LeMond Cycling, Inc. v. Trek Bicycle Corporation
Filing
139
Attachment 4
DECLARATION of Emily S. Zastrow in Opposition to
117 Memorandum in Support of Motion,
114 MOTION for Summary Judgment filed by Trek Bicycle Corporation. (Attachments: #
1 Placeholder for Exhibits 45,55-57,61,66,70,74, #
2 Placeholder for Exhibits 46-47, #
3 Exhibit 46, #
4 Exhibit 47, #
5 Exhibit 48, #
6 Exhibit 49, #
7 Exhibit 51, #
8 Exhibit 51, #
9 Exhibit 52, #
10 Exhibit 53, #
11 Exhibit 54, #
12 Exhibit 58, #
13 Exhibit 59, #
14 Exhibit 60, #
15 Exhibit 62, #
16 Exhibit 63, #
17 Exhibit 64, #
18 Exhibit 65, #
19 Exhibit 67, #
20 Exhibit 68, #
21 Exhibit 69, #
22 Exhibit 71, #
23 Exhibit 72, #
24 Exhibit 73, #
25 Exhibit 75, #
26 Exhibit 76)(Rolf, Benjamin) SEALED DOCUMENTS RECEIVED IN CLERKS OFFICE on 8/5/2009 (lph). Modified attachment text on 8/6/2009 (RLR).
LeMond Cycling, Inc. v. Trek Bicycle Corporation
Doc. 139 Att. 4
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 1 of 38
ZASTROW EXHIBIT 48
Dockets.Justia.com
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 2 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 1
1
2
UNITED STATES
DISTRICT
COURT
DISTRICT OF MINNESOTA
LeMOND CYCLING,
3
4
INC.,
5
Plaintiff,
vs.
TREK BICYCLE CORPORATION,
6
Case No.
08-1010
7
8 9
Defendant/Third-Party
Plaintiff,
vs.
GREG LeMOND,
10
11 12 13
Third-Party
Defendant.
-----------------------------------------------------video Deposition of
JOHN BURKE
14
15
16
17 18
Tuesday, April 7, 2009
9:31 a.m.
19
20
at
GASS WEBER MULLINS,
LLC
309 North Water
Milwaukee,
21
22
Wisconsin
Street,
Suite
700
53202
23
24
Reported by Julie
K.
Lyle, RPR/RMR/CRR
25
Gramann Reporting, Ltd.
414.272.7878
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 3 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 10
1 2 3 4 5
your last name.
MR.
I'm sorry.
WEBER:
That's all right.
That's
all right.
BY MR.
Q
WEBER:
But just
--
so
I
just caution you,
none of my
6
7
questions are aimed at discovering any of your
communications
that you had with your counsel,
your head
I
8 9
okay?
So
a
just kind of put that in
roadblock.
I
for
kind of
don't want --
don't
10
want to ask you about those.
A
11
12 13
Okay.
Q
What
specific provision did
contract
yesterday?
you look
at in the
LeMond
A I
14
15
16
looked at Section 13.
Q
A
What
is Section
13
13?
LeMond
Section
states that Greg
damage
cannot do
Company.
17
18
19
Q
anything to
And you
the Trek Bicycle
LeMond
believe that Mr.
has,
in fact,
done that?
A
20
Yes.
Okay.
How has he done
a
21
Q
A
that?
I
22
23
There are quite
give you
a
few different ways.
will
well
sales
few examples.
24
In
with the LeMond
2001 we were doing very
I
25
line.
think
we had grown
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Videotape Deposition of John Burke, 4/7/2009
Page 11
1
2
to somewhere
around $16
million.
After Lance
was
Armstrong won the Tour de France, Greg LeMond
3
4
stated publicly that this achievement
a
either
great accomplishment or the greatest fraud in
That caused absolute
caused
a
5 6
7
the history of sports.
--
a
lot of problems with our retailers,
of problems with our consumers.
The bicycle business
caused
lot
8 9
is very
a
10
dependent
on bicycle retailers.
They make
lot
11
12
13 14 15
of decisions
door,
about what products come in the
and those
are the products that go out the
a
door.
They spend
lot of time
recommending
what
products they want to sell.
When
Greg made those comments in
16
17
2001,
the confidence
of those small business
and because
people went down substantially,
of
18
that,
sales.
it
hurt our relationships
and
with those
19 20
21
22
retailers,
it
also hurt our potential LeMond
Again,
in 2004,
when
-- right
in the
summer,
before or
after the tour,
sometime
23
24 25
Greg said that Lance Armstrong threatened my
wife,
were
my
life,
a
and my
livelihood.
we were
Once
again,
a
we
in
situation
where
getting
lot
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Page 12
1 2
of negative feedback from retailers
and we were
getting
that
was
a
lot of negative feedback from
consumers
3
4
undermining Trek's efforts in the
marketplace.
Our
5 6 7
retailers,
our salespeople
are
all
out there working hard for Greg LeMond.
They're selling LeMond product which Greg's
making
a
8 9
royalty
on,
and
they're being undercut.
a
Those are
couple of examples
10 11
12
there.
If
damaged
we
take
a
look at
how Greg
Trek through employee purchases,
somewhere
in his
13
contract he gets
and he
around 15 free bikes
14
gets the ability to buy bicycles for
15 16
17
18 19
friends,
for
This is
excuse
a
met
for family.
All
right?
--
something
that Trek
employees
can do.
Over the relationship
he ended up purchasing
with Greg,
$1.5 million worth of
20 21
22
23 24 25
bicycles.
same
Just to give you an example,
in that
period of timet Gary Fisher purchased around
Lance Armstrong purchased around
$24/000. $24/000.
It
Greg LeMond had
a
even got to the point where
price list that
he used.
In
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Page 13
1 2 3 4 5
fact,
of
he was
actually -- in certain cases,
in Minneapolis
where Greg was
he was
competing with our dealers.
a
There's an example
sale
up
competing
with our dealers.
Those
are
a
couple of examples
6
7
where Greg has damaged Trek.
Q
I
--
I
understand that those are
I
a
couple of
8 9
examples.
want you to give
me
me
the exhaustive
Greg LeMond
list.
A
Tell
I
-- tell
you
a
me how
else
10 11
12 13
has damaged
Trek.
Well,
just gave
couple of the big ones
that -- I can be a little more specific and tell you that in 2001, the LeMond business was about
15 or $16
14
15 16
17
million.
Everything
up
until that
and
point had been going pretty well.
All
other athletes.
We
the sudden we get to 2001,
comments
Greg starts making disparaging
about
18
19 20 21 22 23 24
25
were
in
a
perfect position at
of cycling
in
a
that point in time.
growing
The sport
was
significantly.
as
a
LeMond was
great
position
grown
brand.
my
That business could have
to,
in
estimation,
at least $30 million
and
over the next
five years,
it
stayed
flat at
best.
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Videotape Deposition of John Burke, 4/7/2009
Page 14
1
2
There's an example.
Another example is what happened
3
4 5
in the PTI lawsuit.
was not doing
Back
in the late 1990s, Trek
We
so
well financially.
were
6
7
look at making -- we were reviewing our business to see where we could make some changes.
taking
a
We
took
a
look at the
LeMond
contract and
a
we
8 9
said, you know what, we're not doing
of selling
LeMond
good job
accessories.
10
11 12 13
And we
Greg and said,
Greg,
so
talked to -- I talked to is there a way that we could
restructure this
company.
that we're not going to sell
LeMond accessories and you can do
it
with another
14 15
And we
talked about that for
we came
a
16 17
18
19
while.
things.
we
And sure enough,
a
to an agreement
where we gave Greg
We
couple extra things,
large
expanded the length of the contract,
on
agreed to pay more royalties
international
20
sales,
and we got out of the accessory contract.
I
21 22
23
brought up to Greg at that
Greg,
we
point,
you know,
really don't
independent
want to
see LeMond accessories
go to the mass merchant.
24
That's
a
big competitor for
Greg
bicycle
25
retailers.
said that's not going to happen.
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Videotape Deposition of John Burke, 4/7/2009
Page 15
1 2
If
anything takes place here,
I'll
let
you know.
If
you go back and you
take
a
look
3
4
at it, unfortunately,
once again,
there had been
a
negotiations with PTI, there had been
intent signed even before he
conversation.
and
I
letter of
5 6
7
had that
It's just
would make commitments.
time and time again Greg
He would say
8
I'm going
9
to
do one
thing, and then he would
do something
10
11 12
else.
You can go back
in the history
when we
and
take
when
a
look, in 2001,
in 2004, in 2006
--
13
14
Greg would comment on
specific athletes
do
and
we'd get to the end of this and Greg would say,
you know what,
15
16
17
Ilm not going to
that
anymore.
I'm done with that.
I'm not going to do that.
Ilm going to support
I'm going to support Trek.
your
18 19
retailers.
And,
That's the way
And we'd say,
it's
going to be.
and weld go
great,
20 21
22 23
24
out there.
know,
as we always
have done, you
we
kept going on and on.
we
Despite
And
all
the
problems,
kept moving on.
it
was
disappointing.
But those are just more examples.
Q
25
Do you have
any
other examples?
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Videotape Deposition of John Burke, 4/7/2009
Page 16
1 2 A
I'm
that
sure there's
I
plenty of more.
Those are ones
can
recollect at this time, and those are
for the
3
4 5
quite substantial.
Q
Well, you've had three weeks to prepare
deposition,
right?
You've been
6
7
A
Yes,
And
I
have.
Q
you've met three times over the past three
8 9 A
weeks,
right?
Uhm-uhm.
10
Q
A
Is that
Yes.
a
yes?
11
12
Q
A
And you've never been deposed
I
before, right?
13
have not.
14
15
Q
So
this is probably
what?
a
little
bit of
a
nervous
event for you,
A
right?
16
A
A
17
18
19
Q
A
nervous event for you in your
life.
with this?
No.
Q
A
Okay.
You're
totally
comfortable
20 21
22
23
No.
Okay.
Q
A
Somewhere-somewhere
They're
in between there.
Q
A
Somewhere
--
somewhere
in
between?
24
Yep.
25
Q
But you've obviously had time to think about how
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Page 17
1 2 A
Greg LeMond has
I
injured Trek,
right?
have.
3
4
Q
And as you're
sitting here today, you've given
me
the exhaustive
list
of every way that Greg LeMond
5 6
7 8 9 A
has damaged Trek;
No.
MR.
is that right?
Just
WEBER:
a
second.
Yeah.
Objection.
THE WITNESS:
BY MR.
No,
it's
not
right.
what
10 11
12
13
14
WEBER:
Q
A
Okay.
All right.
I
Well,
then
tell
me
else.
There are -ways
just
gave you three very large
that Greg
LeMond has damaged
Trek.
There
are plenty of others.
I
15
do
--
do you
look at
me when
I
16 17 18
Q
A
answer the questions?
Not always.
Okay.
I
run
a
sizable bicycle
on,
and so
company.
I
I
have
a
19
lot of things going
everything.
Q
A
don't
remember
20
21
Those are
three very large issues.
Okay.
Are you done answering?
22
23
Yes.
Q
All right.
me
As you
sit
here today,
have you told
24
25
everything that you remember regarding the
ways
that Greg
LeMond has
injured Trek?
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Page 18
1 2 3
4 5 A A
Yes.
Okay.
Q
The
--
how many consumer
complaints have
you produced
in this lawsuit from 2001?
to ask the lawyers.
You would have
Okay.
Q
A
Do you know
that you've produced none?
6
7
You would have How many
to ask the lawyers on that.
has Greg LeMond made
Q
athletes
I
8 9
A
disparaging comments regarding since 2001?
One
that
know
of.
10 11 12
13
Q
A
And who's
that person?
That would be Lance Armstrong.
The PC
LeMond
Q
--
the PTI lawsuit involved
a
deal that
Cycling entered into with respect to
14
15 16
17 18
A
accessories;
A
is that right?
That
is correct.
contracts have you entered into
as
a
Q
How many
CEO
on
No
behalf of Trek?
idea.
19
Q
A
Dozens?
20 21 22 23 24
25
Probably.
Would
Q
it
have
been
difficult for
you to request
a
contract between Trek and LeMond Cycling that
would have
prohibited Mr. LeMond from entering
into an accessories contract that enabled LeMond
Cycling to provide accessories
to the mass
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Page 28
1 2
things out.
successful.
We
wanted things to be
really
time
those
And we'd have problems time and
3
4
again.
And, you know, we'd discuss
problems,
and we'd
try to rectify those problems.
and those
5 6
7
And Greg would make commitments,
commitments
would be broken.
But we always
-- I'm
we
an optimistic
8 9
person.
I
always hope that
We're not
a
can
find
a
solution.
10 11
12
Q
instead of trying to
to solve problems.
litigious company, and so file lawsuits, we're trying
a
Well, you say that Trek is not
company.
litigious
13 14 15
16 17
A
Is that right?
LeMond
A
That's correct.
And
Q
yet, after
time?
served you with
a
lawsuit,
what was your reaction
Which
to that?
18
Q
A
In 2008. In 2008,
was
19
after
he served us
with
a
lawsuit,
it
20
21
22
23
Q
A
my judgment
that there had been
so many times
that Greg had not lived up to his commitments.
Uhm-uhm.
And
there had been too
many times when he had
we
24 25
threatened us, that when
received another
my
lawsuit less than ten days after
father
had
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Page 29
1 2
died,
a
I
figured that
you
was
enough.
And so we made
decision at that time to end the relationship.
3
4 5
Q
A
You
We
-did.
filed
a
lawsuit against Mr.
LeMond?
Q
And
that lawsuit
was
filed
here in Wisconsin,
6
7
right?
A
Yes.
And
8 9
Q
it
was
later
MR.
dismissed
after
we won
a
transfer motion in Minnesota,
WEBER:
right?
as to foundation
10
Object
as
11 12
13
14
15
to the procedural events that occurred.
MR.
MADEL:
You can go ahead and
answer.
MR.
WEBER:
If
I
you know about the
procedural
events,
you can
tell
don't
him.
know.
16 17 18
THE WITNESS:
MR.
WEBER:
You can
tell
him
if
you
don't.
THE WITNESS:
BY MR.
Q
19
Yeah.
20
MADEL:
21
22
23
that that lawsuit -- our lawsuit ultimately filed in Minnesota, right?
You know
I
was
A
know
that.
that your lawsuit -you
24 25
Q
And you know
filed
your
lawsuit in Wisconsin?
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Page 44
1 2
get you that information.
Q
You say that Mr.
LeMond
did
a
lot for the
same?
LeMond
3
4 5 6
brand.
Was
--
was
the efforts that Mr. Armstrong
did for the LeMond brand the
MR.
WEBER:
You
just said -- let
I
me
just stop you.
MR.
7
MADEL:
Did
just
do
the same
8 9
thing?
THE WITNESS:
MR.
Yep.
I
10 11
12 13
MADEL:
used
it
again.
I'm
sorry.
THE WITNESS:
MR. MR.
Sorry about that.
No,
Push
MADEL:
WEBER:
that's all right.
the reset button.
I
14
15
16
17
MR.
MADEL:
Here we go.
will.
Thank
you.
BY MR.
Q
MADEL:
18
With respect to your statement that Mr. Armstrong
19 20
21
22
23
24
A
did
Mr.
I
a
lot for the
do?
LeMond brand, what
did
Armstrong
think the basic thing is
is
he
--
he brought
up the
tide and all the boats rose with
it,
really
including Trek's, including Greg LeMond's,
including Specialized.
His tour victories
boom
25
ignited the road bike
in the United States.
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1 2 3 4 A
that presentation referring to Mr. idiot?
That was
a
LeMond as an
quote from
one
of our managers,
a
manager who had worked very hard to promote
LeMond
the
5 6 7 8 9
line.
And,
once again,
as
he's out there
working hard to promote Greg LeMond's line that
Greg's
making royalties on, Greg LeMond goes out
Lance Armstrong.
And,
and disparages
once again,
who has
that manager,
who
10 11
12
13
14
was Malcolm Davies,
the highest
integrity,
spend
a
once
again that manager
is having to
customers
who
lot of his time talking to
when he does
are asking him, Why do you do business with Greg
LeMond
Q
this time
and time again?
15
16
Move
to strike as nonresponsive.
Do you
consider Greg LeMond an
17
18 19
A
idiot?
No,
I I
don't consider
some
Greg LeMond
to be an idiot.
consider
of his actions to be idiotic.
A
20
They
don't make sense.
21
22
23
lot of
Greg LeMond's actions
we have been out
there building his brand,
and he
working
hard for his brand,
consistently
part of
24
shoots himself
in the foot.
There's
a
25
very interesting
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1 2
3 4
Q
A
Is the -You must
--
you must
-- it -we
you must
understand,
in the context,
were served with
around ten days
We
a
lawsuit ten days --
somewhere
5 6
7
after
same
my
father's death.
we
All right?
were given
were
type of lawsuit
in 2004.
All
to
right?
8 9
It
be threatening,
we
Q
was
a
lawsuit that
we found
and we wanted
to
make sure
that
10 11
12 13
A
were organized in how we put our message out.
What
did Trek
do
to Mr.
LeMond
within seven days
of his mother's death?
I
don't
know.
I
-- to
be honest with you,
I
14
didn't
Q
even know
that his mother had died.
send you
a
15 16
And
did Mr.
LeMond
note of condolence
after your father
A I
passed away?
17
18
believe that he did.
(Exhibit 135 was marked for
)
19
identification.
BY MR.
Q
20 21
22
23
MADEL:
Exhibit
2004,
135 is
a
letter
from Loren Brown,
LeMond
on
behalf of Trek, to Mr.
right?
dated August 10,
24
A
It
is.
25
Q
And the
first
two paragraphs say,
"My
firm
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4 5
just
Q
A
one way.
so
The media was going to
write about
the story,
they might as well hear the story.
Were you angry
No,
I
at this time at Greg
I
LeMond?
I
don't think
was
angry.
I
would say
was
disappointed.
I'd
We
put 14 years
into that
6
7
relationship.
started that relationship
out.
8
It
$4
was
interesting going through the notes that
9
our minimum sales target was something
like
far
a
10 11
12
13 14
million.
The success of LeMond with Trek
exceeded
those
original expectations.
There were
some
We
put
lot into it.
rocky times along
Every time we
the way based on Greg's behavior.
went out of our way to
15 16
17
try
and put
things back
who
together,
we
lost
we
customers
along the way
And
wondered why we continued with Greg.
and time again,
move
Q
time
18
19
tried to patch that
up and
--
move
it
along.
as
a
20
21
22
Did you lose any customers
result of your
April 8, 2008, presentation?
A
We
-- not to
Was
my
knowledge.
a
23 24
25
Q
Okay.
there
reason
--
now,
within your
April 8, 2008, presentation,
you included some
e-mails from customers.
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Filed 08/05/09 Page 18 of 38
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Page 77
1 2 3
4 A
Okay.
Why
Q
A
did
you do
I
that?
a
Because
magnitude,
think -- in I think it
decision of that
good
was
for everybody to
5
understand the kind of e-mails and the kind of
6
7 8 9
feedback that we had been getting.
After Greg's
2004 or 2006,
we
comments
in 2001 or
would get an amazing amount of
e-mails from upset retailers, from upset
customers.
And
I
10
think
it
was
important that
11
12 13
Q
A
that's something that
Define "amazing."
went
into our
decision-making process.
14 15 16
17
18
don't have to -- I don't but it was in the hundreds.
And
I
have the exact number,
Q
all of
those,
presumably,
should have been
produced
A
in this case, right?
a
That would be
You
I
legal question.
19
20
Q
A
don't
not.
know
if
they've been produced or not?
do
21
22
Q
A
Do you know
I
if
any of them have been discarded?
do not know.
23
24
Q
Was
there any effort at Trek, after 2004 to
today,
to have Trek employees
document
problems
25
that they were having with
LeMond
in the field?
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Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 19 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 83
1 2 3 4 A
The 2004 complaint
that
you had
summarized,
ridiculous
I
did you -- did you consider that at the time?
can't
remember.
5
6 7
Q
But yet you
--
even
after that
was
served on you
in 2004,
you made
the specific decision to
continue doing business with Mr. LeMond?
MR. WEBER:
8 9
Object.
Just
a
second.
Object to the form of the question.
mailed to him.
MR.
It
was
10 11 12
MADEL:
Okay.
Fair.
2004 complaint
BY MR.
Q
A
MADEL:
13
14
15
After
Yeah.
after you received the
-and
Q
you decided not to proceed with
litigation
LeMond;
16 17
to continue
doing business with Mr.
is
that right?
A
18 19
In the end, that
was
the decision that
was made
after
numerous
conversations with Greg and
20
assurances,
once again,
that Greg
was going
to
21 22 23
24 25
Q
support Trek,
comment
support
Trek
retailers,
and not
on
specific athletes.
was
The sequence was
a
Exhibit
a
135, you noticing
breach; LeMond serves
to continue
lawsuit on you; Trek
decides
to do business with LeMond,
Gramann Reporting,
Ltd.
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Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 20 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 84
1 2
right?
MR.
WEBER:
Object.
No.
3
4 5
THE WITNESS:
MR.
WEBER:
Wait.
Object to the form
of the question.
MR.
It
I
6
7
MADEL:
WEBER:
said serve again?
no, no.
MR.
No,
In addition to
8
that
-MR.
MR.
9
MADEL:
WEBER:
All right.
10 11
12
-we
we
have
a
standing
what that's
objection.
about.
I
think
understand
13
But beyond
that,
there's
-- you're
14
15
16
17
18
taking an event in August and an event in
December
and an event in the spring of '05 and
assuming that those are the only three events.
BY MR.
Q
A
MADEL:
Go
I
ahead and answer.
19
think the -- to
my
recollection,
sequence
the part that
20 21 22
23
24
25
you have not put
in your
of events are
conversations
with Greg about going forward and
really
having him make some adjustments in terms
of not commenting on specific athletes.
In 2004, part of that is
we
said,
okay?
listen,
we
just
want to end the agreement,
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Case 0:08-cv-01010-RHK-JSM Document 139-5
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Videotape Deposition of John Burke, 4/7/2009
Page 85
1 2
We're honorable peoplel
we're good peoplel
Why
we
obviously have
you go out and
a
disagreement here.
don't
And
3
4
find another company.
do any harm
Okay?
you
Why
we'll
know
I
do
we
a
nice transition
here becausel
5 6 7 8
don't want to
here.
don't you just
go out and
find another company.
I
And he went out and he looked around
and he
couldn't find another company.
And
we
9
that's
when he came
backl and
10
were taking
a
look at
it.
And we
just saidl
and put
11
12
13 14
Q
okaYI
let's --
once againl
let's try
this
thing back together.
we
And we
did thatl
and we
--
carried
on again.
The
-- weIll
first
-I
of
alII
how do you know he
15
couldn't find another
A
company?
16
17
18
Conversations
would say that's conversations
that I've had with counsel.
Q
Has anybody
-- weIll strike that.
Has
19
20
Greg LeMond or anybody on
behalf of Greg
find another
A
LeMond
told
you
that he couldn't
21
22
company?
No.
MR.
WEBER:
23
24
And by "you/"
you mean
Mr.
Burke personally as opposed to Trek?
MR.
25
MADEL:
I
don't think this is
a
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Page 94
1 2 A
That's true.
And you wouldn't
Q
ever turn
a
blind eye to that,
3
4 A
would you?
No,
I
I
wouldn't.
5 6
7
Q
mean,
if
you had
facts in front of you that
a
convinced you that this person was actually
doper, you're going to drop them from the Trek
8
family,
A
right?
provided
me
9
If
somebody
with evidence
in this
10 11
12
country, you're innocent until proven guilty,
right?
So
if
somebody
was
convicted of doping,
then they would be dropped from the Trek family.
Q
13
I've
on
got
a
trial
on May 5,
a
and
I
hope that you're
a
14
it.
That was
joke.
It's just
I
joke.
15 16
17
18
A
It's like, I'm like
May 5?
where am
going to be on
MR. WEBER:
He's
a
criminal defense
lawyer.
THE WITNESS:
19
Okay.
I
20 21 22
23
MR. MADEL:
couldn't --
I
couldn't
agree with you more.
BY MR.
Q
MADEL:
With respect to the evidence against
Mr.
24
Armstrong with respect
to doping
25
A
Yep.
Gramann Reporting, Ltd.
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Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 23 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 95
1
2 3 4 5 A
Q
--
do you have
--
do you know
of any evidence
drugs
that he
has used performance-enhancing
at
any time during his cycling career?
I
do
not.
I
Q
A
Have you read any?
No.
6
7
You know,
time to time
have been
really don't -- I'm sure from I've read an article where there
where he's made
you know,
I
8
allegations or I've had conversations
LeMond
9
with Mr.
plenty of
10 11 12 13
Q
A
allegations.
most
But,
-- this
guy
is the
tested athlete in the history of sports.
Uhm-uhm.
I'm aware that the
doping
allegations
were
14
litigated in the
won
Q
seA
lawsuit, and Mr. Armstrong
15
that lawsuit.
16
17
18
19
Was
it -a
was
there
a
factual finding that
he
didn't
A
dope
in that lawsuit?
I'm not
Has
lawyer.
a
Q
there been
problem with doping in the Tour
20
21 22
A
de France
in the last few years?
teams have had problems with doping,
Yes.
Numerous
Q
23
including the winner of last year's tour, right?
A I
24
couldn't specifically tell
you
that.
do you
25
Q
Do you know
of any players -- players -Gramann Reporting, Ltd.
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Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 24 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 97
1 2
to investigate
somebody
A
when
there are allegations of
doing
just that?
There's
3
4 5
We're not investigators.
-- there's
a
DCI.
They have
a
-- I'm
sure they have
And
rules and
they have doping protocol.
worked.
I
it's
obviously
6
7 8
they've found -- as you mentioned earlier, they found a number of people
mean,
here in the last few years.
Q
9
Well,
have
there been tests where
Lance Armstrong
EPO
10 11
12
13
14
A
proved positive for use
I
-- taking
in
1999?
do not know.
Q
Okay.
The
--
when you said
that Trek won't do
business with somebody that dopes,
do you
at
what point
believe
it
has been
established
that
15 16
17 18
Q
A
somebody has doped?
Well,
I
really don't -body came to
So
I
would say once the
governing
that conclusion.
for
All right.
example,
if
we
take Mr. Landis,
19
you would have done business
with
20
21
22
23
A
Mr. Landis up to the time that the arbitration
panel
came
out and said he's
a
-- he's guilty?
me
Isn't that
-WEBER:
MR.
Just let
object to the
24
form of the question as hypothetical.
THE WITNESS:
25
Right, hypothetical.
Gramann Reporting,
Ltd.
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Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 25 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 103
1
2 3 4 5 6 7 A
"how many."
I
mean, how many could be 20 to
--
if
of
Q
you
really wanted to
count
custom
builders,
to the best
et cetera,
my
it
could go as high as 40,
knowledge.
What was Trek's
fastest-growing
2000 to 2007?
road bike brand
in the period of
I
don't have those figures in front of
me,
but
I
8
9
would assume that
Q
A
it
was
the Trek brand.
Why would you assume
that?
a
10 11
12
13
Because the
--
we've had
lot of
growth with
Trek.
As
I
mentioned earlier,
the road bike
business,
after
Lance Armstrong won his
first
tour,
the road bike business,
not just for Trek
went up, and
14
15
but for everyone
in the industry,
it
just continued to
And
go up and up and up.
I
16 17
18
know
that
we have
a
large
share of that business,
and so as the business
continued to grow,
Q
so
did our sales.
19
20 21
22
23
With respect
you mentioned
to Mr. LeMond's bicycle sales which
at the very beginning of the
did you
deposition,
when
first
learn about the
extent of his bicycle purchases from Trek?
A
Way
When
I
too late.
24
Q
A
did you --
when was that?
I
25
would say
--
don't have the exact date on
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Case 0:08-cv-01010-RHK-JSM Document 139-5
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Videotape Deposition of John Burke, 4/7/2009
Page 108
1 2 A
1995 to 1999 entirely
No.
to Trek's efforts?
It
was
a
team effort between Trek and Greg.
a
3
4 5
Greg brought
great
name,
famous
cyclist,
won
the tour three times.
We
took that
name
and that image
6
7
and we put
it
together
with good product
we
designers.
And most important,
a
put
it
a
8 9
together with
great group of -- with
great
distribution
channel.
10 11 12 13
Trek's sales team is known as the
most competent
in the bicycle industry,
is second to none.
a
and the
You
Trek
retail
network
put
those things together and you've got
combination.
Q
good
14 15
16 17
And from 2000
through 2008,
do you
attribute the
level of those sales to be entirely due to Trek's
efforts?
A
18
19 20
"Entirely"
no,
is
a
very strong word.
I
would say
not
entirely.
But
after
2001,
when Greg
called
21
22
Lance
either the greatest hero or the greatest
we
fraud and again in 2004 and again in 2006,
were
23
fighting
an
uphill battle to sell Greg's
24 25
Q
bikes.
Yet the sales continued to increase?
Gramann Reporting, Ltd.
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Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 27 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 109
1
2 A I
think the sales continued to increase.
there
a
The
market share continued to decrease.
Q
3
4
Was
reason you chose not to put those
market share
A
statistics in your presentation?
5 6
7
You know,
the
--
you know,
the problem with the
I
market share statistics
is, as
said before, the
bicycle industry doesn't have great numbers.
8 9
It's
last
Q
not
like
the auto industry where you can see
how many Toyota priuses were sold
in
Dane County
10
11
12
month.
It
so
just doesn't have that kind of
I
information,
So
did not put
it
in here.
bikes
then when you said that the market share
LeMond
13
14
statistics with respect to the
decreased through
what were you basing
A
the period 2000 through 2008,
15
16
that testimony
on?
I'd
for
say
I
base
it
on being
a
in the bike business
17 18
19
24 years and having
pretty
good handle
on
our business.
numbers
There are
come
-- there's industry
They're not really good,
that
out.
20 21 22
23 24
A
but generally you can kind of see what's going
on.
Q
Okay.
What are those industry numbers
that
you're relying upon?
It's
called
BPSA,
which
is bicycle products,
a
and
25
we can
kind of get -- get
Gramann Reporting, Ltd.
handle on what's
414.272.7878
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Page 114
1
PTI.
And he never said anything
about
that,
and
2
3 4 5
he said
if
we're ever looking to do anything in
the mass,
he already
I'll
let
you know.
And
all that
time,
knew.
And
that's just another
example
of
6
7
business dealings with Greg,
where he does some
really
good things, but
stuff like that,
in the
it
--
it
8 9
certainly undercuts the confidence
relationship.
Q
10 11
12 13 14 15 16 17
18
That damage
that
you have as
phrase
A
that
you used
is
a
I think the -gut feel to you.
The damage
is
a
gut feel because that's very hard
to quantify.
Because
what's happening
is
retailers
brand
who
have strongly supported the LeMond
-- all right.
There's
a
three blocks away there's
retailer and Target. Well, all
a
Trek
the sudden now Target's selling
$9.99 LeMond
What's
helmets.
going on?
now
And
I
that retailer is going,
19
got to compete with somebody else
same name;
I
20 21
22
selling the
don't like that.
that.
So
all
Q
the sudden he starts buying less LeMond
bikes.
And
It's
hard to quantify
23
I'm
somewhat
sure that you're exaggerating
24
25
with the $9.99 LeMond helmet.
more than
It
was
probably
that.
Gramann Reporting,
Ltd.
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Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 29 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 115
1 2 A
You're-But
I
Q
think what you're trying to point out is
3
4
that they were selling
it for
a
cheaper value
than what would exist in an independent bike
5 6
7 A
dealer shop.
Uhm-uhm.
Yes.
Q
I'm going to direct your attention back to your
8
presentation where you have
And
some
e-mails here.
9
it
says
"Fallout" at the top.
What did you mean by
10
11
"fallout"
there?
A
12 13
Fallout would
MR.
MR.
be what the consequences
of Greg's
actions were to Trek.
WEBER:
14 15
Go
to the prior page.
MADEL:
Yeah.
16
17
18 19
20
BY MR.
Q
MADEL:
The
--
so
-a
and then on
that
first fallout
a
page,
you put in two e-mails
from
--
Trek customer
e-mail and
A
LeMond customer
e-mail, right?
We're on
fallout,
which says
-- starts out
21 22
23
Q
A
"Thanks to Greg's comments"?
Yes.
Yes.
And then you put
24 25
Q
in
two
additional customer
e-mails on the next page that says "Fallout" at
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Videotape Deposition of John Burke, 4/7/2009
Page 118
1 2 3
4 5 A
Do you see
that?
First sentence
of the second paragraph.
I
do.
"No
Q
That last sentence of that paragraph,
whether you believe Mr. Armstrong
why not
matter
doped or not,
a
6
7
position the Trek and
LeMond brand on
higher ground."
Do you see
A I
8 9
that?
do.
10
11
12
Q
"There's no doubting Mr. LeMond's commitment
clean cycling,
and based on
to
his very public
anti-doping stance,
that?"
why doesn't Trek support
13 14
Do you see
A
that?
15 16
I
do.
Q
A
How would you answer
I
that question?
17
would answer that question
that Trek did
18
19
20
support, on numerous occasions, Greg's
anti-doping stance.
I
On many
different
In fact,
I
occasions
told
Greg,
I
don't have an issue of Greg's
encourage
21
22
stance against anti-doping.
it;
Greg
Trek encouraged
it.
his
comments
23
It
-- regarding
was
regarding
24
Lance Armstrong and
specific
25
athletes that Trek objected to.
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Filed 08/05/09 Page 31 of 38
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Page 128
1
are going to come up and say, you know, John
2
3 4 5 A
Burke,
I
thought that that was the most shameful,
my
stupid presentation I've ever seen in
No,
I
life?
dealers
don't think they are because
I
think they
looked at that presentation
had been
--
and those
6
7
living this
I
program.
They've had
coming
a
customers over the
last eight years
into
8 9
the stores saying
LeMond.
And
wouldn't even look at
10 11
12
there they had these small
business people who have invested in the
inventory,
it's sitting
a
there,
and
all
the sudden
Greg
13
14 15
16
they're taking
LeMond,
look and there's ESPN,
"Lance Armstrong threatened my
wife,
a
my
life,
and my
livelihood."
And
there's
We
bicycle
dealer and he's going, "Not again.
through in this in 2001.
Now
went
17
we're going through
18 19
Q
this in 2004.
And these
It
just keeps going on and on."
bike dealers,
they do
independent
20
21 22
23
A
business with you,
They do.
And
right?
Q
they send you money for bikes,
you provide
them with bikes,
A
right?
24
They do.
So
25
Q
they have
a
business relationship
with you,
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Page 151
1
2
Q
A
Yeah.
Yeah.
I
The food's
I
much
better here.
much
3
4 5
Q
A
don't travel
so
--
All right.
Q
--
--
so,
you know,
it's
probably
my
problem.
6 7 8 9
But the
does
granted,
if
you
take --
it
surprise
you that the person
that's the
to his
general manager of Trek's European
minus
division,
the UK,
is criticizing
LeMond due
10
11
12 13
14
A
low sales of LeMond bikes in places
such as
France,
No,
Holland, and Spain?
because that person has gone
-- it's
a
been
a
tough
And
sell, not that person
came
an easy
sell.
It's
tough
sell.
has gone out of his way.
And
15
that e-mail
in after another one of Greg's
Lance Armstrong.
a
16 17
18
comments going
after
And
there
Malcolm is introducing
new
line, getting all
and then he opens
the show samples out, putting together the
catalogs,
up
19
doing
all
this stuff,
20
21
22
23
the newspaper
and here we go
again.
Greg would
Every time we did this,
make
--
Greg would make
a
commitment.
He'd say,
you know what?
I'm not going to talk about Lance
And
24
25
Armstrong
about
anymore.
I'd
say,
great,
and
a
talk
clean
doping
all
you want,
Greg,
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Ltd.
414.272.7878
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 33 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 152
1
2
sport; that's
awesome.
And
he'd say, I'm not going to
3
4 5
talk about Lance Armstrong again.
And then
it
would
come
around Tour
I
de France time,
and then there
it
is.
remember
6 7 8
going to the Tour de France 2000
was
--
I
think
it
right?
2004.
I'm in the Minneapolis airport,
We're taking 100 of our best customers
to France
9
to watch the tour.
There
Lance Armstrong
10
11
12 13
it
is,
ESPN,
breaking news,
-- or
Greg LeMond says Lance
Armstrong
threatened his wife, his
That's all
we
life,
and his
a
livelihood.
week
a
talked about for
We
14
with your
100 top dealers.
talked about
15 16
17 18 19
few other things,
But
too.
it's
it
just kept going
You know,
on
I
and on.
And people
are frustrated.
sat there in 2006, right?
2004 thing,
we came
Once again,
after the
back and we repaired the
I
20
whole thing, right?
we worked
We
put
okay.
my
hand out to Greg,
21
22
it
a
through,
We're back on line.
new
poured
lot of
We
money
into
product
23
development.
carbon
came out
with the most killer
okay?
24
25
fiber bike.
Beautiful,
And what we
said is,
414.272.7878
you know
Gramann Reporting, Ltd.
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 34 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 153
1 2
what?
We're really going to get this thing
And so we
rolling again.
customers.
We
invited
all
these
And
3
4 5
flew them into Milwaukee.
We
I'll
And
never
forget this.
I
were out
at the
resort on Lake --
think
it's
Lake Nagawicka.
we
6 7 8 9
there
we
are out there and
got Greg out
there.
And he and
I
are
I
up on
a
stage and
we're outdoors and we've got like 200 of our or 100 of our best customers.
3
--
10
11
12
mean, our top
percent of our dealers make up 30 percent of
and these are important
guys.
We
our sales,
13
brought them all in for the Trek 100 to introduce
the new LeMonds so they could ride the new stuff.
And
14
15
16
17
18 19
they're all fired up about
is rolling.
Everything's
two weeks
this.
great.
Everything
And then
all the
after
have
sudden,
later,
All
there
it
is right back in the papers, we've got
Lance Armstrong.
Greg LeMond going
20
that energy,
we
all
the money,
a
21 22
23
put in to really
all that stuff that killer line and
like Malcolm,
people
who
selling Greg's stuff.
And so
a
guy
he's
who
a
24 25
representative of
a
lot of
at Trek
put in
wanted this thing to succeed,
lot of
Gramann Reporting, Ltd.
414.272.7878
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 35 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 154
1 2
time and effort.
man,
And
it
was
just kind of like,
that's
what
here we go again.
He sent me
And
that
3
4 5
e-mail is.
that e-mail.
And
it
was
just -Q
But you recognize,
though, too, when we're
on
6
7
looking at, you know, just so far here
Exhibits
138 through 143,
8
there's -- there's a pretty big segment of cyclist enthusiasts out
there that really like anti-doping
stances and
9
10
11
12 13
A
really like
right?
Wrong.
what Greg was saying about Armstrong,
You got to separate
who
those two.
There's
a
lot of people out there
stances,
Q
A
like anti-doping
14
all right?
People want
a
15 16
Yep.
And
I'm one of them.
When you
clean sport.
a
17
18
All right?
then say that there's
lot
of people against Lance Armstrong,
those are different
Q
those are
19
topics.
20 21
22
Well, but -- and
I
understand that you -- you say
done much on behalf
that you're against doping, but, you know, have
you,
you know,
really
of the
23
24
entity for Trek to demonstrate
stance?
A
your anti-doping
25
Well,
I
mean, we've done
--
you know,
if
you take
Gramann Reporting, Ltd.
414.272.7878
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 36 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 155
1 2 3 4 5
a
look,
game
it's
is
the rules of the
you
game.
We
The
rule of
we
the
can't dope.
don't --
don't
take care of the rules of the game.
That's the
UCI.
Q
A
That's their responsibility.
Greg
I
understand.
6
7
Okay.
--
you know, different
people
take on
different causes.
Q
A
8
Uhm-uhm.
9
And Greg's
one of Greg's
One
causes
is
10
11
12
13
anti-doping.
of his causes is
is this
Every
was,
absolute consumption of Lance Armstrong.
time
Greg,
we
talked about doping with Greg,
it
talk
about anti-doping as much as you want,
go out there and do,
14
promote
Q
it,
that's great.
15
16
17 18
Did -- did you ever talk to Greg about what Lance Armstrong had said to him in terms of threatening
him by
getting ten people together that said that
Greg used EPO?
A
19 20 21 22
23
No.
Q
All right.
Greg LeMond
Did you
--
you obviously knew
that
considered Lance Armstrong
to have
cheated when he won the Tour de France?
A
Yes.
He
24 25
Q
A
told
you
that
on numerous
occasions?
Yes.
Gramann Reporting,
Ltd.
414.272.7878
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 37 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 156
1 2 3
4 A
Q
Did you ever ask Greg
LeMond
to sign
a
statement
saying that he believed that Lance Armstrong had
never taken any performance-enhancing drugs?
I
do not
--
I
think
you might be
referring to the
a
5 6 7 8 9
2001 retraction, and
I'd
have
to take
look at
it.
MR.
WEBER:
Before
we
-- before
we so
get
into that, we've been going another hour,
let's take
examples.
a
break.
MADEL:
Oh,
10
11
12
13
14
MR.
that's
one of those
Yes.
VIDEO TECHNICIAN:
This is the end of
Videotape No.3.
2:04 p.m.
(A
We're going
off the
record
at
15
recess was taken.)
TECHNICIAN:
4
16
VIDEO
This is the
17
18
beginning of Videotape No.
in the continuing
are back on the
deposition of John Burke.
record at 2:20 p.m.
We
19 20 21 22 23
24
(Exhibit
145 was marked
for
identification.
BY MR.
Q
A
)
MADEL:
Mr. Burke, what's Exhibit
145?
Exhibit
145 is an
e-mail to TrekBikes.com from
25
Steve Hansen.
Gramann Reporting, Ltd.
414.272.7878
Case 0:08-cv-01010-RHK-JSM Document 139-5
Filed 08/05/09 Page 38 of 38
Videotape Deposition of John Burke, 4/7/2009
Page 185
1 2
statements the communications
from Armstrong and Stapleton?
A
that you'd received
3
4 5
No.
I
think
it
was
was
a
a
combination of
a
lot of
a
things.
Trek
It
combination of
my own
disappointment.
It
was
a
combination of
and
lot of
6
7
retailers calling Trek,
calling.
you
it
was
Armstrong
and Stapleton
Q
8 9
Do
you
recall
telling
Mr.
LeMond when you
you were
called him on this that the reason that
10
calling him
A
was because
of pressure you were
11
12
13
receiving from Armstrong and Stapleton?
You know,
11m sure
I
that
a
was one
of --
one of the
I
reasons.
was
was
a
in
very
difficult situation.
14
15
in between
a
three-time winner of the tour
in the middle to be the
was
a
and
most famous cyclist in the world at that
And
I
16
time.
was put
17
18
19
Q
peacemaker,
and
that
tough position to be
in.
I
think
you described
yourself
at the time that
20 21 22 23
24
A
you were
trying to be Henry Kissinger there.
I
You know,
tried
and
as hard as
was
I
could to be Henry
I
Kissinger,
it
not
and
think,
as
I
remarked on that phone
taped
call, which
Greg LeMond
later told
me
that the reason
it
was
25
taped was because his answering machine
was
Gramann Reporting, Ltd.
414.272.7878
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