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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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