non BP WO NO -|- ODO OO WDN OO OT BP WO NYO —

Oo O DN OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — 46 MR. SIMPSON: Let me -- MR. SCAROLA: You are not permitted to get indirectly what you cannot get directly, and by phrasing the questions as you have phrased them, you are attempting to narrow down the source of information to an attorney/client privileged communication. I can't allow the witness to respond to that question and thus disclose information that may fall within the scope of the attorney/client privilege or common interest privilege. BY MR. SIMPSON: Q. Let me ask it -- try asking it this way: You filed this pleading in the CVRA case; is that correct? A. Yes. Q. And if I understand correctly, you have argued and the court has agreed that this is a civil proceeding; is that right? A. That's a very complicated question that would require a longer answer, so I'm just tipping you off, if you want a long answer, we can talk about that. Q. Give me a fair answer to the question. What's been your position and have there been rulings on the nature of the proceeding? A. So this requires some context here. This ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021869