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BY MS. PLEVIN:

Q. I WANT TO CLARIFY -- LET ME ASK A QUESTION IN A SLIGHTLY DIFFERENT WAY BECAUSE I THINK I MISSTATED IT YESTERDAY. BETWEEN 1980 AND THE DEATH OF MR. HUBBARD, AT ANY TIME DID YOU MEET WITH AN INTERMEDIARY ON BEHALF OF MR. HUBBARD, SPECIFICALLY PAT BROEKER, WHO AT THE TIME YOU MET WITH HIM, YOU BELIEVED TO HAVE BEEN SPEAKING ON BEHALF OF MR. HUBBARD FOR YOU -- OR TO YOU?

MR. HELLER: ARE YOU GOING FIRST, MR. HERTZBERG?

MS. PLEVIN: THERE IS EXTENSIVE COLLOQUY.

MR. DRESCHER: THERE IS NO COLLOQUY WHATSOEVER.

MR. HERTZBERG: THERE IS NO COLLOQUY. GO AHEAD, RESPOND TO THE QUESTION.

MR. DRESCHER: THERE IS CONSULTATION BETWEEN TWO COUNSEL WHO ARE REPRESENTING THE WITNESS. MS. PLEVIN: AND THERE IS A CONFERENCE BETWEEN COUNSEL AND THE WITNESS.

MR. HERTZBERG: FOR ABOUT TEN SECONDS NOW HE'S BEEN READY TO ANSWER THE QUESTION.

MS. PLEVIN: OKAY.

THE WITNESS: NO.

MR. HERTZBERG: I WAS TRYING TO -- AND I'LL MAKE -- THE ANSWER IS "NO." I'M GOING TO TELL YOU EXACTLY WHAT SAID TO MR. LIEBERMAN, MY CO-COUNSEL IN THIS CASE. BECAUSE YOU'RE REVISITING AN AREA THAT YOU COVERED EXTENSIVELY YESTERDAY, I JUST WANTED TO MAKE SURE THIS PARTICULAR QUESTION HADN'T BEEN ASKED AND ANSWERED BEFORE.

MS. PLEVIN: FINE, GOOD.

MR. HERTZBERG: AND HAVING DETERMINED THAT, I TOLD MR. MISCAVIGE TO GO AHEAD AND ANSWER IT, AND HE SAID, "NO."

MS. PLEVIN: VERY GOOD.

Q. NOW, DID YOU HAVE ANY COMMUNICATIONS FROM MR. HUBBARD WHILE YOU WERE -- AFTER YOU ARRIVED AT GILMAN HOT SPRINGS, IN WRITING, EITHER BY TYPED COMMUNICATION OR TELEX REGARDING THE MANAGEMENT OF THE CHURCH OF SCIENTOLOGY OF CALIFORNIA? A. AFTER I -- I MISUNDERSTOOD THAT QUESTION. YOU SAID, "AFTER I WAS BRIBED AT GILMAN HOT SPRINGS?" IS THAT WHAT YOU SAID?

Q. NO. NO, AFTER YOU -- I'M SORRY.

A. COULD YOU GIVE ME THE QUESTION AGAIN? I'M SORRY, I MISSED IT. I GOT STUCK THERE.

MS. PLEVIN: PLEASE READ IT BACK.

(RECORD READ AS FOLLOWS: "QUESTION: NOW, DID YOU HAVE ANY COMMUNICATIONS FROM MR. HUBBARD WHILE YOU WERE -- AFTER YOU ARRIVED AT GILMAN HOT SPRINGS, IN WRITING, EITHER BY TYPED COMMUNICATION OR TELEX REGARDING THE MANAGEMENT OF THE CHURCH OF SCIENTOLOGY OF CALIFORNIA?")

THE WITNESS: OKAY. I UNDERSTAND THE QUESTION.

MS. PLEVIN: CONFERENCE.

(ATTORNEY-CLIENT DISCUSSION HELD OFF THE RECORD.) THE WITNESS: NO.

BY MS. PLEVIN:

Q. DID YOU HAVE ANY COMMUNICATIONS FROM MR. HUBBARD, IN WRITING, EITHER BY TELEX OR TYPEWRITTEN FORM, REGARDING THE MANAGEMENT OF OTHER SCIENTOLOGY ORGANIZATIONS OR CORPORATIONS AFTER YOUR ARRIVAL AT GILMAN HOT SPRINGS? A. I DON'T KNOW WHAT YOU MEAN BY "OTHER," BY THE WAY. AND DEFINE FOR ME YOUR TERM "MANAGEMENT" AND "OTHER." YOU SAID, "OTHER." OTHER THAN WHAT? I DON'T KNOW WHAT THAT MEANS.

Q. OTHER THAN THE CHURCH OF SCIENTOLOGY CALIFORNIA.

A. I DON'T GET THE QUESTION. I DON'T KNOW WHAT YOU'RE ASKING ME.

MS. PLEVIN: PLEASE READ THE QUESTION BACK.

(RECORD READ AS FOLLOWS: "QUESTION: DID YOU HAVE ANY COMMUNICATIONS FROM MR. HUBBARD, IN WRITING, EITHER BY TELEX OR TYPEWRITTEN FORM, REGARDING THE MANAGEMENT OF OTHER SCIENTOLOGY ORGANIZATIONS OR CORPORATIONS AFTER YOUR ARRIVAL AT GILMAN HOT SPRINGS?") MS. PLEVIN: CONFERENCE --

MR. HELLER: DO YOU AUTOMATICALLY --

MS. PLEVIN: -- BETWEEN WITNESS AND COUNSEL.

MR. HELLER: -- NOTE IF THERE'S A CONFERENCE?

THE REPORTER: YES.

MR. HELLER: SO IT'S NOT NECESSARY FOR YOU TO SAY THAT EVERY TIME.

(ATTORNEY-CLIENT DISCUSSION HELD OFF THE RECORD.)

THE WITNESS: TELL ME WHAT YOU MEAN BY "MANAGEMENT." YOU DEFINE FOR ME "MANAGEMENT."

BY MS. PLEVIN:

Q. WELL, WHAT DO YOU UNDERSTAND "MANAGEMENT" TO MEAN, MR. MISCAVIGE?

MR. HELLER: NO. NO.

THE WITNESS: I DON'T UNDERSTAND THE QUESTION.

MR. HERTZBERG: HE DOESN'T UNDERSTAND THE QUESTION. WOULD YOU, PLEASE, EXPLAIN THE QUESTION?

BY MS. PLEVIN:

Q. DO YOU HAVE AN UNDERSTANDING AS TO WHAT "MANAGEMENT" MEANS?

A. I DON'T UNDERSTAND THE QUESTION. I DON'T UNDERSTAND WHAT YOU MEAN BY "MANAGEMENT" WHEN YOU USE THAT TERM. YOU ALSO ASKED ME NUMEROUS THINGS.

Q. OKAY.

A. I'M QUITE WILLING TO ANSWER IF YOU MAKE IT CLEAR TO ME EXACTLY WHAT YOU'RE ASKING ME.

Q. I'M READING FROM "THE COMMAND CHANNELS OF SCIENTOLOGY," A BOOKLET COPYRIGHTED BY CSI IN 1988, WHICH WAS ALSO IN DISCUSSION YESTERDAY, WHICH DEFINES, FROM AN LRH ESSAY ON MANAGEMENT, THE FOLLOWING, "MANAGEMENT COULD BE SAID TO BE THE PLANNING OF MEANS TO ATTAIN GOALS AND THEIR ASSIGNATION FOR EXECUTION TO STAFF AND THE PROPER COORDINATION OF ACTIVITIES WITHIN THE GROUP TO ATTAIN MAXIMAL EFFICIENCY WITH MINIMAL EFFORT TO ATTAIN DETERMINED GOALS."

A. SO I'VE READ THE ESSAY ON MANAGEMENT; IS THAT YOUR QUESTION?

Q. NO.

A. I'VE ALSO READ THIS BOOK WHICH IS 1988, WHICH IS EIGHT YEARS AFTER THE QUESTION YOU'RE ASKING ME. I'M NOT SURE WHAT -- WHAT EXACTLY DO YOU WANT TO KNOW? Q. USING THAT DEFINITION OF MANAGEMENT, MR. MISCAVIGE, DO YOU --

A. OKAY. GIVE ME THAT.

Q. THERE YOU GO (INDICATING).

A. WHEN ARE YOU ASKING ME THIS?

Q. THERE'S THE DEFINITION OF MANAGEMENT. YOU'VE ASKED WHAT THE MEANS.

A. NO. NO. I'M ASKING WHEN. YOUR QUESTION DOESN'T --

Q. ALL RIGHT.

A. WHAT TIME FRAME? WHEN ARE WE TALKING ABOUT?

Q. I'M ASKING, SUBSEQUENT TO YOUR ARRIVAL AT GILMAN HOT SPRINGS. MISS COURT REPORTER, WOULD YOU, PLEASE, READ BACK THE QUESTION?

(RECORD READ AS FOLLOWS: "QUESTION: DID YOU HAVE ANY COMMUNICATIONS FROM MR. HUBBARD, IN WRITING, EITHER BY TELEX OR TYPEWRITTEN FORM, REGARDING THE MANAGEMENT OF OTHER SCIENTOLOGY ORGANIZATIONS OR CORPORATIONS AFTER YOUR ARRIVAL AT GILMAN HOT SPRINGS?") THE WITNESS: WHEN? JUST THEN?

BY MS. PLEVIN:

Q. AFTER YOUR ARRIVAL AT GILMAN HOT SPRINGS UNTIL HIS DEATH.

A. ANY? YES.

Q. ABOUT HOW MANY?

MR. HERTZBERG: DON'T GUESS.

BY MS. PLEVIN:

Q. MORE THAN TEN?

A. YOU TELL ME EXACTLY -- I DON'T GET EXACTLY WHAT YOU -- WHAT EXACTLY YOU'RE WANTING TO KNOW ABOUT THIS. I'M GOING TO BE EXTREMELY PRECISE HERE.

YOU SAY ABOUT MANAGEMENT. SO IF I READ THIS DEFINITION, LIKE ABOUT THIS PARAGRAPH, I DON'T KNOW THAT I RECEIVED ANY.

Q. NO, ABOUT THE CONCEPT WHICH THAT PARAGRAPH DEALS --

A. WELL, THIS --

Q. -- WITH, MR. MISCAVIGE.

A. THIS IS A CONCEPT.

Q. I REQUEST THAT YOU RESPOND --

MR. HERTZBERG: WAIT, WAIT.

THE WITNESS: THIS IS A CONCEPT OUT OF AN ESSAY ON MANAGEMENT. NOW, IF YOU'D LIKE -- DO YOU HAVE A COPY OF THE ENTIRETY OF THE ESSAY ON MANAGEMENT WHICH WE PROBABLY SHOULD READ HERE JUST SO WE'RE NOT -- SO WE HAVE A COMPLETE -- THIS, OBVIOUSLY, WAS NOT WRITTEN FOR THIS DEPOSITION. THIS WAS WRITTEN FOR --

MS. PLEVIN: MR. MISCAVIGE --

THE WITNESS: -- SCIENTOLOGISTS.

MR. HERTZBERG: WOULD YOU LET HIM FINISH? HE DOESN'T UNDERSTAND EXACTLY WHAT YOU'RE LOOKING FOR. HE'S ASKING YOU SOMETHING SO THAT WE CAN CLARIFY THIS AND MOVE ON; SO HE CAN ANSWER THE QUESTION. HE'S TRYING TO ANSWER THE QUESTION. THE WITNESS: YOU'RE ASKING ME ABOUT A PARAGRAPH OUT OF THIS, AND I THINK --

MS. PLEVIN: ALL RIGHT.

THE WITNESS: I THINK IF YOU HAVE THE ESSAY ON MANAGEMENT, LET'S TAKE A LOOK AT THE WHOLE THING, AND MAYBE I COULD -- IF THAT'S WHAT YOU'RE TALKING ABOUT, I CAN PROBABLY ANSWER IT MORE EASILY.

I MEAN, IF YOU LOOK AT THIS, THIS IS A PRETTY -- THIS ISN'T A DOINGNESS. THIS IS A STATEMENT, A CONCEPT. YOU'RE READING TO ME ABOUT A CONCEPT? I DON'T KNOW. I HAVE TROUBLE WITH THAT.

MS. PLEVIN: I WILL NOTE FOR THE RECORD THAT I WILL CONSIDER THIS A FAILURE TO ANSWER THE QUESTION AND, THEREFORE, SUBJECT TO A MOTION TO COMPEL. NOW, I WILL TRY TO GIVE YOU A DIFFERENT DEFINITION --

MR. DRESCHER: WAIT.

MS. PLEVIN: -- AND PERHAPS WE CAN MAKE --

MR. DRESCHER: WAIT A MOMENT. THIS IS A FAILURE TO PHRASE A QUESTION THAT THE WITNESS UNDERSTANDS. I DON'T BELIEVE THERE'S A MOTION TO COMPEL A PROPER QUESTION.

MS. PLEVIN: FINE.

MR. DRESCHER: I WISH THERE WERE.

BY MS. PLEVIN:

Q. I'LL TRY TO PHRASE A DEFINITION OF MANAGEMENT WHICH PERHAPS YOU CAN WORK WITH, MR. MISCAVIGE.

A. I'M NOT ASKING YOU FOR A DEFINITION. I'M ASKING EXACTLY WHAT DOES YOUR QUESTION MEAN? YOU WERE ASKING ME A QUESTION THAT I CONSIDER ABOUT AS GENERAL AS, "DID ANYBODY EVER SPEAK TO YOU ABOUT LIFE?" I MEAN, I DON'T KNOW HOW TO ANSWER THAT QUESTION. IT'S A BIG, BROAD, GENERALITY.

I WANT TO ALSO NOTE THAT I'M NOT TRYING NOT TO ANSWER THIS. I AM QUITE WILLING TO ANSWER THIS.

I HAVE A PROBLEM WHEN YOU USE SCIENTOLOGY TERMINOLOGY OR SCIENTOLOGY SCRIPTURES AND DISTORT THEM. I'M NOT GOING TO SIT HERE AND LET YOU ALTER THEM OR ADD TO THEM. I KNOW IT -- I KNOW FAR MORE ABOUT THE SCRIPTURES OF THE CHURCH THAN YOU DO, AND I'M NOT GOING TO HAVE YOU PULL IT OUT AND FALL INTO THAT GAME.

AND FURTHERMORE, I'M GOING TO BE EXTREMELY PRECISE SINCE YOU HAVE ALREADY HANDED ME A DOCUMENT IN THIS DEPOSITION WHERE YOU ABSOLUTELY ADDED A PAGE TO IT: WE'RE BOTH AWARE YOU DID. IT WAS NOT THERE, AND NOW I'M ON MY TOES BECAUSE I, QUITE FRANKLY, CAN'T TRUST THAT WHAT YOU'RE ASKING ME -- I CANNOT FIGURE OUT WHAT IT IS, AND I'M NOT GOING TO ASSUME THAT I KNOW WHAT IT MEANS. I WANT YOU TO EXPLAIN IT TO ME PRECISELY, AND I WILL ANSWER ANY QUESTION THAT I UNDERSTAND AND THAT IS STATED CLEARLY.

AS FAR AS I'M CONCERNED, YOUR QUESTIONS ARE GARBLED TO ME. YOU THROW AROUND SCIENTOLOGY TERMINOLOGY, AND YOU DON'T UNDERSTAND IT. I WANT TO KNOW YOUR DEFINITION, AND MAYBE I CAN ANSWER IT. YOU PULLED OUT ONE PARAGRAPH THERE OF A VERY, VERY LONG WRITING BY MR. HUBBARD. IF YOU HAVE THAT WRITING, I'LL READ IT. JUST SO I'M CLEAR.

MS. PLEVIN: ARE FINISHED?

THE WITNESS: WELL, I THINK YOU'RE SUPPOSED TO ASK THE A QUESTION, AND I'M GOING TO ANSWER IT.

MS. PLEVIN: I DON'T WANT TO INTERRUPT YOU WHILE YOU'RE ON A ROLL.

THE WITNESS: GOOD. THANK YOU.

MS. PLEVIN: ARE YOU FINISHED?

MR. HELLER: HE STOPPED. HE'S FINISHED. NOW, STOP DOING THINGS FOR EFFECT.

MR. HERTZBERG: HE'S TRYING TO ANSWER YOUR QUESTIONS.

MR. HELLER: ASK YOUR QUESTION, MISS PLEVIN.

MR. HERTZBERG: HE'S TRYING TO ANSWER.

MS. PLEVIN: LET'S TRY TO COME UP WITH A DEFINITION OF MANAGEMENT THAT WE CAN BOTH CAN LIVE WITH.

MR. HELLER: THE JOB IS NOT HIM COMING UP WITH IT.

MS. PLEVIN: OKAY.

MR. HERTZBERG: THIS IS NOT A --

MR. HELLER: THE JOB IS YOU DEFINING IT.

MR. HERTZBERG: THIS IS NOT A GAME. THIS IS NOT A GAME FOR HIM. JUST TELL -- HE'S EXPLAINED TO YOU WHAT HE DOESN'T UNDERSTAND. I THINK THE CORE OF WHAT MR. MISCAVIGE -- BECAUSE I HAVE THE SAME PROBLEM. LISTEN TO ME NOW. THE CORE OF THE PROBLEM WAS, I THINK, WHEN MR. MISCAVIGE INDICATED TO YOU THAT YOU WERE ASKING DID HE EVER SPEAK TO YOU ABOUT MANAGEMENT IS TANTAMOUNT TO ASKING SOMEBODY, "DID HE EVER SPEAK TO YOU ABOUT LIFE?"

MS. PLEVIN: OKAY.

MR. HERTZBERG: I THINK IF YOU COULD BE MORE SPECIFIC, WE'LL WASTE LESS TIME.

BY MS. PLEVIN:

Q. MANAGEMENT MEANS, FOR THE PURPOSE OF THIS QUESTION --

A. OKAY.

Q. -- THE OVERALL PLANNING, DIRECTION, EVALUATION, EXECUTION OF PROJECTS AND PLANS OF AN ORGANIZATION.

A. OKAY. NOW, LET ME TELL YOU WHAT IT IS I DON'T UNDERSTAND ABOUT IT BECAUSE I DON'T THINK YOU UNDERSTAND YET. YOU'RE ASKING ME ABOUT AN ORGANIZATION OR CORPORATION AND TO THAT I ASK YOU: CAN YOU SHOW ME EVALUATIONS YOU'VE EVER DONE FOR YOUR CORPORATION? CAN YOU EVEN DEFINE THEM FOR ME? THAT IS WHERE I HAVE THE PROBLEM. SO I WANT TO KNOW EXACTLY WHAT YOU'RE ASKING ME.

Q. YOU SAID YOU --

A. I THINK THERE'S VARIOUS PEOPLE -- I ASSUME THAT YOU'RE PART OF A CORPORATION OR YOU HAVE YOUR OWN CORPORATION. I WOULD LIKE TO KNOW IF FOR THAT CORPORATION IF YOU HAVE PLANS, PROGRAMS, IF YOU HAVE EVALUATIONS, AND MAYBE WE CAN GET SOMEWHERE ON THIS. YOUR QUESTION ASKS SO MANY DIFFERENT ITEMS, I WANT TO KNOW PRECISELY WHAT IT IS YOU WANT TO KNOW.

Q. ALL RIGHT.

A. ARE YOU TALKING ABOUT THE DOINGNESS, ABOUT THE SCIENTOLOGY TECHNOLOGY?

MS. PLEVIN: ARE YOU GOING TO INSTRUCT YOUR CLIENT TO ANSWER THE QUESTION, MR. HERTZBERG? MR. HERTZBERG: HE IS ANSWERING --

MS. PLEVIN: OKAY.

MR. HERTZBERG: -- TO THE BEST OF HIS ABILITY, SUBJECT TO YOUR FRAMING A QUESTION THAT HE UNDERSTANDS. THAT'S THE PROBLEM HERE. MS. PLEVIN: OKAY.

Q. YOU STATED YOU DID RECEIVE COMMUNICATIONS IN WRITING FROM MR. HUBBARD ABOUT THIS SUBJECT; PLEASE IDENTIFY THOSE.

MR. HELLER: WHAT SUBJECT?

MR. HERTZBERG: WELL, HE INDICATED THAT HE'S NOT SURE -- WHEN YOU SAY, "THIS SUBJECT," I ASSUME YOU'RE REFERRING TO YOUR BROAD USE OF THE WORD MANAGEMENT, WHICH YOU HAVEN'T BEEN ABLE TO SPECIFY TO HIS UNDERSTANDING; IS THAT WHAT YOU'RE REFERRING TO? MS. PLEVIN: NO. I AM REFERRING TO MANAGEMENT WHICH I -- WHICH MR. MISCAVIGE REFUSES TO ACCEPT --

MR. HERTZBERG: OKAY.

MS. PLEVIN: -- A REASONABLE STATEMENT IN ENGLISH AS TO WHAT IT MEANS; AND, THEREFORE --

MR. HERTZBERG: IT'S NOT A REASONABLE --

MS. PLEVIN: HE'S REFUSING TO ANSWER. ALL RIGHT. LET'S DO THIS --

THE WITNESS: LET ME ASK YOU, THEN, WHAT DO YOU MEAN BY "COMMUNICATIONS"? TELL ME WHAT YOU MEAN BY "COMMUNICATIONS," AND I THINK WE CAN GET SOMEWHERE HERE.

I'M QUITE WILLING TO ANSWER THE QUESTION. I'M QUITE UNWILLING TO ANSWER A QUESTION WHEREBY YOU HAVE SOME MEANING OR DUBIOUS MEANING OR YOU'RE TRYING TO GIVE ME A DEFINITION AND CALL IT OFFICIAL CHURCH DEFINITIONS WHEN YOU WOULDN'T HAVE A CLUE.

NOW, YOU TELL ME WHAT YOU MEAN BY THAT, AND I'LL ANSWER THAT BECAUSE I'M NOT HERE TO INITIATE WHAT YOU MEAN BY YOUR QUESTION.

BY MS. PLEVIN:

Q. NOW, YOU DON'T KNOW WHAT THE WORD COMMUNICATION MEANS?

A. I WANT TO KNOW WHAT YOU MEAN BY THAT BECAUSE I'M ANSWERING YOUR QUESTION ON THIS RECORD. IT'S GOING TO BE THAT I'M ANSWERING YOUR QUESTION AND YOU'RE GOING TO TAKE THAT QUESTION AND YOU'RE GOING TO DESCRIBE LATER WHAT IT MEANS. SO I WANT TO KNOW RIGHT NOW WHAT IT MEANS, AND I WILL ANSWER IT.

Q. A STATEMENT --

A. I THINK YOU AND I HAVE DIFFERENCES OF DEFINITIONS. WE CAME UP WITH TWO OR THREE YESTERDAY. Q. FINE.

A. I WANT TO KNOW WHAT THIS MEANS.

Q. THIS --

A. LET ME ASK YOU: DO YOU MEAN LIKE, FOR INSTANCE, ANY -- OKAY. A COMMUNICATION, ANY WRITING ON THE SUBJECT OF THIS; IS THAT WHAT YOU MEAN? IS THAT GOOD? IS THAT A GOOD DEFINITION FOR US TO AGREE UPON? Q. WELL, I THINK AT THIS POINT THAT THAT IS NOT WHAT I INTEND, AND I DON'T THINK THAT'S WHAT YOU INTEND.

MR. HERTZBERG: THAT'S NOT --

MS. PLEVIN: LET'S CLARIFY.

MR. HERTZBERG: FORGET WHAT YOU THINK HE INTENDS BECAUSE THAT'S IMMATERIAL.

MS. PLEVIN: ALL RIGHT.

MR. HERTZBERG: WHY DON'T YOU JUST TELL US WHAT YOU INTEND?

BY MS. PLEVIN:

Q. MR. MISCAVIGE, A COMMUNICATION FROM MR. HUBBARD TO YOU ON ANY SUBJECT WOULD BE A COMMUNICATION DIRECTED TO YOU WITH REGARD TO THAT AND NOT HIS PREVIOUS WRITINGS.

A. OKAY. WELL, THERE'S ONE MISUNDERSTANDING I HAD. YOU SAID, "COMMUNICATIONS FROM MR. HUBBARD." I DIDN'T REALIZE YOU WERE TALKING ABOUT TO ME.

Q. THAT'S WHAT THE QUESTION WAS, MR. MISCAVIGE.

A. SO DIRECTED TO ME.

Q. THAT'S WHAT THE QUESTION WAS. THE QUESTION WAS: DID YOU RECEIVE ....

A. OKAY. TO ME. YES.

Q. ALL RIGHT. WOULD YOU TELL US WHAT THOSE WERE, PLEASE?

A. ALL RIGHT. YOU MAY HAVE HEARD OF A TAPE --

MR. LIEBERMAN: WAIT.

THE WITNESS: -- CALLED "RON'S JOURNAL 38."

MR. DRESCHER: WAIT A SECOND.

MR. HERTZBERG: ALL RIGHT. WE'RE GOING TO CONFER FOR A MOMENT BECAUSE I WANT TO MAKE SURE MY CLIENT IS NOT CONFUSED.

MS. PLEVIN: ALL COUNSEL AND THE CLIENT ARE LEAVING THE DEPOSITION ROOM.

MR. DRESCHER: ARE YOU GOING OFF THE RECORD NOW?

MS. PLEVIN: YES.

MR. DRESCHER: OKAY. I JUST WANTED TO MAKE SURE BECAUSE YOU CONTINUED TO TALK WHEN WE STARTED TO LEAVE.

(ATTORNEY-CLIENT DISCUSSION HELD OFF THE RECORD.)

qq


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