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S.’


search, somebody intentionally withheld them, whether I

can hold that’ person in contempt or not. So I’m a
little —- I’m a little unclear with 5the ambiguity in
the response. And that’s something that we may need to
work on when I get ‘back from vacation. But
——
MS. VAUGHAN: Well, what we can say is that

they don’t exist, and they haven’t been analyzed for
purposes of work product.

MR. CROW:
You’ve told us that.
MS. VAUGHAN: And we conducted an e~’tensive

search. That was Glen’s purpose. Glen was not to be a

fact witness, go from A person to B person to R person,

it wouldn’t be helpful. S

MR. CROW:
I think it would be very helpful.
MS. VAUGHAN:
How can he conceivably.
MR. CROW:
He could have asked people.
I’m not going to debate --

MS. VAUGHAN: He is from the
Church of Scientology. There are a number of witnesses
in the case, and when we got in the case we would
request that Mr. Steilo not speak to other witnesses in
the case. And I think that’s standard. Plus these
people are represented by counsel. I don’t think that
that is
—— I mean, I understand that you’re upset about
that, but I don’t think that that’s standard --

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