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A.
No. I don�t believe �� I believe it was counsel.
Q.
So you do a second search in April, but you have
no idea of the scope or the results, specific results of who
looked where for what and what they found or didn�t find?
 
A.
Prior?
Q.
Prior to that.
A.
No. I have some knowledge. I don�t know ��
let�s �- I don�t have a comprehensive knowledge. S
 
Q.
And you made no organized effort to learn. Is
that a fair statement?
 
A.
In particular relation to the PC folders, no.
Q.
Well, in particular reference to the caretaker
records or the records relating -- drafted by the three
people who transported her to the hospital?
 
A.
Not for this -- not for, those three people, no.
was looking for records. Those records, any records that
would have been written about the incident should be ��
should have been found, let�s say, by myself in my search.
 
Q.
Okay. Well, let�s go back then.
Where would those reports normally go to? The
reports of the three people who took her to the hospital,
what folder does that go to? 
 
A.
Well, I don�t know. I have no idea. They could
have gone to an ethics file, they could have gone to her PC
folder, I guess.

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