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document. And I’m asking, did he talk to him about
it, on that topic in response to the subpoena.
You presented him as someone who’s done a
search, okay? He says the documents should be in
possession of this person. And you’re telling me I
can’t ask him if he found out if that person had the
documents?
MS. VAUGHAN: If Bob Johnson, another lawyer
representing the Church, had them, just like, if we had
them In our office, you’d have them.
 
MR. CROW: I’m sorry, I disagree physical
possession of evidence is a privileged fact.
 
Q.
Would you answer the question, please, or invoke
your privilege., but take your pick.
 
A.
What is the --
S
Q Did you ask Mr. Johnson orally or in writing if he
knew anything about these documents?
 
A.
Not in writing, but verbally.
Q.
Okay. 
A.
And he identified some files in his office and I
went to his office.
 
  Q Okay. Let’s backtrack.
Did you ask him about the reports of these three
people we’re talking about? 
 
A. No, sir. No.
 

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