36 1 let him do that. 2 MR. SIMPSON: That certainly is not 3 privileged. That's fact. 4 THE WITNESS: I think this is a -- I would be 5 happy to answer the question, but this is a very 6 complicated issue that -- that I think I should 7 confer with -- I don't want to inadvertently 8 waive a privilege that my client, Virginia 9 Roberts, has or other persons may potentially 10 have, so I think I would like take to short break 11 and confer with my counsel on that question. 12 MR. SIMPSON: We will take a short break. 13 THE VIDEOGRAPHER: We are going off the video 14 record, 2:13 p.m. 15 (Thereupon, a recess was taken. ) 16 THE VIDEOGRAPHER: We are back on the video 17 record, 2:25 p.m. 18 MR. SCAROLA: So that the record is clear, we 19 have had an opportunity to consult, and we are 20 asserting both the attorney/client and common 21 interest privilege, and I can tell you that there 22 is no source of information outside of the 23 attorney/client and common interest privilege 24 that relates to the area of your current inquiry. 25 MR. SIMPSON: Well, and I'll ask the question ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021859