International Automated Systems (fka IAUS)

[scion]

From: Case 2:15-cv-00828-DN-EJF Document 256-27 Filed 11/17/17

(Greg Shepard's deposition)

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Q. My understanding, I have read this agreement and my understanding is that you were leasing the lenses that you had leased from IAS, on the same date, December 28, 2005, you had turned around and subleased those to LTB; is that correct?
A. Yes.
Q. That's your understanding of the contract?
A. That's my understanding.
Q. This also referred to Yermo, California; is that right?
A. Yes.
Q. When is the first time you heard about LTB?
A. On this date.
Q. Okay.
A. Or a little before. I'm not sure.
Q. All right. What is LTB?
A. I don't know. I mean, other than what it says there, a Nevada limited liability company. And they are authorized, I guess, to --
Q. That's all you know about them?
A. Yes. I don't know who owns it or who runs it or who -- I don't know anything about the entity.
Q. All right. Before you signed this agreement to sublease your lenses to them, did you do any research on LTB?
A. No.
Q. Do you know -- you don't know any of its history?
A. No.
Q. Do you know if it has any expertise or experience in --
MR. REAY: Objection. Calls for speculation. Sorry. I should have let you finish.
Q. -- operating and maintaining solar lenses?
A. I don't know.
MR. REAY: Objection. Calls for speculation.
A. Yeah.
Q. Was the first time you heard of LTB when it was on this agreement?
A. Yes.
Q. Who drafted this agreement?
A. I don't know.
Q. Who gave you this agreement, Exhibit 464?
A. I can't remember.
Q. Is there any reason to believe it wasn't International Automated Systems?
A. No.
Q. No, there's no reason to believe that?
A. They probably did, but I can't recall it. It's twelve years ago.
Q. Okay. So the first time you ever heard of LTB, LLC was when it was --
A. Yes.
Q. -- on this contract?
A. Yes.
Q. And you subleased your lenses to them.
A. Yes.
Q. Okay. Do you know what LTB did with your lenses after they had been subleased?
A. No.

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There are some other interesting exchanges in that deposition.

Would YOU sublease an asset to somebody you had never heard of?

Sure is a pretty day.

TED