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1.16 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:
1.16 MB
Summary
Page 44 of a rough draft deposition transcript involving a witness identified as Professor Cassell. Attorney Mr. Scarola instructs Cassell not to answer questions to preserve the attorney/client privilege of Virginia Roberts. Mr. Simpson questions whether the witness will consistently follow these instructions, to which the witness agrees.
People (5)
| Name | Role | Context |
|---|---|---|
| Professor Cassell | Witness |
Identified in line 16; refusing to answer questions based on attorney instructions regarding privilege.
|
| Mr. Scarola | Attorney |
Instructing the witness not to answer based on attorney/client privilege.
|
| Mr. Simpson | Attorney |
Conducting the questioning (Q.).
|
| Ms. McCawley | Attorney |
Present at deposition, objecting to Scarola's instructions.
|
| Virginia Roberts | Subject of Privilege |
The individual whose attorney/client privileges are being protected by the witness.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| House Oversight Committee |
Inferred from Bates stamp 'HOUSE_OVERSIGHT'
|
Timeline (1 events)
Unknown
Relationships (2)
Cassell is protecting Roberts' attorney/client privilege.
Scarola is instructing Cassell on how to answer, and Cassell is complying.
Key Quotes (3)
"I'm being instructed not to waive attorney/client privileges of Virginia Roberts and I'm going to follow that instruction, yes."Source
HOUSE_OVERSIGHT_021867.jpg
Quote #1
"On the basis of attorney/client privilege, I instruct him not to answer."Source
HOUSE_OVERSIGHT_021867.jpg
Quote #2
"You can assume that Professor Cassell will follow my instructions."Source
HOUSE_OVERSIGHT_021867.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,010 characters)
44
1 MR. SCAROLA: I instruct you not to answer.
2 MS. McCAWLEY: And I object to that.
3 MR. SIMPSON: Okay.
4 BY MR. SIMPSON:
5 Q. So will you not answer that question?
6 MR. SCAROLA: On the basis of attorney/client
7 privilege, I instruct him not to answer.
8 BY MR. SIMPSON:
9 Q. And you will follow the instruction?
10 A. I'm being instructed not to waive
11 attorney/client privileges of Virginia Roberts and I'm
12 going to follow that instruction, yes.
13 Q. To shorten the deposition --
14 MR. SCAROLA: I might be able to help you a
15 little bit. You can assume that Professor
16 Cassell will follow my instructions. You
17 don't need to ask for --
18 MR. SIMPSON: We are at the same place. I
19 was just going to say, we have an agreement that
20 if --
21 THE WITNESS: Yeah, yeah.
22 MR. SIMPSON: Let me just finish. If
23 Mr. Scarola on Ms. McCawley instructs you not to
24 answer, you're going to follow it?
25 A. That's fine. I don't want to try to run out
2 MS. McCAWLEY: And I object to that.
3 MR. SIMPSON: Okay.
4 BY MR. SIMPSON:
5 Q. So will you not answer that question?
6 MR. SCAROLA: On the basis of attorney/client
7 privilege, I instruct him not to answer.
8 BY MR. SIMPSON:
9 Q. And you will follow the instruction?
10 A. I'm being instructed not to waive
11 attorney/client privileges of Virginia Roberts and I'm
12 going to follow that instruction, yes.
13 Q. To shorten the deposition --
14 MR. SCAROLA: I might be able to help you a
15 little bit. You can assume that Professor
16 Cassell will follow my instructions. You
17 don't need to ask for --
18 MR. SIMPSON: We are at the same place. I
19 was just going to say, we have an agreement that
20 if --
21 THE WITNESS: Yeah, yeah.
22 MR. SIMPSON: Let me just finish. If
23 Mr. Scarola on Ms. McCawley instructs you not to
24 answer, you're going to follow it?
25 A. That's fine. I don't want to try to run out
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021867
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