What is your current title?

Vice-president of corporate research and development.

How long have you held that position?

Since October 1975.

And prior to that time, did you have any other position at Generico, Inc.?

Yes.

What was that position?

Director of advance product development.

And for what period of time did you hold the position of director of
advance product development?

Starting in May of 1975.

Prior to that position, did you have any other position at Generico, Inc.?

No.

As director of advance product development, who did you report to?

Fredick Quimby.

What were your responsibilities as director of advance product development?

Primarily, my responsibility involved advance development work on new
product areas for the corporation. The majority of my time was working on
a product which has since been announced as the Gen-o-Matic Plus.

Did you work on the Super-matic Extra product at all during the time you
held that position?

What do you mean by "at all"?

Well, did you have any responsibilities with regard to the product known
as Super-matic Extra at the time you were director of advance product
development?

I had no direct responsibilities for the development of Super-matic Extra
during that period.

Did you have any indirect responsibilities with regard to Super-matic
Extra during that period?

Not what I would call responsibilities. The people who were working on
portions of Super-matic were physically near where my office was, and so
at times, I would discuss aspects of the product with them in a kind of
informal consulting arrangement.

And who were those people that you had those kind of discussions with?

William Nilly for one. I can't remember who else was involved at the time.

And when you assumed your present position in October of 1975, who did
you first report to?

Initially, I reported to Fred Quimby.

Did that change in your position involve a promotion that occurred in
October of 1975?

No. In October of 1975, yes, I was promoted to vice-president of corporate
research development, and I continued to report to Fred Quimby at that
point in time.

Was the position that you assumed a new position?

Yes, it was.

Did your responsibilities change in any way when you became vice-president
of corporate research and development?

Yes, they did.

And how did they change?

I assumed a responsibility in terms of coordination of various product
development activities across the company, particularly in the areas of
product planning between the various business units.

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