42 1 Q. I'm asking whether he was aware of I'm not 2 asking about -- well, let me back up. 3 Are you aware of any witness who could be 4 called who, as of December 30th, 2014, any person who 5 could be called as a witness who would testify, I have 6 knowledge that Alan Dershowitz abused a minor to support 7 the allegation that Alan Dershowitz abused other minors? 8 MR. SCAROLA: Outside of information gathered 9 through attorney/client or common interest 10 privileged communications; is that correct? 11 MR. SIMPSON: No. It's not correct. 12 MR. SCAROLA: Okay. Then, I'm not going to 13 permit him to answer the question to the extent 14 that it includes a request for information within 15 the attorney/client and common interest 16 privilege. 17 MR. SIMPSON: Is it your position that the 18 name of a person who could be called as a witness 19 is somehow privileged? 20 MR. SCAROLA: It is my position that any 21 information communicated within the scope of the 22 confidential attorney/client communication is 23 privileged information. 24 It is my position that any information 25 including names communicated in the scope of ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021865