Page:Simpson-transcript-redacted.pdf/267

Glenn SimpsonPage 267 A. I believe I described it before. We do a lot of public records research, things that are in the news, things that are in court documents. We summarize those things and try to document, you know, and attach them to the underlying source material.

Q. So you create sort of summary memoranda of those documents?

A. Yes.

Q. Okay. And to whom is that distributed?

MR. LEVY: As a general matter?

MR. DAVIS: Well, within the course of this investigation.

MR. LEVY: Inasmuch as that answer calls for client communications the answer might be privileged, might touch on obligations Mr. Simpson has. So he's not going to answer that question.

MR. FOSTER: Did you provide work product to your client?

MR. LEVY: Again, the answer to that question might implicate privilege or his obligations.

BY MR. DAVIS:

Q. Is the version of the Steele memoranda that was published by BuzzFeed identical to the version that Orbis provided Fusion? 1-800-FOR-DEPO