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Glenn SimpsonPage 205 MS. SAWYER: Were these documents that were requested or obtained from a third party in the course of the investigation?

MR. DAVIS: These were documents that were published in the media. I believe the second one was published by McClatchy.

MS. SAWYER: And what about the first?

MR. DAVIS: That was the one published by the Washington Times.

(Exhibit 5 was marked for

identification.)

BY MR. DAVIS:

Q. So with the second one on page 8 of Exhibit 5, under the response to 18 Steele's attorneys state "The journalists initially briefed at the end of September 2016 by the second Defendant and Fusion at Fusion's instruction were from the New York Times, the Washington Post, Yahoo News, the New Yorker, and CNN. The second Defendant" — that would be Mr. Steele — "subsequently participated in further meetings at Fusion's instruction with Fusion and the New York Times, the Washington Post, and Yahoo News which took place in mid-October 2016. In each of those cases the briefing was conducted verbally in 1-800-FOR-DEPO