Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4595 Page 1 of 224
`
` IN THE UNITED STATES DISTRICT COURT
`
` FOR THE SOUTHERN DISTRICT OF CALIFORNIA
`
`UNITED STATES, :
` :
` Plaintiff :
` :
` vs. : NO. 18-cr-4683-GPC
` :
`JACOB BYCHAK, et al., :
` :
` Defendants :
`
` VIDEOTAPED TRIAL DEPOSITION OF STEPHEN A. DORN
`
` Taken in the Edward N. Cahn U.S.
`
`Courthouse & Federal Building, Conference Room 3600,
`
`504 West Hamilton Street, Allentown, Pennsylvania,
`
`on Wednesday, September 15, 2021, commencing at
`
`10:34 a.m., before Steven R. Mack, Registered Merit
`
`Reporter, and Bill Heilman, Videographer.
`
` * * *
` GALLAGHER REPORTING & VIDEO, LLC
` Mill Run Office Center
` 1275 Glenlivet Drive, Suite 100
` Allentown, PA 18106
` (610)439-0504 / (800)366-2980
` GallagherReporting@Verizon.net
`
`
`
` IN THE UNITED STATES DISTRICT COURT
`
` FOR THE SOUTHERN DISTRICT OF CALIFORNIA
`
`UNITED STATES, :
` :
` Plaintiff :
` :
` vs. : NO. 18-cr-4683-GPC
` :
`JACOB BYCHAK, et al., :
` :
` Defendants :
`
` VIDEOTAPED TRIAL DEPOSITION OF STEPHEN A. DORN
`
` Taken in the Edward N. Cahn U.S.
`
`Courthouse & Federal Building, Conference Room 3600,
`
`504 West Hamilton Street, Allentown, Pennsylvania,
`
`on Wednesday, September 15, 2021, commencing at
`
`10:34 a.m., before Steven R. Mack, Registered Merit
`
`Reporter, and Bill Heilman, Videographer.
`
` * * *
` GALLAGHER REPORTING & VIDEO, LLC
` Mill Run Office Center
` 1275 Glenlivet Drive, Suite 100
` Allentown, PA 18106
` (610)439-0504 / (800)366-2980
` GallagherReporting@Verizon.net
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4596 Page 2 of 224
`
`2
`
`APPEARANCES:
`
` U.S. DEPARTMENT OF JUSTICE
` CRIMINAL DIVISION
` By: CANDINA S. HEATH, ESQ.
` 1301 New York Avenue NW
` John C. Keeney Building
` Washington, DC 20530
` candina.heath2@usdoj.gov
` -- For the Plaintiff
`
` WIECHERT, MUNK & GOLDSTEIN, PC
` By: JESSICA C. MUNK, ESQ.
` 27136 Paseo Espada
` Suite B1123
` San Juan Capistrano, CA 92675
` jessica@wmgattorneys.com
` -- For Defendant Jacob Bychak
`
` MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND
` POPEO, P.C.
` By: RANDY K. JONES, ESQ.
` MARK J. GOODRICH, ESQ.
` 3580 Carmel Mountain Road
` Suite 300
` San Diego, CA 92130
` rkjones@mintz.com
` -- For Defendant Mark Manoogian
`
` BIRD, MARELLA, BOXER, WOLPERT, NESSIM,
` DROOKS, LINCENBERG & RHOW, P.C.
` By: NICOLE R. VAN DYK, ESQ.
` 1875 Century Park East, 23rd Floor
` Los Angeles, CA 90067-2561
` nvandyk@birdmarella.com
` -- For Defendant Peter Pacas
`
` * * *
` GALLAGHER REPORTING & VIDEO, LLC
` Mill Run Office Center
` 1275 Glenlivet Drive, Suite 100
` Allentown, PA 18106
` (610)439-0504 / (800)366-2980
`
` GallagherReporting@Verizon.net
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4597 Page 3 of 224
`
`3
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`APPEARANCES: (CONT'D.)
`
` BIENERT KATZMAN LITTRELL WILLIAMS, LLP
` By: CARLOS A. NEVAREZ, ESQ.
` 601 West 5th Street
` Suite 720
` Los Angeles, CA 90071
` cnevarez@bklwlaw.com
` -- For Defendant Mohammed Abdul Qayyum
`
`ALSO PRESENT:
`
` Andy Stengel, FBI agent
`
`ALSO PRESENT REMOTELY:
`
` Melanie Pierson, Esq.
` Sabrina Feve, Esq.
` Ryan T. Dougherty, Esq.
` Darren L. Patrick, Esq.
` James D. Riddet, Esq.
` Ray Christenson, IT
` Dominick Bellizzie, IT
`
` * * *
`
` GALLAGHER REPORTING & VIDEO, LLC
`
` Mill Run Office Center
`
` 1275 Glenlivet Drive, Suite 100
`
` Allentown, PA 18106
`
` (610)439-0504 / (800)366-2980
`
` GallagherReporting@Verizon.net
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4598 Page 4 of 224
`
`4
`
` INDEX TO WITNESSES
`
`STEPHEN A. DORN
`
` By Ms. Heath (Direct) 13
` By Mr. Jones (Cross) 62
` By Ms. Munk (Cross) 167
` By Ms. Heath (Redirect) 168
` By Mr. Jones (Recross) 172
` By Ms. Heath (Redirect) 175
`
` INDEX TO GOVERNMENT EXHIBITS
`
` Exhibit 6 Registration information for 55
` class B address of 167.87.0.0
`
` Exhibit 40 Authorization to 44
` Announce/Re-Announce IP
` address dated 6/28/13
`
` Exhibit 190 Color photograph of a man 50
`
` Exhibit 191 Color photograph of a man 50
`
` Exhibit 192 Color photograph of a man 50
`
` Exhibit 193 Color photograph of a man 50
`
` Exhibit 194 Color photograph of a man 50
`
` Exhibit 195 Color photograph of a man 50
`
` Exhibit 196 Fax dated 5/13/93 from 16
` Stephen A. Dorn and
` Application for Internet
` Network Number
`
` Exhibit 197 Letter from Network Solutions 24
` dated 5/17/93
`
` Exhibit 198 Stephen A. Dorn's Siemens 42
`
` business card
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4599 Page 5 of 224
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`5
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` INDEX TO GOVERNMENT EXHIBITS (CONT'D.)
`
` Exhibit 208 Photocopy of driver's license 53
` of Stephen A. Dorn for two
` time periods
`
` Exhibit 209 Document with the subject: 58
` Hijacked ARIN Legacy block -
` Moore Products Co.
`
` Exhibit 211 RIPE Database query service 59
` for IP 167.87.0.0.
`
` INDEX TO DEFENDANT'S EXHIBITS
`
` Exhibit A Email dated 5/20/21 from 87
` Steve Dorn to Glenn Booth
`
` Exhibit B Email dated 5/31/21 from 103
` Steve Dorn to Glenn Booth
`
` Exhibit C Emails dated 6/6/21 and 118
` 6/8/21 between Steve Dorn and
` Glenn Booth
`
`
`
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`13
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` (The witness was duly sworn.)
`
` DIRECT EXAMINATION
`
`BY MS. HEATH:
`
`Q. Please state your name for the record,
`
`your full name.
`
`A. Stephen Alan Dorn.
`
`Q. And do you reside in or around the
`
`Allentown, Pennsylvania, area?
`
`A. I resi -- yes.
`
`Q. Are you married?
`
`A. Yes.
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`Q. How long?
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`A. I can't remember. It's 15, 16 years,
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`something like that.
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`Q. Any children?
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`A. No.
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`Q. Are you currently employed?
`
`A. No.
`
`Q. And are you retired?
`
`A. Yes.
`
`Q. How long have you been retired?
`
`A. Since 2007.
`
`Q. And what type of occupation did you have
`
`prior to retiring?
`
`A. I was a manager of computer networks and
`
`operations for a company called Moore Products
`
`Company since 1975. And in the year 2000 Siemens
`
`purchased our company, and I worked for Siemens up
`
`until the year 2006 as --
`
`Q. And what --
`
`A. -- as a computer -- manager of computer
`
`networks and operations was my title.
`
`Q. And approximately when did you retire?
`
`A. The last time I worked was in Janu --
`
`January 2007.
`
`Q. And are you testifying today in response
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4609 Page 15 of 224
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`to a subpoena you received from the Government?
`
`A. Yes, I am.
`
`Q. Are you on any medications at this time
`
`that would impair your ability to testify?
`
`A. No, I am not.
`
`Q. And have you received any promises or
`
`benefits from the Government in exchange for your
`
`testimony?
`
`A. No.
`
`Q. Could you tell a little bit about your
`
`educational background.
`
`A. I have a four-year degree from Albright
`
`College in mathematics and -- and went to work in
`
`1975 --
`
`Q. And you said --
`
`A. -- after I graduated.
`
`Q. -- you worked in the IT field?
`
`A. Correct.
`
`Q. Did you receive various trainings along
`
`the way?
`
`A. Yes. A lot of it was self-training, and
`
`then there were some courses that I took through the
`
`company sending me off to training courses.
`
`Q. And you indicated that you started with
`
`Moore Products in 1975; is that correct?
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4610 Page 16 of 224
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`A. Correct.
`
`Q. Let me turn your attention to 1993.
`
`Were you employed at Moore Products at that time?
`
`A. Yes.
`
`Q. And what was your title in 1993?
`
`A. I think -- can I look in the paperwork
`
`here?
`
`Q. Are you needing to refresh your
`
`recollection --
`
`A. Yes.
`
`Q. -- with a document?
`
`A. Yes.
`
`Q. Which document would assist you in
`
`refreshing your recollection? If you go to
`
`Exhibit 196?
`
`A. Yes. In Exhibit 196, yes.
`
`Q. And does -- was Exhibit 196 something
`
`prepared by you back in 1993?
`
`A. Yes.
`
`Q. And does it have an indication in there
`
`as to what your title was at that time?
`
`A. Yes.
`
`Q. And what was your title at that time?
`
`A. Stephen A. Dorn, supervisor of technical
`
`services and computer operations.
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4611 Page 17 of 224
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`Q. Give us a little background or tell us a
`
`little bit about what Moore Products did,
`
`specifically focused in 1993.
`
`A. We were a manufacturer of industrial
`
`controls. And we were based out of Pennsylvania but
`
`had sales offices throughout the United States and
`
`also international locations in Canada and England.
`
`We had some sales offices and locations in Australia
`
`and Singapore, and -- that's about as much as I can
`
`remember from there.
`
`Q. Do you have any idea as to how many
`
`people were employed by Moore Products at that time?
`
`A. To the best of my recollection, I'd say
`
`around 1200 worldwide.
`
`Q. In 1993 did you have internet
`
`connectivity?
`
`A. No.
`
`Q. Were you able to communicate with other
`
`individuals by email?
`
`A. Within our office, yes.
`
`Q. And how was that?
`
`A. How was that?
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4612 Page 18 of 224
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`Q. Yeah, how did that happen?
`
`A. We had a mainframe computer running
`
`manufacturing software. People that had the ability
`
`to sign in via a dumb terminal could have an email
`
`account, and they could just email themselves
`
`locally. We had no external communications.
`
`Q. And what is a dumb terminal?
`
`A. It's -- it's just something you can go
`
`up, and it just has a display and a keyboard; and
`
`you can hit the return button, and it comes up, and
`
`it says give me your user name and password. You
`
`need to sign in, and it connects you to the
`
`mainframe computer. There's no -- there's no
`
`personal computer or any of that kind of stuff.
`
`Q. In order to communicate with one another
`
`were there IP addresses needed? At that time.
`
`A. At the time our email was done via a
`
`communications to a mainframe. So everybody logged
`
`in to the mainframe and they were on their own
`
`private network, and they could communicate, but all
`
`the mail was stored on the mainframe.
`
`Q. Was that sufficient for Moore Products
`
`to continue to operate in 1993?
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4613 Page 19 of 224
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`19
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`A. No.
`
`Q.
`
` You said that your company was
`
`able to communicate with one another through the
`
`mainframe.
`
`A. Correct.
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`Q. Was that sufficient to continue to
`
`operate and grow as you've mentioned?
`
`A. No.
`
`Q. What did Moore Products need to do at
`
`that point?
`
`A. Moore Products needed to grow.
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`Q.
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`Let me refer you to Government's
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`Exhibit 196. Do you recognize that?
`
`A.
`
`Q.
`
`A.
`
`Yes.
`
`And what is that?
`
`This is an application that myself and
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`my boss wrote for a network address registration so
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`that our internal network could get attached to the
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`growing and the new -- newly infantile internet as
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`we know it today.
`
`Q.
`
`And this is a document you prepared
`
`along with your boss?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`Yes.
`
`And who was your boss at that time?
`
`His name was Jeffrey Richards.
`
`And was it -- why was it necessary to
`
`make an application for this, for IP addresses?
`
`A.
`
`A.
`
`At the time we were --
`
`At the time we were -- had our own
`
`internal network, and all these devices that we were
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`adding and the personal computers, all the other
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`devices, we were now at a point where we had
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`exceeded the amount of IP addresses that we could --
`
`which is 255, which we could use in our own private
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4616 Page 22 of 224
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`22
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`network. Plus we were going to be attaching all
`the sales offices around the country, around the
`world onto the internet.
`In doing so, we needed to increase the amount of
`IP -- TCP/IP addresses that we had, and in order
`to do this we applied to Network Solutions, which
`was the registration services at the time in
`1993, for a class B, as in baker, IP address
`network.
`Q. And what is a class B IP network?
`A. A class B IP address network is one that
`could give you up to -- it's roughly 65,000 IP
`addresses that you could use to grow your company
`with.
`Q. What did you have prior to applying for a
`class B internet network?
`A. We had a non-routable class C address. A
`class C address is a -- an address structure of
`such that you can have 255 network devices
`attached to one network; and everybody could know
`who everybody else is, and they could route
`information back and forth and also communicate
`thusly. I'll call it like this: A class C address
`is -- is 255 people living in their own
`community and being able to communicate with
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4617 Page 23 of 224
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`everybody.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4618 Page 24 of 224
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`Q. Were you able to obtain a class B
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`network number?
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`A. Yes.
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`Q. Let me refer you to Government's
`
`Exhibit 197.
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`A. Okay.
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`Q. Do you recognize that document?
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`A. Yes.
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`Q. And what is that document?
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`A. A document that we -- was sent from
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`Network Solutions in response to our application
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`that we had just sent them a few days before. And
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`it says that --
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`Q. Well, before you read from it, is this
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`something that you received from Network Solutions?
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`A. Yes. The date is 17 May,
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`nineteen-nine -- 1993 up at the top.
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`Q. And was Government's Exhibit 196 and
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`197, were they documents kept in your control or
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`your custody during your time at Moore Products?
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`A. Yes.
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`Q. And are these true and correct documents
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`from Moore Products?
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`A. Yes.
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` MR. JONES: Objection.
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` MS. HEATH: Is there --
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` MR. JONES: They're not documents
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`from Moore Products, but objection, lack of
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`foundation.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4620 Page 26 of 224
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`BY MS. HEATH:
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`Q. Let me ask it this way: Was
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`Government's Exhibit 196 and 197 documents prepared
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`and used in the ordinary course of business at Moore
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`Products?
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`A. The documents in question were documents
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`for submission to Network Solutions for a class B IP
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`address string. I had to fill out the questions
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`that were required by Network Solutions in order to
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`solicit them for a network -- a class B network.
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` In response to the -- in response
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`to my application, and I say my -- our -- from Moore
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`Products Company, we were granted a class B IP
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`address network from the company called Network
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4621 Page 27 of 224
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`Solutions, which at the time was in charge of
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`internet registration.
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` In response to the application, on
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`the -- on a letter of May 17th, 1993, I received
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`from Network Solution -- and when I say I, and Moore
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`Products Company, received this letter stating that
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`we have been granted a class B IP address network.
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`Q. Mr. Dorn, I -- I appreciate the
`
`explanation, and that helps clarify Government's
`
`Exhibits 196 and 197. Did Government's Exhibits 196
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`and 197, were they maintained in the ordinary course
`
`of business of Moore Products?
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` MR. JONES: Objection.
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` MS. VAN DYK: Objection: lacks
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`foundation.
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` MR. JONES: In particular to 197.
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` MS. VAN DYK: And compound.
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`A. These documents were kept at Moore
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`Products Company and shared with everybody, the
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`network administrators throughout the rest of the
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`organization, stating the fact that we were granted
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`a class B IP address
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` MR. JONES: Move to strike as
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`
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4622 Page 28 of 224
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`28
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`nonresponsive and lack of foundation as to 197.
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`BY MS. HEATH:
`
`Q. And in your position at Moore Products
`
`you were able to maintain care, custody, and control
`
`over Government's Exhibits 196 and 197, correct?
`
`A. These documents were sent to Moore
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`Products Company and maintained and stored in filing
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`cabinets at Moore Products Company.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4623 Page 29 of 224
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` MS. HEATH: The Government offers
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`Government's Exhibits 196 and 197 into evidence.
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` MR. JONES: Objection: lack of
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`foundation with respect to 197 in particular,
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`compound, and lack of personal knowledge.
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` MS. MUNK: And hearsay.
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`Q. Mr. Dorn, let me refer you to
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`Government's Exhibit 196. What was the date of the
`
`application for the class B internet address network
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`number?
`
`A. May 13th, 1993.
`
`Q. And you were the sender on this
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`document; is that correct?
`
`A. Yes.
`
`Q. Your name appears as Stephen A. Dorn.
`
`Is that how you would normally refer to yourself?
`
`A. Yes. Professionally that's how I would
`
`sign all my documents.
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`Q. And on the first page of Government's
`
`Exhibit 196 it has your name with the title
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`"Supervisor, Technical Services & Computer
`
`
`
`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4624 Page 30 of 224
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`30
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`Operations," correct?
`
`A. Correct.
`
`Q. Was that your title at that time?
`
`A. Yes.
`
`Q. On page 2 of the document, it appears to
`
`be addressed to Network Solutions. Is that correct?
`
`A. Correct.
`
`Q. And what was Network Solutions?
`
`A. Network Solutions was the organization
`
`at that time that was responsible for all internet
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`addresses maintained and assigned. So we need to --
`
`we needed to fill out the questionnaire as we did
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`here on all -- all of these, which there's eight
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`questions that needed to be answered and submitted
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`to Network Solutions in order to solicit them and
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`get an IP address registered to Moore Products
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`Company.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4625 Page 31 of 224
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`31
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`Q. No. 2: It says "no nic handle at this
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`time." What does that mean?
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`A. A NIC handle to the best of my ability
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`was the fact that we didn't have anybody registered
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`with Net -- Network Solutions as a -- like a user ID
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`would be today. None of us within Moore Products
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`Company had a NIC handle.
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`Q. And your name is the only name that
`
`appears on this in answer to the question No. 2,
`
`correct?
`
`A. Correct.
`
`Q. You indicate the address for Moore
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`Products Company that -- Sumneytown Pike; is that
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`correct?
`
`A. Yes. S-u-m-n-e-y-t-o-w-n.
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`Q. Okay. And that's Spring House,
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4626 Page 32 of 224
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`32
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`Pennsylvania?
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`A. Correct.
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`Q. There's a network mailbox. Is that the
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`network that you discussed earlier as far as the
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`addressing system for Moore Products?
`
`A. The network mailbox --
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`A. The network mailbox SMTP, percent sign,
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`quote, DORNSA@MPCDP3, end quote, that was the
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`mainframe email and was not connected out to the
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`outside world whatsoever. That was just our
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`internal email.
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`Q. Okay.
`
`Q. The Network Name Recommendation is
`
`"mpco.com." Do you see that?
`
`A. Correct.
`
`Q. What was that for?
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4627 Page 33 of 224
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`33
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`A. They needed a network name, and at the
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`time we thought it was the best thing to see; MPCO
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`standing for Moore Products Company.
`
`Q. And let me refer you to Government's
`
`Exhibit 197. And what was the date that you
`
`actually received the class B network number?
`
`A. 17 May, 1993.
`
`Q. Is that the date on the top of the
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`Government's Exhibit 197?
`
`A. Correct.
`
`Q. Is it addressed to you?
`
`A. Yes.
`
`Q. What was the network number that you
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`were given?
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4628 Page 34 of 224
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`34
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`A. 167.87.0.0.
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`Q. And how many numbers did you receive in
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`this network?
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`A. Again, it's roughly 65,000.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4629 Page 35 of 224
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4630 Page 36 of 224
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4631 Page 37 of 224
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`37
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`Q. Was the acquisition of a class B network
`
`system important for your company?
`
`A. Yes.
`
` MS. MUNK: Object: vague.
`
` MS. VAN DYK: Objection: vague.
`
` MR. JONES: Asked and answered.
`
`Q. And why was that?
`
` MR. JONES: Objection: relevance,
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`asked and answered.
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` MS. VAN DYK: Vague and personal
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`knowledge and lacks foundation.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4632 Page 38 of 224
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`A. A class B network address was necessary
`
`in order for our company to grow and be successful
`
`and compete in the -- in the world of process
`
`controls. It allowed us to put our sales offices in
`
`remote locations online and allowed them to
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`communicate to the internet directly.
`
` MR. JONES: Move to strike as
`
`nonresponsive.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4633 Page 39 of 224
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`39
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`Q. The assignment of the class B network
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`number 167.87.0.0 through 167.87.255.255, was that
`
`internet range allowed to be used by any other
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`company or any other individual?
`
` MR. JONES: Objection: lack of
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`foundation, misstates the evidence contained on 197,
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`is vague, lack of personal knowledge.
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` MS. VAN DYK: Calls for a legal
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`conclusion.
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`A. The document that we see here was a
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`document from Network Solutions that assigned the
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`class B IP address network of 167.87 to Moore
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`Products Company and Moore Products Company alone.
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` MR. NEVAREZ: Strike as
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`nonresponsive.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4634 Page 40 of 224
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`40
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`Q. You mentioned that in 2000 the Siemen
`
`Corporation acquired Moore Products; is that
`
`correct?
`
`A. In the year 2000 Siemens purchased Moore
`
`Products Company.
`
`Q. And were you still working at Moore
`
`Products Company at that time?
`
`A. Correct, yes.
`
`Q. What was your title at the time of the
`
`Siemens Corporation acquisition?
`
`A. Manager of computer operations and
`
`networks.
`
`Q. And what did that job entail?
`
`A. It entailed maintaining our global
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`network, as well as our internal network at the
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`corporate headquarters, and all of the operations on
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`a day-to-day basis of our manufacturing computer
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4635 Page 41 of 224
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`41
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`software that ran the business.
`
`Q. When Siemens Corporation acquired Moore
`
`Products, did your title change?
`
`A. No. I -- I still remained computer --
`
`manager of computer operations and networks,
`
`networks and operations.
`
`Q. And what became of the title of the
`
`company Moore Products?
`
`A. Due to the fact that Siemens purchased
`
`Moore Products, the name of Moore Products and all
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`the assets thereof of Moore Products Company were
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`purchased and assumed by Siemens,
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` MR. JONES: Objection: lack of
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`foundation, lack of personal knowledge, calls for
`
`speculation, and vague.
`
` MS. VAN DYK: And nonresponsive.
`
`Q. How long did you work for Siemens
`
`Corporation?
`
`A. Until 2006.
`
`Q. And with regard to the transition, was
`
`there any change of location, change of business as
`
`far as your personal day-to-day involvement?
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4636 Page 42 of 224
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`42
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`A. Everything -- everything was changing.
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`We got assimilated into their network. There was a
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`project that had us go through and re-address our
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`entire network in order to fit into the now Siemens
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`network.
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` And day-to-day operations? A lot
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`were the same and some were different because of
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`Siemens now owned us, so we played by the rules that
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`Siemens dictated to us.
`
`Q. Let me show you Government's
`
`Exhibit 198. And what is -- do you recognize
`
`Government's Exhibit 198?
`
`A. Yes. That is my business card.
`
`Q. Is that a business card from the time
`
`that you were working for Siemens?
`
`A. Yes.
`
`Q. And is that a business card that you --
`
`you used on a daily basis for the business?
`
`A. Yes.
`
`Q. Is everything on that card true and
`
`correct? And I know it has been redacted, but
`
`everything that shows on the card, is that true and
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`correct?
`
`A. Yes.
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4637 Page 43 of 224
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` MS. HEATH: The Government offers
`
`Government's Exhibit 198 into evidence.
`
`Q. Now, how long did you work for Siemens?
`
`A. Until the year 2006.
`
`Q. And was this business card accurate from
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`2000 when you were acquired -- or Moore Products was
`
`acquired by Siemens to the time that you ended your
`
`involvement with Siemens?
`
`A. Yes.
`
`Q. Now, the address remains the same on
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`this: the Sumneytown Pike in Spring House,
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`Pennsylvania; is that correct?
`
`A. Correct.
`
`Q. That the -- the name is the same as we
`
`saw on the previous document: Stephen A. Dorn; is
`
`that correct?
`
`A. Correct.
`
`Q. And the title provided on the document,
`
`is that the title that you had while working for
`
`Siemens?
`
`A. Yes.
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`Q. You have an email address on there:
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`Case 3:18-cr-04683-GPC Document 351-2 Filed 03/24/22 PageID.4638 Page 44 of 224
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`steve.dorn@sea.siemens.com. Was that your email
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`address at the time?
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`A. Yes.
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`Q. Now, the SEA before Siemens, what did
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`that stand for?
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`A. Siemens Energy & Automation. It's like
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`a division of -- Siemens is so large that they have
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`different divisions.
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`Q. Now, after the Siemens acquisition of
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`Moore Products, was there any part of Moore Products
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`that continued on separately from Siemens?
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`A. No. Everything that was owned by Moore
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`Products Company was purchased by Siemens.
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` MS. VAN DYK: Move to strike as
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`nonresponsive, and lacks personal knowledge, lacks
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`foundation.
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`Q. Let me refer you to Government's Exhibit
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`No. 40. Do you recognize that exhibit?
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`A.
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