46 1 MR. SIMPSON: Let me -- 2 MR. SCAROLA: You are not permitted to get 3 indirectly what you cannot get directly, and by 4 phrasing the questions as you have phrased them, 5 you are attempting to narrow down the source of 6 information to an attorney/client privileged 7 communication. 8 I can't allow the witness to respond to that 9 question and thus disclose information that may 10 fall within the scope of the attorney/client 11 privilege or common interest privilege. 12 BY MR. SIMPSON: 13 Q. Let me ask it -- try asking it this way: You 14 filed this pleading in the CVRA case; is that correct? 15 A. Yes. 16 Q. And if I understand correctly, you have 17 argued and the court has agreed that this is a civil 18 proceeding; is that right? 19 A. That's a very complicated question that would 20 require a longer answer, so I'm just tipping you off, if 21 you want a long answer, we can talk about that. 22 Q. Give me a fair answer to the question. 23 What's been your position and have there been rulings on 24 the nature of the proceeding? 25 A. So this requires some context here. This ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021869