Page:Simpson-transcript-redacted.pdf/210

Glenn SimpsonPage 210 associates.

A. As I said earlier, in any project, and that would include this one, the objective is to gather relevant information, and some of that information was gathered for other purposes and some of it was gathered for the possibility that it might be useful to the press.

Q. Did your client instruct you to have these meetings?

MR. LEVY: The answer to that question might implicate privilege or obligations that we've set forth.

BY MR. DAVIS:

Q. Do you have any reason to believe that Mr. Steele passed any information on to journalists without Fusion?

A. Without me — you mean without me participating, without me authorizing it? Can you be more specific?

Q. Sure. Let's start without you participating. The filing references meetings that both you and Fusion jointly had with journalists. Do you believe he had any meetings with journalists without you present?

MR. LEVY: Without Mr. Simpson physically 1-800-FOR-DEPO