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Rh [3:11 p.m.]

MR. SIMPSON: I honestly don't know.

MR. SCHIFF: And how about Breitbart?

MR. SIMPSON: Again, I'm sorry to say, I just -- I don't have any recollection.

MR. SCHIFF: Now, you don't have a recollection because there might be other people at the firm who would be providing that information, or it would be you but you just don't recall?

MR. SIMPSON: It would be a little of both. I mean, those aren't my go-to news sources, so I don't really spend a lot of time -- you know, I don't read Breitbart every day, and I certainly don't watch FOX every day.

So, you know, if it ran in The New York Times and it was my work, I'd probably remember it, but not if -- and so -- but it's also true that, you know, we have 12 or so people in the company, and depending on the matter, someone else might have handled it.

MR. SCHIFF: So this might also be a situation where your client, the Free Beacon, might be providing information to various news sources without discussing it with you?

MR. SIMPSON: Yes.

MR. SCHIFF: I see. So in that case, it could appear on FOX even though you didn't have a conversation with FOX yourself?

MR. SIMPSON: That's right.

MR. SCHIFF: During the time that you were doing work for Free Beacon, you had mentioned some work in the first phase. You had discovered business relationships with Felix Sater and Bayrock. By first phase, do you mean while you UNCLASSIFIED, COMMITTEE SENSITIVE