Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
430
Declaration of Francis Ho in Support of #424 Apple's Reply in Support of its Motion for a Preliminary Injunction, filed by Apple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F-1, #7 Exhibit F-2, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J-1, #12 Exhibit J-2, #13 Exhibit K, #14 Exhibit L-1, #15 Exhibit L-2, #16 Exhibit M, #17 Exhibit N, #18 Exhibit O, #19 Exhibit P, #20 Exhibit Q, #21 Exhibit R, #22 Exhibit S, #23 Exhibit T, #24 Exhibit U, #25 Exhibit V, #26 Exhibit W, #27 Exhibit X, #28 Exhibit Y, #29 Exhibit Z, #30 Exhibit AA, #31 Exhibit BB, #32 Exhibit CC, #33 Exhibit DD, #34 Exhibit EE, #35 Exhibit FF, #36 Exhibit GG, #37 Exhibit HH, #38 Exhibit II, #39 Exhibit JJ, #40 Exhibit KK, #41 Exhibit LL)(Related document(s) #424 ) (Bartlett, Jason) (Filed on 11/29/2011) Modified text on 11/30/2011 (dhm, COURT STAFF).
Exhibit Y
Page 1
1
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
2
3
4
APPLE, INC., a California
corporation,
5
Plaintiff,
6
vs.
7
8
9
10
SAMSUNG ELECTRONICS CO., LTD.,
a Korean business entity;
SAMSUNG ELECTRONICS AMERICA,
INC., a New York corporation;
SAMSUNG TELECOMMUNICATIONS
AMERICA, LLC, a Delaware
limited liability company,
11
Defendants.
)
)
)
)
)
) Case No.
) 11-CV-01846-LHK
)
)
)
)
)
)
)
)
)
12
13
14
15
VIDEOTAPED DEPOSITION OF ROGER F. FIDLER
16
TAKEN ON BEHALF OF THE PLAINTIFF
17
SEPTEMBER 23, 2011
18
19
20
(Starting time of the deposition:
9:32 a.m.)
21
22
23
24
25
Job Number: 41966
TSG Reporting - Worldwide
877-702-9580
Page 4
1
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
2
3
APPLE, INC., a California
corporation,
4
Plaintiff,
5
vs.
6
7
8
9
SAMSUNG ELECTRONICS CO., LTD.,
a Korean business entity;
SAMSUNG ELECTRONICS AMERICA,
INC., a New York corporation;
SAMSUNG TELECOMMUNICATIONS
AMERICA, LLC, a Delaware
limited liability company,
10
Defendants.
)
)
)
)
)
) Case No.
) 11-CV-01846-LHK
)
)
)
)
)
)
)
)
)
11
12
13
14
15
16
17
18
19
20
21
VIDEOTAPED DEPOSITION OF ROGER F. FIDLER,
produced, sworn and examined on September 23, 2011,
between the hours of nine o'clock in the forenoon and
eight o'clock in the evening of that day, at the
offices of Midwest Litigation Services, 401 Locust
Street, Suite 204, Columbia, Missouri 65201, before
William L. DeVries, a Certified Court Reporter (MO),
Certified Shorthand Reporter (IL), Registered
Diplomate Reporter, Certified Realtime Reporter, and a
Notary Public within and for the State of Missouri, in
a certain cause now pending in the United States
District Court, Northern District of California,
between APPLE, INC., a California corporation,
Plaintiff, vs. SAMSUNG ELECTRONICS CO., LTD., a Korean
business entity; SAMSUNG ELECTRONICS AMERICA, INC., a
New York corporation; SAMSUNG TELECOMMUNICATIONS
AMERICA, LLC, a Delaware limited liability company,
Defendants; on behalf of the Plaintiff.
22
23
24
25
TSG Reporting - Worldwide
877-702-9580
Page 5
1
A P P E A R A N C E S
2
3
4
5
For the Plaintiff:
Ms. Jennifer Lee Taylor
Morrison & Foerster
425 Market Street
San Francisco, California 94105
6
7
8
For the Defendants:
9
10
11
Mr. Michael T. Zeller
Quinn Emanuel Urquhart & Sullivan
865 South Figueroa Street,
Los Angeles, California 90017
12
13
14
15
Mr. Michael D. Sadowitz
Quinn Emanuel Urquhart & Sullivan
51 Madison Avenue, 22nd Floor
New York, New York 10010
16
17
18
19
Also present:
Mr. John Niehaus, Videographer
20
21
22
23
24
25
Court Reporter:
William L. DeVries, RDR/CRR
Missouri CCR #566
Illinois CSR #084-003893
TSG Reporting - Worldwide
877-702-9580
Page 174
1
lab.
They opened the lab shortly after we opened our
2
lab.
The -- Paramount opened a lab on the opposite
3
side of our office.
4
US West had a -- a small office there where the people
5
that were working with us on communications were
6
located.
So we had Paramount, Apple.
7
Q.
Was this all on one floor?
8
A.
All on the same floor.
And
9
10
US West, I'm not
sure if they were on the same floor or not.
I think
they were on another floor.
11
Q.
What's Paramount?
12
A.
Paramount Motion Pictures.
They were
13
looking at how to do entertainment and videos and very
14
interested in the tablet for being able to distribute
15
videos and multimedia.
16
17
Q.
In your -- or what was -- you said it was
an Apple Media Lab; is that correct?
18
A.
It was the Apple Media Lab.
They had a
19
couple people who had been locally hired that I've
20
mentioned, Dennis Dube.
21
Q.
Could you spell that?
22
A.
D-U-B-E, the last name.
Dennis is first
23
name.
Joe Pezzilo I think is how it was --
24
P-E-Z-Z-I-L-O I think is the spelling.
25
sure about the spelling, but those are the two names I
TSG Reporting - Worldwide
Yeah, I'm not
877-702-9580
Page 175
1
remember.
2
There were -- there were at least two other
3
people that were in the lab on a fairly regular basis,
4
but -- and we -- at that point we were working with
5
them on the development of -- of newspaper content for
6
the Apple Newton, and it was just as the Apple Newton
7
was being developed and they were getting ready to
8
launch the Apple Newton, '92, '93.
9
Q.
Is that when it launched?
10
A.
'93 I think is when it -- when it launched.
11
Q.
So you said a couple -- you used the phrase
12
13
14
a couple of local hires?
A.
Well, Dennis and -- and Joe both lived in
Boulder and were hired by Apple.
15
Q.
Uh-huh.
16
A.
And they had a -- a couple other people.
17
don't know if they were local hires or they were hired
18
from Apple.
19
their staff situation.
20
and meet with us occasionally.
21
lab and talk to them about the Apple Newton.
22
were right adjacent to our lab.
23
Q.
You know, we weren't really involved in
But they would come to our lab
We would go to their
But they
Do you know if they were working on
24
anything else other than newspaper content for the
25
Apple Newton?
TSG Reporting - Worldwide
877-702-9580
I
Page 176
1
A.
Well, they were working on content for the
2
Newton, but to my knowledge they were most interested
3
in getting news content for the Newton.
4
was their mandate from Apple.
5
6
Q.
I think that
Do you know why they were doing this in
Boulder, Colorado?
7
A.
Well, they opened the lab after we opened
8
our lab, and I think it was, you know, because we were
9
there.
10
They opened their lab to work with us.
was no other reason for them to be in that location.
11
12
There
Q.
Did anyone tell you that's why they opened
their lab?
13
A.
I suspect at some point in the conversation
14
they mentioned that the -- well, in fact, I knew when
15
they -- when they opened the lab that they were
16
opening it because we were there and they wanted to
17
work with Knight-Ridder on developing content for the
18
Newton.
19
was intentional.
20
Q.
So yes, they did -- they did tell us that it
Can you -- do you remember any -- what
21
period of time were you working with the folks at
22
Apple Media Lab to develop the content?
23
A.
It would have been probably beginning in --
24
I would suspect in 1993.
We opened our lab in August,
25
September of -- of '92, and wasn't very long after
TSG Reporting - Worldwide
877-702-9580
Page 177
1
that that they opened their lab adjacent to us.
2
Paramount opened its lab also in '93.
3
4
And
Q.
Do you know how long the Apple Lab stayed
A.
I think they shut down shortly after
open?
5
6
Knight-Ridder shut down our lab, that all of -- all of
7
the people who had been working with us in that
8
building shut down their laboratories soon after we
9
left.
10
11
Q.
Other than discussing content for the
Newton with them --
12
A.
Uh-huh.
13
Q.
-- do you remember any other discussions
14
you had with them?
15
16
MR. ZELLER:
A.
17
18
The question --
Well, we -MR. ZELLER:
The question is vague at this
point --
19
THE WITNESS:
20
MR. ZELLER:
Uh-huh.
-- as to -- he's already
21
testified about some discussions he had with -- with
22
Apple -- Apple people.
23
vague and confusing at this point.
24
25
So I think the question is
THE WITNESS:
Q.
Uh-huh.
(By Ms. Taylor)
Go ahead.
TSG Reporting - Worldwide
877-702-9580
Page 178
1
A.
So they visited our lab quite often.
We
2
had lunches together.
They were intrigued by my
3
vision of the tablet, and I may be mistaken, but I'm
4
fairly confident that Dennis Dube who was heading up
5
the lab was the person who actually recommended the
6
videographer that we ended up using because he was --
7
he had -- he was native to Boulder and had been there
8
for some time.
9
Boulder.
As far as I know, he's still living in
10
So yes, we -- we had lots of discussions
11
about the validity of the -- my vision of the tablet
12
and when that might happen and -- and my view as that
13
the Newton was just the beginning of what was coming.
14
15
Q.
When you say you had discussions about the
validity of my vision of the tablet --
16
A.
Uh-huh.
17
Q.
-- what do you mean when you say my vision
18
19
of the tablet?
A.
Well, the idea of a magazine-sized tablet,
20
it would be lightweight, easy to carry, that
21
newspapers could use to do more visually rich
22
presentation.
23
With the Newton, all that we could do at
24
that time was just text, and it was small -- it was so
25
small that all you could really do was one column of
TSG Reporting - Worldwide
877-702-9580
Page 179
1
text.
2
3
Q.
display text; you don't mean send a text message?
4
5
A.
8
9
No.
It was just -- you know, it would
display the stories on the -- on the screen.
6
7
When you say just text, you mean just
Q.
Life has evolved.
A.
Uh-huh.
Text has another meaning
now.
Uh-huh.
No, we also had Newton
poetry at that time when -- it was handwriting
10
recognition if you recall on the Newton.
And so the
11
joke at the time was that the handwriting recognition,
12
whatever you wrote, it would -- it would create its
13
own poetry too.
14
Q.
That all -- it was quite humorous.
I think you used the phrase they were
15
intrigued by your vision of the tablet.
16
made you say that or what makes you think that?
17
A.
What -- what
Well, because I think Dennis came from a
18
newspaper background, was equally concerned about the
19
digital transformation of newspapers, and so was eager
20
to know as much as he could about what we were doing.
21
As I said earlier, we had no interest in
22
building hardware, and if -- if I was able to
23
stimulate Apple to move more quickly to build tablets,
24
I would have been very happy.
25
Q.
Do you think you did?
TSG Reporting - Worldwide
877-702-9580
Page 180
1
A.
I don't know.
No way to know for sure.
2
Obviously the -- with the videos being widely
3
circulated and -- and as many conferences as I spoke
4
at and the fact that one of our members of our team
5
went to work for Apple after we shut down the lab, I
6
have to believe that people at Apple knew about the
7
work I was doing.
8
9
10
In all fairness, that was at the time when
Sculley was the CEO and Steve Jobs didn't return
until, what, 1997 I believe it was.
11
12
Q.
After Knight-Ridder closed, have you had
any communications with anyone at Apple?
13
A.
No.
We've tried, but...
14
Q.
When did you try?
15
A.
Well, when I went to Kent State we tried to
16
see if Apple would be interested in helping fund our
17
research and development work, but were unsuccessful.
18
We had -- Adobe funded our research.
19
20
Q.
Did you have anyone else fund it while you
were at Kent State?
21
A.
I'm sorry?
22
Q.
Did anyone else fund your research at Kent
24
A.
Los Angeles Times.
25
Q.
Anyone else?
23
State?
TSG Reporting - Worldwide
877-702-9580
Page 187
1
2
Q.
And -- and if that was happening, that's
separate from what you're doing?
3
A.
Yeah, absolutely.
4
Q.
Okay.
5
Other than what you've described
that may be happening --
6
A.
Uh-huh.
7
Q.
-- are you aware of any other possible
8
connections between Samsung and the Reynolds?
9
A.
That's all I'm aware of.
10
Q.
If you'll go to Exhibit H of your
11
declaration, it is the article with the picture of
12
you.
13
A.
Uh-huh.
Uh-huh.
14
Q.
I think this is Forbes ASAP.
15
A.
Uh-huh.
16
Q.
Second page --
17
A.
Uh-huh.
18
Q.
-- first column --
19
A.
Uh-huh.
20
Q.
-- halfway down --
21
A.
Uh-huh.
22
Q.
-- just below where it says "Telecosm."
23
the left side it says, "Down the hall is an Apple
24
Computer media center which is developing graphical
25
forms of AppleLink, the company's on-line network."
TSG Reporting - Worldwide
877-702-9580
On
Page 188
1
Do you see that.
2
A.
3
4
MR. ZELLER:
Exhibit 8.
5
6
A.
9
10
I'm sorry.
We're on
What paragraph is that again?
Right.
They're talking -- the Apple Media
Lab.
7
8
Uh-huh.
MR. ZELLER:
Q.
Thank you.
(By Ms. Taylor)
Is that the media lab you
were describing earlier?
A.
Yes, that's what I'm referring to.
I think
11
George Gilder didn't fully understand it.
12
was -- we were looking at ways to deliver content to
13
the Newtons.
14
was the -- that was our main focus at that time.
15
And yes, he
He doesn't mention the Newton, but that
AppleLink I believe by that time -- I
16
worked with AppleLink and I had close relation with
17
Apple early on because I licensed the AppleLink
18
technology in 1994 to launch what I called Presslink
19
as a global intranet for the newspaper industry to
20
deliver graphics and photos.
21
So -- but I think by the time he wrote this
22
article, I think he was mistaken that AppleLink was --
23
had already been sold, and that was the basis for AOL
24
to be able to launch a similar system.
25
So I think what he was referring to here
TSG Reporting - Worldwide
877-702-9580
Page 189
1
is -- is that to provide a way to deliver content
2
on-line to the -- the Newton, which he doesn't
3
mention.
4
Q.
I'll have to admit I'm a little bit
5
confused.
6
he's -- the timing, like AppleLink --
Is it -- is -- is the potential error that
7
A.
Uh-huh.
8
Q.
-- had already been sold to some third
9
10
11
12
13
party by the time this article was written?
A.
If my memory serves me correctly, AppleLink
had already been sold by that time.
Q.
At some point when this Apple Computer
media center was in Boulder --
14
A.
Uh-huh.
15
Q.
-- do you know if it was working on what
16
he's described in this article?
17
A.
I don't think he accurately described it.
18
Q.
Okay.
19
A.
And it may be that they did not want to
20
tell him what they were working on at that point, but
21
that's my personal speculation.
22
Q.
The last -- we'll go to paragraph ten of
23
your declaration.
24
page four.
25
break because you've been sitting there a long time
Go to the front.
Paragraph ten,
By the way, tell me if you want to take a
TSG Reporting - Worldwide
877-702-9580
Page 190
1
since we watched a video.
2
A.
Paragraph ten?
3
Q.
Paragraph ten.
4
A.
Uh-huh.
5
Q.
The last sentence, paragraphs ten says IDL
6
worked with Apple on news content --
7
A.
Uh-huh.
8
Q.
-- for Apple's Newton product --
9
A.
Uh-huh.
10
Q.
-- until IDL shut down in 1995.
11
A.
Uh-huh.
12
Q.
Can you tell me what that means?
13
A.
That's what I had just said, that we -- our
14
involvement with them -- with Apple was specifically
15
about delivering news content to the Apple Newton
16
during -- from about 1993 to 1995.
17
18
19
20
Q.
But what did you really do on a day-to-day
A.
We were looking about -- at how we would
basis?
get the feeds of -- of news from newspapers --
21
Q.
Uh-huh.
22
A.
-- and to be able to deliver them to the
23
device and what the content might look like when it's
24
on the Apple Newton.
25
Q.
And how were you talking about getting the
TSG Reporting - Worldwide
877-702-9580
Page 191
1
2
feeds to the device?
A.
The -- again, remembering this is before or
3
just as the -- the web was developing, trying to
4
figure out the most efficient way to get it to them.
5
And as I recall -- again, it's a while -- that nothing
6
specific came out of that -- those discussions or we
7
didn't actually end up producing something that they
8
could use because even by the time we shut down in
9
1995, it was apparent that the Apple Newton was not
10
going to be a successful product.
11
when the Apple Lab finally shut down.
12
13
Q.
And I think 1996 is
The next sentence, which is the first
sentence in paragraph eleven --
14
A.
Uh-huh.
15
Q.
-- says during the time IDL and Apple
16
collaborated --
17
A.
Uh-huh.
18
Q.
-- Apple personnel were exposed to my
19
tablet ideas and prototypes.
20
A.
Uh-huh.
21
Q.
Do you see that sentence?
22
A.
Yes, uh-huh.
23
Q.
What -- what is -- what was that
24
25
collaboration?
A.
We had a conference room in our lab where
TSG Reporting - Worldwide
877-702-9580
Page 192
1
we would meet and talk about -- we certainly talked
2
about the Newton, but we were talking about at what
3
point can we expect to see a tablet, and I would show
4
the prototypes that we had.
5
Again, we were not trying to keep our
6
tablet idea secret because we wanted companies to
7
build a tablet device.
8
encouraging them to pursue a larger magazine-sized
9
device for displaying newspaper content.
So I was probably certainly
10
And we showed them some of our early ideas
11
for -- or our ideas for how news could be presented on
12
a tablet.
13
video that we produced, the 1994 video.
When we produced our video, they saw our
14
Q.
Exhibit L.
15
A.
At -- at the -- what?
16
Q.
Exhibit L.
17
A.
Oh.
18
Q.
That's the -- that's how we identified the
19
20
1994 video, Exhibit L.
A.
Right.
Right.
1994 video in our lab.
And
21
so in collaboration -- that may be a bit strong, but
22
we -- you know, I would pick their brains for what
23
they knew and -- and what we might learn about how
24
tablets might evolve and how news might be presented
25
on those devices.
TSG Reporting - Worldwide
877-702-9580
Page 193
1
So it was a very congenial, relaxed -- we
2
would go to lunch together.
3
was -- it was -- it was not a formal arrangement with
4
them.
5
6
Q.
We would have -- so there
When you were working with them on the news
content --
7
A.
Uh-huh.
8
Q.
-- as referenced in the previous
9
paragraph --
10
A.
Uh-huh.
11
Q.
-- did you have a contract in place with
13
A.
There was no contract.
14
Q.
Did one company pay the other company?
15
A.
No.
16
Q.
Was --
17
A.
And we -- and -- and they received no money
12
18
19
20
21
them?
We received no money from Apple.
from us.
Q.
Was -- was there a formal relationship
between the companies?
A.
No.
There was no -- there was no NDA
22
between us.
23
that I recall that we actually signed.
24
25
Q.
At least -- let me correct that.
No NDA
So how did it come to be that you were
working with them on news content for the Apple's
TSG Reporting - Worldwide
877-702-9580
Page 194
1
Newton product?
2
A.
Because that was -- my understanding was
3
that that was their main reason for existing in
4
Boulder, Colorado was to learn about how -- you have
5
to understand, the Newton was originally set up to be
6
a personal digital assistant.
7
And so its original focus was more on
8
maintaining your calendar, maintaining your phone
9
list, all the basic information, plus being able to
10
take notes and -- and have that translated into
11
machine-readable text.
12
At the time that they opened the lab in
13
Boulder, they were beginning to think about what kinds
14
of more dynamic information we could provide that
15
would make the Newton more valuable to people.
16
And so our discussions were more general
17
and exploring what the issues would be, what
18
newspapers would have to do if they wanted to
19
contribute content, much the same that later they had
20
to learn how to do -- to provide to e-readers.
21
Very similar situation.
But to my
22
knowledge, we were not able to get any newspapers to
23
deliver content to them.
24
them, but we actually did not have a newspaper working
25
with them.
We could simulate content to
TSG Reporting - Worldwide
877-702-9580
Page 195
1
We did attempt to work with The Daily
2
Camera, which is the local newspaper in Boulder,
3
Colorado which Knight-Ridder owned, and I do recall
4
meetings with Dennis Dube, Barrie Hartman, who is the
5
editor and later the publisher of the -- of the
6
newspaper and I would sit down and we would talk about
7
the future and how perhaps we could experiment with
8
content from the daily news -- or I mean the -- The
9
Daily Camera to simulate what we could do with the
10
Apple Newton.
11
At the same time, by the way, I was also
12
working -- or looking at the -- the GO Tablet that was
13
developed by GO Corporation and meeting with people
14
from GO and from Slate, a company that was based in
15
Arizona that was developing content for the GO Tablet,
16
which was in fact a letter-sized black and white
17
display.
18
And they launched that also in -- I think
19
they began it in 1992, but it was finally launched in
20
1993.
21
22
23
So ...
Q.
How did you first meet the people at the
Apple Computer Media Lab?
A.
I honestly don't recall of how that
24
occurred, but I -- I remember meeting with Dennis
25
Dube, who headed the lab at that time, and -- when he
TSG Reporting - Worldwide
877-702-9580
Page 196
1
indicated he'd like to set up the Apple Media Lab
2
adjacent to our lab and collaborate with me.
3
Q.
Was Dennis Dube -- is it a V or a B?
4
A.
B, Dennis Dube.
5
Q.
B, okay.
Was Dennis Dube an employee of
6
Apple before the Apple Media Lab was set up as far as
7
you know?
8
A.
I don't know.
9
Q.
But you recall meeting with him before the
10
media lab was set up?
11
A.
Right.
12
Q.
And did he ask if -- if you would help them
13
with what they were planning to do?
14
MR. ZELLER:
I think the question is vague.
15
A.
I -- I don't recall exactly what he asked
16
me at that point.
17
Q.
18
people --
19
A.
Uh-huh.
20
Q.
-- who worked at the Apple Media Lab.
21
A.
Uh-huh.
22
Q.
Mr. Dube and --
23
A.
Joe Pezzilo.
24
Q.
Pezzilo.
25
A.
Uh-huh.
(By Ms. Taylor)
You identified two
TSG Reporting - Worldwide
877-702-9580
Page 197
1
2
Q.
Do you recall any other names as the day
has gone on?
3
A.
Not at this point.
4
Q.
Do you know how many more people there
A.
Only -- if memory serves me, I think there
5
were?
6
7
were four people at the lab, but that's just my
8
memory.
9
that.
10
I have no specific information to corroborate
Q.
Did the collaboration that you had, that
11
you reference in paragraph eleven, go beyond working
12
with Apple and news content for Apple's Newton
13
product?
14
A.
Apple what?
15
Q.
Apple's Newton product.
16
MR. ZELLER:
17
answered.
18
A.
19
20
21
22
23
This is -- this is asked and
It's also vague.
At that time the Apple Newton was the only
thing we were focused on.
MS. TAYLOR:
Okay.
I've been told we're
just about out of time, so let's take a break.
VIDEOGRAPHER:
We're going off the record
at approximately 4:14 p.m.
24
(WHEREIN, a recess was taken.)
25
VIDEOGRAPHER:
We're back on the record on
TSG Reporting - Worldwide
877-702-9580
Page 343
1
that's confidential?
2
A.
3
was confidential.
4
5
To my knowledge, nothing I discussed today
MS. TAYLOR:
Okay.
I think I'm done.
So
we'll go off the record.
6
MR. ZELLER:
I may have one question.
7
me see one second.
8
further questions for you.
9
VIDEOGRAPHER:
10
11
MR. ZELLER:
Signature?
We have -- we have a
VIDEOGRAPHER:
We're going off the record
at approximately 7:52 p.m.
14
15
I have no
stipulation.
12
13
No, I was incorrect.
Let
(WHEREIN, the deposition was concluded at
7:52 p.m.)
16
17
18
19
20
21
22
23
24
25
TSG Reporting - Worldwide
877-702-9580
Page 344
1
CERTIFICATE OF REPORTER
2
STATE OF MISSOURI
3
CITY OF ST. LOUIS
4
)
) ss.
)
I, William L. DeVries, a Certified Court
5
Reporter (MO), Certified Shorthand Reporter (IL),
6
Registered Diplomate Reporter, Certified Realtime
7
Reporter, and a Notary Public within and for the State
8
of Missouri, do hereby certify that the witness whose
9
testimony appears in the foregoing deposition was duly
10
sworn by me; that the testimony of said witness was
11
taken by me to the best of my ability and thereafter
12
reduced to typewriting under my direction; that I am
13
neither counsel for, related to, nor employed by any
14
of the parties to the action in which this deposition
15
was taken, and further that I am not a relative or
16
employee of any attorney or counsel employed by the
17
parties thereto, nor financially or otherwise
18
interested in the outcome of the action.
19
20
____________________________
21
Notary Public within and for
22
The State of Missouri
23
Dated September 24th, 2011
24
25
My commission expires August 14, 2015.
TSG Reporting - Worldwide
877-702-9580
Page 345
1
STATE OF
)
2
3
)
COUNTY OF
)
4
5
6
7
8
I, ROGER F. FIDLER, do hereby certify:
That I have read the foregoing deposition;
That I have made such changes in form and/or
substance to the within deposition as might be
necessary to render the same true and correct;
That having made such changes thereon, I hereby
subscribe my name to the deposition.
I declare under penalty of perjury that the
foregoing is true and correct.
9
10
ROGER F. FIDLER
11
12
13
Executed this 24th day of September,
2011.
14
15
16
Notary Public:
17
My Commission Expires:
18
19
20
21
22
23
24
25
TSG Reporting - Worldwide
877-702-9580
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?