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no. b-000119-c melinda matthews, individually ) in the district court ...

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105<br />

1 A I can't -- I can't speak to anyth<strong>in</strong>g about <strong>the</strong><br />

2 avoidance of liability.<br />

3 Q But you just don't k<strong>no</strong>w why <strong>the</strong>y did it?<br />

4 A I don't k<strong>no</strong>w <strong>the</strong>ir motivation. I th<strong>in</strong>k -- It<br />

5 looks to me from <strong>the</strong> documents that <strong>the</strong>y were concerned.<br />

6 Q Yeah. How many of those documents went out<br />

7 without <strong>the</strong> Legal Department look<strong>in</strong>g at <strong>the</strong>m?<br />

8 A I don't k<strong>no</strong>w.<br />

9 Q Do you k<strong>no</strong>w if any of <strong>the</strong>m went out without<br />

10 <strong>the</strong> Legal Department look<strong>in</strong>g at <strong>the</strong>m?<br />

11 A I don't k<strong>no</strong>w.<br />

12 Q Who was <strong>in</strong> charge of <strong>the</strong> Texas Dairy Queen<br />

13 playground project?<br />

14 MR. LIGHTY: Object to <strong>the</strong> form.<br />

15 A I don't k<strong>no</strong>w.<br />

16 Q That's what we are here about today, isn't it?<br />

17 MR. LIGHTY: Object to <strong>the</strong> form.<br />

18 A And we can look <strong>in</strong> this report, and I'm sure I<br />

19 wrote down somewhere <strong>in</strong> this report who was <strong>in</strong> charge.<br />

20 I should say "I don't recall" ra<strong>the</strong>r than "I don't<br />

21 k<strong>no</strong>w."<br />

22 Q What about was Sr<strong>in</strong>ivasa Murthy <strong>in</strong> charge of<br />

23 <strong>the</strong> Texas Dairy Queen playground project?<br />

24 A Certa<strong>in</strong>ly <strong>in</strong>volved.<br />

25 Q What about Bill Zucco? Was he <strong>in</strong> charge of

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