49 1 are Claiming privilege as -- as to, are you aware of any 2 person who, as of December 30th, 2014, had said, I have 3 knowledge that Professor Dershowitz abused other minors? 4 MR. SCAROLA: I'm sorry. I need to have that 5 question repeated. 6 (Thereupon, a portion of the record was read 7 by the reporter.) 8 MR. SCAROLA: That's fine. You can answer 9 that. Were there any nonprivileged 10 communications of that? 11 BY MR. SIMPSON: 12 Q. My question is -- for purposes of this 13 question, I'm putting aside what you're claiming is 14 scope of privilege. Were you aware of anyone who made 15 the assertion that Alan Dershowitz had abused other 16 minors? 17 A. I didn't have a named person, but I had a 18 pool of persons that I understood would be potentially 19 available to provide that kind of information. 20 Q. So the answer to the question is, no, you did 21 not have a person who had said to you that Alan 22 Dershowitz abused other minors? 23 A. I think that is slightly different than what 24 I just said. I didn't have a named person. I had a 25 pool of people in mind, the names of whom I didn't, you ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021872