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report was handed over to a security person. Is it within
the security person’s, to your knowledge, in your
involvement in the legal affairs of the Church, is it within
a security person’s authority or position to direct a
witness to an incident to write reports in contemplation of
litigation or would that have come from some other source?

officer. A security person wouldn’t write or request
reports in contemplation of litigation.

directive, but they would not —-

where ——

instance if that happened or not, I’m just asking generally
if that’s what you expect.

I —- I —— you have a security guard who sees a
situation, and it may be legal or litigious or may not. He
would normally write a report as a Security Officer.

have, to use your term, a not optimum situation like this,
to call you and let you know about it?