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that time probably civil litigation.
MR. McGARRY: It might have been under one of
my broader subpoenas.
MS. VAUGHAN: Right.
• And when John sat down and talked to Sandy
prior to his interview here, he said he talked to her and kind of resolved the issue with her, and that she would have created this document in the normal course of her duties, even though it was also created for lawyers.
So since that was the case, since it would
have been something she would have generated in the ordinary course of her job, in addition to being for lawyers, we decided that there wasn’t a very strong work product privilege and we didn’t have any problems waiving —- I mean, we didn’t want to waivea privilege or work product privilege, but we didn’t think it was pure work product or work product at all, so John gave it to you first. And then I just Bates stamped,it and gave it to you.
MR. McGARRY: Okay.
BYMR. McGARRY:
there anything else you did in the first week of December in
reference to Lisa McPherson, of 1995? |
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