Document mB8N3KRbDMLjzNqZkBGpRw2Kg

T. Marmor Page 121 - 1 question about-them. So ray objection. 2 remains.^ 3 : MS.-ROSENBERG: Your objection is 4 . noted, and my offer stands. 5 M R. KAY: We join as well. 6 MS. NIELSEN: The O'Brien firm 7 joins as well. . 8 MR.iGIANARIS: Take a look at 9 what we will mark as Exhibit number 4 10 which is.'a Schedule A, a list of 11 documents to be produced at the ,-t 12 deposition. . . 13 (Whereupon Schedule A, documents 14 to be.produced at ^deposition was marked 15 Exhibit 4 for identification as of this . 16 date.) 17 Q. . Have.you seen that, sir?-. 18 A, .1 saw that yesterday at 19 5.o!clockyactually 5:15.: j. 20 . Q. Earlier than! saw-your 21 documents. 22 A. That!$. right. . m: 23 . . ..Q., Have you attempted to.,comply With- 24, oithat?' 25 .in*A-. .; Yesj to the extent L'm able to. Page 123 1 A. My answer to number 8 is yes, I 2 brought that. 3 Q. So 1 have all the documents here 4 in this exhibit that you will rely upon to give 5 any opinions in this case? 6 A. But I presumed that there were 7 other documents availablejn the case that have 8 to do with Union Carbide only. That's the only 9 one that I have any claim to having studied. 10 MR. GIANARIS: 1 understand. 11 i'll make the same objection. 12 Q. You don't have any letters 13 between you and defense counsel regarding your 14 testimony? 15 A. No, they're oral communication. - 16 Q. For this ten or eleven months of 17 work, is that right? 18 A. Yes. .. . 19 Q. How much have you billed this law 20 firm and Union Carbide? 21 A. About $90,000j something between 22 90,000 and $100,000, 23 Q... Between.90,0.00 and $100,000? 24 A. Yes.' , 25 Q, Is that for .your time only? . . ! Page 122 1 T.haMs my,flle-for this case. J can go . 2 through'this.with youj but wbatl'do ln this 3 - >kind,;.o.f situation.is.assemhle the material on 4 which I'm ,going to rely. T was -assuming there , , 5 was other materials, already, in-the trial that I -. 6 can also rely on-because I knew, l.had seen that 7 material-available:- . : 8 While ther.e is,a lot of other ; 9 things that roight,be.brought int I couidn't 10 keep them:allistralght. Shi Lwanted,,for 11 tractability, pick those materials that l was 12 going to.support and giVe the basis for my 13 opinions rather than everything I knew in;, the 14 world. 15 Q. You brought those materials with 16 you here today? .: 17 A. That's the binder: 18 Q. That is the only thing .that you 19 have today that is in response.-to.Schedule A? . 20 A. That's right. 21 MSi.ROSENBERG:. You should note 22 that he also, has, his curriculum vitae 23 with him. 24 A. The answer is in number 8. 25 Q. The.answer? 1 A. For my own. 2 Q. So you've worked one day a week 3 for ten months?-.. . 4 A. Somewhat a little ionger than 5 summertime, which is permitted. 6 Q. Let's talk about how long you've 7 worked. 8 MS, RO-SENBERG:: Keep yourivoice 9 up, Ted. 10 A. We can divide that number by 11 between 200 and 300-'hours. 12 Q.. Between-200 and 3.00 equals 13 $90,000 to $100,000.? 14 A. : I believe that's right: 15 ,Q. How much has your research team - 16 billed? .; 17 A. l don't actually know the figure 18 because John, the head of that firm, does all 19 that billing. I don't get involved in that . 20 billing. 21 Q.. What do you think? 22 A, I really don't know. 23 MS. ROSENBERG: Objection to the 24 form. If he knows, he knows. If he 25 doesn't, he doesn't. Page.124: .>; POHLMAN REPORTING COMPANY (314)421-0099 31 (Pages 121 to 124)