HOUSE_OVERSIGHT_021878.jpg
1.26 MB
Extraction Summary
5
People
1
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal deposition transcript (rough draft)
File Size:
1.26 MB
Summary
Page 55 of a rough draft deposition transcript stamped by House Oversight. Attorney Mr. Simpson questions a witness about what they would have told a judge (specifically Judge Marra). The witness, likely an attorney themselves, objects that the question is speculative and involves attorney-client privilege, but asserts they would have provided an 'ample factual basis for those allegations.' Professor Cassell is mentioned in an objection regarding expert witnesses.
People (5)
| Name | Role | Context |
|---|---|---|
| Mr. Simpson | Attorney |
Conducting the questioning/examination of the witness.
|
| The Witness | Deponent |
Answering questions regarding past legal strategies and attorney-client privilege.
|
| Professor Cassell | Subject of discussion |
Mentioned as not being present as an expert witness. (Likely Paul Cassell).
|
| Judge Marra | Judge |
Referenced as the judge to whom the witness would have presented arguments. (Likely Judge Kenneth Marra).
|
| Unnamed Speaker | Attorney |
Speaking in lines 1-5, objecting to the question on grounds of speculation.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| House Oversight Committee |
Inferred from Bates stamp 'HOUSE_OVERSIGHT_021878'.
|
Timeline (1 events)
Unknown
Deposition testimony regarding legal strategy and factual basis for allegations.
Unknown
Relationships (2)
Witness discusses presenting arguments to Judge Marra.
Simpson is questioning the witness in a deposition.
Key Quotes (3)
"I would have provided an ample factual basis for those allegations."Source
HOUSE_OVERSIGHT_021878.jpg
Quote #1
"we are setting aside attorney/client communications, right?"Source
HOUSE_OVERSIGHT_021878.jpg
Quote #2
"that would have involved going back to my client and carving out what kinds of things we were going to present to Judge Marra"Source
HOUSE_OVERSIGHT_021878.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,097 characters)
55
1 because Professor Cassell is not here as an
2 expert witness and hypotheticals are
3 inappropriate. You're calling for speculation on
4 his part and I'm not going to instruct him not to
5 answer, but it is an improper question.
6 MR. SIMPSON: I disagree, but you can answer
7 the question.
8 THE WITNESS: Right. So the factual basis
9 would -- we are setting aside attorney/client
10 communications, right?
11 BY MR. SIMPSON:
12 Q. I'm asking: What would you tell the judge?
13 A. Right. So that -- that's speculative. I
14 don't think I can give a fair answer at this point
15 because that would have involved going back to my client
16 and carving out what kinds of things we were going to
17 present to Judge Marra in light of the posture of the
18 case at that point.
19 So it's a speculative question. I would
20 have -- let me just, without going into any
21 attorney/client privileged communications, I would have
22 provided an ample factual basis for those allegations.
23 MR. SIMPSON: Move to strike as
24 nonresponsive.
25 BY MR. SIMPSON:
2 expert witness and hypotheticals are
3 inappropriate. You're calling for speculation on
4 his part and I'm not going to instruct him not to
5 answer, but it is an improper question.
6 MR. SIMPSON: I disagree, but you can answer
7 the question.
8 THE WITNESS: Right. So the factual basis
9 would -- we are setting aside attorney/client
10 communications, right?
11 BY MR. SIMPSON:
12 Q. I'm asking: What would you tell the judge?
13 A. Right. So that -- that's speculative. I
14 don't think I can give a fair answer at this point
15 because that would have involved going back to my client
16 and carving out what kinds of things we were going to
17 present to Judge Marra in light of the posture of the
18 case at that point.
19 So it's a speculative question. I would
20 have -- let me just, without going into any
21 attorney/client privileged communications, I would have
22 provided an ample factual basis for those allegations.
23 MR. SIMPSON: Move to strike as
24 nonresponsive.
25 BY MR. SIMPSON:
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021878
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