He may um, have told you something, but it does not appear that there's any evidence that the client ever waived and allowed that information to convey to you the next question. Thank you, judge. Um All right, let's see. So, um, we talked about um M Willis and Mr Wade coming to and from your office and security details um, following them. Do you recall that? Do I need to look at my phone? I think I did. Do you recall security taking Miss Willis to your office? I'm going to that. Um, does he? But you can answer the question, sir. Um, I do recall, um, security detail bringing Miss Willis to my office. Ok. Do you recall approximately when that was? I do not? And um, was that on more than one occasion? I remember two occasions? Ok. Yes. Can you tell me about those? I can't remember when they were, um, were they before she became D A? So I don't know if she had a security detail before she became D A. So, I mean, if she, if she was sworn in or I, I don't remember the dates. Uh, but I do remember, um, I think she was dealing, um, maybe during her transition team period. Was that? No, it wasn't. Um, I'm trying to remember. She would have had to have been the DAII, I think. Um, and I, I don't wanna go, I think, um, but I do remember twice, um, are coming to our office. Correct? And she had a security team. Both of those times. There was a, yes, she has a security team with her. Um, and do you believe that it's a different security team than she has now? I don't know, we security team now. However, I'm sorry, I, I don't know her security team now. Um, I don't know her security team. Now, you remember telling me that it changed at some point. Her security team. Yes. Uh, I think I recall saying that yes. And that the most likely people that, that could testify or had seen things about them having a romantic relationship early on would be the original security team. I don't recall saying that no. But do you recall talking to me about other people that might have known about their romantic relationship? I recall. Yeah, I mean, I objection based on we all know thesaurus, this is based on privileged information or it's, it's neither I need to clarify if you're actually gonna think if you think that the straws on information from outside the relationship that we've already, he's already testified to the need to lay that foundation. Are you aware of other people that you believe would have known about when their relationship began. I object to the relevance of that. Again, the witness has testified. He has no firsthand information of it. Anything he knows about the topic came from representation, who he thinks might have been able to say something else is speculation, not relevant to anything and a back door to get in the gossip and innuendo, that has been pretty much this entire, all right. Ok, Miss Merchant, I think we're getting to the point where, you know, the, the reason I thought this line of, of questioning was appropriate was to revise certain differences about why we're here in the first place. But to go into it at the granular level, I'm, I'm not as wild about. So maybe you can ask more over arching questions and if you have anything else, you think that's relevant, then you can get to those as well. Um, isn't that true that I gave you a copy of the motion to disqualify. In this case, I emailed it to you and you read it, reviewed it and emailed me back with everything and it was accurate to your knowledge. You emailed me and I, ok. All right. So there are things contained within that Miss Merchant, which he has now said, uh, fell within the privilege and that he did not have the ability to wait. So that's where we have to leave it there. And I believe I still have to ask the questions and then if he wants to assert the privilege, well, I think we pretty much already established the privilege and the objection has been made. And I think it's a valid one at this point based on the record. So the answer was he did acknowledge that you sent him the motion and I think we leave it at that. Um Let's see. Um And you had, you had knowledge about an apartment. I'm not asking what Mr Ray told you and for the rest of legal advice, but you had knowledge about an apartment in East Point or a condo, East Point that um was owned by someone and Miss Willis was staying there. I think in the way the question is phrased. She, she qualified that. So I did not have knowledge. You did not have knowledge. I did not have personal knowledge at all. So no knowledge outside of what is privileged. That's correct. Um Are you, did you have tests between um yourself Miss Willis and Mr Waite? Do I have you ever, I, I have maybe once or twice but did Mr Wade ever ask to use your credit card to pay for trips objection on, on um on life is still the same thing I just ask you, do you use your credit card? How is that in the nature of furthering a divorce proceeding? I have a business card and we would use my business card, the firm would use my business card for travel. Are you asking if I use my business card for traveling? Would Mr Wade use your business card for travel? I recall um I recall a trip. Um but I don't know if that trip has anything to do with this case. So I do recall him using my card once. When was that? And I don't even know when that was and that sounds true. Um I recall him using my card once, but I cannot remember what that was for. I do remember it was a trip but I cannot uh every state, you know, where it was and who was with the war, anything like that. And he paid you back for that trip in cash. I can't remember how you paid. Uh, I think it, I think it was, I mean, uh, I'm not, I'm not certain if it was cash or a check. Um, we routinely would use, uh, my card, um, for filings for, um, paper for whatever stuff at the office. And so, and so he would, whether he paid me back in cash or whether he wrote a check, uh, you know, it was paid back to the business card and, but this was the only time he had used it for travel. I cannot recall, I don't even have that business card anymore. Um, but I do recall at least once for travel. Yes. And, um, that was when you were still law partners with him that practice. Do you recall approximately when that was, um, you did not go on that travel with him though? Correct? And so he asked you to use your card for the travel. Yes. Uh, I mean, I'm, I'm assuming, um, I mean, he, we would use the card for F stuff and so it was a business card. Your business, my business card. Yes. The law office of Terence Bradley, correct? Ok. So it showed up on your account. That is correct. Ok. Wouldn't show up on his account. Is that correct? That that would be accurate? Yes. Um Do you know if this was before he became special D A in this case, special prosecutor, I cannot recall. Um Did you see he and Miss Willis together? You said you were in and out of the office in and out of the um das office? You saw them together, correct? In and out of my office or the DAS office, the DAS office, you saw them together in and out of the DAS office. Did I see them in and out? Um, well, if you prefer it like that. No, I saw him in and out of the office when I would be there doing my filter work for the tank team. He would come by, I rarely saw Miss Willis and Mr Wade together in the DAS office. So you brought the taint team. Let's talk about that for a minute. Tell me about, um, you did work as you had a contract as a taint lawyer, correct? Ok. And that was in the anti corruption unit. Um, uh, yes, I think so. Yes. Correct. And how did you get that contract? What do you mean, how did they get it? How did you get the contract? Um, it was, did you apply online? Oh, no. Um, it was proposed, um, we were, um, it was proposed by, I just came from the district attorney. I mean, I, I didn't, um I didn't speak directly with her. It was um with Mr Wade and he asked if we would be interested um, and having a contract with the Fulton County. Um, uh I think so. I mean, I, I can't recall if he asked us both together or not. Uh, rarely, um, we all handle several may not different things for the firm, criminal, personal injury, uh things like that. Uh Family law. And so really were we together um there at the same time, like for an abundance of times. So he may have called me and then he may have called Chris. I can't remember, I can't recall um how we got the contract but did, um was Mr Wade to your knowledge, part of the transition team from as well as to my knowledge, he was part of the transition team. Did he spend a lot of time at that office during this transition period? He did so from when Miss Willis took office to when you left the firm, did Mr Wade spend most of his time at the das office? You say most of his time? Are you saying just working business hours or I would say he spent, um I would probably say he spent the majority of time. If you say over 51% I would say yes, he spent over 51% of his time. And that was the entire time from when she took office to when you left the firm. I can't say that that was the entire time, but yes, it was majority of. Um, there was a, I mean, I can't pinpoint specifically when the time that he would. And um I think a um if my memory serves correctly, getting to the majority of the time it would have been um whenever he started with this, maybe as a special prosecutor when you said majority of the time, right? Ok. So let's talk about the time before he became a special prosecutor. Did he spend a lot of time at the D A office? Then he said, I mean, it depend on what you say is a lot. Um He spent time at the DAS office. And so just so we're clear you were hired first. Um On January 25th, both you and Mr Campbell were law partners and you were both hired by the D A uh January 25th, 2021. Is that correct? Repeat the question, I'm sorry, you and Mr Campbell, both were hired on a contract basis by D A Willis January 25th, 2021. Correct. Which contract are you? Tell me the first one, the contract, not the first appearance contract. The, well, you said the first one and the Tank contract wasn't the first contract. And so, ok, so the, so what was the first contract to my knowledge? The first contract was the first appearance. Ok, so, um let me just mark these and see what I'm building 23 24. 0.5. I got this one judgment they gonna reviewing in this contract, please. Six this rally showing up. It's the market. I said at 2324 and 25 and you get the six of those. Ok, I'll see you so on. Um, now that you've reviewed those, is it true that on January 25th, 2021 you got your first contract as taint wear as a tank lawyer? Yes, I see the date on, on that as a tank lawyer, but I'm also looking at this contract here um for first appearance and they, you know, there must have been, I I don't have it for me, but there must have been a contract before this. Ok. So you think there's 1/4 contract? Uh I can't say that there is or isn't what I do know is that we did first appearance during COVID and it was before 2021. So, I don't know. Um Yeah, you know, if I had a contract, a written contract at that particular time or anything. But I do know, I think that the, I mean, it's, you could look at the recordings because everything was recorded at that time. Um As to when the f the first appearance contract started and the tent contract started. So when the three of you were partners, you had at least two contracts to do paint work, which is a filter work. Um And then a con two, at least two contracts to do first appearance work pretty much throughout the entire two years. Right? Well, it renewed. So, I mean, um it just renewed so to uh yes, I mean, if it was the same contract, but it was a renewal of. Ok. And so, so how did you, and you said you got, you got these contracts through Miss Willis gave them to you, but it was through her knowing Mr Wade. Correct. Yes. Um I didn't have a, a meeting with Miss Willis or anything. Um It was, it was brought to the attention that um a contract was gonna be needed or awarded. Um And if we or if I was interested because this was over mine and I said yes and so, and so Mr Wade brought that to your attention, he asked if I was interested in doing the contract, correct? And then after that is when, as well as you know, would come in or I think we actually came down here or something, um, and sign the contract. Ok. Um, and so that is how you were paid, um, from Bolt County. These contracts from, from Fulton County government. Yes, ma'am. And you shared, um, your partnership, you shared a third of all your profits with Mr Wade at that time. Yes. And so his contracts, he got a contract that same year 2021 and he shared a third of all his profits with you. Correct? Yes, that should be fair. Accurate. Ok. So during 2021 2022 you all had two filter taint contracts. You had two first appearance contracts and you had Mr Wade's special counsel contracts. Correct? My firm had what I have here but Mr Campbell and Mr Wade were part of your front. Correct. So we didn't, I don't think at this time we had established W BC. Um, at this time, I think it was, I had mine, Chris at his Nathan at his and we operated in the same building. But if you ask me, did we fees share or, you know, without everything that came in. Yes, that is correct. So you weren't actually partners with fees share at this time. Well, yes, uh at this time, we were not. If we were at this time, I had law officer Terrence Bradley, um Chris Campbell PC and whoever Nathan's was, if I'm not mistaken, I'm just, and all these con the taint contracts and the Nathan's Special Council contracts, all of those were under the anti-corruption unit. Correct? First appearance was not under that, uh, the tank contract if I recall was under the, um, I, I don't, I don't think they called it. What, what are you calling it? You can take a look at your contract if you need. Ok. And I'm, I'm not asking about the first appearance I'm asking about the Taint contracts and then Mr Wade's contract which has already been admitted in Evans if you need to look at that. Ok. Let me know when you're done. We're ok. Well, I see on the first page where it says Taint Attorney and I'm, I'm trying to go through and I see where it continue says Taint Attorney, but it always says Fulton County District Attorney's office, your question was specific as to the anti corruption unit and I'm looking for the verbiage of anti corruption unit. So I apologize. No, take your time. Yeah, and see on both pages, I mean, it starts out Fulton County District Attorney's Office and then it just goes to initials F CD A. Um unless I'm overlooking where it says the anti corruption unit, then the contract was with the F CD A. I mean, unless you want to show me something, I'm just asking you and I didn't know if that would refresh your memory. Those contracts were for the anti-corruption Union. Right. Well, they were for the test. They worked for, I worked for the D A, I work for the D A. Ok. So just in general the D A correct, I work for Fulton County District Attorney's office in a, as a contract person as it says here. And, um, the, when you did the taint work you had to report to Sonia Allen. I did not, you did not. Who did you report to? Then? I can't remember his name. His, his first name was Brian. Ok. And, um, let's see. So I know you said you met with Miss Willis when you signed those contracts, right? Yes, I know I met at least one time to sign these contracts or to sign when I signed the contracts. Yes. Did you meet with her any other times? I did not personally meet with Miss Willis any other time. But, um, when you say meet, what, what do you, what do you mean meet with her with her? I mean, I would see Miss Willis um, in passing if I'm walking through the, through the office and something like that. Um, but no, I, I didn't have any meetings with Miss Willis. Ok. So the only time you met with her were when you signed those contracts, if I meet with, I may not sat down and had a conversation. I signed these contracts. So when I signed these, I met with her to say that I sat down and spoke with Miss Willis. Um Are you saying in life and you saying during this time, what are you asking me? I mean, if it's voluminous, I can narrow down the times, but I didn't, I wasn't, I haven't really heard a point in a while. Can we get along to something or we're gonna have to wrap it up? Um So I had one more question about your text. Um Have you ever been in any group text with anybody other than with me and somebody other than Mr Chopra and Mr Merchant, you gotta, you gotta narrow that down. I'm using my phone with him if there had been any other, any other texts and I think that state had some thing in rebuttal they mentioned. So I was just trying to clean that up before it got there to try to try one more time. Isn't it true that you've the only texts that you and I have ever had have been between me and you, me, you and Mr Chopra and me, you and John Merchant, correct? I leave my phone. So what they've said multiple times that there's this third party that we've talked to and I'm trying to establish a third party and I don't know why it was relevant but the States argued it so well, it, you know why it all the way up and maybe if I, I think you've been able to show OK, what, what maybe launched this and, and, and, and answer the, the state's initial claims. And so let's get back to the core of what we were here for, for this hearing. Is there anything else relevant to ask after you? Yes, just a few more questions after you. Um, after it became known that you were placed under, did you get a call from G box? I do? And was he um trying to determine if you were going to be giving information on this case? I can't, I, I don't know what he was trying to determine. Um He stated that uh it wasn't uh odd. Um I had not, I'm spoken to G um we are um colleagues, we are friends, we are um in the same fraternity gave us and when he called it was out of the blue, but he did call. Yes, ma'am. Ok. And you relate that to me as well. Correct? I did. And then um you also got a call from your best friend um who was relaying a message to you from Mister Wade. Correct? No. Uh I got a call saying that he got a call, not that a message that was supposed to be relayed to me. Um The call was um I know there's a hearsay. Um It, it's the response of the hearsay. That's why it happened. But I sure. So here's the objection as to the contents of the call. I believe the contents of the call were to remember your privilege. I took that as a threat. I think Mr Bradley took it as a threat and I think he would testify to that. Yeah, he hasn't testified to it. And he also said there wasn't any message relayed by Mr Wager and the party. Well, no, he didn't say anything about a party. So, assuming he did hear something from a party, what's the, uh, hearsay exception for that mis, um, I believe that it was a threat. So it's a statement against interest. I'm sorry, it's a, um, um, if, if he took it as a threat to influence his testimony, then it's not your side. That would be a best. All right. So I did not take it as a threat. Uh, if you're saying to the effect on the listener, perhaps, uh, then we'll go from there. Um, were you told to remember your privilege? Then the witnesses testified. He didn't take it as a threat. Understood. Um, over the objection, the test will be given the way it deserves. Can you, were you told to remember? I was not a witness. There may be a potential witness now in the courtroom because the person that miss me is referring to is sitting in the courtroom, she was, if that witness hasn't been told to testify, then I don't see any sequestration issues. I don't know who it is. I don't know his name. Ok. And so were you told anything to that effect. Mr Bradley. Repeat the question one more time. But so I was not told, remember my privilege, something about privilege. Remembering that I, I do recall um, privilege being um mentioned, but it wasn't remember your privilege or, you know, a, a threat of, of any sort. Did you immediately called me after, you know, I called someone else after you called me quickly there after then I talked to you that day. Yes, ma'am. Ok. Thank you. Sit up. No, because this is a defense witness. Is that the state's cross first cross? I had, we had, we had been doing it yesterday. I've been, this is the first time he's gone and then we go through all of the f and then you'll have your chance some foundation questions to begin with. Please. Your testimony as you began representing Mr Wade as his attorney on what date or what approximate date, I didn't have an approximate date and give me an approximate date when you began acting as Mr Wade's attorney. Um I would say it was, you know, if I'm I'm speculating, I, I really don't want you to speculate. I mean, you're the one that was the attorney and Mr Wade was the client. So give us the ballpark figure of when it was that you began acting as his attorney maybe 2017, 2018, I think maybe and the purpose for which you were retained his divorce. So according to you from that time period. Your communications with Mr Wade with regard to the divorce or any matters related to the divorce is your position are confidential. I'm sorry, are privileged. Correct. Yes. The yes. Ok. Good. Now, did you ever meet with Miss Willis and Mr Wade prior to and everything I'm asking you is prior to November of 2021. Ok. Keep that in mind. That's why are you yelling? I don't think he's yelling Mr Bradley. He's just speaking up. All right, let's say that. Let's go. Ok. Thank you prior to Mr Wade getting his, um, contract with Fulton County, which was November 1st of 2021. Ok. Just keep, please keep that in mind. November 1st of 2021. Right? Did you ever socialize with Mr Wade and Miss Willow prior to November 1st of 2021 I've never socialized with Mr Wade or Miss Willis in any setting. If you're asking, have I ever met with them, then I would say yes. But when you say socialize, what do you mean socialize? Have you ever gone out to eat with both of them before? 2021? I do not think first of 2021 out to eat with both of them before. When was she sworn in? I'm, I'm sorry, when was she sworn in? There was a dinner, there was a dinner before. I mean, when she was sworn in that I attended um, Shaquille o'neal. Was there. So it was, it was like her inauguration dinner. So I'm thinking that's before 2021. So I would say yes, for purposes of my question is in early January of 2021. Well, that is early January 2021. Uh Then, uh so yes, I mean, it will be before November. So if it was January, yes, that dinner would have been in, I, I'm assuming January. Ok. And any other time that you socialize, went out to eat, went to anyone's home. Do you know what socialized is? Exactly? So, no, I did not socialize with Mr Willis. I mean, uh with Miss Willis and Mr Wade. So prior to November 1st of 2021 did Miss Willis come to your offices, your offices? I mean, the offices that you shared with Mr Wade, I think she came once or twice to our office script and the purpose for which she came. I don't know we had separate offices. Um I do recall um Well, it's, I, I do recall some type of meeting happening at our office and I don't, I don't know what that was about. I wasn't a part of those meetings. Um There was a meeting, there were other people there. Um There were other people from the, I wanna say D A's office there maybe. Um ok, let's go back to the bases, Miss Willis came to your offices together offices on a couple of different occasions. I recall Miss Willis coming to my office at least twice and on at least one of those occasions, or you tell us, did Miss Willis meet privately with Mr Wade in his office that you observed or heard? I can't recall. You can't recall. Did she ever meet with you in your office, Miss Willis now? Probably in my office. No, I've never met privately in any office with her outside of signing this contract. Did Mr Wade prior to November 1st of 2021 ever talk to you about socializing with Miss Willis? I can't recall. You can't recall you asking me if he, if he ever mentioned to me that he socialized with Miss Willis, correct? And I'm saying I cannot recall if he socialized with Miss Will, if he ever mentioned to me that he socialized. Uh Did he ever mention to you that he ate and went out to dinner with Miss Willis again, time period before November 1st of 2021. Did he? That's your question Mr Wade ever tell you prior to November 1st of 2021 that he had socialized, gone out to eat, visited Miss uh Willis in anything other than a professional setting. I'm sure you did. Maybe um I don't recall any specifics of any dinners, any um specific places you, I mean, it's been three years ago, um the time frame, but I do not recall at this time whether or not he ever mentioned uh any dinners or socializing? Did Mr Wade mention to you that he visited Miss Willis at Miss Willis's then current abode, which would have been um a, a place, not her original house but a place she was staying in the period of uh 2021 before November 1 of 2021. And his question is, did Mr Wade ever tell you that he visited Miss Willis at her house? I don't think I can answer that privilege to rephrase the question you can. But otherwise, that would be on both grounds or just on the privileged ground. I didn't hear a second ground hearsay that that would be on privilege alone. Did you talk to Mr Wade at all about his relationship with Miss Willis prior to November 1st of 2021 I think he's just been laying a record, Mr Wade. It's OK. Uh And so on the same grounds, uh Mr said all on all subsequent grounds and apparently the relationship with Miss Willis in any way is a uh is covered by a privilege according to this witness. But I think the key words respectfully honor are according to this witness. So I'm trying to drill down to see if there are communications that are not within the privilege. I I can. So we need to acknowledge the privilege in the form of your question, right? You are, you're asking me to ask it as in a way saying are, are there any non previledge essentially. Did you ever communicate with Mr Wade prior to November 1st of 2021 about Miss Willis that was not privileged. And when we discussed this contract, um but this contract doesn't help. You have to give me a uh you said before, November 2021. No, first of 2021 before no, this, this contract for 1 25 21 is before that. So, I mean, we discussed this contract um and if I remember correctly point again, just give me that exhibit number so we can wrap that exhibit 23. OK. Hold on one second, one second on exhibit 23. Did I understand you to say that it was Mr Wade? That effect brought you and Miss Willis together for the contract? That would be accurate? Yes. OK. And, and what did you understand was the relationship at that point between Miss Willis and Mr Wade for Mr Wade to be able to bring you to Miss Willis for the contract? Not a hard question. I just say that again, Mr Wade is the one that basically says to you. Go see Miss Willis about this contract, right? That's a yes, correct. Yes. So Mr Wade had to have some knowledge you would sue, right? That you going to Miss Willis might bring you the contract. I never went to Miss Willis. So I I stated I never went to Miss Willis. I was told about the, that there was a potential contract and I was asked by Mr Wade if I would be interested in doing that contract. I never OK. My question to you is what was the basis that you understood? Mr Wade being able to essentially offer you that contract for Miss on Miss willis' behalf. That's a mischaracterization. Mr Wade offered it to him. I think he said he expressed interest and also, II I don't see the um the relevance of, of this at all. Um So just in terms of relevance or phrasing, I'll I'll over rule on those grounds. So question is standing on object two. Mr Bradley, can you repeat the question you've explained to us how the contract came to you? And I, my question is, what was your understanding of the relationship of Mr Wade and Miss Willis for it to have been offered or whatever word you want to use for him to have said um expressed to you whether you had an interest in the contract, Mr Evans is a privilege in my question. So as you say, I think you need to clarify, whether was it a privileged conversation that you had with Mr Wade that, that you know about the contract or knows the relationship is the question you're focused on is the nature I'm trying to do it in such a way. And I understand what the court said was the relationship that I asked you about just now between Mr Wade and Miss Willis that gave rise to the contract. Did you know about that relationship as a result of an attorney, client communication? No, I knew of that. Um, whatever work they did together, um, as municipal court judges. Um, that's, and how did you know that, who told you about the work that they did together as municipal court judges? Miss Ray told me that they, um, did work into at some conference? Ok. Now, this would have been something that Mr Wade said, put to your time period at the time that you were representing. Mr Wade. Correct? Said Mr Wade would have told you what you just told the court after you had established an attorney client relationship with Mr Wade. Correct. Yes. But he the, when he told me of then being at a conference, I mean, I, I don't, I'm not understanding how I really, I'm, I'm trying to understand your question. Well, my question is basically you had communications with Mr Wade directly that were not attorney client privilege, right? I've had conversations with Mr Wade that were not attorney client for. Yes, that involved Miss Willis. Correct. I just stated that they were at a conference. I don't know if whether or not that involved her or not. Well, if he's talking about her, that is if Mr Wade is telling you about Miss Willis and Mr Wade having met at a conference, right? And he's talking about Miss Willis. Correct. Yes. But he also told me about other people that he met at the conference, but he told you about Miss Willis as well. Correct. Uh, uh, I think so. Yes. So there were communications in which Miss Willis was at least a topic that was not covered by attorney client privilege. Correct. This particular instance I was told about a conference and, and when were you told this, I can't remember, uh, the dates, um, of the conference, but it was after, it would have been after the conference. OK. I'm trying to get just the time period here after the conference. I want you to understand from the record. I believe we've shown that the conference was sometime in October of 2019. OK. So could you give us an idea that being uh a fact when you would have had this communication about meeting with Miss Willis at the C Mr Wade meeting, Miss Willis at the conference? Um If the, if that's the conference that they were at, yes, then you know, I don't know how many um municipal court conferences there are. Um I do know that at the time that I was in the firm, Mr Wade was um he had some position with the municipal court, but right now, my only question is time wise, assuming it's October of 2019. When do you tend to remember what's your best recollection of when Mr Wade told you about? And I can't remember because I didn't even remember that it was October 2019 until you said that. Ok. So you don't have a present recollection. I do not remember that. Now had to be before the contract though in January of 2021. Correct that they met. No, no, that you were told about Mr Wade and Miss Willis meeting at the conference. Had to be nice. It would be, it would have been before the Yes. So what other communications did you have with Mr Wade about Miss Willis that are not privileged? We know what one about the meeting at the conference? Are you suggesting that that's the only one you ever had about Miss Willis? That isn't, I cannot recall any, I cannot recall. You cannot recall whether there were any other communications that weren't privileged, you know, I'll be specific and, and I understand there's probably gonna be injections, but I want the record to reflect. Did you have a conversation with Mr Wade prior to November 1st of 2021 about Mr Wade dating Miss Willis? Uh uh Mr W has risen an objection as to state for the record. Excuse me, Mr Evans say that again. Uh You don't have to answer the question. The next question, say that I understand it's been objected to in the court has uh sustain the objection. Can you tell us um the circumstances in which that is under which Mr Wade may have told you about dating? What I wanna do is try to figure out if we can you tell me if you want me, if I can do this, I'd like to know how the communications themselves took place, where they took place, how they took place under what circumstance, whether he was at the time, providing advice, seeking advice. So those are the basics if I can ask you to all those. But if the court's gonna sustain the objection to those, then I don't wanna waste your time. And that's something I'll cover in camera. So I'll note, uh, the question of the, uh, your, uh, your question for the record and I'll, I'll sustain the privilege objection to that. Ok? All of this prior to November 1st 2021. Ok. I'm gonna show you two text messages. I don't have heart document.
