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

99
1 entered into a security agreement, lease, sales
2 agreement, consultation agreement, and executed a bill
3 of sale and covenant on October 15th, 1999.
4 Is that your understanding?
5 A Yes.
6 Q And that was for the Strickland Drive
7 Dairy Queen?
8 A That's my understanding.
9 Q In your opinion who was responsible for the
10 safety of the Dairy Queen Strickland customers on
11 October 23rd of 1999?
12 A Probably a number of people.
13 Q Name them.
14 A The customers themselves, the manager on duty,
15 employees on duty, but I would think that the franchisee
16 of record is the one who is responsible ultimately for
17 making sure that all parts of the operating system are
18 followed.
19 Q Do you place any blame for this accident on
20 Wesley Howard?
21 A I have been not -- I'm not asked to testify on
22 blame. What I'm asked to be an expert on is the
23 playground and the requirements that were followed or
24 not followed because it is outside the purview of the
25 franchise agreement. So, I have been not - not been