Page:Simpson-transcript-redacted.pdf/286

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Page 286

identity of any clients —

MR. DAVIS: I didn't say client.

MR. LEVY:I understand. Or their lawyers.

MR. FOSTER: I think the issue we're trying to deal with is in order to assess your claims of privilege the committee needs to understand at least as much about the context of the dossier work as it does about the Prevezon work in terms of who was involved. So if there's a law firm involved or if he was reporting to a law firm or acting under the direction of a law firm, then we need to be able to assess whether or not that was in anticipation of litigation, whether he was doing it by the direction of a law firm in order to assess your assertions of privilege.

MR. LEVY: I understand. We've identified our position. We've been talking — Mr. Simpson has been answering your questions since 9:30 this morning, it's now 6:15. He's been fully cooperative and he's here because the Chair and the Ranking Member agreed to a limited scope. The questions you're asking are outside of that scope and this is part of why appearing at a hearing was going to be impossible. Through this agreement we're here. He's given you a ton of information.

1-800-FOR-DEPO
Alderson Court Reporting