156

248

available?

MS. VAUGHAN:

Although we didn’t have any

discussions about it, it is classic work product. If

you take look at it, it’s classic work product.

Whether or not --

R. CROW:

Where did that go? Did that go to

counsel?

MS. VAUGHAN:

To Bob.

MR. CROW:

Mr.. Johnson?

MS. VAUGHAN:

Bob Johnson.

MR. CROW:

Okay.

MS. VAUGHAN:

So I think, whether or not

we’ll quibble —-

MR. FUGATE: Went two ways, went to counsel

in L.A. and went to Bob Johnson.

MS. VAUGHAN: —- we can talk about that one,

what we don’t want to do is waive some kind of general
work product privilege. And you know the waiver is
obviously a problem. So, you know, there’d have to be
some form of agreement.

But the -- I think last week it appeared and
from your letter it appears that you may think that
there’s some group of documents that once existed or
that we’re not handing over based on the work product
exception.