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

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127<br />

1 before Tyler's death?<br />

2 A All I k<strong>no</strong>w is what this memo said as of<br />

3 10-10-00.<br />

4 Q So, you don't k<strong>no</strong>w?<br />

5 A I don't k<strong>no</strong>w what that number is.<br />

6 Q Okay. You next wrote - it is on Page 15:<br />

7 IDQ/ADQ after review<strong>in</strong>g <strong>the</strong> store playground surveys<br />

8 took <strong>the</strong> strongest, most decisive and license agreement<br />

9 appropriate actions available to it show<strong>in</strong>g <strong>in</strong>tense and<br />

10 dramatic concern as is <strong>in</strong>dicated by <strong>the</strong> correspondence<br />

11 that went to <strong>the</strong> stores.<br />

12 Do you, as we sit here today, agree with<br />

13 that statement?<br />

14 A Yes.<br />

15 Q If it is shown that ADQ could have defaulted<br />

16 <strong>the</strong> Strickland Drive Dairy Queen based on its playground<br />

17 be<strong>in</strong>g <strong>in</strong> <strong>no</strong>ncompliance with <strong>the</strong> CPSC, would that change<br />

18 your op<strong>in</strong>ion about that statement?<br />

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

20 A It is hypo<strong>the</strong>tical.<br />

21 Q Yes, it is.<br />

22 A I don't k<strong>no</strong>w. I would have to see all <strong>the</strong><br />

23 circumstances around that.<br />

24 Q Well, if ADQ could have defaulted <strong>the</strong><br />

25 Strickland Drive Dairy Queen franchise based on <strong>the</strong>

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