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Q.
All right. So chain of command, she could answer
directly with you, bypass Brian Anderson and never violate
the chain of command?

A.
I would have the authority to issue instructions
to her directly. I would then, in the normal course, at
least carbon Brian, if not go through him, yes.

Q.
The response backwards, the return, she would
normally —— she could call you directly on the telephone in
Los Angeles without talking to Brian?

A.
Certainly. It would be courteous to at least let
Brian know, but she certainly had the ability to do that and
the authority to do that.

Q.
Was it usual for the caretaker notes, along with
the Brenda Hubert and Craig Burton report, to be in the
PC folders?

A.
Craig’s and Brenda’s, not particularly. It would
•be information that a Case Supervisor would want to have if
one of his pre—Clears had an episode like that.

The caretaker’reports, that’s where I would expect
them t,o be.’ Since the Case Supervisor is monitoring her
progress and destimulating her, I would expect them to have
whatever reports caretakers wrote. It wouldn’t be in the
normal course to have a lot of those, necessarily, but what
ones existed he should have in the pre-Clear folder, yes.

Q.
Ben Shaw and Glen Steilo, do they work for you?

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