Page:Simpson-transcript-redacted.pdf/266

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Page 266

product relating to this investigation?

MR. LEVY: Which investigation?

MR. DAVIS: The investigation into Mr. Trump and his associates.

MR. LEVY: In addition to what?

MR. DAVIS: Sorry. The investigation into Mr. Trump and his associates.

MR. LEVY: I'm sorry. Just repeat the whole question.

MR. DAVIS: Sure. In addition to the memoranda compiled by Mr. Steele, did Fusion itself create any other work product as part of this investigation?

MR. LEVY: I just want to make sure there's no confusion. It wasn't Fusion that created the memoranda.

MR. DAVIS: Right, but it was a subcontractor giving it back to Fusion.

MR. LEVY: That's correct.

BY MR. DAVIS:

Q. With that understanding, did Fusion create any work product of its own?

A. Yes.

Q. And can you describe what type of work product that was?

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