first memoranda that he created?
MR. LEVY: He's already answered that question.
BY THE WITNESS:
A. No, I don't know.
Q. Do you know if he provided any other memoranda to the FBI on a rolling basis at all at any point?
MR. LEVY: He's answered that question too.
BY THE WITNESS:
A. I don't know.
Q. So I'd like to go back to Exhibit 4, I believe. On page 3, paragraph 18 Mr. Steele's attorneys are describing the December memoranda and they state "The Defendants" — again, that's Mr. Steele and Orbis — "continued to receive unsolicited intelligence on the matters covered by the pre-election memoranda after the U.S. presidential election and the conclusion of the assignment for Fusion."
They reiterate this point on Exhibit 5 on page 4. Request 11 asks "Please state whether such intelligence was actively sought by the Defendant" —
A. Where are you at?
