37 1 and you can tell me if you'll answer this 2 question. 3 BY MR. SIMPSON: 4 Q. Who, aS your understanding as of December 5 30th of 2014, with which attorneys did you have a common 6 interest privilege? 7 A. Brad Edwards from, obviously, the law firm 8 that I've been working with here. Also attorneys from 9 the Boies Schiller law firm who were representing 10 Virginia Roberts at that time. 11 Q. Anyone else? 12 A. The -- at that time, on December 30th, I 13 don't Know that it's directly responsive to your 14 question, but also the Scarola law firm, Mr. Scarola in 15 connection with litigation he was handling for Brad 16 Edwards. 17 Q. Any any other law firm lawyers that you had a 18 common interest privilege with? 19 A. No. 20 Q. And you're going to refuse to answer 21 questions about communications with Miss Roberts; is 22 that right? 23 A. Sure. Those are -- well, some -- some 24 communications are public, we will discuss those, I'm 25 sure as the deposition moves along, but certainly with ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021860