Document 26akjZeOXxRpgJ9m5orn5GnL

1 witness said he would not rely upon it. Page 179 .2 So it was my impression that the work product 3 privilege and all of that stuff, the witness said he 4 would not rely upon it, he didn't consider it to be a 5 valid study at this point, then I would see no reason to 6 question him about it. 7 MR. LANKFORD: Thank you, Your Honor. 8 JUDGE KLINE: Fellows, it's been a pleasure. 9 I'm getting off and if you need me you can reach me at 10 one of these phones. You got the numbers, right? 11 MR. RUCKDESCHEL: Yes. 12 (Brief recess.) 13 THE VIDEOGRAPHER: Back on the record. Here 14 begins Tape 3. The time is 2:21. 15 (Plaintiffs' Exhibit 11 was marked for 16 identification by the court reporter.) 17 BY MR. RUCKDESCHEL: 18 Q Dr. Paustenbach, I just handed across to 19 counsel for Ford and General Motors what I've marked as 20 Exhibit 11. Would you identify that document for the 21 record, please, sir? 22 A It's a list of depositions or trial testimony 23 that I gave between August 18th, 2003 and 1990. 24 Q To the best of your knowledge is that 25 document, was that document complete and accurate at ESQUIRE DEPOSITION SERVICES (415) 288-4280