00005
21	Q   Okay. And can you please state your full
22	name and address for the record, sir?
23	A   Richard Scott Elliott, 410 North Mercedes
24	Drive, Norman, Oklahoma 73069.

00008
15	Q   Mr. Elliott, what is your current job
16	title?
17	A   Human resources portfolio manager for --
18	or in information management and technology.
19	Q   And who is your current employer?
20	A   Kerr-McGee Corporation.
21	Q   And how long have you held this position
22	at Kerr-McGee?
23	A   Three years and a few days.
24	Q   And can you please give me a general
25	description of your job responsibilities in your

00009
1	current position?
2	A   Sure. I manage a group of IT
3	professionals that supports several of our
4	corporate clients, human resources, legal and
5	medical groups.
6	Q   How many IT professionals do you manage?
7	A   Eight other folks besides me.
8	Q   And how many of those report directly to
9	you?
10	A   All of them.
18	Q   Do you also do any work that would
19	support the financial aspect of Kerr-McGee?
20	A   No, that's handled by another group in MI
21	& T.
22	Q   Is there another person who would be
23	considered your counterpart that handles the
24	financials?
25	A   Yes.

00010
1	Q   And who is that?
2	A   Bryan Wilks.
3	Q   And what's his position?
4	A   Portfolio manager as well for financial
5	systems.
6	Q   And do your job responsibilities also
7	include responsibility for software procurement?
8	A   In an advisement capacity, yes.
9	Q   What do you mean when you say in an
10	advisement capacity?
11	A   Our strategy at Kerr-McGee is that our
12	customers are the ones who drive software
13	procurement decisions and we are advisors to them
14	in that process.

00011
17	Q   Are you also responsible for working to
18	insure that Kerr-McGee gets the best deal that it
19	can on software procurement?
20	A   We act in different roles depending on
21	the, depending on the procurement activities.
22	Q   Is it ever a goal to try to get the best
23	value or best price that you can on software
24	procurement?
25	A   Always.

00014
9	Q.   (By Ms. McKinney) Can you explain to me
10	generally what the nature of Kerr-McGee's
11	business is?
12	A   Yes. Again, back to our two main lines
13	of business, oil and gas exploration and
14	production and then chemical manufacturing. Our
15	main product is titanium dioxide, a pigment. We
16	do produce a few other electrolytical chemicals
17	and for a short period of time we still have a
18	small business producing railroad ties. It's
19	being phased out at the end of this year.
20	Q   And does Kerr-McGee have any
21	operations -- or let me ask it this way. In what
22	geographical areas does Kerr-McGee have
23	operations?
24	A   We have operations, I don't know how many
25	states, but across the United States and to my

00015
1	knowledge we have operations in Brazil, Bonine,
2	Morocco, Australia, China, the Netherlands,
3	Germany, the UK. Those are the major ones.

00018
2	Q   So given the definitions that you've just
3	given me, does the oil and gas division have
4	independent authority for procurement of any ERP
5	software?
6	A   In my experience at Kerr-McGee, those ERP
7	software decisions have been global decisions,
8	not business unit specific.
9	Q   And what do you mean by global decisions?
10	A   We, our preferred strategy at Kerr-McGee
11	is to have for each major functional area one
12	global supplier of software. In financials we
13	have one, in HR we have one. We have not been
14	able to accomplish that yet in the supply chain
15	side to my knowledge.

00031
18	Q.   (By Ms. McKinney) And how would you
19	define core functionality on the financial
20	management side?
21	A   The general ledger, accounts payable.
22	There are a variety of for us revenue or I should
23	say upstream oil and gas specific accounting
24	functions that would be core for us. I'm sure
25	there's a variety of others that could be listed,

00032
1	but those are the ones that are main ones for us
2	in my opinion.
3	Q   Do you know what any of those oil and gas
4	specific accounting functions are?
5	A   Some.
6	Q   Can you name them for me?
7	A   One would be -- the two major items are
8	tracking production and then tracking the revenue
9	that we receive for production.

00033
1	Q.   (By Ms. McKinney) Would these
2	accounting functions you've just named, tracking
3	the production and tracking revenue, are those
4	functions that are specific to an oil industry or
5	to an oil company?
6	A   That's not my area of expertise, but it
7	would seem to be so because that is oil and gas
8	production and oil and gas revenue.
9	Q   Which software vendors offer core
10	financial management functionality?
11	MR. HAMMAKER: Objection, vague and lacks
12	foundation.
13	THE WITNESS: I don't know the complete
14	list. Again, not my area of expertise or
15	responsibility.
16	Q.   (By Ms. McKinney) Do you know some?
17	A   Yes.
18	Q   Which ones would you name?
19	A   The ones I can specifically name would be
20	PeopleSoft, Oracle, Lawson and SAP.
21	Q   And with regard to human resources
22	management core functionality, which vendors
23	offer HR core functionality?
24	A   Again, I don't know the complete list,
25	but I would list the same four.

00034
1	Q   Any others?
2	A   It's my understanding that Microsoft
3	purchased Great Plains, which I believe offers in
4	name at least those core functionality.
25	Q   But you don't have the same level of

00035
1	knowledge about Lawson, SAP or Microsoft that you
2	do about Oracle and PeopleSoft?
3	A   The Oracle and PeopleSoft knowledge is
4	more current than the other two because we did
5	not -- or the other three. We did not have
6	detailed evaluations of Microsoft and of SAP
7	during our selection process. Lawson I do have a
8	feel but not detailed modules or detailed
9	functionality.

00039
3	Q   Mr. Elliott, who would you name to be the
4	foremost ERP software vendors currently?
5	MR. HAMMAKER: Objection, vague, lacks
6	foundation.
7	THE WITNESS: Based on our process and a
8	review of Gartner recommendations, the same four
9	I listed previously, PeopleSoft, Oracle, Lawson
10	and SAP.

00040
8	Q.   (By Ms. McKinney) And in your opinion
9	what factor or factors drive innovation in the
10	software industry?
11	A   I would list competition, business
12	environment changes, customer demands, regulatory
13	changes.

00041
10	Q   Do you consider Kerr-McGee's ERP software
11	needs to be complex?
12	A   Yes.
13	Q   Do you consider them to be unique?
14	A   No.

00042
23	Q.   (By Ms. McKinney) Mr. Elliott, what
24	core financial management software does
25	Kerr-McGee use?

00043
1	A   Oracle.
2	Q   And --
3	A   And Energy Extensions from P2ES.
4	THE REPORTER: P2BS?
5	THE WITNESS: ES.
6	Q.   (By Ms. McKinney) Do you know what
7	modules it uses from Oracle on the finance side?
8	A   I do not know for sure.
9	Q   And what is Energy Extensions?
10	A   To my knowledge that deals with all of
11	the oil and gas specific revenue accounting
12	including production.
13	Q   Would you consider that a point solution?
17	THE WITNESS: I really could go either
18	way on that. It's integrated with Oracle. I
19	think, my opinion would be that it is not.
23	Q   And why would it not be considered a
24	point solution in your opinion?
25	A   Oracle integration.

00044
5	Q   Is the Oracle financial management
6	software used in both the oil and gas and the
7	chemical manufacturing business units?
8	A   Yes.

00045
2	Q   Are there any business units within
3	Kerr-McGee that use some other financial
4	management software besides Oracle?
5	A   If there are I don't know.
6	Q   Do you know when Oracle financial
7	management software was initially purchased or
8	licensed?
9	A   Prior to the year 2000.
18	Q   Do you know what languages Kerr-McGee
19	operates the Oracle financial management software
20	in?
21	A   I do not.
22	Q   And do you know what currencies are used
23	on the Oracle financial management software, if
24	there are any foreign currencies used?
25	A   I'm sure there are, but I don't know

00046
1	specifically what we use.
17	Q   We'll shift to the HR side now.
18	What core HR software does Kerr-McGee
19	currently use?
20	A   PeopleSoft.
21	Q   And is the PeopleSoft software used in
22	all geographic regions where Kerr-McGee operates?
23	A   Yes.
24	Q   And are there any business units that do
25	not use the PeopleSoft HR software?

00047
1	A   No.
2	Q   And when was the PeopleSoft HR software
3	initially purchased or licensed?
4	A   2001.
7	Q   And do you recall how much Kerr-McGee
8	paid PeopleSoft?
9	A   There are documents that support this. I
10	believe the license fees were in the neighborhood
11	of 1.5 million.
12	Q   And did Kerr-McGee pay PeopleSoft any
13	implementation fees?
14	A   No. They were not our implementation
15	partner.
16	Q   And does it currently pay PeopleSoft,
17	does Kerr-McGee currently pay PeopleSoft any
18	maintenance fees?
19	A   Yes.
20	Q   And how much does it pay in maintenance
21	fees?
22	A   This year it will be approximately
23	360,000,I believe, this year.
24	Q   Do you know what it has been in previous
25	years since the implementation?

00048
1	A   Yes.
2	Q   What has it been?
3	A   The first year was 300,000, succeeding
4	year was around 330 and then I believe about 345.
5	Q   That brings us to this year, which was
6	360?
7	A   Uh-huh.
8	Q   What version of the PeopleSoftHR
9	software does Kerr-McGee use?
10	A   Is there a specific module that you're
11	asking about?
12	Q   I guess we should back up. Which modules
13	were licensed?
14	A   We have HR, we have time and attendance,
15	we have licensed payroll, benefits
16	administration, data warehouse. There are three
17	analytic suites that we have licensed, Workforce
18	Analytics, Score Card and Rewards. In case I'm
19	missing any of these there's a document in our
20	material that reflects all of them. Employee and
21	manager self service and a variety of E modules
22	such as compensation, recruiting, compensation
23	manager, E pay.

00049
10	Q   In which languages does Kerr-McGee
11	operate the PeopleSoft HR software?
12	A   Currently English, German and Dutch.
13	Q   And do you have any plans to operate it
14	in any additional languages?
15	A   Not at the moment.
16	Q   And in which currencies, if there are any
17	foreign currencies involved, does Kerr-McGee
18	operate the PeopleSoft HR software?
19	A   Foreign is highly dependent on where you
20	are, but if you're talking non U.S. currencies --
21	Q   Non U.S., yes.
22	A   Yes. We -- I'm sorry, we also use
23	French. For -- we use the pound in the UK, we
24	use the euro, we also use the Swiss frank, we
25	also have a Canadian dollar. And I believe

00050
1	that's it. I think the rest of our folks are ex
2	pats, and so it would be the U.S. dollar.
3	Q   Are these foreign currencies that you
4	named, are those currencies in which employees
5	are being paid?
6	A   Yes.

00051
8	Q   Is there any other human resources
9	management software that Kerr-McGee uses?
10	A    No. We have one global instance.
11	Q   Do you use any software from any of the
12	following vendors? And I'm going to go down the
13	list. Do you use any software from SAP?
14	A   Kerr-McGee does not. We contract for
15	payroll processing in Germany with a company who
16	does.
17	Q   What do you mean when you say you
18	contract for payroll processing?
19	A   We pay a fee each year for a company to
20	produce payroll checks for us in Germany.
21	Q   Is that similar to outsourcing payroll?
22	A   It's outsourcing the production of
23	checks.
24	Q   But would you consider it outsourcing of
25	the payroll function?

00052
1	A   No.
2	Q   Just the check process?
3	A   We take care of the function, they
4	produce the checks. It's not BPO.
14	Q   Do you use Hyperion?
15	A   I believe we do for some financial
16	planning, but I am not 100 percent certain.

00053
7	Q   And do you use any software from ADP
8	aside from the payroll processing in Germany?
9	A   We outsource payroll, check production to
10	ADP in the United States. And there is a piece
11	of software that lives at our site that enables
12	that to happen.
13	Q   Do you outsource any other part of the
14	payroll function aside from check processing?
15	A   ADP handles production of checks, direct
16	deposits, tax filing. Other than that we do all
17	of the process work ourselves.

00054
8	Q.   (By Ms. McKinney) I'd like to ask you
9	now about the process through which you selected
10	PeopleSoft for HR software.
11	A   Okay.
12	Q   When did that process begin?
13	A   The actual selection process began
14	shortly after my arrival at Kerr-McGee, which
15	would be June 2001.
16	Q   And who was the primary person
17	responsible for the selection of new HR
18	management software?
19	A   The lead person would have been Lynda
20	Garcia.

00055
1	Q   Is she still with Kerr-McGee?
2	A   She is.
3	Q   Do you know what her title is now?
4	A   I do not. She's in the finance
5	organization.
11	Q   And do you know if Ms. Garcia was the
12	person who managed the project on a day to day
13	basis?
14	A   The selection project?
15	Q   Yes.
16	A   She was, she was our lead person on the
17	Kerr-McGee side.
18	Q   Did she have any title associated with
19	the selection process such as project manager or
20	something similar?
21	A   Not that I'm aware of.
22	Q   And what was your involvement in the
23	selection process?
24	A   I was the I think technical lead was the
25	official title.

00056
1	Q   And what did that mean in practical
2	terms?
3	A   Practical terms, I managed our group of
4	individuals from the IT side that participated in
5	the selection process. I also participated in
6	day to day activities such as question formation,
7	reviewing demonstrations, doing research if
8	required.

00057
8	Q.   (By Ms. McKinney) And what do you
9	recognize this document to be? And let me just
10	say for the record, this document appears to be a
11	Power Point, on the front it's entitled
12	Kerr-McGee HR Financial Analysis, Employee
13	Service Center and HRIS dated September 2001 and
14	Bates labeled Kerr-McGee 008 through 040.
15	Mr. Elliott, what do you recognize this
16	document to be?
17	A   This document is a summarization of the
18	HR strategy that our HR organization was pursuing
19	in 2001.

00058
24	Q   The first one says project consultants,
25	Scott, Madden & Associates. And who was Scott,

00059
1	Madden & Associates?
2	A   An HR consulting firm.
3	Q   And what was their role on the HR
4	software selection process?
5	A   It's described well here. They were
6	facilitators for the process.
7	Q   And what did they do as facilitators?
8	A   A facilitator, possibly coordinator is an
9	equally good term. They organized the work
10	products, facilitated discussions, facilitated
11	planning, were responsible for not only the HRIS
12	side but integrating it into the larger HR
13	strategy that this document represents. And that
14	was their sole involvement. As it states here,
15	they do not have or at least did not have at that
16	time an HRIS implementation practice.

00060
2	Q   Why did you feel it was necessary to
3	engage a consultant to assist in this process?
4	A   I can't answer for Lynda.
5	Q   Was it Lynda who made the decision to
6	engage Scott, Madden?
7	A   It was the HR organization as a whole and
8	Lynda was our point person.
9	Q   And who was the main point person for
10	working with Scott, Madden?
11	A   Lynda and I were both part of the, quote
12	unquote, project office, but Lynda was our point
13	person on the project within.
14	Q   Do you know how much Kerr-McGee paid
15	Scott, Madden for its consulting services?
16	A   I do not.
17	Q   Would Lynda know?
18	A   It's been a while. You'd have to ask
19	her.
25	Q.   (By Ms. McKinney) Now, next on this

00061
1	list it says HRIS project office.
2	A   Uh-huh.
3	Q   Do you know what that term means?
4	A   I know what it means with regards to our
5	selection process.
6	Q   Sure. What was the HRIS project office?
7	A   Would you like me to read it straight off
8	the document?
9	Q   No. I would like to know, you know, what
10	you know. If the document helps to refresh your
11	recollection, that's fine, but I'd like you to,
12	you know, testify based on your knowledge.
13	A   My view of the HRIS project office, the
14	responsibilities again are listed here
15	specifically. We as a group were responsible for
16	coordinating, well, the execution of the project,
17	obtaining resources, doing the visits as we
18	discussed. There were a lot of discussions
19	regarding what questions would be asked, what
20	weighting would be assigned to each one of the
21	criteria, how the RFPs or RFIs would look after
22	they were issued and we were facilitators,
23	coordinators on all those. My personal main task
24	was to coordinate the technical resources
25	involved.

00062
1	Q   Were you a part of the HRIS project
2	office?
3	A   Yes.
4	Q   Who else was a part of the HRIS project
5	office, do you know who made up that group?
6	A   Lynda Garcia was the main person and
7	officially we included Scott, Madden as a part of
8	the project office.
25	Q   And then these boxes here on Page 7, you

00063
1	said these are all people who participated in the
2	process?
3	A   Yes.
4	Q   Anda are these all groups that would be
5	end users of the software?
6	A   Yeah.
11	Q.   (By Ms. McKinney) How were these people
12	selected to participate in the selection process?
15	THE WITNESS: I don't recall the exact
16	process we went through to choose the folks. The
17	goal was to have people representing as many
18	different areas in the HR organization as we
19	could and plus involve technical people in from
20	several of our major areas as well.
21	Q.   (By Ms. McKinney) Who selected these
22	people who were participants in the software
23	selection process?
24	A   I'll go back to my previous answer. I
25	don't know the exact details of how we selected

00064
1	these people. As I look through here it was I
2	believe my recommendations on the technical side
3	to say these are the people that need to
4	participate based on their areas of expertise.
5	Q   And was Lynda Garcia responsible for
6	selecting the other people involved here?
7	A   I'll say again, I don't know the details
8	of how they were selected.
9	Q   But you selected the people listed in
10	this box labeled technical who are here under
11	your name?
12	A   Yes.
13	Q   And are those the people you referred to
14	earlier who you were responsible for managing
15	throughout the selection process?
16	A   For this process, yes.
17	Q   Were you responsible for managing anyone
18	else on this chart?
19	A   No.
20	Q   Was Lynda Garcia responsible for
21	coordinating the other people in these other
22	boxes on this page?
23	A    Yes. She served as the functional lead,
24	if you will.

00065
24	Q   Can you tell me what, what the role of
25	subject matter experts was in this process?

00066
1	A   As I recall, basically the document says
2	input and guidance. Many of these folks would be
3	consumers of, as I recall, some of the services
4	within the HRIS.
12	Q   Did the -- did the technical team that
13	you were responsible for managing meet on a
14	regular basis throughout the selection process?
15	A    Yes. We had scheduled meetings plus as
16	needed meetings depending on what was happening
17	in the process.
18	Q   Let me back up just a second. How long
19	did the selection process take in total?
20	A   We started this in June of 2001, the
21	contract was signed I believe at the end of
22	October 2001.
23	Q   And how frequently did the technical team
24	meet during that time?
25	A   I don't think there was any standard

00067
1	number of meetings we had on a weekly basis.
2	Q   So you didn't have some kind of regular
3	set time for meeting?
4	A   No. There was -- as I recall, there were
5	group meetings where the entire group met
6	together.
7	Q   Would that have been the entire --
8	A   Core selection team.
9	Q   -- core selection team?
10	Including your technical team?
11	A   Yeah.
12	Q   And how frequently were those meetings?
13	A   I think it depended on where we were in
14	the process. I can't recall the exact schedule.
15	Q   Could you estimate the total number of
16	times that the HRIS core selection team met over
17	the course of the selection process?
18	MR. GORESEN: I'm going to object to the
19	extent it calls for speculation.
20	THE WITNESS: Anything I gave you would
21	be a guess.

00068
5	Q   And with regard to your technical team,
6	can you estimate how many times your technical
7	team met on its own throughout the entire
8	selection process?
9	A   As an estimate, we were visiting maybe
10	not in total but at least, you know, two or more
11	weekly basis. We did not have a set time where
12	we got together as an entire team, only as
13	needed.
	Q   I'm not going to ask any more questions

00069
1	on this document for a little bit.
2	What were the main responsibilities of
3	your technical team in this process?
4	A   To review, to the extent we could, the
5	technical soundness of the proposed solutions.
23	Q   Do you know if any presentation was ever
24	made to the CEO or other executives regarding the
25	selection of PeopleSoft?

00070
1	A   I believe there was.
2	Q   And were you part of that presentation?
3	A   No.
4	Q   Who did that presentation?
5	A   I believe Lynda did.
6	Q   Do you know when that was?
7	A   I do not know the exact date. My surmise
8	would be either late September or early October.
9	Q   Did you work with Lynda at all in
10	preparing that presentation?
11	A   Scott, Madden was again the main
12	facilitator for producing documents, but I did
13	participate with Lynda as well.

00072
3	Q   In addition to Scott, Madden, did you
4	consult with any other outside resources as part
5	of the selection process?
6	A   One would have been Gartner.
7	Q   And what was your interaction with
8	Gartner Group?
9	A    We asked the question who would be their
10	I believe the term is magic quadrant vendors with
11	regards to the HR space.
12	Q   And what did they tell you?
13	A   PeopleSoft, Oracle, SAP, Lawson.

00073

13	Q   And did you personally have contact with
14	someone at Gartner Group?
15	A   I did not.
16	Q   Do you know who did?
17	A   I believe Lynda.
18	Q   And do you know if she met with them in
19	person?
20	A   I do not know for sure.
21	Q   Do you know if she had personal contact
22	with them at all?
23	A    Yes. I know for a fact there was
24	definitely a phone visit. At that time we had a
25	subscription to their services, so I don't know

00074
1	if there was anything else involved.
2	Q   Do you know if they provided Kerr-McGee
3	with any written research report?
4	A   I don't know. Ours was a fairly simple
5	and straightforward question.
6	Q   So you never saw some written research
7	report from Gartner Group?
8	A   No.
9	Q   So the information that came from Gartner
10	Group you got through Lynda Garcia?
11	A   Yes.
24	Q   At what stage did you make reference
25	calls?

00075
1	A   After, I believe, the field had been
2	narrowed to PeopleSoft and Oracle.
3	Q   So you didn't call any references for
4	Lawson or SAP?
5	A   None.
25	Q.   (By Ms. McKinney) Do you consider

00076
1	yourself to be a sophisticated customer of EAS
2	software?
3	MR. GOREEN: I'm going to ask for -- are
4	you asking if Scott Elliott considers himself to
5	be a sophisticated customer?
6	MS. McKINNEY: Yes.
7	THE WITNESS: When it comes to
8	Kerr-McGee's needs, yes.
9	Q.   (By Ms. McKinney) Could you describe
10	for me the main steps in the process of selecting
11	the PeopleSoft HR software, if you know?
12	A    You have the documents that describe all
13	of them. At a high level, again, based on
14	Gartner's recommendations, we identified four
15	companies that we felt like we should pursue.
16	All four companies were contacted to let them
17	know that we were actively engaged in a selection
18	process. PeopleSoft, Oracle and Lawson
19	responded. SAP did not. The request for
20	information and detailed questions were
21	developed, sent out and received back from those
22	three vendors. We had on site demonstrations at
23	Kerr-McGee from those three vendors. The RFI
24	responses and the presentations were graded by
25	the HRIS selection team. Lawson was eliminated

00077
1	based on that grading. PeopleSoft and Oracle
2	returned for additional demonstration. Two
3	visits were made, one to Oracle headquarters, one
4	to a PeopleSoft executive gathering. Reference
5	calls were made. The team made the
6	recommendation to upper management and they
7	approved.
12	Q   Were there any other factors that went
13	into developing that list of what four vendors
14	Kerr-McGee would consider?
15	A   Yeah, there were two other vendors
16	that -- I'm not sure, I can't remember the exact
17	nature of the research we did, but Baan and J.D.
18	Edwards were both considered in addition to those
19	four folks. Based on what we could determine, I
20	would think primarily from J.D. Edwards website,
21	it looked like they lacked the international
22	functionality that we thought we needed. Baan
23	was in serious financial difficulty prior to
24	their acquisition by SSI.

00078
18	Q   And then you mentioned that all four of
19	the vendors on your list, Oracle, PeopleSoft, SAP
20	and Lawson, were contacted?
21	A   Correct.
22	Q   In what way were they contacted by
23	Kerr-McGee?
24	A   I believe Lynda Garcia phoned each one of
25	them personally.

00079
1	Q   And do you know about what time frame
2	this was in?
3	A   It would have been in June, I believe.
4	Q   And were you on any of those phonecalls
5	that Lynda Garcia made?
6	A   No.
7	Q   Do you know the nature of the phonecalls
8	or what she said to them?
9	A   Back to my previous, previous answer. It
10	would have been that we were actively engaged in
11	an HR selection process and we were contacting
12	them to solicit their participation and to also
13	find out where we should send our request for
14	information.
15	Q   At the time that she called each of those
16	four, do you know if Kerr-McGee intended to send
17	each of those four vendors an RFI?
18	A   I believe that was our intent.
19	Q   And did she ask for any response from
20	them during those phone conversations? That is,
21	was she seeking any response from them prior to
22	sending the RFI?
23	MR. GORESEN: I'm going to object to the

00080
3	A To the best of my knowledge it was to
4	whom and where should we send the RFIs.
5	Q And you said that three responded?
6	A Yeah.
7	Q And which three were those?
8	A PeopleSoft, Oracle and Lawson.
9	Q And SAP did not respond?
10	A   Correct.
11	Q   And what does that mean?
17	Q.   (By Ms. McKinney) Does that mean -- did
18	Lynda talk to anyone at SAP?
19	A   I do not know specifically who she would
20	have talked to. They did not provide the
21	information which was who should we send the RFI
22	to and to where should it be sent.
23	Q   Do you know if she, if she was able to
24	get anyone on the phone and speak with them?
25	A   I do not know.

00081
1	Q   Do you know who she tried to call at SAP?
2	A   No.
3	Q   Do you know if she left a voice-mail with
4	anyone at SAP?
5	A   I wasn't in on the call. I don't know if
6	she talked to a person or left a voice-mail.
7	Q   Do you know if she ever sent any written
8	communications to SAP?
9	A   Not that I'm aware of.
10	Q   Do you know if she made any subsequent
11	attempts to contact SAP either by phone or
12	through written communications?
13	A   I believe there was more than one
14	attempt. I don't know how many.
15	Q   Do you know how long of a time period she
16	spent trying to get in touch with SAP?
17	A  &n