`Case 1:17-cv-00770-JDW Document 250-32 Filed 10/25/23 Page 1 of 5 PagelD #: 25966
`
`EXHIBIT 32
`EXHIBIT 32
`
`
`
`Case 1:17-cv-00770-JDW Document 250-32 Filed 10/25/23 Page 2 of 5 PageID #: 25967
`
`3/16/2023
`
`Wirtgen America Inc. v. Caterpillar Inc.
`
`Jeffrey Hoyle
`
`Page 1
`
` IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF DELAWARE
` ___________________________
` WIRTGEN AMERICA, INC., )
` Plaintiff, )
` -vs- ) Case No.
` CATERPILLAR, INC., ) 1:17-cv-00770-JDW-MPT
` Defendant. )
` ___________________________)
` P.M. SESSION
` VIDEOTAPED DEPOSITION
` TAKEN REMOTELY VIA VIDEOCONFERENCE
` OF JEFFREY HOYLE
` MARCH 16, 2023
` 1:47 P.M.
`
`
`
` Reported by Audra E. Cramer, CSR No. 9901
` ________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 250-32 Filed 10/25/23 Page 3 of 5 PageID #: 25968
`
`3/16/2023
`
`Wirtgen America Inc. v. Caterpillar Inc.
`
`Jeffrey Hoyle
`
`Page 22
`
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` BY MR. LEVY:
` Q. Do you agree or disagree that it was
` horrible timing to implement the software update
` described in this email?
` A. Well, generally speaking, any time we
` are in discussion of a ship hold, it's always
` horrible timing.
` Q. Understand.
` And the next sentence is "NLR is about
` to ship machines."
` Do you see that?
` A. Yes. Yes.
` Q. What does NLR refer to?
` A. NLR is North Little Rock.
` Q. And this was a facility producing PM600
` and PM800 machines?
` A. Yes.
` Q. Have you ever been to the North
` Little Rock facility?
` A. I have.
` Q. And it's no longer producing cold
` planer machines?
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 250-32 Filed 10/25/23 Page 4 of 5 PageID #: 25969
`
`3/16/2023
`
`Wirtgen America Inc. v. Caterpillar Inc.
`
`Jeffrey Hoyle
`
`Page 23
`
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` A. That's correct.
` Q. It's currently producing reclaimer
` machines?
` A. Yes.
` Q. About how many cold planer machines
` were produced by the North Little Rock facility?
` A. I apologize. I'm not sure I could give
` you that number.
` Q. Mr. Hoyle, don't apologize for not
` knowing the answer. That's not an issue at all.
` I'll ask questions on some issues, I'm sure,
` that are beyond what you might know.
` So you don't have a production capacity
` in mind for North Little Rock?
` A. No. We went through several ups and
` downs in the production process there, so I
` really don't have a good feel for the number.
` Q. Understand.
` Well, what ups and downs did you have
` with the production process in North Little Rock
` for cold planar machines?
` A. As we ramped up North Little Rock to
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 250-32 Filed 10/25/23 Page 5 of 5 PageID #: 25970
`
`3/16/2023
`
`Wirtgen America Inc. v. Caterpillar Inc.
`
`Jeffrey Hoyle
`
`Page 54
`
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` STATE OF CALIFORNIA )
` COUNTY OF LOS ANGELES ) SS.
`
` I, AUDRA E. CRAMER, C.S.R. No. 9901, in and for
` the State of California, do hereby certify:
` That, prior to being examined, the witness named
` in the foregoing deposition was by me duly sworn to
` testify the truth, the whole truth and nothing but the
` truth;
` That said deposition was taken down by me in
` shorthand at the time and place therein named, and
` thereafter reduced to typewriting under my direction,
` and the same is a true, correct and complete transcript
` of said proceedings;
` I further certify that I am not interested in the
` event of the action.
` Witness my hand this 27th day of March,
` 2023.
` _____________________
` Certified Shorthand
` Reporter for the
` State of California
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
`
`202-232-0646
`
`
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