HOUSE_OVERSIGHT_021879.jpg
1.35 MB
Extraction Summary
4
People
1
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal deposition transcript (rough draft)
File Size:
1.35 MB
Summary
This document is a page from a rough draft deposition transcript involving an interrogation by Mr. Simpson. The questioning focuses on establishing the factual basis for allegations concerning 'other minors' known by the witness as of December 30, 2014. Attorney Mr. Scarola interrupts to instruct the witness not to answer based on privilege, leading to a debate about separating privileged legal strategy from non-privileged factual information.
People (4)
| Name | Role | Context |
|---|---|---|
| Mr. Simpson | Attorney / Questioner |
Conducting the examination and asking the witness to separate privileged information from factual basis.
|
| Mr. Scarola | Attorney |
Intervenes to instruct the witness not to answer based on privilege. Referred to as 'Jack' by Mr. Simpson.
|
| Witness (A.) | Deponent |
Unnamed on this specific page; answering questions regarding allegations about minors.
|
| Jack | Attorney |
First name of Mr. Scarola, used by Mr. Simpson.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| House Oversight Committee |
Inferred from the Bates stamp 'HOUSE_OVERSIGHT_021879'.
|
Relationships (2)
Simpson questions the witness; Scarola objects and instructs the witness not to answer. Simpson addresses Scarola as 'Jack'.
Scarola instructs the witness not to answer questions to protect privilege.
Key Quotes (4)
"Let me ask this way: We have talked somewhat about the basis for this allegation about other minors."Source
HOUSE_OVERSIGHT_021879.jpg
Quote #1
"tell me what you knew as of December 30th, 2014, that formed the factual basis for your -- for that allegation about other minors?"Source
HOUSE_OVERSIGHT_021879.jpg
Quote #2
"MR. SCAROLA: And I'll instruct you not to answer that question for the same reason that when the same question was asked earlier, I instructed you not to answer."Source
HOUSE_OVERSIGHT_021879.jpg
Quote #3
"I'm asking you to tell me the nonprivileged information -- and I'm not agreeing with your privilege"Source
HOUSE_OVERSIGHT_021879.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,312 characters)
56
1 Q. Let me ask this way: We have talked somewhat
2 about the basis for this allegation about other minors.
3 Putting aside information as to what you're claiming
4 privilege, tell me what you knew as of December 30th,
5 2014, that formed the factual basis for your -- for that
6 allegation about other minors?
7 MR. SCAROLA: And I'll instruct you not to
8 answer that question for the same reason that
9 when the same question was asked earlier, I
10 instructed you not to answer.
11 MR. SIMPSON: I'm -- maybe we are not being
12 clear, Jack. I'm asking him to put aside -- I
13 mean, certainly, he filed a pleading. You've
14 asserted privilege as to certain aspects. I'm
15 simply asking him, putting aside whatever you're
16 claiming privilege for, right, so I'm not asking
17 you right now to tell me anything you're claiming
18 as privilege.
19 BY MR. SIMPSON:
20 Q. Tell me whatever is not privileged that
21 supports that allegation.
22 A. Okay. The privileged information obviously
23 you're asking me not to reveal at this point.
24 Q. I'm asking you to tell me the nonprivileged
25 information -- and I'm not agreeing with your privilege
2 about the basis for this allegation about other minors.
3 Putting aside information as to what you're claiming
4 privilege, tell me what you knew as of December 30th,
5 2014, that formed the factual basis for your -- for that
6 allegation about other minors?
7 MR. SCAROLA: And I'll instruct you not to
8 answer that question for the same reason that
9 when the same question was asked earlier, I
10 instructed you not to answer.
11 MR. SIMPSON: I'm -- maybe we are not being
12 clear, Jack. I'm asking him to put aside -- I
13 mean, certainly, he filed a pleading. You've
14 asserted privilege as to certain aspects. I'm
15 simply asking him, putting aside whatever you're
16 claiming privilege for, right, so I'm not asking
17 you right now to tell me anything you're claiming
18 as privilege.
19 BY MR. SIMPSON:
20 Q. Tell me whatever is not privileged that
21 supports that allegation.
22 A. Okay. The privileged information obviously
23 you're asking me not to reveal at this point.
24 Q. I'm asking you to tell me the nonprivileged
25 information -- and I'm not agreeing with your privilege
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021879
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