Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 82

MOTION for Extension of Time to File Opposition to Expert by Defendant Forest River Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P)(Fountain, Ryan)

Heartland Recreational Vehicles LLC v. Forest River Inc

Doc. 82 Att. 10

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6 Q. Mr. Taylor, what did you do to prepare to come here today as the 30(b)(6) designee? A. I reviewed the file history and the files of Baker & Daniels and Barnes & Thornburg. Q. Did you talk to anybody at Heartland to gather information? A. No, I did not speak personally with anyone at Heartland. Q. You say speak personally. Did you speak indirectly to anyone at Heartland? A. No, I didn't. Q. Did you look at any of Heartland's records? A. Just to the extent to which they were in the Baker & Daniels and the Barnes & Thornburg files. 84 Q. I see. As part of your analysis, you also made certain credibility judgments, didn't you? A. To a certain extent, yeah. Q. And what techniques or methodology did you use to 85

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1 judge someone's credibility? 2 A. Um, the only issues that I saw there is where there 3 was documents that clearly refuted the testimony. 4 Then, you know, I would make a determination that 5 that's probably not accurate, because it's not 6 supported by the documentary evidence. 7 Q. But you have no way of knowing if those documents 8 were actually received by Heartland, because you 9 didn't look at Heartland's records, did you? 10 A. I have no reason to know that they were not.

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108 Q. Yeah. And you didn't look to see if Heartland had a copy of that in their files, did you? A. I have not seen a copy. All I've seen is Mr. Tuttle's testimony. That if it's there, it will be in Baker & Daniels or Barnes & Thornburg's files. Q. It would also be in Heartland's files, don't you think? A. If they still have their files.

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