𝐍𝐄𝐏𝐄𝐍𝐓𝐇𝐄. || 𝘴𝘶𝘪𝘵𝘴 𝘹 𝘰𝘤

𝟏𝟕 ➻ bad reputation

♛ ┇ ▒ ⋅⋅⋅ WALKER ENT. V. GREENFIELD CORP. ⋅⋅⋅ ▒ ┇♛

THE FOLLOWING IS AN AUDIO TRANSCRIPT OF THE GREENFIELD CORP. DEPOSITION, AUGUST 21st, 2011. VOICES HAVE BEEN DENOTED BY SPEAKER INITIALS. THIS IS CONFIDENTIAL EVIDENCE IN THE WALKER ENTERPRISES V. GREENFIELD CORPORATION CASE.

QW || Quinn Whitaker, Pearson Hardman Associate
LL || Louis Litt, Pearson Hardman Junior Partner
ER || Emily Reed, Renewable Energy Product Manager At Greenfield Corp.
JD || John Daniels, General Counsel for Greenfield Corp.

00:00

[scuffling noises, paper shuffling: deep breath]

QW: Good morning. Could you please state your name and occupation for the record?

ER: My — my name is Emily Reed. I work at Greenfield Corporation, and I... I'm the project manager for our new renewable energy project.

QW: Thank you. You are aware that you are being deposed in the case of Walker Enterprises v. Greenfield Corporation?

ER: Yes, I... why are you asking this?

LL: [sniffing] It's protocol, Ms. Reed. What, you've ever been deposed before?

ER: No, it's my first time —

LL: Okay, great. We'll be asking you questions that you must answer under oath. You understand?

[indecipherable noise]

QW: Don't nod, uh... just say yes or no.

ER: Yes. [breath] Yes, I understand. I... I was sent a form covering all of this. I signed it. Doesn't that... count?

LL: Oh, lovely. I wasn't sure it got to you on time, given your attorney's penchant for non-punctuality. [pause] So... during your time at Greenfield Corp., did you ever encounter confidential information — files, emails, blueprints, photos, whatever — pertaining to Walker Enterprises?

JD: How the hell is she supposed to know if it's confidential, Mr. Litt?

LL: Oh, I don't know, the big fat Walker Enterprises logo on all their proprietary know-how? Using her brain? And don't spit at me, Daniels. Polly works hard to clean these tables.

QW: Back on topic, please. Emily?

ER: No. I... didn't encounter anything.

[papers shuffling; something smacking the table]

LL: Then what's this?

ER: Those are... how do you have those?

QW: Uh, let it be known that the email chain between Emily Reed and a colleague has been shown to the deposed. [pause, paper shuffling] I am now showing the —

LL: In these emails, you explicitly discuss Walker Enterprises.

JD: Yes, in reference to trends of the industry. These two companies are long-standing rivals; I'd be shocked if they didn't talk about one another at some point.