43 1 confidential common interest privilege 2 communications is privileged. Yes, that's my 3 position. 4 MR. SIMPSON: Okay. That, we will have to go 5 to the judge on. 6 BY MR. SIMPSON: 7 Q. Let me ask you this way: As of December -- 8 A. I'm going to write down your question because 9 this one sounds like it's going to be complicated. 10 Q. I'm going to ask it again. It's not 11 complicated. It's very simple. This one is going to be 12 very simple. 13 A. Okay. 14 Q. As of December 30th, 2014, had you spoken 15 personally with anyone who said, I have knowledge that 16 Alan Dershowitz -- I have personal knowledge that Alan 17 Dershowitz abused other minors? 18 MR. SCAROLA: To the extent that that 19 question calls for information conveyed within 20 the scope of either the attorney/client or common 21 interest privilege, I instruct you not to answer. 22 BY MR. SIMPSON: 23 Q. Put aside for the moment Virginia Roberts. 24 I'll ask the question: Did Virginia Roberts tell you 25 that Alan Dershowitz abused anyone other than her? ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021866