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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`Case IPR 2020-01556
`- - - - - - - - - - - - - - - - - - - -x
`WEBER, INC.,
`
`Petitioner,
`
`-against-
`PROVISUR TECHNOLOGIES, INC.,
`Patent Owner.
`- - - - - - - - - - - - - - - - - - - -x
`
`September 28, 2021
`1:04 p.m.
`
` ZOOM DEPOSITION of SCOTT SCRIVEN, the
`Witness in the above-entitled action,
`located in Kansas City, Missouri, taken
`before Dawn Matera, a Shorthand Reporter
`and Notary Public of the State of New
`York.
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`* * *
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`Weber EX1071
`Weber v. Provisur
`IPR2020-01557
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`Case IPR 2020-01556
`- - - - - - - - - - - - - - - - - - - -x
`WEBER, INC.,
`
`Petitioner,
`
`-against-
`PROVISUR TECHNOLOGIES, INC.,
`Patent Owner.
`- - - - - - - - - - - - - - - - - - - -x
`
`September 28, 2021
`1:04 p.m.
`
` ZOOM DEPOSITION of SCOTT SCRIVEN, the
`Witness in the above-entitled action,
`located in Kansas City, Missouri, taken
`before Dawn Matera, a Shorthand Reporter
`and Notary Public of the State of New
`York.
`
`* * *
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
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`516-608-2400
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`Weber EX1071
`Weber v. Provisur
`IPR2020-01557
`
`
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`Page 2
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`APPEARANCES:
` STERNE KESSLER GOLDSTEIN & FOX PLLC
`Attorneys for Petitioner
`1100 New York Ave NW
`6th Floor
`Washington DC 20005
` BY: RALPH POWERS, III, ESQ.
`tpowers@sternekessler.com
` BY: GRAHAM PHERO, ESQ.
`gphero@sternekessler.com
`-AND-
` LEVY CRAIG LAW FIRM
`4520 Main Street, Suite 1600
`Kansas City, MO 64110
` BY: JASON LEIKER, ESQ.
`
` WILLKIE FARR & GALLAGHER LLP
`Attorneys for Patent Owner
`787 Seventh Avenue
`New York New York 10019-6099
` BY: MICHAEL BABBITT, ESQ.
`mbabbitt@willkie.com
` By: MITCHELL FELDHAKE, ESQ.
`mfeldhake@willkie.com
` By: BY: HENRY THOMAS, ESQ.
`hthomas@willkie.com
`
`* * *
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` S. SCRIVEN
`S C O T T S C R I V E N,
` the Witness herein, having first
` been duly sworn by the Notary
` Public, was examined and
` testified as follows:
`EXAMINATION
`BY MR. POWERS:
` Q. Good afternoon, Mr. Scriven.
`My name is Ralph Powers, III and I am an
`attorney at Sterne, Kessler, Goldstein &
`Fox on behalf of Weber, Inc. With me
`today is Graham Phero, also from Sterne
`Kessler. Joining us on the line is Jason
`Leiker, also on behalf of Weber.
` MR. POWERS: Mike, would you
` like to introduce your team?
` MR. BABBITT: Yes, thank you.
` My name is Mike Babbitt for Patent
` Owner Provisur, and with me is Henry
` Thomas and Mitch Feldhake.
` Q. Mr. Scriven, did the lights
`just go out on you?
` A. Yes, they did. I am in a
`completely dark room. Give me a minute
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` S. SCRIVEN
`to go and see.
` [Off the record.]
`BY MR. POWERS:
` Q. Mr. Scriven, who asked you for
`your testimony in this case?
` MR. BABBITT: Objection to form.
` A. I am sorry, I didn't hear the
`question.
` Q. Sure. Who asked you to provide
`testimony in these IPRs?
` MR. BABBITT: Objection to form.
` A. For me to provide testimony? I
`believe you did. I mean I think that's
`why we're here --
` Q. You believe that --
` A. -- unless I am misunderstanding
`it.
` Q. Is it your belief that I asked
`you to provide testimony in these IPRs?
` MR. BABBITT: Objection to form.
` A. I believe that Provisur asked
`me to provide testimony in these IPRs.
` Q. And you provided declarations
`in these IPRs, correct?
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` S. SCRIVEN
` A. Yes, sir.
` Q. Did you say yes, sir,
`Mr. Scriven?
` A. I did say yes, sir.
` Q. Who at Provisur asked you to
`provide testimony in these IPRs?
` MR. BABBITT: Objection to form.
` A. Who at Provisur, I don't
`understand the question.
` Q. You said that Provisur asked
`you to provide testimony in these IPRs,
`correct?
` A. So Provisur -- I would -- our
`attorneys asked me to provide the
`declaration. But as an employee of
`Provisur, I am doing so on behalf of
`Provisur.
` Q. I see. Which attorney of
`Provisur's asked you to provide testimony
`in these IPRs?
` MR. BABBITT: Object to form.
` A. Mr. Babbitt.
` Q. Do you like working for
`Provisur, Mr. Scriven?
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` S. SCRIVEN
` A. I do.
` Q. Is it fair to say that you want
`Provisur to win its litigations against
`Weber?
` MR. BABBITT: Object to form.
` Relevance. Scope.
` A. That would be my desired
`outcome.
` Q. Let's talk about your
`educational background, starting with
`college. Where did you go to college?
` A. I went to St. Ambrose
`university in Davenport, Iowa.
` Q. And what year did you graduate?
` A. 1980.
` Q. Did you go on to any additional
`educational programs?
` A. Other than seminars, no formal
`education beyond college.
` Q. What degree did you obtain from
`St. Ambrose?
` A. A business administration, a
`bachelor of arts in business
`administration.
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` Q. And then after that you got
`your first job; is that right?
` A. Actually, I worked full-time
`through college.
` Q. Good for you. What was your
`first job out of college?
` A. My first job out of college was
`a continuation of my, what I was doing
`during college, which I was a turret
`lathe operator in a machine shop.
` Q. Who did you work for?
` A. The name of the company was
`Cartridge Pack.
` Q. What does a turret lathe
`operator do?
` A. Makes machine parts out of
`blanks of steel.
` Q. And how long did you work at
`Cartridge Pack?
` A. I believe I worked there twice.
`It was 16 years, I believe, in total.
` Q. So you worked there after
`college, and then you took a hiatus and
`worked somewhere else and then came back
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` S. SCRIVEN
`to Cartridge Pack; is that right?
` A. That's correct.
` Q. So where did you work in
`between your stints at Cartridge Pack?
` A. I worked for a company called
`Klockner Bartelt. And then for a company
`called Krones.
` Q. Let's take that one at a time.
`So what years did you work at Klockner
`Bartelt?
` A. From sometime in the latter
`half of '86 until sometime in '89, I
`believe, early '89.
` Q. And what was your job at
`Klockner Bartelt?
` A. I was a regional salesman.
` Q. What were you selling at
`Klockner Bartelt?
` A. Food processing machinery.
` Q. What type of food processing
`machinery?
` A. We sold the equipment that you
`would find things like Carnation Hot
`Cocoa Mix or Lipton Instant Soup pouches
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` S. SCRIVEN
`in, and that was at the time of the
`Tylenol situation. And they had acquired
`a company that made tamper-evident
`banding for consumer protection.
` Q. And what were your duties as
`part of your job at Klockner Bartelt?
` A. To identify -- to support
`existing accounts and customers, and
`acquire new accounts.
` Q. As part of your job at Klockner
`Bartelt, did you have to understand the
`technology that Klockner Bartelt was
`selling?
` MR. BABBITT: Objection to form.
` A. The way that question is
`worded, I am not -- I not sure how to
`answer it. I would say what we
`understood was --
` (Zoom frozen. )
` MR. POWERS: Let's go off the
` record.
` [Off the record.]
`BY MR. POWERS:
` Q. So let's go back to where we
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` S. SCRIVEN
`were. As part of your job at Klockner
`Bartelt, what was your involvement in the
`technology that they were selling?
` MR. BABBITT: Objection to form.
` A. My role was simply to sell it.
` Q. Did you have a pretty good
`understanding of the technology and how
`their machines worked?
` MR. BABBITT: Objection to form.
` A. I mean, generally, I understood
`how the machines worked. But, you know,
`specifically, we determined the features
`or the functions of the machine that
`would allow the customer to choose to buy
`it over a competitor.
` Q. And so would you say as a
`salesman you had to have at least a
`working understanding of the technology
`of the machines?
` MR. BABBITT: Objection to form.
` Scope.
` A. I believe that a working
`knowledge of the basic -- a basic
`knowledge of the function of the machine
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` S. SCRIVEN
`would be beneficial.
` Q. Did you have any role at
`Klockner Bartelt related to patents?
` A. No, sir.
` Q. Did the machines at Klockner
`Bartelt have operator's manuals?
` A. I would believe so.
` Q. Do you recall if they had
`operator's manuals or not?
` A. I don't ever recall having seen
`one.
` Q. So sitting here today, you
`can't say one way or the other whether or
`not Klockner Bartelt machines that you
`provided to customers had operators
`manuals?
` MR. BABBITT: Objection to form.
` A. I would believe that they had
`operator's manuals. I cannot say that I
`ever saw an operator's manual.
` Q. Do you know if Klockner Bartelt
`provided operator's manuals to their
`customers when they sold machines?
` A. I would believe that they would
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` S. SCRIVEN
`have provided manuals. I think it would
`have been customary to provide manuals,
`but I do not know that they did or did
`not provide them.
` Q. Is it customary in the food
`production machinery industry to provide
`operator's manuals with the sale of a
`machine?
` MR. BABBITT: Objection to form.
` Scope.
` A. I would believe that generally
`it would be -- manuals would be provided.
` Q. You mentioned another company
`that you worked for after Klockner
`Bartelt. Is that Krones?
` A. Yes, sir.
` Q. Could you spell that for us?
` A. K-R-O-N-E-S.
` Q. What did Krones do?
` A. High-speed labeling, bottling,
`capping, corking. Things of that nature.
` Q. Is that in the beverage
`production industry?
` A. Obviously corking is for the
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` S. SCRIVEN
`wine. Capping is for soft drinks and
`such. But labeling was, you know, from
`anything from mayonnaise to salsa to, you
`know, anything on a glass jar.
` Q. So the food and beverage
`industries, I suppose; is that correct?
` A. Yes.
` Q. And what were your duties at
`Krones?
` A. Again, I was a salesman.
` Q. Do you recall what your title
`was?
` A. I would say territory salesman.
`I don't recall exactly.
` Q. Do you recall what your
`territory was?
` A. Parts of the upper Midwest. I
`would say some of Iowa. Some of
`Illinois. Also, Minnesota and some of
`Wisconsin.
` Q. What years were you employed at
`Krones?
` A. I was there a very short period
`of time. I left in the middle of '90.
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` S. SCRIVEN
`So I probably joined them maybe 10 months
`before that or 11 months before that.
` Q. Do you know if Krones provided
`operator's manuals to customers when they
`sold a machine?
` MR. BABBITT: Objection to form.
` A. I would believe that they did,
`but I don't believe I ever saw one. But
`I would believe they did.
` Q. Why did you leave Krones?
` A. I chose to return to Cartridge
`Pack. I was asked to return to Cartridge
`Pack, and I chose to.
` Q. And for your second tour at
`Cartridge Pack, what was your job?
` A. When I returned to Cartridge
`Pack, my title was European manager. And
`I was responsible for the commercial
`activities of seven agents and
`distributors in Europe.
` Q. So your job had a very European
`focus at that point; is that correct?
` MR. BABBITT: Object to form.
` Q. And you had seven people
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` S. SCRIVEN
`reporting directly to you, correct?
` A. Actually, I had nobody
`reporting directly to me. I had the
`responsibility to manage the commercial
`activities of seven independent companies
`in Europe who we had distribution
`agreements with to sell our equipment.
` Q. And who did you report to for
`your second tour at Cartridge Pack?
` A. I reported to the general
`manager of the food equipment division.
` Q. Did you have any role regarding
`patents while you were at Cartridge Pack
`for the second time?
` MR. BABBITT: Objection to form.
` Scope.
` A. I don't believe so. I don't
`believe we had many patents, truthfully.
` Q. Do you know if Cartridge Pack
`had operator's manuals for the machines
`that it sold to customers?
` A. They did, yes.
` Q. Did Cartridge Pack provide
`manuals with the sale of its machines to
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` S. SCRIVEN
`its customers?
` A. Generally, yes.
` Q. What do you mean by generally,
`yes?
` MR. BABBITT: Objection to form.
` A. Generally, yes, I mean that the
`serial machines tended to always have
`manuals. You know, special engineering
`may have been developed without operation
`manuals.
` Q. While you were at Cartridge
`Pack, did you ever provide operator's
`manuals to customers personally?
` A. I would have to believe not.
`Manuals would have been shipped as part
`of the machine itself, you know.
` Q. Is that something that's common
`in the food production industry, to
`include a manual with the shipment of a
`machine?
` MR. BABBITT: Objection to form.
` Scope.
` A. I would say in that era it
`certainly was.
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` Q. And what was that era? What
`time frame?
` A. 1990.
` Q. Where did you work after
`Cartridge Pack?
` A. I worked for Weber,
`Incorporated.
` Q. Why did you leave Cartridge
`Pack?
` A. I was offered the title of
`president and CEO of a business, and
`decided to grab the ring.
` Q. And what was your role of
`president and CEO of Weber, Incorporated?
` A. You know, primarily, you know,
`Weber was a sales and service
`organization, particularly at the
`beginning. So, you know, we built a
`sales team. We built a service team.
`And we built a parts department and an
`aftermarket team.
` Q. Who did you report to while you
`were at Weber?
` A. This one could take most of the
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` S. SCRIVEN
`afternoon, counselor. I believe in
`theory I reported to Guenther Weber. But
`because of language challenges, an
`intermediary was generally always in
`place, so the first of those gentleman
`was Peter Danworth. Then we had Maurizio
`Ventura. And we had Michelle Anton.
`Intermingled in there were several tours
`of duty with Hartmut Blocher when we were
`between other managers. And then several
`who were there for such a short period of
`time, I don't remember their names.
` Q. What were your duties at Weber?
` A. So my duties at Weber were to
`help Weber build a business in North
`America through the development of a
`sales team, a service team and then
`ultimately an aftermarket business.
` Q. What does a service team do?
` A. A service team certainly
`primarily would install new equipment.
`It would make service field visits, if
`the customer were unable to resolve an
`operational or maintenance issue. And
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`certainly do diagnostics of,
`troubleshooting diagnostics.
` Q. What does an aftermarket team
`do?
` A. Primarily provide the parts.
`Fulfill parts' orders.
` Q. Does an aftermarket team
`service warranties?
` A. An aftermarket team would
`provide parts under warranty. But the
`service team member would provide any
`physical labor necessary under warranty.
` Q. Where did you work after you
`worked for Weber?
` A. I worked for a company in
`Canton, Massachusetts, Reiser,
`Incorporated.
` Q. What was your role at Reiser
`Incorporated?
` A. I believe my title was
`executive vice president of sales and
`marketing.
` Q. Why did you leave Weber?
` MR. BABBITT: Object to form.
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` Scope.
` A. I left Weber -- I left Weber
`because I thought I was ready for a new
`challenge.
` Q. What do you mean by ready for a
`new challenge?
` MR. BABBITT: Object to form.
` A. By new challenge I meant that,
`one, Guenther Weber is not always an easy
`man to work for. And I believe that at
`the age I was at I didn't want to do that
`for another 15 or more years. And had an
`opportunity to take an equity stake in a
`family business and chose that route.
` Q. What did you mean when you said
`Guenther Weber was not always an easy man
`to work with?
` MR. BABBITT: Object to form.
` Scope. Relevance.
` A. Guenther Weber has medical
`issues -- I will get this light on here,
`give me a second.
` Guenther Weber is fairly well
`known, at least within his business,
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`certain conditions that leave him to be
`manic depressive. And when he drinks on
`top of that, he gets very nasty.
` Q. Is it fair to say you had a
`personality conflict with Guenther Weber?
` MR. BABBITT: Object to form.
` Scope. Relevance.
` A. Not at all. I love Guenther
`Weber, so.
` Q. But you found him difficult to
`work with; is that right?
` MR. BABBITT: Object to form.
` Scope, relevance.
` A. I did at times find him
`difficult to work with.
` Q. What was your role at Reiser?
` A. I was responsible for all
`aspects of sales and marketing.
` Q. Did you have any role regarding
`patents at Reiser?
` MR. BABBITT: Object to form.
` Scope. Relevance.
` A. So Reiser is a unique business
`in that they really were a distribution
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`arm of many European brands. So Weber --
`I apologize, Reiser would not have had
`patents on their own, no.
` Q. Was it Riser's practice to
`provide manuals to customers when selling
`machines to customers?
` MR. BABBITT: Object to form.
` A. I would say a more accurate way
`to say that would be that the companies
`that Reiser represented would have been
`responsible for providing manuals to
`customers.
` Q. How many companies did Reiser
`represent?
` A. In round numbers, a dozen.
` Q. And did each of those companies
`provide -- strike that.
` Did each of those dozen
`companies that Reiser represented provide
`manuals to customers who purchased one of
`their machines?
` MR. BABBITT: Object to form.
` Foundation.
` A. To the best of my knowledge,
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`they would have provided manuals.
` Q. While you were at Reiser, did
`you ever provide an operator's manual to
`a customer personally?
` A. To the best of my knowledge,
`no, I did not.
` Q. Did you have any involvement in
`providing manuals to customers while you
`were at Reiser?
` A. I don't believe so, no. I
`can't think of a situation where I would
`have.
` Q. Where did you work after you
`worked at Reiser?
` A. I then joined Provisur
`Technologies.
` Q. What year was that that you
`joined Provisur?
` A. 2015.
` Q. Why did you leave Reiser to
`join Provisur?
` A. I was hired to be the
`succession plan for the family. And the
`time came and went for the succession to
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`begin. And it was never going to begin.
`And six years later it still hasn't
`begun. And ultimately, the decision was
`reached that the company did not need
`both me and Roger Reiser.
` Q. So is it fair to say you
`weren't happy with the advancement
`opportunities at Reiser and you left?
` MR. BABBITT: Object to form.
` Scope. Relevance.
` A. No, I would say that was not
`the case at all. The case was that Roger
`Reiser was going to step back from the
`business in 2014. He did not. He became
`even more involved in the business,
`rather than winding down. And there was
`not the need for both of us to be there.
`It had nothing to do with advancement.
` Q. So you left and went to
`Provisur; is that right?
` A. Yes.
` Q. And what is your current title
`at Provisur?
` A. My current title is executive
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`vice president of the slicing business
`unit.
` Q. And is that the role that you
`were originally hired into in 2015?
` A. In 2015, I was hired as the
`vice president of the slicing business
`unit.
` Q. And who did you report to when
`you first got to Reiser -- excuse me,
`scratch that.
` Who did you report to when you
`first got to Provisur?
` A. I reported to Mel Cohen, the
`CEO of the business.
` Q. And what were your duties?
` A. My duties were to help revive
`the slicing business at Provisur.
` Q. And what did you do to help
`revive the slicing business at Provisur
`when you were first hired?
` A. We revamped our engineering
`philosophy and revitalized our commercial
`team. And now we're working on the
`slicing team -- I apologize, the service
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`team.
` Q. Did you have any role regarding
`patents at Provisur?
` MR. BABBITT: Objection to form.
` Scope. Relevance. Foundation.
` A. Truthfully, I did not until
`some time well after I was employed by
`Provisur.
` Q. When did you take on a role
`related to patents at Provisur?
` MR. BABBITT: Objection to form.
` Relevance. Foundation.
` A. My best estimate would have
`been in maybe late in the first quarter,
`early second quarter of 2017, maybe.
` Q. What is your role related to
`patents at Provisur?
` MR. BABBITT: Object to scope.
` A. My role is really limited to
`managing the annuities of the slicing
`patent portfolio, and to work with our
`engineering team to determine which of
`the technologies we're developing
`warrants patents or not.
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` Q. Do you interface with patent
`attorneys on behalf of Provisur --
` MR. BABBITT: Object to form.
` Q. -- as part of that role?
` MR. BABBITT: Scope.
` A. Generally, no. But certainly
`this matter is separate. This is not
`part of managing our --
` Q. Aside from this matter.
` A. Aside from this matter I really
`do not, no.
` Q. Do you interface with inventors
`as part of your role in patents at
`Provisur?
` MR. BABBITT: Object to form.
` Scope.
` A. I do interact with them, yes.
` Q. Could you describe how you
`interact with inventors at Provisur?
` MR. BABBITT: Object to form and
` scope.
` A. I sit down with them at a
`break, and have a cup of coffee. And I
`think my role is more of a cheerleader.
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`I have very little engineering
`capabilities. But I like to encourage
`their work and watch the fruits of their
`work.
` Q. Do you think it's fair to say
`that Weber hired you because you knew the
`needs of U.S. customers?
` MR. BABBITT: Objection to form
` and scope. Foundation.
` A. I believe that Weber hired me
`because I knew the U.S. customers.
` Q. As in you personally knew the
`U.S. customers?
` A. Correct, correct.
` Q. Do you think it's true that the
`U.S. market for food slicers is different
`than the European market?
` MR. BABBITT: Objection to form
` and scope.
` A. I would say generally there are
`differences between the U.S. and European
`slicer markets.
` Q. How would you characterize
`those differences?
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` MR. BABBITT: Object to form.
` A. Two things I believe come to
`mind. One is the size of the average
`portion of sliced product in Europe
`versus the United States.
` And secondly, I would say at
`that time, the amount of automation that
`was being used in Europe versus the
`United States.
` Q. Okay. Let's unpack that a
`little bit. So is it fair to say that
`the size of the portion that the consumer
`wants in the United States is bigger than
`in Europe?
` A. It's true.
` Q. Okay. That's what I guessed.
`And can you describe what you meant when
`you said that the other difference was
`the amount of automation being used in
`Europe versus the United States?
` A. Yes. So many of the slicing
`plants in America are legacy buildings,
`maybe built as far back as the '40s and
`'50s. There are various constraints on
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`it. So a lot more human intervention was
`used in getting the sliced product off of
`the slicer belt and into the pocket of
`the thermoforming machine. And while
`there were some of those constraints in
`Europe, there were many newer factories
`that had adequate space to use the
`automated loading systems.
` Q. I see. So is it fair to say
`that you know the customer of the slicing
`machine in the U.S. well?
` MR. BABBITT: Objection to form.
` Scope.
` A. I know a handful of customers
`well. But I don't know -- I know the tip
`of the iceberg, I think would be an
`accurate statement.
` Q. How many employees does a
`typical customer have for a food slicing
`line?
` A. So in one building, in a
`factory, for instance?
` Q. Yeah, could you give me a range
`of what's a typical number of employees?
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` A. It would range probably
`anywhere from 50 or less to 5 or 600.
` Q. How many of those folks would
`be machine operators?
` MR. BABBITT: Objection to form.
` A. Each slicing line would require
`one slicing operator per shift per
`operation.
` Q. And how many shifts are there
`per day in a typical production facility?
` A. Generally you can't have more
`than two because of the need for
`sanitation. But many smaller customers
`might operate only two shifts a week.
` Q. Who else works on a typical
`slicing machine besides the operator?
` A. I would say the typical
`operator makes the machine slice, but a
`maintenance mechanic would actually work
`on the machine.
` Q. What about safety personnel?
` A. I am not aware of any
`facilities where safety -- where unique
`designated safety personnel would be
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` S. SCRIVEN
`involved.
` Q. Not even in sort of food safety
`personnel, like hygiene personnel?
` A. Hygiene personnel would
`potentially take swabs on the machine to
`measure bacteria. And that is a guess on
`my part. I am not sure I have ever seen
`a food safety person on a machine.
` Q. What about engineers, would
`engineers typically be involved in the
`machine operation at a customer?
` A. At a customer engineers may be
`peripherally involved on an installation
`if it's their project. But for operating
`the machine or doing those sorts of
`things, I would have to say generally,
`generally not.
` Q. Could you say about how many
`engineers a typical customer has in the
`U.S.?
` MR. BABBITT: Objection to form
` and scope.
` A. Most of our customers -- most
`of our prospects -- I will say, because
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`they are not customers yet -- have no
`engineers. And even our larger customers
`are pushing the engineering function back
`on the suppliers because of the pressure
`on their margins. So even a large
`enterprise like Smithfield Foods might
`have less than 10 true engineers.
` Q. You said earlier that you
`couldn't have more than two shifts per
`day on a slicing line; is that right?
` A. Assuming that a shift is eight
`hours --
` Q. Right.
` A. -- yeah.
` Q. And that's because for that
`third eight hours in a 24-hour day, you
`need to do cleaning on the line; is that
`right?
` A. That's accurate, yes.
` Q. And who at your customers is in
`charge with cleaning the machine?
` A. A specialized sanitation crew.
` Q. How many folks typically work
`on a specialized sanitation crew?
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` A. I would only be guessing,
`counselor. That happens at 3 in the
`morning when we're comfortably at home.
`I am going to say in a typical slicing
`hall maybe two people, and they would go
`move from slicing hall to slicing hall.
`Maybe three -- maybe up to three.
` Q. Would you like to take a break.
`We have been going for about an hour
`Mr. Scriven?
` A. That would be fine, yeah.
` Q. Okay. Let's just take a quick
`five-minute break.
` [Off the record.]
`BY MR. POWERS:
` Q. Back on the record.
` Mr. Scriven, a while ago you
`said you were hired by Provisur to revive
`their slicing business. Do you remember
`that?
` A. I do.
` Q. What did you mean by revive
`Provisur's slicing business?
` MR. BABBITT: Objection to form
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`
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