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Oo oa .S wo 1) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 133 of 223 132 MS. MCCAWLEY: And again, no attorney/client privileged discussions, you can give the date. A. I don't know the date. MS. MCCAWLEY: Or time frame. A. It would have been, I think, on -- this is not attorney/client privilege? SPECIAL MASTER: Just the time frame. MS. MCCAWLEY: As long as you don't describe it. Just the time frame. SPECIAL MASTER: You can't describe the conversation but you can describe the time frame. A. That's a difficult answer because there -- MS. MCCAWLEY: I don't want you to go into considerations. Think about it in your mind. So don't talk about what you were discussing, but if you can come up with a date in your mind or a time period then you can say that. A. Let's just say the first time I mentioned Alan Dershowitz I think was in 2011. Q. Did you say -- when was the first time, not that you mentioned Alan Dershowitz but that you identified him as a sexual abuser? A. The first time I went into detail about it would have been I think in 2013, maybe early 2014. CONFIDENTIAL