, 1 Q. Would you also agree that if there is any 2 doubt as to whether the allegations might be an issue in 3 the action, courts will deny the motion? 4 A. That was our position in our response to 5 Professor Dershowitz's motion to strike, yes. 6 Q. And in considering a motion to strike, the 7 court must consider the pleadings in the light most 8 favorable to the party making the pleading, correct? 9 A. Yeah, that's our position, that was our 10 position, yes. 11 Q. Okay. In your view, is it -- for an attorney 12 to ask a leading question at a deposition, does the 13 attorney have to have a good-faith basis to believe that 14 that question is true or the facts assumed in that 15 question are true? 16 A. I mean, that's a broad question, but as a 17 general rule, yeah. 18 Q. As a general rule -- I'm not being very 19 articulate -- 20 A. Yeah. 21 Q. -- you don't ask a leading question about a 22 fact unless you have a good-faith basis to believe that 23 facts is true, correct? 24 A. I think that's right. I mean I don't know if 25 over the last day and a half, you know, narrow questions ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021830