[A CA Guy]

How broad a scope of a deposition is expected to be had?

It is possible with a small scope that she could fake not knowing or admitting something in the context of a narrow scope as a dodge IMO.

I hope you get wide latitude.

[A CA Guy]

Speaking of wide latitude, are seats big enough these days to seat her?

[doug from upland]

Peter has home video of Hillary at the events. In her deposition she claimed that she might have spoken to him at one or both of the events (Spago lunch and Gershman tea) but couldn't remember anything they discussed. In fact, at Spago they sat next to each other for an hour and a half. He has her on tape talking about how she doesn't use email anymore because it would be subpoenaed. She is not going to get away with claiming she has no recollection. She told Stan Lee he was a genius for hiring Peter. She knew he was smart before but now he was in the stratosphere.

[doug from upland]

I think there will be a broad scope. When the judge sees all the video evidence that contradicts here lying declaration, I don't think he will be pleased.

At the Gershman tea, he is standing behind where she is sitting to introduce her. He introduces discusses Winter Carnival at Dartmouth. A friend of his had a blind date with her back in the early 1970s. She gets a big laugh when she turns and says for him not to tell everything. She doesn't remember that?