1 2 10 at 12 13 14 15 16 17 18 19 20 21 22 23 24 25 33 A Yes. Q And the device used to record information from your computer system onto the master CD is a device within the Recorder's office -- is that correct? -- as opposed to being in some other building somewhere? A Yes. @ During your tenure in the computer department at the Recorder's office, has the Recorder's office had photocopying machines? MR. CAVANAGH: Objection. Q Any photocopying machine? A When you say "photocopying machine," what do you mean? Q Let me be -- let me make sure I understand your question. You don't have an understanding of what photocopying machine is? A No. I want to make sure that I answer your question correctly. MR. CAVANAGH: Dave, I'll object to the tone of the question. You make it sound like it's unbelievable to you that he wouldn't know what the definition of a photocopy machine is. MR. MARBURGER: I didn't ask10 a 12 13 14 15 16 17 18 19 20 21 22 23 24 25 34 him to define it. I asked him if he had any. A - When you say "photocopying machine," what do you mean? Q et me be clear. The term "photocopying machine" is so ambiguous that you can't picture in your mind what a photocopying machine is in an office setting? A I just want to make sure I answer your question correctly. Q Well, we'll find out. If you can say yes or no, I can do follow-ups, but it seems -- if you really don't know in an office setting what a photocopying machine is, I'd like the Ohio Supreme Court to hear you say so. A I just want to make sure I answer your question correctly. MR. CAVANAGH: There's different types of photocopiers, Dave. MR. MARBURGER: You're speaking instead of -- you're not under oath. This guy is. MR. CAVANAGH: I understand that, but I understand what hiswon 10 a 12 13 14 15 16 17 18 19 20 21 22 23 24 25 35 objection is. You want him to answer the question, but I don't think it's fair. MR. MARBURGER: It's not fair? MR. CAVANAGH: It's not a fair question. A photocopy machine can be a machine that uses photostatic technology, that uses xerographic technology, that uses scanning technology. BY MR. MARBURGER: Q I don't care what kind of technology it uses. Has your office -- we don't have technocrats on the Ohio Supreme Court. We've got people like me, general guys -- MR. CAVANAGH: Objection. Q -- or gals. I'm not really very interested in what the technology element of it is. I want to know -- MR. CAVANAGH: That's what's at issue in the case, Dave. MR. MARBURGER: Not in my judgement. BY MR. MARBURGER: