Free Affidavit in Opposition to Motion - District Court of California - California

Case 3:07-cQ—O2748-I\/IHP Document 105¢2 Filed O2/15/2008 Page 1 0f4
EXHIBIT I
DECLARATION OF ROBERT CHARLES WARD
IN OPPOSITION TO APPLICATION FOR I
ORDER TO SHOW CAUSE RE: CONTEMPT

Case 3:07-cv—O2748-I\/IHP Document 105-2 Filed O2/15/2008 Page20f4
;W%é IN THR UNITED STATES DISTRICT COURT _
` FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

MARK LILLGE d/b/a CREATIVE =E_ &m; mg , §m$y%$_£
MARKETING CONCEPTS,
EE
R me;m;;ff, `T‘* **
l vs. Case N0. CO7~O274B MHP
ANOREW VERITY ANB CHRISTINA CHANG, ·
Defendants.

E
ANDREW VERITY and CHRISTINA CRANE,
M ; Ceumtexclaiments,
II *5-:***; '·~-.=_ l `
e& _; vs. {
MARK LILLGE d/b/e CREATIVE
MARKETING CONCEPTS, and DOES 1-20
Ceumtexdefemdamts.
%___“_______W__, /
I VIDEOTRPED OEROSITION OF MARIA TERESA PRSCUAL E
i l Rxidey, February 8, 2008
* I
Repmxted by:
CYNTHIA.L. THOMAS
CSR 295O
NANCY SORENSEN
Ceuxt Reporting Sexvices
_ 41 Sutter Stxeet, Suite 505 ‘
{ f‘©' ‘I‘` Sen Fxenciscc, Celifexmie 94104
\éC,? ___e (415) 986-4624


Case 3:07-cv—O2748-I\/IHP Document 105-2 Filed O2/15/2008 Page3of4
MARIA FASCUAL
lb in l (5/ll/07 e—mails between Chang and
2 hasoual was marked Exhibit 10.)
3 sr Ma. wash;
4 Q. And just so that there is no confusion, E think
5 it would be very fair for you to get Exhibit l and put
6 them next to each other. .
7 And Exhibit l you testified about earlier.
8 l It's an e—mail thread that begins with a message from
9 a Christina saying, Today is my last day. Thanks for your
1Gi support.
llg Do you see that?
N_ 12 A. Yes.
2 33 Q. And then do you see that Exhibit 10 is another
14 e—mail from Miss Chang?
$5 A. Yes.
16i Q. And did you ask Miss Chang where she was going
ll after leaving CMC?
lg A. Yes, I did.
39 Q. And so you chose to initiate that question with
20 her? _
2l A. Yes.
22 Q. So you wanted to know where she was going?
23 A. yes.
24 Q. And why did you want to know where she was
x` ` 25 going?
72

Case 3:07-cv—O2748-I\/IHP Document 105-2 Filed O2/15/2008 Page4of4
MARIA PASCUAL

{Am? ll A. Because I liked working with her. Tnat’s why I
2 wanted to fied out what happened and what ——.wnere she §
3 was going. ` _
4 Q. And did you want to know where she was going
5 because you were interested in oontinuinq the
6 relationship of buying promotional products from ner?
7 A. Definitely.
@ Q. Now, you mentioned that shortly after learning `
9 that she, Christine Chang, was leaving, that you got a
2
10% cali from someone at CMC?
ii; A. Yes, I did.
wf_ 12% Q. i And do you recall speaking to someone who you
Q -i 33% recall being the Qresident of CMC?
34 A. Yes. .
15 Q. And you do recall the name Mark Lillge?
16 R. The name is really familiar, but I —— I cannot
17;- really recall the name, but I know that he said he is the é
igi President of Creative Marketing Concepts. é
19 Q, and when yon asked whoever this person was, the
Z0 President of CMC, where Ms. Chang had gone, you do recall
211 that he told you sne's going to Canada because of a Visa
E2? issue?
23l A. Yes. ·
_ Z4! Q. And did you understand that to be an ;
S
ii'` `JJ 25 immigration problem? i
3
is i

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