156

216

testified to?

MR. CROW:

Well, he hasn’t testified to

anything in March of this year, that’s why I asked
that.

Q Did you do anything in February concerning those

records?

A.	I’d have to see the subpoena to refresh my memory.
	THE	WITNESS:	Is this it?
	MR.	FUGATE:	Yes.
(Pause.)
	THE	WITNESS:	This is after -—
	MS.	VAUGHAN:	The problem I have with the

question is that these records that were subpoenaed in
more specific subpoenas were clearly already subpoenaed
or we assumed them to be subpoenaed in the earlier
subpoenas.

MR. CROW:

So do we.

MS. VAUGHAN:

Right. So if you say, did he

do anything to look for these records, his search in
response to the first subpoenas would be responsive to
your question, because he had already looked for them
before you served the second subpoenas.

MR. CROW:

Right. And last week he was very

unclear if he had any involvement in the initial search
in March that you responded, I think, March 11th with a