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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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150<br />

1 say<strong>in</strong>g.<br />

2 A An <strong>in</strong>surance company, whe<strong>the</strong>r it was <strong>in</strong>sur<strong>in</strong>g<br />

3 ADQ or <strong>no</strong>t, could have a policy that whenever a<br />

4 playground was on a premises, it had to comply with<br />

5 standards; and <strong>the</strong>n all of a sudden that applies to ADQ.<br />

6 Q But if ADQ refuses to <strong>in</strong>form <strong>the</strong> <strong>in</strong>surance<br />

7 company that some of <strong>the</strong> local stores are <strong>in</strong><br />

8 <strong>no</strong>ncompliance, how would <strong>the</strong> <strong>in</strong>surance company <strong>the</strong>n be<br />

9 able to use that <strong>in</strong>fluence?<br />

10 A How would <strong>the</strong> <strong>in</strong>surance company be able to use<br />

11 it? Well, it may or may <strong>no</strong>t -- They may just say this<br />

12 is it. If you -- You k<strong>no</strong>w, if you have got a<br />

13 playground, it has to be <strong>in</strong> compliance. They may <strong>no</strong>t<br />

14 require any reports from <strong>the</strong> company - ADQ or <strong>no</strong>t. They<br />

15 might do <strong>the</strong>ir own reports. They might ask for an<br />

16 <strong>in</strong>dependent consultant and pay for <strong>the</strong> survey and say,<br />

17 "Send us <strong>the</strong> report."<br />

18 Q What if <strong>the</strong> <strong>in</strong>surance company asked and begged<br />

19 ADQ to send <strong>the</strong>m those reports and ADQ refused?<br />

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

21 Q Would you th<strong>in</strong>k that that was lax on ADQ's<br />

22 part?<br />

23 A I don't k<strong>no</strong>w <strong>the</strong> circumstances. I just need<br />

24 to k<strong>no</strong>w more.<br />

25 Q Who is it that you believe was <strong>in</strong> charge of

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