159

guess, about two weeks ago now, returnable last Thursday.
The search that you talked about doing occurred in

April, in between any response to those subpoenas. But in
talking to you, it appeared that there had been a prior
search, and I’m not sure if it was on behalf of our
subpoenas or on behalf of the Church just trying to find any
documents relating to Miss McPherson’s death. That occurred
in December, and January and February of 1997.

And I want to ask you —— try to exhaust your
knowledge of that. And I realize there may be areas that we
may not agree on as to what’s privileged or not privileged,
but I’m going to ask the questions anyway.

you’re going to answer and not answer.

room, the facts of anything he did in the search we
have no objection to answering, but it might be prior
to his technical designation as records custodian. He
relied on that information as records custodian, he
didn’t redo what he did.

No problem. Only thing I would instruct you
not to answer, conversations between you and me
relating to the case, or otherwise privileged
conversations. But relating to your search you may