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NYTimes - Verbatim Op Docs - What Is A Photocopier? transcript powered by Sonix—the best video to text transcription service

NYTimes - Verbatim Op Docs - What Is A Photocopier? was automatically transcribed by Sonix with the latest audio-to-text algorithms. This transcript may contain errors. Sonix is the best way to convert your video to text in 2020.

Taking Attorney:
And the device used to record information from your computer system on to the master CD is a device within the Recorder's Office? Is that correct? As opposed to being in some other building somewhere?

Deponent:
Yes.

Taking Attorney:
During your tenure in the computer department of the Recorder's Office. Does the Recorder's Office had photocopying machines?

Deponent's Attorney:
Objection.

Taking Attorney:
Any photocopying machine?

Deponent:
When you say "photocopying machine," what do you mean?

Taking Attorney:
Let me make sure I understand your question. You don't have an understanding of what a photocopying machine is?

Deponent:
No, I want to make sure that I answer your question correctly.

Deponent's Attorney:
Dave, I'll object to the tone of the question. You make it sound like it's unbelievable to you that he wouldn't know what the definition of a photocopy machine is.

Taking Attorney:
I didn't ask him to define it. I asked him if he had it.

Deponent:
When you say "photocopy machine," what do you mean?

Taking Attorney:
The term "photocopying machine" is so ambiguous that you can't picture in your mind what a photocopying machine is in an office setting?

Deponent:
I just want to make sure I answer your question correctly.

Taking Attorney:
Well, we'll find out. If you can say yes or no. I can do follow-ups, but it seems if you really don't know in an office setting what a photocopying machine is... I'd like the Ohio Supreme Court to hear you say so.

Deponent:
I just want to make sure I answer your question correctly.

Deponent's Attorney:
There's different types of photocopiers, Dave.

Taking Attorney:
You're speaking instead of... You're not under oath. This guy is.

Deponent's Attorney:
I understand that, but I understand what his objection is. You want him to answer the question. I don't think it's fair.

Taking Attorney:
It's not fair?

Deponent's Attorney:
It's not a fair question. A photocopy machine can be a machine that uses photostatic technology, that uses zero graphic technology, that uses scanning technology.

Taking Attorney:
I don't care what kind of technology it uses. Has your offices. We don't have technocrats on the Ohio Supreme Court. We've got people like me, general guys...

Deponent's Attorney:
Objection.

Taking Attorney:
Or gals.

Taking Attorney:
I'm not really very interested in what the technology element of it is. I want to know...

Deponent's Attorney:
That's what's at issue in the case, Dave.

Taking Attorney:
Not in my judgment.

Taking Attorney:
Do you have photocopying machines at the recorder's office? If you don't know what that means in an office setting, please tell the court you don't know what that means in an office setting to have a photocopying machine.

Deponent:
I would like to answer your question to the best of my ability.

Taking Attorney:
I'm asking you to answer that.

Deponent:
So if you could explain to me what you mean by...

Taking Attorney:
I want to establish on the record that you really don't know what it is. I want to establish that.

Taking Attorney:
Now, do you know what it is or do you not know what it is? Do you understand what that term means in common parlance or not?

Deponent:
Common parlance?

Taking Attorney:
Common language...

Deponent:
I'm sorry, I didn't know what that meant.

Deponent:
I understand that there are photocopying machines and there are different types of them. Just like there are different cars any some of them run under gas power. Some of them under electric power.

Deponent:
And I'm asking if you could help me out by explaining what you mean by "photocopy machine."

Taking Attorney:
That's a great point.

Deponent:
Instead of trying to make me feel stupid.

Taking Attorney:
If you feel stupid, it's not because I'm making you feel that way.

Deponent's Attorney:
Objection.

Deponent:
I have self confidence. And I have no problem.

Taking Attorney:
I don't think you're stupid.

Deponent:
I don't have any problem answering the question.

Taking Attorney:
I think you're playing games with me.

Deponent's Attorney:
Dave, the word "photocopying" is at issue in this case. And you're asking him whether something is or isn't a photocopy machine, which is a legal conclusion.

Taking Attorney:
This isn't a patent case. There's no statute that defines where I'm asking him to define technology for me. I'm asking. I want to find out from a lay person's perspective. Not from an engineer's perspective, not from a technicians perspective, but from...

Taking Attorney:
I have an idea. How about this?

Taking Attorney:
Have you ever heard the term "photocopier" or "photocopy" used in the Recorder's Office by anybody?

Deponent:
Photocopy? I'm sure in the time I've been there, someone has used the term.

Taking Attorney:
And have you ever heard them use it in referencing a particular device or machine within the Recorder's Office?

Taking Attorney:
By way of example, can you photocopy that for me?

Taking Attorney:
That's an example of office parlance.

Deponent:
That particular terminology I've not witnessed.

Taking Attorney:
What was the context that you heard the term photocopy used in the Recorder's Office?

Deponent:
I'm sure it's been used. I didn't say I remember a specific instance.

Taking Attorney:
All right.

Taking Attorney:
But you have a general understanding that people have used the term photocopy within the Recorder's Office in terms of something that could be done there. Is that true?

Deponent:
I'm sure it's been used. I don't remember a specific instance or how it was used. I'm sure it's been used.

Taking Attorney:
And is it fair to say that it's been used in terms of being able to copy one piece of paper onto another piece of paper using a machine?

Taking Attorney:
No? Not sure of that?

Deponent:
I'm sure it's been used. I don't recall a specific instance in which it was.

Taking Attorney:
Do you have a secretary?

Deponent:
No.

Taking Attorney:
Does anybody there have a secretary?

Deponent:
Yes.

Taking Attorney:
Have you ever heard a secretary use the term photocopy?

Deponent:
No.

Taking Attorney:
Have you ever... Do you have machines there... where I can put it in a paper document. Push a button or two. And out will come copies of that paper document... Also on paper.

Taking Attorney:
Do you have such a machine?

Deponent:
Yes, sir.

Taking Attorney:
What do you call that machine?

Deponent:
Xerox.

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