Q. Page 4, request 11. It states "Please state whether such intelligence was actively sought by the second Defendant or merely received as presently pleaded." The response they say is "Such intelligence was not actively sought, it was merely received."
Did anyone — are you aware of who sent this unsolicited intelligence to Mr. Steele?
A. No.
Q. Could you describe his methods of compiling the dossier a little more? I think before you described field interviews. He seems to be talking about unsolicited information coming to him rather than information he sought out?
A. I can try. When you're doing field information gathering you have a network of people, sources. It's not like a light switch that you turn on and off, these are people you work with. So they call you and tell you stuff. You know, you don't close the window and stop answering phone calls, you know, when the engagement ends. So I assume this is stuff that came in straggle, whatever you call it.
Q. To the best of your knowledge, did Mr. Steele pay any of his sources or subsources in
