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Q.	Well, you nodded to -— to the attorneys here.

Obviously, they weren’t retained —- were they retained in
December of ‘95?

A.	It was late December sometime.

MS. VAUGHAN:

He said ‘95.

I’m sorry, ‘96.

No, I don’t know who.

Q.	Well, who would have an idea when —— if someone is

actually directing —— and we’ve been told at least by
counsel at the last portion of the statement that they
believe those reports are privileged because they were
drafted in contemplation of litigation. Now, obviously, we
don’t agree with that, but we were told that. That they
weren’t withholding them for that reason, but if they had
them, they would claim that privilege.

So I assume that if he’s telling me that, and
perhaps you don’t know, but —— but I assume since he told me
that, that someone made a conscious decision we need to do
reports ‘cause we might get sued. And I assume that would
not be the first time that’s happened in the history of the
Church of Scientology. And I assume that there must be some
organized manner, if you’re going to retain something for
litigation, to put it someplace so you can find it when you
need it or else what’s the purpose in doing it.

Right.