14

cycle. Now, that’s admittedly kind of vague and general,
but it would be the file he would keep at his desk to do
whatever he needed to do.

Obviously, he was going to be responding to

questions from the attorney, questions from the media. So
were I in his shoes, I would have whatever summary existed
about the matter, and then probably copies of press, if any
resulted, correspondence with the lawyers --

this copy just recently, but I actually got it from a lawyer
that represented Annie Mora first.

Do you have any specific knowledge how —- I didn’t
subpoena this document, it was given to me gratuitously by

counsel. Do you have any firsthand knowledge of how I came
to get this? I mean, were you involved in that? •

whether —- all of my knowledge isn’t firsthand --

Q. Right.
A. -- but most of it is. ‘
Q. Okay.
A. That was one of the documents that I f,ound in --
when I was gathering up documents for our subpoena. There

was a concern whether or not it was privileged, because one