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

I&-SQUISH Condo mr scIt”M Daniel M. Lund
1
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I 0. Do you rcmcmhcr what you sold il lid
I publications?
2 .A. The price I sold il li>r?
3 (J, Yes.
4 A. II was in the SX,OOO I’igurc. I’m not sure
5 cxnclly whal il was.
h 0, Do you know how nlany nlilcs you had on il?
7 A. II wx over IO,OOO, hul I’m WII sure of the
X 6~x1 niilcagc on il.
LJ 0. Okay. So you dtl IW ahoul IIW ‘96 Sportstcr
I) you purchased, mrl then you’ve indicnlcd you purchased 3
I ‘97 niotlcl t‘roni Sl. I’ml I Ix-Icy?
2 A. uh-tllllL
3 Q. Was lhal lhc sccontl I Inrley-Davidson lhal you
4 owned?
5 A. Uh-huh.
6 Q. What model was that?
7 A. Same thing, 1200 Custom sportster.
8 Q. What did you pay for that?
9 A. I think that was probably in the same figure
0 as the ‘96 was, probably around $10,000.
I Q. And had you placed your name on a waiting list
2 to obtain that motorcycle?
,3 A. Yes, I did.
:4 Q. Did you have to pul any money down to get on
5 that one?
Page If
I A. No money down.
2 Q. Do you know if the price you paid for the ‘97
3 gportster was above MSRPY
4 A. Yes, it was.
5 Q. Do you know by how much it was above MSRPS
6 A. No, I’m not sure.
7 Q. Do you still have that motorcycle?
8 A. No. 1 traW that in when I bought the one
9 from Twin City Harley.
0 Q. And you said you owned three Harley-Davidsons?
1 A. Yeah. That was my second one, the ‘97.
I2 Q. Thethirdonewastheoneyouobtainedfrom
13 Twin City Harley?
14 A. Yes.
15 Q. Do you belong to any motorcycle or
16 H&y-Davidson-related clubs, groups, or .aqociations?
17 A. I belong to the HOG chapter. I don’t belong
I8 to any chapter. I’m a member of the HOGgroUp.
I9 Q. When did you become a member of HOG?
20 A. When I bought my first motorcycle, they
11 automatically signed you up and paid your first-year
L2 membership.
13 Q. And you retained a membership ever since?
14 A. Yes, I have.
25 Q. And as part of that, do you rcmive any
‘age 13 - Page 16
2 A. Yes, I do. They scncl oul m xxxssory
3 magazine, culalog, parls ~md sld‘l‘. And I dso ycr ;I
4 couple 01’ ma@ncs lhal lclls ahoil~ Ihc niolorcyclcs,
5 stories and ahout other mcmhers mltl slul‘f.
h 0, Arc Ihosc IIW;-rclnlctl mgnzincs’!
1 A. Yes.
8 0. Do you suhscrihc IO tiny other --
9 A. I’m also a member of the AMA. which they IIWJ
0 a nxgazinc loo.
I Q. Any olhcr motorcycle-lcl3lctl pthlicalions’!
2 A. As fir as clubs go?
3 Q. JUSI in general.
4 A. I belong to the Christian Motorcycle
5 Association, too, CMA.
6 Q. Any olher clubs or groups? associations’!
7 A. 1 don’t believe so.
8 Q. Any other publications: motorcycle-related
9 publications that you routinely receive?
:O A. No.
!I Q. Do you belong to any Internet or e-mail
12 communication groups of any type like chat rooms, that type
:3 of stuff?
!4 A. I belong to -- well the C:MA has a -- it’s not
!5 a chat room. It’s just an e-mail address. All the members
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1 have e-mail addresses, and then when you send out e-mail
2 like they’re -- like when they’re having their meetings or
3 whatever, then they send it out on e-mail. That’s the only
4 one as far as motorcycle groups.
5 Q. All right. Do you know anyone in the
6 motorcycle business, someone thal works for a motorcycle
7 dealer or involved in the motorcycle business in any way’!
8 A. Huh-huh, no. -
9 Q. Let me ask you about your experience with Twin
IO CitiesHarley-Davidson. Okay?
I1 A. Okay.
I2 Q. Do you know gny of the owners or employees of
I3 Twin City Hfirlw-Davidson?
I4 ,A...JustwhenImetKevinwhenIboughtmy
I5 motorcycte.
I6 Q. You didn’t know anybody & that?
I7 A. No, I didn’t.
I8 Q. How did you learn about Twin City
I9 Harley-Davidson?
20 A. It was just the closest dealership to my
21 house, so I just went out there to look at their
22 motorcycles.
23 Q. Just strictly due to location?
24 A. Yes.
25 Q. You previously had a relationship with
A
Kirby A. Kennedy & Associates (952) 922- 195 5