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are Claiming privilege as -- as to, are you aware of any
person who, as of December 30th, 2014, had said, I have
knowledge that Professor Dershowitz abused other minors?
MR. SCAROLA: I'm sorry. I need to have that
question repeated.
(Thereupon, a portion of the record was read
by the reporter.)
MR. SCAROLA: That's fine. You can answer
that. Were there any nonprivileged
communications of that?
BY MR. SIMPSON:
Q. My question is -- for purposes of this
question, I'm putting aside what you're claiming is
scope of privilege. Were you aware of anyone who made
the assertion that Alan Dershowitz had abused other
minors?
A. I didn't have a named person, but I had a
pool of persons that I understood would be potentially
available to provide that kind of information.
Q. So the answer to the question is, no, you did
not have a person who had said to you that Alan
Dershowitz abused other minors?
A. I think that is slightly different than what
I just said. I didn't have a named person. I had a
pool of people in mind, the names of whom I didn't, you
ROUGH DRAFT ONLY
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