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

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39<br />

1 Q (By Mr. Lawdermilk) You have never written an<br />

2 operations manual for a franchisor, correct?<br />

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

4 A Do you mean by that created <strong>the</strong> actual text<br />

5 and put it <strong>in</strong>to a word processor?<br />

6 Q Sure.<br />

7 A No.<br />

8 Q Have you ever been <strong>the</strong> decision-maker on what<br />

9 goes <strong>in</strong>to an operations manual?<br />

10 A That <strong>in</strong> every case is <strong>the</strong> franchisor's area of<br />

11 accountability.<br />

12 Q So, it is <strong>the</strong> franchisor who decides what goes<br />

13 <strong>in</strong>to its operations manual?<br />

14 A Yes.<br />

15 Q Are <strong>the</strong> franchisors -- Who for <strong>the</strong> franchisor<br />

16 typically oversees that?<br />

17 A It would be <strong>the</strong> Operations Department. The<br />

18 head of <strong>the</strong> operations department might delegate that,<br />

19 but that's where <strong>the</strong> expertise would lie.<br />

20 Q And do you f<strong>in</strong>d you are deal<strong>in</strong>g with a lot of<br />

21 lawyers a lot of times, too, for <strong>the</strong> franchisors?<br />

22 A No.<br />

23 Q Never deal<strong>in</strong>g with lawyers?<br />

24 A Very seldom.<br />

25 Q Is one function of <strong>the</strong> operations manual to

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