Document Z88NJegrLGbybrvbKJD1ben7L

Page 26 1 A It's an unusual request because I didn't know 2 you could make such a request. You're asking if I've | 3 been deposed 50 times and been to trial 10 times you j 4 want all those transcripts? 5 Q If you have them. If they are in your 6 possession that's what we're asking. 7 A Okay. Whatever the court and you guys have j j ) ] 8 agreed I'll do whatever makes sense. But I didn't j 9 bring them today. j 10 MR. RUCKDESCHEL: I understand. And Judge 11 Kline, I don't know whether this .is a time where we ; 12 might need your intervention, Counsel, will you provide 13 copies of the transcripts, videotapes and other prior 14 testimony in asbestos cases that are in 15 Dr. Paustenbach's possession? If so, then we don't need 1 16 Your Honor's intervention, but... 17 MR. LANKFORD: Well, I think that what 18 Dr. Paustenbach stated regarding it being an unusual ; 19 request and something that I think the inference 20 essentially is not proper, it is accurate. You're 21 asking the parties to provide to you the, all prior 22 testimony of their expert in other matters. 23 It's burdensome, it's not something that the 24 expert is relying on in this case for his opinions, and 25 therefore it's not something which the expert should ESQUIRE DEPOSITION SERVICES (415) 288-4280