Document GmBD6YpRx9mdBXpGNK0OnakyV
Page 19
1 THE VIDEOGRAPHER: Off the record. The time is
2 9:27.
3 (Discussion off the record.)
4 THE VIDEOGRAPHER: Back on the record the time
5 is 9:28.
6 BY MR. RUCKDESCHEL:
7 Q No. 17, Dr. Paustenbach, requests you produce
8 documents that relate to any draft or outlines or
9 preliminary version orprecursors to the brake
10 articles. Have you brought anysuchdocuments? 11 A There are none.
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12 Q Are there any retainer agreements, this is No.
13 18, confidentiality agreements or other contractual 14 agreements between Ford, General Motors or Chrysler or 15 their attorneys relating to the brake articles you 16 brought?
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17 A Not that I'm aware. If they existed they would
18 have been in the hands of Exponent.
19 Q. And for No. 19, any documents?
20 A I read that as the same as 18. Is there a
21 difference?
22 Q It's simply between ChemRisk as opposed to
23 between you.
24 A The articles were written before, and published
25 I think before ChemRisk was operating.
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