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Official - Subject to Final Review
kinds of communications they're having with people who
could not reasonably be thought to be foreign agents.
JUSTICE GINSBURG: What other measures
besides having to travel to have conversations?
MR. JAFFER: I think it's a spectrum,
Justice Ginsburg. It begins with just being more
circumspect on the telephone, and it goes to, for
example, talking in generalities rather than specifics.
Let me see if I can give you actual
citations for these. So -- so -- so, the Plaintiffs
have in some cases been deterred from communicating on
e-mail or the phone. Chris Hedges discusses that at
366a of the appendix; Scott McKay discusses it at 371a.
In some instances, the Plaintiffs have
talked in generalities rather than specifics. Sylvia
Royce at 352a.
In some instances, it has even required
Plaintiffs to travel overseas to gather information that
they might otherwise --
JUSTICE GINSBURG: Well, the travel overseas
I understand is the one thing that has a dollar amount
attached to it.
MR. JAFFER: Right.
JUSTICE GINSBURG: But these others -- these
other precautions, being more circumspect in their
38
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