2001-01-26 Harley-Davidson Response - Minnesota Judicial Branch

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Daniel M. Lund
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I .4PYEAIlAN A. Good morning.
1 Q. My name is Michael Lafeber, and I rcprc.sent
I Twin City Harley-Davidson. I want to first ask you iI
2 you’ve ever had your deposition taken before.
3 A. Yes.
4 Q. Let me start hy laying down a couple of ground
5 rules. My guess is your attorney has already discussed
6 some of these things with you, but as you can see, we have
7 a court reporter here,;so I want you lo avoid any nonverbal
8 responses such as shaking your head. I need you to avoid
9 answers like huh-huh or uh-huh that are very difficult for
0 the court reporter to get down. Okay? i
1 A. Yes.
2 Q. Second, if you would avoid -- if you would
3 please wait until I’m done asking my question before you
4 answer it so we don’t talk over each other. Again, it’s
5 very difficult for the court reporter to get clown.
Page 5
I A. Yes.
2 Q. And lastly I don’t want you IO answer any
3 questions that you don’t understand. If 1 ask a queslion
4 that you don’t understand, which 1 prohahly will do at some
5 point in the deposition, just ask me to rephrase the
6 question or let me know you don’t understand it, and f’tl
7 be mote than happy to clarify it for you.
8 A. Okay. -
9 Q. Do we have an understanding that you.won’t
IO answer any questions that you don’t understand?
I! A. Yes, sir.
12 Q. Okay. With that said, we’ll start with an
I3 easy one. State your full name for the record, please.
I4 A. Daniel Mark Lund:
IS
I6
Q. And what is you
A. Sixty-seven.
‘t age?
I7
18
%“”
Q. And your date of birth?
A. 2112133.
I9 Q. What’s your current address’!
20 A. 5021 Pourth Street Nortlmt, Columbia Heights
21 55421.
22 v. And how long have you lived d that address?
23 A. Since ‘SA.
24 Q. And let IIIZ ask you ahout your education. Did
25 you graduate from high school?
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