To: Proud_Infidel who wrote (925 ) 9/28/2000 12:21:19 PM From: ima_posta2 Respond to of 1929 More bad news for VSEA! ACTUAL VSEA SLAPP DEPOSITION TESTIMONY! FELCH: It's implying that I am a chronic liar, it's implying that I do not enforce company policies and write salary reviews as required. It's implying that I am fabricating stories of laboratory sabotage, and it also is implying that I am incompetent at work. FALCON: The lab sabotage, did that ever reach a conclusion, the investigation, to your knowledge? McMAHON: Objection, vague, overbroad, not reasonably calculated to lead to the discovery of admissible evidence. But you can answer. FELCH: I think it was answered in the last deposition, and I don't know whether -- that it came to any conclusions. FALCON: Since your last deposition, have any weird occurrences occurred in any of the laboratories that you supervise? McMAHON: Objection, vague, overbroad. You can answer the question. FELCH: No. FALCON: Did Mr. Moro of the security staff at Varian ever tell you his conclusions of what he found from his investigation into the lab sabotage incident? McMAHON: Objection, vague, overbroad, not likely to lead to the discovery of admissible evidence. But you can answer the question. FELCH: I don't recall having a conversation directly with him regarding this. FALCON: On a truth scale of one to ten, one being completely untruthful and ten never telling a falsehood, white lie, where would you fall on that chart -- McMAHON: Objection, vague -- FALCON: -- in your opinion? McMAHON: Objection, vague, overbroad, calls for speculation, incomplete hypothetical. You can answer the question if you can. FELCH: Do you mean that the nine would mean that I tell the truth 90 percent of the time? Or does nine mean almost never tells a lie, just even a little white lie? I mean, you have to define the scale. FALCON: Let's say that nine says almost always tells the truth, but an occasional white lie. McMAHON: Objection, vague, calls for speculation, incomplete hypothetical, overbroad. You can answer the question. FELCH: I would say that when it comes to matters at work, I'm very close to a ten. And probably general life, between a nine and a ten. FALCON: What's the most troublesome white lie or untruth that you've ever had to make? McMAHON: Objection, overbroad, vague, calls for speculation, foundation. You may answer the question. FELCH: I would rather not divulge details, because it involves personal family things, but small little things related to my children's habits that I may be telling a mother.