HOUSE OVERSIGHT 012403 -0929104.TXT 9 Q. Other than conversations that you have had 10 with Mr. Leopold -- I'm not asking about that -- are you 11 aware that Mr. Leopold has filed a lawsuit in federal 12 court seeking fifty million dollars from Jeffrey Epstein 13 on your behalf? 14 MR. LEOPOLD: Same objection. 15 Anything that you learn through 16 conversations between you and me, do not answer. 17 Those are protected. If you know through any 18 other realm of knowledge, you may answer. 19 THE WITNESS: No. 20 BY MR. TEIN: 21 Q. You have no idea that Mr. Leopold filed a 22 fifty million-dollar lawsuit on your behalf against 23 Jeffrey Epstein? 24 MR. LEOPOLD: Same objection. 25 Do not answer that question if it's through 10 1 discussions that you and I had. Outside of that, 2 you may answer. So do not answer that question if 3 that is the only basis by which you understand 4 that answer. 5 THE WITNESS: No. 6 BY MR. TEIN: 7 Q. You didn't know that? 8 MR. LEOPOLD: Don't answer that question. 9 Against, it's attorney/client privilege. Any 10 information you've learned through conversations 11 between you and I are protected. If you know it 12 through any other realm, you may answer. 13 MR. TEIN: Are you going to say that for Page 8