as well as any conversations you may have had with the attorney from Miami. That is also attorney/client privilege. And I'm assuming -- MR. TEIN: You're actually wrong about the attorney/client privilege. MR. LEOPOLD: I'm assuming Counsel is not asking you to divulge attorney/client -- MR. TEIN: Of course not. BY MR. TEIN: Q. a are you aware that Jeffrey Herman, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 07/26/17 Page 2687 Public Records Request No.: 17-295 DOJ-OGR-00033000