Free Motion in Limine - District Court of Colorado - Colorado

Case 1:03-cv-01973-PSF-MJW

Document 167-2

Filed 10/17/2005

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EXHIBIT A

EXHIBIT A

Case 1:03-cv-01973-PSF-MJW

Document 167-2

Filed 10/17/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-F-1973(MJW) J.E.H. KNUTSON, Plaintiff, v. THE WALKER GROUP, INC., Defendant. DEPOSITION OF J. EUGENE HAROLD KNUTSON March 25, 2004

APPEARANCES FOR THE PLAINTIFF: COLIN A. WALKER, ESQ. Fairfield and Woods, P.C. Wells Fargo Center Suite 2400 1700 Lincoln Street Denver, Colorado 80203 RICHARD S. GOTTLIEB, ESQ. (via telephone) Kilpatrick Stockton LLP 1001 West Fourth Street Winston-Salem, N.C. 27101 and JOSHUA MAXIMON, ESQ. The Maximon Law Firm, LLC 12202 Airport Way Suite 170 Broomfield, Colorado 80021 ALSO PRESENT: MARK WILSON (via telephone)

FOR THE DEFENDANT:

Bruno Reporting Company 303 831-1667

0ab4d527-8c5d-11d8-961b-bef50467a376

Case 1:03-cv-01973-PSF-MJW

Document 167-2

Filed 10/17/2005

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Q.

Well, was it given to Walker?

I mean,

I'm just trying to find out what "seized" means. A. Well, I believe that it was taken under

the security agreement. Q. A. Q. A. How are customers seized? How are they seized? Yes. You take either the account receivable

or the contract and transfer it. Q. Did Walker take any First Layer

accounts receivable? A. Q. I -- that, I don't know. And the contracts that you're talking

about were opportunities for Walker to bid on contracts? A. Q. A. business. Q. And Paragraph 2 says, "Waiver and Correct. No guarantees of business? Basically, there's no guarantee of

estoppel based on an agreement that the Guarantee would not be enforced." A. Q. Yes. What -- "agreement that the Guarantee Did I read that correctly?

would not be enforced," what do you mean by

Bruno Reporting Company 303 831-1667

0ab4d527-8c5d-11d8-961b-bef50467a376