RONALD BENDER - American Association for Justice

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1 MR. ALFERT: Yes. 2 THE WITNESS: Yes, on not an inexpensive one but the 3 more costly one, I would have discovered that. 4 MR. ALFERT: Yes. 5 THE WITNESS: There wouldn't have been a trail to say 6 that unless I would have said do you want me to check Long 7 Beach and San Joaquin Counties, because he puts down on 8 his reference sheet, or on there, that his relatives were 9 in those areas. 10 So there was -- on the header search that you 11 normally would conduct, only one address came up and that 12 address was in San Jose. So there would be no reason to 13 check anywhere else unless they wanted me to check where 14 the relatives had lived before and I would run that 15 question by him: Do you want to spend more money and 16 check in these counties? 17 BY MR. ALFERT: 18 Q. Let's back up. If you knew he had only lived for 19 two weeks in San Jose. 20 A. Oh, yes. Oh, sure. 21 Q. That's what -- I'm asking you to assume that you 22 know from the document that this person has only lived in
23 San Jose for two weeks. 24 A. Yes. 25 Q. Would you have discovered the criminal record in DEPOSITION OF RONALD E. BENDER 50
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1 IN THE SUPERIOR COURT OF THE STAT
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1 I N D E X 2 PAGE 3 EXAMINATION BY
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1 BE IT REMEMBERED, that pursuant t
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1 RONALD E. BENDER, 2 called as a w
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1 read the booklet and make any cha
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1 merely be guessing, you should ju
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1 (Whereupon, the document describe
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1 A. Yes. 2 Q. There's a bunch of c
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1 and also the defendant's expert d
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1 MR. WILLIAMS: You're up to 4. You
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1 MR. ALFERT: Okay. 2 (Whereupon, t
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1 publication of any kind with resp
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1 A. Yes. 2 Q. What's the person's
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1 Q. About how old was she? 2 A. Tw
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1 Q. Okay. 2 A. LRS Investigations
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1 With respect to the business of b
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1 break it apart, you could say may
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1 different subsets? 2 A. Yes. 3 Q.
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1 litigation and prelitigation firs
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1 Q. Did you used to take collectio
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1 particular entities or do they wo
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1 A. Counting today or before today
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1 Q. Do you have any notes? 2 We've
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1 declaration which we're going to
Page 49 and 50: 1 declaration then and this deposit
Page 52 and 53: 1 A. Because there are certain rule
Page 54 and 55: 1 depending on the interviews and d
Page 56 and 57: 1 A. Yes. 2 Q. You don't have one o
Page 58 and 59: 1 A. Correct. 2 Q. All right. Is th
Page 60 and 61: 1 past to obtain criminal records.
Page 62 and 63: 1 Q. Anything else? 2 A. (Shakes he
Page 64 and 65: 1 Q. I want to know which years you
Page 66 and 67: 1 Q. Meaning you paid for the servi
Page 68 and 69: 1 A. To run the same search that th
Page 70 and 71: 1 check the criminal records themse
Page 72 and 73: 1 Q. Okay. So 20 to 25? 2 A. Plus a
Page 74 and 75: 1 Q. But how many did you do for th
Page 76 and 77: 1 A. It's a service that specialize
Page 78 and 79: 1 A. They may have. I can't think o
Page 80 and 81: 1 BY MR. ALFERT: 2 Q. -- average to
Page 82 and 83: 1 you were provided an application
Page 84 and 85: 1 A. Well, I'm aware of the article
Page 86 and 87: 1 A. Somewhere. 2 Q. Okay. Now, you
Page 88 and 89: 1 Q. Do you want to take a look? 2
Page 90 and 91: 1 Q. Okay. Was it easy to obtain th
Page 92 and 93: 1 A. Yes. 2 Q. Now, would it be acc
Page 94 and 95: 1 spent most of their time before t
Page 96 and 97: 1 Q. The document that you have the
Page 98 and 99: 1 A. Depending on the county it can
Page 103 and 104: 1 San Joaquin if you -- 2 A. Yes, b
Page 105 and 106: 1 Q. Is it ever aimed at business o
Page 107 and 108: 1 A. That's true. 2 Q. There's a pi
Page 109 and 110: 1 thorough search on them? Is there
Page 111 and 112: 1 Q. And I think you said you used
Page 113 and 114: 1 BY MR. ALFERT: 2 Q. All right. Gi
Page 115 and 116: 1 Q. It doesn't matter -- 2 A. To u
Page 117 and 118: 1 A. On Merlin? 2 Q. On any of the
Page 119 and 120: 1 So on doing -- if I'm looking for
Page 121 and 122: 1 most current data available. 2 We
Page 123 and 124: 1 where? What type of folks retain
Page 125 and 126: 1 would get down to the more and mo
Page 127 and 128: 1 if you can't find them with the p
Page 129 and 130: 1 business associates. It could be
Page 131 and 132: 1 STATE OF CALIFORNIA ) ) ss. 2 COU
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RONALD BENDER - American Association for Justice

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