CONFIDENTIAL
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ----------------
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-----------------------------------------------------
` UMICORE AG & CO. KG,
` Petitioner
` v.
` BASF CORPORATION,
` Patent Owner
`
` Cases IPR2015-01121, -01125
` Patent 7,601,662
` Cases IPR2015-01123, -01124
` Patent 8,404,203
`-----------------------------------------------------
`
` CONFIDENTIAL
` DEPOSITION OF MICHAEL TSAPATSIS, Ph.D.
` Tuesday, April 12, 2016
`
`REPORTED BY:
`DANA S. ANDERSON-LINNELL
`Job no: 16070
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`CONFIDENTIAL
`Page 2
` CONFIDENTIAL DEPOSITION OF MICHAEL TSAPATSIS, Ph.D.,
` taken on Tuesday, April 12, 2016, commencing at
` 9:01 a.m., at the Hyatt Regency, 1300 Nicollet Mall,
` Minneapolis, Minnesota, before Dana S.
` Anderson-Linnell, a Notary Public of and for the
` State of Minnesota.
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` APPEARANCES (continued):
`
` On Behalf of BASF Corporation:
` Anish R. Desai, Esquire
` WEIL, GOTSHAL & MANGES, LLP
` 1300 Eye Street, NW, Suite 900
` Washington, DC 20005
` Phone: 202.682.7000
` Email: anish.desai@weil.com
`
` ALSO PRESENT: Dr. Stefan Retzow, Umicore
` Dr. Frank-Walter Schütze, Umicore
`
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`Page 3
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`Page 5
`
` INDEX
`
` WITNESS: Michael Tsapatsis, Ph.D. PAGE
` EXAMINATION BY:
` Mr. Herman 8
` Mr. Desai 184
`
` INSTRUCTIONS NOT TO ANSWER: (None.)
`
` PRODUCTION REQUESTS: (None.)
`
` INDEX OF MARKED EXHIBITS:
`
` Exhibit 1018 - Graph labeled '662 Patent:
` Examples 1, 1A, 2-9, 12, 13, 16, 17 99
`
` INDEX OF PREVIOUSLY MARKED EXHIBITS:
`
` Exhibit 1001 - IPR 2015/1121, U.S. Patent
` 7,601,662 52
`
` Exhibit 1001 - IPR 2015/1123, U.S. Patent
` 8,404,203 52
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` APPEARANCES
`
` On Behalf of the Umicore AG & Co. KG:
` K. Patrick Herman, Esquire
` Elizabeth Gardner, Esquire
` ORRICK, HERRINGTON & SUTCLIFFE, LLP
` 51 West 52nd Street
` New York, NY 10019-6142
` Phone: 212.506.5000
` Email: pherman@orrick.com
` egardner@orrick.com
`
` (Appearances continued on next page)
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`CONFIDENTIAL
`Page 6
` INDEX OF PREVIOUSLY MARKED EXHIBITS PAGE
` (continued):
`
`Page 8
`
` MICHAEL TSAPATSIS, Ph.D.,
` called as a witness, being first duly sworn, was
` examined and testified as follows:
` EXAMINATION
` BY MR. HERMAN:
` Q. Good morning, Doctor. Is it Dr. Tsapatsis?
` A. Yes.
` Q. Did I get that right?
` A. Right.
` Q. My name is Patrick Herman, and I am with the
` law firm of Orrick, Herrington and Sutcliffe.
` And I'm here today on behalf of Umicore. And
` with me are Elizabeth Gardner, also from Orrick,
` and Stefan Retzow and Frank Mr. Schütze, both
` from Umicore.
` Have you ever been deposed before, Doctor?
` A. No. This is the first time.
` Q. So just before we begin, just a couple of
` things to keep in mind. The first is it would be
` great if whenever you're answering a question to
` respond orally as opposed to shaking your head or
` making some other nonverbal response.
` Is that okay?
` A. That is okay.
` Q. And then the second is we should both try
`Page 9
` our best to wait until each other are finished,
` me asking my question before you respond. And
` I'll do the same for you. I'll wait until you're
` done providing your answer before asking another
` question.
` Is that fine?
` A. That is fine.
` Q. And the last is if you have any trouble
` understanding my question, if there's a part of
` it that's unclear to you, please feel free to let
` me know, and I'll try to rephrase.
` Is that okay?
` A. That is okay.
` Q. Okay. So, Doctor, did you meet with anyone
` today in preparation for your deposition?
` A. Today?
` Q. Just in general, at any time.
` A. I met with Anish.
` Q. Is he the only one you met with in
` preparation?
` A. Yes.
` Q. And when was that meeting?
` A. That was yesterday.
` Q. Approximately how long?
` A. Maybe two hours.
`
` Exhibit 1002 - U.S. Patent 4,046,888 134
`
` Exhibit 1003 - U.S. Patent 4,503,023 134
`
` Exhibit 1004 - U.S. Patent 6,709,644 134
`
` Exhibit 1005 - U.S. Patent Application
` 2006/0039843 120
`
` Exhibit 1007 - Siting of the Cu+ ions in
` dehydrated ion exchanged synthetic and natural
` chabasites: a Cu+ photoluminescence study 134
`
` Exhibit 1010 - U.S. Patent 4,961,917 136
`
` Exhibit 1015 - Declaration of Dr. Frank-Walter
` Schütze 160
`
` Exhibit 2004 - Second Declaration of Pramod
` Ravindran 37
`
`Page 7
` INDEX OF PREVIOUSLY MARKED EXHIBITS PAGE
` (continued):
`
` Exhibit 2011 - Second Declaration of Ahmad
` Moini, Ph.D. 34
`
` Exhibit 2012 - Nature of active species in
` copper-based catalysts and their chemistry of
` transformation of nitrogen oxides 166
`
` Exhibit 2018 - Declaration of Dr. Michael
` Tsapatsis 14
`
` Exhibit 2019 - HIGHLY CONFIDENTIAL -
` ATTORNEYS' EYES ONLY, Declaration of
` Dr. Ahmad Moini 39
`
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`CONFIDENTIAL
`Page 10
` Q. Okay. Did you review any documents that
` refreshed your recollection during the meeting?
` A. Yes. I reviewed my declaration.
` Q. Okay. Anything else?
` A. The associated documents that I cite in my
` declaration.
` Q. Okay. Did you talk with anyone who was not
` present besides Anish?
` A. No, I didn't.
` Q. Okay. Now, I would like to spend a little
` time talking about your background and the work
` that you've done. And I don't want to go through
` your entire work and academic history; so perhaps
` maybe the last 15 years or so.
` Is that okay?
` A. That is okay.
` Q. Let's start maybe in about 2002. What were
` you doing in 2002?
` A. 2002, I was a professor at University of
` Massachusetts at Amherst.
` Q. Okay. And what department were you
` associated with?
` A. Chemical engineer.
` Q. And generally did you have any research that
` you were focusing on at the time?
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`Page 12
`
` with?
` A. Chemical engineering and material science.
` Q. And in 2003, what was your research focused
` on?
` A. On zeolite synthesis for absorption,
` separation and catalysis.
` Q. And when you say "catalysis," what do you
` mean by that?
` A. Accelerating reactions using zeolite
` catalysts, improving selectivity of reactions and
` making the materials that will do this
` accelerations and improvements of selectivity.
` Q. Are there any particular reactions you were
` focused on?
` A. We are focusing on hydrocarbon processing.
` We have focus on processing of tail gases of the
` Claus tail-gas process. And also we have
` reactions on -- we're studying reactions related
` to biomass, conversion to valuable products,
` chemicals and fuels.
` Q. And that was in 2003?
` A. That was starting in 2003.
` Q. Okay. And how long did that particular
` research work continue?
` A. It continues until now.
`
`Page 11
`
` A. Yes. I was focusing on research on
` zeolites.
` Q. Anything in particular about zeolites?
` A. My research in zeolites at the time was on
` zeolite membranes, zeolite absorbants and
` synthesis of zeolite catalysts.
` Q. And did you write papers about those
` particular topics in the 2002 time frame?
` A. Yes, I wrote papers.
` Q. And how long were you a professor at the
` University of Massachusetts?
` A. From 1994.
` Q. And when did you stop working there?
` A. 2003.
` Q. Okay. And did your area of research change
` at all from 2002 to 2003?
` A. No. My area of research did not change.
` Q. Okay. So still those same topics with
` respect to zeolites?
` A. Yes.
` Q. Okay. Then what did you do in 2003?
` A. I moved to the University of Minnesota.
` Q. Okay. And what was your position there?
` A. Professor.
` Q. And what department were you associated
`
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`Page 13
` Q. Okay. You say you've been researching those
` same topics, the synthesis absorption and
` catalysis with respect to zeolites. And with
` respect to catalysis, those areas of catalysis
` that you mentioned to me?
` A. Uh-huh. Yes.
` Q. And that work has been continuing since
` about 2003 until the present?
` A. Yes.
` Q. Okay. Now, in that 2003 to the present time
` frame, are there any particular problems with
` zeolites that you were focusing on?
` A. We are focusing on improving the stability
` of zeolites under hydrothermal -- exposure to
` hydrothermal conditions. We are looking at how
` to improve mass transfer in zeolites by creating
` mesoporosity in the zeolites. We are looking at
` how to improve the stability of zeolites in
` catalytic applications.
` Q. And you mentioned that you were working to
` improve stability of zeolites in catalytic
` applications. Did you write papers about that?
` A. Yes.
` Q. So if I look through the list of papers that
` are attached to your CV, am I going to see some
`4 (Pages 10 to 13)
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`CONFIDENTIAL
`Page 14
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` where that's specifically addressed?
` A. Yes.
` Q. Why don't we take a brief look at your --
` your CV is attached to your declaration, is that
` right?
` A. Yes.
` Q. And I'd like to show you what's been
` previously marked as Exhibit 2018 in all of the
` IPRs that are at issue. So that's IPR
` 2015/01121, 1123, 1124 and 1125. And I believe
` your CV is attached to the back of the document
` that I just handed to you.
` A. (Reviews document.) Yes.
` Q. And if you will turn to that for me.
` Starting at about page 085. Do you see the
` numbers in the lower right corner?
` A. Yes.
` Q. There's a list of papers that you've
` published, is that right?
` A. Yes.
` Q. And if you flip through, they're in date
` order.
` A. Yes.
` Q. You can find the papers that you started
` publishing at about 2003 beginning on page 95.
`Page 15
`
` A. Yes.
` Q. And at the bottom there there's a paper
` that's entitled Highly Crystalline Layered
` Silicate with Three-Dimensionally Microporous
` Layers?
` A. What page?
` Q. On page 95.
` A. Yes.
` Q. So that's one of your papers, right?
` A. Yes.
` Q. And that's about the crystalline structure
` and microporous layers of particular materials
` that you were working with?
` A. Yes.
` Q. And if you start reading up, at 157, item
` number 157 is Roles of Transients and Nucleation
` in Film Deposition Within a Support?
` A. Yes.
` Q. That doesn't say anything about hydrothermal
` aging in its title, is that right?
` A. Yes, it doesn't.
` Q. So 156, that's your next paper. That's
` Microstructural Optimization of the Zeolite
` Membrane for Organic Vapor Separation?
` A. Yes.
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`Page 16
` Q. Is that one about hydrothermal stability?
` A. No.
` Q. How about 155?
` A. No.
` Q. 154?
` A. No.
` Q. 153?
` A. No.
` Q. 152?
` A. No.
` Q. 151?
` A. No.
` Q. 150?
` A. No.
` Q. So that's all the papers you've published in
` 2003, but none of those are about hydrothermal
` stability, is that true?
` A. Yes, that's true.
` Q. And how about 150, is that about
` hydrothermal stability?
` A. No.
` Q. 149?
` A. No.
` Q. So can you find, looking at the papers of
` 2004, any paper in that collection in 2004 that's
`Page 17
`
` about hydrothermal stability of zeolite
` materials?
` A. In 2004, no.
` Q. How about in 2005?
` A. In 2005, no.
` Q. 2006?
` A. In 2006, no.
` Q. Okay. So we looked at 2003, 2004, 2005,
` 2006. And in those time -- that time period, you
` didn't write any papers relating to the
` hydrothermal stability of zeolite materials,
` right?
` MR. DESAI: Objection to form.
` THE WITNESS: Correct.
` BY MR. HERMAN:
` Q. Now, in that time period were you working in
` industry?
` A. No. I was working at the University of
` Minnesota at the time.
` Q. So you were not working to design exhaust
` gas treatment systems, right?
` A. No, I was not.
` Q. And you were not working to select catalysts
` for reducing nitrogen oxides in diesel engine
` exhaust, true?
`
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` A. True.
` Q. And you were not working to optimize the
` operation temperature, the flow rate or any other
` requirements or conditions of such a system, is
` that true?
` A. True.
` Q. And we just saw, looking at your papers,
` that you were not writing papers relating to the
` hydrothermal stability of zeolite materials used
` to treat diesel engine exhaust in the 2003 to
` 2006 time period, true?
` A. True.
` Q. So when was the first time after 2006 that
` you think you wrote a paper relating to the
` hydrothermal stability of zeolite materials?
` A. Can I find the paper? Just a moment.
` Q. Go ahead.
` A. It's paper number 29.
` Q. So 29 is entitled Long-Term Steam Stability
` of MWW Structure Zeolites?
` A. Yes.
` Q. What are MWW structure zeolites?
` A. It's one of the 231 framework types that we
` have studied regarding its hydrothermal
` stability.
`
`Page 19
` Q. Okay. So this paper was written in 2014,
` true?
` A. This paper was written in 2014. It was
` based on work that was done for about ten
` years --
` Q. Okay. And it relates --
` A. -- from a project that was funded by the
` Department of Energy.
` Q. Okay.
` A. And although the paper was written in 2014,
` we have reports to the Department of Energy that
` go from the beginning of that project. So it's
` not that this paper was written in 2014, but we
` are working on stability, thermal stability of
` zeolites and hydrothermal stability of zeolites
` for -- since the beginning of the DOE-funded
` project, of the Department of Energy-funded
` project where we studied the stability these
` materials. If you look at this paper, it has
` months of steam-stability testing, which requires
` that we start the work quite early. And then we
` finish the project and then we write the paper.
` I don't recall the exact date of the start of the
` DOE-funded project that funded this work, but I
` believe it was about ten years earlier than 2014.
`
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`Page 20
` So research was going on in my research group on
` stability of -- hydrothermal stability of
` zeolites. And as you know, the papers are coming
` after a long period. I'm particularly careful
` how I publish papers from my group. And the
` initial results are repeated many times so that
` we can eventually submit and publish a paper.
` I would also like to point out that we have
` a patent on number 13 [ph.], Regenerable System
` For the Removal of Sulfur Compounds From a Gas
` Stream, which refers to a different material for
` absorption of hydrogen sulfide. And the test
` that were performed in that project, which is
` funded by the ADNOC Group, we have studied the
` hydrothermal stability of zeolites with respect
` to tail gases from the Claus process, which
` involves the presence of water.
` Q. And so that patent that you just pointed me
` to relates to tail gases from the Claus process,
` right?
` A. Yes.
` Q. So it does not relate to treatment of the
` exhaust omitted by a diesel engine, true?
` A. Correct.
` Q. Okay.
`
`Page 21
` A. But your question was regarding hydrothermal
` stability studies. That's what I mention. And
` your question, the number of publications that I
` have with respect to the hydrothermal stability
` studies.
` Q. And the other paper --
` A. Just a moment.
` Q. Sorry. Excuse me.
` A. By going backwards through my publications,
` I got the implication that I did not study these
` because it was published in 2014. I just want to
` make clear that research in my group on
` hydrothermal steaming and evaluation of crystal
` structure effects of steaming and performance,
` not for NOx processing, but for related processes,
` including catalytic processing of hydrocarbons
` and Claus tail processing, have been going on for
` about a decade.
` Q. Uh-huh.
` A. And those can be found in various reports in
` addition to the publications that I list here.
` Q. So none of the papers and none of the
` patents that you pointed me to, however, relate
` to the hydrothermal stability of zeolites that
` are being used to reduce nitrogen oxides in
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` diesel engine exhaust, true?
` MR. DESAI: Objection to form.
` THE WITNESS: Correct. I have not
` performed research in my group on the ammonia SCR
` of NOx.
` BY MR. HERMAN:
` Q. So the first time that you ever wrote
` something that was published relating to the
` stability of zeolites for use in reducing
` nitrogen oxides in diesel engine exhaust would be
` your declaration in this case, true?
` MR. DESAI: Objection to form.
` THE WITNESS: Can you repeat the
` question.
` MR. HERMAN: Do you mind reading it
` back, please.
` (Whereupon, the court reporter read
` back the previous question.)
` THE WITNESS: I don't consider this a
` publication.
` BY MR. HERMAN:
` Q. But you understand, though, that your
` declaration is publicly available?
` A. But it's not a publication that I can list
` in my CV.
`
`Page 23
` Q. Okay. So the first time that you wrote a
` paper that is generally available to members of
` the public?
` A. I'm teaching reaction engineering. And I
` talk about -- I'm teaching reaction engineering.
` And I am talking about various processes where
` the NOx abatement is one of the processes that I
` teach. So I do not have a publication in the
` area, but I'm familiar with this process.
` Q. So my question was whether this declaration
` is the first time that you wrote a document that
` is available to the public relating to the
` hydrothermal stability of zeolites for use in
` reducing nitrogen oxides in diesel engine
` exhaust. Is that right? This declaration is the
` first document that you've written that is
` available to the public addressing that subject
` matter?
` A. Yes.
` Q. When were you first contacted regarding the
` subject matter of your declaration?
` MR. DESAI: Objection to form.
` THE WITNESS: I do not remember.
` BY MR. HERMAN:
` Q. Do you know who contacted you?
`
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` A. Anish.
` Q. Okay. Now, if you'll turn to section 2,
` paragraph 8 of your declaration.
` A. (Complies.)
` Q. And if it helps, that's the page that begins
` the 004 in the corner.
` A. Yes.
` Q. Did you find that?
` A. Yes.
` Q. This section is entitled Materials
` Considered, right?
` A. Yes.
` Q. Do you understand that you were to identify
` all information that you relied on that is
` material to your opinion in your declaration?
` A. Yes.
` Q. And is that what you've done in this
` particular section of your declaration?
` A. Yes.
` Q. So this section, this section 2 entitled
` Materials Considered, this section is inclusive
` of all of the information that is material to
` your opinion that you know of, true?
` A. True.
` Q. So without revealing the specifics of the
`Page 25
` discussions you've had with your attorneys, can
` you please give me a very high-level overview of
` your general understanding of your task in this
` particular case.
` A. Is to review declaration of Dr. Lercher and
` examine it with respect to the patents from BASF.
` Q. Okay. Now, in paragraph 8 of your
` declaration here, there are two tables. Do you
` see those? It's the same page that we were
` looking at.
` A. Uh-huh. Yes.
` Q. You found those tables?
` A. Yes.
` Q. And these tables are citing to various
` exhibits that were submitted by both petitioner
` and patent owner in these IPRs, correct?
` A. Correct.
` Q. Okay. And petitioner's exhibits begin with
` a 1. Do you see that?
` A. Yes.
` Q. And then the exhibits that were submitted by
` the patent owner begin with a 2. And those begin
` on page 5.
` A. Yes.
` Q. Do you see that?
`7 (Pages 22 to 25)
`
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`CONFIDENTIAL
`Page 26
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` A. Yes.
` Q. And some of those exhibits that were
` submitted by patent owner are patents and
` publications. Do you see that in that table that
` begins on page 5?
` A. Yes.
` Q. Okay. When was the first time that you
` reviewed those materials listed here that are
` associated with patent owner?
` A. I don't remember the exact date.
` Q. So was the first time that you reviewed
` those materials in connection with the
` preparation of your declaration?
` A. Can you repeat that question, please.
` Q. Was the first time that you reviewed the
` materials listed beginning on page 5 here, was
` that in preparation of your declaration?
` A. Yes.
` Q. So you have never read any of the published
` articles or patents that are listed here at any
` other time in your career besides when you were
` preparing your declaration, true?
` A. No. I don't remember if I have read. I
` read hundreds of papers every week. And I have
` certainly read the literature on copper, copper
`Page 27
` zeolites for NOx. And I have listened to talks.
` I have read the literature. But I don't remember
` studying the specific papers in detail.
` Q. Okay.
` A. But I am, for example, the editor of -- I
` was the editor of Microporous and Mesoporous
` Materials. I have received hundreds of papers
` that I have handled, which I read, and many of
` them deal with the subject. But I don't recall
` all the papers that I have read. The specific
` papers that are listed here I may have seen
` earlier or I may not.
` Q. So you have no specific recollection of
` seeing or reading any of the papers or patents
` that were submitted by patent owner, true?
` A. I don't have specific recollection of
` reading those patents prior to this case or any
` of this literature prior to this case. But if
` you ask me the same question about many other
` subjects, I will give you a similar answer. As I
` said, I read many, many papers every -- I read
` hundreds of papers every week.
` Q. So Exhibits 2001 through 2033 that are
` listed here on pages 5, 6 and 7 of your
` declaration, all of those were provided to you by
`
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`Page 28
` counsel, your attorneys in this particular IPR?
` MR. DESAI: Objection to form.
` THE WITNESS: I don't remember how
` the -- these papers were provided as references.
` Some of them, the starting point which references
` in Dr. Lercher's declaration and then cited
` within the references that were cited there. But
` I don't remember which papers were provided this
` way and which ones were found by doing the
` literature search.
` BY MR. HERMAN:
` Q. Okay. But you personally did not identify
` any of these documents yourself, is that true?
` A. No, it is not true. I did not say that.
` Q. So you identified some yourself?
` A. I identified some myself.
` Q. But you have no recollection of reading any
` of them before authoring your declaration in this
` case?
` MR. DESAI: Objection, misstates his
` testimony.
` THE WITNESS: Can you say that again.
` BY MR. HERMAN:
` Q. You told me before that you didn't have any
` recollection of reading any of these particular
`Page 29
` documents before authoring your declaration in
` this particular case, true?
` MR. DESAI: Objection, misstates his
` testimony.
` THE WITNESS: What I said is that I
` read many papers every week.
` BY MR. HERMAN:
` Q. Uh-huh.
` A. And it is not possible for me to remember
` all of the papers that I have read. But I have
` read papers in the area of catalytic conversion
` of NO.
` Q. So what I'm trying to get a sense of is
` whether any of these documents, Exhibit 2001
` through 2033, came from your files or whether
` they were provided to you by someone else.
` Do you understand?
` A. Yes, I understand. But I don't remember
` which papers came from me and which papers came
` from the references that came along with the
` declaration.
` Q. So can you point me to any that came from
` you?
` A. I have to look at my -- I don't have my
` notebooks with me where I -- how I -- I cannot do
`8 (Pages 26 to 29)
`
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`CONFIDENTIAL
`Page 30
`
`Page 32
` don't remember exactly the time, but it would be
` around that order of magnitude.
` Q. Now, how much time did you spend on this
` matter before preparing your declaration?
` A. As I mentioned, I'm familiar with the
` literature, and I'm an expert on zeolites, so all
` my life.
` Q. But specifically related to preliminary
` preparations and reviewing of materials provided
` to you by your attorneys, can you estimate how
` much time you spent on that?
` A. No, I don't remember. As I said about all
` this, my memory is not good. I have to look at
` my records. I come here with no records.
` Q. So was that included in your 20- to 30-hour
` estimate, is that the totality of time that you
` have spent in connection with this declaration?
` A. No. As I said, I'm familiar with the
` literature, and I have been familiar with the
` area.
` Q. Okay.
` A. So I have prior knowledge of the entire area
` of zeolites.
` Q. Have you prepared invoices that you have
` sent to BASF's attorneys?
`
`Page 33
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` that at this point.
` Q. So sitting here today, you're not able to
` point me to any of these that came from your
` files as opposed to your attorneys, true?
` A. I can point to you if I had access to my
` files.
` Q. How long approximately did it take to
` prepare your declaration?
` A. Maybe 20 hours or 30 hours.
` Q. And did you write all the words yourself?
` A. Yes, I did.
` Q. Okay. Now, your declaration cites a number
` of other declarations signed by other BASF
` declarants, true?
` A. Yes.
` Q. And if you look at that listing of exhibits
` that spans pages 5, 6 and 7, there are three
` declarations authored by a Mr. Moini?
` A. Yes.
` Q. That's Exhibits 2003, 2011 and 2019. Do you
` see those?
` A. Yes, 2003. The other one?
` Q. 2011.
` A. Yes. And which other one?
` Q. And 2019.
`
`Page 31
`
` A. Yes.
` Q. And then you also list a declaration by a
` Mr. Ravindran, that's 2004?
` A. Yes.
` Q. And there's a declaration by a Mr. Zones at
` 2009?
` A. Yes.
` Q. And a declaration by a Ms. Schmidt at
` 2034 -- actually --
` A. I don't have it.
` MR. HERMAN: It's not listed here.
` BY MR. HERMAN:
` Q. So that's not something you relied on since
` it's not listed here?
` A. I don't see 2034.
` Q. Great. So the declarations that you did
` look at, though, did your attorneys provide you
` with any information regarding those declarations
` beyond the declarations themselves?
` A. No other information beyond what is listed
` here.
` Q. Okay. Now, you told me that you spent about
` 20 to 30 hours preparing your declaration, is
` that correct?
` A. Again, I have to look at my records. I
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` A. Yes.
` Q. Do you know generally how many hours of work
` are reflected on those invoices?
` A. Again, I have to look at my record, but
` about the time that I mentioned.
` Q. Somewhere the range of 20 to 30 hours?
` A. 30 hours, something like that.
` Q. Now, moving back to the declarations that
` you've listed here on pages 5, 6 and 7, s