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Case 2:04-cv-00424-ROS

Document 482-2

Filed 08/21/2008

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Case 2:04-cv-00424-ROS

Document 482-2

Filed 08/21/2008

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513012008 Gilmore, Jack

about what was going on what was going on.
Q.

--

I mean, the people didn't know

Whose opinion was that? The retirees that was - - these offsets was being

A.

affected.
Q.

Now, you didn't say that in your e-mail back to

Mr. Brininger, did you? A. No. Did you say that to him at any point? MS. MARTIN: Objection.

Q.

Don't answer that. MR. WILLIAMS: MS. MARTIN: What's the basis?

Because what he says to his

attorney is privileged and confidential. In the context of consulting with an attorney, his comments to his attorney, his attorney's comments to him, the nature of the consultation is privileged. MR. WILLIAMS: question. MS. MARTIN: Okay. But we'll take this in small I'm going to withdraw the

MR. WILLIAMS: steps then. BY MR. WILLIAMS:
Q.

You wrote an e-mail to an attorney seeking an

evaluation of a case that you were thinking of bringing in

Case 2:04-cv-00424-ROS

Document 482-2

Filed 08/21/2008

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513012008 Gilmore, Jack

September 14, 1999, right?

A.
Q.

I wanted to know if we had a case, yes. And the attorney wrote back to you and said that

he was concerned that back in 1984 everyone knew that Allied was doing this, right? A. That's what he writes back, but I don't think he

knew what was going on.
Q.

Well, now, you took these conversations with this

attorney that you had on your e-mail account, correct? A.
Q.

Yes. And there were discussions in these e-mails about

the attorney's impressions of what was known in 1984, right? MS. MARTIN: THE WITNESS: Objection. I don't think this attorney

knew what was going on in '84.

BY MR. WILLIAMS:
Q.
But the attorney stated what his impression was

in his e-mail to you, right? MS. MARTIN: THE WITNESS: BY MR. WILLIAMS:
Q.

Objection. Yes.

And his impression was that back in 1984 everyone

knew that Allied was doing this, right? MS. MARTIN: Objection.

Case 2:04-cv-00424-ROS

Document 482-2

Filed 08/21/2008

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Case 2:04-cv-00424-ROS

Document 482-2

Filed 08/21/2008

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Case 2:04-cv-00424-ROS

Document 482-2

Filed 08/21/2008

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