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of the reasons that it was prepared was to brief counsel.
gave what was the original that I found, which I think is a
copy, I’m not sure if it’s the actual original, as well as
some’ copies to the Church’s lawyers. And they passed it on
to Annie Mora’s attorney, who passed it on to you.

Q.
All right. I didn’t follow you there on all of
that.

You said a subpoena. Was that’my subpoena you’re
talking about?

A.
Yeah, your subpoena to the Church I gathered
everything for.

Q.
All right.
A.
And then the ,lawyers reviewed it.
And now we’re getting into an area where —- we’re
getting into conversations I had with them on decisions we
made which documents are privileged, so I don’t know how far
I can go along that.

MS. ‘VAUGHAN: If it will make it easier, I
can answer your question. ‘ ‘

MR. McGARRY: Okay.

MS. VAUGHAN: It is our impression that would
have been responsive to one of your subpoenas. When he

•
‘ first gathered the documents, the question was, is it
•
work product, because it was prepared for briefing
counsel on the issue inanticipatio,n of civil or -- at

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