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A.
Whatever you have is there. The last couple of
days are missing, as well as Swiss cheese throughout the
time period.

Q.
I was a little confused on your testimony here.
In response to the subpoenas again, is it your testimony
that you would gather up folders that you thought the
information may be contained in, then supply them to the
attorneys, and then the attorneys go through these folders
and supply us with the documents we’re asking for in the
subpoena?

A.
I’m not sure I understand your question.
That was said in response to a question from him,

whether I made the decision to produce or withhold any
specific documents. I did not. I went through every piece
of paper that I pulled. And the subpoenas were phrased in
terms of describing a certain type of folder. So if it was
in the folder, I gave it to counsel. But I did go through
it and look at it to make sure it was there.

Q.
Okay. So then —- and then counsel would not
supply the whole folder, they would go through the folder?

‘A. Well, counsel went through the folder. I believe
we supplied everything except for a couple of things that
were privileged that —— one is Annie’s report that later

became available.
‘ ‘
MR. FUGATE: Well, let’s -- I think where

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