Every indexed document

you have no obligation to respond to 19 MR. SCOTT: Wait.

I would then waive the 14 Particularly because they did so little

and what I had said -- and if you 11 into every single newspaper and media outlet in the

no relevance at all. But they knew that by

you were asked to waive the statute of 7 Why else would they have brought Prince Andrew into

correct? 3 that Paul Cassell and Bradley Edwards intentionally

yes. 1 Q. And by dropping the dime on the media when

I'm trying to find out 16 submitted that statement under oath

he didn't know the answer to that 5 not in the same place at the same time as Virginia

I — 2 media barrage that would interfere with their lives.

yes. 22 the phone number to find out who was attempting to

not so that the 16 Q. Did you ask him for the phone number?

that's a yes. 14 so that's the same thing. And I've already

period. We're not doing this today. 25 off the record

I'm moving for 24 MR. SCOTT: I will provide you the name

I told this to Virginia 20 telling you I don't know her name. And you are

Mr. Scarola. 9 And if you want to know her name

they're 3 Virginia Roberts repeatedly called this -- this

I actually did ask the question and 14 there is clearly a very significant discovery

that's part of the record. 13 There's no production of these documents. And