HOUSE_OVERSIGHT_021859.jpg
1.28 MB
Extraction Summary
5
People
1
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Deposition transcript (rough draft)
File Size:
1.28 MB
Summary
This is a page from a rough draft deposition transcript involving an inquiry related to Virginia Roberts. The witness (likely an attorney for Roberts) requests a break to consult with counsel to avoid inadvertently waiving attorney/client privilege. After a 12-minute recess (2:13 p.m. to 2:25 p.m.), attorney Mr. Scarola places on the record that they are asserting both attorney/client and common interest privilege regarding the source of information in question.
People (5)
| Name | Role | Context |
|---|---|---|
| Mr. Simpson | Attorney/Interrogator |
Questioning the witness and asserting that a specific point is fact, not privileged.
|
| The Witness | Deponent |
An individual representing Virginia Roberts (likely an attorney given the reference to 'my client'), who requests a b...
|
| Virginia Roberts | Client |
Identified as the client of The Witness, holding attorney/client privilege.
|
| The Videographer | Court Staff |
Announces time on and off the record.
|
| Mr. Scarola | Attorney |
Speaks after the break to assert attorney/client and common interest privilege on behalf of the witness.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| House Oversight Committee |
Inferred from Bates stamp 'HOUSE_OVERSIGHT'.
|
Timeline (1 events)
Unknown Date
Recess in deposition proceedings
Deposition room (unspecified location)
Relationships (2)
Witness refers to 'my client, Virginia Roberts'
Scarola speaks on behalf of the witness/defense team after the witness asks to confer with counsel.
Key Quotes (3)
"I don't want to inadvertently waive a privilege that my client, Virginia Roberts, has or other persons may potentially have"Source
HOUSE_OVERSIGHT_021859.jpg
Quote #1
"we are asserting both the attorney/client and common interest privilege"Source
HOUSE_OVERSIGHT_021859.jpg
Quote #2
"there is no source of information outside of the attorney/client and common interest privilege that relates to the area of your current inquiry"Source
HOUSE_OVERSIGHT_021859.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,128 characters)
36
1 let him do that.
2 MR. SIMPSON: That certainly is not
3 privileged. That's fact.
4 THE WITNESS: I think this is a -- I would be
5 happy to answer the question, but this is a very
6 complicated issue that -- that I think I should
7 confer with -- I don't want to inadvertently
8 waive a privilege that my client, Virginia
9 Roberts, has or other persons may potentially
10 have, so I think I would like take to short break
11 and confer with my counsel on that question.
12 MR. SIMPSON: We will take a short break.
13 THE VIDEOGRAPHER: We are going off the video
14 record, 2:13 p.m.
15 (Thereupon, a recess was taken.)
16 THE VIDEOGRAPHER: We are back on the video
17 record, 2:25 p.m.
18 MR. SCAROLA: So that the record is clear, we
19 have had an opportunity to consult, and we are
20 asserting both the attorney/client and common
21 interest privilege, and I can tell you that there
22 is no source of information outside of the
23 attorney/client and common interest privilege
24 that relates to the area of your current inquiry.
25 MR. SIMPSON: Well, and I'll ask the question
1 let him do that.
2 MR. SIMPSON: That certainly is not
3 privileged. That's fact.
4 THE WITNESS: I think this is a -- I would be
5 happy to answer the question, but this is a very
6 complicated issue that -- that I think I should
7 confer with -- I don't want to inadvertently
8 waive a privilege that my client, Virginia
9 Roberts, has or other persons may potentially
10 have, so I think I would like take to short break
11 and confer with my counsel on that question.
12 MR. SIMPSON: We will take a short break.
13 THE VIDEOGRAPHER: We are going off the video
14 record, 2:13 p.m.
15 (Thereupon, a recess was taken.)
16 THE VIDEOGRAPHER: We are back on the video
17 record, 2:25 p.m.
18 MR. SCAROLA: So that the record is clear, we
19 have had an opportunity to consult, and we are
20 asserting both the attorney/client and common
21 interest privilege, and I can tell you that there
22 is no source of information outside of the
23 attorney/client and common interest privilege
24 that relates to the area of your current inquiry.
25 MR. SIMPSON: Well, and I'll ask the question
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021859
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