Page:CTRL0000034605 - Transcribed Interview of Angela McCallum, (December 8, 2021).pdf/8

8 your questions today.

Finally, Ms. McCallum has produced numerous documents to this committee. I sent a letter along with those documents raising numerous objections regarding production issues for Ms. McCallum. Those objections still stand, and we want the record to be clear that Ms. McCallum is not waiving any of the objections in that letter. I believe they were First Amendment, Fourth Amendment, legislative purpose, pertinence, common law privileges that were raised in that letter.

And Ms. McCallum is not waiving those objections by appearing today or answering the committee's questions. However, she is here today. She is not asserting those objections as a basis for not appearing today or as a basis for not answering questions today.

Those are the objections for the record.

I also have a few ground rules I would like to propose.

I understand that, due to the composition of the committee, there is one committee staff; we don't have a minority staff. So that makes the traditional rounds aspect of this deposition difficult. However, we would request that we maintain the 60-minute round format, just allowing everyone a short break every 60 minutes.

Second, I understand we have two counsels for the select committee, and my understanding is both may ask questions. We would request to adhere to a more traditional deposition format. As counsel are both undoubtedly aware, in a traditional deposition one attorney is allowed to ask questions. Same thing in a courtroom for an evidentiary hearing. We would like to remain closer to the traditional format for depositions.

A compromise we are willing to offer would be that, whoever is doing the questioning, if you would like to switch to the other counsel having questions, we are