Page:Simpson-transcript-redacted.pdf/212

Glenn SimpsonPage 212 and Mr. Steele —

MR. LEVY: Where are you again?

BY MR. DAVIS:

Q. Page 2, the response to 4 and to 6. Here the attorneys for Orbis and Mr. Steele state "The duty not to disclose intelligence to third parties without the prior agreement of the Defendants" — again, that's Orbis and Mr. Steele — "do not extend to disclosure by Fusion to its clients, although the Defendants understand that copies of the memoranda were not disclosed by Fusion."

A. Where are you? You're on page 2 — okay. I see it now.

Q. — "do not extend to disclosure by Fusion to its clients, although the Defendants understand that copies of the memoranda were not disclosed by Fusion to its clients."

Further down on that same page in response to a question about whether Fusion's clients, insofar as disclosure to them, was permitted, could themselves disclose the intelligence from Orbis, the filing responds "Defendants understood that the arrangement between Fusion and its clients was that intelligence would not be disclosed."

Is that a correct statement of the 1-800-FOR-DEPO