Page:Simpson-transcript-redacted.pdf/188

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Page 188

MR. SIMPSON: We keep books and records. We should have records of agreements and things, yeah.

MR. FOSTER: So did you not review any of those in preparation for today?

MR. LEVY: What he reviewed is privileged.

MR. FOSTER: Have you reviewed them — I'm not asking if you reviewed them with counsel. Have you reviewed them recently?

MR. LEVY: If he reviewed anything to prepare for this interview it would have been at the direction of counsel and attorney work product.

MR. FOSTER: So you do or don't know whether you have such records that would identify the date — the precise dates of the engagements?

MR. LEVY: We will —

MR. FOSTER: I'm just asking what he knows.

MR. LEVY: I think he's told you. Go ahead.

MR. SIMPSON: I'll just restate that we run a — it's a reasonably well-run company, we keep books and records. So, you know, those kinds of things are kept in our corporate files.

BY MR. DAVIS:

Q. Did Baker Hostetler or Prevezon pay for your travel to New York for the meetings in June of 2016?

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