Page:Simpson-transcript-redacted.pdf/91

Glenn SimpsonPage 91 just whether or not the clients specifically spoke with or directed Mr. Steele's work?

MR. LEVY: So he can't talk about client communications, directions to the client — directions to Mr. Steele as those communications might implicate privilege or obligations, but if you want to ask him whether the clients directed Mr. Steele to go to the FBI, that's a question he can answer. That's in the scope of the interview today.

BY MS. SAWYER:

Q. All right. So we'll get to that. We'll talk about that a little bit later. Let me just follow up on a couple other things that came up and then we'll conclude for our hour and turn it back to our colleagues.

So one of the things that came up in the course of our conversation and when I had asked you specifically about work being done for one client and rules and procedures in place to ensure that that work is not shared with another, can you just specifically describe those rules. I think at one point you indicated that you and Mr. Baumgartner had operated under the same rules?

A. Right. We're both professionals and we 1-800-FOR-DEPO