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101101 Jeff Nicolaysen Testimony

101101 Jeff Nicolaysen Testimony

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Published by: jonortiz8218 on Nov 03, 2010
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07/10/2013

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MR. BAXTER: Fair enough.I call CCPOA's person most knowledgeable who Iunderstand is Jeff Nicolaysen.THE COURT: Come around and be sworn, sir.THE CLERK: Please, raise your right hand.JEFF NICOLAYSEN,was thereupon called as a witness herein by the Plaintiff,and having been sworn to tell the truth, the whole truth andnothing but the truth, was thereupon examined and testifiedas follows:THE CLERK: Please, take a seat. State your name,spell your last name and speak directly into the microphone.THE WITNESS: My name is Jeff Nicolaysen. That'sN-I-C-O-L-A-Y-S-E-N.DIRECT EXAMINATIONBY MR. BAXTER:Q.Good morning, Mr. Nicolaysen. How are you?A.Good.Q.What position do you hold with CCPOA?A.I'm the chief finance officer.Q.How long have you held that position?A.I've been with the organization 25 years. The titleI've had for probably about five years.Q.And you're aware, I assume, that this examination isgoing to focus on CCPOA's financial condition?CATHERINE E.F. BODENE, OFFICIAL COURT REPORTER, USDC(916) 446-6360112345678910111213141516171819202122232425
 
A.Yes, sir.Q.Okay. And you're aware that one of the factors thatthe jury is to consider in determining the amount of punitivedamages is the financial condition of the various defendants,right?A.Yes, sir.Q.Okay. And are you aware that and I, and my clients,recently subpoenaed CCPOA's person most knowledgeableregarding the financial conditions?A.Yes, sir.Q.Are you that person?A.Yes, sir.Q.Do you have personal knowledge of CCPOA's currentincome and expenses?A.Yes, sir.Q.All right. And current knowledge of the CCPOA'scurrent assets and liabilities?A.Yes, sir.Q.Why don't we talk about some of those.Did you prepare what was called a Statement ofFinancial Position in conjunction with your testimony heretoday?A.Yes, I did.Q.Okay. I'd like to flash for the witness only, if wemight, what I've gone ahead and marked as Exhibit 1182.CATHERINE E.F. BODENE, OFFICIAL COURT REPORTER, USDC(916) 446-6360212345678910111213141516171819202122232425
 
(Exhibit published for witness.)Can you see that on your screen, sir?A.No.Q.My fault.(Monitor adjusted.)Have it there?A.Yeah.MR. MASTAGNI, SR.: Your Honor, we'll stipulate thedocuments can come in should Mr. Baxter desire.MR. BAXTER: Great. Thank you very much.I would like to move Exhibit 1182 into evidence.THE COURT: Received.(WHEREUPON, Plaintiff's Exhibit Number 1182 wasreceived into evidence.)BY MR. BAXTER:Q.Okay. Mr. Nicolaysen, just to acclimate the jury tothis document, this is something that reflects yourassessment of the financial position of CCPOA as of September30, 2010, right?(Exhibit published.)A.Yes.Q.Okay. And the first half of the document at the tophas the indication of "Assets," right?A.Right.Q.Okay. And that data that follows represents yourCATHERINE E.F. BODENE, OFFICIAL COURT REPORTER, USDC(916) 446-6360312345678910111213141516171819202122232425

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