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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 207 of 223 206 agreement between the witness and my clients, yes. SPECIAL MASTER: Are you asserting that privilege then? MR. SCAROLA: Yes, we are asserting that privilege and instructing the witness not to answer on the basis of the privilege that exists for Bradley Edwards and Professor Cassell. SPECIAL MASTER: So with that I'm going to grant the motion similar to what I did the other day when Mr. Dershowitz was testifying and under the reservation that that can be dealt with later in front of the judge or in front of me, whichever you choose. BY MS. BORJA: Q. Now, I understand from your testimony that Mr. Edwards did not pressure you to give false information about this matter, is that fair? A. That's fair. Q. Tell me everything that Mr. Edwards told you about this matter? MS. MCCAWLEY: Objection, that's privileged and she has not waived any privilege. She's not here testifying as to what she discussed with her lawyers. SPECIAL MASTER: You know, it's an CONFIDENTIAL