14

13

Q.
A new file, brand new file?
A.
Yeah.
Q.
What would that file be called?
A.
It was just a working file that Brian Anderson
had.

Q.
It wouldn’t be called a PC file?
A.
No, of course not.
Q.
Wouldn’t be called an ethics file?
A.
No.
Q.
So it was just -—
A.
It was a working file.
Q.
All right. If you wanted to gain access to that
file from L.A., you would call Brian Anderson and you would
say, I want that file. And how would you characterize that
file? How would you --

A.
Any files you have on Lisa Mcpherson.
Q.
It would be any files?
A.
Yeah.
Q.
There isn’t a specific name for that
Brian Anderson file that was created?

A. No~ No.
‘ ‘
Q.
Okay. What items would be created —- what items
would go into that’ file?

A.
Well, it was whatever he would need or he felt he
would need in order to -- to do whatever he was doing on the

14