`
`
`Exhibit B
`
`
`
`Case 1:17-cv-00770-JDW Document 245-2 Filed 10/19/23 Page 2 of 5 PageID #: 24549
`
`1/17/2018
`
`337-TA-1067
`Confidential
`
`Paul Clark
`
`Page 1
`
` UNITED STATES INTERNATIONAL TRADE COMMISSION
` WASHINGTON, DC
` Before the Honorable David P Shaw
` Administrative Law Judge
`
`INVESTIGATION NUMBER: 337-TA-1067
`_________________________________________________
`
`In the Matter of
`
`Certain Road Milling Machines
`and Components Thereof
`
`_________________________________________________
`
` VIDEOTAPED DEPOSITION OF
` PAUL CLARK
` CONFIDENTIAL
`Taken: 17 January 2018 By: Jackie McKone
` ____________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 245-2 Filed 10/19/23 Page 3 of 5 PageID #: 24550
`
`1/17/2018
`
`337-TA-1067
`Confidential
`
`Paul Clark
`
`Page 72
`
`1
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` in the 80s?
` MS. LEHMAN: Object to form.
` THE WITNESS: We have offered a cold planer
` to sell for -- for a while.
` BY MR. YONAN:
`Q. Is Cat Paving an expert in the cold planing
` industry?
` MS. LEHMAN: Object to form.
` THE WITNESS: Define expert.
` BY MR. YONAN:
`Q. Well, you've been in the space for quite -- quite
` some time; correct?
`A. We've limped in the space for quite some time.
`Q. What do you mean by limped?
`A. We've only had a very few models, and the CMI we
` had a few models, Bitelli we only had a few
` models. So we've been -- we've struggled in this
` space.
`Q. Why have you struggled?
` MS. LEHMAN: Object to form. You can
` answer.
` THE WITNESS: We hadn't updated the
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 245-2 Filed 10/19/23 Page 4 of 5 PageID #: 24551
`
`1/17/2018
`
`337-TA-1067
`Confidential
`
`Paul Clark
`
`Page 73
`
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` products like they needed to be updated.
` BY MR. YONAN:
`Q. Is that the only reason why you struggled?
`A. To me, that's been the -- the major reason is the
` PM200 and the PM102 for example were very old
` models.
`Q. Are there other reasons why you struggled in the
` space?
` MS. LEHMAN: Object to form.
` THE WITNESS: No. That's relayed to me
` it's -- that's been a major item.
` BY MR. YONAN:
`Q. So it's not for lack of funding?
` MS. LEHMAN: Object to form.
` THE WITNESS: Well, they kind of go
` hand-in-hand between funding and product line.
` BY MR. YONAN:
`Q. But Caterpillar Paving has never been at a loss
` for investing cash into its product lines has it?
` MS. LEHMAN: Object to form.
` THE WITNESS: Say the question again.
` BY MR. YONAN:
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 245-2 Filed 10/19/23 Page 5 of 5 PageID #: 24552
`
`LlL7l20t8
`
`337-TA-L067
`Confidential
`
`Paul Clark
`
`Page 2BI
`
`STATE OF MINNESOTA )
`)5>
`COUNTY OF HENNEPIN )
`
`I Jacqueline McKone, certified shorthand reporter
`and notary public for the State of Minnesota,
`there came before me the deponent herein
`certify
`to the truth
`who was sworn by me to testify
`concerning the matters in the cause and certify
`this transcript is a true transcript of my
`original shorthand notes.
`
`I am neither attorney nor counsel for,
`I certify
`nor rel-ated to, nor employed by any of the parties
`to the action in which this deposition is taken;
`and furthermore, f am not a relative or employee
`of any attorney or counsel employed by the parties
`interested in this action.
`hereto or financially
`
`transcript has been
`The cost of the original
`the deposition, and
`charged to the party noticing
`al-t parties ordering copies are charged at the
`same rate for such coPies.
`
`IN WITNESS
`this day:
`
`WHEREOF, I
`1B January
`
`have affixed my notarY seal
`2OLB
`
`uLlufl,ry (0,ß,
`,-Tacque ine McKone
`
`1 2 3 4 J
`
`6
`
`'7
`
`B
`
`9
`
`10
`
`11
`
`L2
`
`13
`
`14
`
`15
`
`L6
`
`71
`
`1B
`
`19
`
`20
`
`2L
`
`22
`
`www.DigitalEvidenceGroup,com Digital Evidence Group C'rt2018
`
`202-232-0646
`
`
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