Document x5b6apbEDNm9REqayvajnad1b

1 other than what might be locked in your mind? Page 276 2 A No. 3 Q Okay. Did you speak with other employees of 4 Ford, General Motors or Chrysler during the drafting of 5 those papers.about the topics of those papers, the 2003 6 paper and the 2004 paper? 7 A I think I've said before that I talked to Bill 8 Krebs before I finished that paper. 9 Q Did you talk with Mr. Toth during the 10 authorship of those papers? f : \ ] 1 i j 11 A I don't think I saw him during the authorship. 12 I don't recall if it was before or after the paper was 13 accepted or not. I don't remember. Obviously whatever 14 I talked to Paul about didn't have much impact on the 15 paper. 16 Q The propositions in the paper for which you < s1 17 cite your conversations with Mr. Anderson as the source 18 of the information, do you have other authority for 19 those propositions or are.you relying upon Mr. Anderson 20 for them? 21 A That's a good question and it's not been asked 22 before except outside a deposition. I do. And in 23 retrospect I probably should have just cited those. 24 Q It's important from a reader's perspective in 25 critically evaluating a paper. ESQUIRE DEPOSITION SERVICES (415) 288-4280