230

Q Did he ask for that, did the prosecution ask
for that?

A No, he didn’t.

Q You brought it up yourself?

A Yes, I did.

Q Is that part of the Office of Special Affairs
then, to conduct these investigations into critics?

A These files were obtained from the legal
department, where we do keep files on individuals that we
have -- or could potentially have litigation with.

Q Do you ever do that investigation?

A I do legal research.

Q Legal research, let’s see now, legal research,
does that mean like looking into a person’s past, looking
into public records and documents, things like that?

A It means doing court checks, looking into court
records, depending on what it could be. It could be like
looking into -- researching different medical
information, depending on ——
Q Medical information of Mr. Minton?
A No, no. Any type of medical information that

might be needed for a case, not personal medical
information.

Q Who does the personal investigation and
interviews of critics like Mr. Minton? What part of the