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

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

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144<br />

1 A I don't k<strong>no</strong>w. I can't address whe<strong>the</strong>r it was<br />

2 or wasn't. I wasn't asked to give an op<strong>in</strong>ion on that.<br />

3 Q Well, <strong>in</strong> <strong>the</strong> documents you have seen, has <strong>the</strong><br />

4 American Dairy Queen ever given - allowed <strong>the</strong><br />

5 Strickland Drive Dairy Queen to be transferred <strong>in</strong> <strong>the</strong><br />

6 N<strong>in</strong>eties?<br />

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

8 Q Okay. On Page 20, <strong>the</strong> fifth dot down, you<br />

9 state <strong>the</strong> ADQ's force had to do <strong>the</strong> <strong>in</strong>surance <strong>no</strong>t<br />

10 renew<strong>in</strong>g a store's <strong>in</strong>surance due to <strong>no</strong>ncompliance with<br />

11 CPSC standards.<br />

12 Will you tell me what that means? There<br />

13 may have been some typos <strong>the</strong>re. What is your op<strong>in</strong>ion<br />

14 <strong>the</strong>re?<br />

15 A That <strong>the</strong>re was a l<strong>in</strong>kage that <strong>the</strong> <strong>in</strong>surance<br />

16 company had that said before <strong>the</strong>y'd <strong>in</strong>sure <strong>the</strong> place,<br />

17 that it had to be up to standards; and that was part of<br />

18 <strong>the</strong> <strong>in</strong>fluence and force that ADQ had.<br />

19 Q So, one th<strong>in</strong>g that ADQ <strong>in</strong> your op<strong>in</strong>ion used to<br />

20 <strong>in</strong>fluence local stores was <strong>the</strong> threat or - of <strong>no</strong>t<br />

21 be<strong>in</strong>g - of <strong>the</strong> local stores <strong>no</strong>t be<strong>in</strong>g able to get<br />

22 <strong>in</strong>surance until <strong>the</strong> CPSC was up to standard?<br />

23 A Not threat, reality.<br />

24 Q Reality. Did you k<strong>no</strong>w that ADQ refused to<br />

25 give <strong>the</strong> expert reports to <strong>the</strong> <strong>in</strong>surance company? Did

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