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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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