115

=duce them.

Mr. McAllister: We desire to state the
grounds upon which we base this refusal.

Mr. Sake: We object to that, on the
ground that you have no right to encumber
any deposition with such statements.

Q. 589 Mr. Cohen: Had you had any consult=
=ation with counsel on the subject before
you refused on yesterday to submit those
reports?

A. I had not.

Q. 590 Why did you think that they were
not pertinent to the issues of this case?

Mr. McAllister: We object, as irrelevant
and immaterial, to any inquiry as to the
witness's thoughts. We do not object to his
stating any facts. We advise the witness
that he is not bound to state his thoughts.

Q. 591 Mr. Cohen: What were the facts shown
on those papers which induced you to think
that they were not relevant?

A. I decline to state, unless my counsel
advise me that I should state.

Mr. McAllister: We advise the witness
not to answer that question.

Q. 592 Mr. Cohen: Are the sums total of the —
disbursements shown on each of those papers
the amounts that are shown on the two

[bottom left margin:] 114