Page:Simpson-transcript-redacted.pdf/92

Glenn SimpsonPage 92 both deal with multiple clients. So we don't talk about a case with one client with another client.

I think since you raised this I should be clear, Mr. Baumgartner did not know about Mr. Steele, the work I was doing with Mr. Steele or, you know, the memos he was writing.

MR. FOSTER: Can you speak up a little bit.

BY THE WITNESS:

A. Mr. Baumgartner did not know about the work that we were doing with Mr. Steele. One of the ways that we avoid bleeding between one case and another is compartmentalization. We don't tell people — we don't tell one subcontractor what we're doing with another subcontractor. We don't even tell them, you know, that they exist.

Q. What about Mr. Steele, what rules was he operating under when he was doing the work on Candidate Trump?

A. Every subcontractor signs an NDA at the beginning of the discussion before even there's an engagement. So he was operating under an NDA.

Q. And in general what does that NDA provide? And by NDA I assume you mean nondisclosure agreement?

A. Right. Again, the paperwork side of the 1-800-FOR-DEPO