final.txt

		THE REPORTER:  Good morning.  We are going on the record.  Today's date is October 18th, and the time is 10:04 a.m. eastern time.  My name is Dembe Zuma and I'm the court reporter assigned by Example Deposition Technologies.  I request all parties stipulate and agree that by videoconference technology, this will be the remote deposition of Amber Hard in the case of John Doe, II v. Amber Hard.  Before going on the record, the witness positively identified herself by New York State driver's license as Amber Hard, and she is currently located in the Bronx, New York.  Counsel, will you please state your appearance for the record, who you represent, and that you agree to stipulate that we may place this witness under oath and report this proceeding remotely?
		MS. KEEN:  Good morning.  Elizabeth Keen on behalf of the plaintiff, John Doe.
		MR. REDDINGTON:  Yes.  Good morning.  Raymond Reddington on behalf of the defendant, Amber Hard.  And we stipulate.  Law firm is Raymond Reddington, PLLC.
		THE REPORTER:  Okay.
		MS. KEEN:  I so stipulate.
		THE REPORTER:  Okay.  And Ms. Hard, will you please raise your right hand?
		(Witness sworn.)
		THE REPORTER:  Okay.  Counsel, please proceed.
		MR. REDDINGTON:  Thank you.
DIRECT EXAMINATION
BY MR. REDDINGTON:
	Q.	Good morning.  How are you doing today?
	A.	I'm doing well.  How about yourself?
	Q.	Good.  Thank you for asking.  As you heard, my name is Raymond Reddington.  I'm an attorney.  I work at Raymond Reddington, PLLC.  I'll be taking your deposition today.  Can I get you to start off just by stating your full and complete legal name for the record?
	A.	Yes.  My name is Amber Hard.  H-A-R-D.
	Q.	And for purposes of today, may I call you Amber?  Or do you prefer Ms. Hard?  Let me know your preference.
	A.	Amber is fine.
	Q.	And Amber, have you given a deposition before?
	A.	Yes.
	Q.	Amber, can you please state your current occupation and the nature of your work?
	Q.	I work as a marketing consultant for XYZ Marketing Agency.  My role involves developing and implementing marketing strategies for clients.
	Q.	How long have you been employed in this capacity?
	A.	I've been working as a marketing consultant  here in the U.S. for approximately five years now.
	Q.	Prior to your current position, did you have any other relevant professional experiences?
	A.	Yes, before XYZ Marketing Agency, I worked as a marketing coordinator at ABC Advertising for two years.
	Q.	Let's turn our attention to the events leading up to this deposition.  Did you -- strike that.  
		Were you acquainted with the plaintiff, John Doe, II, before the incident in question?
	A.	Yes, I knew John Doe.  We were acquaintances.
	Q.	Can you provide a brief overview of the nature of your relationship with Mr. Doe?
	A.	We met through mutual friends and occasionally attended social events together.  We were not close friends, but we knew each other.
	Q.	Now, turning to the specific incident in question, can you describe your version of what transpired on the date in question?
		MS. KEEN:  Objection.  Vague.  The question lacks specificity as to the incident referred to.
		MR. REDDINGTON:  I'll rephrase.
BY MR. REDDINGTON:
	Q.	On the date in question, did you have any interaction or encounter with John Doe, II?
	A.	Yes, I did.
	Q.	Could you please provide a detailed account of the events that occurred during that interaction?
	A.	We bumped into each other at a local café.  There was a brief exchange of words, but nothing out of the ordinary.  It was a casual encounter.
	Q.	Were there any disputes or disagreements during this interaction?
	A.	No, there were no disputes or disagreements.  It was a brief and unremarkable conversation.
		MS. KEEN:  Objection.  Form.
BY MR. REDDINGTON:
	Q.	Amber, did anything unusual happen during or after your interaction with Mr. Doe?
	A.	No, nothing unusual.  After our brief conversation, we went our separate ways.
	Q.	Did you have any further contact with Mr. Doe following that encounter?
	A.	No, I did not.
		MS. KEEN:  Objection.  Leading.
BY MR. REDDINGTON:
	Q.	Can you confirm whether you had any subsequent contact or communication with John Doe, II, after the incident at the café?
	A.	No, I did not have any further contact or communication with him.
		MR. REDDINGTON:  Mr. Court Reporter, can we take a five-minute break, please?
		THE REPORTER:  Okay.  The time is 10:32 a.m., and we are off the record.
		(Off the record.)
		THE REPORTER:  We are back on the record.  The time is 10:38 a.m.
BY MR. REDDINGTON:
	Q.	Amber, you mentioned a casual encounter at the local café with Mr. Doe.  Can you recall the date and time of this incident?
	A.	I believe it was on the evening of July 15th, but I can't recall the exact time.
	Q.	That's understandable.  Now, regarding the cafe's location, could you identify the establishment where the encounter took place?
	A.	It was "Café Serenity" on Maple Street.
	Q.	Thank you for clarifying.  Were there any other individuals present or witnesses to your interaction with Mr. Doe?
	A.	I don't recall anyone else being directly involved in our conversation.  It was a busy evening, and the café had several patrons.
	Q.	Moving forward, after the encounter, did you become aware of any issues or disputes arising between you and Mr. Doe?
	A.	No, there were no issues.  As I mentioned earlier, it was a brief and unremarkable conversation.
	Q.	Did you receive any communication from Mr. Doe after this incident?
	A.	No, I did not receive any communication from him.
	Q.	Did you become aware of any legal action or complaint filed against you by Mr. Doe?
	A.	No, I was not aware of any legal action until I was served with the lawsuit papers.
		MS. KEEN:  Objection.  Form.
BY MR. REDDINGTON:
	Q.	Amber, prior to being served with the lawsuit papers, were you aware that Mr. Doe intended to take legal action against you?
	A.	No, I had no knowledge of any such intention.
	Q.	Let's delve into your professional background.  How long -- strike that.  
		As a marketing consultant, can you describe the nature of your work and the type of clients you typically handle?
	A.	Certainly.  As a marketing consultant at XYZ Marketing Agency, my role involves developing comprehensive marketing strategies for clients across various industries.  I work on brand development, digital marketing campaigns, and overall promotional efforts.
	Q.	In the course of your work, do you engage in any activities that involve potential conflicts or disputes?
		MS. KEEN:  Objection.  Relevance.
		MR. REDDINGTON:  I'll connect it to the case.
BY MR. REDDINGTON:
	Q.	Amber, in your role as a marketing consultant, have you ever encountered situations where clients or individuals expressed dissatisfaction or disagreements with your marketing strategies?
	A.	Yes, it's not uncommon for clients to have differing opinions or preferences.  However, we always work towards finding common ground and delivering effective solutions.
	Q.	Have you ever faced any legal disputes or litigations related to your work?
	A.	No, I have not been involved in any legal disputes related to my work.
		MS. KEEN:  Objection.  Relevance.
		MR. REDDINGTON:  Noted.
BY MR. REDDINGTON:
	Q.	Amber, returning to the incident with Mr. Doe, did you notice anyone else observing or recording your interaction at the café?
	A.	No, I did not notice anyone acting in that manner.
	Q.	Were there any security cameras in or around the café that might have captured the incident?
	A.	I'm not sure about specific cameras, but many establishments have surveillance for security purposes.
		MR. REDDINGTON:  We'll verify that information independently.
		MS. KEEN:  Sure.
BY MR. REDDINGTON:
	Q.	Amber, did Mr. Doe make any specific statements or gestures during your interaction that stood out to you?
	A.	No, the conversation was brief and ordinary.  There was nothing remarkable about his statements or gestures.
		MS. KEEN:  Objection.  Vague.  The term "ordinary" is subjective and does not provide clear details about the interaction.
		MR. REDDINGTON:  I'll seek more clarity.
BY MR. REDDINGTON:
	Q.	Amber, can you recall any specific statements made by Mr. Doe during your interaction?
	A.	He greeted me, we exchanged a few pleasantries, and that was it.  There were no noteworthy statements made.
	Q.	Did Mr. Doe express any concerns or complaints during this encounter?
	A.	No, there were no expressions of concern or complaints.
		MR. REDDINGTON:  I have no further questions for the witness at this time.
		MS. KEEN:  Can we take a break before I begin my cross?
		MR. REDDINGTON:  Sure thing.
		THE REPORTER:  The time is 11:02 a.m., and we are off the record.
		(Off the record.)
		THE REPORTER:  We are back on the record.  The time is 11:05 a.m.
CROSS-EXAMINATION
BY MS. KEEN:
	Q.	Good morning, Amber.  My name is Elizabeth Keen, and I represent Mr. John Doe, II, the plaintiff in this case.  Let's begin by clarifying some details.
	A.	Good morning.
	Q.	In your previous testimony, you mentioned that you and Mr. Doe were acquaintances who occasionally attended social events together.  Can you elaborate on the nature of these social events?
	A.	Sure.  We had mutual friends, and sometimes we would all gather for dinners or parties.  It was more of a casual social circle.
	A.	Were these gatherings organized by a specific group, or were they more spontaneous?
	A.	It was a mix.  Sometimes our mutual friends would plan events, and other times we would informally decide to meet up.
	Q.	Regarding the incident at Café Serenity, did you enter the establishment with the intention of meeting Mr. Doe, or was it a coincidental encounter?
	A.	It was coincidental.  I happened to be at the café, and we ran into each other.
	Q.	Can you recall if there were any specific topics discussed during your conversation at the café?
		MR. REDDINGTON:  Objection.  Form.  You may answer, Amber.
		THE WITNESS:  We talked about general things—how we were doing, work, and some light banter.  Nothing specific or noteworthy.
BY MS. KEEN:
	Q.	Did Mr. Doe appear upset or agitated during the conversation?
	A.	No, he seemed perfectly fine.  It was a normal, casual conversation.
	Q.	You mentioned that there were no disputes or disagreements.  Can you confirm that there was no mention of any potential conflicts or issues during your conversation?
	A.	That's correct.  We didn't discuss anything of that nature.
		MR. REDDINGTON:  Objection.  Leading.
BY MS. KEEN:
	Q.	Did the conversation at Café Serenity include any mention of disagreements, disputes, or potential issues between you and Mr. Doe?
	A.	No, there was no mention of any disagreements or issues.
	Q.	You've stated that the encounter was unremarkable.  Were there any circumstances or details that you found unusual or concerning?
	A.	No, nothing stood out as unusual.  It was a routine meeting, and we went our separate ways.
	Q.	Following this encounter, did you discuss the meeting with anyone else?
	A.	Not immediately.  It was a brief and ordinary encounter, so I didn't find it noteworthy.
	Q.	Did you share any details of this encounter with your friends or colleagues afterward?
	A.	No, I didn't see the need to discuss it.  It was a minor interaction.
		MS. KEEN:  No further questions for the witness at this time.
REDIRECT EXAMINATION
BY MR. REDDINGTON:
	Q.	Amber, during the conversation at Café Serenity, did Mr. Doe mention anything about his emotional or mental state?
	A.	No, he did not discuss anything related to his emotional or mental state.
	Q.	Was there any indication, either through his words or demeanor, that he was distressed or unhappy?
	A.	No, there was no indication of distress.  It was a casual and normal conversation.
	Q.	Ms. Keen mentioned the lack of discussion about potential conflicts or issues during the café encounter.  Did Mr. Doe give any impression that he had concerns or grievances, even if not explicitly stated?
		MS. KEEN:  Objection.  Assumes facts not in evidence.  The witness has already testified that there were no indications of conflicts or issues.
		MR. REDDINGTON:  I'll move on.
BY MR. REDDINGTON:
	Q.	Amber, did you notice if Mr. Doe was accompanied by anyone else at the café during your encounter?
	A.	No, he was alone.
	Q.	In the days or weeks following the café incident, did you receive any communication from Mr. Doe, whether by phone, email, or any other means?
	A.	No, there was no communication from him.
	Q.	Moving forward, Amber, were you served with any pre-litigation notices or warnings related to the allegations before the formal lawsuit was filed?
	A.	No, I did not receive any pre-litigation notices or warnings.
		MR. REDDINGTON:  No further questions.
		MS. KEEN:  Can we take a break?
		MR. REDDINGTON:  Sure.  Mr. Court Reporter?
		THE REPORTER:  The time is 12:03 p.m. We are off the record.
		(Off the record.)
		THE REPORTER:  We are back on the record.  The time is 12:20 p.m.
RECROSS-EXAMINATION
BY MS. KEEN:
	Q.	Let's discuss the events following the filing of the lawsuit.  Upon receiving the lawsuit papers, did you seek legal counsel immediately?
	A.	Yes, as soon as I received the papers, I contacted my attorney.
	Q.	Did you discuss the allegations with your attorney before today's deposition?
	A.	Yes, we had discussions about the case.
	Q.	Can you share the nature of those discussions?  What guidance did your attorney provide?
		MR. REDDINGTON:  Objection.  Attorney-client privilege.
		MS. KEEN:  I'm seeking general information.
		THE REPORTER:  Amber, you may answer.
		THE WITNESS:  My attorney provided an overview of the legal process and discussed potential strategies for the deposition.  We focused on clarifying the details of the café encounter.
BY MS. KEEN:
	Q.	Did your attorney provide any advice regarding potential resolutions or settlement discussions?
	A.	Yes, we briefly discussed potential resolutions, but it was more in the context of understanding the options available.
	Q.	Amber, have you taken any specific steps or actions to gather evidence or documents related to the allegations against you?
	A.	Yes, my attorney and I have been working to collect relevant information to build a comprehensive defense.
	Q.	Can you provide insight into the nature of the evidence or documents you've gathered?
	A.	We are collecting any records or documents that may shed light on the events in question, including any potential witnesses or surveillance footage.
	Q.	In your professional capacity as a marketing consultant, do you handle any confidential or sensitive information?
	A.	Yes, I often deal with confidential client information.
	Q.	Have there been instances in the past where clients raised concerns about the handling of their confidential information?
	A.	No, I have not faced such concerns.
		MS. KEEN:  Well, given that, I have no further questions.
		THE REPORTER:  Mr. Reddington, do you have any questions?
		MR. REDDINGTON:  I do not.  I do not have any questions.
		THE REPORTER:  Okay.  So this is the court reporter speaking.  Ms. Keen, would you like to order a copy of the transcript?
		MS. KEEN:  No, I'll just have to ask her if she wants to read or waive.
		THE WITNESS:  I'll read.
		MS. KEEN:  The witness likes to read.
		THE REPORTER:  Okay.  And Ms. Hard, where would you like your read and sign mail sent to?
		MS. KEEN:  Her counsel.
		THE WITNESS:  Just send it to counsel.
		MR. REDDINGTON:  Yes, you have my information.  You can send it to me.
		THE REPORTER:  Okay.  And Mr. Reddington, would you like to order a copy of the transcript?
		MR. REDDINGTON:  Not at this time.
		THE REPORTER:  Okay.  We are now going off the record.  This concludes the deposition of Amber Hard.  The time is 12:54 p.m. eastern time.