“The meek with teeth shell inherit the earth” [sic]

No Devil Lived On?=nO deviL liveD oN?

To: NextraTerrestrial listeners and doers of good.

It is my hope that the following deposition recently taken by a competent anD experienced attorney will help folks get an idea of the nature of the process that takes place at a deposition in the course of discovery, that the devil is not in the detail but rather it takes detailed individuals to fashion the correct statements, to mention little of what little it takes to pull together someone who is already the queen-bee while would-be kings trumpet about in disguise disposing of a pet or tTOo along the way, birds to boot.

And of course it is common knowledge the emperor has no clothes, furriers a thing of the past, to avoid though at all cost making the same mistake twice.

We all pay when others get tTOo pumped up trickling all the way down to the point where we all pay at the pump. There is a joke I once heard about these two extraterrestrials who arrived on earth for the very first time and where rather hungry and as they approached a gas station, the one said to his mate,

“Hey, look at that dude filling up everyone standing in line but we don’t have the right currency. I guess I will just pop him one square between the eyes with my shoulder pistol.”

The second alien became quite alarmed as his buddy started taking aim,

“Hey man, don’t mess with that dude. He is simply doing his business.”

The first alien pays no attention to the pleas of his buddy and pulls the trigger. The gas station explodes and the two aliens end up in Timbuktu. As they gather themselves off the ground the first alien says to the second,

“Christ almighty how was I to know the guy was ready to blow a fuse?”

His buddy turns to him and says,

“I told you not to mess with the dude. Anyone who can take their shalong, wrap it around their shoulder and then stick it in their ear after giving it to a third party in the rear is not someone you want to mess with.”

The moral of this story can come in several forms. First and foremost, when I mean business I mean business. Second, when someone messes with my business they are messing with the lifeblood of me. Third, the level of testosterone has clearly been on the increase in our society ever since folks like Pythagoras concluded that man, not God, can take care of himself as long as he abides by nature’s laws.

The Pythagoras Theorem was much more than simply putting an equation to a form understood by folks who came thousands of years before him. “This plus this equals that” should have been enough for everyone to realize that we have the power within each one of us to square things neatly away, that the more we divide just like a right angled triangle, the more we remain alike, much the same, until such time as there is only one. Hence, the expression, “Number is the essence of all things, good or evil.” The choice if doing good or bad is ours for the taking.

The genius of Pythagoras was not putting into practice the benefits of a right angle triangle that forms the basis of all mathematics but rather for the first time in history mysticism and superstition had been taken out of the equation in the quest to understand the meaning of life without eliminating spirituality from his midst, believing it was vitally important to keep women on the forefront of science and physics, paying very careful attention to form as well as substance.

The rule of law when practiced by the best is something to behold. Unfortunately not everyone can be as masterful as Mr. “Circle” K but more troubling is how easy it is for folks to lie and think they can get away with it simply because folks have essentially been lying, cheating and stealing for some 2,500 years and getting away with it.

Genius is something each one of us is born with and only when folks start interfering with the sequencing do things begin to unravel. Wacko begins when kids are allowed to get away with “murder” thinking that they are more special than those who give them the right care which doenst always come from their biological parents. Once we start using words like “I love you” which have little meaning since it means something different to each and every one of us to the point that it eventually lands on deaf ears although I am all in favor of the world gobbledygook even though I sometimes have trouble with its spelling. Thank God though for allowing us to make it through to the Digital Age.

The breakthroughs in technology that led to the transistor that resulted in the chips that power our computers are not that far from the chip off the old block, bloc-buster.com to boot, that allows us to type away with spell check getting better with each passing minute, amount to nothing more than the discoveries by the Babylonians of the 60 minute clock and the number system which makes perfect harmony to those of us not having forgotten our past, tapped in to the calls of nature, now knocking on the doors of both friend and foe, having no fear.

When nature calls each one of us pretty much knows what to do and so we come down to what I believe is at the grass roots of all that sets us apart from one another while we go at each others throats like there is no tomorrow. It can all be found in the Zquestion which is very much a WIP as in Work in Progress which will require input from each one of us who remains on this earth as we continue to take pot shots at one another for reasons that should no longer be that difficult to explain to our children.

Those of us “blessed” with helping raise other peoples’ children know only too well what it means to have a pointed gun constantly pointed at one’s throat not knowing one day to the next wet-her a rapacious individual who simply mothered or fathered a child will be able to pull out their “shalong” and blow us to kingdom come just because “I say so” [sic].

Kids are sick to death of the threats, the blows, the destructive nature of parents who themselves were poorly parented to begin with and now pass on along with their genes the nonsense that has been blowing in the air in large measure the result of the industrial revolution which simply put Europe on the map.

The indigenous peoples of Africa and the Americas were doing just fine but nevertheless welcomed the me on horse back with open arms believing they were in fact Gods armed to boot as they stole their purses and then some, time for Yale University to return what rightfully belongs at the top of Machu Picchu.

In turning back the clock just a tick in what is nothing more than one moment in time, we can see how time has in fact stood still as we have gone about blowing each other to smithereens. Getting back to Time Moment One is nothing more than an ego trip for a bunch of TOES who want their place in the history books along with their Wall Street brothers who have been firing up storms while the rest of the world has looked on in amusement especially when one considers those bowler hats, ducking though for cover as James Bond 007 does his thing on behalf King and country to mention little of the force de jour that emanate from queens with testosterone bulging through their varicose veins who sit on the throne encompassing the most hedonistic form of an ugly monarch with no one willing to stand behind her, keeping her in check, fearful of the winds of war.

There is though nothing funny about being called at night especially if you are a widow, orphan or pensioner from a guy coming out of a boiler room stealing your last nickel which has been ploughed from the ground by folks doing most of the tilling as the Wall Streeters went “ching ching” making due with more than a hairdo as the farmers of the third world took most of the haircut with Federal bailout programs going back to the same Wall Streeters who had bought up the debt they had first sold to those who really weren’t in need of anything but to be simply left alone; quite a masquerade, a put on show that now has their eyeliner being used for headlines describing a show some thought would never end. The downfall of Ronald “The Finagle King” Perelman is the beginning of the end for all those who lie, steal and cheat.

One needs both form and substance to keep the lines both parallel and perpendicular otherwise everything collapses. There is absolutely nothing known to man that can keep the stock markets continuing to tick away and they will implode without any assistance from any terrorist group not even the French Ministry of Health and Terror, performance measured by the drop of the water tables throughout the land, Vivendi, Universal Studios to boot TimpucktTOo.

This is something I not only know for certain, not that I am master of the universe but simply master of my own destiny and I do understand the business of risk rather well.

We don’t need another war for things to go sky high. All we need is just one dam burst. Once one recognizes that time has in fact stood still pretty much for some 2,500 odd years one has to believe that if there is a will there must be a way out of this mess and it won’t be pretty. Removing plastered on makeup that has been baking in the sun for eons is not for the feint hearted.

There are, though, more than a handful of folks who understand these elements rather well and who are ready to step forward at a moments notice and get us back to the basics, trust and respect and worrying about love who is in love is less important when you have hungry mouths to feed.

It will take for many, however, some getting used to, that not only are each one of us captain of our own ships but we have to fight like mad our right to stay afloat until God deems otherwise. It has to be more than simply “I may not agree with a word you say but will fight to the death your right to it” when if everyone where to follow such a path it would mean half the population would be wiped out and then some.

It is, however, very much a matter of the meek with teeth inheriting the earth just like Pythagoras understood the elements of what it meant to be at one without having to bother himself to death with understanding the behavior of artificial light that requires more than simply understanding integers which are both real and imaginary. Certainly he had the imagination of the impossible, including if necessary being able to calculate the square root of a negative number which even today we have difficulty putting down on paper let alone what happens to a 12C Texas Instrument calculator, but he and his followers were enlightened to begin with and didn’t need to burn the candle at both ends.

My Sharp calculator from high school fortunately does not have the square root function otherwise I would spend a lot more time seeing if it has accumulated any more intelligence over the years. Its “Manual and Automatic” switch still functions which has me at times making more of the numbers moving back and forth than what some would regard as productive use of my time.

Dying the richest person in the world was never part of my learning only that I should be preoccupied that at the launch of my rocket to the universes beyond the eye of the sun I would have my reputation in tact and my ego in check or I would end up in TimpucktTOo. Knowing a thing or tTOo about the game of ice-hockey has allowed me to skate around others without them knowing whether I was coming or going and of course at times I would confuse myself.

Quantum Mechanics is what has saved us all up to now, the importance of simultaneous equations cannot be overstated as it prepares one to do move in directions that defy the human muscular skeletal system, to mention little of being able to move forward in reverse and why math even if it is only the basics is so very important but nothing though is as important as telling kids the truth for it is the white lies that stack up until they become just plain vanilla lies and then pretty much anything is acceptable even believing that black and white are colors, colorblind all part of bottoms up schooling which teaches first and foremost what is the right and wrong way to do our business which brings us to where we are now.

In my opinion we have nothing left to lose but time and of course the ones we love most.

One of my very close colleagues believes my end will come with a quick blow to the back of the head, “no pain though.” What is to be gained, however, by getting rid of me given the fact that I am certain that the remaining 7.5 billion on this earth will follow shortly, thus his predictions not only cause me to lose little sleep but I have never slept sounder but the 3^rd World War has already begun and it began on Wall Street not on 9-11 but when we left it to politicians to decide what was right as they took their orders not from above but from the folks who were lining their pockets.

With that said, it takes more than a warrior to shoot other peoples’ arrows although one cannot think of everyone who has worked for “The Finagle King” as a complete idiot. It is the power behind the throne, the one that rocks the cradle that needs watching ever so carefully, sins of the father as well as the mother, never though to smother kids with blankets for when the kid comes of age they will assume that it is only fitting and proper that everything gets swept under the rug, so much for Mr. Perelman’s rug although he probably does use Revlon Outrageous Shampoo when combing his short hairs.

It takes also someone with more than a nose to know not only what right questions to ask when sniffing for rot but to maintain the sequencing, something we should all be aware of when raising a child who is programmed right from the start to trust his-her better instincts, i.e. Manager Minute One, that we should all be our own managers right from the time we can fashion a statement never being afraid to make mistakes, knowing what it takes to stand tall.

It is the tallest trees that attract the most wind but it takes forces of nature to rip us apart, tearing our clothes to shreds, if need be, to mention just in passing what exactly constitutes a good looking fashion plate, never to be deceived by someone good looking who is hell bent on eating everyone alive even a skinny journalist like Christopher Byron.

In a nutshell… Furthermore, one can ascertain how carefully corporate surrogates are prepared to create the appearance of cooperation when the clear motivation is obfuscation to mention little of how it comes about that good people get co-opted in to enlarging the webs of deceit while being satisfied to eat crumbs.

I believe a full airing of this deposition will help people understand the process and the skills that create a favorable outcome and thus will be more inclined to participate in Shareholder Class Action Litigation where substantial skills are needed for a positive outcome to mention little of timing... and good “Jew diligence” [sic].

Naturally, I prefer we resolve our conflicts without going the lawsuit route, which is one of the pursuits of NextraTerrestrial.com but one has to be realistic that it is going to take some doing to bring other rapacious folks like Ronald “The Finagle King” Perelman tumbling to the ground especially when one has so-called “on-the-ball” journalists getting bushwhacked by “pretty good-looking” women.

For some reason Martha Stewart being a director since 1996 of Revlon got lost on Christopher Byron in his 8-16-99 NY Observer article as he prepared to dine on her, prospectus to boot, going slow at first, although there is no mention of him spreading her legs as he later had her going from one side to the other, through the twists and turns uncovering all her wrinkles and soiled past.

One can only wonder what sort of motorcycle Byron has locked up in his garage no doubt mostly collecting moths to mention little of him now having to come out of the closet to explain his memory lapses perhaps soon volunteering for a TV show geared for those who play it fast and loose although we at NT prefer a face lift or tTOo of a different sort. I never got, however, beyond page 3 of Martha Inc’s prologue as I was getting ever so close to throwing up and messing up my latest cartoon character[1].

Interestingly, Mr. Byron did seem to remember Martha on 11-08-99 and then again on 4-23-01 as being associated with Ronald “O. Ring” Perelman who seems to have bought off just about everyone and certainly it cannot be his short-s, or his baldness that has the best of the legal eagles now breathing down his neck with me alongside whispering song and poetry every step of the way.

Given, however, that the house of cards is perched ready to tumble we had all better get prepared for another rumble in the jungle or at least give support to folks like me and the rest of my team who have been training a lifetime for this opportunity of showing that overwhelming forces of light can overcome evil.

In order to keep the conversation lively I have added my own “sic” notes in pink along of course with a hyperlink or tTOo. So far I have managed to get through 64 pages of a deposition that lasted some 9 odd hours and produced an output of some 380 pages. I think though for all intent and purposes the $64,000 question has been asked and answered.

Once the remaining 316 pages have been examined in more depth we will soon be running a quiz with prizes galore on the NextraTerrestrial array of websites asking folks to submit an essay that best captures what is to be gleamed from this deposition that will have some folks no doubt depressed.

Some of us older fogies are now only just getting up tTOo speed as we start twisting and turning those who would have us all continuing to go around in circles, getting their attention, having them cough up a buck or tTOo and doing what’s write or they will have hell to pay for, i.e. time to pay the piper.

Time is of the essence to bring to an end all “Capo di capi”s and naturally we should all go easy on the cappuccinos especially when it now exceeds $3 for tTOo shots.

The devil is not in the detail but rather within each none of us from when we begin to play it fast and loose to when we die and God downloads all the kuk and gobbledygook and then decides what next to do with us. Most would agree the ants are taking over.

Remember to tune in at least 5 times a day to the NextraTerrestrial array of websites as we unleash our Perfect Storms to end all wars in our effort to bring peace and balance to the planet.

Take care,

Gary S. Gevisser

Post script – The time is now for those who are reckless with the truth to fess up to their sins and make amends so that we can all get with the program, The choices are rather simple. If we continue gauging ourselves at the current rate we will eventually become fodder for pigs, “phat and short and very sick” [sic] is what Mr. V should have said about Ronald “The Finagle King” Perelman, and a whole lot more. At some point he will have to account to a higher authority, assuming he believes in anyone higher than the “capo di capi” in his decision not to retain legal counsel who have no interest in being principled.

It is time to remove all the silly little hats we wear as if God doesn’t know the difference between rain and shine to mention little of how we had better start educating our kids right with the correct vocabulary to mention little of a value system immediately they exit the womb or we will all end up eating potatoes, in a best case scenario.

If anyone else comes up with a better way than Guidance tTOo to help measure our words I am all ears but I have a brain as well despite what others all holed-out, brainnes to boot, deem otherweiss, who often simply rock along taking up space to mention little of what good green fairways and lawns do to our oceans as the insecticides and dead pets get washed out to C.

Should we not get our acts together very soon to mention little of our laws that mostly protect the rich and powerful, corrupted in their pursuit of so-called “holy wars” while co-opting good men who upon getting it in the rear shoot forth a mouthful to the women who are left ducking and diving for cover, now in modern times believing that increased testosterone is the only way to save par.

The best of the previous generation are cracking up, those on the left, right and the few who remain centered. There is nothing to laugh about the folks who stood tall like my father whose friends fell from the sky like flies in pursuit of just one evil in mankind’s rather brief time here on earth.

History is repeating itself at blitzkrieg speed with TV adding in no small measure to the shell shock therapy that keeps the drug companies on the war path. There is though enough time left for the rest of the Allies to thank the Americans like Dwight Kroesch who delivered the wright message to Hitler along with others like Amos Wright who probably also doesn’t own more than one umbrella to never ever forgetting the treatment black servicemen received when offering to give up their lives to defend places like Australia whose origins are based in part on deposited convicted felons but who like their white winging counterparts, the South Africans, play rugby and cricket not though as smartly as us English who came from the South African province of Natal, the last depository of English commeruppers who had no other place to hide but every so often try and outrun the comrades marathon runners while thinking about math and how nothing seemed to ever add up.

This is not the time for the Europeans to rest easy especially since they have yet to rid themselves of their fukukta Kings, Queens and terrorist sponsoring agencies.

A new light is dawning for women all around the world who are fed up with the nonsense of an elite ruling class who send their youngsters to war. There are though more than a cupful of able bodied men ready to serve and right now some of us are serving up a storm that will give many heads of illegitimate states including so-called “heads of households” within each of our communities a rise and then some.

Folks, soon it will be time to rise and shine as we launch the next series of Perfect Storms in our efforts to prevent the dogs from inheriting everything together of course with the cats as God turns things around once again attaching tails to those of us with overweight torsos prodding along hi-ways which are as messed as our arteries to mention little of the state of our water canals, but there of course lots of things to “love” about our most beautiful world that is simply needing a bit of TLC.

The word “love”, however, is used a little too often for my liking. How in heavens name can we “love” anyone if we don’t have respect and trust and it does take courage to tell the young ones the truth, the whole truth and nothing but the truth.

Relying on folks like the George Soros’[2] of the world to balance the books who first saturate the minds with poisoned starched pens to mention little of the arrows that make war as good a business as any charity I know with a burn rate equal and opposite to our “aufaces” burning, is like taking a bath with a snake who doesn’t really care what is up or down as long as he is the last one sitting at the table; book ends is what comes to mind and I am not suggesting that we burn King George or his books simply use the books, at least, as bed supports for those without a roof over their head who believed that Soros and Co. are all about good when in fact they are simply sorry God limited their rapacious stay on earth.

What the likes of Soros and Buffet and Perelman and Martha and Co hadn’t figured on was the power of the Internet to have them cough up, while we at NextraTerrestrial in particular have them chew on their words to mention in passing what folks do in the privacy of their homes should remain there for only their maids to see and to then spill their beans, privacy is all in the eye of the beholder. Today we have enough laws in place to protect the privacy of the individual while the chiefs carry on with reckless abandonment.[3]

Few if any of the superrich can attribute their financial success to simply having played it smart and honestly especially if they believe that God is watching every one of their moves and why it is that I for one pay no attention to what someone is worth unless of course I am preparing for battle with them.

I know full well that there isn’t an emperor out there with clothes made of quite the silk like those folks quite like my own father who will no doubt remain humble to his last day, a man I am very proud to call “father…who never once tT-Oot-ed his own horn, not even to this day” [sic].

We can only begin to celebrate New Beginnings as we clean up the train wrecks from the past and of course there will be more blood spilled since few of us overindulgent folks don’t even know how to clean dishes to mention little of those who hoard who eat like they are at a bar hoping to pick up a chick or tTOo instead of waiting for their guests to be seated and then to dis-card.

anD to those who are chomping at the bit at taking a byte out of me I can only say “Ugh” and wish you the best. Just make sure you have done your homework and eaten your whities first, i.e don’t gamble on me ending up broke having to wash dishes.

Remember inbreeding is simply not good for the heart muscle and can contribute to hypertension which puts each one of us with Lilly white skins in the same grouping as inner city African Americans who are more equipped than most of us in all areas bar none. We seem though to be gaining ground in these two particular categories which inflict further hardship of those mostly on the receiving end of what comes out of a barrel of a gun.

We should never forget what a barrel of fun someone like Senator Byrd got during the off season wanting to keep his aim true for when shooting fish in a barrel. Bird in the hand better than even one dead bird, nothing though like a picture perfect child schooled never to lie, steal or cheat.

Ancestors of slaves suffer in many different ways, including the ancestors of those who built the pyramids, pyramid schemes no different to what has ultimately begotten investors believing in Ronald “O. Ring Perelman” who wears his religion on his labels while socking it to those who can least afford it coming back time and again since no one has yet to cut off his shirt sleeves, so much for shirt sleeves to shirt sleeves in 3 generations.

African Americans were not as fortunate as the Israelites who had Moses to lead them on the road to righteousness. Jesse Jackson and his Reverand pal Stockton have more in common with the racist whites of South Africa who continue to wreck havoc on the Black masses as they deprive them of their stock to mention little of what remains of their heritage all now blowing in the wind.

The winds of change are taking hold everywhere in the world. African Americans are a tired people fed up with the bullshit of being told how much white liberals and their stooges are protecting their households as they eat on the run, prison one hell-ava safety net when in fact they should be earning higher incomes, leapfrogging whites in terms of benefiting from having simply equal education including knowing about the food groups, that less is better.

As the tire meets the road and people of color realize that they are much more evolved than those folks who pontificate at establishments like Yale, Oxford and Cambridge who would all be better off with computers doing their talking, filtering out their utter nonsense, the trip ahead will get lighter especially as we at NextraTerrestrial expose these blighters for who they really are to mention little of the end of the rainbow being more at the middle than at the end.

Only as we move away from white and black where there is no color will we all begin to experience the richness of the colors never to forget the values and those brave individuals who first set the pace, i.e. Pythagoras, Jesus Christ and Mohammed.

5 UNITED STATES DISTRICT COURT

6 SOUTHERN DISTRICT OF NEW YORK

8 Master File No. XXX (SHS)

10 - - - - - - - - - - - - - - - - - - x

11 IN RE:

12 REVLON, INC. SECURITIES LITIGATION

13 - - - - - - - - - - - - - - - - - - x

15 DEPOSITION OF V

16 Thursday, October 17, 2002

17 10:15 a.m.

18 XXX Apes

19 One Beacon Street

20 Boston, Massachusetts

21 Reporter: XXX

1 A P P E A R A N C E S

3 XXX

4 (BY: X.)

5 West X

8 Counsel for the Plaintiffs

11 XXX

12 (BY: X ESQ.)

13 Four X Square

14 Counsel for the Defendants

17 3

1 I N D E X

2 DEPONENT DIRECT CROSS REDIRECT RECROSS

3 X

4 (By X

5 E X H I B I T S

6 NO. DESCRIPTION PAGE

7 1 Subpoena duces tecum 19

8 2 Revlon sales force directory 88

9 3 Memo from X 128

10 4 Memo from X 132

11 5 Memo from X 136

12 6 X 1998 supplier agreement 161

13 7 X- partnership meeting, 10/23/XX 183

14 8 Letter from George X to X, X

15 9 Free goods proposal summary by quarter 306

16 10 E-mail from X, 12/3/98 309

17 11 E-mail from X, 5/7/98 312

18 12 E-mail from X, 5/20/98 319

19 13 E-mail from X 5/29/98 321

20 14 Letter to X, 10/6/98 324

21 15 Document X A-00079 through 00081 326

22 16 Letter to Kathy X, 11/10/99 332

23 17 E-mail from X, 3/25/98 334

24 18 Dating program fact sheet 338

1 P R O C E E D I N G S

2 V

3 a witness called on behalf of the Plaintiffs, having

4 first been duly sworn, was deposed and testified as

5 follows:

6 DIRECT EXAMINATION

7 BY MR. K:

8 Q. Good morning. Good morning, Mr. V & Revlon’s attorney.

9 Good morning, Mr. V. My name is Jeffrey

10 K. I represent the plaintiffs in a lawsuit

11 that's directed against Revlon and a number of their

12 officers. You may have read that complaint, and I

13 probably will get around to asking you whether you

14 did or you did not.

15 I would, however, mention to you that

16 notwithstanding the many pages of the complaint,

17 which is the term that we apply to the description

18 of the claims that we have against the defendants,

19 that the case really is based upon the belief on the

20 part of the plaintiffs, who are the shareholders of

21 Revlon, for a specified period of time that

22 basically goes through the end of 1997 through 1998

23 that the condition of Revlon was not accurately

24 depicted to the shareholders as derived or

1 determined by looking at the financial records and

2 the public reports pertaining to the financial

3 records and documents such as the 10(k) and the

4 10(q), because, and this is very simple, we believe

5 that during that time there were artifices that were

6 used for the purpose of showing sales that were

7 greater than what the natural market conditions

8 would have permitted and allowed, and simultaneously

9 there were artifices that were undertaken in order

10 to hold down the expenses. The consequence of those

11 two would show a company that was in better

12 financial health or in a better -- or in a better

13 condition economically than would have otherwise

14 been ascertained by simply looking at the public

15 documents that were disseminated by Revlon and its

16 officers.

17 That's really as simple as the case is,

18 notwithstanding what ends up being a veritable

19 scattershot of allegations that are directed in

20 going through the complaint.

21 I don't know, and I will ask you

22 shortly, whether or not you've had your deposition

23 taken before, because it's a fairly unique process,

24 but I do want to emphasize that the intent of this

1 is a very simple one. That is to find out what it

2 is that you know, when you knew it, and whether or

3 not any of the facts that you may be able to present

4 or any of the best estimates that you may be able to

5 provide will assist us in coming to a determination

6 as to whether or not those allegations and

7 statements regarding what I just said were, in fact,

8 accurate and whether or not there are other places

9 we may be able to locate or look to find out whether

10 those statements are accurate.

11 Now, I believe, though I am not certain,

12 that once we get going into your answering questions

13 instead of me talking, we will find out that you

14 have a significant amount of experience in sales and

15 probably in the sales of cosmetics. That's my way

16 of telling you very simply that if you want to, you

17 probably have the capability to answer my questions

18 by talking rings around my specific questions. That

19 will prolong the deposition. It also will confuse

20 me terribly, because I'm probably not as bright as

21 you are or as well prepared as you are for this

22 deposition.

24 “The fact that I was chief operating officer of Hang Ten International will no doubt allow me to hang you out to dry to mention little of my stint as CEO of a public company that did rather well for its shareholders to mention little of the fact that I have this serfer dude Gary S. Gevisser [GG] in my corner and he happens to be one of the best cut men in the business, Footsak to boot to mention just in passing Perfect Storm III which is about to erupt at his latest website NextraTerrestrial as in NextTrial as in yada yada yard, yacht, jetting soon to TimpucktTOo although Mars may be the safest slingshot back to the year dot” [sic].

23 The intent, hopefully, is not to achieve

24 that because it makes the process more arduous and

1 longer than and lengthier than it has to be, and

2 hopefully we all have other productive ways to spend

3 our time.

4 So if you get the gist of the direction

5 of a particular question, I'd encourage you to

6 answer that within the gist and context of the

7 direction of that question rather than give a

8 literal answer that may, in fact, end up being

9 deceptive when looked at objectively.

10 I will try, and it's a hard thing for

11 lawyers to do, to translate my questions from

12 legalese into English so they can be easily

13 understood. If at any time you don't understand the

14 direction of my questions or where I am going,

15 please, just let me know that, and I'll be happy to

16 rephrase the question.

17 Conversely, understand that you are the

18 master of this deposition, “Don’t pay any attention to the onshore wind it is just GG flapping his wings although it could simply be Tippytoe waking up believing he tTOo can fly”, though there are rules

19 that apply to that declaration, and any time you

20 want to consult with your attorney, take a break,

21 rest for a while, or feel that for some reason you

22 can't give your best answer to a question that I

23 ask, don't hesitate to say that.

24 This isn't a game of trickery in which

1 I'm trying to catch you or find you in a physical

2 situation in which you can't give your best answer.

3 We are simply attempting to arrive at the truth, and

4 the duration of this deposition, both from my

5 perspective, from your attorney's perspective, and

6 from your perspective, can either be fairly lengthy

7 or fairly short, depending upon how quickly we get

8 through these documents and how direct the answers

9 are “and then we can all party at my place as in 5,6,7 and because others might get hold of this deposition at a later date please call me or GG at 1-858-SEL-NEXT for my street address” [sic].

10 I apologize for a long preamble, but I

11 did want you to know what my perspective of it is in

12 trying to make this as comfortable an environment

13 for you to proceed.

14 Do you have any questions up to this

15 point “including anything you would like to hear about the color wheel as Sebastian Capella’s classes are filling up rather quickly these days?” [sic].

16 A. No.

17 Q. Have you at any time read the complaint that

18 is the gravamen of this litigation that you're

19 appearing in?

20 A. No.

21 Q. Now, were you ever the recipient of any

22 memorandums that described the nature of this

23 litigation, if you can recall?

24 A. I received some information regarding coming

1 up here for the deposition, but I can't remember

2 specifically what was in it.

3 Q. I see. And how did you receive that?

4 A. I believe it came by mail.

5 Q. And was that served by one of the law firms?

6 A. Yes.

7 Q. And we served you and asked you to appear

8 here to give information?

9 A. Right.

10 Q. Am I correct -- and I'm not inferring that I

11 know absolutely, am I correct that we noticed that

12 deposition, which is a long term for saying we

13 attempted to hold the deposition in New York, but it

14 was your preference that we hold it in Boston?

15 A. I think I wanted it in Boston. I don't

16 remember if New York was an alternative. I don't

17 remember.

18 Q. And the reason you wanted it in Boston, I

19 presume, is because this is your home or this is

20 where you work?

21 A. Right.

22 Q. Could you tell me what knowledge -- what

23 understanding you have regarding the lawsuit at this

24 point in time, apart from the summary that I just

1 provided you?

2 A. Actually, you summarized it pretty good.

3 That would be my knowledge of it.

4 Q. Apart from that, can you recall any other

5 discussion that you had regarding this lawsuit,

6 apart from conversations that you had with counsel?

7 A. No.

8 Q. Have you discussed your appearance here

9 today with anyone, apart from counsel?

10 A. You're talking like my wife or something?

11 Q. Yes, exactly “unless of course you have tTOo” [sic]

12 A. Sure.

13 Q. And what did you say to your wife?

14 A. Well, I told my wife and friends that I

15 would be up in Boston on a court case.

16 Q. Did they ask you what the case was about or

17 why you were going there?

18 A. I didn't volunteer that.

19 Q. Did anyone ask you what the case was about

20 or why you were coming here?

21 A. My wife.

22 Q. Or anyone else that you might have talked

23 to.

24 A. Family. No.

1 Q. What was your reaction upon learning that

2 you were going to -- that you were served with a

3 subpoena and that you were going to appear here?

4 A. When the guy showed up at my door, I was

5 surprised.

6 Q. The subpoena was personally handed to you?

7 A. Right.

8 Q. It did not upset you, I hope.

9 A. No.

10 Q. And where were you served?

11 A. My yard.

12 Q. Your...

13 A. Yard.

14 Q. On your yacht?

15 A. No, yard.

16 Q. Yard. I'm sorry, yard, yacht. I'm from the

17 West Coast, “grew up in New York, learned a thing or tTOo on the streets of Boston including how to respond to fast balls thrown at or near head” [sic].

18 A. I haven't got my yacht yet, but I was in my

19 yard.

20 Q. I understand.

21 What did you next do? And by that I

22 don't mean finish mowing the lawn. I meant with

23 regard to --

24 A. I believe it was on a weekend, so I did

1 nothing. I called the people that -- the law firm

2 that was on the deposition, I guess, or whatever

3 you --

4 Q. And would that have been KKK?

5 Because I believe -- they're my co-counsel. Again,

6 we're not trying to trick you, but they certainly

7 would have been the prominent -- the firm that was

8 most prominent on that deposition subpoena.

9 A. That was probably -- I called them and asked

10 them what the story was.

11 Q. Uh-huh. And when you said "the story," you

12 wanted to understand what it was that you were

13 expected to do as a result of that?

14 A. Right.

15 Q. And had you retained -- were you represented

16 by counsel at that point?

17 A. No.

18 Q. At some point in time did you retain

19 counsel?

20 A. You're talking him?

21 Q. Well, did you retain any counsel?

22 A. Other than this gentleman here, Jeff, no.

23 Q. Did you retain “Mr. Perelman’s sharpshooter? [sic].

24 A. I called Jeff or Jeff called me, I believe.

1 Q. Jeff called you. Now, why would Mr. -- do

2 you have any idea as to why [he] would have

3 called you?

4 MR. V & REVLON’S ATTORNEY: I object as to form.

5 Q. Did he solicit the representation of you in

6 this -- did he offer to represent you in this case?

7 A. Well, I believe they represented Revlon.

8 Q. Correct.

9 A. And do represent Revlon, and that's how I

10 got involved with Jeff.

11 Q. I see. Do you have -- apart from [Revlon’s attorneys] who are an excellent firm “who are not exactly getting hand me down suits for being such honorable men” [sic], are you represented by

13 attorneys or counsel in any other matters?

14 A. No.

15 Q. Did you consult any other counsel with

16 regard to your appearance here?

17 A. No.

18 Q. Did you feel that there was a possibility of

19 a conflict of interest with regard to having

20 yourself represented here by the law firm

21 representing a defendant in the case?

22 A. No.

23 Q. Did you understand that at the time that you

24 were served with the subpoena to appear here that

1 you were obligated to search for and present

2 documents that would be responsive to the papers

3 that were handed to you?

4 A. Someone asked me -- I don't remember who --

5 if I had records.

6 Q. Do you recall that there was included with

7 the notice and subpoena duces tecum a request that

8 you provide documents that related to a number of

9 subjects?

10 A. I remember that.

11 Q. Could you tell me what you did in order to

12 comply with that request for the documents “other than seeking out Mr. Gevisser’s high-school Latin teacher for a refresher course in what it means to tell the whole truth and nothing butt the truth so help me dog. Tippytoe is that you breathing in my ear?” [sic] today?

13 A. Nothing.

14 Q. Now, is there a reason why you did nothing?

15 A. I have nothing.

16 Q. Did you understand that once you were

17 represented by “Arpes” [sic], you were entitled to

18 seek their advice with regard to responding to that

19 subpoena duces tecum?

20 A. Ask me that again.

21 Q. Did you understand, once you had been

22 contacted and apparently an agreement materialized

23 in which they would represent you here today, that

24 they could assist you in responding to that subpoena

1 duces tecum?

2 A. Yes.

3 Q. And did you ask them to assist you in

4 locating those documents?

5 A. Not specifically, no.

6 Q. Is there a reason why you didn't?

7 A. I didn't have the documents. I didn't --

8 other than that, no. I didn't have them, so I -- I

9 didn't realize -- no, I didn't.

10 Q. If you were aware, speaking hypothetically,

11 that you were to produce not only the documents that

12 you had but the documents in your possession, which

13 I guess is the same, custody, which is a little bit

14 different, because that means it may be held by

15 someone else, or control, and control would mean

16 through any agent including the law firm, would you

17 have reacted different to that request?

18 MR. V’s & REVLON’S ATTORNEY: I'm going to object as to

19 form. I don't understand the question.

20 MR. K: Let me rephrase the

21 question and in the process start the flywheel.

22 Q. Once you have proceeded with a law firm,

23 they represent -- they are fiduciaries to you; and

24 therefore, they are under your control. Did you ask

1 the “Apes” [sic] law firm to proceed and locate

2 those documents that were responsive to the request

3 directed at you?

4 A. No.

5 Q. Did they offer at any time to do that?

6 A. I don't remember.

7 Q. What is it that you don't remember about it?

8 A. Whether I offered or asked them or they

9 offered.

10 Q. So you don't recall whether or not any

11 search had been undertaken of documents responsive

12 to the subpoena that had been done either by a law

13 firm or an auditor or any other consultants that you

14 may deal with?

15 A. My assumption at the time was that someone

16 would provide the materials. I didn't have them, so

17 someone would, I assume.

18 Q. And who did you expect, of the people that

19 you were talking to --

20 A. Probably the law firm.

21 Q. Okay. I will ask you, are there any

22 materials that you've presented here that have --

23 that you're producing responsive to the document

24 request?

1 A. Personally?

2 Q. Yes.

3 A. Did I have anything? No.

4 Q. Or provided to you by your agent, the law

5 firm?

6 A. I don't have anything.

7 Q. Thank you.

8 MR. K: “Mr. V’s & Revlon’s attorney” [sic], do you have any

9 documents that you are here to provide me in

10 accordance with the document request that was served

11 on your client?

12 MR. V’s & REVLON’S ATTORNEY: No. The witness has told

13 you at least twice that he possesses no documents

14 responsive to the request.

15 MR. K: Yes, I understand that.

16 And my point was that, as his agent, he could have

17 controlled your activity in that regard, speaking

18 hypothetically -- I'm not trying to -- maybe I am

19 trying to make a legal record, but nothing was done

20 to respond to that?

21 MR. V’s & REVLON’S ATTORNEY: Well, for the record, what

22 was done to respond to it was to confirm that Mr.

23 V did not possess any documents within his

24 possession, custody, or control responsive to the

1 subpoena.

2 Q. Were questions asked of you as to possible

3 sources that you could control to locate documents

4 that would be responsive to the deposition?

5 A. No.

6 Q. In fact, nothing was asked of you with

7 regard to responding to the document request apart

8 from whether you had any in your possession?

9 A. Correct.

10 Q. Thank you.

11 MR. K: May I, just to confirm

12 this, mark as Exhibit -- is there numbering that's

13 been established, Jeff?

14 MR. V & REVLON’S ATTORNEY: Consecutive? No, we've

15 been starting with 1 for each deposition.

16 MR. K: I see. So we will call

17 this G-1? Is that the thought?

18 MR. V & REVLON’S ATTORNEY: That's fine.

19 MR. K: Could I have this

20 identified as Exhibit G-1, and please show it to the

21 witness.

22 (Document marked as V Exhibit 1

23 for identification)

24 Q. Please look at that, Mr. -- V.

1 MR. K: And I will stress that

2 "V" [sic] is the name that Mr. V has asked that he

3 be addressed by, “different to vini, vidi VS et al. Please Lord hold GG off from launching Perfect Storm III at least until my bosses girlfriend approves my year end bonus” [sic].

4 Q. And my question's going to be a very simple

5 one. Is that a copy of the document that was

6 originally served upon you?

7 A. (Witness reviews document) I can't remember.

8 Q. Do you have any reason to doubt that that's

9 a copy of the document?

10 A. No.

11 Q. Okay. Thank you.

12 MR. K: You can give that back to

13 the court reporter, and perhaps I should say that

14 during the course of this deposition you will see

15 that there are documents that we'll number

16 sequentially V 1 through V 22, and

17 sometimes you will recognize them and sometimes you

18 will not. They simply represent milestones and/or

19 pieces of evidence that we use.

20 Q. This is principally background for a short

21 period of time, Mr. V. I don't know what your

22 time limitations are, but I will do my best to

23 attempt to conclude this deposition either today or

24 early tomorrow morning.

1 MR. V & REVLON’S ATTORNEY: I'll just note that under

2 the rules, you don't have the option of continuing

3 till tomorrow morning.

4 MR. K: I believe that that is a

5 statement of your counsel, and he's entitled to make

6 that. I don't believe that that applies in this

7 jurisdiction for a number of reasons. And we are in

8 Massachusetts under the federal court rules that

9 apply in this jurisdiction, principally because

10 the -- your law firm determined that they preferred

11 to take the deposition here.

12 MR. V & REVLON’S ATTORNEY: We actually operate

13 pursuant to the rules of Judge Stein in the Southern

14 District of New York, and also under the Federal

15 Rules of Civil Procedure, which also limit you to

16 one day.

17 MR. K: Yes, and I understand the

18 position “and for that matter so does GG whose name I understand has come up in at least one other deposition involving former executives of Revlon such as yourself to mention in passing Judge Jack Weinstein’s familiarity with Mr. Gevisser’s past and God only knows what GG is up to right now given the fact that he started his BUS back in 1989 at 1 Wall Street giving the most deserving i.e. Bank of New York et al a haircut aided by a University of Virgin Law School grauduate who has probably forgotten that GG knows a thing or tTOo about his roots, never to sweep things under the carpet especially when there is time left in the day to make a buck or tTOo and seize those by the coattails who continue to play it fast and loose. GG’s grandfather, who along with the ‘poor Jews’ of eastern Europe got the discounted ship fares to places like South Africa, began his rather successful trading career by picking up unbroken bottles off the streets of Durban, placing them in a wheelbarrow, quickwheels to boot, before moving on to the slaughter houses where he traded up to wheeling and dealing in animal bones creating a wake that had his grandson eventually begin cleaning up the mess on Wall Street and what a Christmess 2002 is going to be, although things should improve in 2003 with GG having established a presence first in the Eastern district and now in the Southern District covering essentially the tTOo remaining quadrants creating a springboard to have the rest of us sling our spears and arrows forgetting we are all part of one planetary system or we could just as easily end up in one big melting pot in Timbuktu where it all began” [sic].

19 And the worst thing that could happen is

19 for counsel to start arguing, but the opportunity

20 was provided to get a protective order, and the

21 content of the notice specifically says that it will

22 continue from day to day until concluded. We will,

23 nonetheless, make that academic, I hope, in getting

24 this done today.

1 Q. Could you -- and this falls under the

2 background. I said that there were some questions

3 that would be asked that weren't immediately

4 apparent to you, and this falls under the category

5 of background. Could you please summarize your

6 educational background. I don't care where you went

7 to high school, but let's start with the diploma in

8 high school and then tell me what you did after

9 that, and the years.

10 A. And the years?

11 Q. And correspond it to years in the interest

12 of attempting to make this, as I say, as quick a

13 deposition as possible. And I'll be listening to

14 you even though I'm getting up and getting a cup of

15 coffee, if no one objects “although I probably should just stick with herbel tea different to Mr. Gevisser’s “Verbal [non-sic] remedies for saving the wor.d.” [sic].

16 A. Okay. Boston College, four years. That's

17 it.

18 Q. And can you tell me when you graduated from

19 Boston College?

20 A. '68.

21 Q. And what degree did you have at that time?

22 A. English, BA, I guess.

23 Q. And after you graduated from BC in 1968, did

24 you subsequently apply to any graduate schools in

1 order to gain further education?

2 A. I went to a couple of courses at night.

3 Babson.

4 Q. At Boston College?

5 A. Babson.

6 Q. At Babson. But you graduated from Boston

7 College?

8 A. Just for one semester.

9 Q. And what courses did you take at Babson?

10 A. Business.

11 Q. And could you tell me what your areas of

12 concentration were while you were at Boston College?

13 A. Liberal arts.

14 Q. And what did you view, if you had any view,

15 of what you would be doing after you graduateed from

16 Boston College with your degree in liberal arts “aside from Mr. Gevisser’s Bottoms Up Schooling” [sic].

17 A. Gainful employment somewhere. Location

18 unknown.

19 Q. Because liberal arts didn't exactly prepare

20 you for anything specific, at least that's my

21 recollection. And you, in fact, got, I assume, a

22 degree from Boston College in 1968, I believe you

23 said?

24 A. Right.

1 Q. And that would have been just a liberal arts

2 degree, correct?

3 A. Correct.

4 Q. And the continuing education that we're

5 talking about was limited to a number of night

6 courses at Babson?

7 A. Yes.

8 Q. And I apologize. That was my job to

9 actually tell you that the court reporter, who

10 really is the boss here, apart from you as the boss,

11 will indicate to you that gestures or responses that

12 can't be translated into words are sometimes

13 difficult for her to transcribe. I apologize to

14 both of you for that.

15 During what period of time did you

16 attend Babson?

17 A. I believe it was the fall of '68, I think.

18 Q. So would it be fair to say that after

19 graduating with a liberal arts degree from Boston

20 College, you went to Babson to just enhance your

21 education in a couple of specific degrees and make

22 you more attractive as an employee candidate?

23 A. Correct.

24 Q. Could you tell me whether, at Boston College

1 or beforehand, you received any awards or special

2 recognitions?

3 A. I can't remember.

4 Q. Were you a football player?

5 A. No.

6 Q. Earn a letter or anything?

7 A. No.

8 Q. You were just a studious student?

9 A. I was a student.

10 Q. Did you seek employment during your last

11 year or previously while attending Boston College?

12 A. Did I seek -- come again?

13 Q. Let me begin. Did you work while you were

14 going to school at Boston College?

15 A. Yes.

16 Q. Please tell me what you did.

17 A. I worked in a warehouse.

18 Q. And was that -- would I be correct in

19 assuming that that was work that you did like most

20 students do, pick up extra money and allow you to

21 continue with your education?

22 A. Correct.

23 Q. It wasn't intended to light your path to

24 your future employment aspirations?

1 A. Not really.

2 Q. Upon graduation or prior to graduation,

3 could you tell me what you did to locate your first

4 employment?

5 A. I went to work for the company that owned

6 the warehouse.

7 Q. And what was the name of that company?

8 A. It was the John E. Cain Company.

9 Q. What did they do?

10 A. They were food manufacturers.

11 Q. What did they manufacture?

12 A. Mayonnaise -- edibles, mayonnaise, potato

13 chips, pickles, ta-da ta-da.

14 Q. They actually manufactured and didn't

15 distribute?

16 A. No, manufactured and distributed.

17 Q. And you began on a part-time basis, if I'm

18 to understand your testimony correctly, while you

19 were at Boston College and then progressed to your

20 being offered a full-time job upon graduation?

21 A. That's correct.

22 Q. So in 1968, upon graduation, you went to

23 work for X Cain?

24 A. C-a-i-n “and don’t blame my dna on all the blotches that will appear on these pages as you take me through the grinder bringing up stuff best dealt with by selective memory a product of poor parenting Mr. Able attorney” [sic]

1 Q. Where are they located?

2 A. They were located in Cambridge, Mass. at the

3 time.

4 Q. Are they still in business?

5 A. Yes.

6 Q. And how long did you work for them?

7 A. Maybe six months.

8 Q. Would that have put it into the end of 1968

9 or the beginning of 1969 when you left them?

10 A. Beginning of '69, I believe.

11 Q. And what was your next employment?

12 A. U.S. Army.

13 Q. Were you drafted?

14 A. Yes.

15 Q. And what happened -- where did you go and

16 what happened in the U.S. Army?

17 A. I was drafted and then went overseas.

18 Q. Would that have been Vietnam?

19 A. Correct.

20 Q. Were you decorated at all?

21 A. Yes.

22 Q. And what were you decorated with?

23 A. Bronze star.

24 Q. And at some point in time did you leave the

1 U.S. Army?

2 A. Yes.

3 Q. And what year would that have been?

4 A. Probably two to two and a half years later.

5 Q. So we're talking approximately 1971 or '72?

6 A. Right.

7 Q. And were you injured during your time in

8 Vietnam?

9 A. I was injured before I went in a parachuting

10 accident.

11 Q. But that isn't what you won your bronze star

12 for; is that correct?

13 A. No.

14 Q. Because you win a bronze star for bravery

15 and courage in the face of battle?

16 A. Correct.

17 Q. And that, in fact, happened to you?

18 A. Yes.

19 Q. When you returned in 1971 or '72, did you

20 then seek other employment?

21 A. Yes.

22 Q. And when did you start working for who?

23 A. I went to work for Chesebrough -- a company

24 called Chesebrough-Pond's.

1 Q. And what year would that have been?

2 A. C-h-e-s-e-b-r-o-u-g-h. '72, '73, in there.

3 Q. And what was the position that you had with

4 them?

5 A. A sales rep.

6 Q. So is it correct to say that you --

7 following your time in the military, your first job

8 involved sales?

9 A. Correct.

10 Q. And did you leave Chesebrough-Pond's in

11 1973?

12 A. Leave?

13 Q. Yes.

14 A. I went there, right.

15 Q. When did you leave Chesebrough-Pond's “and time is getting short I have no idea how long I can hold off Mr. Gevisser so please stay with the program, okay” [sic]?

16 A. Okay. I'm going to get close, but may not

17 be totally accurate.

18 Q. Your best estimate is fine.

19 A. Okay. '73 -- Chesebrough-Pond's was

20 acquired by Unilever.

21 Q. The British corporation “and of course you are aware of momworker63’s plea on 6-11-99 where there is reference to Uni-evil?” [sic].

22 A. British-Dutch, correct. And I left them, I

23 believe, in 1995.

24 Q. So correct me if I'm wrong, you spent over

1 20 years at Chesebrough-Pond's/Unilever?

2 A. Right.

3 Q. And could you tell me the progression of

4 your titles, and then I'll ask you the

5 responsibilities that correspond to those titles --

6 you can do it all at once, again, if you want to

7 save time -- from the time that you began at

8 Chesebrough-Pond's.

9 A. I was a sales rep, then I think I became a

10 district manager.

11 Q. For sales?

12 A. For sales. A regional manager, then a

13 general manager of a small group, then I became a

14 vice president of sales, then a senior VP of sales.

15 Q. Then senior VP of sales?

16 A. Yes. I think that was, you know -- give me

17 a little leeway on the titles.

18 Q. I will. Senior VP of sales, though, was the

19 highest position? And you know what I mean by

20 "highest position."

21 A. Then I became a general manager.

22 Q. That's higher than senior VP?

23 A. Yes, within the Unilever company.

24 Q. And what year would that have been?

1 A. The last title?

2 Q. Yes.

3 A. Probably '93 maybe.

4 Q. Now, could you tell me what your

5 responsibilities were as district sales manager?

6 A. A district, Boston district, I believe, with

7 maybe four or five people reporting to me, a

8 customer base, small customers.

9 Q. So is it fair to say that your job at that

10 point was to manage and oversee hopefully the

11 increase of sales of Chesebrough-Pond's product?

12 A. My job at the time would have been to manage

13 a group of people and make the objectives, whatever

14 they would be.

15 Q. And were the objectives normally to increase

16 sales?

17 A. Could have been. May not have been.

18 Q. What other objectives normally were there at

19 that time?

20 A. At times we didn't need to increase sales.

21 Q. Could you describe for me at that time the

22 products that you were principally involved with?

23 A. They would have been -- Chesebrough-Pond's

24 primary products were Vaseline, Q-Tips, Pond's cold

1 cream.

2 Q. They have an overall title such as

3 consumer --

4 A. Yes, it would be the consumer products

5 division. Well, it was a consumer products company.

6 Q. Yes. And so that we don't have to go

7 through it one by one, were the sequential titles

8 that you had as regional manager, and then I missed

9 one. After regional manager you became district

10 manager?

11 A. No, I think after regional manager I became

12 a general manager of a small group.

13 Q. And when you say "a small group," correct me

14 if I'm wrong, that means that within

15 Chesebrough-Pond's there were different groups that

16 had responsibility for different segments of the

17 market?

18 A. By product line.

19 Q. By product line. And what product line were

20 you the general manager of?

21 A. Smaller volume, nonadvertised products.

22 Q. Such as...?

23 A. Oh, gee.

24 Q. If you don't recall, please, that's fine.

1 A. Yes, small products.

2 Q. Now, when you became vice president of

3 sales, did that responsibility change?

4 A. Then I became responsible, yes, for all the

5 products.

6 Q. And that means cold creams, Vaseline, the

7 entire consumer products line?