Carlo Herrera testifies about Richard 'Dick' Aurelio - the fascist SLAPP CEO & Chairman of VSEA!
FALCON: You're married? HERRERA: Yes. FALCON: Did your wife work at Varian at one time? HERRERA: Yes. FALCON: In the thin film business? HERRERA: Yes. FALCON: And did she work with or for Dick Aurelio? Do you know who Dick Aurelio is? HERRERA: Yes. FALCON: Did she work for or with Dick Aurelio? HERRERA: He was -- FALCON: He was the head of that? HERRERA: Well, yes. FALCON: Okay. POPPE: Objection; vague. HERRERA: Yeah. FALCON: Your wife had complaints regarding Dick Aurelio, did she not? POPPE: Objection; calls for husband-wife communications. FALCON: It would be great in a criminal action. POPPE: A person is not required to testify about communications they have with their spouse. FALCON: Okay. Are you aware of any complaints lodged against Dick Aurelio made by anybody? POPPE: I will -- objection. I'll instruct the witness not to respond to the extent he learned about any such complaints from his wife or from counsel. Subject to that instruction, you can answer the question if you understand it. HERRERA: Don't understand what he's asking. FALCON: Sometimes working conditions of a place become unsatisfactory, intolerable. Sometimes bosses tend to be oppressive, excessive, whatever, harassive. Are you aware of any such complaints made by anybody regarding Dick Aurelio? POPPE: Again, I'll instruct the witness that he shouldn't testify about anything that he has learned from his wife or from counsel, and subject to that instruction, you can answer the question if you understand it. HERRERA: I am not sure the content of that question how it's -- FALCON: Do you need to take a break? POPPE: I think he's saying he doesn't understand the question. FALCON: Do you have a source of information -- another person, a document, a news article -- about complaints about Dick Aurelio other than what you may have heard from your attorney? POPPE: Or from your wife. FALCON: Well, to the -- I don't agree with that one. That part, I would like to have certified. POPPE: Sure. I am instructing the witness not to answer about anything he learned from his wife or from counsel. FALCON: I don't want to know what you learned from your attorney, if that's your only source of information. He is also instructing you that if your only source of that information is your wife, he is telling you not to answer. So for right now, eliminating those two sources, do you have any source of information regarding complaints made by anyone regarding Dick Aurelio? HERRERA: No. |