56 1 Q. Let me ask this way: We have talked somewhat 2 about the basis for this allegation about other minors. 3 Putting aside information as to what you're claiming 4 privilege, tell me what you knew as of December 30th, 5 2014, that formed the factual basis for your -- for that 6 allegation about other minors? 7 MR. SCAROLA: And I'11 instruct you not to 8 answer that question for the same reason that 9 when the same question was asked earlier, I 10 instructed you not to answer. 11 MR. SIMPSON: I'm -- maybe we are not being 12 clear, Jack. I'm asking him to put aside -- I 13 mean, certainly, he filed a pleading. You've 14 asserted privilege as to certain aspects. I'm 15 simply asking him, putting aside whatever you're 16 Claiming privilege for, right, so I'm not asking 17 you right now to tell me anything you're claiming 18 as privilege. 19 BY MR. SIMPSON: 20 Q. Tell me whatever is not privileged that 21 supports that allegation. 22 A. Okay. The privileged information obviously 23 you're asking me not to reveal at this point. 24 Q. I'm asking you to tell me the nonprivileged 25 information -- and I'm not agreeing with your privilege ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021879