"our client be afforded an opportunity to peruse the report, or alternatively, that he be advised who has had access to the report over the past 12 years, and who currently has access to the report."
The above is accompanied by a 30-day deadline. OBSERVATION: Such behaviour is not merely doubtful in itself, but is prohibited in the Congregational Church -- where all members are executive members, and therefore all members have access to all reports. Everything is in principle open. If a secret report exists, it contradicts the principles of Congregationalism.
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