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repor’~ was handed over to a security person. Is it within
the security person’s, to your knowledge, in your
involvement in the legal affairs of the Church, is it within
a security person’s authority or position to direct a
witness to an incident to write reports in contemplation of
litigation or would that have come from some other source?

A.
That would come from my position as a legal
officer. A security person wouldn’t write or request
reports in’ contemplation of litigation.

Q.
Okay.’ So they might be the conduit for’~the
directive, but they would not —-

A.
Exactly. S
Q.
—— be the initiating person?
A.
I would think so. I can’t think of any incident
where —— S

Q.
I realize you don’t know specifically in this
instance if that happened or not, I’m just asking generally
if that’s what you expect.

A.
Exactly.’ S
I —- I —— you have a security guard who sees a
situation, and it may be legal or litigious or may not. He
would normally write a report as’a Security Officer.

Q.
Do people have any standing orders, when you
have, to use your term, a not optimum situation like this,
to call you and let you know about it?

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