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that time probably civil litigation.

MR. McGARRY: It might have been under one of
my broader subpoenas.

MS. VAUGHAN: Right.

• And when John sat down and talked to Sandy
prior to his interview here, he said he talked to her
and kind of resolved the issue with her, and that she
would have created this document in the normal course
of her duties, even though it was also created for
lawyers.

So since that was the case, since it would
have been something she would have generated in the
ordinary course of her job, in addition to being for
lawyers, we decided that there wasn’t a very strong
work product privilege and we didn’t have any problems
waiving —- I mean, we didn’t want to waivea privilege
or work product privilege, but we didn’t think it was
pure work product or work product at all, so John gave
it to you first. And then I just Bates stamped,it and
gave it to you.

MR. McGARRY: Okay.

BYMR. McGARRY:

Q.
After you’ received this copy in L.A. by fax, is
there anything else you did in the first week of December in
reference to Lisa McPherson, of 1995?

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