|
75
out.
|
Q.
|
Who has ultimate say what goes to the attorneys?
|
|
Q.
|
You can look through the files without consulting
|
with your superiors
--
|
A.
|
Uh—huh. I would consult with General Counsel if I
|
had a question.
|
Q.
|
So your training is such what you can decide what
|
you consider privileged an’d what’s not?
|
A.
|
Our criteria is broad enough I can make that
|
determination. I leave the determination of privilege to
the lawyers involved. If the request concerns apples and
pears, I’m experienced enough not to pull out reports
concerning, oranges in response to it.
|
Q.
|
Did you
—-
when you found these caretaker notes,
|
did you look through those caretaker notes?
|
Q.
|
Did you ever see any reports written by
|
Heather Petzoid?
|
A.
|
No, I don’t believe I did.
|
|
Q.
|
Did you ever see any reports dated the 4th or
|
5th of December?
‘
|
A.
|
Just the summary in Annie’s
——
Annie’s report.
|
|
