Al 1 A. Yes. 2 Q. Okay. Because of the privilege instruction, 3 I'm going to ask it this way: As of December 30th, 4 2014, when you put your -- allowed your name to be put 5 on this pleading as -- 6 A. I didn't allow it. I was proud to sign this 7 pleading. 8 Q. Okay. As of December 30th, 2014, when you 9 were proud to sign this pleading, was there any witness, 10 whether a victim or anyone else, who could be -- person, 11 whether a victim or anyone else, who could be called as 12 a witness who would say, I have knowledge that Alan 13 Dershowitz abused a minor, other than Virginia Roberts? 14 A. I believe with further discovery we could 15 have identified witnesses, yes. 16 Q. So is the answer to my question, no, when I 17 ask: As of December 30th, 2014, when you signed this, 18 were you aware of a single witness who would testify, I 19 have Knowledge that Alan Dershowitz abused a minor, 20 other than Virginia Roberts? 21 MS. McCAWLEY: Objection. I just want to be 22 clear. Outside the context of Virginia Roberts, 23 what he learned through the common interest 24 privilege. 25 BY MR. SIMPSON: ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021864