Free Response - District Court of Arizona - Arizona

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Case 2:02-cv-02099-RCB Document 490-10 Filed 08/17/2007 Page10f3

I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
Diane Mann, as Trustee for )
the Estate of LeapSource, )
Inc., et al., )
)
Plaintiffs, ) No. CV 02-2099 PHX RCB
)
vs. g
GTCR GOLDER RAUNER, L L.C., )
a Delaware limited liability )
company; et al., g
Defendants. )

VIDEOTAPED DEPOSITION OF DIANE MANN
Phoenix, Arizona
September 20, 2005
9:06 a.m.
REPORTED BY: (COPY)
Carrie Smalanskas, RPR, CCR
Certified Court
Reporter #50355 HOLIDAY & ASSOCIATES
Registered Professional Reporters
202 North Third Street, Ste. 8-173
Phoenix, Arizona 85004
(602) 712-9700
PREPARE FOR:
NICHOLAS GORGA
ATTORNEY—AT-LAW
Case 2:02-cv-02099-RCB Document 490-10 Filed 08/17/2007 Page 2 of 3

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1 had those discussions or what he knew about that, correct?
2 .A. Correct.
3 C) I am done with that one, Ms. Mann. I have one
4 last line of questioning that I wanted to ask you.
lh22 6 You, as trustee, eventually hired on behalf of
6 the estate a consultant to value the ICG division of
7 LeapSource, correct?
3 .A. Correct.
9 Cl The individual you hired was Morris Aron from
lh23 10 MCA Financial Group, Limited, correct?
ll .A. Correct.
12 Cl Mr. Breger in a previous deposition has taken
13 the position that Mr. Aron was a consultant as to whose
14 work is protected by the work product doctrine and,
lh23 15 therefore, in this line of questioning, I don't want to
16 get into the substance of any discussions that you may
17 have had with Mr. Aron or any of the actual work that he
18 might have done. Are we clear on that?
19 .A. Yes.
lh23 20 C) You, as trustee, retained Mr. Aron in the
21 bankruptcy to provide valuation advice of ICG, correct?
22 .A. Correct.
23 24 Exhibit 634 a document that was filed in the bankruptcy
lh24 25 case, but it has not been marked in the litigation.
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