Académique Documents
Professionnel Documents
Culture Documents
September 7, 2011
Page 163
I
1
UNITED STATES DISTRICT COURT
2
DISTRICT OF OREGON
3
PORTLAND DIVISION
4
5 W. BRAND BOBOSKY and WE NOT
6
ME, LTD.,
7
Plaintiffs,
8
V .
No. CV1O-630-PK
9 ADIDAS AG d/b/a THE ADIDAS
10
GROUP, ADIDAS AMERICA, INC.,
11
180LA, LLC, NBA PROPERTIES,
12
INC., NBA MEDIA VENTURES, LLC,
13
BANNER SEVENTEEN LLC d/b/a THE
14
BOSTON CELTICS, and KEVIN
15
GARNETT,
16
Defendants.
17
18
19
VOLUME II
20
21
VIDEOTAPED DEPOSITION OF WILLARD BRAND BOBOSKY
22
Taken in behalf of Defendants
23
September 7, 2011
24
25
Beovich Walter & Friend
Exhibit B
Page 1 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 8 of 35 Page lD#:
l884
Willard Bobosky
September 7, 2011
Page 174
1
Q. What does it mean?
2 A. It means that the applicant, which is the
3 corporation, has an intention to use the mark in
4 connection with a particular class, which I
5 think appears later, class 25.
6> Q
A
7
g
a
9 S -
10
11
12 s
I 1II d
13 belt rga
4
14 dress
15 mis pe 1
16
AC 1
19
21
Q.
So thii: er oodt>h4 ]mbrogi
22 created
23 *. We Jii s1i and e tanare,
24 t
25 t1 st
Beovich Walter & Friend
Exhibit B
Page 2 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 9 of 35 Page lD#:
l885
Willard Bobosky
September 7, 2011
Page 175
I
1 pr ld
2 e
3:
4 1 app 1Thton?
T k-
6
Q. Is it your understanding this is the entirety of
7 class 25?
8 A. I dont know. Theres an awful lot of items
9 there.
10
Q.
And towards the bottom of the page theres a, in
11 the center a declaration heading. Do you see
12 that?
13 A. Yes.
14
Q.
And Mr. Ambrogi, as your attorney, signed the
15 declaration stating "The undersigned, being
16 hereby warned that willful false statements and
17 the like so made are punishable by fine or
18 imprisonment or both under 18 Usc section 1001
19 and that such willful false statements and the
20 like may jeopardize the validity of the
21 application or any resulting registration,
22 declares that he/she is properly authorized to
23 execute this application on behalf of the
24 applicant; he/she believes the applicant to be
25 the owner of the trademark/service mark sought
Beovich Walter & Friend
Exhibit B
Page 3 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l0 of 35 Page lD#:
l886
Willard Bobosky
September 7, 2011
Page 185
IQ ,, ndst t tahW
ry
nev
1
just come s J !h:e rn them
he d h%yr e But a number of
8 them, again, my understanding was that I am now
9 authorized within that class to affix my
10 trademark to items therein.
11
Q.
But at no time, either prior to January 3rd,
12 2006, or after 2000, January 3rd, 2006, have you
13 manufactured or sold the vast majority of the
14 items that are listed here in class 25; correct?
15 A. Well, the, I dont know what you mean by vast
16 majority.
17
Q.
We can do, we can do --
18 A. I have done, I have done shirts and some other
19 items. Again, I was never under the impression
20 that I had to do anything further than hats.
a.ap1eeconds o wi respeo
22 these good 1 a ow
2 the Who
24 t1 oweQ qts
Z5 LIE
Beovich Walter & Friend
Exhibit B
Page 4 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page ll of 35 Page lD#:
l887
Willard Bobosky
September 7, 2011
Page 186
I
1 mean, the
2 classify d :.
e entthings and, I:iiean.that s,
3 that
4 s
tars I n, oil
icu
5
Q. But this specific list of class 25 goods,
6 including rugby shirts misspelled, its not your
7 understanding that the trademark office put this
8 list in your application, is it?
9 A. Well, I, I dont know. Maybe theres 50 items
10 or so to choose from and maybe Mr. Ambrogi
11 selected them, or 25 or 15 or whatever it is.
12 I, again, I dont know where any of this came
13 from. I just proceeded to have him do the
14 filings and the selections.
15 (Exhibit 87 marked for identification.)
16
Q.
BY MR. FRIEDLAND: Lets look at what Ive
17 marked as Exhibit 87, which is a five-page
18 document bearing adidas production numbers 449
19 through 453. Are you familiar with this
20 document?
21 A. I dont know. Oh, this... Oh, this is entitled
22 the service mark statement of use.
23
Q.
So, and if you look at the second page, theres
24 a, I think youre on the third page. Theres a
25 block that says signature, signature section.
Beovich Walter & Friend
Exhibit B
Page 5 of 28
II
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l2 of 35 Page lD#:
l888
Willard Bobosky
September 7, 2011
Page 187
1 Do you see that?
2 A. Yes.
3
Q.
And underneath Mr. Ambrogis name is the date
4 April 3rd, 2006. Do you see that?
5 A. Yes.
6
Q.
Which is roughly or exactly actually three
7 months after the date of the notice of allowance
8 that was --
9 A. Yes.
10
Q.
-- Exhibit 86? And does that refresh your
11 recollection as to whether or not this
12 particular application required extensions of
13 time?
14 A. Yes, it does. And obviously three months later
15 we did not go to any extensions of time for the
16 reasons that I gave you briefly.
And 19Q
Mt
unde ds
19 the bottom; vj
20 for goods and/, ices it
21 listed hat?
Yes.
Ic
24 u1 e d
25 in Exhibit
Beovich Walter & Friend
Exhibit B
Page 6 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l3 of 35 Page lD#:
l889
Willard Bobosky
September 7, 2011
Page 188
1
are what tenddi..be included on the
2
1 is her
la
4
1 i
5
6
it
7
Mr. ogr
8
Q.
Okay. And right underneath where it says "keep
9
all listed" it shows first use anywhere date and
10
first use in commerce date both as October of
11
2004. Do you see that?
12 A.
Yes.
13
Q.
And on the next page it lists a specimen file
14
name because Mr. Ambrogi would have uploaded the
15
image that is the last page of this exhibit.
16
And I think thats just the link to this
F
17
particular picture and the specimen description
18
states product labeling. Do you see that?
19
A. Yes.
20
Q.
Looking at the next page of this document, which
21
is the typewritten form of the statement of use,
22
the third paragraph that starts for
23
international class 25, do you see that?
24
A. Yes.
25
Q.
"The applicant, which is We Not Me, or the
Beovich Walter & Friend
Exhibit B
Page 7 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l4 of 35 Page lD#:
l890
Willard Bobosky
September 7, 2011
Page 189
I
1 applicants related company or licensee," and at
2 that time you had no licensees or related
3 companies; correct?
4 A. Correct.
5 Q. "Is using the mark jn ommer Ji
6 connectin 1 %ted
7
8
APIN
9A
d
11 A. It is certainly not correct.
12
Q.
And the next paragraph goes on to state, "The
13 mark was first used by the applicant or the
14 applicants related company, licensee or
15 predecessor in interest," and none of those
16 existed other than your company at that time;
17 correct?
18 A. Correct.
19
Q.
"At least as early as October," it says
20 "10/00/2004 and was first used in commerce at
21 least as early as that same date, 10-00-2004,
22 and is now in use in such commerce." Do you see
23 that?
24 A. Well, again, theyre talking about the mark was
25 first used. It doesnt say on every item. I
Beovich Walter & Friend
Exhibit B
Page 8 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l5 of 35 Page lD#:
l89l
Willard Bobosky
September 7, 2011
Page 193
1 say this, I was well aware of the extensions.
2 There was no point in me rushing to, to file a
3 statement of use three months after Im awarded
4 the registration. I could have stretched that
5 out for three years, and I would have had I
6 known that this is, this is the requirement.
7
Q.
But Mr. Ambrogimfiled onApril 3it006,
8 statement governmen1fht
9 s ea in
10
11
1
1
14
Q.
And you knew that?
15 A. I didnt know it was a false statement.
16
Q.
You knew that your company was not using --
17 A. We never discussed that part of it. He filed
18 the statement. He procured the trademark. He,
19 he signed everything. He did it all. I have
20 conversations with him. I have to rely on
21 counsel that I pick and pay.
22
Q.
So its your testimony that he made this false
23 statement without your knowledge?
24 A. Yes. And Im not so certain that he knew it was
25 false. Thats an assumption.
Beovich Walter & Friend
Exhibit B
Page 9 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l6 of 35 Page lD#:
l892
Willard Bobosky
September 7, 2011
Page 194
Y1 se?
ZE A.
3
Q.
And ii. was and;
4
correct?
Yes.
6
Q.
And it was your understanding that once the
7
statement of use was filed and you submitted the
8
hats, that the trademark would issue and it
9
would cover you for all the other goods you
10
listed in class 25 because you had shown use on
11
the hats?
12
That was my understanding per Ambrogis advice.
13
And it was your understanding that by submitting
14
the statement of use to the trademark office, it
15
is what the trademark office would rely upon in
16
deciding whether or not to give you a trademark
17
registration; correct?
18
A,
I, I dont know what their procedures are. I
19
mean, it was a requirement. We submitted it and
20
it issued. Why and how they do it, I, I have no
21
clue.
22
Q.
Just so the record is clear, as of April 3rd,
23
2006, when Mr. Ambrogi filed the statement of
24
use, you were not using We Not Me on
25
sweatshirts, sweatpants, shirts, tank tops,
Beovich Walter & Friend
Exhibit B
Page 10 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l7 of 35 Page lD#:
l893
Willard Bobosky
September 7, 2011
Page 197
1 and use in commerce?
2 A. Yes.
3
Q.
And at the time that registration issued on
4 July 18, 2006, you, in fact, were not using We
5 Not Me in connection with any of the goods
6 listed on this registration except for arguably
7 hats and caps; correct?
8 A. Correct.
9I
D 1 0 athYei
10
11k Yes.
Why?
eco gh"i# what
mE
WtJ
1
W11I
W
1", 7 of
18 notified
19 Ms,,,* Backman
20 t
tf
2
23
AN WMEMOM
24Q.
SS ameffd4d%Vp ema
25 Ms. Backman and adidas put notiMt
Beovich Walter & Friend
Exhibit B
Page 11 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l8 of 35 Page lD#:
l894
Willard Bobosky
September 7, 2011
Page 198
1
2 fraud
3 We1 t
4 discussior do a
5 and the ]11
6
7
Q.
So you placed adidas on notice. Part of adidas
8 response was to tell you that it felt you had
9 perpetrated a fraud on the trademark office, as
10 a result of which you entered into discussions
11 with your attorney, which Im not going to ask
12 you about, and subsequently you amended your
13 registration. Do I have that timeline generally
14 correct?
15 A. You, you have that correct, but Mr. Ambrogi was
16 very reluctant to, to file the amendment because
17 I --
18 MR. DRINNON: Objection, not responsive to
19 the question asked.
20
Q.
BY MR. FRIEDLAND: You can answer the question.
21 A. Well --
22
Q.
I dont want you to tell me what Mr. -- at this
23 point --
24 A. Okay. All right. Yes. Upon advice of counsel,
25 upon advice of counsel I did amend the
Beovich Walter & Friend
Exhibit B
Page 12 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page l9 of 35 Page lD#:
l895
1
2 A.
3
Q.
4
5
6
7
8
9
10
11
12
13
14
15 A.
16
Q.
17
18
19
20
21
22 A.
23
Q.
24
25 A.
Willard Bobosky
September 7, 2011
Page 200
familiar with this document?
I am.
And the last page of this exhibit, bearing
number 441, thats your signature under the
declaration; correct?
Thats my signature and its the only time I
ever signed anything before the trademark
office.
And is this the amendment to your registration
for We Not Me, which is Exhibit 89 that we were
just discussing, that you authorized Mr. Ambrogi
to file after adidas placed you on notice that
it thought you had perpetrated a fraud upon the
trademark office?
Yes.
And in this
middle"
,
page
Ido
And was that amendment made withdur
authorization to Mr. Ambrogis office?
It was.
Beovich Walter & Friend
Exhibit B
Page 13 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 20 of 35 Page lD#:
l896
Willard Bobosky
September 7, 2011
Page 201
2
3
4 - ods
5
6 A.
And wher:.c:
rnIP
8 s t r 1 s e
12
13 word
d unce:.aI4iflg
15
16
1.7
QUM :
18
19 c
20 s g h I
21 came out to be tfi once som .t
22 to my
23 state
24 fa 1
25 f
Beovich Walter & Friend
Exhibit B
Page 14 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 2l of 35 Page lD#:
l897
Willard Bobosky
September 7, 2011
Page 202
2 correct
3 A.
4 5
5
6
8 e x P
s s
9 b j
10 A.
1
NAM
A
ffloffi
14
W
16 a c knowle d
17 2004 but the e r tt
18 t
19 questfl.
20
Q.
Pins; correct?
21 A. Pardon?
22
Q.
Pins?
23 A. Pins and key chains.
24
Q.
Okay.
25
(Exhibit 91 marked for identification.)
Beovich Walter & Friend
Exhibit B
Page 15 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 22 of 35 Page lD#:
l898
Willard Bobosky
September 7, 2011
Page 208
I
1 A. Mr. Ambrogi did it.
2
Q. Why did you file a second application?
3 A. Well, because I wanted to continue to protect my
4 mark. And it was, since it had been amended to
5 just hats, I wanted to go further than that.
6
Q.
How did you want to go further?
7 A. Well, protect myself in other areas.
8
Q.
Such as?
9 A. Clothing and footwear.
LU
Q NIIiWe
j
en
12 my thakd Tknowwhere they! r t
13 leas thought I knew where theyd be going.
14 This and I subsequently
15
p
16
Q.
So you include clothing and footwear to cover
17 areas that you thought adidas might want to
18 cover?
19 A. Or somebody else.
20
Q.
But at that time there was no somebody else, was
21 there?
22 A. How do I know whos out there? There turned out
23 to be a lot of people that came aboard the We
24 Not Me bandwagon.
25
Q.
In March of 2008 you were several months into
Beovich Walter & Friend
Exhibit B
Page 16 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 23 of 35 Page lD#:
l899
Willard Bobosky
September 7, 2011
Page 209
1
making allegations that adidas had violated your
2
rights; correct?
3
A. Several months into it, yes.
4
Q. Okay. So, and adidas is a well-known apparel
5
and footwear company?
6
A. That they are. Doesnt give them the right to
7
steal my mark.
8
Q.
This application was also filed by Mr. Ambrogi
9
on the basis of your companys bona fide
10
intention to use the mark in commerce; correct?
11
A. Correct.
12
What were your plans with respect to using We
13
Not Me in connection with footwear as of
14
March 19, 2008?
15 A.
To apply the trademark to all levels of
16
clothing, from top to bottom, hats, to clothes
17
on the body, to their feet that they walk in.
18
Q.
My question was directed to footwear, what were
19
your plans?
20 A.
That was part of it.
21
Q.
And what --
22 A.
Footwear was top to bottom. Footwear was the
23
bottom part.
24
Q.
And what specific pans had you put into motion
25
Beovich Walter & Friend
Exhibit B
Page 17 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 24 of 35 Page lD#:
l900
Willard Bobosky
September 7, 2011
Page 210
111 W
2 t
3 wt
4
Q.
What effor ha ade a Maci. 2008,
5 to creaeWe N Me!fobtwea product?
6 P1an
7II
8 2j
001111
S
aI:I Iie
11
12 (Exhibit 93 marked for identification.)
13
Q.
BY MR. FRIEDLAND: Handing you Exhibit 93 which
14 bears adidas production numbers 533 and 534, it
15 is the next document in the file history of the
16 second We Not Me trademark registration. Do you
17 recall the trademark office issuing an office
18 action and seeking a more definite
19 identification of the goods you were seeking to
20 register?
21 A. I dont remember this. This, again, was handled
22 by Mr. Ambrogi.
23 (Exhibit 94 marked for identification.)
24
Q.
BY MR. FRIEDLAND: Exhibit 94, Bates production
25 numbers 530 to 532 from adidas, its entitled
Beovich Walter & Friend
Exhibit B
Page 18 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 25 of 35 Page lD#:
l90l
Willard Bobosky
September 7, 2011
Page 213
1
Q.
And--
2 A. You know, they dont just hand these things to
3 you. You pay your lawyer to get it for you.
4 You pay the filing fees.
5 MR. DRINNON: Brand, is there a question
6 pending?
7 THE WITNESS: No.
8 MR. DRINNON: I object to you answering when
9 theres not a question pending.
1 BY
eowi fl
12
13
15 regardto produci eephone
16 ca ii
17
18
21 proposals relat
22 A. The reason is Ididnreceive any.
23
Q.
You have to1etirifinish my question.
24 -- rl
!4o
q1hingpfootwear ofr
25 about Mar O O8
Jaed
this
Beovich Walter & Friend
Exhibit B
Page 19 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 26 of 35 Page lD#:
l902
Willard Bobosky
September 7, 2011
12
13
14
15
16
17
Page 214
S -
Yes.
(Exhibit 96 marked for identification.)
BY MR. FRIEDLAND: Handing you Exhibit 96, which
is the next document in the file history of this
particular trademark, bearing production numbers
from adidas 509 to 512. Were you aware that
Mr. Ambrogi filed an extension of time to file a
statement of use on your behalf in connection
with this particular trademark application?
I think so. Trying to see the date on it.
Wheres the date?
On the second page right below his name,
October 29, 2009.
A. Yes, I am.
1
3L
4 A.
5
6
Q.
7
. 1
10
11
18
MR. FRIEDLAND: Faked you out there.
19
MR. DRINNON: Yeah, you did.
20
(Exhibit 97 marked for identification.)
21
Q.
BY MR. FRIEDLAND: Handing you Exhibit 97, which
22
is a, the next document in the file history of
23
the registry for trademark bearing adidas
24
production numbers 495 through 507 and entitled
25
trademark/service mark statement of use. Are
Beovich Walter & Friend
Exhibit B
Page 20 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 27 of 35 Page lD#:
l903
Willard Bobosky
September 7, 2011
Page 218
I
1 of the web page, the one on the right, is that a
2 representation of the shirts?
3 A. It would appear to be.
4
Q.
Okay. And then if we jump ahead to page 506 and
5 507, are those additional pages that focus on
6 the shirts themselves?
7 A. 506 does, yes, and 507, too.
sentatIo
-.
1"
14 A. Thats corret.
15
Q.
Okay. And yesterday you and your counsel
16 provided us several samples. Im going to show
17 you -- And Im going to call it off-white. You
18 may have a more official color for it -- an
19 off-white color version for the shirt --
20 A. I think its sand.
21
Q.
-- sand version of the shirt. And can you
22 confirm for me that, in fact, the shirt, which
23 Im going to identify as the next number in our
24 sequence, 98, is an actual version of the shirts
25 that are shown on the web pages that we were
Beovich Walter & Friend
Exhibit B
Page 21 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 28 of 35 Page lD#:
l904
Willard Bobosky
September 7, 2011
Page 219
1 discussing?
2 A. I believe it is.
3
Q.
And this shirt, like the ones in the photos, has
4 the words We Not Me on the left sleeve?
5 A. Has it on the left sleeve and, yes, and I would
6 say it also says it via the symbol.
rect
1 Th a t I s correct.
11
Q.
And thats a third party that manufactured the
12 shirt as a blank; correct?
13 A. I, I dont know. I had them purchased through,
14 I wish I could remember the name of that
15 company. Its not Minuteman. Its the other
16 company.
17
Q.
Players Choice?
18 A. That would be it. Yes.
19
Q.
The T-shirt that is Exhibit 98 is, have you
20 sold, other than different color T-shirts, have
21 you sold different versions or designs of a We
22 Not Me T-shirt?
23 A. No. The T-shirts that were sold though do
24 contain that tag line as well. You were talking
25 about identification of whats on it and who
Beovich Walter & Friend
Exhibit B
Page 22 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 29 of 35 Page lD#:
l905
Willard Bobosky
September 7, 2011
Page 220
I
1 supplied it. The tag line that is there as
2 well.
3
Q.
By tag line, are you referring to what Im going
4 to hand you and Im going to mark it as 99 as
5 soon as we talk about it and figure out how I
6 can mark it. What is Exhibit 99?
7 A. This is affixed to the clothes, the hat, the
8 flip flops and the shirts identifying, further
9 identifying the source of the goods as, excuse
10 me, just to complete, the source of the goods
11 being We Not Me, Limited.
12
Q.
Who printed these for you?
13 A. I believe Minuteman Press did.
14
Q.
And would I find among the various Minuteman
15 Press invoices youve given me in this case in
16 discovery an invoice reflecting the printing of
17 these?
18 A. I dont know. I had several drafts done and
19 Ive had a relationship with that company for
20 25 years and something as small as this Im not
21 certain if they would have even billed me or if
22 they would have put, added whatever it was to
23 another bill. I just dont know.
p r iji d?
2
Beovich Walter & Friend
Exhibit B
Page 23 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 30 of 35 Page lD#:
l906
Willard Bobosky
September 7, 2011
Page 221
1 Q Which goods?
2 ; These, thes emsthat are on he, web.
.. i cago
4
be e to
1
1.
the f M s i s e?
1t,
1
1?
1. he hats wer ibte
1verybo6 ,
20
Q.
But the tag that youre holding in your hand as
21 Exhibit 99 was not affixed to the hats prior to
22 May of 07 when you moved to the 34 West Chicago
23 Avenue; correct?
24 A. Thats correct.
25
Q.
How are, what do you call these cards that are
Beovich Wafter & Friend
Exhibit B
Page 24 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 3l of 35 Page lD#:
l907
Willard Bobosky
September 7, 2011
Page 222
1 Exhibit 99?
2 A. Hangtags.
3
Q.
How are they affixed to the various products?
4 A. Theyre attached. My secretary would do it.
5 And this is, and Im not certain how she would
6 affix them and, and then cause them to be mailed
7 out if they were a web purchase.
8
Q.
So the two web purchasers we saw documents about
9 yesterday, Gabe Martin and Rachel Knox, they
10 would have received these products with these
11 hangtags affixed to them?
12 A. Thats what I believe. Thats my, that would
13 be, would have been my instructions to them.
14 think that they certainly did have the tag with
15 them.
16
Q.
Do you know that for a fact?
17 A. Im almost positive because I think I was there
18 when I was giving instructions.
You testified yesterday that other than 1eM
20 theinernet there were,WqXXbus aiei; think
21
:1 p
id iontt ?c.S itive y
2f I 11
t e
2 qt.
Beovich Walter & Friend
Exhibit B
Page 25 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 32 of 35 Page lD#:
l908
Willard Bobosky
September 7, 2011
Page 223
1 nc1ude these hangtags?
2
3 the
.....
92
I
8
9 a
a
1
14
wou
15
Q.
Can you take a look at Exhibit 38 a second,
16 which is your updated expense list.
17 A. Are you finished with these?
18
Q.
For the moment I am. Yes, sir.
19 A. Yes.
20 MR. FRIEDLAND: Stephen, I am doing this for
21 now. Is that okay?
22 MR. DRINNON: Sure.
23 MR. FRIEDLAND: Since we have multiples of
24 this, what Im going do is put it on a piece of
25 paper with both sides, that way well know. And
Beovich Walter & Friend
Exhibit B
Page 26 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 33 of 35 Page lD#:
l909
Willard Bobosky
September 7, 2011
Page 227
1 A. Yes.
I?
i] t3
e
4
he syboI \ritten
Stop
ofbp.
6
tbrj
8
ANIV
10
ops
13
i: $fr tJf
gggV
1
via
NO
20
iAnd nowhere e1
T hat producb
n the
ackg dj6
1Th r the words or t symbol
if
pp
h1YW? rin
2W,
25 Q.
Other than the size label?
Beovich Walter & Friend
Exhibit B
Page 27 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 34 of 35 Page lD#:
l9l0
Willard Bobosky
September 7, 2011
Page 289
CERTIFICATE
2
3
I, Aleshia K. Maeom, CSR No. 94-0296, do
4
hereby certify that WILLARD BRAND BOBOSKY
S
personally appeared before me at the time and
6
place mentioned in the caption herein; that the
7
witness was by me first duly sworn on oath, and
8
examined upon oral interrogatories propounded by
9
counsel; that said examination, together with
10
the testimony of said witness, was taken down by
11
me in stenotype and thereafter reduced to
12
typewriting; and that the foregoing transcript,
13
Pages 163 to 288, both inclusive, constitutes a
14
full, true and accurate record of said
15
examination of and testimony given by said
16
witness, and of all other proceedings had during
17
the taking of said deposition, and of the whole
18
thereof, to the best of my ability.
19
Witness my hand at Portland, Oregon, this
20
13th d September, 2011.
Oregon
CSM
23
Aleshia K. Macam
24
CSR No 94-0296
25
.Beovich Walter & Friend
Exhibit B
Page 28 of 28
Case 3:l0-cv-00630-PK Document l4l-l Filed 09/26/ll Page 35 of 35 Page lD#:
l9ll