Document vBXLknRZYkg6yxdq7BmK9eXMZ

Page 35 1 for service of a request or a deposition notice by the 2 defense? 3 JUDGE KLINE: As far as I'm concerned. j 4 MR. RUCKDESCHEL: Okay, I understand, thank 5 you. 6 BY MR. RUCKDESCHEL: 7 Q Dr. Paustenbach, with respect to No. 22, have 8 you brought with you responsive documents? 9 A I brought some as listed on my CV but I've not 10 brought everything. 11 Q Okay. What materials have you not brought? 12 A Well, it's a very broad request. As I read it, 13 you wanted fundamentally the PowerPoint presentations 14 and any handouts from any speech I've ever given 15 regarding asbestos and brakes, clutches or automobile 16 parts. That's the way I read it. 17 Q That's correct, and may I ask a clarifying 18 question here. Professionally you didn't start working 19 in the asbestos litigation until the middle of 2001; is 20 that correct? 21 A I think it's about right. 22 Q Okay. 23 A It may be a little before that. But it's been 24 in the recent years. 25 Q And in that time since the middle of 2001, and ; ESQUIRE DEPOSITION SERVICES (415) 288-4280