124 1 A. Did I personally do that? 2 Q. Yes. 3 A. No. To my knowledge, I've never met 4 Mr. Josefsburg, so no. 5 Q. To your knowledge, did anyone else in the 6 group of attorneys you were working with ask 7 Mr. Josefsburg that question? 8 MR. SCAROLA: Excuse me. To the extent that 9 that question would call for a communication 10 within the common interest privilege, you should 11 not answer it. 12 THE WITNESS: I'm going take my counsel's 13 advice. I can't answer that. 14 BY MR. SIMPSON: 15 Q. You're not going to answer whether to your 16 knowledge anyone asked Mr. Josefsburg? 17 A. Right. 18 Q. But you are testifying that the fact that 19 Mr. Josefsburg had signed a complaint with a generic 20 term "academicians" in it was some evidence, in your 21 mind, against Professor Dershowitz? 22 A. Yes, because he's an academician and shortly 23 after the complaint was filed, a partner in his firm 24 began asking Alan Dershowitz questions about the sex 25 abuse matter that we are discussing here. ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021947