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

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1 Q What is it that you do personally for your
2 company?
3 A I'm the president. So, I oversee the
4 projects; and I do personal consulting projects of
5 various kinds.
6 Q Would you know how to write an operations
7 manual?
8 A Yes.
9 Q Where would you have gained that knowledge?
10 A Because I've done a lot of writing in my life
11 and I know how to organize and do research and document.
12 Q But you have never written an operations
13 manual?
14 A No, but I have overseen the process and the
15 projects of operations manuals. I have been part of the
16 entire process; but I have never texturally written one,
17 no.
18 MR. LAWDERMILK: Objection.
19 Nonresponsive.
20 Q (By Mr. Lawdermilk) You have never written an
21 operations manual for a franchisor?
22 A No, but I have supervised the project from
23 beginning to end.
24 MR. LAWDERMILK: Objection.
25 Nonresponsive.