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Oo O DN OO FF WwW NY = NO RO PRP LP PNMO NO | S| S| |S FS FS S| S| | | no Bb WO NO F- ODO OO WDNnN DO OT BP WO NYO — Q. Would you also agree that if there is any doubt as to whether the allegations might be an issue in the action, courts will deny the motion? A. That was our position in our response to Professor Dershowitz's motion to strike, yes. Q. And in considering a motion to strike, the court must consider the pleadings in the light most favorable to the party making the pleading, correct? A. Yeah, that's our position, that was our position, yes. Q. Okay. In your view, is it -- for an attorney to ask a leading question at a deposition, does the attorney have to have a good-faith basis to believe that that question is true or the facts assumed in that question are true? A. I mean, that's a broad question, but as a general rule, yeah. Q. As a general rule -- I'm not being very articulate -- A. Yeah. Q. -- you don't ask a leading question about a fact unless you have a good-faith basis to believe that facts is true, correct? A. I think that's right. I mean I don't know if over the last day and a half, you know, narrow questions ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021830