HOUSE OVERSIGHT 012404 -0929104.TXT 14 every question in the deposition, Mr. Leopold? 15 MR. LEOPOLD: When you ask improper 16 questions like that without the proper -- 17 MR. TEIN: You're going to stop your 18 speaking objections right now. Okay? 19 MR. LEOPOLD: Without the proper -- 20 MR. TEIN: You need to stop your speaking 21 objections. 22 Let's continue. 23 MR. LEOPOLD: Counsel, you just asked me a 24 question and I'm going to state it on the 25 record -- 11 1 MR. TEIN: You need to stop your speaking 2 objections. Check your rules. 3 MR. LEOPOLD: Excuse me. For the record, 4 Counsel asked me a question. I'll state the 5 answer on the record. He asked me the question am 6 I going to be answering that way throughout the 7 deposition. So long as there's improper 8 foundation and predicate asked by the attorney, I 9 will protect my client and I make the record where 10 appropriate. If counsel wishes to ask an 11 appropriate worded question with the proper 12 foundation and predicate, I will certainly allow 13 the client to answer the question. 14 MR. GOLDBERGER: Why don't you just state 15 attorney/client privilege and just be done with 16 it. 17 MR. LEOPOLD: I want the record to be Page 9