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analysis to the lawyers out here.

We had a central file, which is a particular type
of folder in the Church. Correspondence to and from the
person usually goes in there. She had been on Flag’s lines
for a little while, so I just figured there would be —— when
we got to that one I took that whole file and just copied it
for myself.

Except for the detailed search of the pre-Clear
folders, it was pretty much a matter of, all right, where is
that file? Good, give me the whole thing. The whole thing
goes over to the lawyers and let them parse through it to
determine what’s responsive to the subpoena or not. But the
way the subpoena was written, it was written in broad
categories of documents that would fit in a certain file
anyway, so I just took everything and sent it on.

Q.
Okay. So you weren’t doing an assessment of
documents to the extent that you were’ making determinations
of whether or not something was falling under a certain
privilege, whether or not it was, you know, something -- an
area that would be prohibited from the non-Scientologist’s
view. Were you making determinations in reference to that?

A.
No, not really. I didn’t really have to.
The only one of those that I would make and --

rather than leaving to the lawyers would’be priest/penitent,
like something from a pre-Clear folder that was forbidden

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