253 255 1 BY MR. SCAROLA: 1 MR. INDYKE: Objection. This is Darren. 2 Q. Who told you that the manifests confirm 2 Anything that relates to your conversations 3 the accuracy of your publie statements? | 3 with Jeffrey -- 4 MR. SCOTT: If it involves lawyer-client 4 THE REPORTER: He's going to have to speak 5 privilege, don't answer it. 5 up. 6 THE WITNESS: Okay. 6 MR. SCOTT: You're going to have to speak 7 BY MR. SCAROLA: 7 up a little bit more, Counsel. 8 Q. You're refusing to answer? 8 MR. INDYKE: Objection. This is Darren 9 A. No, I would like -- 9 Indyke. Anything that Alan might have to say 10 MR. SCOTT: Instruct you not to answer. 10 to that, to the extent they are covered under il A. -- to answer. But I've been instructed il conversations with Jeffrey Epstein, privileged 12 not to answer. 1 would like to answer. 12 under attorney-client privileges as well as 13 You've made a statement -- 13 common interest privileges. 14 MR. SCOTT: There's no question pending. 14 MR. SCOTT: Do you understand? 15 THE WITNESS: But he made a statement -- 15 THE WITNESS: I do. 16 MR. SCOTT: But there's no question 16 BY MR. SCAROLA: 17 pending, sir. 17 Q. To which your response was: "Sure, sure, 18 BY MR. SCAROLA: 18 certainly I have been his lawyer and I did speak to 19 Q. What does it mean to make something up out 19 him about it. I wanted to make sure that his memory 20 of whole cloth? 20 and mine coordinated about when I was at his island. 21 A. It means that Virginia Roberts and your 21 He was able to check. I was able to check. | 22 clients -- 22 checked with my friends who went with me." 23 Q. No, sir, I hayen't asked you anything 23 Did you make that answer to that question? 24 about Virginia Roberts. I haven't asked you 24 A. Yes. 25 anything about my clients. 2s Q. Diselosing the contents of your 254 256 1 I want te know what the words "making 1 communication with Jeffrey Epstein, correct? 2 something up out of whole cloth" mean. 2 A. I disclosed that I had spoken to him