LeMond Cycling, Inc. v. Trek Bicycle Corporation

Filing 148

Case 0:08-cv-01010-RHK-JSM Document 148-3
LeMond Cycling, Inc. v. Trek Bicycle Corporation

Filed 08/13/09 Page 1 of 4
Doc. 148 Att. 2

Exhibit 79

Dockets.Justia.com

Case 0:08-cv-01010-RHK-JSM Document 148-3

Filed 08/13/09 Page 2 of 4

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

LEMOND CYCLING, INC., vs * Plaintiff, Civil No. 08-1010

TREK BICYCLE CORPORATION, Defendant vs. GREG LEMOND, Third-party Defendant.
&

Third-party Plaintiff,

CERTIFIED COPY

VIDEOTAPED DEPOSITION OF WARREN GIBSON DATE: TIME: LOCATION: Tuesday, March 17, 2009

9:04 a.m.
THE TOLL HOUSE HOTEL 140 South Santa Cruz Avenue Santa Cruz Room Los Gatos, CA 95030 AUDREY KOLTERER, CSR NO. 11875

REPORTED BY: #32982

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Q-Reporting Q

I083 Lincoln Avenue, San Jose, California 95125, Telephone [phone], Fax [phone]

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Case 0:08-cv-01010-RHK-JSM Document 148-3

Filed 08/13/09 Page 3 of 4

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A.

No, I don't. Would it surprise you if there are no
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records of such

or very few records of such people

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actually contacting Trek directly? MR. TOBIN: MS. RAHNE: THE WITNESS: MR. TOBIN: THE WITNESS: Which one is it, very few? Very few.

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I could not tell you that.
That's your answer. I could not tell you that. Mr. Gibson, so you have - - it

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Q.

BY MS. RAHNE:

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sounds like you have a lot of knowledge of purchases that you were involved in, correct? A. That ' s correct, yes. Isn't it true that you don't - - do not have

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actual knowledge of what payments were made to Trek from LeMond Cycling ultimately for the bikes? A. Trek.

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I don't - - I don't know what was paid to
And you don't know if there was any

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discrepancy, what the purpose of the discrepancy was? I don't know.
So it could have been overhead built in or it

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internally A.

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could have been some other cost that was built in

- - internally?
I don't.

You don't know that, right?

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DEPOSITION OF WARREN GIBSON
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Case 0:08-cv-01010-RHK-JSM Document 148-3

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MR. WEBER: question.

Object to the form of the

Calls for speculation. BY MS. RAHNE: I'm just asking whether you

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know. A.

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I don't know. Mr. Gibson, did you meet with anybody in

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preparation for this deposition? Yes. And who did you meet with? I met with my attorney Bob Tobin, Mr. Weber,

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Mr. Burns?
- - Mr. Burns, yes.

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How many meetings were there in preparation

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for this deposition? One. And when did that meeting occur? Yesterday. And who was at that meeting? Three individuals I just named. Were there any other meetings prior to coming

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into this room for this deposition? No. Did you by chance have breakfast with

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Mr. Weber this morning?

DEPOSITION OF WARREN GIBSON
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