DEPOSITION TRANSCRIPT
Case: Ironclad Legal Technologies Inc. v. Cascade Renewable Energy Corp.
Case No.: 4-23-cv-56985-VEC
Court: United States District Court
Witness: Karen Bishop, Director of Human Resources
Date: 2023-08-11
Examining Attorney: [Counsel for Cascade Renewable Energy Corp.], Gibson, Dunn & Crutcher LLP
EXAMINATION BY COUNSEL:
Q: Please state your name and current title for the record.
A: My name is Karen Bishop. I serve as Director of Human Resources.
Q: How long have you been in that role?
A: Approximately 4 years.
Q: I want to direct your attention to the subject of trade secret access and disclosure.
Were you personally involved in those matters?
A: Yes, I was directly involved.
Q: Please describe your involvement.
A: I oversaw the relevant process and was responsible for ensuring compliance
with all applicable agreements and obligations.
Q: Were you aware of the specific contractual provisions at issue?
A: Yes. I reviewed those provisions carefully before proceeding.
Q: Did you take any steps to comply with the notice requirements?
A: We followed our standard procedures, which I believed to be compliant.
Q: I'm showing you what has been marked as Exhibit A. Do you recognize this document?
A: Yes, I signed it. I understood it restricted certain activities.
Q: And you understood the geographic scope of that restriction?
A: Yes. I believe it covered the continental United States.
Q: At any point did you consult legal counsel regarding these obligations?
A: Yes, we engaged Gibson, Dunn & Crutcher LLP to advise us on compliance.
Q: Nothing further. Thank you.
[END OF EXAMINATION]
Certified by: _______________________________
Court Reporter
I, Karen Bishop, certify that the foregoing transcript accurately reflects my testimony.
Signature: _______________________________
Date: 2023-08-11