Davis Interview #4

Mr. Davis

We'll go back on the record. It's 5:43 p.m.

Mr. Davis

Mr. Simpson, could you walk us through your itinerary to the best you remember it from June 8th through 10th of 2016, especially any interactions you had with Prevezon team members during those three days?

Mr. Levy

Beyond what he's discussed today?

Mr. Davis

Yes.

Mr. Simpson

I took the train to New York. I don't recall, but I may have had other business. I don't remember. I think there was a dinner. I went back to my hotel, went to bed. Got up the next morning. I don't remember the sequence, but I remember meeting with Weber Shandwick, the PR firm, about preparations for—I think we expected there was going to be a trial. I think that's what it was about. It might have been about the press coverage of the hearing. I just don't remember. I went to the hearing and I think—if I remember the sequence correctly, I went to the hearing, then I had the meeting with those guys, the Weber Shandwick guys, and then I hightailed it home. My son's junior prom was that night or senior prom and I was under some pressure to go home and be a dad.

Mr. Davis

And then on the 10th, that first day back in D.C.?

Mr. Simpson

I don't think that was my first day back. I was back the evening of the 9th.

Mr. Davis

Sorry. The first full day.

Mr. Simpson

I think it was a weekend. So I don't know what I was doing. Probably just relaxing. I went to the dinner, it was at a restaurant called Barcelona up on Wisconsin Avenue, it was a social occasion. I brought my wife, other people brought their wives. We talked about books and other other nongermane topics. It was just a social occasion.


Mr. Davis

I'm going to show you an exhibit. I think we're on 6. We understand these are meeting notes. Do these phrases about—including Mr. Browder mean anything to you or relate to any of the research that you conducted or otherwise aware of regarding Mr. Browder?

Mr. Levy

When say "meetings notes," meeting notes about what meeting?

Mr. Davis

These are the meeting notes from the June 9th meeting at Trump Tower. These are Mr. Manafort's notes or they're contemporaneous.

Mr. Simpson

I could tell—obviously you know who Bill Browder is. Cyprus Offshore, Bill Browder's structure, you know, investment—Hermitage Capital, his hedge fund, set up numerous companies in Cyprus to engage in inward investment into Russia, which is a common structure, both partially for tax reasons but also to have entities outside of Russia, you know, managing specific investments. I can only tell you I assume that's what that references. I don't know what the 133 million—

Mr. Foster

Can I interrupt? And you know that from research that you did and provided to—

Mr. Simpson

Yes.

Mr. Levy

Let him finish.

Mr. Foster

-- research that you did and provided to Baker Hostetler and their client?

Mr. Simpson

Yes. There was a—I can elaborate a little bit. As part of the research into how Hermitage Capital worked we looked at various things, their banking relationships, the way they structured their investments in Russia. I don't remember how many, but there was a large number of shell companies in Cyprus that were used to hold the investments of individual clients of Hermitage. So one of the things we discovered from that was the likely identities of some of Hermitage's clients.

Mr. Davis

Do any of the other entries in here mean anything to you in light of the research you've conducted or what you otherwise know about Mr. Browder?

Mr. Simpson

I'm going to—I can only speculate about some of these things. I mean, sometimes—

Mr. Levy

Don't speculate.

Mr. Simpson

Just would be guesses.

Mr. Davis

Okay.

Mr. Simpson

I can skip down a couple. So "Value in Cyprus as inter," I don't know what that means. "Illici," I don't know what that means. "Active sponsors of RNC," I don't know what that means. "Browder hired Joanna Glover" is a mistaken reference to Juliana Glover, who was Dick Cheney's press secretary during the Iraq war and associated with another foreign policy controversy. "Russian adoptions by American families" I assume is a reference to the adoption issue.

Mr. Davis

And by "adoption issue" do you mean Russia prohibiting U.S. families from adopting Russian babies as a measure in response to the Magnitsky act?

Mr. Simpson

I assume so.

Mr. Davis

The information here, is this generally consistent with the type of information you or Baker Hostetler were providing about Mr. Browder and his activities?

Mr. Levy

Can you repeat that question.

Mr. Davis

Is the information here, to the best you can decipher it, consistent with the information that you and Baker Hostetler and HRAGI were relaying to other parties about Mr. Browder's activities?

Mr. Levy

He's just told you that a lot of what's here he doesn't know what it means, he doesn't have knowledge or recollection as to these terms.

Mr. Davis

The parts you do recognize.

Mr. Simpson

Couple of the items touch on things that I worked on, Cyprus, Bill Browder.

Mr. Davis

I'm going to jump back to the Russia investigation. You'd mentioned before you've had some subcontractors that you've worked with long enough that you call them super subs; is that correct?

Mr. Simpson

Yes.

Mr. Davis

Orbis or Mr. Steele, is that one such super sub in your opinion?

Mr. Simpson

It's a loose term. We don't have a list of super subs.

Mr. Foster

Is he one of them?

Mr. Simpson

There is no list. So I can't tell you if he's one of them. He's a reliable subcontractor who's worked with us in the past and we've been very satisfied with the quality of his work.

Mr. Levy

Just to reiterate, I think as you described these super subs earlier loosely, even with some of these super subs Mr. Simpson said that he would talk about clients only on a need-to-know basis even with the super subs, so-called.

Mr. Davis

Beyond the memoranda prepared by Mr. Steele, did Fusion create any other work product relating to this investigation?

Mr. Levy

Which investigation?

Mr. Davis

The investigation into Mr. Trump and his associates.

Mr. Levy

In addition to what?

Mr. Davis

Sorry. The investigation into Mr. Trump and his associates.

Mr. Levy

I'm sorry. Just repeat the whole question.

Mr. Davis

Sure. In addition to the memoranda compiled by Mr. Steele, did Fusion itself create any other work product as part of this investigation?

Mr. Levy

I just want to make sure there's no confusion. It wasn't Fusion that created the memoranda.

Mr. Davis

Right, but it was a subcontractor giving it back to Fusion.

Mr. Levy

That's correct.

Mr. Davis

With that understanding, did Fusion create any work product of its own?

Mr. Simpson

Yes.

Mr. Davis

And can you describe what type of work product that was?

Mr. Simpson

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.

Mr. Davis

So you create sort of summary memoranda of those documents?

Mr. Simpson

Yes.

Mr. Davis

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.

Mr. Davis

Is the version of the Steele memoranda that was published by BuzzFeed identical to the version that Orbis provided Fusion?

Mr. Simpson

To my knowledge, yes.

Mr. Davis

The version published by BuzzFeed contains several redactions, not merely the ones by Mr. Gubarev, G-U-B-A-R-E-V, that were later added. Were those redactions in the versions Mr. Steele provided to you?

Mr. Levy

So wait. You're asking about the version in Exhibit 3?

Mr. Davis

Right.

Mr. Levy

And you're asking if the redactions that appear here were delivered to Fusion?

Mr. Davis

Right.

Mr. Simpson

No.

Mr. Davis

Do you know who added those redactions?

Mr. Simpson

No.

Mr. Davis

Did any version of the memoranda list source and subsource names rather than referring to sources anonymously?

Mr. Simpson

I'm not sure I understand the question.

Mr. Davis

In the version that we have as an exhibit obviously it doesn't give identifying information for sources, it says source A, subsources, things like that. Was there ever a version that listed the actual source names rather than substituting them?

Mr. Simpson

These are the versions that we received.

Mr. Davis

They're what?

Mr. Simpson

These are the memos that we received.

Mr. Davis

Those are the memos you received. Okay.

Mr. Foster

But he's asking if you received any other memos that listed the sources?

Mr. Levy

He did not—what I think he said is that he did not receive any versions of these memos that listed the sources.

Mr. Foster

Okay. Did you receive any other documentation from Mr. Steele that listed the sources?

Mr. Simpson

I don't want to get into source information.

Mr. Davis

Again, I don't want to repeat questions that have been asked, but I don't want to unintentionally omit anything. Did the version provided to the FBI include all source names?

Mr. Simpson

I don't know that there was a version provided to the FBI.

Mr. Davis

When Mr. Steele first met with the FBI in the summer of 2016 do you know if he provided the first memoranda that he created?

Mr. Levy

He's already answered that question.

Mr. Simpson

No, I don't know.

Mr. Davis

Do you know if he provided any other memoranda to the FBI on a rolling basis at all at any point?

Mr. Levy

He's answered that question too.

Mr. Simpson

I don't know.

Mr. Davis

So I'd like to go back to Exhibit 4, I believe. On page 3, paragraph 18 Mr. Steele's attorneys are describing the December memoranda and they state "The Defendants"—again, that's Mr. Steele and Orbis—"continued to receive unsolicited intelligence on the matters covered by the pre-election memoranda after the U.S. presidential election and the conclusion of the assignment for Fusion."

They reiterate this point on Exhibit 5 on page 4. Request 11 asks "Please state whether such intelligence was actively sought by the Defendant"—

Mr. Simpson

Where are you at?

Mr. Davis

Page 4, request 11. It states "Please state whether such intelligence was actively sought by the second Defendant or merely received as presently pleaded." The response they say is "Such intelligence was not actively sought, it was merely received."

Did anyone—are you aware of who sent this unsolicited intelligence to Mr. Steele?

Mr. Simpson

No.

Mr. Davis

Could you describe his methods of compiling the dossier a little more? I think before you described field interviews. He seems to be talking about unsolicited information coming to him rather than information he sought out?

Mr. Simpson

I can try. When you're doing field information gathering you have a network of people, sources. It's not like a light switch that you turn on and off, these are people you work with. So they call you and tell you stuff. You know, you don't close the window and stop answering phone calls, you know, when the engagement ends. So I assume this is stuff that came in straggle, whatever you call it.

Mr. Davis

To the best of your knowledge, did Mr. Steele pay any of his sources or subsources in the memoranda for information?

Mr. Simpson

I don't know. I think there's been a little bit of confusion I would like to clear up. Some people were saying that he was paying people for information. I don't know whether he does or not, but that's not basically how I understand field operations to work. You commission people to gather information for you rather than sort of paying someone for a document or to sit for an interview or something like that. That's not how I understand it works.

Mr. Davis

To make sure I understand, are you saying you don't pay for particular information, you would have an established financial arrangement with someone?

Mr. Simpson

If he did at all, but I did not ask and he did not share that information. He did not invoice me for any such.

Mr. Davis

Did Mr. Steele ever discuss his opinion of Mr. Trump with you?

Mr. Simpson

We didn't discuss our political views of Mr. Trump, I don't think, at least not that I specifically remember, if that's what you mean.

Mr. Davis

That is.

If I recall correctly, you said earlier that once Fusion had exhausted public documentary sources you turned to Mr. Steele and some other subcontractors for human intelligence; is that correct?

Mr. Simpson

Yeah, field intelligence.

Mr. Davis

Would your engagement with your client have ended had you not turned to human intelligence?

Mr. Simpson

I have no idea. I mean, I can't speculate.

Mr. Davis

Well, to clarify, when say you had exhausted the public documentation, are you saying you reached the end of your work or was there still more?

Mr. Simpson

No. It's a broad project, there's lots of things going on. We're pulling legal filings and bankruptcies and all sorts of other stuff on all kinds of issues. I was talking about specific lines of inquiry.

Mr. Davis

To the best of your knowledge, do Rinat Akhmetshin and Christopher Steele know each other?

Mr. Simpson

I don't know.

Mr. Davis

To the best of your knowledge, has Mr. Akhmetshin ever worked with Orbis?

Mr. Simpson

Not to my knowledge.

Mr. Foster

If Mr. Akhmetshin were one of the sources in the dossier, would you know that?

Mr. Simpson

I believe he would have told me that by now given the public controversy over this matter, but he hasn't.

Mr. Davis

I'm sorry. Is the "he"—

Mr. Simpson

Chris Steele.

Mr. Davis

How often would you say you interacted with Mr. Akhmetshin during the 2016 elections season?

Mr. Simpson

Infrequently, intermittently.

Mr. Davis

When was the last time you spoke with him?

Mr. Simpson

I don't remember, but I don't think it was—I just don't remember.

Mr. Davis

To the best of your knowledge, was Ed Lieberman aware of your Trump research project?

Mr. Simpson

Not to the best of my knowledge.

Mr. Foster

Could you just tell us generally who else other than your client was aware of the Trump research project as it was going on. So excluding your client and excluding your subcontractors, who else knew that you were doing it?

Mr. Simpson

Journalists.

Mr. Foster

In the summer of 2016?

Mr. Simpson

Yes.

Mr. Foster

And they knew that because you were telling them about it?

Mr. Simpson

We get calls from journalists who are working on stories about all kinds of subjects and some things we can answer questions on and others we don't. I'm a former journalist, as I think you know, and we do lots of different kinds of research and people who are working on a story will call us and say what do you know about, you know, Carter Page and we'll say, well, here's the things that we know.

Mr. Foster

And they're aware you're being paid to do that research for a client?

Mr. Simpson

I don't know. Generally that's not an issue.

Mr. Foster

So my question was who knew that you were doing the research, the Trump-Russia research at the time?

Mr. Levy

He answered the question. He told you he spoke with journalists and told them what he had found.

Mr. Foster

Right. I was trying to clarify. My question was whether or not they knew you were being paid to do that research.

Mr. Levy

He answered that question too and he said he did not explain that to the journalists.

Mr. Simpson

It's hard to generalize. I run a business, it's a research business. Reporters know we have clients who pay us to do research. So, you know, I don't remember any specific queries about whether we were being paid or not, but I think most journalists would assume that someone had paid us to do research.

Mr. Foster

They knew you were doing a Trump oppo research project as opposed to a Hillary Clinton oppo research project?

Mr. Levy

From 2015 through the end of the election?

Mr. Foster

Can you let the witness answer, please.

Mr. Simpson

The word "they" is extremely broad. Journalists would call and ask questions about specific things and from that they might conclude that we were doing a Trump oppo project.

It's just worth pointing out that in a political season all kinds of people are doing research on all kinds of things. Some people are interested in trade, other people are interested in guns. So you wouldn't necessarily intuit exactly what we were doing. Most people are interested in, you know—they're interested in the story they're working on. So some people will say, hey, I'm interested in whether Donald Trump gets his ties from third-world countries and they wouldn't ask about anything else.

Mr. Davis

You mentioned before, if I recall correctly, that Fusion was having issues with persons attempting to hack it?

Mr. Simpson

That's a current concern, yes.

Mr. Davis

When did that concern—when did you first become aware of that concern?

Mr. Simpson

Relatively recently.

Mr. Davis

So after the election?

Mr. Simpson

Yes.

Mr. Foster

Did you tell journalists that you had engaged Mr. Steele in the summer of 2016?

Mr. Simpson

I don't specifically remember doing that until the fall.

Mr. Foster

After the election or before?

Mr. Simpson

Before the election.

Mr. Foster

Can you remember the context in which you told them that?

Mr. Simpson

Yes.

Mr. Foster

Can you describe it for us, please.

Mr. Simpson

Sure. Essentially there was—at some point the controversy over the Trump campaign's possible relationship with the Kremlin became, you know, one of the main—major issues in the campaign and there were things that Chris knew and understood to be the case that only he could really explain in a credible way, and I thought that—we thought that he should be the one that explains them, you know. So we sat down with a small group of reporters who were involved in investigative journalism of national security issues and we thought were in a position to make use of him as a resource.

Mr. Foster

Do you recall whether that was before or after he ended his relationship with the FBI?

Mr. Simpson

Before.

Mr. Davis

Do you recall what the first published article—when the first published article came out that referenced material from the memoranda?

Mr. Simpson

Not specifically.

Mr. Foster

Earlier you talked about evaluating the credibility of the information in the memoranda that you were being provided by Mr. Steele and, by way of summary, you talked about your belief that he was credible and that you had worked with him before and the information he had provided you had been reliable in the past. Did you take any steps to try to assess the credibility of his sources, his unnamed sources in the material that he was providing to you?

Mr. Simpson

Yes, but I'm not going to get into sourcing information.

Mr. Foster

So without getting into naming the sources or anything like that, what steps did you take to try to verify their credibility?

Mr. Simpson

I'm going to decline to answer that.

Mr. Foster

Why?

Mr. Levy

It's a voluntary interview, and in addition to that he wants to be very careful to protect his sources. Somebody's already been killed as a result of the publication of this dossier and no harm should come to anybody related to this honest work.

Mr. Foster

I'm not asking him to identify the sources. I'm just asking what steps he took to try to verify or validate the information.

Mr. Levy

He's given you—

Mr. Foster

If he can answer generally without identifying the sources, I'd ask him to answer.

Mr. Levy

He's given you over nine hours of information and he's going to decline to answer this one question.

Mr. Foster

And several others.

Mr. Levy

Not many.

Mr. Davis

I think you mentioned that you were in London when you first heard that someone was interested in hiring Fusion to work on the Trump research; is that correct?

Mr. Levy

Repeat the question.

Mr. Davis

If I recall correctly, Mr. Simpson said that he was in London when he first heard that somebody was interested in hiring Fusion to do Trump research?

Mr. Simpson

That's my recollection.

Mr. Davis

Were either of the clients on this project not American citizens?

Mr. Simpson

Were either of the clients on this—

Mr. Levy

Clients on which project?

Mr. Davis

Were any clients on the Trump research not American citizens?

Mr. Simpson

I don't mind answering that if that's okay. They're domestic clients.

Mr. Foster

You said earlier that the information that you gather in your work is owned by the client, it's not owned by you, and so therefore you also referenced your nondisclosure agreements and that you felt like if you had information that related to national security or law enforcement that the nondisclosure agreement did not prevent you from disclosing that information to third parties. Is that a fair summary?

Mr. Levy

Wait. You said a lot there. Which third parties are you talking about?

Mr. Foster

Well, to law enforcement.

Mr. Levy

I think he's answered this already. You're asking him whether it was permittable under his contractual obligations to report a crime to the national security community, and he said yes, it's fine for him to do that.

Mr. Foster

Right. I'm trying to summarize the previous answer as a premise to my next question. Is that an accurate summary of what you said before?

Mr. Levy

Summarizing testimony is dangerous after he's given nine hours of it. If you want to ask him a question, ask him a question.

Mr. Foster

Is there a specific provision in your NDA that provides an exception for disclosure to law enforcement or intelligence agencies?

Mr. Levy

I think he earlier didn't talk about the contract, but if you want to talk about it as a matter of practice what your understanding is, go ahead.

Mr. Simpson

I don't know.

Mr. Foster My colleague Ms. Sawyer asked you earlier about public reports that the initial client on the Trump work was a Republican and that it's also been publicly reported that later there was another client who was a supporter of Hillary Clinton. Are you the source for any of those public reports? Mr. Levy

A hundred percent of what you were saying was referring to news articles, right.

Mr. Simpson

I've been asked about this by various journals as to what I've heard, whether they can report things that they've heard elsewhere, and I have not—I don't know if you'd classify that as being a source, but I've been asked those questions and I've avoiding getting into specifics. But I have—if people have accurate information of a general nature like that, I generally would not—I would confirm things.

Mr. Foster

Sorry. I didn't understand your answer.

Mr. Muse

It's quite clear.

Mr. Simpson

Depends on what you say a source is. If someone calls me and say I hear client No. 1 was a Republican, then I'd say I don't have any problem with you writing that. That's not quite the same thing.

Mr. Foster

So you confirm the accuracy of information?

Mr. Levy

He didn't say that.

Mr. Simpson

There are certain things that I've chosen not to deny. You know, generally speaking, I deal with a lot of journalists. I'm not going to mislead people.

Mr. Davis

To the extent you can clarify, is it that there were two sets of clients, one of whom was Republican and one of which was a Clinton supporter, or was it one person's whose views changed?

Mr. Levy

We're not going to get into the identity of clients. As you know, we've agreed to an interview about questions 5 through 13 of the March 24 request. Questions 1 through 4 talk about the identities of the clients. The Chair and the Ranking Member agreed with counsel for Mr. Simpson about the scope of this interview and that question is outside of it. In addition, the answer to that question would implicate privilege and obligations. He's talked to you for nine hours, he's given you a lot of information, and he's not going to answer questions about identities of clients.

Mr. Davis

You've asserted attorney-client work product privilege—

Mr. Levy

There is no such privilege. I've asserted the attorney work product privilege, we've asserted privileges under the First Amendment, we've asserted the attorney-client privilege, and we've asserted privileges of confidentiality. It's a voluntary interview and he's declining to answer the question.

Mr. Davis

I understand that.

Mr. Davis

So with the Prevezon matter, then, is it correct the law firm involved was Baker Hostetler and the ultimate client was Prevezon, is that right, while you were working there?

Mr. Simpson

Yes.

Mr. Davis

So any attorney-client privileges within the context of that information would be—the holder of that privilege is Prevezon; is that correct?

Mr. Levy

That's a legal conclusion that he's not qualified to draw.

Mr. Davis

You don't feel that you can speak to it without their permission?

Mr. Levy

Speak to what?

Mr. Davis

To questions that would be covered by attorney-client privilege.

Mr. Levy

I'm not sure he's qualified to answer that question.

Mr. Davis

Did you work with any law firms in relation to the Trump investigation?

Mr. Levy

Again, we're not getting into the identity of any clients—

Mr. Davis

I didn't say client.

Mr. Levy

I understand. Or their lawyers.

Mr. Foster

I think the issue we're trying to deal with is in order to assess your claims of privilege the committee needs to understand at least as much about the context of the dossier work as it does about the Prevezon work in terms of who was involved. So if there's a law firm involved or if he was reporting to a law firm or acting under the direction of a law firm, then we need to be able to assess whether or not that was in anticipation of litigation, whether he was doing it by the direction of a law firm in order to assess your assertions of privilege.

Mr. Levy

I understand. We've identified our position. We've been talking—Mr. Simpson has been answering your questions since 9:30 this morning, it's now 6:15. He's been fully cooperative and he's here because the Chair and the Ranking Member agreed to a limited scope. The questions you're asking are outside of that scope and this is part of why appearing at a hearing was going to be impossible. Through this agreement we're here. He's given you a ton of information. If you want to discuss the privilege with counsel after the interview, you may do so. He's answered a ton of questions today and he's going to decline to answer this last one.

Mr. Foster

The last one was did you work with a law firm on the Trump matter?

Mr. Levy

He's declining to answer.

Mr. Foster

There were several points in the interview where you made a point of saying your firm is not a Democratic linked firm in reference to the Sarah Huckabee Sanders quote. It's been publicly reported that you did opposition research for a client targeting Mr. Romney in the 2012 election. Obviously we've been talking about the Trump opposition research. Have you ever done opposition research regarding Mr. Obama?

Mr. Levy

We're not going to get into specific client matters that are outside the scope of this interview. He's told you he's represented clients on the right and left, but he's not going to get into other matters beyond Prevezon and what he did in the 2016 election.

Mr. Simpson

I did investigate Senator Obama's campaign in 2008 when I was working for the Wall Street Journal and wrote an article that caused his campaign chair to resign. The record is replete—or the public report of my work is replete with examples of investigations I've done of Democrats that resulted in them losing their elections and being prosecuted.

Mr. Levy

At the Wall Street Journal?

Mr. Simpson

Yes.

Mr. Davis

Are you party to a joint defense agreement related to your Prevezon work?

Mr. Levy

He's not going to talk about privileged discussions or agreements, and he's probably not qualified to answer anyway.

Mr. Davis

Is Fusion GPS paying Cunningham Levy for the firm's representation of you or as a third party?

Mr. Levy

That's privileged also. He's not getting into payments to his lawyers and it's beyond the scope of this interview which has now gone on for almost nine hours.

Mr. Davis

Has Fusion GPS ever offered directly or indirectly to pay journalists to publish information?

Mr. Simpson

No.

Mr. Davis

Are you aware of any Fusion clients offering directly or indirectly to pay journalists to publish information from Fusion?

Mr. Levy

While working for Fusion on a Fusion matter or as a general matter?

Mr. Foster

Can you let the witness answer.

Mr. Levy

Well, if the question's clear he can answer any question—

Mr. Foster

I think the question was clear.

Mr. Levy

-- within the scope of the interview—

Mr. Davis

Are there any of Fusion's clients offering—

The Reporter

Guys.

Mr. Davis

I'll repeat the question. Are you aware of any of Fusion's clients offering directly or indirectly to pay journalists to publish information from Fusion?

Mr. Simpson

Not to my knowledge or recollection, no.

Mr. Foster

What was the end date of the Trump engagement?

Mr. Levy

He told you he didn't recall exactly.

Mr. Simpson

That's not correct. The election was the end date. I assume you're asking about the general election? The election date would have been the end.

Mr. Foster

So you didn't do any work on the Trump matter after the election date, that was the end of your work?

Mr. Simpson

I had no client after the election.

Mr. Foster

It's 6:21. Let's go off the record for a minute.