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` J. Cole
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________________________
` PETROLEUM GEO-SERVICES INC.
` Petitioner
` v.
` WESTERNGECO LLC
` Patent Owner
` _____________________________
`Case No. IPR2014-01475, -01476, -01477, -91478
` Patent No. 7,162,520 B2
` Patent No. 7,162,967 B2
` Patent No. 7,080,607
` _____________________________
`
` DEPOSITION OF JACK H. COLE, Ph.D.
` Washington, D.C.
` Volume One - June 25 2015
`
` Reported by: Mary Ann Payonk
` Job No. 94684
`
`TSG Reporting - Worldwide 877-702-9580
`
`WESTERNGECO Exhibit 2044, pg. 1
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
`Page 2
`
`Page 3
`
` J. Cole
`
` June 25 2015
` 9:08 a.m.
`
` Deposition of DR. JACK H. COLE, Ph.D.,
` Volume One, held at the offices of Williams &
` Connolly, 725 12th Street, N.W., Washington,
` D.C., pursuant to Notice before Mary Ann
` Payonk, Nationally Certified Realtime Reporter
` and Notary Public of the District of Columbia,
` Commonwealth of Virginia, States of Maryland
` and New York, CA-CSR No. 13431.
`
`Page 4
`
` J. Cole
` Appearances (Cont'd.):
` ON BEHALF OF PATENT OWNER:
` SIMEON PAPACOSTAS, ESQUIRE
` KIRKLAND & ELLIS
` 300 North LaSalle
` Chicago, IL 60654
`
`
` ALSO PRESENT:
` Kevin Hart, (by Internet Realtime)
` Petroleum Geo-Services, Inc.
` Ms. Marta Chlistunoff
`
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` J. Cole
` APPEARANCES:
` ON BEHALF OF PETITIONER:
` THOMAS FLETCHER, ESQUIRE
` ALEC SWAFFORD, ESQUIRE
` JESSAMYN BERNIKER, ESQUIRE
` WILLIAMS & CONNOLLY
` 725 12th Street N.W.
` Washington, D.C. 20005
`
`
` ON BEHALF OF PATENT OWNER:
` MICHAEL KIKLIS, ESQUIRE
` CHRISTOPHER RUCCIUTI, ESQUIRE
` KATHERINE CAPPAERT, ESQUIRE
` OBLON McCLELLAND MAIER
` & NEUSTADT
` 1940 Duke Street
` Alexandria, VA 22314
`
`
`Page 5
`
` J. Cole
` MR. KIKLIS: I guess let's do 09:08:01
` appearances. Michael Kiklis for 09:08:03
` WesternGeco, patent owner. With me is 09:08:07
` Chris Ricciuti and Kate Cappaert, all 09:08:10
` from the Oblon firm. Also, we have 09:08:14
` Simeon Papacostas from Kirkland & Ellis 09:08:16
` in the Chicago office. 09:08:20
` MR. FLETCHER: Tom Fletcher for 09:08:22
` petitioner Petroleum Geo-Services, Inc. 09:08:23
` Williams & Connolly. With me are my 09:08:26
` colleagues Jessamyn Berniker and Alec 09:08:29
` Swafford, and one of our summer 09:08:33
` associates, Marta Chlistunoff. We have 09:08:35
` observing by remote realtime feed Kevin 09:08:37
` Hart, Petroleum Geo-Services, Inc. 09:08:40
` DR. JACK H. COLE, Ph.D.,
` called as a witness, having been duly
` sworn, was examined and testified as
` follows:
` EXAMINATION
` BY MR. KIKLIS: 09:08:47
` Q. Good morning, Dr. Cole. 09:08:47
` A. Good morning. 09:08:49
` Q. How are you today? 09:08:49
`
`TSG Reporting - Worldwide 877-702-9580
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`WESTERNGECO Exhibit 2044, pg. 2
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
`Page 6
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` J. Cole
` A. I'm good. How are you? 09:08:50
` Q. Very good. So we're here to take 09:08:51
` your deposition today in three related cases. 09:08:59
` Is that your understanding? 09:09:04
` A. Yes, sir. 09:09:05
` Q. Okay. One of the cases is 09:09:06
` IPR2014-01478 for the 729,520 patent. Is that 09:09:08
` your understanding? 09:09:19
` A. May I see the documents? 09:09:24
` Q. Sure. I'm going to hand you your 09:09:26
` three declarations in these matters. And we 09:09:29
` will be referring to them of course during the 09:09:36
` course of this deposition. This has already 09:09:38
` been marked. I'm handing what's been marked 09:09:43
` already as Exhibit 1003 in the -- let me get 09:09:46
` the right translation here -- in the 1478 IPR. 09:09:55
` A. Is it okay if I write on the front of 09:10:10
` this? 09:10:12
` Q. Yeah, absolutely. In fact, you 09:10:12
` should probably write on there IPR2014-014 -- 09:10:14
` A. Just a minute. I'll write that at 09:10:19
` the top. "IPR." 09:10:21
` Q. 2014. 09:10:22
` A. 2014. 09:10:23
`
`Page 8
`
` J. Cole
` Q. Now I'm going to hand you what's been 09:11:22
` marked as Petitioners' Exhibit 1003 -- 09:11:24
` A. This is the same thing. 09:11:32
` Q. It's actually in a different case. 09:11:34
` A. Oh, I'm sorry. Whatever. 09:11:34
` Q. Different case. 09:11:35
` A. I'm sorry. 09:11:36
` Q. No problem. And this is from the 09:11:37
` case number IPR2014-01477. 09:11:42
` A. Would you repeat that again? 09:11:50
` Q. Sure. Actually, here's your depo 09:11:52
` notice for this case, for that particular case. 09:11:54
` You can copy it right off of there. 09:11:57
` Any objections, counsel? 09:11:59
` MR. FLETCHER: Are you marking that 09:12:00
` as an exhibit? 09:12:00
` MR. KIKLIS: No, I just want him to 09:12:02
` copy it off, that's all. 09:12:04
` MR. FLETCHER: That's fine. 09:12:07
` THE WITNESS: That's very helpful. 09:12:08
` MR. KIKLIS: A lot of numbers to be 09:12:13
` thrown around here. I want to be sure 09:12:13
` we get it right. 09:12:15
` THE WITNESS: This is in regards to 09:12:17
`
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` J. Cole
` Q. 1478. 09:10:24
` A. 1478. 09:10:26
` Q. And if you look -- 09:10:27
` A. Wait just a minute. Sometimes I'm a 09:10:28
` little bit dyslexic. I tend to transpose 09:10:32
` numbers. 1478? 09:10:35
` Q. Sure. 09:10:37
` A. Okay. And the patent is 7,293,520? 09:10:38
` Q. Yes. 09:10:45
` A. That's what you refer to as the '520 09:10:45
` patent. 09:10:49
` Q. Exactly. 09:10:49
` A. Is that okay if I write that on here? 09:10:50
` Q. Sure. During the course of this 09:10:54
` deposition, what I'm going to prefer to refer 09:10:55
` to is the '520 patent case. 09:10:57
` A. Okay. 09:11:01
` Q. I'm not going to be referring to 09:11:01
` 1478. Okay? But we can all agree, I would 09:11:05
` like your agreement at least that when I'm 09:11:09
` referring to the '520 patent case, you 09:11:10
` understand that I'm referring to the case 09:11:13
` number IPR2014-01478. 09:11:16
` A. I understand. 09:11:22
`
`Page 9
`
` J. Cole
` '607? Is that what that says? 09:12:18
` MR. KIKLIS: Correct. 09:12:23
` THE WITNESS: You say this is 09:12:28
` from -- make sure I heard you. Did you 09:12:29
` say this is from a different deposition? 09:12:31
` MR. KIKLIS: No. If you flip 09:12:35
` open -- 09:12:37
` THE WITNESS: The one that I 09:12:38
` just -- 09:12:38
` MR. KIKLIS: Yes. 09:12:40
` THE WITNESS: So '607 B2. 09:12:46
` MR. FLETCHER: Different case 09:12:49
` numbers, but the case numbers don't 09:12:50
` exist on the covers yet. 09:12:52
` THE WITNESS: Oh, I see. 09:12:54
` MR. KIKLIS: Now I'm going to hand 09:12:55
` you what's been marked as Exhibit 1003 09:12:56
` in the IPR2014-01475 IPR relating to 09:13:17
` U.S. Patent Number 7,162,967. Here is 09:13:25
` your deposition notice for that case. 09:13:30
` You can copy off the numbers if you 09:13:33
` like. 09:13:35
` A. Just a second. I think I got the 09:13:37
` number off there. IPR2014-01475? 09:13:38
`
`TSG Reporting - Worldwide 877-702-9580
`
`3
`
`WESTERNGECO Exhibit 2044, pg. 3
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
`Page 10
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` J. Cole
` Q. Correct, correct. So for the balance 09:13:43
` of this deposition, I'm going to be referring 09:13:46
` to your '967 declaration because that's your 09:13:50
` declaration dealing with the '967 patent. 09:13:54
` A. Is this the declaration I'm holding 09:13:59
` in my hand? 09:14:00
` Q. That is correct. And then for the 09:14:03
` declaration that you did with respect to the 09:14:04
` '607 patent, I'll refer to that as the '607 09:14:06
` declaration. 09:14:10
` A. That's this one? 09:14:11
` Q. Correct. And then with respect to 09:14:12
` your declaration for the '520 patent, I'll be 09:14:15
` referring to that, the '520 declaration. 09:14:21
` A. This document? 09:14:23
` Q. Yes. So what I'm trying to get 09:14:25
` across, Dr. Cole, is for the balance of your 09:14:28
` deposition, I'm going to be referring to the 09:14:29
` patent numbers, not necessarily the IPR 09:14:32
` numbers. Okay? 09:14:34
` A. That would be very helpful. 09:14:35
` Q. Yes. I think it would be easier for 09:14:36
` everybody. 09:14:38
` A. Okay. 09:14:39
`
`Page 12
`
` J. Cole
` Q. And did you agree to testify 09:15:43
` truthfully and honestly when you drafted that 09:15:46
` declaration? 09:15:49
` A. Yes. 09:15:50
` Q. Okay. Let's move to the third one. 09:15:51
` Could you identify that for us? 09:15:53
` A. '520 patent. 09:15:55
` Q. That's your declaration in the '520 09:15:57
` patent case? 09:15:59
` A. Yes, sir. 09:16:06
` Q. Okay. Did you sign that declaration? 09:16:07
` A. Yes, sir, I did. 09:16:09
` Q. And did you agree to testify 09:16:10
` truthfully and honestly in your testimony for 09:16:13
` that declaration? 09:16:16
` A. Yes, sir. 09:16:17
` Q. So during the course of this 09:16:23
` deposition, I'll be referring to "these cases" 09:16:25
` sometimes, in which case I'm referring to all 09:16:30
` three of those of the cases for which you did 09:16:32
` declarations. Okay? 09:16:35
` A. Let me make sure I understand what 09:16:37
` you're saying. These three are different 09:16:39
` cases. 09:16:41
`
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` J. Cole
` Q. Okay. So since I've handed you these 09:14:40
` exhibits, why don't you go one at a time and 09:14:44
` tell me for the first one that you have in your 09:14:47
` hand -- 09:14:50
` A. The one I have in my hand is the 09:14:51
` '967. 09:14:52
` Q. What is it? It's the '967 09:14:53
` declaration? Okay. Is that your declaration, 09:14:56
` sir? 09:15:00
` A. Yes. 09:15:03
` Q. Okay. Did you sign that? 09:15:03
` A. Yes. 09:15:14
` Q. And when you signed that, you 09:15:14
` understood that you were under oath and had to 09:15:16
` testify truthfully? 09:15:18
` A. Yes, sir. 09:15:19
` Q. Okay. Now if you could pick the next 09:15:20
` one up and identify that for us. 09:15:22
` A. '607 patent. 09:15:26
` Q. Okay. Is that your declaration for 09:15:28
` the '607 patent case? 09:15:30
` A. Yes, it is. 09:15:41
` Q. And did you sign that? 09:15:41
` A. Yes, sir. 09:15:42
`
`Page 13
`
` J. Cole
` Q. They are. 09:16:41
` A. Okay, good. 09:16:42
` Q. That's why you wrote down different 09:16:43
` case numbers on the top of each. 09:16:45
` A. I understand that, thank you. 09:16:46
` Q. And you testified in February about 09:16:47
` three different cases. Do you remember that? 09:16:50
` A. February of this year? Let me -- 09:16:57
` Q. February of 2015, did you have a 09:17:02
` deposition related to these patents? 09:17:03
` A. I would have to check my notes, but 09:17:06
` I -- I think that's correct. 09:17:09
` Q. Okay. 09:17:11
` A. I don't have my calendar with me. 09:17:12
` Q. That's okay. 09:17:13
` A. But I did this year, so I believe it 09:17:14
` was. I'm sorry, go ahead. 09:17:17
` Q. How many times have you ever been 09:17:19
` deposed? 09:17:20
` A. One. 09:17:20
` Q. One? So -- and that other deposition 09:17:21
` was with respect to the '607, the '967 and the 09:17:24
` '520 patents; right? 09:17:28
` A. That's correct. 09:17:29
`
`TSG Reporting - Worldwide 877-702-9580
`
`4
`
`WESTERNGECO Exhibit 2044, pg. 4
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
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` J. Cole
` Q. And those -- that deposition also 09:17:30
` dealt with IPRs for those patents? 09:17:33
` A. Cases. 09:17:39
` Q. Correct. 09:17:39
` A. Yes, sir. 09:17:40
` Q. Now, you've been sworn in today. Do 09:17:44
` you understand what that means, sir? 09:17:45
` A. Yes, sir. 09:17:49
` Q. That means you've got to testify 09:17:49
` truthfully and honestly; correct? 09:17:52
` A. Correct. 09:17:54
` Q. And if you do not testify truthfully 09:17:54
` and honestly, then you could be subject to a 09:17:56
` charge of perjury. Do you understand that? 09:17:59
` A. Yes, sir. 09:18:02
` Q. Okay. I'm going to be asking you a 09:18:02
` series of questions today, and if at any point 09:18:05
` my questions are ambiguous, unclear, please 09:18:07
` just let me know and I'll try to rephrase them 09:18:12
` so that you can understand the question and 09:18:16
` answer it. Okay? 09:18:18
` A. Okay. 09:18:21
` Q. If at any point you need to take a 09:18:22
` break, it's absolutely fine as long as there 09:18:25
`
`Page 16
`
` J. Cole
` Q. I think that's something you'd 09:19:20
` remember. 09:19:22
` Have you met Dr. Evans? 09:19:29
` A. No, sir. 09:19:32
` Q. Do you know who Dr. Evans is? 09:19:33
` A. Yes, sir. 09:19:35
` Q. Who is he? 09:19:35
` A. He's a engineer -- I just know a 09:19:38
` little bit about it. I -- I think when I heard 09:19:42
` that he was going to be another witness, I 09:19:47
` Googled, if you will, his information. And as 09:19:55
` I understand, he's a professor of petroleum 09:20:00
` engineering in Australia somewhere, a 09:20:03
` university there. 09:20:09
` Q. What else do you know about 09:20:10
` Dr. Evans? 09:20:12
` A. I don't recall without refreshing 09:20:15
` myself because I was impressed, as I recall, at 09:20:19
` the things he'd done. He has a pretty -- 09:20:24
` especially because he's an academic, as I at 09:20:28
` least used to be, so I was very much interested 09:20:32
` in that. 09:20:34
` And the other thing is I try to 09:20:35
` network with people who are in this industry. 09:20:37
`
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` J. Cole
` isn't a question pending. We will try to take 09:18:27
` a break every hour or so, so you can stretch 09:18:29
` your legs, we can all stretch our legs and 09:18:32
` whatnot. Fair enough? 09:18:35
` A. Fair enough. 09:18:37
` Q. So as long as -- if you need to take 09:18:37
` a break for whatever reason, as long as there 09:18:39
` isn't a question pending, we can do that. 09:18:41
` Now, sir, are you under any 09:18:45
` medication or the influence of any substance 09:18:46
` whatsoever that would prevent you from 09:18:47
` testifying completely and honestly and 09:18:51
` truthfully today? 09:18:54
` A. Not to my knowledge. 09:18:55
` Q. Okay. And have you ever been 09:18:57
` diagnosed with any condition whatsoever that 09:18:58
` would affect your cognitive abilities or your 09:19:00
` memory? 09:19:04
` A. Not that I'm aware of. 09:19:05
` Q. And forgive the next question, but I 09:19:08
` have to ask it. Have you ever been arrested, 09:19:09
` sir? 09:19:11
` A. No, sir, not to my -- not to my 09:19:15
` remembrance. 09:19:18
`
`Page 17
`
` J. Cole
` And I almost went to Australia one year, so I 09:20:40
` thought if I ever go back, I -- he's one person 09:20:45
` I really want to look up. 09:20:47
` Q. When you refer to "this industry," 09:20:49
` what industry are you referring to? 09:20:50
` A. The -- well, let me preface that 09:20:54
` remark about what I do. My field is -- is 09:20:56
` what's called subsurface diagnostic and 09:21:00
` imaging, and that covers the spectrum of what 09:21:04
` we do to try to determine what's beneath the 09:21:09
` earth and where it is. And I'm also a 09:21:15
` petroleum engineer by education and training. 09:21:19
` He's a petroleum engineer. So we -- we have 09:21:26
` more than one area. We have the engineering 09:21:30
` aspect of it, then there -- there are more than 09:21:33
` one aspect of -- of geophysics or so forth. 09:21:36
` There's -- there's called upstream and 09:21:40
` downstream, if you will. 09:21:42
` The upstream has to do with -- they 09:21:44
` used to call it expression production, then 09:21:47
` they changed it to, what was it, like searching 09:21:51
` and finding, or finding and producing. 09:21:54
` But I think both of us work in -- in 09:21:58
` those two areas. So I think that that's what 09:21:59
`
`TSG Reporting - Worldwide 877-702-9580
`
`5
`
`WESTERNGECO Exhibit 2044, pg. 5
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
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` J. Cole
` I'm referring to when I talk about the areas 09:22:06
` that we work in. 09:22:10
` Q. So when you refer to "this industry," 09:22:12
` you're referring to petroleum engineering? Is 09:22:13
` that what you're saying? 09:22:17
` A. Well, this industry is very 09:22:18
` comprehensive in that there are people involved 09:22:20
` from industries, there are private consultants, 09:22:29
` there are -- some companies, for example, the 09:22:34
` company that I worked with for years was 09:22:37
` involved in not only -- they were involved in 09:22:39
` petroleum engineering, they were involved in 09:22:42
` refining, they were involved in pipelines, they 09:22:43
` were involved in exploration. They were a -- a 09:22:45
` leader and a pioneer in -- in a number of the 09:22:49
` geophysical concepts. They were -- almost 09:22:52
` could be called a total integrated company. 09:22:58
` So would you repeat your question 09:23:01
` again? 09:23:02
` Q. First of all, I'm not looking for a 09:23:03
` history lesson of the various industries that 09:23:06
` may relate to this case. 09:23:09
` What I am looking for is simply what 09:23:10
` industries you were referring to when you used 09:23:13
`
`Page 20
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` J. Cole
` A. Not that I recall. 09:24:52
` Q. Now, you did review Dr. Evans's 09:25:02
` declaration in these cases, didn't you? Let me 09:25:06
` start over. 09:25:10
` Do you understand that Dr. Evans is 09:25:12
` an expert witness for PGS in these cases? 09:25:14
` A. Yes, sir. I understand that. 09:25:21
` Q. Did you read his declaration in these 09:25:21
` cases? 09:25:23
` A. Yes, yes, I read at least one, 09:25:27
` maybe -- I think I read them all. I would have 09:25:29
` to -- let me refer to -- I think this is common 09:25:34
` to all my declarations. 09:25:49
` The one I have in front of me is the 09:25:50
` '520 patent. And if you refer to paragraph 26, 09:25:52
` it says, "To be clear, I've not been asked to 09:26:05
` form an opinion as to whether certain claims 09:26:07
` are anticipated or rendered obvious. I 09:26:09
` understand that those issues are addressed in 09:26:12
` Dr. Evans's declaration." 09:26:16
` So if I read Dr. Evans's declaration, 09:26:18
` it would not have been to address the issues 09:26:26
` that he addressed but, rather, what I've been 09:26:30
` asked to. 09:26:33
`
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` J. Cole
` the word "this industry" when referring to 09:23:15
` Dr. Evans being in the same industry as you. 09:23:19
` So -- So can you answer that question, please? 09:23:22
` MR. FLETCHER: Objection. 09:23:24
` A. When one says "this industry," one -- 09:23:31
` well, you can interpret it a number of ways, 09:23:36
` from the totality of the set of things or a 09:23:42
` subset. And I was referring to the totality of 09:23:46
` things that involve what Dr. Evans and I do, 09:23:51
` which include exploration, petroleum, geology, 09:23:57
` environments, different environments. 09:24:05
` So I think -- I don't know how to 09:24:09
` answer it except to say that it -- it's -- my 09:24:10
` perception is that Dr. Evans and I have a lot 09:24:15
` in common, and therefore, I would like to meet 09:24:20
` him so that I would enlarge my network of 09:24:26
` people that I know and learn from and give 09:24:28
` information to and so forth. 09:24:33
` BY MR. KIKLIS: 09:24:34
` Q. Have you ever spoken to Dr. Evans or 09:24:35
` communicated with him in any way? 09:24:37
` A. I have not. 09:24:40
` Q. Have you ever heard of Dr. Evans 09:24:47
` before beginning work on these cases? 09:24:48
`
`Page 21
`
` J. Cole
` So because those are separate issues, 09:26:36
` I didn't understand that studying his 09:26:39
` declaration in detail would be significant to 09:26:45
` what I said. 09:26:48
` Q. Okay. So you read Dr. Evans's 09:26:50
` declaration in each of the cases but didn't 09:26:53
` study them in detail. Is that your testimony? 09:26:58
` MR. FLETCHER: Objection. 09:27:00
` A. I don't remember. It's been a while 09:27:10
` since I looked at those. 09:27:11
` BY MR. KIKLIS: 09:27:13
` Q. So sitting here today, sir, you don't 09:27:17
` have any recollection of reading Dr. Evans's 09:27:18
` declarations in these cases; is that correct? 09:27:21
` MR. FLETCHER: Objection. 09:27:24
` MR. KIKLIS: What's your objection? 09:27:27
` MR. FLETCHER: Well, I'm not 09:27:29
` supposed to give speaking objections, 09:27:30
` but if you would like me to explain it, 09:27:32
` I'm happy to. It's that you're 09:27:34
` misstating his prior testimony. He said 09:27:36
` he reviewed them, but he doesn't 09:27:38
` remember what parts or in what depth. 09:27:40
` Now you're saying does he remember not 09:27:42
`
`TSG Reporting - Worldwide 877-702-9580
`
`6
`
`WESTERNGECO Exhibit 2044, pg. 6
`PGS v. WESTERNGECO
`IPR2014-01477
`
`

`
`Page 22
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`Page 23
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` J. Cole
` having reviewed them. That's -- 09:27:44
` MR. KIKLIS: Thank you, counsel. 09:27:48
` BY MR. KIKLIS: 09:27:49
` Q. Do you recall reading Dr. Evans's 09:27:50
` declarations? 09:27:52
` A. When you say "recall," I recall that 09:27:53
` I read them. I don't remember when, and I 09:27:56
` don't remember them in detail. 09:28:00
` Q. When you read them, I think you 09:28:15
` testified a little earlier that you didn't 09:28:17
` study them. Is that correct? 09:28:19
` A. "Study" again is a pretty broad term. 09:28:23
` And to the extent that -- that I would study 09:28:32
` them to understand the -- exactly what -- 09:28:36
` here -- here's the thing. Let me preface this, 09:28:39
` or interject, the -- the thought that Dr. Evans 09:28:42
` had some different experiences that he had than 09:28:47
` I did. 09:28:51
` He -- he planned surveys. I 09:28:51
` understand that he was on vessels and those 09:28:55
` sorts of things to a greater extent than I was. 09:28:58
` So when he testified about -- about those 09:29:03
` things that he was familiar with that I would 09:29:05
` not have been familiar with, I was -- had my 09:29:09
`
`Page 24
`
` J. Cole
` the reference documents. I -- I don't 09:30:41
` understand the question more than that, how 09:30:47
` would I prepare. I -- 09:30:50
` BY MR. KIKLIS: 09:30:51
` Q. Well, you -- you testified that you 09:30:52
` met with your attorneys; is that correct? 09:30:53
` A. Yes. 09:30:57
` Q. Okay. How long did you meet with 09:30:57
` your attorneys? 09:30:59
` A. How long? 09:31:00
` Q. Yes, sir. 09:31:01
` A. In what time frame? 09:31:02
` Q. In preparation for this deposition. 09:31:04
` Let me start over. 09:31:08
` A. Well, I just came -- 09:31:09
` Q. Let me just rephrase the question. 09:31:10
` In preparation for today's deposition, sir, how 09:31:12
` long did you meet with your attorneys? 09:31:14
` A. I'm going to have to recall, because 09:31:25
` I have been working pretty intensely for a 09:31:27
` number of days now. As I recall, we met 09:31:34
` Friday. Monday, Tuesday, Wednesday. I guess 09:31:37
` that would be four days. 09:31:43
` Q. And how many hours did you meet each 09:31:44
`
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