Reply Letter - Page 1. From CoS lawyer Lisa Vaughn to McCabe's office, providing statements made by various Scientologists who w

Date:
Pages:1

ZUCKERMAN, SPAEDER, TAYLOR & EVANS, LLP
ATTORNEYS AT LAW
401 EAST JACKSON STREET
RESIDENT IN FLORIDA SUITE 2525 COUNSEL
RONALD B. RAVIKOFF TAMPA, FLORIDA 33602 MELISSA HAMMERSLEY CLARK
MICHAEL S. PASANO (813) 221-1010 ----------
MORRIS "SANDY" WEINBERG, JR. TELECOPIER LAURA L. VAUGHAN
HUMBERTO J. PENA (813) 223-7961 JENNIFER R. COBERLY
SHARON L. KEGERRUS ------- JILL M. GRANAT
THOMAS J. MEEKS 201 SOUTH BISCAYNE BOULEVARD CHRISTOPHER S. CARVER
MICHAEL STEVEN GREEN MIAMI, FLORIDA 33131 CHRISTYNO L. HAYES
GUY A. RASCO (305)579-0110 BEATRIZ C. COSCULLUELA
STEPHEN J. BRONIS ------- ANTOLIN MESA
ONE EAST BROWARD BOULEVARD RICARDO J. BASCUA
FORT LAUDERDALE, FLORIDA 33301
(954)356-0463

May 23, 1997

BY HAND DELIVERY
Mark R. McGarry, III, Esq.
Assistant State Attorney
Sixth Judicial Circuit
14250 49th Street North
Suite #B-200
Clearwaterf Florida 34620

Re: Lisa McPherson
Case N. 1951474

Dear Mr. McGarry:

Enclosed please find additional,documents Bates numbered 738
through 744.

These documents were generated during the course'of an
internal investigation that occurred following the death of Lisa
McPherson and at the request of both in-house and outside counsel.
It is the corporation's belief that the work product privilege
applies to all documents generated as part of that internal
investigation. These specific documents, however, were created for
a dual purpose: (1) as part of an internal investigation; and (2)
to address the problems raised by the fact that Lisa McPherson may
have died from an infectious disease.' Because it is our desire to
bring this matter to a conclusion and because these specific
documents were created for a dual purpose we are producing these
documents to you.

The production of these documents will not constitute a waiver
of the attorney-client or work product privileges with regard to
any other documents generated during the course of the internal

[continued on page two, TIF 5067]

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TIF 5066 OCR and bracketed comments by Michael Reuss