RONALD BENDER - American Association for Justice

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23 DIABLO VALLEY REPORTING SERVICES Certified Shorthand Reporters 24 2121 N. California Blvd., Suite 310 Walnut Creek, California 94596 25 925-930-7388 DEPOSITION OF RONALD E. BENDER 1
1 I N D E X 2 PAGE 3 EXAMINATION BY MR. ALFERT 4 4 --oOo-- 5 E X H I B I T S 6 NUMBER PAGE 7 1 Amended Notice of Taking Depositions 7 8 of Defendants' Expert Witnesses 9 10 2 Declaration of Karen Foster in Support 8 11 of Plaintiffs' Separate Statement of 12 Facts 13 14 3 6/25/02 fax from Lois Yoshida/Plaintiff's 9 15 Exchange of Expert Witness Lists and 16 Information 17 18 4 6/18/02 fax from Richard Williams/ 10 19 Application for Employment 20 21 5 ChoicePoint Online printout 11 22
Page 1: 1 IN THE SUPERIOR COURT OF THE STAT
Page 5 and 6: 1 BE IT REMEMBERED, that pursuant t
Page 7 and 8: 1 RONALD E. BENDER, 2 called as a w
Page 9 and 10: 1 read the booklet and make any cha
Page 11 and 12: 1 merely be guessing, you should ju
Page 13 and 14: 1 (Whereupon, the document describe
Page 15 and 16: 1 A. Yes. 2 Q. There's a bunch of c
Page 17 and 18: 1 and also the defendant's expert d
Page 19 and 20: 1 MR. WILLIAMS: You're up to 4. You
Page 21 and 22: 1 MR. ALFERT: Okay. 2 (Whereupon, t
Page 23 and 24: 1 publication of any kind with resp
Page 25 and 26: 1 A. Yes. 2 Q. What's the person's
Page 27 and 28: 1 Q. About how old was she? 2 A. Tw
Page 29 and 30: 1 Q. Okay. 2 A. LRS Investigations
Page 31 and 32: 1 With respect to the business of b
Page 33 and 34: 1 break it apart, you could say may
Page 35 and 36: 1 different subsets? 2 A. Yes. 3 Q.
Page 37 and 38: 1 litigation and prelitigation firs
Page 39 and 40: 1 Q. Did you used to take collectio
Page 41 and 42: 1 particular entities or do they wo
Page 43 and 44: 1 A. Counting today or before today
Page 45 and 46: 1 Q. Do you have any notes? 2 We've
Page 47 and 48: 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 100 and 101:
1 MR. ALFERT: Yes. 2 THE WITNESS: Y
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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