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

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61<br />

1 A $350.<br />

2 Q What are your o<strong>the</strong>r pay rates?<br />

3 A I th<strong>in</strong>k this should reflect that, and I th<strong>in</strong>k<br />

4 it says $3500 for deposition preparation a day and $3500<br />

5 for depositions.<br />

6 Q About how many days did it take you to prepare<br />

7 for this deposition?<br />

8 A Maybe one. Now, to be - I need -- Because of<br />

9 this <strong>no</strong>tebook th<strong>in</strong>g, I want to make sure I'm answer<strong>in</strong>g<br />

10 that.<br />

11 The depositions that I was given,<br />

12 <strong>no</strong>rmally I would consider that toward <strong>the</strong> expert report<br />

13 k<strong>in</strong>d of th<strong>in</strong>g ra<strong>the</strong>r than sitt<strong>in</strong>g down and prepar<strong>in</strong>g;<br />

14 but <strong>the</strong>y were part of my last few days. So, <strong>in</strong> a sense,<br />

15 you could say, yeah, read<strong>in</strong>g those - that list that you<br />

16 got - that could be called prepar<strong>in</strong>g.<br />

17 Q What else did you read to prepare for this<br />

18 deposition?<br />

19 A That's it.<br />

20 Q You didn't review any o<strong>the</strong>r documents?<br />

21 A Those three pages you got I reviewed.<br />

22 Q And what are <strong>the</strong> pages - <strong>the</strong>se three pages <strong>in</strong><br />

23 Exhibit 2?<br />

24 A In Exhibit 2?<br />

25 Q Yes, sir.

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