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56
Q. Let me ask this way: We have talked somewhat
about the basis for this allegation about other minors.
Putting aside information as to what you're claiming
privilege, tell me what you knew as of December 30th,
2014, that formed the factual basis for your -- for that
allegation about other minors?
MR. SCAROLA: And I'11 instruct you not to
answer that question for the same reason that
when the same question was asked earlier, I
instructed you not to answer.
MR. SIMPSON: I'm -- maybe we are not being
clear, Jack. I'm asking him to put aside -- I
mean, certainly, he filed a pleading. You've
asserted privilege as to certain aspects. I'm
simply asking him, putting aside whatever you're
Claiming privilege for, right, so I'm not asking
you right now to tell me anything you're claiming
as privilege.
BY MR. SIMPSON:
Q. Tell me whatever is not privileged that
supports that allegation.
A. Okay. The privileged information obviously
you're asking me not to reveal at this point.
Q. I'm asking you to tell me the nonprivileged
information -- and I'm not agreeing with your privilege
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021879
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