24 Reported By: — Blue Flame Medical LLC v. Chain Bridge Bank, N.A., et al., No. 1:20-cv-00658
- Date
- 2021-05-20
Source document: 24 Reported By; document type: Deposition transcript excerpts (10 pages), Confidential/Highly Confidential.
Full text
EXHIBIT 101
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CONFIDENTIAL
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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF VIRGINIA
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(Alexandria Division)
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BLUE FLAME MEDICAL LLC, )
Plaintiff, )
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)
vs. )Civil Action
7
)No.
CHAIN BRIDGE BANK, )1:20-cv-00658
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N.A., JOHN BROUGH, and )
DAVID M. EVINGER, )
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Defendants. )
_______________________ )
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CHAIN BRIDGE BANK, )
N.A., )
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Third-Party )
Plaintiff, )
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)
vs. )
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)
JPMORGAN CHASE BANK, )
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N.A., )
Third-Party )
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Defendant. )
_______________________ )
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***CONFIDENTIAL***
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REMOTE VIDEOTAPED DEPOSITION OF
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JOANNA WILLIAMSON
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located in McLean, Virginia
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Sunday, April 11, 2021
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Reported By:
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CATHI IRISH, RPR, CRR, CLVS
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8 April 11, 2021
9 9:34 a.m.
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11 Remote videotaped deposition of
12 JOANNA WILLIAMSON, with all
13 participants appearing via
14 videoconference, before Cathi Irish, a
15 Registered Professional Reporter,
16 Certified Realtime Reporter, and
17 Notary Public of the State of
18 New York.
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2 A P P E A R A N C E S:
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4 SCHULTE ROTH & ZABEL LLP
5 Attorneys for Plaintiff
6 919 Third Avenue
7 New York, New York 10022
8 BY: GREGORY J. KETCHAM-COLWILL, ESQ.
9 ANGELA GARCIA, ESQ.
10 JASON T. MITCHELL, ESQ.
11 EKENDILICHUKWU E. UKABIALA, ESQ.
12 NATHANIEL PALMER, ESQ.
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14 ROBBINS RUSSELL ENGLERT ORSECK
15 & UNTEREINER
16 Attorneys for Defendants and
17 Third-Party Plaintiff
18 2000 K Street, N.W.
19 Fourth Floor
20 Washington, D.C. 20006
21 BY: MATTHEW M. MADDEN, ESQ.
22 ZACHARY N. FERGUSON, ESQ.
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2 A P P E A R A N C E S: (continued)
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4 WILMER HALE LLP
5 Attorneys for Third-Party Defendant
6 JPMorgan Chase Bank
7 7 World Trade Center
8 250 Greenwich Street
9 New York, New York 10007
10 BY: MARISSA MEDINE, ESQ.
11 TODD CLAYTON, ESQ.
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13 ALSO PRESENT:
14 PHIL GLAUBERSON, videographer
15 ETHAN BEARMAN
16 BETSY SHARON
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2 THE VIDEOGRAPHER: Good morning.
3 We are going on the record at
4 9:34 a.m. Eastern time April 11, 2021.
5 Please note that microphones are
6 sensitive and may pick up whispering
7 and private conversations. Please
8 mute your microphone whenever
9 possible. Audio and video recording
10 will continue to take place unless all
11 parties agree to go off the record.
12 This is media unit 1 of the video
13 recorded deposition of Joanna
14 Williamson in the matter of Blue Flame
15 Medical LLC versus Chain Bridge Bank
16 N.A., et al. filed in the United
17 States District Court, Eastern
18 District of Virginia, 1:20-CV-00658.
19 This deposition is being held
20 remotely.
21 My name is Phil Glauberson from
22 the firm Veritext and I am the
23 videographer. The court reporter is
24 Cathi Irish from Veritext.
25 I am not authorized to administer
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2 A. I review the calculation on a
3 monthly basis. It's reported to our
4 regulators on a quarterly basis.
5 Q. So it would -- Chain Bridge Bank
6 reported its leverage ratio to the OCC
7 shortly after the end of March 2020?
8 A. We report it in our call reports.
9 The call report for March 31st was not
10 filed until late in April of 2020.
11 Q. But I believe, as you testified
12 earlier, that the timing of when funds are
13 received -- when a deposit is received by
14 the bank doesn't affect the leverage ratio
15 because that impact is averaged out over
16 the entire quarter?
17 MR. MADDEN: Objection to the
18 form. The testimony speaks for
19 itself.
20 THE WITNESS: If assets are
21 elevated for -- yes, that is correct.
22 If assets are elevated for, you know,
23 a short period of time, it's not
24 necessarily going to have a
25 significant impact on the leverage
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2 ratio because of that averaging
3 mechanism.
4 BY MR. KETCHAM-COLWILL:
5 Q. The size of the deposit would
6 have an affect on the average though;
7 correct?
8 A. Yes, but only for those days in
9 the quarter.
10 Q. Do you recall what Chain Bridge
11 Bank's total average assets were at
12 quarter end, first quarter end 2020?
13 A. I don't remember what they were,
14 no.
15 Q. Do you know what they are today?
16 A. I know what -- approximately what
17 total assets are today.
18 Q. And what are they?
19 MR. MADDEN: Objection to the
20 form.
21 THE WITNESS: I just want to make
22 sure that it is appropriate for me to
23 be revealing the bank's balance sheet
24 today even though it hasn't been made
25 publicly available.
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2 MR. MADDEN: The short answer is
3 yes. We'll mark this portion
4 confidential or highly confidential so
5 it will be protected within the
6 litigation. So if you need to take a
7 break to discuss that, that's fine,
8 but --
9 MR. KETCHAM-COLWILL: I'll just
10 note that to the extent you want to
11 mark it highly confidential,
12 Mr. Bearman is on here right now and
13 he would not be able to hear that
14 testimony if it were highly
15 confidential.
16 MR. MADDEN: I think at least on
17 this question, we can proceed without
18 waiving any rights.
19 THE WITNESS: So today, the
20 bank's --
21 MR. MADDEN: Sorry, just to
22 return to my objection to the
23 question. Are we talking about now
24 the bank's total assets or the total
25 average assets as of some time?
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2 MR. KETCHAM-COLWILL: Total
3 average assets as of the most recent
4 quarter end.
5 THE WITNESS: I don't recall off
6 the top -- I'm worried I would
7 misspeak if I gave a guess.
8 (The following portion continued
9 in highly confidential portion of
10 transcript.)
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2 BY MR. KETCHAM-COLWILL:
3 Q. Can you provide an estimate?
4 A. I think that our average assets
5 for the first quarter were 870 million
6 dollars. That was for the first quarter
7 of 2021. But I'm really uncertain about
8 that figure. I haven't studied it and
9 committed it to memory carefully enough.
10 (Continued in confidential
11 portion of transcript.)
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2 BY MR. KETCHAM-COLWILL:
3 Q. So the wire transfer represented
4 more than half of the bank's -- well, that
5 estimate you gave was for this most recent
6 quarter end. Can you give a rough
7 estimate for the bank's total average
8 assets over the first quarter of March --
9 of 2020, excuse me?
10 A. I don't know. I can look it up
11 but I don't know off the top of my head.
12 Q. Is it roughly in the same range
13 as it is -- as of the most recent quarter?
14 A. I could not say.
15 Q. Don't you monitor the leverage
16 ratio every month?
17 MR. MADDEN: Objection to the
18 form, asked and answered.
19 THE WITNESS: I do monitor the
20 leverage ratio every month.
21 BY MR. KETCHAM-COLWILL:
22 Q. And in calculating the leverage
23 ratio, you would have to know the bank's
24 total average assets; correct?
25 A. Yes, but I don't remember what it
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2 was from March of 2020. I don't even
3 remember what it was from March of 2021
4 off the top of my head.
5 Q. What's the highest the bank's
6 total average assets have ever been?
7 A. I think we've been around a
8 billion.
9 Q. And the lowest?
10 A. Probably that would be around
11 when the bank was formed and I don't
12 remember. I wasn't even an employee of
13 the bank then.
14 Q. What's the lowest the bank's
15 total average assets have been while you
16 have worked at Chain Bridge Bank?
17 A. I don't know. I cannot recall.
18 Q. You can't. Can you recall a
19 rough estimate?
20 A. I cannot, no.
21 Q. When the bank uses an ICS
22 account, the one-way sell, I believe you
23 put it, that type of ICS transaction, does
24 the bank -- how much -- sorry, I'll start
25 again.
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2 You testified that the bank would
3 make money off funds it puts in an ICS
4 account. It gets paid fees by IntraFi; is
5 that right?
6 A. Yes.
7 Q. Do you know how much those fees
8 are generally?
9 A. No, it's based on a rate bridge
10 that fluctuates over time.
11 Q. Do you know what they are right
12 now?
13 A. No, I don't.
14 Q. That's not something you have to
15 know in preparing any financial
16 statements?
17 A. It's not -- I review it for
18 fluctuation and reasonableness on a
19 month-to-month basis, not the rate bridge
20 itself, just the income that we've
21 recorded.
22 Q. You said on the recording the
23 wire would have a really big impact on our
24 capital ratios. What did you mean by
25 that?
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2 A. So I think here I am trying to
3 get a handle on what might be the impact
4 on the bank's leverage ratio. And please
5 keep in mind that this is my initial
6 reaction to the transaction. I hadn't
7 actually done any calculations or had an
8 opportunity to really analyze any of the
9 impacts. And after further reflection
10 because there was only six days left in
11 the quarter, and given all the other tools
12 and potential short-term nature of the
13 deposit, I don't believe it would have had
14 a significant impact.
15 Q. So was your comment that the wire
16 would have a really big impact on our
17 capital ratios stated within the context
18 of the bank keeping that money on its
19 balance sheet?
20 MR. MADDEN: Objection to the
21 form.
22 THE WITNESS: I don't -- I don't
23 remember. I don't remember exactly
24 what I was thinking.
25 ///
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2 BY MR. KETCHAM-COLWILL:
3 Q. Could you have been thinking
4 anything else given that if the bank had
5 only kept the money on its balance sheet
6 for a few days, you say the impact would
7 not be significant?
8 MR. MADDEN: Sorry, just a
9 second. Objection to form. Thank
10 you.
11 THE WITNESS: Can you say that
12 question again?
13 BY MR. KETCHAM-COLWILL:
14 Q. I'm wondering what other possible
15 meaning you could have intended when you
16 told Ms. Schoeppe that the wire would have
17 a really big impact on our capital ratios.
18 You've testified that if the bank had only
19 held the funds on its balance sheet for a
20 period of say six days or some short term,
21 the effect would not be significant. But
22 you're saying in this recording it would
23 have a really big impact.
24 Were you assuming that the bank
25 would keep the money on its balance sheet
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2 when you said that?
3 A. I don't know what --
4 MR. MADDEN: Objection to the
5 form. Sorry, just give me a second.
6 Objection to the form, misstates the
7 testimony and calls for speculation.
8 Go ahead, if you can.
9 THE WITNESS: What I'm trying to
10 convey is that the statements I made
11 on the phone call, as I've mentioned,
12 I hadn't had an opportunity to do a
13 full analysis or really think through
14 the situation, so these are really
15 fleeting thoughts as I was
16 brainstorming the possible impacts. I
17 hadn't at that point had an
18 opportunity to fully analyze the
19 situation.
20 BY MR. KETCHAM-COLWILL:
21 Q. When you made that comment to
22 Ms. Schoeppe that the wire would have a
23 really big impact on our capital ratios,
24 what consequences were you thinking of?
25 MR. MADDEN: Object to the form.
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2 THE WITNESS: I'm not sure I was
3 thinking in terms of consequences but
4 I think I was trying to figure out
5 what the impacts might be, the asset
6 growth and what the impact might be to
7 the leverage ratio.
8 BY MR. KETCHAM-COLWILL:
9 Q. Why would you want to know the
10 impact of the leverage ratio?
11 A. That's something that we monitor
12 for regulatory compliance. The thought of
13 falling out of regulatory compliance
14 really never crossed my mind but it is
15 still something that I, you know --
16 monitoring leverage ratio is still
17 something that I am generally trying to be
18 aware of and give consideration to.
19 Q. When do funds that the bank
20 receives via wire transfer first become
21 reflected on the bank's balance sheet?
22 A. They are memo-posted to the
23 bank's balance sheet when they are
24 received and then they would be
25 hard-posted, I believe, during the bank's
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2 overnight batch processing so it would be
3 the end of that day.
4 Q. Can you explain the term memo
5 post?
6 A. I will do my best.
7 My understanding of memo post is
8 that it's really like a notice for a
9 pending transaction, but that transaction
10 isn't completed and reflected in records
11 until a hard post occurs, which occurs
12 during the core processer's overnight
13 batch processing.
14 Q. You also referred to a hard post?
15 A. Yes.
16 Q. And what does that -- is what you
17 were just saying the hard post, when the
18 batch processing gets done, that is how
19 the hard post happens?
20 A. That's my understanding. I'm not
21 an expert on the processing but yes, that
22 is how I believe it to work.
23 Q. Were you concerned about any
24 other ratios the bank maintains or
25 monitors when you told Ms. Schoeppe that
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2 the wire would have a really big impact on
3 our capital ratios?
4 MR. MADDEN: Object to the form.
5 THE WITNESS: I didn't -- I don't
6 believe I was expressing concern over
7 any ratios but there weren't any other
8 ratios that I was attempting to give
9 consideration to.
10 BY MR. KETCHAM-COLWILL:
11 Q. Was the bank able to hold a 450
12 million dollar deposit on its balance
13 sheet given its existing capital levels at
14 the time?
15 A. Yes, it was.
16 MR. KETCHAM-COLWILL: Angie, can
17 we play the recording from --
18 MR. MADDEN: Sorry, Greg, if
19 we're going to move on we've been
20 going about an hour and a quarter.
21 Would now be an appropriate time for a
22 break?
23 MR. KETCHAM-COLWILL: Fine with
24 me.
25 THE VIDEOGRAPHER: This will end
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2 media unit 2. We're going off the
3 record at 11:55, April 11, 2021.
4 (Recess taken from 11:55 a.m. to
5 12:08 p.m.)
6 THE VIDEOGRAPHER: We are back on
7 the record. The time is 12:09, April
8 11, 2021. This will begin media unit
9 3.
10 MR. KETCHAM-COLWILL:
11 Ms. Williamson, we are going to play
12 another part of that phone call you
13 had with Ms. Schoeppe on March 25th.
14 This is still Plaintiff's Exhibit 14.
15 We're going to play it from the
16 mark to the 4:25 mark. Go ahead when
17 you're ready, Angie.
18 (Audio was played.)
19 MS. GARCIA: That was all you
20 wanted, Greg, until 4:30?
21 MR. KETCHAM-COLWILL: Yes.
22 BY MR. KETCHAM-COLWILL:
23 Q. In that part of the recording,
24 Ms. Williamson, you said you weren't sure
25 if an ICS account could be set up in time
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2 for the wire coming in the next day; is
3 that right?
4 A. Yes.
5 Q. Did you have any reason to
6 believe that an ICS account could not be
7 set up in time?
8 A. It actually doesn't really matter
9 when the ICS account is set up. We didn't
10 have to have an ICS account set up to
11 receive this transfer, so my statement
12 about in time I believe is misguided
13 because the ICS account can get set up
14 after the fact, after the deposit is
15 received.
16 Q. Where would the funds be held in
17 that time before they are placed in an ICS
18 account?
19 A. They would be held on the bank's
20 balance sheet until the ICS account was
21 set up.
22 Q. Where would they be reflected on
23 the bank's balance sheet during that time?
24 A. As a deposit.
25 Q. And what deposit account would
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2 well, as you may know, every accounting
3 transaction needs a debit and a credit and
4 they need to be equal. In normal cases if
5 the funds were posted to a client's
6 account, then you would just have a debit
7 in the Fed's GL. But in this case, what
8 this corresponding debit tells me is that
9 the funds were never actually credited to
10 the client.
11 Q. The second row, WT-Blue Flame
12 Medical LLC, that's a debit to an asset
13 account and the asset account is the one
14 we see at the top of this page due from
15 Federal Reserve Bank; is that correct?
16 A. Yes.
17 Q. And the fourth row, wire
18 transfer-California State Treasurer with a
19 credit in the same amount is a credit to
20 this very same asset account?
21 A. It is.
22 Q. And so what is the purpose of
23 having these offsetting entries, credit
24 and debit entries in the same asset
25 account?
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2 A. This occurred because the system
3 didn't have a customer account to credit
4 the funds to. So that's why the
5 offsetting credits came back to the Fed GL
6 because there was never a hard-post
7 credits to the client's account.
8 Q. Is this a document that's
9 generated during the nightly batch
10 processing you referred to before?
11 A. I don't know exactly how to
12 answer that. I do believe it would be --
13 I believe it would be created as a result
14 of the nightly batch processing. But as
15 far as the timeline of when this specific
16 report is produced, I'm not sure.
17 But you can see -- yeah, these GL
18 accounts are normally looked at in the
19 morning after the prior day. So for
20 example, the account history from 3/26
21 through 3/26 I would see in the morning of
22 the following day. If it was 3/27, that's
23 when I would have this report available to
24 me.
25 Q. So these four entries, the order
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2 in which we see them on the page doesn't
3 reflect any sequence in time?
4 A. Yeah, unfortunately I don't think
5 so because all of these hard posts
6 occurred like I said during overnight
7 batch processing. I don't know that
8 there's a minute-by-minute timestamp on
9 these.
10 Q. So not to beat a dead horse but
11 this is -- this reflects the entire
12 activity with respect to the wire transfer
13 in Chain Bridge Bank's Federal Reserve
14 Bank account on March 26th?
15 A. I believe so, yes.
16 Q. Looking at the balance column,
17 and focusing again on the second and
18 fourth rows which are the incoming wire
19 transfer, the amount for both of those
20 rows is 44,058,474.05; is that correct?
21 A. That is the balance, yes.
22 Q. And that -- the balance is the
23 same there because the second row, that
24 amount came in and the third -- and the
25 fourth row that amount went out and so the
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2 wire transfer had no end-of-day effect on
3 the bank's Federal Reserve Bank account
4 balance?
5 MR. MADDEN: Objection to the
6 form.
7 THE WITNESS: I just want to make
8 sure I'm answering you as best I can
9 so can you restate or rephrase that
10 question?
11 BY MR. KETCHAM-COLWILL:
12 Q. Sure.
13 44,058,474.05, does that reflect
14 the end-of-day balance in Chain Bridge
15 Bank's Federal Reserve Bank account?
16 A. I don't know what the end-of-day
17 balance was because there's other
18 activity. That's where you see
19 nonresponsive. So there was additional
20 activity in the Federal Reserve Bank
21 account. So what you're looking at under
22 balance is just a running total of what
23 the balance was as various transactions
24 posted.
25 Q. As various transactions posted.
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2 Why are the amounts different for
3 the wire transfer return entries, rows 1
4 and 3?
5 MR. MADDEN: Object to the form.
6 THE WITNESS: I can't see where
7 they are different.
8 BY MR. KETCHAM-COLWILL:
9 Q. Row 1, wire transfer return or
10 RTM-Blue Flame Medical LLC, the balance
11 there says 412,830,125.95.
12 A. It's just presenting a running
13 total.
14 Q. I'm wondering why they don't --
15 why they are not the same like the entries
16 for the second and fourth rows are, if you
17 understand my question.
18 A. I'm not totally sure that I -- I
19 think I do but it's because the entries
20 are not posted in the natural order of
21 events, so you have a credit followed by
22 two debits followed by another credit.
23 Q. So maybe backing up for the wire
24 transfer return entries, there is a debit
25 in the third row which is wire transfer
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2 return-California State Treasurer and that
3 debit reflects an increase in this asset
4 account?
5 A. Taken in that order, yes.
6 Q. Why would the wire transfer
7 return reflect -- result in a debit to
8 this asset account?
9 A. The wire return ordinarily you
10 would see a credit which you see in the
11 first line under wire transfer return. So
12 ordinarily if funds had been hard posted
13 to a client's account, the client's
14 account would receive that debit. In this
15 case the client's account was never
16 credited with the funds, the debit is
17 coming from the Federal Reserve Bank
18 general ledger account. There is no funds
19 credited to the client's account to debit.
20 Q. And so if we were looking at a
21 document like this for demand deposits on
22 the liability side of a ledger, there
23 would be no offsetting transaction with
24 respect to the incoming wire transfer
25 entries if we are looking at the same day,
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2 March 26th?
3 MR. MADDEN: Objection to the
4 form. Answer if you can.
5 THE WITNESS: They would be --
6 I'm sorry, can you say that question
7 again?
8 BY MR. KETCHAM-COLWILL:
9 Q. In the event the customer's
10 account was deposited with these or was --
11 yeah, the funds from this wire transfer
12 were deposited into the customer's
13 account, there would be an offsetting
14 entry in the demand deposit account;
15 correct?
16 MR. MADDEN: Objection to form.
17 THE WITNESS: If a customer's
18 account was credited with the funds,
19 then yes, the demand account would
20 then be debited for the return.
21 BY MR. KETCHAM-COLWILL:
22 Q. For the return?
23 A. Yes.
24 Q. And for the incoming wire
25 transfer, there would be a credit, the
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2 offsetting transaction would be a credit?
3 A. If the client's account had -- if
4 credit had been given to the client's
5 account, then yes, the incoming wire would
6 be reflected by a credit in the deposit
7 accounts.
8 Q. What form would that entry take
9 in the demand deposit account?
10 A. It would be -- I'm sorry, can you
11 give me the whole scenario so I make sure
12 I'm answering the right question?
13 Q. Yeah.
14 In the event the wire comes in,
15 and so I guess looking at the second entry
16 here, wire transfer-Blue Flame Medical and
17 then there's a debit for 456 million, and
18 then the bank deposits that money into the
19 customer's account, what would we see in
20 the demand deposit version of this
21 document?
22 MR. MADDEN: Object to the form.
23 THE WITNESS: If those
24 circumstances occurred, then we would
25 have a credit.
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2 BY MR. KETCHAM-COLWILL:
3 Q. In the same amount?
4 A. Yes.
5 Q. Would that literally be what we
6 see or would it be -- or would that amount
7 be added to other customer deposits made
8 that day?
9 MR. MADDEN: Objection to form.
10 Answer if you can.
11 THE WITNESS: I think it would be
12 itemized in the client's records.
13 BY MR. KETCHAM-COLWILL:
14 Q. What about on the printout of the
15 demand deposit account in this general
16 ledger account history?
17 A. I'm not sure.
18 Q. So with respect to any Fedwire
19 funds transfer that comes into the bank's
20 Federal Reserve Bank account, we would see
21 a debit in here to this particular asset
22 account and we would see a corresponding
23 offsetting entry in the demand deposit
24 account, but either -- and both of those
25 entries would appear after batch
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1 WILLIAMSON - CONFIDENTIAL
2 processing or upon batch processing?
3 MR. MADDEN: Objection to the
4 form.
5 THE WITNESS: They would remain
6 in a pending state until batch
7 processing occurred.
8 BY MR. KETCHAM-COLWILL:
9 Q. So entries get automatically
10 posted here but they are in a pending
11 state until that batch processing occurs?
12 MR. MADDEN: Objection to form.
13 THE WITNESS: Yes.
14 BY MR. KETCHAM-COLWILL:
15 Q. Would there be something on this
16 document that indicated the entry was a
17 pending one?
18 MR. MADDEN: Objection to form.
19 THE WITNESS: I don't know that I
20 can produce these reports. I don't
21 know. I don't know whether I can
22 produce these reports with memo posts
23 or not.
24 BY MR. KETCHAM-COLWILL:
25 Q. Is it possible to access this
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1 WILLIAMSON - CONFIDENTIAL
2 general ledger account history the same
3 day the entries are automatically made?
4 MR. MADDEN: Objection to the
5 form.
6 THE WITNESS: Can you say your
7 question again?
8 BY MR. KETCHAM-COLWILL:
9 Q. I'm wondering if today, say April
10 11th, you could go into this program,
11 module, whatever it is, for the account
12 history and see the automatic entries
13 being made for that same day.
14 A. Any entries that show up during
15 the same day are signified as a memo post.
16 Q. And that's what this printout
17 would say?
18 A. I don't believe I could get it
19 printed out.
20 Q. That's what you would see on your
21 computer screen?
22 A. I think so, yes.
23 Q. Would there be a separate column
24 for that, a different column than any of
25 the ones that we see here?
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1 WILLIAMSON - CONFIDENTIAL
2 MR. MADDEN: Object to the form.
3 THE WITNESS: I think I have --
4 I'm uncertain. I think I would have
5 to select a separate tab to see the
6 intraday memo posts.
7 BY MR. KETCHAM-COLWILL:
8 Q. But you could see them, it might
9 be a separate tab, and they might indicate
10 that they are memo posts but you would be
11 able to go onto your computer and view
12 them that day?
13 MR. MADDEN: Objection to form.
14 THE WITNESS: Yeah, I'm not sure
15 about the automatic -- excuse me, the
16 system-generated entries. I'm really
17 thinking about manual journal entries
18 that my team might post. And I'm not
19 sure if there would be a difference in
20 what I could see on my computer screen
21 based on the source of the journal
22 entry and that's why I'm having
23 trouble answering your question.
24 BY MR. KETCHAM-COLWILL:
25 Q. You never tried to do what I'm
41 (Pages 158 - 161)
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