deposition of timothy williams 1 superior court of ... 9 a this is my updated cv. not cv, but cases

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  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 1

    1 SUPERIOR COURT OF CALIFORNIA

    2 COUNTY OF SANTA CLARA

    3

    4 GARRETT BONDAUG, ) )

    5 Plaintiff, ) )

    6 ) vs. ) Case No. 1-12-CV-238152

    7 ) )

    8 CITY OF SANTA CLARA, a public ) entity; GREG DEGER, an )

    9 individual; COLIN STEWART, an ) individual; and DOES 1 through )

    10 50, Inclusive, ) )

    11 Defendants. ) _________________________________)

    12

    13

    14

    15

    16

    17

    18

    19 DEPOSITION OF TIMOTHY T. WILLIAMS, JR.

    20 Los Angeles, California

    21 Monday, January 5, 2015

    22

    23

    24 REPORTED BY:

    25 RICH ALOSSI, RPR, CCRR, CSR NO. 13497

  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 2

    1 SUPERIOR COURT OF CALIFORNIA

    2 COUNTY OF SANTA CLARA

    3

    4 GARRETT BONDAUG, ) )

    5 Plaintiff, ) )

    6 ) vs. ) Case No. 1-12-CV-238152

    7 ) )

    8 CITY OF SANTA CLARA, a public ) entity; GREG DEGER, an )

    9 individual; COLIN STEWART, an ) individual; and DOES 1 through )

    10 50, Inclusive, ) )

    11 Defendants. ) _________________________________)

    12

    13

    14

    15

    16

    17

    18 DEPOSITION OF TIMOTHY T. WILLIAMS, JR., taken on

    19 behalf of the Defendants, at 445 South Figueroa Street,

    20 Suite 3100, Los Angeles, California, on Monday, January 5,

    21 2015, from 10:47 A.M. to 12:40 P.M., before RICH ALOSSI,

    22 RPR, CCRR, CSR NO. 13497, pursuant to Notice.

    23 * * *

    24

    25

  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 3

    1 APPEARANCES:

    2

    3 For the Plaintiff:

    4 HOLMES & USOZ LLP BY: STEPHEN J. USOZ, Attorney at Law

    5 333 West Santa Clara Street, Suite 805 San Jose, California 95113

    6 (408) 292-7600 steve@hulawyers.com

    7 For the Defendants:

    8 RANKIN, STOCK & HEABERLIN

    9 BY: JON A. HEABERLIN, Attorney at Law 96 North Third Street, Suite 500

    10 San Jose, California 95112-7709 (408) 293-0463

    11 jheaberlin@rllss.com

    12 Also Present:

    13 GARRETT BONDAUG

    14

    15

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    17

    18

    19

    20

    21

    22

    23

    24

    25

  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 4

    1 I N D E X

    2 WITNESS PAGE TIMOTHY T. WILLIAMS, JR.

    4 BY MR. HEABERLIN 5

    5 BY MR. USOZ 76

    6

    7

    8 E X H I B I T S

    9

    10 (None.)

    11

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  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 5

    1 LOS ANGELES, CALIFORNIA; MONDAY, JANUARY 5, 2015

    2 10:47 A.M. - 12:40 P.M.

    3

    4 TIMOTHY T. WILLIAMS, JR.,

    5 having been first duly sworn by

    6 the court reporter, was examined

    7 and testified as follows:

    8

    9 EXAMINATION

    10:47 10 BY MR. HEABERLIN:

    11 Q Good morning, sir.

    12 Can you are please state your name for the

    13 record.

    14 A Timothy T. Williams, Junior. T-i-m-o-t-h-y,

    10:48 15 Williams, W-i-l-l-i-a-m-s.

    16 Q Mr. Williams, have you ever had a deposition

    17 before?

    18 A I have.

    19 Q About how many times?

    10:48 20 A I anticipated your question, and I have an

    21 answer here for you.

    22 Forty-seven times.

    23 Q Okay for me to dispense with the ground rules

    24 for a deposition?

    10:48 25 A You can do that.

  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 6

    1 Q Okay. There are a number of file materials

    2 in front of you, and I want to, in the most efficient

    3 way possible, inventory everything that's here.

    4 Let me just ask you first: Did you bring

    10:48 5 your entire file relating to Mr. Bondaug's case?

    6 A I did.

    7 Q Can you -- do you have an index, or do you

    8 want to sort of take me through things?

    9 A I have an index for each volume, and it's

    10:48 10 self-explanatory there. I made some copies for -- I

    11 know you wanted copies of my notes; so I made copies of

    12 that as well.

    13 Q Okay. Well, let's just start with your

    14 first --

    10:49 15 A First volume.

    16 Q -- first volume.

    17 And you're pushing that over to me. And the

    18 first tab, is that "PL chrono?

    19 A Yeah.

    10:49 20 Q And what is that?

    21 A That's the chrono, the time I spent on the

    22 case.

    23 Q The first entry I see is 12/2/2014?

    24 A That's correct.

    10:49 25 Q Is that when you were first contacted in this

  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 7

    1 case?

    2 A I believe so. I don't have the narrative in

    3 front of me, but I'm sure that it was.

    4 Q Fair enough.

    10:49 5 And then Tab 2 is "Notes."

    6 Probably an obvious question, but what's

    7 contained --

    8 A Notes.

    9 Q Notes on depositions? Notes on everything?

    10:49 10 A Notes on everything.

    11 Q Okay.

    12 A Then I have my CV -- current CV and log of

    13 cases I'm handling.

    14 Q I went on your website over the weekend and

    10:50 15 printed off your CV.

    16 Do you know whether this is the same as

    17 what's on there now?

    18 A No. My person is going to be updating my

    19 stuff. I brought my current stuff with me.

    10:50 20 Q Thank you.

    21 Line 3, "Confidential Correspondence," what's

    22 contained therein?

    23 A I don't know what you have there. I have to

    24 look at it.

    10:50 25 Q Sure.

  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 8

    1 A It's just one of two emails from -- and I

    2 also -- your notice for me to do a deposition prior to

    3 me being contacted.

    4 Q Just for the record, that's the Notice of

    10:50 5 Deposition that I signed on December 10th, 2014?

    6 A That's correct.

    7 Q Okay. 4 is your retainer. And that's a

    8 retainer agreement?

    9 A That's correct.

    10:51 10 Q Did you happen to bring a copy of that?

    11 A I did.

    12 Q Okay. Great.

    13 5, "expenses." Looks like it's blank.

    14 A That's correct.

    10:51 15 Q What typically would go in the "expenses"

    16 tab?

    17 A If I would go someplace that I have parking

    18 related to this or travel or anything that's related to

    19 expenses.

    10:51 20 Q 6 is your billing. And then this is -- I

    21 guess it's stated herein, but up through what date is

    22 your billing?

    23 A Current up to today.

    24 Q Your hourly is 300?

    10:51 25 A It is.

  • Deposition of Timothy Williams

    Pulone Reporting Services 800.200.1252 www.pulone.com 9

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