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