`Case 1:17-cv-00770-JDW Document 369-16 Filed 04/12/24 Page 1 of 5 PagelD #: 33656
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`EXHIBIT 16
`EXHIBIT 16
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`Case 1:17-cv-00770-JDW Document 369-16 Filed 04/12/24 Page 2 of 5 PageID #: 33657
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`Confidential
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` UNITES STATES INTERNATIONAL TRADE COMMISSION
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` Washington, D.C.
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`Page 1
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` Before the Honorable David P. Shaw
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` Administrative Law Judge
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`________________________________________________________________
`
`In the Matter of:
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` Investigation No. 337-TA-1067
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`CERTAIN ROAD MILLING MACHINES
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`AND COMPONENTS THEREOF
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`________________________________________________________________
`
` ***CONFIDENTIAL***
`
` Deposition of:
`
` JEFF WILEY
`
` January 10, 2018
`
`Reported by: Jenny Checuga, LCR, RPR
`
`________________________________________________________________
`
`Job No. 135397
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`TSG Reporting - Worldwide 877-702-9580
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`Case 1:17-cv-00770-JDW Document 369-16 Filed 04/12/24 Page 3 of 5 PageID #: 33658
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`Confidential
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`Page 142
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` JEFF WILEY
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`BY MR. WALTER:
`
`Q. To your knowledge is -- strike that.
`
` Do you have any idea why Mr. Matiko may have
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`been concerned with this particular machine?
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` MR. LEVY: Objection, vague, calls for
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`speculation.
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` THE WITNESS: His job's to report any
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`competitive machine that's running out there that we
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`might not know about. It could have been another
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`model. He just heard about it, and he's just
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`reporting it.
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`BY MR. WALTER:
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`Q. Okay. Thank you. Move onto another exhibit.
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` MR. WALTER: Going to mark this
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`Exhibit 17.
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` (WHEREUPON, a document was marked as
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`Exhibit Number 17.)
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`BY MR. WALTER:
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`Q. This document bears Bates stamp 341152
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`through 53.
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` Do you recognize this document?
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`A. Yes.
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`Q. What is this document?
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`A. That's an e-mail to me, telling me that the
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`TSG Reporting - Worldwide 877-702-9580
`
`
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`Case 1:17-cv-00770-JDW Document 369-16 Filed 04/12/24 Page 4 of 5 PageID #: 33659
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`Confidential
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`Page 143
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` JEFF WILEY
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`Cat machine showed up in Nashville.
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`Q. This is the same PM-600 series we were
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`talking about earlier in Nashville?
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`A. Yes.
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` MR. LEVY: Objection, vague.
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`BY MR. WALTER:
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`Q. And then it says here that Caterpillar showed
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`up today. When they get it inside the shop, we'll
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`get an inspection done. Do you know who is being
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`referred to by "they" in this e-mail?
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` MR. LEVY: Objection, vague.
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` THE WITNESS: Somebody unloaded it.
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`That's all they are talking about. I'm not sure who
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`that individual was.
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`BY MR. WALTER:
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`Q. Okay. And it says here, "...to get an
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`inspection done." Do you know what was meant by
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`that?
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` MR. LEVY: Objection, vague.
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` THE WITNESS: Well, just my opinion, but
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`this is my used equipment guy and he probably saw it
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`on a trailer, and he has no idea why that machine's
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`there. So I don't know what he meant by that.
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`TSG Reporting - Worldwide 877-702-9580
`
`
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`Case 1:17-cv-00770-JDW Document 369-16 Filed 04/12/24 Page 5 of 5 PageID #: 33660
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`Confidential
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`Page 144
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` JEFF WILEY
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`BY MR. WALTER:
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`Q. Was there an inspection done, to your
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`knowledge?
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`A. Not by me.
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`Q. Was there an inspection done to your
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`knowledge by someone other than you?
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`A. I had Tom run the machine into the shop
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`because he's the most familiar man we have, as far as
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`moving that machine around and understanding how it
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`works without running into something. So Tom spent
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`some time around it.
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`Q. By "Tom," you mean Mr. Chastain?
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`A. Yes.
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`Q. And when you say "run the machine," you mean
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`physically bring it in or operate it?
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`A. Start it up, move it, and get it in.
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`Q. I think we can move on on this one. One
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`moment.
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` Take another look at the top of this e-mail,
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`it says December 19, 2016.
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`A. Yes.
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`Q. Do you have any reason to dispute that date?
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`A. No.
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`Q. Based on that date, would it cause you to
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`TSG Reporting - Worldwide 877-702-9580
`
`
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