Steve Jae Youn Kim - February 13, 2017
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` IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF VIRGINIA
` NORFOLK DIVISION
`
` _____________________________
` )
` NADER ASGHARI-KAMRANI and )
` )
` KAMRAN ASGHARI-KAMRANI, )
` )
` Plaintiffs, )
` )
` vs. ) Civil Action No.
` ) 2:15-cv-00478-
` UNITED SERVICES AUTOMOBILE ) RGD-RJK
` )
` ASSOCIATION, )
` )
` Defendant. )
` )
` ____________________________)
`
`
`
` Videotaped Deposition of STEVE JAE
`
`YOUN KIM, held at the offices of Fish & Richardson
`
`P.C., 1425 K Street, Northwest, Washington, D.C.,
`
`commencing at 9:42 a.m., Monday, February 13,
`
`2017, before Cappy Hallock, Registered
`
`Professional Reporter, Certified Realtime
`
`Reporter. and Notary Public in and for the
`
`District of Columbia.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` 1
`
`USAA 1069
`USAA v Asghari-Kamrani
`CBM2016-00063
`CBM2016-00064
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`
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` IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF VIRGINIA
` NORFOLK DIVISION
`
` _____________________________
` )
` NADER ASGHARI-KAMRANI and )
` )
` KAMRAN ASGHARI-KAMRANI, )
` )
` Plaintiffs, )
` )
` vs. ) Civil Action No.
` ) 2:15-cv-00478-
` UNITED SERVICES AUTOMOBILE ) RGD-RJK
` )
` ASSOCIATION, )
` )
` Defendant. )
` )
` ____________________________)
`
`
`
` Videotaped Deposition of STEVE JAE
`
`YOUN KIM, held at the offices of Fish & Richardson
`
`P.C., 1425 K Street, Northwest, Washington, D.C.,
`
`commencing at 9:42 a.m., Monday, February 13,
`
`2017, before Cappy Hallock, Registered
`
`Professional Reporter, Certified Realtime
`
`Reporter. and Notary Public in and for the
`
`District of Columbia.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` 1
`
`USAA 1069
`USAA v Asghari-Kamrani
`CBM2016-00063
`CBM2016-00064
`
`
`
`Steve Jae Youn Kim - February 13, 2017
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`Page 2
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` A P P E A R A N C E S O F C O U N S E L
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`FOR THE PLAINTIFFS AND THE WITNESS:
`
` MEI & MARK LLP
` BY: REECE NIENSTADT, ESQUIRE
` 818 18th Street, Northwest
` Suite 410
` Washington, D.C. 20006-3506
` rnienstadt@meimark.com
` (202) 567-6417
`
` FOR THE DEFENDANT:
`
` FISH & RICHARDSON P.C.
` BY: MICHAEL T. ZOPPO, ESQUIRE
` 601 Lexington Avenue
` 52nd Floor
` New York, New York 10022-4611
` zoppo@fr.com
` (212) 765-5070
`
` FISH & RICHARDSON P.C.
` BY: MATTHEW C. BERNTSEN, ESQUIRE
` One Marina Park Drive
` Boston, Massachusetts 02210-1878
` berntsen@fr.com
` (617) 542-5070
`
`ALSO PRESENT:
`
` TJ O'Toole, Videographer
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Steve Jae Youn Kim - February 13, 2017
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` I N D E X
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` Deposition of Steve Jae Youn Kim
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` February 13, 2017
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`EXAMINATION BY: PAGE
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` Mr. Zoppo 7
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` Mr. Nienstadt 239
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` Mr. Zoppo 262
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`Steve Jae Youn Kim - February 13, 2017
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` E X H I B I T S
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`KIM PAGE
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`Exhibit 1 U.S. Patent No. 7,356,837 B2 35
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`Exhibit 2 U.S. Patent No. 7,444,676 B1 36
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`Exhibit 3 U.S. Patent No. 8,281,129 B1 36
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`Exhibit 4 U.S. Patent No. 8,266,432 B2 36
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`Exhibit 5 curriculum vitae 37
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`Exhibit 6 NKL Law - Professionals: Web 41
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` site printout Steve Jae Youn Kim
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`Exhibit 7 Notice of Deposition 65
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`Exhibit 8 handdrawn illustration 86
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`Exhibit 9 Application No. 11/239,046, '676 100
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` file history USAA_AK_0014310-597
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`GregoryEdwards.com | 866-4Team GE
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` E X H I B I T S: (Continued)
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`KIM PAGE
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`Exhibit 10 2-8-16 letter, Zoppo to 116
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` Nienstadt
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`Exhibit 11 2-11-16 letter, Zoppo to 116
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` Nienstadt
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`Exhibit 12 Application No. 11/333,400, '129 119
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` file history USAA_AK_0006159-879
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`Exhibit 13 Application No. 12/210,926, '432 139
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` file history USAA_AK_0031183-2140
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`Exhibit 14 Documents submitted 2-12-16, 197
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` NOVKIM000001-019
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`Steve Jae Youn Kim - February 13, 2017
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` P R O C E E D I N G S
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` - - - - - -
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` THE VIDEO OPERATOR: All right, stand
`
`by.
`
` On the record with Disc 1 of the video
`
`deposition of Jae Youn Kim taken in the matter of
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`Nader Asghari-Kamrani, et al. versus United
`
`Services Automobile Association, being heard
`
`before the United States District Court for the
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`Eastern District of Virginia, Norfolk Division.
`
`This deposition is being held at the Law Offices
`
`of Fish & Richardson located at 1425 K Street,
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`Northwest in Washington, D.C. on February 13th,
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`2017 at approximately 9:42 a.m.
`
` My name is TJ O'Toole. I am the
`
`Certified Legal Video Specialist. The court
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`reporter is Cappy Hallock. We are both here
`
`representing GregoryEdwards LLC.
`
` Will counsel please introduce
`
`themselves and indicate which parties they
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`represent.
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` MR. ZOPPO: Michael Zoppo, Fish &
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`Steve Jae Youn Kim - February 13, 2017
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`Richardson for defendant United Services
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`Automobile Association. I'm joined by my
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`colleague Matthew Berntsen, also of Fish &
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`Richardson.
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` MR. NIENSTADT: Reece Nienstadt of
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`Mei & Mark LLP on behalf of Plaintiffs and Steve
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`Jae Youn Kim.
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` THE VIDEO OPERATOR: Thank you. Will
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`the reporter please swear in the witness.
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`WHEREUPON,
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` STEVE JAE YOUN KIM,
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` A Witness called for examination, having
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`been first duly sworn, was examined and testified
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`as follows:
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` EXAMINATION
`
`BY MR. ZOPPO:
`
` Q Good morning, Mr. Kim.
`
` A Good morning.
`
` Q Thank you for being here today.
`
` A No problem.
`
` Q Thank you. Okay.
`
` If you could, could you state your
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`name for the record, please?
`
` A My name is Jae Youn Kim. My English
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`name is Steve.
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` Q Okay, so throughout this deposition I
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`will probably often refer to you as Mr. Kim or
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`sir; is that okay?
`
` A Yes, sir.
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` Q Okay. You can call me Mr. Zoppo or
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`Michael and that's just fine. Okay?
`
` A Thank you.
`
` Q Thank you.
`
` For the record, could you state your
`
`home address?
`
` A 7545 Red Hill Drive --
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` Q I'm sorry?
`
` A 7545 Red Hill Drive, Springfield,
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`Virginia 22153.
`
` Q And do you have a business address,
`
`sir?
`
` A Yes.
`
` Q Could you state it for the record,
`
`please?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Steve Jae Youn Kim - February 13, 2017
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`Page 9
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` A 3521 Old Lee Highway, Fairfax -- I'm
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`sorry, Fairfax City, 22030.
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` Q Thank you, sir.
`
` Are you an attorney?
`
` A Yes.
`
` Q Okay.
`
` To which bars are you admitted to
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`practice?
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` A Virginia and Tennessee.
`
` Q I see. Okay.
`
` Have you ever taken a deposition
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`before, sir?
`
` A Yes.
`
` Q Yes. In what context have you taken a
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`deposition, sir?
`
` A I represented a client in a
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`re-examination before, and I defended the patentee
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`and the other party deposed me for my work in the
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`re-examination.
`
` Q Okay, so you took a deposition in a
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`patent office post-grant proceeding; is that
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`correct? Am I understanding your testimony?
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`Steve Jae Youn Kim - February 13, 2017
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`Page 10
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` A Yes. It's correct.
`
` Q Have you ever taken a deposition in
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`the context of a litigation proceeding?
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` A No.
`
` Q Okay.
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` And I believe you said you have been
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`deposed previously; is that correct? Did I
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`understand your testimony?
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` A Yes.
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` Q Okay. And the time that your
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`deposition was taken, you said that was in a
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`re-examination proceeding?
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` A Yes, it was.
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` Q Okay, and what was the subject matter
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`of that deposition?
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` A I don't recall.
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` Q Do you remember the name of the
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`proceeding in which your deposition was taken?
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` A Do you mean the court proceeding or
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`the re-examination proceeding?
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` Q The re-examination proceeding.
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` A I'm not sure.
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` Q Do you remember the subject matter of
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`the patent that was involved in that
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`re-examination proceeding?
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` A I do.
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` Q What was that subject matter, sir?
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` A It was related to a cell phone having
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`a digital camera built in there.
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` Q A cell phone camera -- a cell phone
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`with a built-in digital camera; is that correct?
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` A Yes.
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` Q Okay.
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` I want to talk a little bit about how
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`this proceeding, this deposition is going to work.
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`I'm not going to go through all the details
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`because it seems you have some experience, so I
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`will just go over some of the highlights. Okay?
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` A Yes.
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` Q The fundamental process of what is
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`going to happen here is I'm going to ask you a
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`question and you're going to answer the question.
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`You have Mr. Nienstadt here. From time to time he
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`may interpose an objection. Okay? Do you
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`understand why Mr. Nienstadt might interject an
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`objection?
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` A Yes.
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` Q Okay. Why?
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` A Do you mean -- your question is why I
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`understand he is objecting to your questions?
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` Q No. Why do you understand
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`Mr. Nienstadt might object during these
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`proceedings?
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` MR. NIENSTADT: Objection, vague and
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`ambiguous. Calls for speculation.
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` A He is my attorney defending me at this
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`deposition, and the questions might be
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`objectionable so he may say objections for me.
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`That's what I understand. I don't know.
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` Q Okay, but do you understand that if
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`Mr. Nienstadt makes an objection you still have to
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`answer the question unless he instructs you not to
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`answer the question. Do you understand that?
`
` A I do.
`
` Q Okay.
`
` Now, we have madam court reporter
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`Steve Jae Youn Kim - February 13, 2017
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`Page 13
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`present, and what she is doing, she is typing down
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`my words and your words, and occasionally
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`Mr. Nienstadt's words. Okay?
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` And what that means is we can't talk
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`over each other, okay, because the court reporter
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`can only take down one thing at a time. Okay? So
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`I will do my best not to speak over you and I will
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`ask that you do your best not to speak over me.
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`Is that okay?
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` A Yes, sir.
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` Q Okay.
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` Also because of your cold, which may
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`have compromised your ability to speak today, I
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`would ask you to try to speak as clearly and
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`loudly as you can for the benefit of the court
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`reporter. Is that okay?
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` A Yes, sir.
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` Q Okay.
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` And also we have a videographer
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`present so this proceeding is being videotaped and
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`may be played at the trial for this case. Do you
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`understand that?
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`Page 14
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` A I do.
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` Q Okay.
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` During the course of the examination
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`if I ask you a question and you don't understand
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`something you have to tell me that you don't
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`understand it, because if you answer a question
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`that I ask, we are all going to understand that
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`you understood my question. Does that make sense?
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` A Yes.
`
` Q Okay.
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` You understand you are under oath
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`today?
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` A Yes.
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` Q Okay. That means you have to tell the
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`truth, right?
`
` A Yes.
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` Q Is there any reason why you can't give
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`truthful testimony today?
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` A No.
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` Q During the course of the deposition if
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`you feel the need to take a break, you just let me
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`know that and that's fine. The only rule is you
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`Page 15
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`have to answer the pending question; is that fair?
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` A Yes, sir.
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` Q Okay.
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` Now, I understand that English is not
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`your first language, correct?
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` A Yes.
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` Q Okay. Do you consider yourself fluent
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`in English?
`
` A Yes.
`
` Q Okay. You seem so.
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` Now, are you aware that in this
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`litigation that there have been expert reports
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`served from USAA onto the Plaintiffs?
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` A I don't know.
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` Q You're not aware of any expert reports
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`that exist or have been served in this litigation?
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` A To whom? To me or to the patentee in
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`the litigation, or to patentee in this CBM?
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` Q I'm talking about the litigation,
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`reports that USAA served onto the patentees or the
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`Plaintiffs.
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` A From your side to the Plaintiffs?
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` Q Correct.
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` A Yes, I am aware of the expert report.
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` Q Have you reviewed those?
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` A Yes.
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` Q When did you review those?
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` A I'm not sure the date.
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` Q Approximately.
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` A About one or two weeks ago.
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` Q Okay.
`
` Now, we are going to get into your
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`background in some more detail but I just wanted
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`to put this one thing out there. Clearly you are
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`a very experienced patent lawyer, okay, and
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`many -- I will say all the lawyers in this room
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`are also experienced patent lawyers, and so the
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`four of us share a certain, I will say a lingo
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`about patents, okay, and we all share a common
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`understanding of a great deal of principles having
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`to deal with patent law. However, I will probably
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`be asking you a number of questions that seem
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`simplistic to you, and the reason for that is this
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`matter is currently set for a jury trial. And I
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`think you would agree with me that we shouldn't
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`expect that the entire jury is going to be
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`impaneled with patent lawyers, okay, so we need to
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`make sure we have a basic understanding of some of
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`our principles on the record so that everybody can
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`understand what the issues are in this case.
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` Does that make sense?
`
` A Yes.
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` Q Okay.
`
` Did you do anything to prepare for
`
`this deposition today?
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` A I had a meeting with Reece.
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` Q Okay. Was it only Reece?
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` A Yes.
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` Q How long was that meeting?
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` A About two or three hours.
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` Q When did that meeting occur?
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` A Saturday, last Saturday.
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` Q Saturday. Working on the weekend, I
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`see. Okay.
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` A Yes.
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` Q Did you review any documents during
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`that meeting?
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` A What do you mean by the document?
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` Q Did you review any documents? What
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`don't you understand about that question, sir?
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` A What kind of document do you mean?
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` Q Did you review any documents, sir?
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`I'm not asking which ones. I'm asking did you
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`review any documents.
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` A I did not review any document that I
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`submitted to the USPTO or any document submitted
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`to any court. And I printed out some
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`communications, e-mail communications during the
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`meeting, and then I gave them to Reece.
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` Q Okay.
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` Do you know if these are the documents
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`that were produced to us Sunday evening,
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`yesterday, at around 6 p.m.?
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` A Those document are some of the e-mail
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`communications that I printed out and gave to
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`Reece.
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` Q Okay, so -- so you reviewed additional
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`documents in addition to the ones that were
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`produced to us; is that what you're saying?
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` A The additional document means some
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`e-mail communications.
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` Q Okay, and e-mail communications
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`between whom?
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` A Between me and the three lawyers and
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`also between me and my client patent owner.
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` Q Okay.
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` So is it your understanding that there
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`are certain e-mails between the three lawyers and
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`the patent owner that are being withheld on
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`whether it's attorney/client privilege or work
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`product?
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` MR. NIENSTADT: Objection, vague and
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`ambiguous.
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` A That's my understanding, that these
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`communications are privileged under
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`attorney/client or the work product.
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` Q Okay.
`
` Now, when you were reviewing these
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`documents with Mr. Nienstadt, did any of those
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`documents refresh your recollection about any of
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`the facts in this case?
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` A Yes. I did some recollection on this
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`case.
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` Q Okay. Did any of the documents that
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`are being withheld from production on the basis of
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`work product or privilege, did any of those
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`refresh your recollection about any facts in this
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`case?
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` MR. NIENSTADT: I am going to object
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`to that as privileged as it gets to the content of
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`the communications.
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` MR. ZOPPO: It does not get to the
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`content of the communications.
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` MR. NIENSTADT: I am going to instruct
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`you not to answer that question. Maybe there is a
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`way you can rephrase it, but I think that asks him
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`to essentially describe -- it tries to do an end
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`run around the privilege and get him to describe
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`what's in them.
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` MR. ZOPPO: I am not going to ask the
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`witness what is in the documents. I assure you
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`that.
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` MR. NIENSTADT: I think that's sort of
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`what you're doing.
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` MR. ZOPPO: Okay, let's ask it a
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`different way.
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`BY MR. ZOPPO:
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` Q Among the documents that you reviewed
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`yesterday with Mr. Nienstadt --
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` A It was Saturday.
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` Q I'm sorry. Among the documents that
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`you reviewed Saturday with Mr. Nienstadt, were
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`there -- strike that.
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` Among the documents you reviewed
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`Saturday with Mr. Nienstadt, did all of those
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`documents refresh your recollection of the facts
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`in this case?
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` MR. NIENSTADT: Objection, vague and
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`ambiguous.
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` A I don't know. Maybe not.
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` Q Were there some -- were some of the
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`documents that you reviewed with Mr. Nienstadt
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`that did not refresh your recollection of facts in
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`this case?
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` MR. NIENSTADT: Objection, asked and
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`answered.
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` A I mean, you ask whether I get all of
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`the recollections during review of the
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`communications regarding the fact, the fact of
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`this case. My answer to that question is maybe
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`not, because I cannot remember all the things that
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`I communicated with the client and with the
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`lawyers.
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` Q Okay, but it's possible that to some
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`extent the documents that you reviewed Saturday
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`with Mr. Nienstadt refreshed your recollection of
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`the facts relevant to this case?
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` MR. NIENSTADT: I'm going to instruct
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`you not to answer. That's a repetition of the
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`previous question that I instructed you not to
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`answer.
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` MR. ZOPPO: You can't instruct the
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`witness not to answer because of asked and
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`answered.
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` MR. NIENSTADT: I know, but it's
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`repetition of the previous question that asked for
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`privileged information.
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` MR. ZOPPO: How am I asking -- how
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`does that ask for privileged information?
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` MR. NIENSTADT: You are trying to make
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`an end run by asking if it refreshes his memory
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`and then bringing up what the subject matter is
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`that he was refreshed on later.
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` MR. ZOPPO: I'm not going to ask him
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`what was refreshed on. All I'm asking is whether
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`it refreshes his recollection. That's it.
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` MR. NIENSTADT: What significance
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`could that possibly have other than some argument
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`about waiver of attorney/client privilege?
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` MR. ZOPPO: We will hold that question
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`and we have to go to the court on that.
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`BY MR. ZOPPO:
`
` Q But I want to summarize your testimony
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`because I don't know that the record is exactly
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`clear. You testified earlier that you reviewed
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`documents Saturday with Mr. Nienstadt; isn't that
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`correct?
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` A Yes.
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` Q And you testified that to one extent
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`or the other your memory was refreshed by review
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`of some of those documents; isn't that correct?
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` A Yes, to some extent.
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` Q Fair enough, sir. Thank you.
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` Now, I understand that you are
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`represented by Mr. Nienstadt today; that's
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`correct?
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` A Yes.
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` Q Okay, and Mr. Nienstadt is
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`representing you in your personal capacity; is
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`that correct?
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` MR. NIENSTADT: I will represent that
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`I am, yes.
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` Q Do you accept your lawyer's
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`representation?
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` A Yes, of course.
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` Q Okay.
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` Do you have any other lawyer
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`representing you in this matter?
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` A No.
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` Q Okay. It's only Mr. Nienstadt?
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` A Yes.
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` Q Okay.
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` Are you paying Mr. Nienstadt for this
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`representation?
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` A No.
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` Q That's a bargain. Who is paying him?
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` MR. NIENSTADT: Move to strike that
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`comment.
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` Q Who is paying him?
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` A I don't know.
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` Q Okay.
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` Now, I assume that you're aware that
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`Mr. Nienstadt is also representing the Asgharis in
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`this litigation, right?
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` A Yes.
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` Q That being the case, you don't have
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`independent counsel in this action; is that true?
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` MR. NIENSTADT: Objection, asked and
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`answered.
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` A Why do I --
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` MR. NIENSTADT: Vague and ambiguous as
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`to the word independent.
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` Q You don't have your own lawyer
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`separate and apart from the lawyer that's
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`representing the Asgharis in this case.
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` MR. NIENSTADT: Objection, asked and
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`answered.
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` Q Right? Isn't that true?
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` MR. NIENSTADT: Same objection.
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` A Reece is my attorney.
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` Q Right.
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` A I think he is independent attorney for
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`me.
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` Q Okay, understood.
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` Are you being paid to be here today,
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`Mr. Kim?
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` A No.
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` Q Are you billing your time for this
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`deposition?
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` A I want to bill my time to you.
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` Q I'm sorry, but I need a real answer.
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`That was funny, though.
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` Are you billing your time for this
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`deposition?
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` A No.
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` Q Okay.
`
` Let's see, have you ever heard of an
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`individual named Shawna Shaw?
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` A I'm not sure if Shawna is the Shawn
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`who is one of the attorneys.
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` Q That's the one I'm referring to,
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`Mr. Kim. Have you ever heard of her?
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` A I vaguely remember the name.
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` Q Okay.
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` MR. NIENSTADT: I think there may be a
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`misunderstanding. Sorry to interrupt, but she is
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`not an attorney so I think you may be talking past
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`each other or talking about different people.
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` Q Mr. Nienstadt makes a good point.
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`Ms. Shaw is a patent agent, not a patent lawyer.
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`I don't know if that may clarify your
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`recollection.
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` A I'm not sure about her position. I
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`said I'm vaguely, I'm not sure, but I vaguely
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`remember the name.
`
` Q Thank you, sir.
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` You're not her lawyer; is that
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`correct?
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` A No.
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` Q Okay.
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` Now, since you don't really know about
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`Shawna Shaw, you don't really have an opinion as
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`to whether she is a competent patent agent or not,
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`do you?
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` MR. NIENSTADT: Objection, lacks
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`foundation.
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` A I don't have an opinion.
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` Q That's fine.
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` Have you ever heard of an individual
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`named Michael Fortkort?
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` A Yes.
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` Q You have. Okay.
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` Do you represent Mr. Fortkort? Are
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`you his attorney?
`
` A No.
`
` Q Have you ever been his attorney?
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` A No.
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` Q Has your law firm ever represented
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`Mr. Fortkort?
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` A No.
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` Q Okay.
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` Do you -- are you able to form any
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`opinion as to the competency of Mr. Fortkort as a
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`patent lawyer?
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` MR. NIENSTADT: Objection, vague and
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`ambiguous. Calls for speculation.
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` A No.
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` Q You have no opinion?
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` MR. NIENSTADT: Same objections.
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` A No.
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` Q Have you ever heard of a law firm
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`called Fortkort & Houston?
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` A Would you repeat that question?
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` Q Sure. Fortkort & Houston.
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` A No.
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` Q Okay. In that case, I would assume
`
`that you are not counsel to Fortkort & Houston?
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`You are not their lawyer; is that correct?
`
` A Right.
`
` Q Okay.
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` And I assume you have never been the
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`lawyer for Fortkort & Houston?
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` A No.
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` Q And your law firm hasn't either; is
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`that correct?
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` A Not that I know.
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` Q Have you ever heard of an individual
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`named Veronica Cau, and I may be mispronouncing
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`her last name.
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` MR. ZOPPO: Am I?
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` MR. NIENSTADT: I think that's fine
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`the way you pronounced it.
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` Q Okay. Veronica Cau is her name.
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` A Yes.
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` Q Are you Ms. Cau's lawyer?
`
` A No.
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` Q Have you ever been her lawyer?
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` A No.
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` Q Okay.
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` Has your law firm ever served as
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`Ms. Cau's lawyers?
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` A No.
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` Q Have you formed any opinion as to
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`whether Ms. Cau is a competent patent lawyer?
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` MR. NIENSTADT: Objection, vague and
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`ambiguous. Calls for speculation.
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` A No.
`
` Q Have you ever heard of a law firm
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`called Weiss & Moy?
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` A Weiss & Moy?
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` Q Yes, sir.
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` A No.
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` Q So I assume you are not Weiss & Moy's
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`lawyer, you have never been Weiss & Moy's lawyer,
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`and your law firm has never been the lawyer for
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`Weiss & Moy; is that correct?
`
` A Yes.
`
` Q Okay.
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` Have you ever heard of an individual
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`named Stanley Green?
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` A Stanley Green. No.
`
` Q Okay, so we can assume that you're not
`
`Mr. Green's lawyer, you have never been
`
`Mr. Green's lawyer and your law firm is not
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`Mr. Green's lawyer; is that correct?
`
` A Yes.
`
` Q Okay.
`
` Now, I assume you have heard of an
`
`individual named Mr. Nienstadt sitting at the
`
`table today, correct?
`
` A Yes, of course.
`
` Q Okay.
`
` Are you Mr. Nienstadt's lawyer?
`
` A No.
`
` Q Okay.
`
` Have you ever been Mr. Nienstadt's
`
`lawyer?
`
` A No.
`
` Q Okay. Has your firm ever been
`
`Mr. Nienstadt's lawyer, or counsel?
`
` A No.
`
` Q Okay.
`
` Have you ever formed any opinion as to
`
`whether Mr. Nienstadt is a competent patent
`
`lawyer?
`
` MR. NIENSTADT: Objection, vague and
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
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`ambiguous. Calls for speculation.
`
` A No.
`
` Q Have you ever heard of a law firm
`
`named Mei & Mark?
`
` MR. NIENSTADT: Mei & Mark.
`
` MR. ZOPPO: I'm sorry, let me ask the
`
`question again.
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` Q Have you ever heard of a law firm
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`named Mei & Mark?
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`
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