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Q Individual tactics are expressed by higher-ups?
 
A What do you mean?
 
Q Check lists?
 
A Oh, yeah, all that is issued from senior
management.
 
Q Okay, and that is derived from the policies
that are still in place?
 
A
Yes.
Q And those can’t be changed?
 
A
No.
MR. TYSON: Judge, I have just one follow
up question since this is a proffer, I would be allowed
to go back and go outside the scope of the redirect a
little bit, if you will allow me?
 
THE COURT:
No problem, go ahead.
RECROSS EXAMINATION
 
BY MR. TYSON:
 
Q If you were filming me right now and I was
putting a little laser pen-light right in your face while
you are filming me, do you know what I am talking about?
 
A Uh-huh,
 
Q Do you know what a laser pen is?
 
A Yes, sir.
 
Q Would that be “Fair Game”?
 
A
No.

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