Every indexed document

I would 7 daughter's journal notes that I had taught his

I would have been 5 gather documents literally within an hour. I was

I would have been able to point them to 24 exonerated him.

at the courtesy of simply 23 the documents that proved his innocence

4 superb memory whether you remember having said -

I know I haven't been there. 23 MR. SCAROLA: Thank you. And you're

19 vigorously -- and you're a great lawyer --

which was not during 1 MR. SCOTT: We don't agree on that point

you were and still are his lawyer in the 12 It is certainly possible that at some earlier point

when the pleadings were filed in the 9 recollection of ever being in New Mexico except to

which continue to this day. And I regard 5 Q. -- how about the last 20 years?

but certainly that's the common 13 A. No

sir. 17 Q. To which your response was: ""Sure

22 the communication was. The communication was

the 16 arc. It constitutes a waiver of whatever

11 he can't have it both ways. He can't insert

I never flew down on 4 with your current lawyers

24 have conclusively told me that their review of the

I never 22 reviewed the manifests. Not only had I reviewed the

you should have produced them in discovery and 25 period of time. And the manifests show that I never