United Parcel Service of America - Page 81




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                    Q.   You're not aware -- you did not discuss it with              
               any state regulators.                                                  
                    A.   No, I didn't.                                                
                    Q.   Either insurance or transportation.                          
                    A.   That's correct.                                              
                    Q.   And you're not aware of anybody at UPS discussing            
               it with any state regulators, insurance or transportation.             
                    A.   No, I'm not.                                                 
                    Q.   Throughout the entire time that UPS was                      
               considering revising the excess value program, it never                
               obtained a legal -- a written legal opinion relating to                
               whether the excess value activity could be construed as                
               insurance.                                                             
                    A.   I did not.                                                   
                    Q.   And you're not aware of UPS doing it.                        
                    A.   No, I'm not.                                                 
                    Q.   And you never -- UPS never prepared an opinion of            
               even in-house counsel relating to whether the activity --              
               its excess value activity could be construed as insurance.             
                    A.   Not that I'm aware of.                                       
                    Q.   Pardon me?  I didn't hear you.                               
                    A.   I said -- I'm sorry -- not that I'm aware of.  I             
               did not request one.                                                   
                    Q.   Even after you became concerned and started with             
               the negotiations, you didn't ask for an opinion, a legal               
               opinion.                                                               
                    A.   No.                                                          
                    Q.   Okay.  You indicated yesterday you were concerned            
               about the Avis and Hertz collision damage waiver cases.                
                    A.   And liability insurance.                                     





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