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confidential common interest privilege
communications is privileged. Yes, that's my
position.
MR. SIMPSON: Okay. That, we will have to go
to the judge on.
BY MR. SIMPSON:
Q. Let me ask you this way: As of December --
A. I'm going to write down your question because
this one sounds like it's going to be complicated.
Q. I'm going to ask it again. It's not
complicated. It's very simple. This one is going to be
very simple.
A. Okay.
Q. As of December 30th, 2014, had you spoken
personally with anyone who said, I have knowledge that
Alan Dershowitz -- I have personal Knowledge that Alan
Dershowitz abused other minors?
MR. SCAROLA: To the extent that that
question calls for information conveyed within
the scope of either the attorney/client or common
interest privilege, I instruct you not to answer.
BY MR. SIMPSON:
Q. Put aside for the moment Virginia Roberts.
I'll ask the question: Did Virginia Roberts tell you
that Alan Dershowitz abused anyone other than her?
ROUGH DRAFT ONLY
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