`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - - - - - - - - x
`Case Nos.
`YITA LLC,
`:
`Petitioner, : IPR2020-01139, IPR2020-01142
`: U.S. Patent Nos.
`v.
`: 8,382,186 and 8,833,834
`MACNEIL IP LLC,
`Patent Owner. :
`- - - - - - - - - - - X
`
`Interview of JANINA KAMINSKIENE
`Conducted Virtually
`Friday, July 2, 2021
`10:06 a.m. EDT
`
`Job No.: 382851
`Pages 1 - 113
`Reported by: Debra A. Whitehead
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`EX1051
`Yita v. MacNeil
`IPR2020-01139
`
`
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
`
`2
`
` Interview of JANINA KAMINSKIENE, conducted
`virtually.
`
` Pursuant to notice, before Debra Ann Whitehead,
`E-Notary Public in and for the State of Maryland.
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`3
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` A P P E A R A N C E S
` ON BEHALF OF PETITIONER:
` JASON A. FITZSIMMONS, ESQUIRE
` STEPHEN A. MERRILL, ESQUIRE
` R. WILSON POWERS, III, ESQUIRE
` STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
` 1100 New York Avenue, NW
` Suite 600
` Washington, DC 20005
` (202) 371-2600
`
`ON BEHALF OF PATENT OWNER:
` DAVID G. WILLE, ESQUIRE
` CLARKE STAVINOHA, ESQUIRE
` BAKER BOTTS LLP
` 2001 Ross Avenue
` Suite 900
` Dallas, Texas 75201-2980
` (214) 953-6595
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`4
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` A P P E A R A N C E S C O N T I N U E D
`ON BEHALF OF PATENT OWNER:
` JEFFERSON PERKINS, ESQUIRE
` PERKINS IP LAW GROUP, LLC
` 4200 Commerce Court, Suite 310
` Lisle, Illinois 60532
` (630) 505-1305
` - and -
` TIMOTHY M. SCHAUM, ESQUIRE
` DASPIN & AUMENT, LLP
` 300 South Wacker Drive, Suite 2200
` Chicago, Illinois 60606
` (312) 258-3792
`
`ALSO PRESENT:
` AUSTIN GRAY
` DINA HENNESSEY, Interpreter
` JAIMIE HENSLEY, A/V Technician
` VLADIMIR ORLOV, Check Interpreter
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
`
`5
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` C O N T E N T S
`INTERVIEW OF JANINA KAMINSKIENE PAGE
` By Mr. Fitzsimmons 6
` By Mr. Wille 102
`
` EXHIBITS MARKED IN PRIOR SESSIONS
` (Not Attached)
`INTERVIEW EXHIBIT PAGE
` Exhibit 2105 Photos of Foot Wells of 1984 97
` Lada Niva
` Exhibit 2031 English Translation of 20
` Declaration of Janina Kaminskiene
` Exhibit 2042 Declaration of Ryan Granger 91
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`6
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` P R O C E E D I N G S
` (DINA HENNESSEY, Interpreter, sworn.)
` EXAMINATION BY COUNSEL FOR PETITIONER
`BY MR. FITZSIMMONS:
` Q Hello, Ms. Kaminskiene. How are you
`today?
` A Thank you, not bad.
` Q Can you please state your full legal
`name, for the record.
` A Janina Kaminskiene, yes.
` Q Thank you. And so do you understand why
`you're here for the interview today?
` A I think so.
` Q And why is that?
` A To confirm certain designations of
`vehicle part in Niva vehicle, which what been
`manufactured since the beginning of the year and
`until presently, to confirm that they were
`unchanged and to verify certain distances; for
`example, distance between the seats, from the
`driver's seat to the middle, and from the middle
`to the passenger seat, at least in this particular
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`Transcript of Interview of Janina Kaminskiene
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`7
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`case that was the question presented to me by
`Mr. David, and I am ready to give this statement.
` Q Thank you. And so you understand this
`interview today is in connection with two
`declarations that you provided for a proceeding at
`the U.S. Patent and Trademark Office. Right?
` A Yes.
` Q And, for the record, the case numbers are
`IPR2020-01139 and IPR2020-01142.
` Is that your understanding?
` A Am I supposed to have something, some
`kind of paperwork related to this case, or is just
`the numbers of my declarations?
` Q You don't need anything right now. Those
`are the numbers of the proceedings. And maybe you
`don't know the proceeding numbers specifically.
`But if you can just confirm that you understand
`your declarations were provided for proceedings at
`the U.S. Patent and Trademark Office.
` A Yes, I made those verification statements
`in that matter.
` Q And the proceedings, they involve two
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`Transcript of Interview of Janina Kaminskiene
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`8
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`patents, U.S. Patent Number 8,382,186 and U.S.
`Patent 8,833,834.
` Have you reviewed those patents
`themselves?
` A No.
` Q Is it your understanding that MacNeil,
`IP, LLC, is the owner of those two patents?
` A Possibly.
` Q Okay. So you're not sure who is the
`owner of those patents.
` Is that correct?
` A No, personally I am of course not
`familiar with them. I just provided the
`information for which I am responsible. And where
`this information is going to be given further,
`that's a separate matter.
` Q Okay. Thank you.
` Have you ever provided a declaration for
`a legal or administrative proceeding before?
` A No, it never happened to me before.
` Q And so you have never served as a witness
`in a legal proceeding before.
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`9
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` Is that correct?
` A No, no.
` Q No, that's not correct; or, no, you have
`not served as a witness in a legal proceeding
`before?
` A No, I did not serve.
` Q Okay. Thank you. And is Russian your
`native language?
` A Yes, I graduated from secondary education
`school, I completed my education in Russian, and I
`also graduated from the trade school, technical
`trade school, also in Russian.
` Q And do you also speak English?
` THE WITNESS: So-so.
` A No, I almost don't. I do not speak the
`language freely, but I can understand a little
`bit.
` Q Okay. And do you speak any other
`languages?
` A I speak Lithuanian and Polish, and I know
`the basics of German.
` Q And which of those languages is your
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`10
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`native language?
` A Russian.
` Q And are you fluent in Lithuanian and
`Polish?
` A Yes. Otherwise I wouldn't have been able
`to work if I didn't know Lithuanian.
` Q And why is that?
` A Because all the documentation, all the
`programs are in Lithuanian language. I live in
`Lithuania, so it's necessary to know the language.
` Q And so I'm just going to go over a couple
`of rules for the rest of the interview today, so
`that we have an understanding today.
` So if you don't understand one of my
`questions, will you please tell me?
` A Yes, of course.
` Q And if you don't ask me to clarify a
`question, I'll assume that you understood it.
` Is that okay?
` A Yes.
` Q And the counsel for the patent owner
`might object to questions from time to time, but
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`11
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`you'll still need to answer that question.
` Do you understand that?
` A I understand.
` Q And I'll try to take a break every hour.
`Except if there's a question pending, I would just
`ask that you answer that question before we took a
`break.
` Is that okay?
` A No problems.
` Q And are you under the influence of
`anything such as medications that might make it
`difficult for you to understand and answer my
`questions today?
` A No. No.
` Q And is there any other reason that you
`can't provide your complete and accurate testimony
`today?
` A I don't see any such reason yet. I don't
`see any such reason.
` Q Thank you. And are you alone in the room
`that you're doing this interview in?
` A Yes.
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` Q And do you have any communication devices
`other than the computer that you're using for this
`remote interview?
` A My mobile phone.
` Q And I would just ask that you don't use
`your phone during this deposition.
` Do you agree to that? I'm sorry, during
`the interview.
` A Yes, I turned it off. I turned the sound
`off.
` Q Thank you. And so you're employed by
`LitLada Parts. Correct?
` A Yes. Yes.
` Q And how long have you been employed
`there?
` A I started working for this company since
`2009.
` Q And what is your current job title?
` A I'm the company director.
` Q And what does that role entail?
` A What does it entail? Well, it means I'm
`responsible, how should I put it, I'm responsible
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`Transcript of Interview of Janina Kaminskiene
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`13
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`for my work. I'm responsible for my subordinates,
`for everything that relates to all of our
`activities. The director is responsible for
`everything.
` Q So do you report to anyone within the
`company above you?
` A Just the stakeholder. He has 90 percent
`of shares in the company, I have ten.
` Q And so you're the only two stakeholders
`in the company then?
` A Yes, yes.
` Q And who's the majority stakeholder?
` A Would you like me to give the first and
`last name, or ...
` Q Yes, please.
` A Give me one second. I forgot. Give me
`one moment.
` Dimitri, Dimitri. Well, you know,
`honestly I just forgot his last name. He's a
`citizen of Belarus, so I need to open some
`documents to look it up.
` Q That's okay for now.
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`14
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` What are your day-to-day responsibilities
`at LitLada?
` A It's ordering parts from Russia, it's
`doing wholesale of those parts to Europe, we
`selling the parts to Europe and also to some other
`third countries. We have two managers in the
`company, so we distribute work between those
`managers. And I'm also responsible for all the
`communication with our clients who submitting some
`kind of requests to us.
` Q And did you have any previous job titles
`before your current one of company director?
` A In this company, no. I became the
`company director from the very beginning. But I
`have overall experience in this area, in this
`field, of about 25 years.
` I started from a simple manager, then I
`became a senior sales manager, and then I was
`elected to be the company director.
` Q And what company or companies did you
`work at before LitLada, then?
` A Orbet Dlada (phonetic). Orbet Dlada.
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`15
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`Then what was that? Vg Dlada.
` What else? I guess that will be about
`it. Maybe I shouldn't be even mentioning my work
`experience after I graduated from high school. I
`was working at the central statistical department,
`I was handling electronic computational machines,
`as they called them back then. And then when all
`the changes happened, when we started having
`co-ops and closed partnerships, I was invited to
`work at the company where I was handling all the
`parts.
` Q And so the other two companies you
`mentioned also sold auto parts.
` Is that correct?
` A They used to.
` Q Do they no longer exist?
` A Yes, those businesses got closed.
` Q Okay. And I take it from the names of
`those companies, they also sold parts for the Lada
`vehicles.
` Is that correct?
` A Yes. They just had different
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`16
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`stakeholders. And when the crisis happened in
`2000 -- 2000 what? The first one was in 1998,
`then there was another one in 2010. So those
`businesses got closed, and we created our own
`company. Well, not our own company, we have a
`different stakeholder. But we just continued
`working in this field.
` Q And so for the past 25 years you have
`been in the field of selling Russian auto parts.
` Is that correct?
` A Absolutely correct, yes.
` Q How many people are employed currently at
`LitLada?
` A Seven persons. Our company is small.
` Q And so you provide parts for vehicles
`made by Lada. Correct?
` A Yes.
` Q And that includes the Lada Niva.
` Correct?
` A Yes, primarily -- well, our biggest sales
`are in relation to this vehicle.
` Q And do you manufacture -- or do you sell
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`Transcript of Interview of Janina Kaminskiene
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`17
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`parts for other brands of vehicles?
` A Well, the other ones will be GAZelle,
`UAZ, UAZ Hunter, that's one of the modifications,
`GAZ-53. But that's quite rare we work with those
`vehicles because they are becoming historical
`vehicles. And there is not much supply of parts
`for those particular vehicles. Maybe there are
`some orders for Kamaz parts as well, but we only
`work on a order-by-order basis with those.
` Q And so what percentage of LitLada's parts
`sales are for the Lada Niva, would you say?
` A I think that would comprise about 70
`percent.
` Q And where does LitLada get its parts
`from?
` A From Russia, from Russia, from Belarus,
`and from China.
` Q And how many -- what percentage of the
`parts that you sell would you say are from Lada
`Nivas before 1993 model?
` A Well, that's an interesting question.
`Well, I don't think I will be able to give you the
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`Transcript of Interview of Janina Kaminskiene
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`18
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`exact answer percentage-wise. But the only thing
`that I can tell you is that the parts that's
`been -- that has been -- that have been
`manufactured since 1977, they still fit Niva
`vehicles, even manufactured as of today. Well,
`maybe up to 2016. Those are the same parts.
` Q And so after 2016 was there some change
`that the parts no longer fit the more current
`vehicles?
` A Well, I'm in the majority. There were
`some changes. There were some changes made to
`suspension, for example, the front suspension, the
`back suspension, to some outside tuning parts, for
`example. There were changes made to the mirrors,
`they're now adjustable, they have heating option.
`So there were some changes made to the exterior.
`And to the suspension as well, for example,
`electronic pedal was added that was not an option
`for Lada vehicles made in 1993 and 1994.
` Q And are the majority of your sales now to
`individuals, or are they wholesale?
` A Mostly we have whole sales. But of
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`19
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`course we also wouldn't refuse to serve individual
`clients as well.
` Q And you mentioned previously your
`education. It sounds like after high school you
`went to trade school.
` Is that correct?
` A Yes.
` Q And what was the trade school?
` A Electrical mechanics trade school.
` Q And did you receive a degree from that
`school?
` A Yes, in my -- yes, in my diploma it says
`that I am a technology specialist.
` Q In what type of technology?
` A At the time when I was graduating, I was
`a specialist in electronic computational machines,
`and we were working with Cimatron machines. They
`were pretty big and they were using punch cards,
`and we were inputting information into them.
` Q Did you receive any training in part
`design?
` A No.
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`20
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` Q Do you have any engineering experience?
` A I wouldn't say that, no. I'm not a
`manufacturer of auto parts. We are selling them,
`and we know which part would fit a specific
`vehicle.
` MR. FITZSIMMONS: Can I have the
`technician, please, pull up Exhibit 2031 from the
`1139 proceeding on the screen. And can we go to
`Page 5, please. And so this is the English
`version translation of Ms. Kaminskiene's
`declaration.
` (Exhibit 2031, previously marked, not
`attached.)
` MR. FITZSIMMONS: And so I'd like the
`technician to then please turn to page -- I'm
`sorry, you know, can we just let, can we just
`scroll through slowly Pages 5 through 12 here of
`the document for Ms. Kaminskiene to see.
` Q And, Ms. Kaminskiene, do you understand
`that this is the English translation of the
`declaration that you provided?
` A Yes.
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` MR. FITZSIMMONS: And then can we go to
`Page 146 of this document, which is, again,
`Exhibit 2031. And then we can scroll through to
`Page 154, please. Thank you.
` Q And, Ms. Kaminskiene, is that your
`signature here on Page 154 of the PDF?
` A Yes. Yes, of course.
` Q And when did you sign this document?
` A Well, the date is right there. March 18,
`2021.
` Q Thank you. And you reviewed this
`declaration before you signed it.
` Is that correct?
` A Yes, of course.
` MR. FITZSIMMONS: And, David, can we
`stipulate that the Exhibit 2031 in the 1142
`proceeding is identical? I'm also happy to pull
`it up, if you'd like.
` MR. WILLE: Yes, we so stipulate.
` MR. FITZSIMMONS: Thanks, David. That
`will just save us a little bit of time.
` Q So after the signature page, there is
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`Exhibit A.
` MR. FITZSIMMONS: Can we turn to the next
`page, and the one after that.
` And the next page, please, the Page 156
`of the declaration.
` Q What is Exhibit A?
` A Is this the question for me?
` Q Yes.
` A This is the part that installed in a Niva
`vehicle. It's a foot well trim piece for the left
`and right side, that's a set.
` Q And did you, personally, find Exhibit A
`on the internet?
` A No. Well, we have those parts. I guess
`I could even ask someone to go bring them from our
`warehouse. We have them in stock.
` Q But this screen shot, did you take this
`screen shot on the computer?
` A No. Yes, okay, please interpret.
` Q Do you know who did?
` A I think it was taken by our client to
`whom we supply parts.
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`23
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` Q And what client is that?
` A It's Lada Power. Lada Power. This is a
`Lada Power firm, because the logo type on this
`page is of our client. And this makes me believe
`that this is the -- well, I'm forgot, I forgot the
`word I'm looking for. This is the presentation of
`the parts that he has in stock for selling online.
` Q And who did you receive Exhibit A from?
` Did counsel provides that to you?
` A Well, I'm thinking some time has passed
`already. I think maybe I myself, I think maybe I
`found it myself. I don't quite remember now. But
`it's possible that I found this website on the
`internet just to look up that part to see what it
`looks like. Maybe I did it myself. But I do not
`remember exactly now.
` Q Had you ever visited this website
`previously, before your declaration?
` A Yes, of course.
` Q So this is a website that you are
`familiar with.
` Is that correct?
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`24
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` A Yes.
` Q Have you purchased parts previously, or
`have you -- I'm sorry, have you purchased parts
`from this website before?
` A No; we are a supplier.
` Q And so have you supplied parts to Lada
`Power before?
` A Yes, of course. We are still currently
`supplying it to them.
` Q And do you know when the screen shot for
`this Exhibit A was acquired?
` A I am unable to answer this question.
` Q Why is that?
` A Because I can't remember, I need to look
`it up in the correspondence to see when I was
`sending that file, which proves what part is
`installed in that vehicle, in the body of that
`vehicle.
` Q And are these trim pieces on every Lada
`Niva vehicle?
` A No; just -- just on Niva. This
`particular shape applies only to Niva models. But
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`25
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`different Lada models would have different shape
`of those pieces.
` Q Okay. That answers my question.
` My question was, does every Lada Niva
`vehicle have these trim pieces?
` A Yes, of course.
` Q And why would someone need to replace
`these parts?
` A Because they break. Because they break,
`because of cracks.
` Q And what are these parts made out of,
`what material?
` A Out of plastic, plastic.
` Q Do you know what type of plastic?
` A I can't tell you, because our company is
`not a manufacturer. The manufacturer in this case
`would be Syzran. There is a plant called Syzran
`in Russia, and they are manufacturing plastic
`parts. And what type of raw materials they use,
`that's insignificant to us.
` Q Okay. After Exhibit A, on the next page,
`there's a heading for Exhibit B. And we can just
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`26
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`stay there. So I'm in the version after your
`declaration, it's PDF Page 158, and after the
`English version, Exhibit B starts on Page 16 of
`the PDF.
` MR. FITZSIMMONS: And can we actually
`just go to Page 15 of the PDF? Or, I'm sorry,
`Page 16 of the PDF?
` A/V TECHNICIAN: Of course.
` MR. FITZSIMMONS: Thanks. And since
`these are the same I'll just stick with these so I
`don't need to switch back and forth with the two
`different page numbers.
` Q And, Ms. Kaminskiene, what is Exhibit B?
` A What specifically do you mean?
` Q You have an attachment to your
`declaration, Exhibit B. Correct?
` A Well, I don't know what page number that
`would be, but this is a Niva catalogue. The Niva
`catalogue of parts for sales purposes.
` Q Okay. So Exhibit B is a parts catalogue
`for the Niva.
` Is that correct?
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`27
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` A Yes, this particular page is Page Number
`1 of that catalogue, and that shows the engine and
`what parts are -- are in the engine. And it gives
`the parts numbers.
` Q And did you, personally, find Exhibit B
`to include with your declaration?
` A Yes, we have that book. Well, you know,
`the manufacturer is making those vehicles, but
`those vehicles tend to break, and some parts need
`to be replaced eventually. So we publish those
`parts catalogues, they're published every year.
`And we have the edition -- I can even look it up,
`I think we have the edition for 1984 or 1988.
`It's a big catalogue. It has 200 pages. I can
`look it up to see how many exactly. So that's it.
`That's that catalogue in PDF format, the catalogue
`which we have, the catalogue of parts.
` Q And so is this PDF a copy of a catalogue
`that you, personally, have?
` A Yes. Yes.
` Q And who copied or scanned that catalogue
`to include as Exhibit B?
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`28
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` A We had it in our software, we have this
`catalogue. And I can even tell you more. I can
`tell you we've had it for ten to 15 years. I
`think initially we got it from the OSB plant. And
`then we included it into our software and we
`shared it with our clients so it would be easier
`for them to order parts using specific part
`number. So it would be easier for us to work
`them.
` Q I see. So is it correct that you have an
`electronic version of this catalogue, and that's
`what Exhibit B is?
` A Yes.
` Q And is this the entire parts catalogue?
` A Yes, of course.
` Q Is Exhibit B missing any pages, to your
`knowledge?
` A Do you mean the first page specifically
`or the whole catalogue?
` Q Is Exhibit B the entire parts catalogue?
` A Yes.
` Q And so there are no pages of the parts
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`29
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`catalogue missing, to your knowledge, in Exhibit
`B.
` Is that correct?
` A No.
` Q That's not correct, or it's not missing
`any pages, to your knowledge?
` A No, not missing.
` Q Thank you.
` Is there a cover to this catalogue?
` A I don't think they ever include covers in
`electronic versions. But if I have a printed
`version somewhere, I can show you a copy. I just
`think the cover is so worn out that it's barely
`visible.
` Q And do you know what year the version
`that's -- of the catalogue that you provided as
`Exhibit B is from?
` A I think it's '78, '88, if I'm not
`mistaken.
` Q You don't know if it's from 1978 or 1988,
`though?
` A If it doesn't state the year here
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`30
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`anywhere, then I will need to look it up.
` Q So right now you're not sure what year
`it's from.
` Is that correct?
` A Yes, I'm not sure, because each catalogue
`would have the same initial pages. They all start
`from the pages with engine, the engine block,
`those pages are all the same. And you would need
`to look at the title page, which would include the
`publication here. And in this version that page
`is not shown.
` MR. FITZSIMMONS: Can we please turn now
`in the PDF to Page 142. Yeah. And then on Page
`143 and 144 of the PDF.
` Q This is Exhibit C. Is that correct?
` A Do you mean this photograph? Because
`here I don't see any C or anything else it doesn't
`show here.
` Q If we go to Page 142, it says in English,
`Exhibit C. We can go to the Russian version if
`you'd like.
` A Yes, yes. Yes, understood. No, no need
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`31
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`for that. I understood now.
` Q And so then let's go to Page 144 of this
`Exhibit 2042 -- or I'm sorry, Exhibit 2031.
` And did you acquire this screen shot
`image that's shown here?
` A No. No; that's what I sent.
` Q What -- what did you send, this part?
` A I sent that image to -- we can say to
`prove that the bottom, that the body floor, that
`specific part, fits old Nivas and also Nivas which
`are made as currently as 2013, 2014. So this
`specific body part is the same. And it was the
`same since the vehicle started to be manufactured,
`and until present day it was unchanged.
` Q And why, in your opinion, does it prove
`that this part fits old Nivas and also current
`Nivas?
` A Yeah, so here you can see the product
`code 5101024 -- well, no don't interpret this
`part. Let me try to start over.
` So this image is to show what this
`particular part, the body floor, looks like. And
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`32
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`it has the original product code, which is
`2121-5101024. And this product code has been
`unchanged during all this time.
` Q Then also on this page there are the
`numbers 2121, and then comma 21213, 21214.
` What do those mean?
` A This numbers mean that this product code
`is compatible with those Niva models.
` Q And so what are those Niva models?
` A Well, those are the model numbers shown,
`2121, 21213, 21214, those are the model
`notifications that ever existed or still exist.
`So that part would fit old Nivas and the Nivas
`which were produced when that vehicle started to
`be manufactured. And it would also fit more
`current Nivas. I don't know what else to tell
`you.
` Q When you say "old Nivas," what years do
`you mean by that?
` A Starting from 1977 until present time.
` Q So you said, Old Nivas and then current
`Nivas. So do you have a cutoff for distinguishing
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`33
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`between old Nivas and current Nivas?
` A The older ones, well, they started
`manufacturing them in 1977, and it went on until
`1981. In 1981, if I'm not mistaken, they started
`making the model 21213, which had 1.7 engine. And
`then in 2006 I believe they started making the
`model 21214, which is alternatively called Lada 4
`by 4. I don't know what else to tell you.
` Q And so the -- was the only difference
`between the 2121 model and the 21213 model the
`engine?
` A The -- well, yes, the engine volume older
`Niva had 1.6 engine, and Niva 13 had 1.7 engine,
`1.7 carburetor. It was the injector, distributor
`was modified, and also there were some changes
`made to the body exterior. And if it's important,
`I can go over them.
` Q Were there any changes to the interior
`foot well between those two models?
` A No.
` MR. FITZSIMMONS: We've been going a
`little more than an hour. Would you like a
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`Transcript of Interview of Janina Kaminskiene
`Conducted on July 2, 2021
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`34
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`five-minute break, or would you like to continue?
` THE WITNESS: Let's take five.
` MR. FI