PARTIAL DEPOSITION TRANSCRIPT OF ANDI DENMAN
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MR. BERTSCH: You were transferred to your current position involuntarily, correct?
DENMAN: I would not characterize my transfer as involuntary.
MR. BERTSCH: Look, we’ve gone around and around this issue several times. Why won’t you just give me the details that surround your transfer? When was that, anyway?
DENMAN: In 1998.
MR. BERTSCH: 1998 was the year you left the Rocket Launch Division at NASA, then, correct?
DENMAN: Yes, and went to Oceanic Processes.
MR. BERTSCH: And you took a significant pay cut, didn’t you?
DENMAN: Yes, but the new position gave me the latitude to begin my corporation and, ultimately, my salary went up.
MR. BERTSCH: But it wasn’t being paid by NASA—I mean, your total pay was based on a reduced amount plus income from InfaStorm, right?
DENMAN: Yes.
MR. BERTSCH: Before your transfer, you had been involved in the Civitron Rocket Launch project for NASA, correct?
DENMAN: I have told you before, that is classified information.
MR. BERTSCH: I would be happy to stop this deposition, pack it all up, and go down to Judge Curnan to get an order so that you may declassify your information. Is that really necessary?
(Whereupon an off the record discussion was had between counsel)
DENMAN: I was involved in a top secret new rocket program until my transfer.
MR. BERTSCH: In fact, you were in charge of coordinating trial launches of these new rockets. That is, you had the ultimate decision as to whether a launch could proceed or would be delayed or even cancelled because of the weather—any weather problems, or whatever, right?
DENMAN: I consulted with others on the team and we would make our decisions based upon those consultations.
MR. BERTSCH: But, ultimately, the decision was yours, entirely yours, correct?
DENMAN: Yes, ultimately the decision was mine. I see where you are going with this and I don’t like it. What happened that year was…it was a fluke and it was no person’s fault. We had a rocket crash, o.k.? But nothing ever linked that crash or the resulting fatalities to my work or my weather forecasting abilities.
MR. BERTSCH: It was a launch into the eye of a hurricane that suddenly appeared without warning?
DENMAN: Precisely. You never know with these things what will happen. A storm can come up out of nowhere. All systems were go for a clear and safe launch. Nobody had a clue that the storm would change its course. It was tracking due south, away from us, when it turned around and it was too late.
MR. BERTSCH: You can never really tell with weather, can you?
DENMAN: Exactly.
MR. BERTSCH: Your corporation, InfaStorm, is going public soon, correct?
DENMAN: Yes, that’s true. We hope to be SEC approved and ready to trade by year’s end.
MR. BERTSCH: You need increased cash flow particularly badly right now, don’t you?
DENMAN: We are growing.
MR. BERTSCH: Actually, you need funds to support litigation that is currently pending against you in 12 states for fraud, negligence, and other torts, don’t you?
DENMAN: I don’t have to tell you about these things. It’s a part of business that you get sued. You should know that. You greedy lawyers ruin everything.
MR. BERTSCH: Well, we will save that discussion for another day. I am, however, very interested to discuss the Iowa lawsuit captioned Best Aviators, Inc. v. InfaStorm, Inc. If memory serves me the basis of that suit is faulty forecast information from you, personally, that caused an airplane to crash just outside of Peoria, Illinois, correct?
DENMAN: That’s it. I am not answering any more questions.
MR. BERTSCH: Then we’ll take a break and go see the Judge.
(Whereupon discussion was had between counsel and the deposition terminated.)
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DR. ANDI DENMAN
WHEREFORE, THE DEPONENT ANDI DENMAN HAS REVIEWED THIS DEPOSITIO AND HAS FOUND NO ERRORS THAT OCCURRED DURING THE TRANSCRIPTION OF THIS DEPOSITION
As a notary public in the state of Midlands, I certify that Dr. Denman has reviewed and signed this document.
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R. E. PALM