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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 — 42 Q. I'm asking whether he was aware of I'm not asking about -- well, let me back up. Are you aware of any witness who could be called who, as of December 30th, 2014, any person who could be called as a witness who would testify, I have knowledge that Alan Dershowitz abused a minor to support the allegation that Alan Dershowitz abused other minors? MR. SCAROLA: Outside of information gathered through attorney/client or common interest privileged communications; is that correct? MR. SIMPSON: No. It's not correct. MR. SCAROLA: Okay. Then, I'm not going to permit him to answer the question to the extent that it includes a request for information within the attorney/client and common interest privilege. MR. SIMPSON: Is it your position that the name of a person who could be called as a witness is somehow privileged? MR. SCAROLA: It is my position that any information communicated within the scope of the confidential attorney/client communication is privileged information. It is my position that any information including names communicated in the scope of ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021865