MR. DAVIS: On page 5 —
MR. FOSTER: Is it something that you discussed with him that you were doing?
MR. SIMPSON: We would discuss inquiries that we had received from reporters, yes.
MR. FOSTER: And that you were answering?
MR. SIMPSON: To the best of our ability. I mean, we obviously didn't tell people about the existence of these things for a long time.
BY MR. DAVIS:
Q. On page 5 of that same exhibit, paragraph 32 there's a portion of the sentence — and I'll just read this for background before we move on to another segment. I think this is relevant for context. There's a portion here in which Steele's attorneys state that he gave — that the Defendants gave "Off-the-record briefings to a small number of journalists about the pre-election memoranda in late summer/autumn 2016." I'd like to provide Exhibit 5 which is the second filing by Mr. Steele's attorneys.
MS. SAWYER: Patrick, you've represented this one as the second filing. Are we sure these are —
MR. DAVIS: Second for the purpose of this interview, second one we're referencing.
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