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

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1 A Ask me that a different way.
2 Q What is Exhibit 2?
3 A Ah. Those are some notes I took on - on --
4 Basically they tell me how good you guys are at asking
5 questions and to just be aware of that whole process.
6 Q Well, Exhibit 2 is actually notes you took
7 when you met with ADQ's lawyer in preparation for giving
8 a deposition in this case, correct?
9 A That's right.
10 Q And you were given some instructions in that
11 meeting with ADQ's lawyer, weren't you?
12 A No.
13 Q You weren't given any instructions?
14 A No - was given - simply we had a very - it was
15 about an hour and we just simply - what normally
16 happens -- What normally happens is you sit down and you
17 say, "Look, this is the way these guys might ask you
18 questions; and, you know, just do your best."
19 Q But you took notes on things you were told in
20 that meeting with ADQ's lawyer in preparation for this
21 deposition, didn't you?
22 A I took notes that I thought might be helpful
23 to me. I wasn't told anything, just we had a discussion
24 about the deposition process.
25 Q Well, one of the notes you wrote was: Don't