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S
document~. And I’m asking, did he talk to him about
it, on that topic in response to the subpoena.

You presented him as someone who’s done a
search, okay? He says the documents should be in
possession of this person. And you’re telling me I
can’t ask him if he found out if that person had the

S
documents?
MS. VAUGHAN: If Bob Johnson, another lawyer
representing the Church, had them, just like, if we had
them In our office, you’d have them. ~“ S

MR. CROW: I’m sorry, I disagree physical
possession of evidence is a privileged fact.

Q.
Would you answer the question, please, or invoke
your privilege., but take your pick.

A.
‘What is the -- S
S
Q~ Did you ask Mr. Johnson orally’ or in writing if he
knew anything about these documents?

A.
,S Not in writing, but verbally.
Q.
Okay. S 5
A.
And he identified some files in his office and I
went to his ,off ice. ‘ S - S

S Q• Okay. Let’s backtrack.

Did you ask him about the reports of these three
people we’re talking about? S

A. No, sir. No.
S S

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