Page:Simpson-transcript-redacted.pdf/224

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Page 224

MR. DAVIS: Anyone we've left out.

MR. LEVY: The answer to that might implicate privilege or other obligations. So he's going to decline to answer the question.

BY MR. DAVIS:

Q. To the extent there's any portion of the answer to that question that would not implicate those privileges, I would ask that you reveal those.

A. I'm not sure I see how I could answer that question without getting into privileged areas.

MR. FOSTER: Again, what privilege?

MR. LEVY: We can discuss it at the end. It's a voluntary interview. He's declining to answer that.

BY MR. DAVIS:

Q. Did any Fusion employees communicate with any foreign governments or foreign intelligence agencies about the memoranda or the information contained therein?

A. I don't believe so, certainly not knowingly.

Q. Did you and Mr. Steele ever discuss any communications he had with foreign government officials about the information in the memoranda?

1-800-FOR-DEPO
Alderson Court Reporting