PATENT OWNER
`PATENT OWNER
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`EXHIBIT 2022
`EXHIBIT 2022
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`PATENT OWNER
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`EXHIBIT 2022
`EXHIBIT 2022
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` 1
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`Harker - Depo 0503amer
`
` 1
`
` 2 IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
` 3 CASE NO. 2:07-CV-271-TJW-CE
`
` 4
` AMERANTH, INC.,
` 5
` Plaintiff,
` 6
` vs.
` 7
` MENUSOFT SYSTEMS, CORP., et als.,
` 8
` Defendants.
` 9 ------------------------------------------
`
` 10
`
` 11 TRANSCRIPT OF
` VIDEOTAPED DEPOSITION OF JOHN V. HARKER
` 12
`
` 13
`
` 14 TRANSCRIPT of the stenographic
`
` 15 notes of the proceedings in the
`
` 16 above-entitled matter, as taken by and
`
` 17 before TAB PREWETT, a Registered
`
` 18 Professional Reporter, a Certified
`
` 19 Shorthand Reporter, a Certified LiveNote
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` 20 Reporter, and Notary Public, held at the
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` 21 Offices of LOCKE, LORD, BISSELL & LIDDELL,
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` 22 LLP, 3 World Financial Center, New York,
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` 23 New York 10281-2101, on Monday, May 3,
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`Page 1
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`Harker - Depo 0503amer
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` 24 2010, commencing at 12:30 p.m.
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` 25
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`
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` 2
`
` 1
`
` 2 A P P E A R A N C E S:
`
` 3
`
` 4
` LOCKE, LORD,
` 5 BISSELL & LIDDELL, LLP
` BY: JOHN W. OSBORNE, ESQ.
` 6 3 World Financial Center
` New York, New York 1028-2101
` 7 Attorneys for the Plaintiff
`
` 8
`
` 9
` FULBRIGHT & JAWORSKI, L.L.P.
` 10 BY: MARC L. DELFLACHE, ESQ.
` 2200 Ross Avenue, Suite 2800
` 11 Dallas, Texas 75201-2784
` Attorneys for the Defendants
` 12
`
` 13
`
` 14
` ALSO PRESENT:
` 15
` Ilitch Peters, Videographer
` 16
`
` 17
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` 18
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`Harker - Depo 0503amer
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
`
` 3
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` 1 John V. Harker
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` 2 P R O C E E D I N G S
`
` 3 THE VIDEOGRAPHER: This is tape
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` 4 number one of the videotaped
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` 5 deposition of Mr. John V. Harker in
`
` 6 the matter of Ameranth, Incorporated,
`
` 7 plaintiff, versus Menusoft Systems
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` 8 Corporation, et al., defendants, in
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` 9 the United States District Court for
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` 10 the Eastern District of Texas, case
`
` 11 number 2:07-CV-271-TJW-CE.
`
` 12 This deposition is being held
`
` 13 at firm Locke, Lord, Bissell &
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` 14 Liddell, 3 World Financial Center, on
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` 15 May 3rd, 2010, at approximately
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` 16 12:33 p.m. My name is Ilitch Peters
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` 17 from the firm of Elisa Dreier
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`Page 3
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`Harker - Depo 0503amer
` 18 Reporting Corporation, and I am the
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` 19 legal video specialist. The court
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` 20 reporter is Tab Prewett in association
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` 21 with Elisa Dreier Reporting
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` 22 Corporation, located at 950 Third
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` 23 Avenue, New York, New York. For the
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` 24 record will counsel please introduce
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` 25 themselves.
`
` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
`
` 4
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` 1 John V. Harker
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` 2 MR. OSBORNE: John Osborne,
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` 3 from Locke Lord, for plaintiff
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` 4 Ameranth.
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` 5 MR. DELFLACHE: Marc Delflache
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` 6 from Fulbright & Jaworski for the
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` 7 defendants.
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` 8 THE VIDEOGRAPHER: Now, will
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` 9 the court reporter please swear in the
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` 10 witness.
`
` 11 J O H N V. H A R K E R,
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` 12 residing at 72 Colonel Enoch Drive,
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` 13 Carmel, New York 10512,
`
` 14 DIRECT EXAMINATION BY MR. DELFLACHE:
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`Page 4
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`Harker - Depo 0503amer
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` 15 Q Good morning, Mr. Harker.
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` 16 A Good morning.
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` 17 Q Is that how you pronounce your
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` 18 name, Harker?
`
` 19 A Yes.
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` 20 Q Give us your current address.
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` 21 A I am at 72 Colonel Enoch Drive,
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` 22 Carmel, New York 10512. I have been there
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` 23 for the last eight years.
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` 24 Q Have you ever had your
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` 25 deposition taken before?
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 5
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` 1 John V. Harker
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` 2 A Never.
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` 3 Q All right. Well, each of the
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` 4 lawyers here will ask you a question; and,
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` 5 if you would pause a second before you
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` 6 answer to make sure I am finished with the
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` 7 question, then I will show you the same
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` 8 courtesy. That way we won't be stepping on
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` 9 each other's responses.
`
` 10 A Okay.
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`Page 5
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`Harker - Depo 0503amer
` 11 Q What did you do to prepare for
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` 12 your deposition today?
`
` 13 A Really not much. I mean, I
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` 14 work for a new company now. I did a lot of
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` 15 work over the weekend out in the yard and
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` 16 getting myself prepared for my Monday
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` 17 morning executive meetings where I am now.
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` 18 Q Do you understand that you are
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` 19 being represented by Mr. Osborne?
`
` 20 A Yes, I am.
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` 21 Q Did Mr. Osborne speak with you
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` 22 before the deposition today?
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` 23 A We corresponded about the
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` 24 deposition. I told him I would be willing
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` 25 to do it.
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 1 John V. Harker
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` 2 Q Did you visit with him over the
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` 3 phone?
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` 4 A Over the phone, yes, once when
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` 5 we talked about the, you know, what might
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` 6 transpire.
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` 7 Q How long did that telephone
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`Harker - Depo 0503amer
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` 8 conversation last?
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` 9 A I would say just a few minutes.
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` 10 Q And you said you
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` 11 communicated -- was that by E-Mail?
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` 12 A There was an E-Mail.
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` 13 Communication. He kept me current. I do a
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` 14 lot of traveling, as to -- if we were
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` 15 going to have a deposition, if we were not,
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` 16 and, if so, what dates would be available.
`
` 17 Q I hand you what has been marked
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` 18 as Exhibit 288.
`
` 19 (Exhibit No. 288, Subpoena for
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` 20 Deposition, is marked by the reporter
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` 21 for identification.)
`
` 22 Q Did you receive a copy of this
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` 23 subpoena?
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` 24 A I don't recall.
`
` 25 Q Were you -- you understand you
`
` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 7
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` 1 John V. Harker
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` 2 are appearing here today pursuant to a
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` 3 subpoena?
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`Harker - Depo 0503amer
` 4 A Absolutely.
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` 5 Q This subpoena, just for the
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` 6 record, was delivered to your lawyer who is
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` 7 representing you.
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` 8 Did he provide you with a copy
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` 9 of this subpoena?
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` 10 A He may have in an E-Mail.
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` 11 Q Do you know?
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` 12 A I don't recall.
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` 13 Q Well, do you recall reviewing
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` 14 the subpoena in response to the request for
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` 15 documents?
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` 16 A He asked me if I ever had any
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` 17 documents.
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` 18 Q That general?
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` 19 A And I don't.
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` 20 Q He just asked you if you had
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` 21 any documents and you said no?
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` 22 A He said, "Do you have any
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` 23 documents" around when I left Symbol
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` 24 Technologies?
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` 25 You know, I did not keep my
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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`Harker - Depo 0503amer
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` 1 John V. Harker
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` 2 files. I was -- as a matter of fact, I
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` 3 was -- when I left Symbol, I was terminated
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` 4 so --
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` 5 Q Let me ask you to look at the
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` 6 last page of Exhibit 288. Do you see the
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` 7 heading says "Document Requests"?
`
` 8 A Yes.
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` 9 Q Do you recall reading this
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` 10 page?
`
` 11 A No.
`
` 12 Q Now, this particular page has
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` 13 ten categories of document requests.
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` 14 Do you see that?
`
` 15 A Yes.
`
` 16 Q Did your lawyer go through each
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` 17 one of the categories with you and ask you
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` 18 if you had documents responsive to each
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` 19 category?
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` 20 That's just a yes or no answer.
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` 21 A That's a no.
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` 22 Q Did he specifically ask you
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` 23 whether or not you had any documents in
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` 24 your possession that related to the
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` 25 relationship that you had or Symbol had
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`Harker - Depo 0503amer
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 9
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` 1 John V. Harker
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` 2 with Ameranth?
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` 3 MR. OSBORNE: Objection to the
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` 4 form.
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` 5 Q You can answer the question.
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` 6 He's just got to make an objection, but you
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` 7 can answer it?
`
` 8 A Can you repeat your question,
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` 9 please.
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` 10 Q Sure. Looking at the first
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` 11 category, did he specifically ask you for
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` 12 documents that you might have in your
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` 13 possession between you or Symbol and
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` 14 Ameranth?
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` 15 A Yes, he did once previous, and
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` 16 I told him. I do not have any of my files
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` 17 from Symbol Technologies.
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` 18 Q And you said a few minutes ago
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` 19 that that's because you left suddenly?
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` 20 A Yes.
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`Page 10
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`Harker - Depo 0503amer
` 21 Q You were terminated; is that
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` 22 correct?
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` 23 A I was terminated.
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` 24 Q Do you know the cause for the
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` 25 termination.
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 1 John V. Harker
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` 2 A Yes. Symbol Technologies was
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` 3 under an SEC investigation. And,
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` 4 basically, I was an executive; and the
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` 5 entire executive team was asked to leave
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` 6 the company while they had the
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` 7 investigation. I was never deposed. I was
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` 8 never charged.
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` 9 It was something that was with
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` 10 the senior-most -- I was just a director at
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` 11 the time -- but the chief financial
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` 12 officer, the president, and a number of
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` 13 others were indicted.
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` 14 Q And you were not indicted?
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` 15 A Absolutely not.
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` 16 Q Do you know whatever happened
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` 17 to the charge or the investigation against
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`Harker - Depo 0503amer
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` 18 you personally?
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` 19 A It wasn't an investigation
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` 20 against me. There was no investigation.
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` 21 It just was they brought in a -- I think,
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` 22 an accounting team, and they came right in.
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` 23 And they decided that all of the executives
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` 24 at a certain level and above had to go.
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` 25 Bill Newty came in to run the company from
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 1 John V. Harker
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` 2 Cisco, and he brought his entire team in.
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` 3 Q Did the SEC ever advise you
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` 4 that any review of what you did was
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` 5 terminated?
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` 6 A No.
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` 7 Q Now, you mentioned the CEO and
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` 8 the CFO were indicted; is that correct?
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` 9 A Yes, I believe so.
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` 10 Q Were they ever convicted?
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` 11 A I believe there were some
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` 12 convictions.
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` 13 Q Did any of them ever serve any
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` 14 jail time?
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`Harker - Depo 0503amer
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` 15 A I have no idea.
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` 16 Q I'm sorry.
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` 17 A That was -- I left the company
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` 18 and I put a new chapter on in my life.
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` 19 Q When did that happen?
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` 20 A That happened in 2002.
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` 21 Q When did you go to work for
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` 22 Symbol?
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` 23 A 1989.
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` 24 Q What position did you have when
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` 25 you started to work at Symbol?
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` 950 Third Avenue, New York, NY 10022
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` 1 John V. Harker
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` 2 A I took a sales position. It
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` 3 was a very small company. It was around
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` 4 $87 million. I was a graduate. I
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` 5 graduated college in 1986.
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` 6 And I thought I saw where the
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` 7 future was headed. And I took a big gamble
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` 8 and left a job I was doing very well in to
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` 9 join Symbol, and just took a typical sales
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` 10 position.
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`Harker - Depo 0503amer
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` 11 Q And what was the big gamble
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` 12 that you thought you wanted to take?
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` 13 A The gamble was I thought that
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` 14 the mobile wireless world was going to
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` 15 really explode. I thought for sure that
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` 16 there was great opportunity and potential
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` 17 across many, many different marketplaces.
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` 18 And that gamble paid off.
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` 19 Q I'm sorry.
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` 20 A That gamble paid off.
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` 21 Q In what respect?
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` 22 A Well, when I left 15 years
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` 23 later, we were a $2 billion company from 87
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` 24 million.
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` 25 Q Did you have any stock interest
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` Elisa Dreier Reporting Corp. (212) 557-5558
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` 1 John V. Harker
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` 2 in Symbol?
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` 3 A Absolutely.
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` 4 Q Have you sold all of that
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` 5 stock?
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` 6 A I have sold it all.
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`Harker - Depo 0503amer
` 7 Q Now, where did you graduate
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` 8 from college?
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` 9 A I graduated from Cortland
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` 10 State. It's a state university of
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` 11 New York.
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` 12 Q Who did you go to work for?
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` 13 A I went to work for Tandy
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` 14 Corporation, which is out of Texas. They
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` 15 own Radio Shack. I was in their computer
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` 16 products division selling their computers
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` 17 to schools and businesses.
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` 18 Q Were you in sales as well?
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` 19 A Yes, I was.
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` 20 Q Did you work closely with the
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` 21 CEO and the CFO of Symbol?
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` 22 A I worked very, very closely
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` 23 with the CEO. His name was Jerry Schwartz.
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` 24 He was a mentor of mine.
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` 25 Q And he's the one who was
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` Elisa Dreier Reporting Corp. (212) 557-5558
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` 1 John V. Harker
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` 2 indicted?
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` 3 A No. The -- I'm sorry. Jerry,
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`Harker - Depo 0503amer
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` 4 when I joined the company, was CEO. He
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` 5 then became chairman of the board, so he
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` 6 was just chairman of the board and our
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` 7 chief scientist. Tomo Razmilovich was the
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` 8 CEO and president.
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` 9 Q You are going to have to spell
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` 10 that for the court reporter?
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` 11 A I don't know how to spell
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` 12 Razmilovich.
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` 13 Q He's the one who was indicted?
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` 14 A Yes, he was.
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` 15 Q Did you work with him?
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` 16 A I worked with him. I had
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` 17 meetings with him. Yes.
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` 18 Q Did you work with the CFO who
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` 19 was indicted?
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` 20 A I have had meetings with him.
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` 21 Yes.
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` 22 Q What is his name?
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` 23 A Ken Jaegge, J-a-e-g-g-e, or
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` 24 something like that.
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` 25 Q Now, you said there were
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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`Page 16
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`Harker - Depo 0503amer
` 15
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` 1 John V. Harker
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` 2 several people indicted. Were those the --
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` 3 A Yes.
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` 4 Q Who were the others?
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` 5 A The others were the vice
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` 6 president of sales.
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` 7 Q What is his name?
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` 8 A His name was Frank Borgese,
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` 9 B-o-r-g-e-s-e.
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` 10 Q I'm sorry. B-o-r-g-h --
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` 11 A B-o-r-g-e-s-e.
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` 12 Q And what -- was he convicted as
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` 13 well?
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` 14 A That I can't tell you. I
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` 15 haven't followed it that closely.
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` 16 Q He was your boss?
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` 17 A No. He was not my boss.
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` 18 Q What was the position that you
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` 19 had at the time you were terminated?
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` 20 A At the time, I was director of
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` 21 hospitality and gaming, and I reported into
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` 22 the director of business development.
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` 23 Q And who was that?
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`Harker - Depo 0503amer
` 24 A Tom Roselack.
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` 25 Q Was he an officer as well?
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 1 John V. Harker
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` 2 A No. He was not an officer.
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` 3 Q Did he resign as well?
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` 4 A No. He is still working.
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` 5 Q Is there a reason that you
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` 6 resigned being a subordinate to him and
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` 7 they did not resign?
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` 8 A Yes. When everything happened,
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` 9 they decided that, when Bill Newty came in,
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` 10 that they were going to go back to their
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` 11 core. And the core was retail warehouse
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` 12 distribution, transportation, and they got
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` 13 rid of health care. They got rid of
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` 14 hospital and gaming.
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` 15 Q What was the nature of the SEC
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` 16 investigation as best you can recall?
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` 17 A I believe you call them "candy
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` 18 deals." That's where you put product into
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` 19 the marketplace, and you know they weren't,
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` 20 I think, fudging the books. It was all a
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`Harker - Depo 0503amer
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` 21 surprise to me.
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` 22 I kicked myself in the butt
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` 23 because I didn't see it. I didn't know it
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` 24 was happening. But they had some, I guess,
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` 25 major, major resellers that they would
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` 950 Third Avenue, New York, NY 10022
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` 1 John V. Harker
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` 2 supply product to.
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` 3 And at the end of the year,
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` 4 whatever they didn't sell, it could come
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` 5 back. But then something called 9/11
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` 6 happened, and the world changed from that
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` 7 point forward. And I think it became
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` 8 exposed.
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` 9 Q What became exposed?
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` 10 A Just the fact that they -- I
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` 11 guess they are called "candy deals." I
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` 12 don't know.
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` 13 Q What was the sweet or the candy
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` 14 deal that was going on in Symbol's case in
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` 15 particular?
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` 16 A I just think they were flooding
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`Harker - Depo 0503amer
` 17 marketplace -- you know, not flooding the
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` 18 marketplace -- they were putting a lot of
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` 19 product into the reseller channel.
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` 20 Q And these were wireless
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` 21 hand-helds?
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` 22 A No, just Symbol's business is
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` 23 broken up into many different things.
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` 24 Scanning devices is their number one core
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` 25 competency -- scanning, imaging hand-helds,
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 1 John V. Harker
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` 2 wireless, OEM products. They did a number
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` 3 of different things, so generally the
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` 4 channel distribution was scanning.
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` 5 Q So why did the company decide
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` 6 to get out of the hospitality and gaming
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` 7 business?
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` 8 A Why? Because I think they
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` 9 wanted to go right back to their core and
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` 10 put all of their money into their core
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` 11 competencies, their traditional core
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` 12 competencies.
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` 13 You had one management that
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`Harker - Depo 0503amer
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` 14 believed in continued growth and new
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` 15 markets, and then you had a new philosophy
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` 16 coming, which was Bill Newty, who was from
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` 17 Cisco who said just stick to the core. And
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` 18 that's why the health care and the
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` 19 hospitality teams were let go.
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` 20 Q Was the hospitality team
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` 21 profitable or the hospitality product line,
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` 22 was it profitable?
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` 23 A I thought we did a very good
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` 24 job; but, unless you are a $100 million
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` 25 business a year at the time, you weren't
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 19
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` 1 John V. Harker
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` 2 going to be around.
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` 3 Q Now, you said Bill Newty -- you
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` 4 said he came from Cisco?
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` 5 A Yes.
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` 6 Q Was there a relationship
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` 7 between Cisco and Symbol at that time?
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` 8 A No, there was not.
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` 9 Q So he left Cisco to join
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`Page 21
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` 10 Symbol?
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`Harker - Depo 0503amer
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` 11 A Yes. As a matter of fact, we
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` 12 were rivals in many ways. I think Bill was
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` 13 a very young, sharp guy, one of the top
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` 14 guys reporting into Bill [sic] Chambers.
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` 15 Bill had grown up in Long Island, and I
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` 16 thought he wanted to go back to his core
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` 17 and his roots. Unfortunately, I don't
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` 18 think it worked out for him; and he left
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` 19 after two years to pursue another career.
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` 20 Q Do you know where he is now?
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` 21 A I have no idea.
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` 22 Q And you said he reported to
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` 23 Mr. Chambers?
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` 24 A At his old position at Cisco,
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` 25 yes, Bill Newty reported to John Chambers.
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` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
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` 20
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` 1 John V. Harker
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` 2 Q Are you being compensated for
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` 3 your time today?
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` 4 A No. I never asked.
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` 5 Q Have you been asked to appear
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` 6 at trial in this matter?
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`Harker - Depo 0503amer
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` 7 A I don't know. I think this is
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` 8 the deposition. I don't know if you call
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` 9 this a trial. But I have never been in a
`
` 10 deposition or a trial so --
`
` 11 Q Have you been asked if you
`
` 12 would volunteer to travel to Marshall,
`
` 13 Texas, to testify live at the trial?
`
` 14 A No, I have not.
`
` 15 Q Would you agree to do so?
`
` 16 A I would have to reserve
`
` 17 judgment on that until the time comes.
`
` 18 Q Well, the reason I say "agree"
`
` 19 is because no one can ask you to go down,
`
` 20 that you would have to volunteer to go down
`
` 21 there. That's why I asked you that.
`
` 22 A Okay.
`
` 23 Q Have you made any kind of
`
` 24 agreement to go down there?
`
` 25 A No, I have not. I handle in my
`
` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
`
` 21
`
` 1 John V. Harker
`
` 2 current job the East Coast operations, and
`
`Page 23
`
`
`
`Harker - Depo 0503amer
` 3 I like to stick to the East Coast unless I
`
` 4 am on vacation. Texas is not on my
`
` 5 vacation list.
`
` 6 Q Let me show you what has been
`
` 7 previously marked as Exhibit 29.
`
` 8 (Previously Marked Exhibit No.
`
` 9 29, Symbol Product Requirement
`
` 10 Document is introduced into the
`
` 11 proceedings.)
`
` 12 Q Have you previously seen this
`
` 13 Symbol product requirement document?
`
` 14 A I have read it before.
`
` 15 Q Were you involved in its
`
` 16 preparation or review prior to lease?
`
` 17 A No. The business development
`
` 18 team worked with the product development
`
` 19 teams, just as far as maybe what type of
`
` 20 requirements needed to be in the devices.
`
` 21 But I did not work with Bob on putting this
`
` 22 document together.
`
` 23 Q Who is Bob?
`
` 24 A I think it says Bob Schreib,
`
` 25 the author.
`
` Elisa Dreier Reporting Corp. (212) 557-5558
`
`Page 24
`
`
`
`Harker - Depo 0503amer
` 950 Third Avenue, New York, NY 10022
` 22
`
`
`
` 1 John V. Harker
`
` 2 Q What position does Mr. Schreib
`
` 3 have?
`
` 4 A I think he was just product
`
` 5 manager, and I think he was probably just
`
` 6 for a year on that product. But he was the
`
` 7 product manager. Every product at Symbol
`
` 8 Technologies had a product manager.
`
` 9 Q He was the designated product
`
` 10 manager for this product?
`
` 11 A Yes, he was.
`
` 12 Q How about the other two
`
` 13 individuals who are mentioned there,
`
` 14 Mr. Nanbuttari and Mr. Fuccillo?
`
` 15 A Yes. I don't know. I think
`
` 16 those are just probably very technical
`
` 17 engineering people, who, Bob, being a
`
` 18 product manager -- and these are probably
`
` 19 from the engineering teams. I have never
`
` 20 heard their names or seen their names
`
` 21 before. But that's what I am assuming.
`
` 22 Q Now, this document has a date
`
` 23 on the lower right-hand portion that says
`
`Page 25
`
`
`
`Harker - Depo 0503amer
`
` 24 December 24, 1998. Would that be the date
`
` 25 that that product would have -- this
`
` Elisa Dreier Reporting Corp. (212) 557-5558
` 950 Third Avenue, New York, NY 10022
`
` 23
`
` 1 John V. Harker
`
` 2 document would have been released?
`
` 3 A No.
`
` 4 Q What does that date mean in the
`
` 5 Symbol convention?
`
` 6 A That means if -- I think, if
`
` 7 you see the top there called "Stealth" on
`
` 8 the top of that document, that means this
`
` 9 is still a product that we are talking
`
` 10 about. But it is "Stealth" is its
`
` 11 developmental name.
`
` 12 Q What does MCS mean before the
`
` 13 date?
`
` 14 A Where would that be?
`
` 15 Q MCS, those initials right
`
` 16 before December 24, 1998.
`
` 17 A I have no idea.
`
` 18 Q Would you have reviewed this
`
` 19 document on or about this time?
`
`Page 26
`
`
`
`Harker - Depo 0503amer
` 20 A If it was presented to me,
`
` 21 "John, would you review it," I have seen
`
` 22 this document before. I have seen it when
`
` 23 it came out in its product form. But I
`
` 24 can't recall.
`
` 25 Q You saw it at some point. You
`
` Elisa Dreier Reporting Corp. (21
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