Ninth Circuit Case Madhuri Trivedi v. DHS 17-15217

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Case: 17-15217, 03/04/2017, ID: 10343298, DktEntry: 17-1, Page 1 of 205
WITNESS: WILLIAM BARBIAUX 3/4/14
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In the matter of the Arbitration between:
MADHURI TRIVEDI
Claimant,
and Case No. 51 160 0126013
GE HEALTHCARE
Respondent.
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Deposition of
WILLIAM BARBIAUX
Tuesday, March 4, 2014
2:00 p.m.
At
1405 Rockridge Road
Waukesha, WI 53188
Reported by Beth Zimmermann, RPR
1
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APPEARANCES
MADHURI TRIVEDI, 1405 Rockridge Road, Waukesha, WI 53188

Appearing pro se.
QUARLES & BRADY, By Sean M. Scullen, Attorney at Law, 411

East Wisconsin Avenue, Ste. 2040, Milwaukee, WI 53202,
appearing on behalf of GE Healthcare.
EXHIBIT INDEX
Ex. No. Description Page
1 12/8/11 Trivedi E-mail Re: Insite ExC

Agent Testing 39
2 3/8/12 Trivedi E-mail Re: Network
Packet Analyzer
3 3/28/13 E-mail Re: Enterprise UI 80
4 1/17/13 Trivedi E-mail Re: Tasks 80
5 1/17/13 E-mail Re: RSVP Prototypes 80
6 4/25/12 E-mail Re: Package Analyzer Info 80
7 2/20/12 E-mail Re: HeliOS Machine 80
8 2/1/12 E-mail Re: Tasklist Discussed 100
9 6/11/12 E-mail Re: Memory Error Stopping 101
10 1/4/13 E-mail Re: UX Experience Meeting
Notes 121
11 6/11/12 E-mail Re: Memory Error Stopping 121
12 3/9/12 E-mail Re: Localhost 127
13 8/20/12 E-mail to Dave Mehring Re:
Failing NW Connectivity 127
14 8/20/12 E-mail to Carl Conrath Re:
Failing NW Connectivity 130
15 1/31/13 Barbiaux E-mail Re: SupportCentral
Case Comment 134
(ORIGINAL EXHIBITS ATTACHED. EXHIBITS 3-7 AND

EXHIBITS 10 & 11 WERE NOT IDENTIFIED IN THE
RECORD.)
EXAMINATION INDEX
Page
BY MS. TRIVEDI 3
2
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1 WILLIAM BARBIAUX being first duly
2 sworn on oath to tell the truth, the whole
3 truth, and nothing but the truth, was examined
4 and testified as follows:
5 EXAMINATION BY MS. TRIVEDI:
6 Q So have you given deposition before?
7 A No.
8 Q Did you get any deposition coaching?
9 A Depends what you mean by coaching; but, no. I
10 think I talked with Sean for about an hour,
11 but it was all around the process, like, Here
12 is what will happen, there will be a reporter
13 and questions, and answer the questions
14 honestly. So it was all of the basic what's
15 going to happen.
16 Q Would you be concerned about your job future
17 with GE if you tell the truth and if it's
18 against management or if it's exposing certain
19 things?
20 A No.
21 Q Did I treat you with respect when I was with
22 GE?
23 A Yes.
24 Q You had good working relationship with me,
25 right?
3
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1 A Yep.
2 Q Things went well, without difficulties in
3 working with two of us?
4 A Yeah, for the most part. We didn't have a
5 direct assignment together, but we worked --
6 We worked near each other, so --
7 Q You worked with me on Insite ExC Surgery
8 Integration --
9 A Right. I helped with some of it, yeah.
10 MR. SCULLEN: Just wait because the
11 court reporter can only take down one person
12 at a time.
13 MS. TRIVEDI: This is off the
14 record.
15 (Off the record discussion.)
16 BY MS. TRIVEDI:
17 Q So you and I worked -- as we spoke, you and I
18 worked on Insite ExC Surgery Integration. You
19 helped me, you said?
20 A Yes.
21 Q How long have you worked with GST?
22 A GST? Since before it was GST, so from 1993
23 until now, so that's --
24 Q That's fine. How long have you known Dave
25 Mehring?
4
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1 A Probably 15 to 20 years, most of the time in
2 GST.
3 Q How long have you known Greg Stratton?
4 A For 25 years.
5 Q And Nate Davis?
6 A Probably 14 years, somewhere in there.
7 Q And Sachin Kendale?
8 A Probably two years. I don't know exactly.
9 Q And how about Alan Kuhn?
10 A I think close to 20 years.
11 Q And Greg Jacobs?
12 A However long he's been at GE, but I don't know
13 how many years that is.
14 Q Two, three years?
15 A Something like that, yeah.
16 Q You were in part of the Insite ExC core team,
17 as well as RSVP GEIP core team?
18 A Insite ExC core team, is that what you said?
19 Q Um-hum.
20 A The Enterprise piece, not necessarily -- not
21 the Agent piece. It's in two halves,
22 Back-Office and the Agent. So I was more
23 involved in the Back-Office.
24 Q And you were in GEIP RSVP core team?
25 A For part of the time, yeah.
5
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1 Q What does that mean "for part of the time"?
2 A Well, because I'm a principal engineer, I
3 don't work on the details of the project as
4 it's being implemented as you. I'm working
5 early in the project, and then I move on to
6 the next project, the early phases.
7 So I only work the early phases of GEIP.
8 So I was familiar with it, but I wasn't
9 day-to-day in all of the core team meetings.
10 Q Once in awhile -- you go in once in awhile?
11 A Right.
12 Q What is the main technology used within GST?
13 Is it Java J2EE?
14 A Probably. That's the main software
15 programming language, but we have a lot of
16 technologies.
17 Q But it's -- GST is a Java shop heavily, not
18 Microsoft shop, right?
19 A Right.
20 Q Was Windows Communication Foundation, WCF,
21 it's also called SOA from Microsoft, ever used
22 at GST prior to RSVP GEIP project?
23 A I don't know. I don't do a lot of software
24 work, pure software, so I don't know.
25 Q Do you know if any web services were used?
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1 A Used on what?
2 Q On Insite ExC or -- Not Insite ExC, because --
3 MS. TRIVEDI: Take off the record.
4 (Off the record discussion)
5 MS. TRIVEDI: Now you can put on the
6 record.
7 MR. SCULLEN: I'm going to object as
8 vague and compound. You can answer if you
9 can.
10 THE WITNESS: I know GST uses web
11 services in several places, but that's --.
12 BY MS. TRIVEDI:
13 Q The current RSVP Axeda project is mainly a
14 Java-based, not Microsoft-based project,
15 right?
16 A Say that one again. I missed the beginning.
17 Q Current RSVP with Axeda, it's heavily Java
18 technology-based project and not
19 Microsoft-based project, right?
20 A I believe that's true. Again, some of these
21 answers are software specific, and I'm not a
22 software engineer. That's not my daily focus.
23 I do more system stuff and network stuff
24 and security stuff, so I'm -- Those are the
25 best of my knowledge, but it may not be
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1 entirely correct.
2 Q You know that FDA halted sales of Surgery OEC
3 after serious quality control lapses were
4 found by FDA audit in 2007?
5 A I don't remember the date; but yes, OEC had --
6 Q And you agree that since I joined November,
7 2011 -- Can we erase that? I'm rephrasing.
8 Insite ExC project that you helped me on
9 was a project for ExC Surgery OEC modality
10 integration. Is that correct?
11 A I don't remember the product it was for. I
12 know the operating system roughly it was for,
13 which is Linux.
14 Q So you don't know the modality with Surgery?
15 A I did not know that, no.
16 Q I mean, it was Surgery, so --
17 MR. SCULLEN: Ms. Trivedi, you are
18 testifying. He's testified he doesn't know.
19 THE WITNESS: I don't know.
20 BY MS. TRIVEDI:
21 Q You don't know or you don't remember?
22 A I don't know. I could find out, but I don't
23 know -- I don't know.
24 Q Did you know at that point?
25 A That it was Surgery? I don't think it
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1 mattered. What was important to me -- I've
2 worked on dozens and dozens of product
3 integration, so I don't remember exactly which
4 integration was on which product because I've
5 been doing this for 20 some years, so -- I
6 don't remember which product exactly it was.
7 Q My point was that all new engineer get
8 training, and OEC halting sales of Surgery --
9 FDA halting sales of Surgery, that's in all
10 quality training. So everybody gets training
11 about that. And my first project was about
12 Surgery. So that's why I'm trying to --
13 MR. SCULLEN: I'm going to object
14 because you're not asking a question. You're
15 making a statement.
16 Q So if you can -- That's why I'm saying if --
17 That's fine.
18 MR. SCULLEN: Asked and answered.
19 A I don't know.
20 Q Do you know that in April, 2012, or so GST
21 leadership was mainly looking for adding more
22 people, body counting, RSVP GEIP project in
23 order to meet project workload?
24 A I don't remember the timeframe. You said
25 April, 2012. I don't remember exactly when.
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1 I know at various times on the project we've
2 had to add people to meet the workload, but I
3 don't remember if that was one of those times.
4 Q What was your involvement -- You said system.
5 Wasn't your involvement in RSVP GEIP project?
6 A In the GEIP portion of it?
7 Q Um-hum.
8 A Principal engineer, so early -- setting some
9 early direction and sort of not really
10 requirements, not enough detail, but direction
11 for the project. Early direction with several
12 other people.
13 Q So were you involved in the decision making
14 process to break up with GEIP?
15 A Somewhat, yeah, along with other people.
16 Q Do you have any -- What would be your comment
17 about the reasons and the -- the status of
18 RSVP GEIP project when we broke up?
19 A The status at the time we --
20 Q Right, in terms of GST.
21 A -- stopped working with GEIP? The project was
22 probably a little bit behind, but it was
23 nearing their first release, or something like
24 that. I don't remember the exact details.
25 And the main reason we stopped and
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1 changed direction there was because our
2 existing Insite ExC Enterprise, our
3 Back-Office, was having difficulty. We knew
4 that we needed to replace it sometime in the
5 next couple years because of the load and the
6 age of the servers and the software and
7 things, we couldn't upgrade it.
8 So GEIP was not at a point where they
9 would handle connections from our existing
10 install base of ExC systems or Questra
11 products. So GEIP could not handle our
12 install base. And that was a more immediate
13 priority, supporting our install base and
14 replacing Questra, than developing the future
15 product, which was RSVP. I could talk about
16 that for weeks, but that's the gist.
17 Q You did fine. So why GEIP was not able to
18 support existing install base, or why it was
19 not considered a goal and objective two years
20 before when the RSVP project was kicked off in
21 2010, 2011? Why this --
22 Was that part of a goal and objective to
23 have existing install base support?
24 A It was discussed, and it was on their roadmap
25 pretty far out, and it took longer than
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1 expected to get to where we were at the time
2 we terminated that relationship.
3 And in the meantime, from when we started
4 with GEIP until we stopped, it became clear
5 that the load on the Questra Back-Office, it
6 was deteriorating faster than we had thought.
7 So GEIP wasn't scheduled to be able to help
8 with that for another two or three years. We
9 needed a quicker solution.
10 Q So in 2010, 2011, the point was, Okay, let's
11 work with GEIP and develop next generation
12 software and then work on supporting existing
13 installment, and then, on the line, developing
14 new software delayed lot more than
15 anticipated, and then the next goal, which was
16 to support existing install base, got further
17 kicked out. And in the meantime, the existing
18 install base was kind of having problems?
19 MR. SCULLEN: Objection,
20 misstates -- vague and misstates his
21 testimony.
22 THE WITNESS: I couldn't keep up.
23 Q I was trying to redirect what you just said.
24 A I couldn't follow what you said, so I wasn't
25 sure.
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1 MS. TRIVEDI: Can we take off the
2 record?
4 MR. SCULLEN: You need to stay on
5 the record if you're going to ask him
6 questions.
7 MS. TRIVEDI: That's fine. We can
8 move to next step.
9 Q So what was the plan in terms of replacing old
10 Back-Office?
11 MR. SCULLEN: Object as to vague as
12 to time.
13 MS. TRIVEDI: Plan asked --
14 MR. SCULLEN: But plans evolve over
15 time. You're asking about at what point in
16 time?
17 BY MS. TRIVEDI:
18 Q Okay. So does it include replacing existing
19 Back-Office and existing Agent, or --
20 MS. TRIVEDI: Same objection. What
21 period of time are you talking about?
22 THE WITNESS: Period of time and
23 specifically which Back-Office? We have lots
24 of Back-Offices.
25 MS. TRIVEDI: Insite ExC --
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1 THE WITNESS: Because we were
2 talking GEIP and RSVP, and I'm not sure --
3 BY MS. TRIVEDI:
4 Q There is only --
5 A If you can be specific, please.
6 Q In terms of Insite ExC, what is the plan --
7 what was the plan when I was there to replace
8 existing Insite ExC Back-Office and existing
9 Insite ExC Agent, or only one of them?
10 MR. SCULLEN: Same objection with
11 the time. You were there for a year. What
12 period of time -- What specific date and time?
13 MS. TRIVEDI: Year and a half. I was
14 there for a year and a half.
15 MR. SCULLEN: Okay, year and a half,
16 so that's too long a period of time.
17 BY MS. TRIVEDI:
18 Q Currently when we were on RSVP GEIP project,
19 and I also worked on RSVP Axeda project, so I
20 want to know overall GST plan, does it include
21 replacing existing ExC Back-Office, existing
22 Agent or one of them?
23 MR. SCULLEN: Again, same objection.
24 What time are you talking about?
25 MS. TRIVEDI: Last year, 2012, 2013.
14
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1 MR. SCULLEN: Same objection, but
2 you can testify.
3 A I can give it a shot and see. The plans, like
4 you said, change over time. There are always
5 different plans. We know we have to -- We
6 knew then -- we had to replace the ExC
7 Back-Office. And we know we, also, have to
8 not replace the install base of ExC Agents but
9 have a new Agent going forward, because we can
10 no longer get ExC Agents on new operating
11 system ports. We have to get them from the
12 company that makes them, and the company no
13 longer makes them. Axeda, the company.
14 So we know their Axeda Back-Office will
15 replace the Questra Back-Office, ExC
16 Back-Office, and we know we need replacements
17 for our future product Agents. We can't
18 replace the install base. We won't replace
19 the install base.
20 So your question -- I don't know if that
21 really answered it, but --
22 Q So in terms of RSVP GEIP --
23 A Okay.
24 Q -- GST team worked for about two years. And
25 do you think in terms of what GE Healthcare
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1 needed, was it delivered at the end? Because
2 I have a request of interrogation response,
3 and they said the project never failed, so --
4 In terms of GE Healthcare criteria, do
5 you think that the RSVP GEIP project failed in
6 terms of what GE Healthcare needed?
7 MR. SCULLEN: Object as to vague.
8 Go ahead and answer if you can.
9 A There were several phases to the GEIP project,
10 and the first -- I mean, the project was
11 delayed, but we never even took delivery of a
12 first official release.
13 So did it fail? I don't know. It was a
14 project that was going to go on for years,
15 so --. I'm not sure how to answer the
16 question.
17 Q So I had my goal and objective that I picked
18 up from Carl Conrath, goals and objective, and
19 his goal was to release RSVP project by
20 sometime 2012. So that was goal, and so
21 that's what I had, because I mentioned I'm
22 copying it from Carl, who is a manager.
23 So my point was, in terms of -- I
24 explained yesterday that she ordered size 15
25 and I ordered size 10. The project was
16
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1 working for GE Energy where they had 300
2 transformers, but the RSVP was not able to
3 support 60,000 devices.
4 So in terms of criteria, other than
5 delay, it didn't meet the criteria, so the
6 project -- GST managers and engineers and core
7 team members were responsible for high level
8 design requirement and delegate those to
9 engineers who work on low level, do you think
10 that there was -- there should be some
11 accountability and responsibility in terms of
12 not having a working software after two years?
14 to vague, compound, and his personal views are
15 totally irrelevant, but -- And it also assumes
16 there was an accountability to the extent
17 that --
18 MS. TRIVEDI: There isn't. That's
19 why I'm asking.
20 A I'm not sure how to answer that. I'm not sure
21 what the question was.
22 Q Do you think Dave Mehring, Nate Davis and Greg
23 Stratton -- I don't know your level of
24 accountability or role in RSVP project, but do
25 you think those three individuals should be
17
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1 held accountable and responsible for not
2 having a working software after two years?
3 A I would say no. There are lots of factors in
4 any project. And if by "accountable" you mean
5 they're responsible for the failure of the
6 project, which I don't think it failed --
7 We went one direction and we changed
8 direction as circumstances changed, which is
9 what we always do -- So, no. So I don't think
10 they are -- I don't remember the exact wording
11 of the question.
12 Q Accountability and responsibility.
13 A They have accountability for their own work,
14 but they're not doing all of the work on the
15 project.
16 Q So even though Carl's goal was to deliver
17 RSVP --
18 A Um-hum.
19 Q -- and that goal was never met, do you think
20 that -- So when an engineering manager and
21 team fails, there is nobody gets
22 accountable -- You said that -- Okay.
23 After two years you don't have a working
24 product, and you said that's not a failure and
25 nobody is held accountable?
18
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1 MR. SCULLEN: That's not what he
2 said, Ms. Trivedi.
3 A No. I said that circumstances change. No one
4 person or three people are responsible for an
5 entire project or can be held accountable for
6 things outside of their control.
7 It was a big project. Things change. We
8 don't always meet every goal. GE has, you
9 know, all kinds of goals. Many we meet, many
10 we don't.
11 Q So then there is no performance -- So people
12 are treated differently when they don't meet
13 goal based on their position and relationship
14 with others?
16 mischaracterizes his testimony. And his
17 personal views on this are irrelevant. He's
18 not a manager.
19 MS. TRIVEDI: He's a principal
20 engineer with 30 years experience. His input
21 matters.
22 MR. SCULLEN: He's not a manager.
23 He wasn't a manager. Ms. Trivedi, let me note
24 this for the record. He's not a manager. He
25 wasn't your manager. This line of questioning
19
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1 is totally irrelevant. You've gone on --
2 MS. TRIVEDI: No. He has provided
3 he was --
4 MR. SCULLEN: He's not a manager.
5 MS. TRIVEDI: That's not -- You can
6 not object things when I need information.
7 MR. SCULLEN: Well, I've let you
8 go -- I mean, if you want to continue these
9 depositions long beyond when we need to be
10 here and incur additional cost and creating
11 long transcripts --
12 MS. TRIVEDI: I'm looking for the
13 truth.
14 MR. SCULLEN: Just let me make my
15 record.
16 MS. TRIVEDI: You can take this off.
17 MR. SCULLEN: No, I want it on the
18 record for the arbitrator in case we need to
19 involve him. He's answered the question, and
20 you don't like the answer. But at the end of
21 the day, ultimately this entire line of
22 inquiry is irrelevant.
23 MS. TRIVEDI: It's not irrelevant.
24 You don't want your witness to give me
25 information that will help my case and want to
20
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1 protect GE Healthcare from their misdoing.
2 MR. SCULLEN: I haven't stopped you
3 from --
4 MS. TRIVEDI: And they are being
5 trained to speak certain way because otherwise
6 their jobs will be at stake. I know when he
7 was helping me during level two and three,
8 Dave Mehring stopped by and asked him two,
9 three times, Did you talk with Madhuri. So, I
10 mean, I know that job is definitely at stake.
11 MR. SCULLEN: He's already testified
12 that's not the case.
13 MS. TRIVEDI: So why are you not
14 letting me get information?
15 MR. SCULLEN: I am. But you're
16 asking him the same question over and over
17 again. He's given you an answer you don't
18 like, so you keep asking the question again.
19 And the question -- his personal views on
20 hypothetical questions about managers is
21 irrelevant. Let's move on.
22 BY MS. TRIVEDI:
23 Q So your conclusion was that at times GE
24 Healthcare people doesn't meet goal, and that
25 happens all of the time, as you said, and
21
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1 nobody gets held accountable or responsible?
2 MR. SCULLEN: Objection.
3 A No, that's not what I said.
4 MR. SCULLEN: Mischaracterizes his
5 testimony. Just let me -- I'm just noting --
6 Just so you're clear, I'm making an objection
7 because the form of the question is incorrect.
8 That gives you an opportunity to correct it or
9 not. The witness can still answer. I'm not
10 telling him not to answer, but just let me
11 finish so you're not talking over me so that
12 the court reporter can --
13 MS. TRIVEDI: So this document --
14 MR. SCULLEN: Ms. Trivedi --
15 MS. TRIVEDI: My discovery request
16 had so many lies, perjury, and I have made a
17 list already. And this perjury, lying under
18 oath, it will continue. And no matter if it
19 takes me money, but I need to prove that
20 people are lying. It's series of lie
21 information, just not stating the full
22 information, leaving information, using just,
23 you know, different words. It's just be
24 honest and tell the truth. It shouldn't take
25 this long.
22
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1 MR. SCULLEN: Ms. Trivedi, everyone
2 is doing that. You just don't like the
3 answers. The purpose of a deposition is for
4 you to ask questions and for the witness to
5 answer. Why don't you continue to do that.
6 BY MS. TRIVEDI:
7 Q So rewinding, concluding this your -- I asked
8 Dave Mehring, along with other team members,
9 like Mike Suchecki, Mohieddine -- these three:
10 Dave Mehring, Nate Davis and Greg Stratton
11 were part of the core team. Those were senior
12 individuals and managers. They had certain
13 amount of responsibility, along with others,
14 in the team to deliver this project.
15 The project was not delivered to GE
16 Healthcare, and they are not -- you think that
17 they shouldn't be held accountable and
18 responsible?
20 mischaracterizes his testimony. Misstates
21 evidence and assumes facts not in evidence.
22 You can answer if you can.
23 A I think I already answered --
24 Q No, right? They shouldn't be held
25 accountable?
23
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1 MR. SCULLEN: Let him finish his
2 answer. Stop interrupting the witness.
3 A I think there were lots of circumstances
4 around that project, as any project, and there
5 is no clear place to place the blame. Things
6 changed, and we changed direction over time.
7 Sometimes we don't meet our goals, like I said
8 before. That's not necessarily anyone's
9 fault.
10 Q Do you know that Greg Stratton's performance
11 was negative around September, 2012?
12 A I have no idea.
13 Q And his job was at stake?
14 A I have no idea. I don't know.
15 Q Did you provide any performance evaluation
16 input about Greg Stratton or Nate Davis?
17 A I can't remember. We occasionally -- Or the
18 managers sometimes ask for feedback on peers.
19 Sometimes I fill out the spreadsheet and
20 sometimes I do not, and I don't remember if I
21 did that that year. I don't remember.
22 Q Do you remember about me? Did you fill out
23 mid-year review?
24 A I don't remember.
25 Q Not mid-year, not final?
24
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1 A Yeah, I don't remember.
2 Q Did Dave Mehring send you a sheet to fill out
3 or he didn't?
4 A Dave usually sends a sheet for feedback,
5 spreadsheet of all of the people we might have
6 worked with, and leaves it up to individuals
7 to reply if they want to.
8 Q Did he send that out for me?
9 A I've seen him -- It's not sent out for a
10 person, it's sent out for the group. So when
11 mid-year or end-of-year feedback is requested
12 from managers, they send a spreadsheet with
13 all of the people in the group, and you have
14 the right to respond to any or all or none of
15 those people. So it's not sent out for a
16 specific person.
17 Q Are you aware of continuous conflicts and
18 fights between GE Healthcare and GEIP?
19 A I don't think they were continuous. I was
20 aware that some team members didn't always get
21 along, but it's hard to do working
22 relationships over the phone and things, so --
23 Q So I --
24 A I don't know about specifics.
25 Q So I will remove. You said not continuous.
25
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1 So you agree that there were conflicts and
2 fights?
3 A Like I said, I think there were some
4 difficulties in the working relationship. I
5 don't know that there were fights. I don't
6 know who was involved.
7 Q So there were difficulties in working
8 relationship, as you said. Who were
9 individuals from GE Healthcare side?
10 A I don't know for sure. There were several
11 people working on them, and I just heard this
12 secondhand or thirdhand. I wasn't day-to-day
13 working with both sides.
14 Q So who would be those people at high level, if
15 you have to say? Would there be core team
16 members, all core team members?
17 A Probably core team members, whoever had the
18 most interaction with GEIP personnel.
19 Q So I learned from Mohieddine yesterday, the
20 core team for RSVP was Mohieddine, Mike
21 Suchecki, Dave Mehring, Greg Stratton, Nate
22 Davis, Anish, Subodh and Biju.
23 A Okay.
24 Q And as you said, that there were difficulties
25 in terms of working relationship with GEIP and
26
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1 GE Healthcare.
2 A There were, yeah, disagreements about
3 technical issues, things like that. But I
4 don't know any details. I was not on that
5 core team at that time or knowledgeable about
6 any conversations, so I'd be guessing.
7 Q You used to sit next to Greg, and you don't
8 know he was the LSD? You can hear two aisles
9 away, he was just shouting, so it was
10 pretty --
11 A I sit in the same aisle as Greg, so --
12 Q So it was pretty obvious to people, he was
13 just -- Okay. That's fine.
14 A There is also a TV right next to my desk, so I
15 often hear the television.
16 Q Do you think GEIP was being selfish and
17 looking out for themselves?
18 A I have no idea.
19 Q Another witness told me this, so that's why
20 I'm reaffirming it.
21 Do you have any information about
22 operating mechanism and team dynamics?
23 Compound question -- breaking. Do you have
24 any information about operating mechanism of
25 RSVP project?
27
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1 MR. SCULLEN: Object as vague.
2 A From when?
3 Q From RSVP GEIP project?
4 A Any information about operating mechanisms?
5 Very little. Only from past experience on
6 other projects. So I know they had some
7 regular meetings. I don't know when they were
8 and who was in them and what their operating
9 mechanisms were.
10 Q Would you describe -- Would you confirm that
11 issues existed, such as issues of poor
12 communication and unclear strategy expectation
13 within team?
15 What team and when?
16 Q RSVP team and Insite ExC integration.
17 A Okay, two different teams. So what was the
18 beginning of your question again? Aware of
19 what?
20 Q Issues existed, such as poor communication and
21 unclear strategy, expectation within the team,
22 changing priority and scope?
23 A I don't have any specifics, but projects are
24 often long. Priorities and scope changes
25 several times through a project, and not
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1 everything is always clear. It's hard to have
2 perfect foresight and give people their direct
3 assignments and have them be clear and concise
4 and correct without change over time.
5 So that's true in any project though. I
6 didn't see ExC or RSVP GEIP being any
7 different than any project I worked on for 20
8 some years.
9 Q So who's responsible for providing direction,
10 setting up strategy and sending out clear and
11 concise message?
13 With regard to what?
14 Q Is the engineer responsible for setting up
15 strategy and direction? Is team lead
16 responsible? Is principal engineer
17 responsible, LSD responsible, or manager in
18 this hierarchy --
19 A I would answer yes. I think everyone is
20 responsible for some piece of that. But there
21 is never one person you can point to. It's a
22 group thing.
23 I'm responsible for what a principal
24 engineer does for the team, but that's not
25 everything. Managers are responsible for some
29
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1 things. Functional managers, program
2 managers, LPIs, lead system designers, they're
3 all responsible in different ways.
4 Q So what is the responsibility of a team lead?
5 A I don't know that we have a title "team lead,"
6 but -- So I'm not sure.
7 Q Do you know that Anthony was a team lead,
8 Dipti was a team lead, and Prasad was a team
9 lead?
10 A And so what was the question specifically?
11 Q What's the responsibility of team lead?
12 MR. SCULLEN: In what -- Objection,
13 vague.
14 THE WITNESS: Yeah.
15 Q When they get evaluated, or in terms of their
16 job description, what they are being told
17 about their job description, what they are
18 supposed to do -- Like, as you said, as a
19 principal engineer, you are supposed to do
20 this. So similar to that as team lead, what
21 they are supposed to do?
22 MR. SCULLEN: But Ms. Trivedi, he
23 testified he's not aware of people who are
24 team leads, so I don't think he's competent.
25 MS. TRIVEDI: I gave him name and he
30
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1 knows.
2 MR. SCULLEN: You told him. But
3 then you need to ask him -- He testified he
4 doesn't -- he's not aware of team leads. You
5 need to clarify that with him or ask him
6 specifically about an individual that you've
7 named and what their responsibilities were, if
8 he knows.
9 BY MS. TRIVEDI:
10 Q Okay. So what was the responsibility of
11 Dipti?
12 A I don't fully know.
13 Q Whatever you know.
14 A In general, the development of new Insite ExC
15 Agents at that time, or ports of an Agent to a
16 different product operating system. So as
17 the -- I think she was LSD at the time, lead
18 system designer, she would handle the
19 documentation, a lot of the -- She was
20 responsible for delivering requirements,
21 document and -- design document and test plans
22 and things like that and making sure the
23 execution happened.
24 MS. TRIVEDI: I forgot, audio. Just
25 audio, okay?
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1 Q What was the -- Same about Alan Kuhn.
2 A What was the same? The same question?
3 Q Yes.
4 A I don't know what his role was at the time.
5 Q On Insite ExC?
6 A Right. I don't know exactly what his role
7 was.
8 Q He was LSD?
9 A He might have been. I don't know. I thought
10 Dipti was LSD at that time when you were
11 working on that project.
12 Q She was team lead.
13 A I don't know what a team lead is, because
14 that's not a title we typically have, so -- As
15 far as I know.
16 Q What is the same thing for Greg Stratton and
17 Nate Davis?
18 A What were their roles, their titles?
19 Q Yes, roles or responsibilities, job
20 description responsibility. My role was to do
21 low level design, write code, testing, do
22 FMEA, things like that. So in similar
23 context.
24 A Nate Davis was probably the architect at that
25 time for RSVP and ExC. Greg was also a lead
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1 system designer of part of that project. I
2 don't know which part, if it was the device
3 side or the Back-Office side. It might have
4 been both. It might have only been the device
5 side.
6 Q That's fine. Thank you.
7 A But that was the RSVP portion.
8 Q So you and I worked on Insite ExC Surgery
9 Integration because you were curious about
10 IPv6?
11 A Yes. You had asked for help, and you were
12 having some issues around the Linux port of
13 ExC. And since I sat across from you, I
14 offered to help.
15 Q Do you think around that time Greg Stratton
16 told you not to help me?
17 A I don't think he told me not to help you.
18 Q You were working with me, and given he was an
19 LSD of Insite ExC for a long time, he was not
20 providing me information, and I was brand new
21 to the company. I needed to learn about the
22 product before I do any --
23 And along being new, I needed some
24 information from LSDs and people like Alan
25 Kuhn and Dipti. And Dipti was kind of not
33
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1 giving information. She might have been very
2 busy --
3 MR. SCULLEN: Ms. Trivedi, you're
4 testifying. You're not asking a question.
5 MS. TRIVEDI: I'm trying to --
6 MR. SCULLEN: You need to ask a
7 question.
8 Q So because Curt Gran, who passed away in 2012,
9 we three of us mainly work for the security
10 portion. And Greg told you that you shouldn't
11 be working with me and I should be let
12 alone --
13 MR. SCULLEN: Objection, asked and
14 answered.
15 MS. TRIVEDI: That happened, so --
16 MR. SCULLEN: But you asked him that
17 question, he said no.
18 MS. TRIVEDI: I rephrased just to
19 clarify. I'm rephraseing it.
20 MR. SCULLEN: Right. I'm just
21 saying I object, it's asked and answered, but
22 he can answer again.
23 BY MS. TRIVEDI:
24 Q So what's your answer?
25 A So what was the question again specifically?
34
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1 Q Did Greg tell you or indicate that you -- not
2 indicate -- you directly or indirectly by
3 behavior or by body language in a way that,
4 Don't work -- help Madhuri --
5 A Greg and I did have one conversation about
6 that. We had been working together for a
7 while -- days, weeks, I don't know -- and Greg
8 had heard us talking, because we sit right
9 next to him. And he said not -- He did not
10 say don't get involved. He said you might --
11 something along the lines of if you get
12 involved, you might -- or you should leave
13 that for Dipti and Madhuri to work out in the
14 team. You have to -- They've got to figure
15 out their team dynamics. And if you get
16 involved, it will just drag you into things.
17 So he -- He didn't say don't get involved
18 technically or answer questions. He said
19 there is some team dynamics problems there,
20 they have to sort it out. Let them sort it
21 out.
22 Q So --
23 A So that was my first indication from someone,
24 other than talking to you, that there were
25 issues on that team.
35
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1 Q But it was December, 2012, so I was just
2 20 days old.
3 A Okay.
4 Q And I have an e-mail so I will show you, you
5 can see. And in 20 days, a person cannot be
6 that bad. And person needs at least a few
7 months to learn the product. In 20 months you
8 cannot just expect a person to do, you know --
9 I mean, it's just --
11 testifying.
12 MS. TRIVEDI: I'm just surprised
13 that the things are done at GE --
14 MR. SCULLEN: This is not the
15 opportunity for you to express your surprise
16 or feelings. You're here to take a
17 deposition. This witness is here to answer --
18 MS. TRIVEDI: But he said when he
19 heard, so I'm clarifying things. I'm
20 continuing.
21 MR. SCULLEN: You need to ask a
22 question.
23 MS. TRIVEDI: Okay.
24 Q So I'm just asking that it was my -- I was
25 20 days old, and Dipti and Alan were not
36
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1 providing me product information. I needed to
2 learn, and Greg -- Greg was an LSD, so he
3 was -- Weren't you surprised that Greg was not
4 giving me or letting me learn product or
5 helping me learn the product?
6 MR. SCULLEN: Objection, assumes
7 facts not in evidence. And also
8 mischaracterizes his testimony.
9 MS. TRIVEDI: We had a conversation
10 that he was surprised long time back. He
11 might have forgotten, so that's why I'm trying
12 to have him recall certain things.
13 MR. SCULLEN: Remember, he can
14 answer the question if he --
15 THE WITNESS: Could you ask a
16 question again so I could --
17 BY MS. TRIVEDI:
18 Q So I was 20 days old. And in that period of
19 time, LSD leads, people like Dipti, Alan Kuhn
20 and Greg Stratton were supposed to get me up
21 to speed, give me information about the
22 product procedures and guidelines about GE
23 Healthcare, product integration. They were
24 not providing that.
25 You saw some of that as kind of not right
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1 thing, so that's why you felt that you should
2 work with me. So my question was that those
3 people were kind of not being inclusive.
4 Or is that the way things are done at GE
5 Healthcare, that people don't -- within
6 20 days or so, that people don't -- you leave
7 them alone even after -- within 20 days you
8 leave them alone?
9 A I don't remember when you started, so I don't
10 know that it was 20 days. Some of these --
11 Q I started on November 29th.
12 MR. SCULLEN: Ms. Trivedi, let him
13 finish his answer.
14 A These are dated from earlier in the year, like
15 March, so it's a lot longer than 20 days. So
16 I'm not sure.
17 Q These are December.
18 A Okay.
19 Q I join on November 29th.
20 MR. SCULLEN: Let's stop for a
21 second. If you're asking the witness -- Are
22 you going to mark this as an exhibit?
23 MS. TRIVEDI: Yes. You have all of
24 the --
25 MR. SCULLEN: So that the court
38
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1 reporter will mark it as an exhibit so it's
2 referenced.
3 MS. TRIVEDI: All right. Give her
4 whatever document you want to mark as an
5 exhibit.
6 (Off the record. Short recess taken.)
7 MS. TRIVEDI: You can mark this as
8 an e-mail from Dipti Patel -- e-mail to Dipti
9 Patel on December 8th, 2011.
10 (Exhibit No. 1 marked for identification.)
11 MR. SCULLEN: I don't think you
12 meant to include this. This is a different
13 e-mail.
14 MS. TRIVEDI: Right. So you told me
15 to ask him what --
16 MR. SCULLEN: I'm just saying to --
17 Part of my -- We can go off the record.
19 BY MS. TRIVEDI:
20 Q So what was your experience or knowledge in
21 terms of those individuals providing me
22 information on December, 2011?
23 A Okay. In reading this e-mail, I'm not sure
24 that it's relevant other than a timeframe and
25 you were working on ExC, but --
39
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1 What I remember from that time is that
2 Greg did not offer and Al did not offer to
3 help you. Curt and I offered to help. But
4 numerous times during the time we would help,
5 you had questions along the lines of, Well,
6 I'm not sure what to do. This test fails,
7 what do I do? And I said, It depends what
8 your assignment is. Are you supposed to fix
9 the test plan or are you supposed to make sure
10 the software is working, and they're two
11 different tasks. And I said, Speak with
12 your -- whoever gave you the assignment,
13 Dipti, and clarify that.
14 And the next day, we would have the same
15 discussion over again, and I would say -- You
16 would ask me what to do, and I would say the
17 same thing: Figure out from your leader what
18 your real assignment is. Are you supposed to
19 fix the test plan or make sure the software
20 works, because you can't do both the way
21 they're written. The test plan works fine on
22 Windows, it doesn't work on Linux. You need
23 to sort this out with your leader.
24 It wasn't my job, because I wasn't
25 working on the project, and Greg and Al
40
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1 weren't offering to help. So I spoke up at
2 that time.
3 Q Thank you.
4 A So that's what I remember from that timeframe.
5 Q Right. And as I told you after those
6 discussion, I very clearly remember, that --
7 MS. TRIVEDI: I'm asking again a
8 question.
9 MR. SCULLEN: You're asking him what
10 you told him?
11 MS. TRIVEDI: No. The next question
12 before I ask a question, I need to have a
13 foundation.
14 Q So I did write back to Dipti and Al, but they
15 are not clear. And it was both, fixing a test
16 plan as well as testing, and that kept
17 changing continuously?
18 MR. SCULLEN: But I'm going to
19 object because you're not asking him -- He
20 can't testify to what you talked to Dipti
21 about.
22 MS. TRIVEDI: So I'm asking him.
23 Don't continually object. It breaks my
24 thoughts. And we have, you know -- I need --
25 So what I'm asking is -- What did I say?
41
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1 (Reporter read pending question.)
2 Q You have knowledge of that?
3 A I have knowledge of what I've told you in the
4 previous question. Are you saying knowledge
5 about --
6 Q Changing --
7 A No, I don't have knowledge that they changed
8 or that direction was changed. I don't know.
9 I had not heard that.
11 Q Can you look at this? Do you remember when
12 working on Insite ExC Surgery Integration, we
13 found out a test plan where network packet
14 analyzer was used?
15 A Yes.
16 Q And the test plan developed by team leads Alan
17 Kuhn and Dipti Patel included screen shot
18 rather than actually having a SOAP message?
19 So when you analyze a packet --
20 A So I remember. Was there a question there
21 other than do I remember?
22 Q So you remember that, yes?
23 A Yes.
24 Q And we found that that was not correct, right?
25 It should be a SOAP -- the SOAP message, not a
42
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1 screen shot. They had a screen shot of an
2 ideal packet compared with the test packet by
3 a screen shot. So you take screen shot of
4 your ideal packet, and you test -- you take a
5 screen shot, and the test plan was written the
6 way -- by testing and comparing those two
7 screen shots.
8 And the correct way was to actually
9 capture a SOAP package and compare that with
10 the ideal SOAP package.
11 A My response to that is it isn't a matter of
12 correct or incorrect. What they had written
13 in the test plan and the screen shot and stuff
14 worked fine as long as you were testing on a
15 Windows computer. When you were now trying to
16 execute that test plan on a Linux computer,
17 you could not execute those tools.
18 The network packet capture did not run
19 because it only ran on Windows, and you were
20 on a Linux computer, so you could not complete
21 that test plan as it was written.
22 You could infer what it meant and find
23 the real meaning of the test and do it a
24 different way, but you couldn't, per the
25 letter of the test, pass the test.
43
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1 So was it correct or not? It depends.
2 It was correct, fine for Windows. It wasn't
3 working for Linux.
4 Q But in general, isn't it true that you
5 captured the SOAP message and -- I haven't
6 heard anyone --
7 A This is like kind of a --
8 MR. SCULLEN: Let him answer the
9 question.
10 Q Do you think that it was a hack? You know
11 hacking, right? We do that all of the time.
12 A Yes. Do I think the test plan was a hack?
13 Q Not a hack, the screen shot.
14 A It's not how I would have done it. But when
15 you were working solely on Windows, it worked
16 fine.
17 Q So why -- That's not how the way you would do
18 it. You said that's not how the way you would
19 do it?
20 A Because it's specific to Windows. If you know
21 you're going to run your test plan on Windows
22 and Linux and other versions of Linux, you
23 would write a more generic test plan.
24 But at the time, they had written ExC,
25 and they ported it to many Windows products,
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1 that test plan worked perfectly well for
2 years. It didn't work well once we changed to
3 Linux products.
4 Q So you would take screen shot and not capture
5 actual SOAP package?
6 A Well, I don't remember the test plan for sure.
7 But it wasn't a screen shot so much as cut and
8 paste the text of the screen, I thought.
9 Right? It was an actual -- you know, hex dump
10 of the bytes on the network layer, and there
11 would have been a much more friendly, human
12 readable way to do that, to write that test.
13 If I were writing it, I probably would
14 have written it different, but it worked the
15 way they said on Windows.
16 Q So even if you would have helped as a
17 principal engineer -- Suppose if I'm working
18 for you and you are my principal engineer, and
19 if I'm developing a test plan for that, and if
20 I have done that by copying instead of
21 capturing actual SOAP package, and if you
22 would have to review, would you tell me to
23 change it or -- You know what I'm going to
24 say, right?
25 A No, I don't know what you're going to say.
45
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1 Q Even if you had to work it only on Windows,
2 would you have it done the way it was done or
3 you would have it done differently?
4 A I don't know.
5 Q What's the engineering practice? Shouldn't --
6 My point was that the knowledge -- the
7 networking knowledge that you don't capture
8 the hex byte even for Windows to work doesn't
9 mean the actual engineering practice is to
10 capture a SOAP message and not the hex --
11 A The SOAP message and the hex bytes of that
12 SOAP message are the same thing. It's like
13 having text written in French and English.
14 The meaning of the words is the same. It's
15 just two different representations of the same
16 thing.
17 If you're looking at the network layer
18 and watching the bytes go by, you will see the
19 hex. You won't see the SOAP message. It's
20 not until you translate them into ASCII
21 English code that you will see the SOAP
22 message, but the SOAP message is there.
23 MS. TRIVEDI: Off the record.
25 MR. SCULLEN: Let's go back on the
46
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1 record. I want to note for the record that
2 Ms. Trivedi just instructed the witness not to
3 answer in as much detail because the
4 arbitrator wouldn't be able to follow that
5 much detail.
6 MS. TRIVEDI: That's a
7 misrepresentation of what I said, and it's
8 misleading. I am objecting. What I said is
9 that Mr. Barbiaux need not go in very, very
10 engineering detail of the problem because it's
11 not needed, and even for arbitrator. The
12 point is to investigate and understand
13 employment problem, not engineering problem.
14 MR. SCULLEN: But the problem,
15 Ms. Trivedi, you don't like the answers you're
16 getting. They're not nice, neat answers that
17 fit into your theory of the case, which -- I
18 mean, all of this line of questioning
19 ultimately is totally irrelevant, for one
20 thing.
21 Secondly, the witness -- You can't force
22 the witness not to provide the accurate answer
23 just because it may be more complex than what
24 fits into your theory of the case.
25 BY MS. TRIVEDI:
47
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1 Q Do you recall that you and I spoke with Dipti
2 about the same SOAP package, and Dipti
3 resisted that it needed to be changed?
4 A I don't recall that the three of us spoke
5 together, but we might have. I don't
6 remember.
7 Q Do you remember any conversation with Dipti or
8 Alan or Greg about this, and you mentioned --
9 A No, I don't.
10 Q -- they should be -- Even for Windows it was
11 fine, it was kind of a hack; but in general,
12 and even for Linux, it should be done the way
13 I was proposing. And I expressed concern that
14 Alan, Greg and Dipti were not accepting that?
15 A Right. I do remember the situation there. I
16 remember telling you how you could do the
17 packet capture on Linux using Wireshark, and
18 that would also have worked on Windows, and
19 the test plan could be rewritten and make it
20 human readable, and you would see the SOAP
21 text and make it readable instead of the
22 binary or hex dump. I remember several
23 discussions on that with you.
24 I don't remember any discussions with
25 anyone else. There might have been, but I
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1 don't remember them.
2 Q I'm trying to refresh your memory. When I
3 expressed that those individuals were not
4 accepting this and were kind of upset about
5 that, you spoke briefly with either one of
6 them and mentioned that this is the way it
7 should be done for Windows and Linux, and they
8 should be -- why they are not accepting it,
9 what's the problem. Because I remember we had
10 that. But a long time, so it's fine if you --
11 A Right.
12 Q So you don't remember?
13 A I don't remember. I know we talked about it
14 in our aisle at your desk and mine, and Greg
15 sat right next to us, so he may have heard
16 that discussion. But I don't remember having
17 a discussion with anyone else but you. We
18 might have, but I don't recall that.
19 Q When Dipti came to that aisle, you mentioned
20 that they should be accepting this, and what's
21 the problem, why they're resisting.
22 A That's quite possible, but I don't remember
23 all of the conversations I have in the
24 hallway.
25 Q So that's quite possible, he said. Okay.
49
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1 That's fine. Do you remember that Insite ExC
2 Surgery Agent for HeliOS, during testing, we
3 were able to access the Agent on several
4 ports, including IPv6 and IPv4?
5 A Um-hum. Yes.
6 Q And what should be the ideal -- Should it be
7 that way or it should not be that way?
8 Because when I was testing, I found out that
9 it was working on multiple ports randomly.
10 The ports would change, and it was working on
11 IPv6 and IPv4 both.
12 A So does Agent --
13 Q Does Insite ExC Agent normally work that way,
14 or it works only for one port or it should
15 work only for one port?
16 A ExC Agents should only work on the specific
17 configured port for each protocol.
18 Q All right.
19 A So the VNC should be on a VNC port, things
20 like that.
21 Q The ExC Agent was working on IPv6 and IPv4,
22 and it was considered security issue, right,
23 because --
24 A Possibly.
25 Q Can you be specific? Possibly or --
50
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1 A Well, this is getting very technical, so --
3 answer before you start marking documents.
4 A You were working on a test of a new port. It
5 wasn't released, right? So it wasn't -- The
6 product was not out in the field.
7 This wasn't a terrible security lapse.
8 It was, Oh, isn't this interesting. The way
9 the service is set up, it listens for both on
10 IPv4 networks and IPv6 networks, which nobody
11 realized at the time. So that was eye-opening
12 for me and for others that IPv6 is now turned
13 on by default. We need to start concerning
14 ourselves with it because it might open
15 security holes.
16 Q So you considered that was a security
17 vulnerability?
18 A A possible security vulnerability.
19 Q And what do you think about my work on that
20 point? As you already said, that you also
21 came to know about that after me working --
22 you, me and three of us start working
23 together, and that led you more -- that got
24 you more interested in that because you wanted
25 to know.
51
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1 So given that you considered that that
2 was good work, that was needed work with --
3 A Well, I do remember that I was the one who
4 pointed out to you that IPv6 was available and
5 it was listening there. I'm not sure you knew
6 about it at the time.
7 I had been working on an IPv6 advanced
8 technology program, so I was surprised by it
9 and used your test system to test some IPv6
10 stuff, and I pointed it out to you, so -- Was
11 it great work? I don't know.
12 Q Not great, but in terms --
13 A It was stuff we discovered in the course of
14 working on a different issue, so --.
15 Q I remember I found something -- I tested and I
16 found that it was working on different ports,
17 and then I came to you to -- even you are a
18 networking expert, I wanted an expert opinion.
19 And then you and Curt confirmed that, and you
20 led me to more detail because you were already
21 working on that.
22 But the reason I came to you was to
23 confirm these things because you are an
24 expert, and I wanted an expert opinion. And
25 it was a networking issue and you were a
52
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1 networking expert. So then -- So my point was
2 that --
3 MR. SCULLEN: Do you have a point or
4 a question?
5 MS. TRIVEDI: The question was --
6 That's okay.
7 THE WITNESS: It is cold in here.
9 BY MS. TRIVEDI:
10 Q The question was that the the test results and
11 the investigation we were doing or I started
12 doing for IPv6 led to people who were longer
13 with GST or people who are leads, principal
14 engineers like you, came to know, one, about
15 the possible security vulnerability.
16 The second thing they came to know about
17 having Agent accessible on another port, like
18 IPv6 or IPv4 for first time, right, because it
19 didn't happen before?
20 MR. SCULLEN: Object as to complex
21 and vague.
22 A What I remember about the situation was I told
23 you about IPv6 and pointed out that it was
24 also listening there. I also remember issues
25 around the VNC listener service that you had
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1 difficulty getting started because it wasn't
2 configured properly on the product, and you
3 had a lot of questions about how is it
4 supposed to run? Is it set up by the modality
5 or is it set up by ExC.
6 And because it was a test system, whoever
7 had configured it before set it up differently
8 than we would see it in a product. So you
9 were uncovering difficulties with that test
10 system and how it was configured surrounding
11 VNC and stuff.
12 The IPv6 stuff I pointed out to you
13 because I was working on a project, and I used
14 your test system to test some things that I
15 figured out.
16 So there were issues around VNC and
17 getting that set up, and it was sometimes
18 listening on the correct port and sometimes
19 the wrong port, and it wasn't the right
20 version that was installed, and there were
21 several issues around that.
22 MS. TRIVEDI: Can you make a note he
23 said there were several issues around --
24 (Off the record discussion with reporter.)
25 BY MS. TRIVEDI:
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1 Q So what's your observation on Dipti, Alan and
2 Greg cooperation with me about this security
3 issue when I was working on?
4 A I don't really recall. I do -- About what
5 they thought. I don't know what they thought.
6 I remember asking you several times, Talk with
7 the rest of your team to figure out the right
8 way.
9 And I remember giving you pointers about
10 how VNC is supposed to run and things, but I
11 don't remember specifics about other people
12 involved in that.
13 Q Did I tell you that those people were not
14 cooperative and they didn't want me to
15 investigate further or they were kind of being
16 reckless? They were overconfident that it has
17 worked for long time on Windows, what's the
18 problem?
19 A I remember in general like that, where they
20 were having -- they didn't realize that Linux
21 was fundamentally different and things that
22 had worked for them fine in the past didn't
23 work. And that's where there were some
24 confusion, difficulties, whatever, sorting
25 that out.
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1 Q So there were issues where I was trying to
2 insert -- or I was trying to bring into light
3 the issues of security, possible security
4 vulnerability, VNC server had all
5 configuration issues, whether modality
6 configures, and their response was that,
7 What's the problem? It has always worked,
8 so --
9 Is it considered negligence, kind of, or
10 is it considered recklessness because it
11 was -- they were just being overconfident?
12 MR. SCULLEN: I'm going to object.
13 Are you asking him now -- There were several
14 statements and comments in there.
16 MR. SCULLEN: Are you asking him
17 about what you told him or what he knew from
18 having observed them?
19 MS. TRIVEDI: Both.
20 MR. SCULLEN: Then you need to
21 clarify and break that down.
22 BY MS. TRIVEDI:
23 Q Both.
24 A I'm not sure I caught the question.
25 MS. TRIVEDI: Can you read it?
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2 A I don't think it's -- I would consider it
3 negligence. I think they didn't realize that
4 what worked fine on Windows doesn't always
5 work on Linux, and that was their education
6 period.
7 And you were in the middle of that
8 because your job was to figure this out and
9 there were problems figuring that out. So I
10 don't know that there is any blame. It's just
11 things that you've been doing the same way for
12 years and have worked fine, suddenly they
13 don't work, and it's a little surprising to
14 you. So that's something you have to sort
15 through, and sometimes that takes time. Do I
16 blame them? No.
17 Q Do you expect them to do it differently?
18 A Differently the next time?
19 Q That point. If you would be them, would you
20 have been more open and accepting to a new
21 person who just joined, was one month old, and
22 bringing up these tons of issues indirectly,
23 because I was assigned. It was not I was just
24 doing intentionally that. That was my job
25 that I was hired to do. And as part of my job
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1 duty, I was addressing those -- I was bringing
2 those issue into the light, and they -- I was
3 kind of beaten up on the whole time that --
4 MR. SCULLEN: I'm going to object.
5 Q I'm just -- I'm the person who is just
6 bringing out issue, but it was them who had
7 just -- It was -- They were neglecting or
8 being -- as you said, what -- They were used
9 to one thing for a long period of time and
10 then it was a learning period for them.
11 A Right.
12 Q So would you have blamed me or should they
13 blame me?
15 to both hypothetical and also assumes facts
16 not in evidence. He has not testified that
17 he's aware that they blamed you or that they
18 weren't willing to -- that they treated you
19 poorly. He hasn't testified to any of that.
20 BY MS. TRIVEDI:
21 Q So do you think, given the circumstances of
22 what happened and their behavior and their
23 treatment, including Dave Mehring's, is it
24 considered proper treatment given that they
25 had to learn new things and they were all
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1 confident and borderline negligence or --
2 MR. SCULLEN: Object as to what
3 treatment you're referring to.
4 A Yeah. I'm not aware of their interactions
5 with you. I'm aware about my interactions
6 with you about that issue, and that's the
7 extent of my knowledge.
8 So you and I had discussions about the
9 test plan needs to change or things that
10 worked fine on Windows don't work on Linux,
11 and I remember asking you several times, You
12 need to take that to your team leader. I'm
13 not working on your project. I don't know
14 exactly what your assignment is. Go back and
15 figure that out.
16 Q And did I express my frustration to you that
17 those team leads, including manager, were kind
18 of being overconfident thinking that it has
19 worked on Windows. I expressed serious -- as
20 we used to talk a lot -- Do you recall that I
21 expressed that they are not taking it
22 positively?
23 A I don't recall that from the -- during the
24 time it was happening. I recall you saying
25 that later.
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1 Q When?
2 A In discussions throughout your time at GE when
3 we would talk, I remember you bringing up that
4 time period a lot and saying, They weren't
5 listening to me, or whatever, some of the
6 things you just said.
7 At that time, I remember us discussing
8 it, and you would ask me, What do I do, and I
9 would say, Go back to your team and figure out
10 what the assignment is. I don't know what
11 your assignment is, so --.
12 Q So in your opinion, the work I did for -- I
13 did for security VNC server issues on Surgery
14 was good work, and it was good for GST given
15 that I was a couple of months old within the
16 company, and it was -- I was bringing tons of
17 issues, and it was too much for them.
18 I was expressing tons of concerns, and it
19 was truth. It was not just -- It was
20 happening. Things were not working the way
21 they were supposed to.
22 MR. SCULLEN: Objection, compound.
23 A Getting back to what I think was a question --
24 Q Good work for GST.
25 A Yes. Technically, I thought what you were
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1 doing -- a lot of what you were doing made
2 sense. A lot of it was advice I was giving
3 you on IPv6 and on VNC, and of course I would
4 think it made sense because we worked together
5 on it. So technically that wasn't the
6 problem.
7 Q I didn't understand what --
8 A I don't think there were any technical
9 problems with what you worked on. If there
10 were problems at that time, it was in
11 communicating, because you would ask me every
12 day the same question and what to do about it,
13 and I would give you the same answer, and that
14 never seemed to change. The technical stuff
15 was fine. The communication stuff was
16 difficult.
17 Q Did I tell you that -- Did I come back and
18 tell you the same, that I'm talking with Dave
19 Mehring, I'm talking to all team leads, and
20 they are just giving me cold shoulder, and you
21 are the only person who would listen to -- not
22 the only, but you are the person who were
23 diligently listening to my concerns.
24 And it was my job, as a test engineer, to
25 do the testing, so if they don't listen to me,
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1 I'm not going to sign a test.
2 MR. SCULLEN: Are you now asking a
3 question or are you making a statement? Is
4 there a question? What's the question?
5 MS. TRIVEDI: I'm trying to form
6 what I said. I know he said to go back and
7 ask your team leads, and I came back and I
8 said they are giving me cold shoulder, and I
9 had serious concerns that I was not well
10 received when I was raising concerns and I was
11 not getting any cooperation.
12 Q And so the reason I came back to you again --
13 MR. SCULLEN: Now you're not saying
14 what you told him --
15 MS. TRIVEDI: I'm confirming. Can
16 you read all that again?
17 MR. SCULLEN: Just ask a question.
18 You need to ask him what you told him, if
19 that's your question.
20 MS. TRIVEDI: Can you read all over
21 again?
22 (Reporter read previous question.)
23 BY MS. TRIVEDI:
24 Q Right.
25 A And I missed the question in that.
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1 Q Do you recall this, that I came back -- that
2 after talking with you and you suggesting me
3 to go back, I came back that, Okay, I did
4 that, but here is what's happening?
5 A We probably talked about that at some time. I
6 remember us having the same conversation over
7 and over again, saying, Clear it with your
8 team, figure out what your assignment is.
9 And I was getting frustrated because you
10 would come back with the same question, "What
11 do I do?"
12 Q And --
13 A So I don't know what happened with your
14 discussion with someone else.
15 MS. TRIVEDI: He said that ten
16 times, so I need to -- If his point is to
17 come -- He said that ten times, so I need to
18 tell him that we do not repeat the same thing
19 he said 15 or 20 times.
20 Q So what I'm saying is, I did come back to you,
21 and I did say that -- as you inserted, I went
22 back and told them the same security and all
23 those quality concerns, but they were not
24 listening to me.
25 And I was new. I was concerned that
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1 given that's a regulated environment and I'm
2 responsible for testing, I'm not going to just
3 compromise my integrity.
5 whether you said that to him?
6 MS. TRIVEDI: Not exact word, but
7 I'm just trying to set up the team, that it
8 was not that he was talking to me and I was
9 not -- I was going and talking to them, but
10 they were --
11 MR. SCULLEN: So just ask a
12 question.
13 BY MS. TRIVEDI:
14 Q Do you recall that, any of that, a little bit
15 of that?
16 A Yes. I remember lots of discussions with you,
17 and you probably expressed difficulty that you
18 couldn't get your point across to either Dave
19 or your team. But that's --
20 Q So you think that there are security issues,
21 they are being overconfident, they have
22 learning point, and I'm having difficulty
23 getting my point across? There is culpable
24 negligence by managers and team leads, and
25 person who is showing their recklessness has a
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1 problem getting a point across? Is this -- I
2 mean, is this legal, regulated? I have talked
3 with FDA and they said no.
5 facts not in evidence. Complex, confusing,
6 but go ahead and answer.
7 A The security aspect is a separate issue. That
8 was IPv6 stuff and things like that. That was
9 new and not really the point of the discussion
10 at the time. That wasn't a big issue.
11 The test plan working on Windows versus
12 Linux was an issue. And I remember several
13 conversations with you and conversations I
14 ultimately had with Dave to make sure he was
15 aware that technically some of the things you
16 were working on were good and important, and
17 the difference between Windows and Linux was
18 important, and the rest of the team should
19 know about that.
20 There were also communication issues, as
21 evidenced -- we went over numerous times.
22 That's a different issue. That was the real
23 problem. The technical things weren't --
24 Those were solvable problems. Getting to that
25 point was the difficulty.
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1 Q Right. So the point is, on my second month at
2 GE, I raise this security vulnerability
3 issues, quality issues. They were not
4 listening to me, as you said. They didn't
5 even -- They had a learning curve to
6 differentiate between Windows and Linux. Even
7 though IPv6 was kind of along the line, you
8 cannot pass a test when it's hackable by IPv6
9 and IPv4 technology.
10 So technically, you cannot just say that,
11 Okay, well, you know, IPv6 is future, but you
12 don't -- It's not present. But if it's
13 hackable on IPv6, then that's a failed test,
14 so it's -- It was required -- They were not
15 anticipating that. They were not aware.
16 Even engineering manager and team leads
17 who were working that for a decade had zero
18 knowledge and understanding technically. They
19 had no technical understanding or prior
20 technical knowledge about this issue. They
21 didn't understand, and then they were not even
22 listening to me.
23 So do you think that that's considered --
24 That's -- What do you think of that type of
25 behavior?
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1 MR. SCULLEN: Object, assumes facts
2 not in evidence. Mischaracterizes his
3 testimony. He hasn't testified that he's
4 aware, from his personal knowledge, that they
5 weren't listening to you or any of the
6 other --
7 MS. TRIVEDI: No. He said that I was
8 having difficulty getting my point across.
9 MR. SCULLEN: Ms. Trivedi, let me
10 finish the objection. He hasn't --
11 Mischaracterizes his testimony. Part of your
12 statement/question was repeatedly saying that
13 they weren't listening to you. He hasn't
14 testified that he's aware of that from his
15 personal knowledge.
16 You testified to -- You made a number of
17 other statements that are facts not in
18 evidence and/or they mischaracterize his
19 testimony. The question is complex and
20 confusing. You can answer if you can.
21 MS. TRIVEDI: That's the crux.
22 That's the problem. So they are going to
23 defend this. Do we need to put a hostile
24 witness deposition in here or -- considering a
25 hostile witness? (Ms. Trivedi asking
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1 reporter.)
2 REPORTER: I don't know what you're
3 talking about.
4 MS. TRIVEDI: He's my witness for
5 trial, but at trial you can consider a hostile
6 witness, right? You know the legal term?
7 MR. SCULLEN: I don't know what
8 you're talking about in the context of this.
9 No, I have no idea.
10 MS. TRIVEDI: It's not in
11 deposition, it's at the trial time, right?
12 MR. SCULLEN: Correct.
13 MS. TRIVEDI: He was my witness, but
14 if it's on the GE side, then it's considered
15 hostile witness.
16 MR. SCULLEN: It doesn't have any
17 application --
18 MS. TRIVEDI: It's at the trial
19 time.
20 MR. SCULLEN: I think you're totally
21 misconstruing a legal term that you don't
22 understand, but let's move on.
23 MS. TRIVEDI: I'm just saying it's
24 not at a deposition. Okay. That's fine.
25 BY MS. TRIVEDI:
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1 Q So you did say that you -- What did you say
2 about me getting my point across for
3 security-related work?
4 A In my perception, that was -- from my point of
5 view, that was the difficulty. The
6 communication between the team members was the
7 difficulty. It wasn't a technical thing. The
8 security and IPv6 was irrelevant. Nobody knew
9 about that issue, including myself. And
10 that's what I was investigating at the time.
11 We know about it now. There are lots of
12 changes and IPv6 firewalls and things. That's
13 sort of a moot point. The difficulty was
14 communicating among the team members.
15 Q So if you don't -- So if you and other senior
16 managers and team leads don't know the
17 technology and a new person is trying to bring
18 this up, is it considered the person having
19 difficulty getting a point across?
20 A I'm not sure I followed, but I will take a
21 shot. The -- Like I said before, the
22 technical issues were not the real issue. The
23 communication between you and team members,
24 among team members, was the issue.
25 The security issue and stuff is a side
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1 issue, and I pointed out most of those issues
2 to you.
3 Q You confirmed most of the issues, not pointed
4 out. You confirmed. Being an expert, you are
5 a networking expert, so you confirmed. You
6 are an expert --
7 A Yes.
8 Q -- person?
9 A Yes, but I believe that you did not even --
10 you did not even know IPv6 until I pointed it
11 out to you and I noticed that it was listening
12 on a different network and connected to it
13 and --
14 Q I knew some, but you also knew because this
15 was December, 2011, and you and Curt had IPv6
16 training in May, 2012, for three days.
17 MR. SCULLEN: Are you asking a
18 question or making a statement, Ms. Trivedi?
19 Q Do you recall that, you and Curt had IPv6
20 training in May, 2012?
21 A I don't know the date. I know Curt and Kevin,
22 Jay and myself took a week of IPv6 training.
23 Q And it was May, 2012. So it was six months
24 after this.
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1 Q You can go back and check. It was six months
2 after happening of this. So even for you --
3 You are an expert, but IPv6 was -- Because I
4 know it was May, 2006, that you and Curt
5 went -- had a week-long training. April or
6 May.
7 So my point was that -- I shouldn't use
8 my point with word several time. There were
9 issues. They were not realizing difference
10 between Windows and Linux and how test should
11 work. They were being negligent in addressing
12 that, and they diverted their ignorance and
13 their --
14 It's not considered -- Do you think is it
15 considered good engineering practice?
16 MR. SCULLEN: Objection as to vague.
17 What --
18 A Yeah, what --
19 MR. SCULLEN: What are you referring
20 to?
21 A -- is good engineering practice?
22 Q To not give a test engineer enough time to
23 investigate these issues?
25 facts not in evidence. You can answer.
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1 Q Do you remember I asked more time and I -- I
2 had to go back and forth several time. I come
3 to you, I go to them, I come to you, and every
4 time you told me to go to them, I went to
5 them, and they were just giving me cold
6 shoulder. They just wanted me to -- They just
7 pretty much overconfident.
8 MR. SCULLEN: Ms. Trivedi, he can't
9 testify as to what you did with those people.
10 This is the point --
11 Q You remember they didn't give me much time?
12 A I don't know how much time. I think I
13 remember you saying they're asking me to get
14 this done, and we had the same conversation
15 over, talk to them and point out the
16 differences and, you know, the difficulties
17 between Linux and Windows. That's the issue I
18 remember.
19 Q So do you think that you, manager and team
20 leads, not having prior knowledge of IPv6 and
21 security vulnerability has anything to do with
22 me getting my point across and communication,
23 or it's you, managers and team leads not
24 having the technical knowledge?
25 So if those individuals, including you,
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1 didn't have technical knowledge, should my
2 communication skill be considered -- you and
3 other managers and team leads lack of
4 technical knowledge was the problem, because
5 you already said that it was -- they were
6 learning.
7 So when they were learning, how can
8 they -- When they were learning, and they
9 didn't even have technical knowledge,
10 including you, as you said, would it consider
11 me having issue with getting my point across
12 or it's considered they not even having
13 technical knowledge?
14 MR. SCULLEN: Objection, vague.
15 Q It was me educating them along with you and
16 me. I was also educating myself. I know I
17 went once at Nobles and got 10 books. I spent
18 several weekends sitting whole day and
19 reading, because I cannot buy 12 books, it's
20 expensive.
21 So I remember going spending whole
22 Sunday -- Saturday and Sunday and reading
23 whole day, 10 Linux books. And then I come to
24 you on Monday and -- because I was concerned
25 that I was working on OEC Surgery and FDA had
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1 halted the sales. And in my opinion, it was
2 culpable negligence from their part;
3 therefore, it was recklessness and culpable
4 negligence --
5 MR. SCULLEN: Ms. Trivedi, you've
6 just spent the last several minutes making a
7 statement, not asking a question.
8 MS. TRIVEDI: I did ask -- What was
9 the question? I was trying to have him talk
10 because he's -- he's different guy. I need
11 information. That's the truth, and I need to
12 have the truth.
13 Q If they don't know technical thing, is it fair
14 and legal to blame my communication or getting
15 me? I know it's in my EMS Madhuri has a point
16 across. But you, including you and managers,
17 don't -- don't have technical skills. Is it
18 my role to educate you or communicate to you
19 and have you learn that, or it's, you know,
20 the other side's fault that they don't know
21 technical things?
22 A Let me recount a little bit here from that
23 timeframe. At the time I first worked with
24 you on this issue in the Linux versus Windows,
25 there were difficulties -- you know, you had
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1 difficulties finishing that test plan in a
2 timely manner, you said. And I kept asking
3 you to talk with your team --
4 Q Can I interrupt?
5 MR. SCULLEN: No, you have to let
6 the witness finish his answer.
7 A Let me finish saying what I'm saying. And
8 then I thought this is something maybe I can
9 help with. I should talk to Dave to make sure
10 since you were expressing concerns to me about
11 getting your point across to the team or the
12 difficulties with that.
13 So I thought I should talk to Dave and
14 make sure he knows that these are technical --
15 there are technical issues here that the team
16 needs to sort out, Linux, Windows, the test
17 plan needs to change, things like that, and
18 that in itself should not reflect poorly on
19 your performance --
20 Q Of communication?
21 A -- of communication. That these technical
22 things here should not be affected -- or
23 should not influence his opinion of your
24 communication skills because there are
25 technical issues, and I just wanted him to
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1 know that.
2 Eventually, I know that he got that
3 point. And over time I realized that the
4 technical issues were not the problem. The
5 communication issues stayed.
6 Q Right, because technical issues stayed. You
7 were not in RSVP, so you don't know anything.
8 You already said you were not in RSVP, so
9 those technical issues stayed.
10 MR. SCULLEN: Objection, misstates
11 his testimony.
12 A I was in RSVP from the beginning.
13 Q You were, but you were not on the project.
14 A I wasn't always on the core team. I was a
15 member of RSVP from the beginning.
16 Q At high level?
17 A Right, at various times.
18 Q So first in the beginning you said that you
19 didn't know the develop level, low level
20 tasks, so you don't know the technical issue.
21 Do you know technical issues in RSVP, any --
22 A Some, yes.
23 Q How many? 10 percent, 50 percent?
24 A I have no way of estimating.
25 Q You have little bit of knowledge of technical
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1 issues in RSVP?
2 MR. SCULLEN: Objection, vague.
3 A Yeah.
4 Q Do you have low level technical information
5 about RSVP?
6 A It's too vague.
7 Q You already --
8 A Some I do, some I don't. I don't know --
9 Q First you said that you worked on the RSVP
10 project in the beginning at the very early
11 stage, at high level, starting the direction.
12 This was your exact wording today.
13 A Yes.
14 Q So now you are saying that you are aware of
15 the technical low level issues?
16 A It depends on the type of issue.
17 Q So first you said this, and now you are -- you
18 want to correct yourself or --
20 THE WITNESS: No.
22 arguing with the witness. Just ask a
23 question.
24 MS. TRIVEDI: I'm not arguing. He's
25 just changing his statement or he misstate
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1 something, which he didn't intentionally do.
2 MR. SCULLEN: You can clarify, but
3 you're --
4 MS. TRIVEDI: This is left and right.
5 First he said that he was involved only in the
6 beginning at high level.
7 MR. SCULLEN: That wasn't his
8 testimony.
9 MS. TRIVEDI: Can you find? That's
10 what you said today. Do you remember?
11 MR. SCULLEN: He never said he was
12 involved only in the beginning of the project.
13 THE WITNESS: I said I was involved
14 all the way through when GEIP and RSVP --
15 right -- RSVP was a project that encompassed
16 several years. We were doing it with GEIP. I
17 wasn't on the core team. I was involved
18 early.
19 So every new phase of the project, I'm
20 involved early when the direction changes or
21 something or we start a next phase, but I'm
22 not on the day-to-day technical details. So
23 I'm not aware of all of the technical details.
24 But just this morning I was working on
25 some very low level technical details on the
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1 RSVP project with Nate. So I'm aware of some
2 of them, not all of them. There are hundreds
3 of technical details on any project.
4 BY MS. TRIVEDI:
5 Q So you would confirm that on the RSVP GEIP
6 project, you didn't know or you were not aware
7 of many of the technical issues -- You are not
8 involved in day-to-day activities. You
9 wouldn't be able to confirm about some -- you
10 know, whether the technical issues existed or
11 you wouldn't have actually real factual
12 knowledge of those.
13 It would be you heard few of them, you
14 were involved on few of them, and it's just
15 that is all you know. Is that correct?
16 A That could be correct. I'm aware of some of
17 the technical issues on programs, not all of
18 them.
19 Q So if there would be technical issues that
20 were happening on RSVP, you cannot confirm
21 that you knew them?
22 MR. SCULLEN: He just testified
23 three times he knows some of them and not all
24 of them. Either ask him about specific issues
25 or you need to move on.
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1 Q Do you know that there was several
2 requirement -- missing requirement issues in
3 RSVP, including not having a delete function,
4 not having an auto log-out, security and HIPAA
5 vulnerability -- change that -- HIPAA missing
6 requirement? Do you know that or you don't?
7 A I don't remember those specifics.
8 Q Because we have that. So you cannot confirm
9 that you knew about specific technical issues,
10 which were even higher severity?
11 MR. SCULLEN: Higher severity than
12 what?
13 THE WITNESS: Than what? Yeah.
14 MS. TRIVEDI: Higher severity in
15 terms of contravention of code, so that's
16 contravention of law.
18 facts not in evidence.
19 REPORTER: Can we take a break?
20 MS. TRIVEDI: Sure.
21 (Off the record. Short recess taken. Exhibit
22 Nos. 3-7 marked for identification. Reporter
23 read previous testimony.)
24 MS. TRIVEDI: So we will go back on
25 the record.
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1 Q I needed more time in order to finish Insite
2 ExC test given there were security
3 vulnerability issues, and initially managers
4 and team leads didn't anticipate the security
5 issues, so original time given to me to
6 perform this testing was not enough given
7 there was security issues, so I needed to have
8 more time.
9 So that's different than me not able to
10 finish the testing in timely manner, which he
11 was saying, but actually what happened or
12 anyone would say --
13 MR. SCULLEN: Ms. Trivedi, this --
14 MS. TRIVEDI: I'm just trying to
15 correct because --
16 MR. SCULLEN: You don't get to
17 correct his testimony. You ask questions here
18 and the witness answers questions. That's
19 what happens at a deposition.
20 MS. TRIVEDI: I'm making --
21 MR. SCULLEN: But you don't make
22 statements, you ask questions.
23 MS. TRIVEDI: I'm not making a
24 statement.
25 MR. SCULLEN: You are. You just
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1 made a two-minute statement.
2 MS. TRIVEDI: You told me that --
3 And another thing is, I didn't tell him -- He
4 said he -- I told -- I didn't tell Bill --
5 MR. SCULLEN: Ms. Trivedi, we're not
6 going to continue the deposition if you --
7 MS. TRIVEDI: I need to make --
8 MR. SCULLEN: You need to ask the
9 witness questions. That's what happens at a
10 deposition.
11 MS. TRIVEDI: In my answer, if he
12 tells that I told him something --
13 MR. SCULLEN: You don't answer at a
14 deposition.
15 MS. TRIVEDI: If he tells that I
16 told him something, and if he didn't, given it
17 was long time back, I need to tell him that
18 that's not what I said.
19 MR. SCULLEN: That's not what
20 happens at a deposition. You can do that at
21 the hearing. All you can do at this
22 deposition is ask questions that the witness
23 will answer. If you don't agree with those
24 answers, you don't -- this is not your
25 opportunity to contest that.
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1 MS. TRIVEDI: That's fine.
2 Q All right. So you agree that the first part
3 you said about Insite ExC, that there were
4 technical issues and not my communication
5 issue, period. Is that correct?
6 For Insite ExC only right now. Not
7 only -- For Insite ExC period of time, you
8 already said that on record, right?
11 MS. TRIVEDI: I'm just trying to --
12 THE WITNESS: I can repeat what I
13 said.
14 MS. TRIVEDI: She read that, right?
15 MR. SCULLEN: You're asking him to
16 say what he said, right?
17 THE WITNESS: You asked do I agree
18 that, but -- I agree with what I said. I can
19 restate my statement. But if you're asking do
20 I agree with you --
21 BY MS. TRIVEDI:
22 Q You don't agree with me, that's fine.
23 A No.
24 Q But you already said that team needed to sort
25 out technical issue. So it was not me getting
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1 my point across, but team having technical
2 issue, including managers and you?
3 MR. SCULLEN: Objection, that's not
4 what he said.
5 Q Is that correct?
7 said.
8 MS. TRIVEDI: Let me ask my
9 question.
10 Q Is that correct? That for Insite ExC,
11 manager, team leads and you, including you,
12 had a learning curve in terms of technology
13 and the security issues?
14 A There were technical issues on ExC and there
15 were also communication issues --
16 Q And --
17 A -- on ExC, on that project and other projects
18 after that.
19 Q I will ask only -- Answer only I ask you. You
20 don't have to build -- You are not defending
21 company and you are not making a case here, so
22 you just ask for only specific thing I ask you
23 today. So I only ask for ExC, so you need not
24 just make this, you know, whole picture.
25 So what I ask, for Insite ExC period,
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1 there were technical challenges to managers,
2 you and team leads where they didn't have
3 knowledge or skills or ability to anticipate
4 and understand these very issues. Is that
5 correct?
6 A Well, yes, there were technical issues on the
7 ExC project.
8 Q And you already said that given the amount of
9 technical issues and managers and leads not
10 able to differentiate Linux and Windows test
11 environment, I shouldn't be held -- or I
12 shouldn't be blamed for my communication issue
13 for Insite ExC part?
15 Q There was this whole technical issue --
16 MR. SCULLEN: Misstates his
17 testimony, but --
18 A I think I said you shouldn't be blamed for the
19 technical issues. There were technical issues
20 here and that should not reflect poorly on
21 your performance.
22 Q In terms of communication. You already said
23 that on record. She already read that once.
24 A And maybe I said that. And what I meant was
25 the technical issues you shouldn't be dinged
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1 on, right, or they shouldn't be black marks on
2 your record.
3 Q Even though you don't know technical thing, my
4 having a problem in my communication because
5 you cannot understand technical thing. Is
6 that true?
7 A Wait. Are you asking if I -- I'm not sure
8 what that means.
9 Q So suppose a person doesn't understand
10 technical thing and the opposite person is
11 communicating, is the other person having a
12 communication problem and the other person
13 being communicated doesn't have technical
14 knowledge or skills needed, so they have
15 basically --
16 It's like, okay, I don't know algebra and
17 you are talking -- and my job is to do some
18 work algebra and you tell me you are having a
19 communication problem because I don't know
20 algebra. So the person has a problem. But,
21 well, I don't know algebra.
22 So is it my problem that I'm talking to
23 you about algebra or it's your problem that
24 you don't know algebra?
25 MR. SCULLEN: Objection, speculative
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1 and confusing, vague. Go ahead if you can
2 answer.
3 A I will take a stab at answering. Technical
4 issues -- There are real technical issues.
5 The team around ExC had some technical
6 problems. There were also communication
7 issues. Sometimes the two interact, right?
8 If I'm telling you about some technical
9 thing that's brand new to you, it may seem
10 like communication issues. But until you
11 have, you know, the same -- roughly the same
12 amount of technical understanding in any two
13 people --
14 But there are also communication issues
15 that are independent of the technical issues.
16 I think that's what these were, were
17 communication issues independent of the
18 technical issues, and I learned that over
19 time.
20 Q Don't go there, over time. We're only talking
21 about ExC. You are not making a case here.
22 So you already said you are changing your
23 testimony, and just so --
24 MR. SCULLEN: Ms. Trivedi, stop.
25 It's not --
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1 MS. TRIVEDI: -- it's confused.
2 Q You have to tell the truth, and we will again
3 have this -- You know, it's not going to work
4 out. Not work out, but this is not proper.
5 You already said first that I shouldn't
6 be held accountable for my communication when
7 there was technical issue. They were not
8 understanding, technical team.
9 How can I have a problem getting my point
10 across when the opposite party is reckless,
11 doesn't even give a damn about the security
12 issues and is overconfident? You already said
13 that 20 times. Now you are changing?
14 A I did not say that 20 times. I think you
15 might have said that numerous times. What I
16 said was, again, the technical issues -- and I
17 wanted to make sure Dave understood, that the
18 technical issues that were going on should not
19 reflect poorly on you regarding communication.
20 I don't remember exactly how I said it, but
21 there were technical issues, and there were
22 communication issues.
23 Q Like what? Can you give specific example?
24 A About communication issues?
25 Q Yeah.
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1 A Like I said earlier, we would meet daily to
2 talk about some of the ExC and test plan
3 issues, and I would ask you to talk to Dipti,
4 and you would come back and ask me the same
5 question: What do I do here, and I would
6 again answer, Talk with Dipti, talk with your
7 leadership or your team and figure out what
8 the real assignment is. I can't tell you
9 that. I'm not part of that project.
10 And again, those communication issues
11 became evident when day after day on ExC we
12 would have the same conversation over and over
13 again.
14 Q All right. You are just elaborating this
15 thing so much, and now when I'll ask you do
16 you remember that I came back to you all of
17 those times and I told that Dave Mehring and
18 Dipti and those team leads are not addressing
19 or listening to my concern, you are
20 elaborating this part for ten minutes. And
21 when I ask you, you are saying you don't
22 recall.
23 So that's what you did in past, and I let
24 it go. But now -- Every time I came back to
25 you and I said that you are the person who is
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1 diligently listening to these concerns and is
2 interested in solving and even understanding
3 these concerns. Fixing is the next thing.
4 Every time I come back to you and said
5 that they are not listening, they are giving
6 me hard time and they are making things more
7 difficult for me. Do you recall any of that,
8 or -- You recall these things very clearly,
9 and you said in very detail now, we don't
10 recall that. I came back to you every time?
11 A I'm not quite sure what the question is there.
12 Q You said that you would tell me to go back and
13 talk to Dipti --
14 A Right.
15 Q -- and team leads, Alan and Greg -- or Alan,
16 and I said -- Next day I'll say, Okay, I did
17 talk to them, but they are just not listening,
18 including Dave Mehring.
19 A I don't remember that conversation very much.
20 I remember you asking the same question and --
21 Q How come you --
23 answer.
24 MS. TRIVEDI: Five minutes, the same
25 thing. He's talking the same thing in detail
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1 for five minutes that I went -- I talked and I
2 went back, and he's just making this whole
3 nice story. He remembers that very clearly.
4 And when I am saying to him that do you
5 remember that I did talk to Dipti and got back
6 to you saying that -- he's saying that -- How
7 can that be possible? So either you don't
8 want to tell or either you want to omit, or --
9 I don't know how can that be possible.
10 If you remember this very clearly, how
11 can you not remember this, unless you don't
12 want to tell the truth.
13 MR. SCULLEN: Let me be very clear,
14 and this is all on the record. If you
15 interrupt the witness again in the middle of
16 an answer, we're going to stop the deposition
17 and we're not going to proceed. You're not
18 going to get to depose the witness anymore.
19 You do not have the right to interrupt
20 the witness and start haranguing the witness
21 because you don't like the answer or
22 questioning his honesty or veracity because of
23 whatever his level of recall and to the extent
24 it differs from you.
25 Let's be very clear. I want to be very
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1 clear about that. The witness has the right
2 to answer. You do not have the right to argue
3 with the witness and call him a liar or say
4 that he doesn't -- that his answers suggest to
5 you that he's lying.
6 If you're going to continue that, we're
7 going to stop the deposition and we won't
8 continue it. And we'll object to any further
9 depositions of this witness or others if
10 you're going to behave in that fashion.
11 MS. TRIVEDI: Are you done?
12 MR. SCULLEN: I am.
13 MS. TRIVEDI: Can I go on? One
14 thing is opposing counsel should not
15 continuously object and stop witness from
16 giving the information, the truth, because
17 that's -- his intent is not to help me truth.
18 So every time I'm asking and drilling
19 down and getting into the real information,
20 he's bringing up all kind of objections to
21 stop me doing that. I never -- or I didn't
22 say that he was lying -- that the witness is
23 liar, but witness has been changing his
24 statements few times now.
25 And either he's hesitant to tell the
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1 truth, or maybe he doesn't -- He's just
2 missing -- He's telling one point very clearly
3 and answers to that he doesn't have a clear
4 memory. So how can that be possible if he has
5 a memory of day one, and when I asked him what
6 happened on day two, he doesn't recall.
7 So that's -- It's misleading to me. He
8 can say that he doesn't want to give me
9 information and I cannot force or I cannot
10 have him give me, but that would go on the
11 record that he doesn't want to give. And he
12 has a privilege to do so given that amount of
13 information he want to give.
14 But then this is not clear that whether
15 he is not remembering or whether it's -- It's
16 misleading for me and it's not taking my
17 deposition the way I need to go in terms of
18 getting the information.
19 He's already critical person, and I need
20 this information. He has already changed his
21 statement few times, and I need the answer
22 what he meant -- if he meant one thing in the
23 first time and second -- a different thing on
24 the second time. So what was the question
25 when we were talking? Now we have to go back
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1 to the question.
2 MR. SCULLEN: You need to let him
3 finish answering the question that you
4 interrupted him in the middle of.
5 MS. TRIVEDI: Okay. So my question
6 was --
7 MR. SCULLEN: Let her read back the
8 question. Let her read back his answer, and
9 then he can continue with his answer
10 uninterrupted.
11 (Reporter read previous answer and question:
12 "Like I said earlier, we would meet daily to
13 talk about some of the ExC and test plan
14 issues, and I would ask you to talk to Dipti,
15 and you would come back and ask me the same
16 question: What do I do here, and I would
17 again answer, Talk with Dipti, talk with your
18 leadership or your team and figure out what
19 the real assignment is. I can't tell you
20 that. I'm not part of that project.
21 And again, those communication issues became
22 evident when day after day on ExC we would
23 have the same conversation over and over
24 again. Question: All right. You are just
25 elaborating this thing so much, and now when
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1 I'll ask you do you remember that I came back
2 to you all of those times and I told that Dave
3 Mehring and Dipti and those team leads are not
4 addressing or listening to my concern, you are
5 elaborating this part for ten minutes. And
6 when I ask you, you are saying you don't
7 recall. So that's what you did in past.")
8 REPORTER: Do you want me to
9 continue?
10 MR. SCULLEN: You can continue with
11 your answer.
12 THE WITNESS: I think that was my
13 answer.
14 BY MS. TRIVEDI:
15 Q So do you recall -- So my question was that
16 every time you told me to go back to leads and
17 manager, I came to you all of those times and
18 I told you that I am expressing and
19 communicating my concerns, but they are -- I'm
20 getting a cold shoulder, and they are just
21 avoiding me and neglecting me, all important
22 issues I communicate. And that's why then you
23 went and talked to Dave, I guess. I don't
24 know what you did, but --
25 A Right. I don't remember every day that we
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1 would have the conversation you would bring up
2 that they weren't listening or, you know,
3 weren't communicating.
4 What I remember more often was us having
5 the same discussion over. But at some point I
6 realized that I wanted to talk to Dave
7 about -- to make sure that the technical
8 issues and whatever communication issues were
9 going on were understood and that the
10 technical issues were real, and he should
11 understand what was happening there with the
12 test plans and Linux and why it was taking
13 longer than Dipti or whoever thought it should
14 take. So I just wanted him to know that.
15 Does that make sense?
16 Q Okay. So if you would be a manager for Insite
17 ExC Surgery Integration, you would have done
18 the things the way they were done, or how
19 would you do it differently?
20 A I don't know how to answer that. I'm not a
21 manager, so --. It's a hypothetical question.
22 Q Or technical lead or LSD or principal
23 engineer?
24 A How I would have done what differently?
25 Q The testing and integration and security
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1 investigation.
2 MR. SCULLEN: Objection, lack of
3 personal knowledge and calls for speculation.
4 MS. TRIVEDI: So can you read back
5 the time -- what you said, the time given by
6 Dipti to me?
7 (Reporter read previous answer: "He should
8 understand what was happening there with the
9 test plans and Linux and why it was taking
10 longer than Dipti or whoever thought it should
11 take.")
12 BY MS. TRIVEDI:
13 Q So basically the scheduling, do you think that
14 scheduling -- There were scheduling issues,
15 right? Dipti was responsible as a project
16 lead to schedule, and you already said it
17 was -- why it was -- you wanted Dave to know
18 why it was taking longer than --
19 So Dipti was responsible. Dipti and Alan
20 were leads. They were responsible for
21 schedule. Would you consider that that was a
22 scheduling -- scheduling needed to be
23 flexible, or it was a scheduling issue where
24 it was not anticipated or accommodated?
25 A I don't know what the schedule was. But in
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1 talking with you, it seemed like you were
2 getting pressure. You would say you were
3 getting pressure to get it done --
4 Q Scheduling.
5 A Okay. And I wanted Dave to know that
6 Windows -- what works fine on Windows may not
7 work on Linux. You need to have enough time
8 to figure that out schedulewise. So I think
9 I've said that before, but --
10 MR. SCULLEN: That's all he knows.
11 He can't testify.
12 MS. TRIVEDI: Yeah, I know. But I
13 need -- He's just expressed telling what
14 happened, and based on that we need to come to
15 a conclusion.
16 MR. SCULLEN: No. But you're asking
17 him whether he thinks the schedule -- He
18 doesn't have personal knowledge. He wasn't
19 the one responsible. He's not the right
20 witness to ask that question of.
21 His views on that are irrelevant because
22 he doesn't have personal knowledge of what the
23 schedule was. He wasn't responsible for it.
24 He's never seen -- He doesn't know the
25 schedule. He wasn't on this team. This
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1 witness doesn't have personal knowledge of
2 those issues.
4 Q So you do think or agree with -- agree would
5 be strong word, and you would say, Well, I
6 don't agree. But you do think there were
7 scheduling problem, and the scheduling was
8 team lead's responsibility?
11 MS. TRIVEDI: It was not
12 anticipated, so they basically didn't
13 anticipate and didn't --
14 MR. SCULLEN: He can't testify to
15 what they know. He's not competent. He's not
16 a competent witness. You can't ask him about
17 things that he doesn't have personal knowledge
18 of.
19 BY MS. TRIVEDI:
20 Q You want to look at that scheduling?
21 A I can look at that.
22 Q Take your time. This is like asking him
23 helicopter -- giving him a helicopter ride.
24 A So is this --
25 MR. SCULLEN: So first of all, you
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1 need to establish whether he's ever seen this
2 document or whether he's competent to testify
3 to it.
4 MS. TRIVEDI: I have him read along
5 the whole line.
6 MR. SCULLEN: You need to ask him
7 that, whether he's ever seen that.
8 THE WITNESS: I don't recall seeing
9 this. If you e-mailed it -- I can look at it.
10 I don't see my name on the "To" list, so --
12 MS. TRIVEDI: It's marked as 8.
13 MR. SCULLEN: Ms. Trivedi has
14 indicated she only needs the witness until
15 5:00 or 5:30.
16 MS. TRIVEDI: I haven't indicated
17 that.
18 MR. SCULLEN: I told you when we
19 agreed to reschedule the deposition that if
20 you wanted to start at 2:00 --
21 MS. TRIVEDI: It was not possible,
22 Mr. Scullen.
23 MR. SCULLEN: You only have this
24 witness until 5:30 today, and we're not
25 continuing his deposition. So you should
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1 either more quickly --
2 MS. TRIVEDI: We will have to, for
3 an hour when we do Dave's.
4 MR. SCULLEN: No, we're not.
5 MS. TRIVEDI: We have to. I won't
6 have --
7 MR. SCULLEN: Ms. Trivedi, I told
8 you -- When you started e-mailing me at 11:30
9 last night --
10 REPORTER: Can we go off the record?
11 MR. SCULLEN: Let's go off the
12 record.
14 MR. SCULLEN: Let's move on.
15 THE WITNESS: I have the schedule.
16 (Witness referring to Exhibit 8)
17 BY MS. TRIVEDI:
18 Q Did it help to clarify?
19 A Not really, because I don't know who wrote the
20 schedule, and I don't know the details of the
21 test involved, so --. I don't know how long
22 they would take or should take. I'm not sure
23 where that would help.
25 A I've read it.
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1 Q You read that -- both pages?
2 A Yeah.
3 MR. SCULLEN: Note for the record
4 that he's reviewing Exhibit 9.
5 Q Can you tell?
6 A Can I tell what?
7 Q What is -- If I ask him, it would be -- Can
8 you describe this issue on the record?
9 A I don't know if I remember it fully, but there
10 was some problem with the ActiveX control for
11 Questra when it was running inside Internet
12 Explorer 8, right? Or --
13 MS. TRIVEDI: Can I go off the
14 record?
16 MR. SCULLEN: We've got to go back
17 on the record.
18 MS. TRIVEDI: That's fine.
19 Q Go. Sorry.
20 A The problem was a technical issue where the
21 ActiveX control from Questra didn't run in
22 Internet Explorer 8. It looks like an e-mail
23 from me to the group where I had the question,
24 "Are we able to rebuild the ActiveX control,"
25 meaning from source code, or do we get the
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1 binary from Questra. Do we get it straight
2 from Questra and we can't rebuild it. That
3 dictates where we go to solve the problem.
4 Q And what was my --
5 A This was the last of the chain.
6 Q And I wrote an e-mail, and which he replied,
7 and it was originally written by Glyn
8 Livermore.
9 A All right. Okay. And you just stated what
10 you think the problem is. "Controls are built
11 using old versions of ATL crashing when DEP is
12 enabled. The solution is to turn DEP off or
13 rebuild the ActiveX control using Visual C++"
14 or higher -- "2005 or higher," sorry.
15 And there is more here, but -- And I sort
16 of summarized yours and said, okay, if
17 rebuilding is one solution, are we able to
18 rebuild or do we need to go back to Questra to
19 rebuild.
20 Q And can you go to the Glyn? Is there a Glyn?
21 A I think that was the original e-mail saying
22 what the problem was.
23 Q So what was the problem?
24 A "It appears if you don't uncheck 'enable
25 memory protection to help mitigate online
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1 attacks' on IE8, then you get the error seen
2 here," and you can't see the error because
3 it's all black and fuzzy. But maybe that was
4 what he saw on the screen.
5 Q No. I have a real good screen shot. So the
6 issue was that enable memory protection was
7 required to be unchecked. That's what Glyn
8 said?
9 A Right.
10 Q If you check the memory protection to mitigate
11 online attacks, then you cannot run Insite
12 ExC.
13 A Right.
14 Q And in order to run Insite ExC connectivity,
15 it was needed to uncheck that?
16 A Correct. Yes.
17 Q And it was in production. Do you agree it was
18 in production?
19 A It was probably in production. I can't tell
20 from here, but that's usually how these cases
21 get escalated.
22 Q So your answer is vague.
23 A Well, I don't know. It doesn't say here which
24 environment it was. But from my history,
25 users would have a problem, they would create
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1 a case in our support central group, sort of a
2 help forum, and Glyn or you or someone else
3 would investigate the case and reply to their
4 problem. Those were usually production
5 issues. I don't know if this one was. I
6 don't recall.
7 Q So for the record, that was a production issue
8 with service operation?
10 Ms. Trivedi --
11 MS. TRIVEDI: I'm finding an
12 e-mail --
13 MR. SCULLEN: But again, a
14 deposition is for you to ask the witness
15 questions. This is not your opportunity --
16 Once we leave, if you want to stay --
17 MS. TRIVEDI: It's a production
18 issue, otherwise Glyn doesn't even come into
19 the picture. He giving misleading answer.
20 MR. SCULLEN: Ms. Trivedi, I'm not
21 going to continue to subject the witness to
22 this.
23 MS. TRIVEDI: Okay. That's fine.
24 Give me that back.
25 Q So can you -- I'll take printout later. I'm
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1 showing him Insite 2.0.
2 A Should I go and look?
3 Q 3Q.
4 MR. SCULLEN: I need to see it as
5 well.
6 Q 3Q 2012, page "SPR Trends."
7 A Okay.
8 MS. TRIVEDI: Later I'll print out
9 and we'll label it.
10 MR. SCULLEN: What's the question?
11 You need establish whether he has -- As you
12 recall from the deposition yesterday --
14 Q Can you read this?
15 MR. SCULLEN: No. I'm not going to
16 have him read a document --
17 MS. TRIVEDI: It says 465 design
18 nonconformances.
20 asking the witness about some document on your
21 screen that he's not competent to testify to
22 unless you establish that he --
23 MS. TRIVEDI: Fine. We are talking
24 about Insite platform system performance
25 review. That's the document. Fiscal week,
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1 2012. You have copy of that.
2 MR. SCULLEN: I don't know whether I
3 do.
4 MS. TRIVEDI: I have sent it.
5 MR. SCULLEN: But you need to
6 establish with this witness whether this
7 witness is familiar with this document,
8 because he's not -- If he's not, you can't
9 ask --
10 MS. TRIVEDI: He is involved in
11 this.
12 BY MS. TRIVEDI:
13 Q Are you involved in system performance review?
14 A I attend many of the meetings. I usually try
15 to attend whenever Nate presents on the
16 Insite 2. So I likely have seen this before.
17 I don't recall that exact date, but --
18 Q Do you have knowledge that there were design
19 nonconformances, means defects in Insite ExC
20 in production?
21 A Yes.
22 Q Do you have any idea of how many of them?
23 A I don't recall. I know there were several
24 hundred or more.
25 Q So it says 465.
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1 A Okay.
2 Q And do you know FDA guideline in order for
3 medical device manufacturer to handle products
4 with this amount of design nonconformance?
5 A No, not -- I don't recall the details of FDA
6 guidelines on that.
7 Q Do you have any idea, basic understanding?
8 A I don't know that FDA guidelines talk about
9 numbers of defects in devices very clearly,
10 but they might. I don't know.
11 MR. SCULLEN: You can sit down.
12 Q Not number, but design nonconformances, how
13 they should be handled if it's more than
14 ten -- If it's more. If it's just two, then
15 nobody would care, right? It's trivial.
16 A It depends on the type of nonconformance how
17 serious it is. You do risk assessments and
18 things like that. Because this is not a
19 medical device, ExC, it's not a medical
20 device, non -- there is nothing to conform to.
21 It doesn't require a 510(k) FDA clearance or
22 anything. This is not a medical device. It's
23 a service tool.
24 Q But do you think that it's considered good
25 engineering practice to have this amount of --
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1 hundreds of nonconformities and/or defects on
2 service product that's used -- that's used
3 solely for connecting with medical devices?
4 A Let me take the first part. Is it a good idea
5 to have that many defects?
6 Q Engineering practice. Is it considered good
7 engineering practice?
8 A No, probably not. You would not want to have
9 a lot of defects in your production software.
10 However, this software was purchased
11 primarily, so most of the defects that were
12 there came with the Questra software that we
13 got from the company. And that company had
14 gone out of business by that time, and we were
15 looking for the replacement. That was what
16 the RSVP project is, it's to replace Questra
17 with better software.
18 And if you look at the next bullet on
19 that slide, it says something to the effect of
20 all of these nonconformance defects will be
21 marked -- I forget the terminology -- as soon
22 as it's replaced, because this software is
23 going end of life. They become irrelevant
24 defects because we're no longer using that
25 software.
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1 Q Do you know some of the defects were
2 unresolved for ten years? It shows here in
3 the -- They were unresolved for ten years. Do
4 you think, is that considered acceptable?
5 A It depends. If your alternative to running
6 that software is worse, I'd rather have
7 software to get the job done, even if it has
8 defects than not have that application at all,
9 right?
10 Q What does that mean?
11 A Well, as an example, this software helps GE
12 remotely diagnose a medical system problem,
13 right? We can do it remotely. If we had to
14 send a field engineer to that site, it might
15 take hours or days to get the field engineer,
16 and the customer would be down that whole
17 time.
18 If we can log in remotely with software,
19 even if it has bugs, we can save the customer
20 downtime, we can -- they can prevent having to
21 reschedule patients, they can potentially save
22 lives if we can do our job remotely servicing
23 that equipment even with software that has
24 defects.
25 So your question, should we have defects
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1 in software? Well, no, we shouldn't, but
2 sometimes it's acceptable if the alternative
3 is even worse.
4 Q So your -- I'm talking about -- I'm just
5 consolidating everything in one sentence.
6 Your point was connectivity is better than
7 defects in Insite ExC. At the least we would
8 have connectivity?
9 A Right.
10 Q And some are unresolved for ten years, which
11 is, as you said, not acceptable. But given
12 that there was no alternative, it went on?
13 A Right. And like I said, it was purchased
14 software, so I don't know that any of these
15 were really ten years old because we weren't
16 even in production at that point, but they may
17 be.
18 Q If you want to read -- It's 2004.
19 A Okay, a couple of them. That was very early
20 stages. That was before we actually released
21 the first version of the software.
22 Q Do we know in December, 2012, GST close --
23 tried to close all of these defects in bulk
24 closing, so closing everything in one shot
25 without actually doing anything and -- with a
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1 statement that RSVP program will -- But then
2 RSVP program was not released, so RSVP was not
3 in production.
4 But despite this, SPRs were basically
5 bulk closed, is it -- Do you have any
6 knowledge of that?
7 A Yes. And the reason, like I said before, is
8 the ExC software was going to be replaced with
9 RSVP. When it's ready to be replaced -- which
10 is soon, because that's what I should be
11 working on now -- when it's ready to be
12 replaced, we will no longer be running that
13 software. Any SPRs that point to that
14 software become irrelevant. They can be
15 closed, saying we're not using that anymore.
16 There will be a whole new set of
17 potential issues in the RSVP software --
18 that's a different problem.
19 And that's GE practice: If you retire
20 some software, if it has bugs that you can't
21 fix because it's a vended -- something you
22 bought and you don't have the source code to
23 fix it, you just have to live with those
24 defects. You retire those defects when you
25 replace that software.
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1 Q Without doing anything?
2 A There is nothing to do. You can't fix the
3 software.
4 Q But you are still not fixing the problem, so
5 those problems still exist?
6 A No, they don't exist because you're not
7 running that software anymore.
8 Q But that's not happening. You haven't -- RSVP
9 is not in production.
10 A It's not yet.
11 Q Right. So these defects were closed in bulk
12 in December, 2012?
13 A But they were closed saying we cannot fix
14 these right now. They weren't closed, they
15 were put in -- They were marked to say we
16 cannot fix these bugs. The best we can do is
17 replace it with new software and these bugs go
18 away. So let's stop reviewing these bugs
19 every month because there is nothing we can do
20 about them. Let's instead focus on the new
21 software. That's how we -- This comes up all
22 of the time.
23 Q And it's March, 2014, so still there is no
24 RSVP in production. So there is no
25 replacement for this defective product, and
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1 those defects are still existing in
2 production. Is that true?
3 A Most of them, yes. Some things we fix by
4 other ways or we mitigate the problems, but
5 yes.
6 Q Most of them are still existing in production?
7 A Correct.
8 Q Do you think these defects can potentially
9 affect the safety and security of the
10 operation of medical device and even to the
11 patient in any way?
12 A No.
13 Q It could have been, given that it's defects or
14 it's --
15 A No. They're defects to Back-Office software.
16 The only thing it could affect is if there is
17 a serious defect in the Back-Office software,
18 we couldn't connect to that device at the
19 hospital and get it up and running again, and
20 we would have to send a field engineer, which
21 would take more time. But that's a
22 productivity thing for the hospital and for
23 us. It's not a patient safety issue.
24 Q Directly or indirectly it could have been?
25 MR. SCULLEN: Objection, asked and
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1 answered.
2 A Not a patient safety issue.
3 Q All right. Can we on the record, SPR means
4 defects. It's a technical term, so we need
5 to --
6 A Well, it means it's a problem report. That
7 problem that's stated in there, that item
8 might be a defect, a nonconformance. It might
9 be an improvement opportunity, or it's a new
10 request for a feature. It's not really a
11 defect, so it depends on how they're
12 classified.
13 Q So can you read the same blue item?
14 A "Not so good news. We have been experiencing
15 a large number of issues on the device facing
16 side of the application. This means that even
17 though users can get into the Questra app,
18 they --" And that's all that's highlighted.
19 Q You can finish the remaining.
20 A " -- they cannot use remote service features
21 of the application. We have mechanisms to
22 detect the issue, but not to do trending on
23 it."
24 Q Can you explain what that means or elaborate.
25 A Okay. That means that we have an application
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1 in the Back-Office, the Questra application or
2 ExC application. Users, the engineers working
3 at GE, can log into the application and view
4 the pages, but the medical devices cannot
5 reliably connect to the application.
6 So there is three parts to this
7 application, the medical device and the Agent,
8 so the Agents and the Back-Office can't talk
9 to the medical device.
10 Q Can't connect to Back-Office?
11 A Can't connect to the Back-Office reliably.
12 That's the way I read that statement from
13 Nate. That's an area that I'm very familiar
14 with because that's what I've been working on
15 for the last couple of years.
16 MS. TRIVEDI: So I'm just repeating
17 what he said --
18 MR. SCULLEN: Is there a question?
19 MS. TRIVEDI: No.
20 MR. SCULLEN: You don't get to --
21 You need to ask a question.
22 MS. TRIVEDI: I need to ask second
23 question.
24 MR. SCULLEN: Then ask the question.
25 You don't --
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1 BY MS. TRIVEDI:
2 Q So you just said that medical device cannot
3 connect to the Back-Office reliably, right?
4 As per the --
5 A At the time that statement was made, there
6 were some issues, yes.
7 Q Is it fixed?
8 A I don't remember exactly what the issues are.
9 There have been numerous issues over the
10 years. Today things are reliably connecting.
11 Q Do you know, was logging and reporting and
12 auditing feature in Insite ExC?
13 A Logging -- Those are three different features.
14 Q You can explain all of them one by one.
15 A I can?
16 Q Not how this works in terms of technically,
17 but do you know that proper reporting existed
18 or proper reporting was there in Insite ExC,
19 or is there?
20 A Reporting of what? To who?
21 Q Audit trails, audit controls.
22 A There is an audit trail log in Insite 2.
23 Q Is it useful or does it -- Is it enough, or is
24 it what it should be?
25 A It's close. There is an application that
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1 collects those audit logs and generates
2 reports for customers, along with Insite 1,
3 Audit and Auto SC audit logs.
4 There used to be reporting of that on the
5 Questra application itself. We disabled that
6 years ago because it wasn't very useful or
7 reliable, so instead we use iCenter to do
8 audit trail reports. That's working today.
9 Q So do you remember Mike Walls and you stopped
10 by at my desk and I was working on prototyping
11 of RSVP Gen 1?
12 A I think so, yeah, a couple times.
13 Q Mike Walls mentioned that I shouldn't be
14 reproducing -- I was told to repeat some of
15 the features from Insite ExC, and you and Mike
16 expressed the concern that some of the
17 features were not usable, like search
18 function, along with other -- and customers
19 were frustrated, and there was kind of a
20 concern?
21 A I remember general discussions. I don't
22 remember the specific issues.
23 Q So you remember the general discussion
24 about --
25 A About that you were -- We were developing new
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1 screens, and we were trying to take the
2 Questra screens and do something very similar
3 for RSVP, and there were issues that you
4 brought up around that.
5 Q And the point you and Mike were trying to
6 convey was that even these issues or concerns
7 exist in Insite ExC, they shouldn't be
8 reproduced, because --
9 A Mike or I might have said something like that
10 or expressed our opinions. We weren't working
11 on that piece directly, you were, so you were
12 more familiar with that than us.
13 But we might have said, Yeah, we don't
14 like the way the user interface is now --
15 probably one of those 465 bugs that people
16 complained about -- and we thought, you know,
17 when we're doing the new screens, maybe it's
18 time to fix some of those.
19 But it would be completely new software,
20 so it is likely that those bugs would be fixed
21 or be completely different in the new
22 implementation.
23 Q But they shouldn't be replicated or
24 reproduced. My point was --
25 A Right. But all we were doing at that time was
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1 screens, how the screens look.
2 Q All right.
3 A So you don't know how they're functioning
4 underneath, you were just doing screen
5 drawings.
6 Q So going back to the reporting. I need an
7 e-mail. I sent out an e-mail to confirm to
8 Mike, and I also have a -- I can show you.
10 Q So I confirmed with Mike Walls. After you and
11 Mike stopped by, I had a meeting in January,
12 2013, or December, 2012 -- actually, December,
13 2012, with Mathews Matson about usability and
14 basically designing of RSVP Gen 1.
16 MR. SCULLEN: Is there a question?
17 MS. TRIVEDI: Before I ask, I need
18 to have him see that.
19 Q Can you just read the log-in. It was missing
20 log-in functionality.
21 MR. SCULLEN: For the record,
22 Mr. Trivedi has asked him to read an e-mail on
23 her computer screen.
24 MS. TRIVEDI: I have a printed copy,
25 I just need to --
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1 MR. SCULLEN: I understand, but
2 that's not -- you don't have it in front of
3 the witness. So it's an e-mail between
4 Mathews Matson dated January 4th, 2013, in
5 response to an e-mail from Ms. Trivedi dated
6 January 3rd. What's the question?
7 MS. TRIVEDI: Have him finish
8 reading instead of asking him in helicopter
9 view that nobody can even understand.
10 THE WITNESS: I won't remember all
11 of these details, so --
12 MR. SCULLEN: He's not on the
13 e-mail, so --
14 MS. TRIVEDI: I have an exhibit.
15 Can you mark this?
16 (Exhibit Nos. 10-11 marked for
17 identification.)
18 MR. SCULLEN: Maybe just note on the
19 record that Exhibit 10 is a printout.
20 BY MS. TRIVEDI:
21 Q So as I mention in e-mail to Mathews, Mike
22 Walls confirmed or communicated to me that,
23 "Current reporting in Questra Back-Office is
24 not really helpful. There is no good way to
25 pull all information together and see." And
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1 information it pulls up is very basic and
2 limited.
3 So the conclusion was -- his point was
4 there is no good reporting in Insite ExC.
5 MR. SCULLEN: You just can't testify
6 to what Mr. Matson meant or what this e-mail
7 says. He's not competent to testify.
8 Q Do you know? He's an Insite ExC --
9 MR. SCULLEN: Does he know what?
10 Q Can you confirm this or --
11 MR. SCULLEN: Confirm what?
12 Q Is there a good way it pull up all
13 information, or is there a good audit control
14 and reporting?
15 MR. SCULLEN: Do you mean as of
16 January 3rd, 2013? You need to give me --
17 Q As of January 3rd, 2013.
18 A Well, if you're asking if what Mike said --
19 your e-mail about what Mike said, you said you
20 spoke with Mike, and he said there is no easy
21 way to do that. Mike would be correct, if he
22 said that -- I don't know if he did -- that
23 the Questra reporting capability that I said
24 earlier that we had disabled because it wasn't
25 very useful and didn't function well, is not
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1 very good, but that the iCenter application is
2 the way we collect these logs, and that
3 includes the who, what, when, where, why of a
4 remote connection to a medical device that we
5 wanted to audit.
6 So Questra on its own, yes. All of the
7 data is there in the database, but you've got
8 to pull it from several tables. That's what
9 we do in the iCenter report.
10 Q So is there -- Practically is it possible on
11 daily basis to look at all of the activity, at
12 all of the details -- the level of all those
13 details that needed --
15 A Yes, it's possible.
16 Q Is it available?
17 A The iCenter report is available for customers
18 and for us. It's not used very well or very
19 often. Mike and I both know how to go into
20 the database and look at the audit log
21 whenever we do, but there is not a convenient
22 reporting mechanism for that, so --
23 Q Okay. So you can confirm that there is no
24 convenient reporting mechanism?
25 A For Insite 2 audit trail logs, sure. I can
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1 confirm that.
2 Q All right. That's -- Thank you. Do you know
3 HIPAA HITECH law? It's a mandated requirement
4 for all medical software and system to have an
5 audit trail --
6 A Right.
7 Q -- and detail?
8 A Yes.
9 Q That's a required feature, so it's not
10 optional. It's a mandatory required feature.
11 A It's required for medical providers to keep
12 track of who has seen patient information when
13 and where. And because GE connects to and
14 might in the course of servicing a piece of
15 medical equipment transfer some patient
16 information, we also keep an audit log so that
17 if our customers ask where did this image go,
18 who saw this image of some patient, we can --
19 we have records and we can say who from our
20 side might have seen that.
21 So yes, I'm familiar with that, and all
22 of that data is logged.
23 Q But there is no convenient reporting
24 mechanism?
25 A Right. But that wasn't a requirement. It's
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1 just do you have an audit trail, is the
2 requirement, so --
3 Q I think reporting mechanism is also required.
4 I was reading --
5 MR. SCULLEN: Ms. Trivedi --
6 MS. TRIVEDI: But that's not a
7 matter -- Sorry. Okay. All right. Can I
8 take one, two second break?
10 BY MS. TRIVEDI:
11 Q Do you have any knowledge that Insite ExC
12 Surgery Integration was halted or kind of
13 stopped in mid-2012 for connectivity problems,
14 the integration itself?
15 A I don't recall that. I don't recall that.
16 Q Axeda investigation.
17 A Well, you said Surgery ExC.
18 Q Yeah, so there was -- the problem was when you
19 disconnect the network cable.
20 A Okay.
21 Q Agent would stop, and when you reconnect it
22 back, Agent should automatically restart.
23 A Right. Okay. I remember parts of that issue.
24 I'm sure I'll have the technical details
25 wrong, but yeah.
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1 Q And it was not -- Basically you don't have a
2 product if you don't have that feature
3 working?
4 A Well, right. That feature should work, right.
5 We shouldn't ship if that doesn't work,
6 correct.
7 MS. TRIVEDI: Can you read what he
8 said?
9 (Reporter read previous answer.)
10 Q Do you know that Axeda investigated this
11 issue?
12 A I don't know the details about it. I don't
13 remember -- I don't remember all of the
14 details about the issue. I know about it.
15 Q What do you remember about it?
16 A I remember, like you said, there was an issue
17 with unplugging the network and things
18 restarting. If I remember correctly, we -- I
19 think we might have needed a patch from Axeda
20 or we misconfigured Linux wrong or something,
21 but something was wrong in the build -- in the
22 Agent we ultimately were trying to build. So
23 it was an actual software defect, and once it
24 was fixed, the problem was solved.
25 And it was tricky to figure out. That's
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1 what I remember about it. It took a little
2 while to figure it out. So that's the extent
3 of my recollection so far.
5 (Exhibit Nos. 11-13 marked for
6 identification.)
7 MR. SCULLEN: He's reviewed it if
8 you're ready. You want him to review another
9 exhibit before you ask about 12?
10 MS. TRIVEDI: Yes.
11 MR. SCULLEN: He's reviewed them.
12 MS. TRIVEDI: You reviewed both of
13 them. So for the record, let's talk like
14 exhibit number --
15 MR. SCULLEN: He's reviewed Exhibits
16 12 and 13.
17 THE WITNESS: 12 and 13.
18 BY MS. TRIVEDI:
19 Q So this is the test for the same thing we
20 talked about on network?
21 A Sounds similar, yes. Sounds like that
22 problem.
23 Q And it says it was March, 2012?
24 A Yeah. From Dipti's response to you, yeah.
25 Q And you read that Dipti -- This was a test
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1 that I was conducting?
2 MR. SCULLEN: Wait.
3 MS. TRIVEDI: I'm giving him
4 background.
5 MR. SCULLEN: But you can't. He's
6 not a recipient of the e-mails. You have to
7 ask him about his personal knowledge.
8 MS. TRIVEDI: I'm asking him a
9 question.
10 Q What does -- The e-mail says that Dipti --
11 e-mail -- wrote an e-mail -- Dipti wrote an
12 e-mail to Alan Kuhn and me mentioning that, I
13 helped Madhuri with network cable disconnect,
14 so this issue is closed.
15 Prior to that e-mail that Dipti sent out,
16 I sent an e-mail to Dipti and Al mentioning
17 that it's -- when you disconnect our network
18 cable and connect it back, Questra agent is
19 not starting, so the test is failing.
20 MR. SCULLEN: So he's not a
21 recipient on those e-mails. He doesn't have
22 personal knowledge.
23 MS. TRIVEDI: I'm asking him a
24 question.
25 MR. SCULLEN: But he can't testify
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1 as to what you e-mailed. He wasn't a
2 recipient or a participant in these e-mails.
3 MS. TRIVEDI: Not this, but how
4 about Dave's e-mail?
5 MR. SCULLEN: He's not a recipient
6 on that either.
7 MS. TRIVEDI: Okay. That's good.
8 BY MS. TRIVEDI:
9 Q So do you recall that HeliOS Insite ExC
10 Surgery Integration was halted because of
11 these issues? Kind of you recall vaguely,
12 right?
13 A I remember that issue. Like I said earlier, I
14 didn't know it was stopped in the middle of
15 development. But I remember the issue where
16 disconnecting the network cable and
17 reconnecting it, the Agent wasn't functioning
18 properly anymore, so --
19 Q And as for this e-mail, what does that mean?
20 That the test was initially failed. Is that
21 correct?
22 MR. SCULLEN: Ms. Trivedi, he can't
23 comment on an e-mail that he didn't receive
24 and wasn't a participant to.
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1 MS. TRIVEDI: Say the witness is
2 reviewing Exhibit 14.
3 MR. SCULLEN: He's reviewed it.
4 MS. TRIVEDI: Okay. Can I get it
5 back?
6 THE WITNESS: Well, I want to read a
7 little bit at the beginning first.
8 MS. TRIVEDI: Take your time.
9 MR. SCULLEN: Again, this is -- You
10 realize this is an e-mail he wasn't included
11 on, correct, Ms. Trivedi?
12 MS. TRIVEDI: It's about the
13 problem, technical problem.
14 THE WITNESS: Okay.
15 BY MS. TRIVEDI:
16 Q So as we spoke earlier, you mentioned that
17 there was a software defect and --
18 A Yes.
19 Q -- and we don't have Insite ExC product if
20 that feature doesn't work, basically, because
21 that was --
22 A For that Agent build on that operating system,
23 yes. That had a problem.
24 Q And as for this e-mail chain you saw, it
25 appeared that I failed the test and then Dipti
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1 passed the test.
2 MR. SCULLEN: Well, you're asking
3 him to say what -- The e-mail speaks for
4 itself. He wasn't a participant in the
5 e-mail.
6 MS. TRIVEDI: Can't he read and
7 confirm?
8 MR. SCULLEN: It's not appropriate
9 for him to comment on -- You want him to say
10 what it says?
11 MS. TRIVEDI: No. But does it say
12 that the test was failed by me?
13 MR. SCULLEN: Well, the e-mail says
14 what it says, Ms. Trivedi. It's not
15 appropriate to ask a witness --
16 MS. TRIVEDI: I need to conclude
17 something here.
18 MR. SCULLEN: But his testimony
19 about what the e-mail says is irrelevant.
20 MS. TRIVEDI: So my point was I
21 failed the test, team lead passed the test.
22 MR. SCULLEN: The question is does
23 he know any of that. That's what you need to
24 ask him.
25 MS. TRIVEDI: He knows a little. He
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1 already said that when I --
2 MR. SCULLEN: No, about whether you
3 personally failed the test is the point. He
4 can't testify to that. This witness isn't
5 competent. You can testify to all of that.
6 It's just not appropriate in his deposition to
7 ask him about it.
8 BY MS. TRIVEDI:
9 Q But you do confirm that that was a software
10 defect and it was -- the GST group was looking
11 into it?
12 A Right.
13 Q You don't know the details. And you already
14 said that it was -- for this Agent, we don't
15 have a product if this network connectivity
16 doesn't work the way it's supposed to, and it
17 was not working.
18 A Right. That's a defect we should fix before
19 we ship that software to a product team. We
20 make software that goes into another medical
21 device, so it's -- yeah, a long way before it
22 gets to production.
23 MS. TRIVEDI: All right. Thank you.
25 BY MS. TRIVEDI:
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1 Q Are you familiar with a document that I
2 created for Insite ExC Support of installing
3 ActiveX, which is basically connecting
4 Back-Office with the medical device?
5 A I'm familiar with a document you edited. I
6 don't know that you created it.
7 Q Edited, yes. That's true.
8 A Right.
9 Q So you are familiar with that?
10 A Yes. I've edited that document, too, by the
11 way, so --
12 Q And you are aware that that issue was a
13 widespread issue for connectivity for Insite
14 ExC? The field engineers and online engineers
15 were having lots of problem on connecting with
16 medical devices because of that issue?
17 A I don't remember the specific issue. That
18 document is a troubleshooting guide for all
19 kinds of issues.
20 Q The one I edited?
21 A Right. That document is a troubleshooting
22 guide for numerous issues that engineers have
23 in using the application because they have
24 different versions of laptops or different
25 applications loaded. So this is a
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1 troubleshooting guide to help them get through
2 their problems. So there are numerous
3 problems.
4 Q And do you know the part that I edited, it was
5 for installing Insite -- installing ActiveX?
6 A I know about it, but I don't remember the
7 details of that.
8 MR. SCULLEN: Ms. Trivedi, what's
9 the -- Off the record for a second.
10 (Off the record discussion. Exhibit No. 15
11 marked for identification.)
12 MS. TRIVEDI: He's reviewing
13 Exhibit 15.
14 MR. SCULLEN: Just note for the
15 record that Exhibit 15 is GEHC 172 through
16 175. He's reviewed them.
17 Q Can you tell me what --
18 A In general, the person who created the case,
19 Denise, was having trouble with getting the RA
20 Viewer control, the ActiveX control working on
21 her laptop. She had a laptop reimaged and
22 encountered a problem, and I directed her to
23 Section 4.2 of that troubleshooting doc we
24 were talking about earlier.
25 Q Which I created?
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1 A Which you edited and I've edited, yeah. And
2 that section covers ActiveX stuff, which is
3 one of the sections you worked on.
4 Q Right. And was that -- There was several
5 hundred cases, SupportCentral cases, opened
6 for this very issue. You can go back and --
7 A I don't know that. I would have to look back
8 through case after case.
9 Q You can search this issue and come up with the
10 research in one search. And can you do that?
11 MR. SCULLEN: No, we're not doing
12 that.
13 A And you can't really search by the issue very
14 easily. There were probably several hundred
15 cases there, yeah.
16 Q Regarding this issue?
17 A I don't know if they were regarding that
18 specific issue. Like I said, there were many
19 issues in that troubleshooting guide, because
20 there are lots of different issues. There
21 continue to be issues today, and we have cases
22 every day where someone has a problem with
23 their laptop regarding the ActiveX control,
24 so --.
25 Just things change all of the time.
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1 Microsoft does an update, GE does an update,
2 something breaks, we figure out a fix, the
3 troubleshooting doc gets updated, users get
4 pointed to it, and life goes on.
5 Q Do you recall that modality managers, which
6 means GST internal customers, sent an e-mail
7 complaining to -- sent an e-mail to general
8 manager, Dave Elario, about significant Insite
9 ExC issues, and Insite Back-Office was down 23
10 times or more and --
11 A I don't recall an e-mail like that.
12 Q Or any discussion that you had with the
13 customers?
14 A Well, I recall discussions with users of the
15 system because I had weekly telephone calls
16 that I ran with some of them.
17 Q So do you recall that Insite ExC Back-Office
18 was down 23 times?
19 A I don't recall the numbers.
20 Q But do you recall that it was down -- it was
21 unavailable?
22 A Well --
23 Q Was not working properly?
24 A It is down periodically, and it has issues,
25 like we covered earlier. That's why we're
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1 replacing it with RSVP. And one of my jobs is
2 to keep it running.
3 So I'm very aware of the issues around
4 Insite ExC Back-Office, yes.
5 Q And there were issues -- numerous issues
6 surrounding Insite ExC Back-Office?
7 A Yes.
8 Q So when I was working on Insite ExC Surgery
9 Integration for developing a test plan, as
10 well as testing, one thing is, as you said,
11 Back-Office had a numerous issues. And as we
12 talked, there were 500 -- 465 defects.
13 How can team leads like Alan Kuhn, Greg
14 Stratton and remaining members continue
15 integrate Insite ExC on all kind of medical
16 devices when there are this many issue? How
17 does the testing work? Shouldn't the test
18 fail?
19 A Well, there is a difference between what Al
20 and Greg do because they focus on the product
21 side, the medical device side, the Agent side.
22 Most of those issues, the SPRs in our
23 defect tracking system, are related to the
24 Back-Office side, which is what we have to
25 replace. We're not replacing the Agents in
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1 the field. Those are largely fine.
2 The problem is their Back-Office
3 software. The RA Viewer ActiveX controls,
4 software being up and down, the system being
5 up and down -- It's all the Back-Office stuff.
6 Greg and Al did not work on that. Nor did
7 Dipti. So they were working on the Agent
8 side.
9 Q But when you integrate Insite ExC, you have an
10 Agent and Back-Office. I remember when I did
11 testing, I was testing by logging into
12 Back-Office and connecting with Agent. You
13 cannot have one thing to test.
14 When you test, you need client and server
15 both. So I know --
16 A Right.
17 Q Several of my test cases involved Back-Office.
18 A Okay.
19 Q Because that's how front and back works. It's
20 all together one.
21 A You need them both.
22 Q You need them both.
23 A In many cases, right.
24 Q In any case you need them both. And given
25 there were issues in Back-Office, and given
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1 when I was test -- I was given a task to do
2 the testing, which involved Back-Office and
3 Agent both, and given that there were issues
4 and defects, how -- do you think that these
5 things should have been addressed in the test
6 plan, or how can --
7 How does the testing work given this
8 amount of defect? Are those defects ignored
9 or overlooked or considered as a -- I don't
10 know --
11 A Those defects would be largely irrelevant.
12 You would write the test plan for the Agent.
13 Where it interacted with the Back-Office, the
14 test plan might need to take into account what
15 to look for if there is a Back-Office bug,
16 right? But those issues and --
17 You're mixing a lot of stuff up. Your
18 comment about modality, saying the system is
19 down was the production Back-Office instance.
20 When you're testing new Agents, you're
21 pointing to development or staging or pilot,
22 usually not production, because you shouldn't
23 be testing on production. So those are
24 difference instances. There are lots of
25 factors involved.
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1 Q It's a different test that's done. We are
2 done with that deposition question about the
3 Back-Office now. This was the second
4 question.
5 A Okay.
6 Q And it was -- I said Insite ExC Surgery
7 Integration. So it was in test environment.
8 And as you already said, that when there is an
9 interaction between Agent and Back-Office
10 while testing, someone needs to look whether
11 there is a bug -- what did you say --
12 associated with this issue or --
13 A Right. If you're running a test on an Agent
14 and it interacts with the Back-Office and
15 there is a bug there, you might have to
16 mention that in your test plan as to how to
17 work around that bug.
18 But I don't recall any specific instances
19 like that. There may be some. I don't know.
20 There are -- The test plans have hundreds of
21 tests in them, so --
22 Q So do you think all current modality
23 integration team takes into account the
24 existing defects when they integrate --
25 A Well, like I said, they're largely irrelevant.
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1 When who integrates with what?
2 Q When modality integration team, so those team
3 leads when they integrate this product, do you
4 think or are you aware that -- are you aware
5 of the matter --
6 Do you have any information that they
7 take into consideration existing bugs when
8 they develop test plan or when they do
9 testing?
10 A I don't have specific knowledge of that. They
11 might. They might not. It wouldn't surprise
12 me one way or the other.
13 Q Why?
14 A Because like I said, most of those bugs are
15 irrelevant to the actual test plan. If they
16 become relevant, I'm sure they will work out
17 how to deal with that, whether it's change the
18 test plan or just change the process a little
19 bit or --
20 Q Now, given this amount of defects, were these
21 defects in Windows environment or -- These
22 defects were in Windows environment, right?
23 A Well, depends on the defect. There are 465.
24 Q No. But you said there was no Linux product
25 before, right?
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1 A Well, that's on the Agent side. Most of those
2 defects we're talking about are the
3 Back-Office side, which run on Unix servers
4 and Solaris servers and run on the ActiveX
5 control.
6 So there is Windows environments on the
7 users laptops where the ActiveX control runs,
8 but that's a Back-Office piece of software.
9 That's Windows-based. The Enterprise
10 Back-Office software is Solaris-based. The
11 products are Linux or Windows. That's where
12 your Linux/Windows issues come up.
13 Q Now, do you -- What would you say about your
14 knowledge about technical issues concerning or
15 related to RSVP GEIP project?
16 A Related to that project, I probably don't know
17 a lot of the details because I'm on the early
18 end of the project. So by the time they're in
19 the technical details, I'm off on to the next
20 project. I hear about them, but I don't know
21 enough details about them.
22 Q If there would be technical issue, you
23 wouldn't know?
24 A Probably not, unless I'd hear it from Nate or
25 Greg or someone, right. I get involved up to
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1 maybe the requirements documents, so nothing
2 has been implemented yet. So you don't really
3 get the technical details until you start
4 implementing and testing and things are not as
5 rosy as they looked when you were writing the
6 requirements.
7 MS. TRIVEDI: I want to pause for 30
8 seconds.
9 (Off the record.)
10 BY MS. TRIVEDI:
11 Q So given you didn't know about the technical
12 issues, you wouldn't have any knowledge about
13 me working on RSVP project and realizing those
14 technical issues -- not realizing -- me
15 working on the RSVP project and having
16 technical issues?
17 MR. SCULLEN: Object as vague and
18 compound, but go ahead and answer.
19 A I'm not aware of specific details, or I don't
20 recall specific details. I'm sure there were
21 numerous details working with GEIP RSVP
22 project, and I believe you worked on that at
23 some point with Greg and Nate, so you're
24 probably far more familiar with the technical
25 details of that team, because I wasn't on that
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1 core team at that time, so --
2 Q All right. That's fine. Did you provide
3 input on performance appraisal about Greg,
4 Nate, Sachin, Naresh, Alan Kuhn and Greg
5 Jacobs, mid-year and final year?
6 A I don't recall, but I probably did not. At
7 least not all of them because I only give --
8 When I give feedback, which is not every time,
9 I only do it for people I work fairly closely
10 with. So I didn't work really closely with
11 Greg or several of the people you mentioned.
12 Greg Jacobs, for example.
13 Q Did you give any input in mid-term or final
14 about me?
15 A I don't recall.
16 Q You don't recall?
17 A I honestly don't know. I talked to Dave one
18 on one, but I don't know that I filled out --
19 Q The sheet?
20 A -- feedback spreadsheet.
21 Q Mid-term as well as --
23 Q Mid-term as well as in final, you cannot
24 remember?
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1 Q Would you be able --
2 A I'm notoriously bad at filling that out.
3 Sometimes I do, I know I filled it out, but I
4 don't always do it.
5 Q Would you be able to go and find out, by any
6 chance?
7 A I don't know if I would have those records
8 saved or not. They would be on an old hard
9 drive because I have a different laptop.
10 Q Do you remember when we were coming back from
11 Brewers Stadium, the Milwaukee Stadium, Sachin
12 Kendale mentioned that he came from
13 programming background and he doesn't have
14 skillset networking?
15 A I don't recall that specifically, no.
16 Q Anything related to him not having enough
17 technical knowledge and in networking
18 technology?
19 A I don't recall that coming back from the
20 Brewers game or wherever it was. But I was
21 Sachin's mentor this entire last year, so we
22 had weekly -- biweekly meetings and we talked
23 about stuff like that all of the time, yeah.
24 He wanted to know more about networking and
25 connectivity, so -- That's one of the reasons
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1 he chose me as a mentor, so --
2 Q But you don't recall that he didn't have a
3 prior -- He said that --
4 MR. SCULLEN: He said he doesn't
5 recall.
7 MS. TRIVEDI: I'm trying to suggest
8 in case if he can refresh --
10 Q So maybe that's why he came to you as a
11 mentor, seeking a mentor, because then he
12 mentioned that he directly came from
13 programming and he doesn't know technical
14 skills -- networking? Can you try to recall?
15 A Well, I don't recall that conversation. I
16 recall from mentoring him for the last year,
17 and we met again just two days ago, that he
18 wanted to know more about networking, and
19 that's one of the things we discussed every
20 week or so for the last year.
21 So yeah, I'm very familiar with that.
22 But not from the time you recall that bus
23 conversation. I don't remember that.
24 Q So maybe he didn't -- My experience with Greg
25 was -- Greg Stratton was he would have a
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1 passive-aggressive behavior. What do you
2 think?
3 A I don't know.
5 whether --
6 Q Have you observed the same thing, different
7 thing?
8 A No. I don't think so.
9 Q Do you think that GST wanted to go for Axeda
10 kind of rather than going with GEIP, given
11 that they had been already working with Axeda
12 for Insite ExC platform?
13 A I'm not sure I understand the question.
15 Q For RSVP project. So we wanted -- We were
16 working with GEIP for -- I'm trying to
17 explain. This is not a question. We were
18 working with GEIP for RSVP?
19 A Yes.
20 Q And Insite ExC is now owned by a company
21 called Axeda. And was it a safe route from
22 the beginning to go for Axeda in replacement
23 of Insite ExC than GEIP?
24 A When Questra, which is -- We built ExC on top
25 of Questra. When Questra went out of business
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1 or was bought, their assets were bought by the
2 Axeda Corporation, we were originally going to
3 upgrade or migrate to Axeda Back-Office with
4 our software.
5 We started on that effort because that's
6 what Axeda recommended. At some point --
7 Q This is too much elaborating --
8 MR. SCULLEN: Let him finish.
9 MS. TRIVEDI: You know, it's
10 unnecessary. I don't need all that
11 information.
12 MR. SCULLEN: Ms. Trivedi, let him
13 finish the answer.
14 MS. TRIVEDI: I don't have enough
15 time. You just said we don't have enough
16 time.
17 MR. SCULLEN: You should ask better
18 questions then because this is irrelevant.
19 But let him finish the answer.
20 A At some point we started working toward Axeda
21 with RSVP. That changed and we started
22 working with GEIP instead of Axeda for RSVP.
23 Somewhere in there we were going to build it
24 completely ourselves, and I don't remember
25 exactly when that was, and eventually we
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1 stopped with GEIP and went back to Axeda.
2 They weren't ready at the time we wanted
3 to upgrade, and there are lots of issues over
4 the -- this timeframe, so now we're back with
5 Axeda.
6 Q All right. Thank you. What do you think
7 about my intellect and technical ability?
8 A I think you're a decent engineer. Technically
9 there were never any issues. About intellect
10 regarding technical stuff, I don't think there
11 were major problems.
12 Q Technical. All right. I was taking an
13 initiative when needed, right?
14 A That's --
15 MR. SCULLEN: Objection, lack of
16 foundation and vague.
17 Q Do you find me a person who was taking
18 initiative and --
19 MR. SCULLEN: Again, object. His
20 opinion on that is --
21 MS. TRIVEDI: It matters because my
22 manager says that he sought and got input from
23 him. So either he didn't say what he said or
24 he didn't say or if he said what I want to
25 know.
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1 A So this question was --
2 Q Did you find I was taking initiative, taking
3 initiative rather than sitting and not doing
4 anything?
5 A I would say yes, you took initiative on some
6 things.
7 Q Do you find I was having sense of urgency?
8 A Yes. Sometimes too much.
9 Q Do you believe that being an effective team
10 member is also about taking initiative?
11 A Yeah. Sometimes, yes. You need to take
12 initiative sometimes.
13 Q And do you believe that being an effective
14 team member is also about having some --
15 having sense of urgency?
16 A At times, if it's really urgent.
17 Q Do you admire an employee who speaks the truth
18 and is honest even to the people in power,
19 even if their authority is challenged and
20 their blind spots and weaknesses are exposed?
21 A That's a broad question. But yes, I admire
22 people who speak the truth.
23 Q Did you have any issues with Greg Stratton,
24 communication issues?
25 A Me personally? Not really. There were issues
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1 related to this topic when we were -- you were
2 working on the test plan and he wasn't
3 offering help. And I offered help because I
4 knew he was working on -- he had worked on
5 that test plan.
6 So that was the only time I recall in
7 25 years of knowing him where there was an
8 issue.
9 Q Do you think that Greg Stratton is a person --
10 he had been with GE for -- has been a person
11 passed over for promotion person with some
12 grudges?
14 A I didn't follow that.
15 MR. SCULLEN: Unintelligible.
16 Q What's your thought about Greg having -- He's
17 with GE for a long time and he's just an LSD.
18 So do you find him as a person he thinks as
19 being passed over, so he's not a manager?
20 A I don't know.
21 Q And he is having grudges and resentment?
22 A I don't know his opinion on that. I doubt
23 that he wants to be a manager, but --
24 Q Not manager, but having something different
25 than what his current role is?
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1 A I don't know.
2 Q Gives him more power?
3 A That's his opinion. I don't know.
4 Q Did you have gender speak training provided at
5 GE Healthcare about gender diversity for
6 retention of female engineers?
7 A Retention of female --
8 Q Female engineers.
9 A Sorry. I don't recall that training. I
10 recently looked at my training record
11 because -- for a different issue, different
12 project I'm working on, and I got a copy of my
13 training record, and I had 200 classes in the
14 last six years, but I don't remember that one
15 specifically.
16 Q So have you taken that training or you
17 haven't?
18 A I don't think I have, but I don't recall. I
19 had 200 classes, and I don't remember exactly
20 what the topic of each one was.
21 Q Do you have any recall that the training
22 regarding retention of female engineers at GE
23 Healthcare was identified, that there was a
24 problem at GE -- or GE Healthcare about
25 retention of female engineers?
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1 The main concern was how the females were
2 perceived by peers and manager, as well as
3 measured in terms of their behavior,
4 communication and soft skills. And the
5 training was geared towards educating men and
6 women on the differences that -- how men
7 communicate is different than how female
8 communicate, and both sides should understand
9 these differences and work on accepting and
10 basically working it out?
12 facts not in evidence. And lack of personal
13 knowledge, but --
14 A I did not have the training. I don't remember
15 that specifically. I remember you talking
16 about it in some conversations, but I don't
17 believe I had that training.
18 Q Should I show you that? Do you want to see?
19 A It's fine if you show it to me, but -- I
20 already told you what I remember. I don't
21 remember, so --.
22 Q Do you like a female engineer who
23 is relatively new compared -- You have been
24 30 years, others have been with the company
25 for 20 years, and I considered myself as a --
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1 compared to you, a person, for example me, who
2 is ambitious, have potential to grow quickly
3 and -- and but basically who is ambitious and
4 have potential to grow quickly. Do you like
5 female engineer who has potential to grow and
6 who is ambitious?
7 A Well, I don't distinguish much between male
8 and female engineers. I like good engineers
9 who are good at what they do and work well on
10 a team and, you know, do assignments and help
11 out where needed.
12 I like all kinds of things. It doesn't
13 matter to me if they're male or female. I've
14 worked with both in the past for years, so --.
15 Q Do you think -- What's your thought on success
16 and likability positively correlated for men
17 and negatively correlated for women?
18 MR. SCULLEN: Ms. Trivedi, object as
19 vague and -- His personal views on that are
20 totally irrelevant. He wasn't your manager.
21 Q Do you think that when a female is great at
22 her job, as you all said I was great
23 technically --
24 A I said good.
25 Q But she's not -- When she's just not well
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1 liked by her peers and managers, they find
2 that, well, she's just a bit aggressive, so
3 that's unconscious -- reflection of
4 unconscious thinking of stereotype?
5 MR. SCULLEN: Object, vague and
6 unintelligible. I didn't understand.
7 Q She's great at her job, right? You all have
8 said she's really good at technical --
9 MR. SCULLEN: Mischaracterizes his
10 testimony.
11 Q Do you think that --
12 MS. TRIVEDI: Let him answer.
13 MR. SCULLEN: I'm not going to let
14 you mischaracterize his testimony. He didn't
15 say you were great technically.
16 THE WITNESS: Right.
17 BY MS. TRIVEDI:
18 Q Not technically. Okay, was good. Okay. Let
19 me rephrase.
20 A Yeah.
21 Q Do you think the person who is good, a female
22 engineer who is good at her job, but as the
23 managers and peers some. They don't like
24 female mainly just because she was female, and
25 she was good at her job and she was
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1 aggressive, assertive, she was confident,
2 coming up front, talking and basically showing
3 manager their weaknesses and their lack of
4 technical skills and understanding and
5 knowledge.
6 A There was a lot there. It seemed like it was
7 a hypothetical question. But what I'll say
8 about what I think is good for engineers at
9 GE, a large company, are good, competent
10 engineers who can handle their technical
11 skills and who can also communicate well and
12 work well on teams.
13 We do a lot of big things where you can't
14 be just an individual working off on the side.
15 Ambition is fine as long as you can still work
16 together with your team members.
17 Q So do you agree that the manager unconsciously
18 reflected -- my case manager unconsciously
19 reflected a stereotype when they judged my
20 performance saying that she's good at her job,
21 but, well, she's just not well liked --
22 It's a common, industrywide issue. I
23 have -- People are writing a book right now as
24 we speak.
25 MR. SCULLEN: Objection. You're now
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1 making statements as to your personal beliefs.
2 MS. TRIVEDI: I wanted him to
3 confirm or explain or --
4 MR. SCULLEN: Just move this along.
5 Are you just asking him whether he believes
6 that your managers were discriminating against
7 you because you're a woman? Is that what you
8 are asking?
9 BY MS. TRIVEDI:
10 Q Showed an unconsciously reflected stereotype.
11 A No, I don't believe they did. I believe that
12 they evaluated your technical performance --
13 and I read some of this in your EMS, which you
14 allowed me to see -- technically was fine.
15 Skills, interpersonal skills and
16 communicating and working on a team were where
17 the problems came up, and that's what I agreed
18 with.
19 Q So now, Sachin Kendale didn't have prior
20 networking knowledge. Sachin was working on
21 RSVP Back-Office with GEIP. There are 200
22 defects in development the day I joined.
23 Despite, Sachin Kendale was not held
24 accountable, was not given negative
25 performance despite having negative technical
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1 contribution, because maybe he was being nice
2 to the manager and you and others and I was
3 punished for doing the job I was supposed to
4 do?
6 facts not in evidence. And he doesn't know --
7 There is no evidence in the record about what
8 Sachin's performance evaluation was. He
9 doesn't have personal knowledge of that, and
10 these aren't appropriate questions for this
11 witness.
12 BY MS. TRIVEDI:
13 Q I'm asking is it fine for a male engineer to
14 not --
15 MR. SCULLEN: You're making
16 assumptions that aren't in the record. You're
17 making assumptions about facts which aren't in
18 the record and about which this witness has no
19 knowledge.
20 Q Okay. You know about Greg Stratton, right?
21 You know about Greg Stratton and --
22 A What about Greg Stratton?
23 Q Greg Stratton -- WCF, Windows Communication
24 Foundation, was never used at GST. It was
25 released in 2008. And given that Greg
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1 Stratton didn't work on that, and the fact was
2 GEIP RSVP project was -- the Back-Office was
3 using WCF and Greg was supposed to drive the
4 requirement and high level design, and Greg
5 didn't have technical experience in that area,
6 the project was not delivered to GE Healthcare
7 after two years. Was Greg held accountable
8 for his lack of technical ability?
9 A I don't know how -- I don't know.
10 Q Should he be held accountable?
11 MR. SCULLEN: First of all, it
12 assumes facts not in evidence. And this
13 witness --
14 MS. TRIVEDI: It is in evidence.
15 This is not evidence? (Motioning to table)
16 MR. SCULLEN: No. This witness --
17 No, there is -- You can't wave your hand at a
18 pile of papers and say that something is in
19 evidence.
20 MS. TRIVEDI: What do you want in
21 evidence?
22 MR. SCULLEN: Well, you would have
23 to provide -- This witness isn't competent to
24 testify to Greg's performance.
25 MS. TRIVEDI: He doesn't want to
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1 answer because it's the truth. And the truth
2 will expose what was the truth and expose
3 wrongdoing. So that's why the goal --
4 MR. SCULLEN: Why don't you let him
5 answer that question.
6 A I know nothing about Greg's performance
7 reviews. He didn't share anything. His
8 manager didn't share anything. I know a
9 little bit about yours because you agreed to
10 share, so that's -- you're the only one.
11 I've never been a part of any other
12 performance review at GE except my own because
13 I'm not a manager. And I've never been a
14 manager, so --
15 Q Do you know that the WCF was used for GEIP
16 RSVP? Kind of? You said you were high
17 level -- involved with high level?
18 A Right, and that was -- Details I don't know
19 about, but yeah.
20 Q It's architecture. It's not detail, it's
21 architecture.
22 A Right. But again, that's an implementation
23 choice that GEIP and people wanted, and that
24 is not my area of expertise.
25 Q Is there a way to confirm that?
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1 MR. SCULLEN: Confirm what?
2 MS. TRIVEDI: This whole WCF issue.
3 MR. SCULLEN: Not with this witness.
4 Not right now.
5 THE WITNESS: I don't know about
6 that.
7 MS. TRIVEDI: Later? Can we do that
8 later? Go off the record.
10 BY MS. TRIVEDI:
11 Q Did Dipti Patel ever wear clothing that you
12 felt were inappropriate or provocative?
13 A No.
14 Q Do you know why Ofir Dahan left GE Healthcare?
15 A No.
16 Q Carl Conrath told me in my meeting when Dave
17 Mehring was present that Ofir Dahan was fired
18 because of he having -- he had relationship
19 problem and he was trying to set up an example
20 to me, something like that. So I need to
21 know --
22 MR. SCULLEN: He said he doesn't
23 know and he wasn't in that meeting.
24 MS. TRIVEDI: I'm trying to refresh
25 that if he knows anything.
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1 A I don't know. I don't know anything about
2 that. This is -- I know nothing about why he
3 left.
4 MS. TRIVEDI: For the record, I
5 spoke with Ofir, and he said he wanted to --
6 MR. SCULLEN: Ms. Trivedi, this is
7 the tenth time. This is a deposition. You
8 don't --
9 MS. TRIVEDI: I don't want to have
10 him tell me later that Madhuri said that Ofir
11 was fired, and Ofir got mad when -- I spoke
12 with Ofir, and he told me he that he was not
13 fired --
14 MR. SCULLEN: Please finish asking
15 your questions. You're wasting time at the
16 deposition.
17 MS. TRIVEDI: No. Carl Conrath and
18 Dave Mehring were giving me wrong information
19 about the termination --
20 MR. SCULLEN: You're wasting time.
21 MS. TRIVEDI: -- of a person.
22 MR. SCULLEN: You're wasting time.
23 Please continue.
24 MS. TRIVEDI: All this information I
25 need verify.
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1 MR. SCULLEN: He's already answered
2 the question. You've asked him twice. Move
3 on, please.
4 BY MS. TRIVEDI:
5 Q Do you remember when we broke up with GEIP,
6 Greg got angry at me and he was kind of
7 hostile. I was concerned about this whole
8 behavior that he did. And it was in
9 September, 2012, right after Milwaukee temple
10 shooting, which happened in August, 2012.
11 And you -- I told you to -- I told you
12 about this briefly, and you mentioned that
13 Greg was kind of not speaking for two, three
14 days in all of your coding meetings, and he
15 was just -- something was going on?
16 MR. SCULLEN: Object as compound.
17 A I don't remember details about that. I
18 remember something about you saying something
19 about a GEIP requirement or something that was
20 missed or something, and you asked them to put
21 it in, but Greg thought it should have gone
22 through him or something like that.
23 But that was -- I'm hearing that -- I
24 heard that from you. I don't know that I ever
25 talked to Greg about that, so -- Stuff I heard
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1 from you.
2 Q And that he was -- Because of this
3 disagreement in requirements he had with GEIP,
4 he unnecessarily got angry at me, and
5 basically he was hostile. And I expressed --
6 And you mentioned that he was not talking in
7 all of the meetings where you were present?
8 A I don't know if this was exactly the time, but
9 I have a vague recollection that Greg was not
10 happy the way the GEIP project was going. No
11 one was, because it wasn't meeting our
12 timeline or our needs. And we knew we were --
13 we needed -- we had pressure to get the
14 Questra Back-Office fixed. So that was sort
15 of probably before the time of --
16 Q This was September, 2012, the day when Axeda
17 people came from Boston for a meeting at
18 Milwaukee, those days. And he was -- He --
19 basically because of this requirement,
20 disagreement with GEIP, which I was working
21 on -- he got angry. And I expressed that --
22 And you mentioned that he was not talking in
23 meetings where even you are present.
24 And you kind of mentioned that he -- he's
25 just calm right now, maybe something is going
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1 on inside.
2 A I don't remember enough details about that,
3 but --
4 Q Do you remember you -- and I was concerned
5 that -- I was really concerned about me
6 sitting next to him and his hostile behavior,
7 and you kind of mentioned that he's a dormant
8 volcano. Not kind of, but --
9 A I don't believe I ever said that.
10 Q Can you try to recall? You did say that,
11 that, Be careful, he's a dormant volcano?
12 A I don't believe I ever said that.
13 Q He's not even talking to us in our meetings,
14 so maybe something is going on inside him and
15 maybe, you know, it's -- Something is going
16 on, so it might kind of, you know -- The
17 hostility might reoccur.
18 Given other circumstances though. You
19 know, the actual reason for the angry and
20 hostile behavior could be different. But you
21 find a weak person or weak, you know,
22 opportunity, and then that anger gets
23 diverted, like parent -- child/parent getting
24 that from children when it's like venting it
25 out.
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1 So do you remember we did talk -- Maybe
2 it was before some time --
3 A Like I said again, I don't ever remember
4 saying he was an active volcano --
5 Q Dormant?
6 A -- dormant volcano. The only conversation
7 before this, we might have talked about that
8 at the time, and Greg might have been stressed
9 and quiet because of issues, or they might
10 have been issues at home, I have no idea.
11 But I was asked about this topic from a
12 previous HR person last year, and I used the
13 term, "Nah, he's a teddy bear." He's big.
14 He's a big guy. He's, you know, 300 pounds,
15 whatever. But he's a very calm, likable guy.
16 So when I was asked in the past about my
17 opinion of his personality, it was not dormant
18 volcano. I said, No, he's a teddy bear. I
19 worked with him for 25 years.
20 Q During -- When we spoke after my
21 performance -- around the time of my
22 performance evaluation, you did mention that
23 you had interaction problem and some friction
24 with Greg Stratton in past prior to me. In
25 past you had an occasion where you had issues
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1 with Greg.
2 A I don't remember that.
3 Q You told me that -- That was a diagram I still
4 have. That's fine. I have diagram, but
5 that's okay.
6 A I'm confused. I don't know what that's about.
7 Q You mentioned in the past with Greg Stratton
8 you had interaction problem or there were
9 issues in terms of communication or
10 interpersonal issues.
11 A No, I don't remember that. I've never had
12 problems talking with him, so --
13 MS. TRIVEDI: Can we reconvene?
14 MR. SCULLEN: No.
15 MS. TRIVEDI: I will have to. We
16 will have to.
17 MR. SCULLEN: This is your
18 opportunity -- We've now stayed a half hour
19 past when we said that we would. We've now
20 been here for four hours.
21 MS. TRIVEDI: You can take a
22 deposition up to eight hours.
23 MR. SCULLEN: That's right. But you
24 requested --
25 REPORTER: Can we go off the record
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1 now?
2 MR. SCULLEN: Yes, let's go off the
3 record.
5 BY MS. TRIVEDI:
6 Q Do you remember when Insite ExC was released
7 it was having security -- it failed security
8 test or having security issue when the website
9 was public facing?
10 A Okay. When ExC 5.2 was released? I remember,
11 because ExC was actually my idea a few years
12 before we found a vendor who could do it.
13 Q When it was released first time or along the
14 line, when it was released --
15 A The second major release.
16 Q At the time of Insite ExC release, when it was
17 public facing, it failed a security test or
18 had the security concerns?
19 A Yes.
20 Q And the reason was?
21 A It went through Scabba testing.
22 Q And?
23 A And the results were there were some
24 vulnerabilities we didn't want exposed on the
25 internet, so we did not leave the application
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1 facing the internet. We pulled it inside GE.
2 So the user interface is accessible only
3 from inside GE. The Agent traffic can access
4 from outside GE.
5 Q So any GE employee can -- So were the security
6 issues fixed?
7 A Some were.
8 Q Some weren't?
9 A And one of the big fixes, mitigations for that
10 issue was to not leave the user interface
11 exposed on the internet. We have it only
12 inside GE.
13 Q And some were not fixed? This was one of
14 those?
15 A Some we could fix and some we couldn't because
16 it's a vended application. It's from Questra,
17 so we can't change all of the code.
18 Q So there were security issues in production
19 for Insite ExC, security vulnerability,
20 because -- The reason is different. The
21 reason, Well, you know, that's excuses. But
22 there were --
23 MR. SCULLEN: This is asked and
24 answered. We went over this three hours ago.
25 MS. TRIVEDI: This is a different
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1 question.
2 MR. SCULLEN: No, it's not.
3 BY MS. TRIVEDI:
4 Q Insite ExC in production had security issues.
5 Is that correct? Or have --
6 A The user interface, which is a little bit
7 different, yes, had some security
8 vulnerabilities found during Scabba testing.
9 Our mitigation was several things: One of
10 them was to move the user interface inside GE.
11 Q And also some of them were not fixed. Some of
12 the security were never --
13 A Right, because we could not fix them.
14 Q So some of the security vulnerability still
15 exist today?
16 A Yes.
17 Q So any GE employee inside GE network can
18 potentially try to exploit that vulnerability?
19 A Depends on the vulnerability.
20 Q But it is possible?
21 A But in general, we keep track of who we give
22 accounts to. Most of the vulnerabilities are
23 only exploitable if you have an account and
24 you can log in, and then you start poking at
25 it, you can find problems. If you don't have
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1 an account to log in, which is the vast
2 majority of people in GE, then those
3 vulnerabilities aren't exposed.
4 Q So are you aware of the Snowden incident where
5 he was an insider of NSA, and he very much --
6 A Yes, I'm aware of that.
7 Q -- he very much hacked everything that NSA
8 had?
9 A Yes.
10 Q So is this -- Do you consider that's insider
11 threat detection, and not having proper
12 insider threat detection in place? Its
13 considered insider threat detection, right?
14 GE has lots of employees, and even people
15 can do espionage or people can have several
16 different motives. So you cannot rely that,
17 well, it's inside GE's network, so that's our
18 mitigation strategy. You know, security
19 problems are fixed by moving it from public
20 facing to GE internal website.
21 Given those security issues still exist
22 where an insider can try to potentially -- or
23 can try to exploit those.
24 A What's the question there?
25 MS. TRIVEDI: Can you go back?
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1 MR. SCULLEN: You didn't ask a
2 question, you made a statement.
3 THE WITNESS: What's the question?
4 Are you asking me --
5 MS. TRIVEDI: Can you read that?
6 Now I forgot where I started. I started a
7 question.
8 (Reporter read previous question.)
9 Q Is it considered good security strategy or is
10 it --
11 A To move the interface to the inside?
12 Q And keep those security vulnerability as --
13 A That was one of our only options. We had
14 several things, and we went through the risk
15 analysis with a third-party company at the
16 time. I'm trying to remember their name and I
17 can't. But they did a big security audit of
18 it.
19 We did our own internal source
20 code-assisted black box testing and determined
21 that that was the best way to deploy this
22 application. We already had the application
23 deployed for a couple of years. The user
24 interface was upgraded from 4.1 to 5.2.
25 That's where a lot of the vulnerabilities came
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1 in, so --
2 Q So do you think that engineers were involved
3 and lead technical leads or all -- I will
4 rephrase.
5 So when ExC was developed, do you think
6 that proper security engineering knowledge was
7 needed? What was the reason for not having --
8 Or do you think the engineers were lacking the
9 security skills or --
10 A Well, I was one of the engineers involved in
11 deploying Insite 2 ExC --
12 Q Not developing.
13 A Not developing that. That was done by a
14 third-party company. So we weren't involved
15 in their development. We bought their
16 software and tested it, tested our -- you
17 know, our modifications to it and their
18 software, found the vulnerabilities and
19 decided to deploy it inside our firewall
20 rather than outside of our firewall so that
21 only qualified GE people who had taken
22 training and done all of the right things had
23 access to that system, so --
24 That's a normal security thing to do, and
25 I was involved in that from the beginning
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1 because I'm the connectivity security person.
4 BY MS. TRIVEDI:
5 Q Have you worked for a female boss before?
6 A I don't think I've worked for a female manager
7 before. But I've had female project leaders.
8 Q So those -- You're referring to reporting to
9 those leaders?
10 A So no, they did not do my performance review
11 or I wasn't directly reporting to them. But
12 on the project work, they were managing
13 schedules, doing assignments, but not doing my
14 performance review, so --. Depends what you
15 mean by reporting to them.
16 Q As I mentioned about the gender speak
17 diversity training offered at GE Healthcare
18 for retention of female engineer, do you think
19 that having that training given to managers,
20 peers, including me, could have helped in
21 perceiving and measuring my communication,
22 because that training --
23 MR. SCULLEN: Object as lack of --
24 Q -- that training was completely targeted to
25 address communication and soft skills?
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1 MR. SCULLEN: Ms. Trivedi, he's
2 testified he didn't take the training. He
3 doesn't have knowledge of the reason the
4 training was implemented, and his personal
5 views about what could have happened are both
6 speculative and irrelevant. Move on if you
7 have other questions.
8 BY MS. TRIVEDI:
9 Q So there is a problem. That's why the
10 training was offered?
11 MR. SCULLEN: Object. Same
12 objection.
13 Q Do you think that has an influence on manager
14 and peers behavior; otherwise, if there is no
15 problem, then why would the training be
16 offered?
17 A Like I answered before, I don't know the
18 training class, so I don't believe I took it.
19 I don't know why it was offered.
20 Q Even if you took it, you don't remember.
21 Maybe you took it, but you don't remember.
22 A I doubt I took it, because I don't remember.
23 But I've had 200 classes, and I don't think
24 that one was in there, because I looked at my
25 training record for a different project last
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1 month.
2 Q Do you remember if I ever worked with chief
3 engineer at GST?
4 A I'm sure you did some stuff with Rick, but I
5 don't know the details.
6 Q What stuff? I haven't done that, so that's
7 why I'm --
8 MR. SCULLEN: You're asking him
9 about --
10 MS. TRIVEDI: This is the response,
11 and I haven't. So I need to know who said
12 that.
13 Q So you are a principal engineer, and chief
14 engineer is one level above you. So I want to
15 clarify what -- why that information was
16 there.
17 A I don't know what the information is. Since
18 Rick sits, you know, in our group and is in a
19 lot of design review meetings and things,
20 because he runs technical reviews and stuff,
21 you've probably interacted with him.
22 Q Only for innovation challenge.
23 A Okay. Well, there you go.
24 MR. SCULLEN: He isn't prepared to
25 know beyond that.
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1 MS. TRIVEDI: And that is also
2 asking for deadline--
3 MR. SCULLEN: You're testifying now.
4 You're not asking him a question. He's
5 already testified that he doesn't know beyond
6 what he already said regarding your
7 interactions with Rick.
8 MS. TRIVEDI: So this is here. So I
9 need to know the truth why he came here.
10 Either he said or he heard from someone.
11 MR. SCULLEN: And he said he doesn't
12 know, so it's not him.
13 MS. TRIVEDI: That's funny, it's not
14 him. Okay.
15 Q Do you think it's illegal to treat a female
16 engineer who is raising technical issues where
17 managers and leads didn't have technical
18 skills or technical knowledge?
21 mischaracterizes his testimony, and it's vague
22 as stated.
23 MS. TRIVEDI: It's not vague. It's
24 clear and very concise. We have been
25 discussing this for --
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1 MR. SCULLEN: He didn't testify that
2 the people didn't have technical knowledge,
3 and your question ended with --
4 MS. TRIVEDI: Let me rephrase.
5 Q Do you think it's legal when a female engineer
6 who is brand new or relatively new, raising
7 technical concerns, security vulnerability and
8 those managers, team leads, LSDs who didn't
9 know about this or such technical issues
10 were -- they had technical learning curve to
11 understand and -- to understand this technical
12 issues?
13 A Again, that's not a complete question. You
14 talk about is it illegal. I don't know the
15 law around that aspect, for someone to bring
16 up technical issues when their managers don't
17 have all of the technical background. And
18 then your question ended --
19 There is nothing illegal about an
20 engineer bringing up technical issues or the
21 managers not knowing about technical issues.
22 Q Okay. All right. So do you think is it
23 legal?
24 MR. SCULLEN: Ms. Trivedi, his
25 personal views are totally irrelevant. This
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1 is just not relevant.
2 Q Do you think it's legal to measure a brand new
3 female engineer who was working on a project
4 and raising security and technical issues
5 where managers and leads didn't have prior
6 knowledge of that technical -- or that
7 technology and managers were diverting their
8 lack of technical knowledge in that area by
9 pointing out communication issue where the
10 problem was they didn't have technical
11 knowledge? So do you think is it considered
12 legal where --
13 A I have no idea about the law. It's not my
14 training.
15 Q Is it legal -- Is it fair or is it ethical?
17 facts not in evidence.
18 Q Is it fair?
19 MR. SCULLEN: Same objection.
20 Q You don't know law, if it's illegal. But do
21 you know, is it fair?
22 A Again, I don't know how to answer that
23 question. I'm not even sure what the question
24 is.
25 MR. SCULLEN: Ms. Trivedi, let's
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1 move on. Do you have any other questions?
2 MS. TRIVEDI: Why you don't
3 understand?
4 MR. SCULLEN: First, your question
5 makes a bunch of assumptions that are
6 incorrect.
7 MS. TRIVEDI: We already -- It's not
8 assumption, it's all facts. He already gave
9 testimony about this.
10 MR. SCULLEN: No, it's not.
11 MS. TRIVEDI: He did. You cannot
12 continually object and be overassertive.
14 said. And you can ask him when he said that.
15 MS. TRIVEDI: No. I'm not going to
16 ask him now.
17 MR. SCULLEN: Then move on.
18 MS. TRIVEDI: He's already testified
19 that twice. I have already that.
20 Q Do you think is it legal for managers and
21 peers to perceive and measure a female
22 engineer as a person having a communication
23 skill problem when they didn't have technical
24 knowledge or there was a lack of technical
25 skills in that area for managers and peers?
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1 A I won't answer the legal. But I think I
2 finally found a question in there, to my
3 opinion. Is it okay for someone who doesn't
4 have technical background --
5 Q Not okay. I just want to know whether it's
6 legal or not legal.
7 A I can't answer legal.
8 Q Fair and ethical? Is it fair?
9 A I can say what I think about that hypothetical
10 situation.
11 Q About my hypothetical. I'm not saying --
12 A You have to be more specific about your
13 question.
14 Q Given what happened Insite ExC -- focus on
15 Insite ExC --
16 A Okay.
17 Q I was raising security vulnerability issues,
18 technical quality issues --
19 A Okay.
20 Q I was relatively new, I was learning the
21 product, I was showing initiative and
22 dedication to quality and technical, because
23 when that points to managers, team leads,
24 other engineers, including LSDs, didn't have a
25 prior technical knowledge, nor technical
181
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1 understanding for the work I was doing, is it
2 legal to treat me in a way they treated?
4 to mischaracterizes the facts.
5 MS. TRIVEDI: This is the crux --
6 MR. SCULLEN: He's not -- We're
7 going to end the deposition right now. If you
8 have another question --
9 BY MS. TRIVEDI:
10 Q Is it considered negative treatment or -- or
11 is it fine? Not legal. Do you think that's
12 how it should be?
13 MR. SCULLEN: Objection as to vague.
14 He started to answer your question. If you
15 want an answer to the prior question --
16 MS. TRIVEDI: You don't want him to
17 answer legal or illegal --
18 MR. SCULLEN: I don't understand the
19 question you're asking.
20 MS. TRIVEDI: Is it legal or not
21 legal?
22 MR. SCULLEN: He's not going to
23 answer legal questions.
24 THE WITNESS: I'm not a lawyer.
25 BY MS. TRIVEDI:
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1 Q But you are an engineer?
2 A I can give you my opinion.
3 Q I don't need your opinion.
4 MR. SCULLEN: That's what you're
5 asking him.
6 A That's what you're asking me.
7 MR. SCULLEN: That's all he can give
8 you is his opinion. You keep asking for his
9 opinion, and then when he tries to give it to
10 you, you interrupt.
11 MS. TRIVEDI: I want to know whether
12 it's okay or not.
13 MR. SCULLEN: Either way, that's his
14 opinion.
15 BY MS. TRIVEDI:
16 Q So you don't know the legal laws --
17 A I do not know.
18 Q -- State and Federal laws of these actions?
19 A Correct. I do not know.
20 Q Can I expand? It's considered protected
21 activity --
22 MR. SCULLEN: Let's stop. We're
23 stopping the deposition at this point. You're
24 not asking --
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2 record. Ms. Trivedi, he's testified -- You
3 asked him four times, four different ways
4 about legal questions. He said four different
5 times he can't answer that.
6 MS. TRIVEDI: He's a principal
7 engineer. He's born and raised in U.S.
8 Wouldn't he know about U.S. law?
9 MR. SCULLEN: No, not necessarily.
10 It's not an appropriate question for him. We
11 can do that -- If you want to ask that
12 question, if you think you have a right to ask
13 it, I suggest you raise it with the
14 arbitrator, and we'll deal with it there.
15 We're not going to resolve it here.
16 MS. TRIVEDI: I need to recollect
17 now.
18 REPORTER: We're off the record.
21 record. Ms. Trivedi has indicated she's not
22 prepared at this point to go forward, but she
23 thinks she has 20 more minutes of questions,
24 but she needs more time to write her
25 questions. We have objected to presenting the
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1 witness again. We're prepared to finish the
2 deposition now. So now it's 6:25. We're
3 ending the deposition.
4 (Deposition concluded at 6:25 p.m.)
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
185
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1 STATE OF WISCONSIN)
2 ) SS:
3 COUNTY OF WAUKESHA)
4 I, Beth Zimmermann, a Registered Professional
5 Reporter and Wisconsin Notary Public, certify that
6 WILLIAM BARBIAUX swore under oath to tell the truth,
7 the whole truth, and nothing but the truth, and that I
8 stenographically reported and reduced to typewriting
9 the deposition.
10 I certify that I am neither related to nor an
11 employee of any party or attorney to this action, and
12 I certify that I have no financial interest in the
13 matter.
14
15 Dated March 12, 2014.
16
17
18
19 ______________________________
BETH ZIMMERMANN
20
21
22
23 Court Reporter and Notary Public
24 My Commission Expires 10/21/2017.
25
186
(187 of 291)
' 164:16 A affect [2] - 114:9, 85:8, 87:12, 93:12,

2013 [5] - 14:25, 114:16 108:4, 108:25,
120:12, 121:4, affected [1] - 75:22 139:8, 141:20
'enable [1] - 103:24 122:16, 122:17 ability [3] - 85:3, age [1] - 11:6 analysis [1] - 172:15
2014 [1] - 113:23 149:7, 159:8 Agent [29] - 5:21, analyze [1] - 42:19
1 23 [2] - 136:9, 136:18 able [12] - 11:17, 12:7, 5:22, 13:19, 14:9, analyzer [1] - 42:14
25 [3] - 5:4, 151:7, 17:2, 47:4, 50:3, 14:22, 15:9, 31:15, anger [1] - 165:22
166:19 79:9, 81:9, 85:10, 50:2, 50:3, 50:12, angry [4] - 163:6,
1 [4] - 39:10, 118:2,
29th [2] - 38:11, 38:19 102:24, 103:17, 50:13, 50:21, 53:17, 164:4, 164:21,
118:11, 120:14
2:00 [1] - 100:20 145:1, 145:5 116:7, 125:22, 165:19
10 [5] - 16:25, 73:17,
acceptable [3] - 126:22, 129:17, Anish [1] - 26:22
73:23, 76:23, 121:19
110:4, 111:2, 111:11
10-11 [1] - 121:16 3 accepting [6] - 48:14,
130:22, 132:14, answer [62] - 7:8,
137:21, 138:7, 16:8, 16:15, 17:20,
11-13 [1] - 127:5
49:4, 49:8, 49:20, 138:10, 138:12, 20:20, 21:17, 22:9,
11:30 [1] - 101:8 3-7 [1] - 80:22 57:20, 153:9 139:3, 139:12, 22:10, 23:5, 23:22,
12 [4] - 73:19, 127:9, 30 [3] - 19:20, 143:7, access [3] - 50:3, 140:9, 140:13, 24:2, 29:19, 34:22,
127:16, 127:17 153:24 169:3, 173:23 142:1, 169:3 34:24, 35:18, 36:17,
13 [2] - 127:16, 127:17 300 [2] - 17:1, 166:14 accessible [2] - 53:17, agent [2] - 125:21, 37:14, 38:13, 44:8,
14 [3] - 5:6, 129:25, 3Q [2] - 106:3, 106:6 169:2 128:18 47:3, 47:22, 51:3,
130:2 3rd [3] - 121:6, accommodated [1] - Agents [8] - 15:8, 61:13, 65:6, 67:20,
15 [6] - 5:1, 16:24, 122:16, 122:17 97:24 15:10, 15:17, 31:15, 71:25, 75:6, 82:11,
63:19, 134:10, account [4] - 139:14, 50:16, 116:8, 82:13, 82:23, 87:2,
134:13, 134:15
4 140:23, 170:23, 137:25, 139:20 89:6, 90:23, 91:16,
172 [1] - 134:15 171:1 aggressive [3] - 91:21, 92:2, 93:21,
175 [1] - 134:16 accountability [5] -
4.1 [1] - 172:24 147:1, 155:2, 156:1 94:8, 94:9, 94:11,
1993 [1] - 4:22 17:11, 17:16, 17:24,
4.2 [1] - 134:23 ago [3] - 118:6, 94:17, 95:11, 95:13,
18:12, 18:13 146:17, 169:24 96:20, 97:7, 104:22,
2 465 [5] - 106:17,
accountable [12] - agree [13] - 8:6, 26:1, 105:19, 126:9,
107:25, 119:15,
18:1, 18:4, 18:22, 82:23, 83:2, 83:17, 143:18, 148:13,
137:12, 141:23
2 [5] - 42:10, 107:16, 18:25, 19:5, 22:1, 83:18, 83:20, 83:22, 148:19, 155:12,
4th [1] - 121:4
117:22, 123:25, 23:17, 23:25, 88:6, 99:4, 99:6, 104:17, 160:1, 160:5,
173:11 157:24, 159:7, 156:17 179:22, 181:1,
5 159:10 agreed [3] - 100:19, 181:7, 182:14,
2.0 [1] - 106:1
20 [18] - 5:1, 5:10, 9:5, accounts [1] - 170:22 157:17, 160:9 182:15, 182:17,
29:7, 36:2, 36:5, 5.2 [2] - 168:10, accurate [1] - 47:22 ahead [4] - 16:8, 65:6, 182:23, 184:5
36:7, 36:25, 37:18, 172:24 actions [1] - 183:18 87:1, 143:18 Answer [1] - 84:19
38:6, 38:7, 38:10, 50 [1] - 76:23 active [1] - 166:4 aisle [3] - 27:11, answered [10] - 9:18,
38:15, 63:19, 88:13, 500 [1] - 137:12 ActiveX [12] - 102:10, 49:14, 49:19 15:21, 20:19, 23:23,
88:14, 153:25, 510(k [1] - 108:21 102:21, 102:24, aisles [1] - 27:8 34:14, 34:21, 115:1,
184:23 5:00 [1] - 100:15 103:13, 133:3, Al [6] - 40:2, 40:25, 163:1, 169:24,
200 [4] - 152:13, 5:30 [2] - 100:15, 134:5, 134:20, 41:14, 128:16, 175:17
152:19, 157:21, 100:24 135:2, 135:23, 137:19, 138:6 answering [2] - 87:3,
175:23 138:3, 142:4, 142:7 Alan [15] - 5:9, 32:1, 94:3
2004 [1] - 111:18 6 activities [1] - 79:8 33:24, 36:25, 37:19, answers [8] - 7:21,
2005 [1] - 103:14 activity [2] - 123:11, 42:16, 48:8, 48:14, 23:3, 47:15, 47:16,
2006 [1] - 71:4 183:21 55:1, 90:15, 97:19, 81:18, 82:24, 92:4,
60,000 [1] - 17:3 actual [7] - 45:5, 45:9, 93:3
2007 [1] - 8:4 128:12, 137:13,
6:25 [2] - 185:2, 185:4 45:21, 46:9, 126:23, 144:4 Anthony [1] - 30:7
2008 [1] - 158:25
2010 [2] - 11:21, 12:10 141:15, 165:19 algebra [6] - 86:16, anticipate [3] - 81:4,
2011 [6] - 8:7, 11:21,
8 add [1] - 10:2 86:18, 86:20, 86:21, 85:3, 99:13
12:10, 39:9, 39:22, adding [1] - 9:21 86:23, 86:24 anticipated [3] -
70:15 8 [5] - 100:11, 100:12, additional [1] - 20:10 allowed [1] - 157:14 12:15, 97:24, 99:12
2012 [20] - 9:20, 9:25, 101:16, 102:12, address [1] - 174:25 alone [3] - 34:12, 38:7, anticipating [1] -
14:25, 16:20, 24:11, 102:22 addressed [1] - 139:5 38:8 66:15
34:8, 36:1, 70:16, 8th [1] - 39:9 addressing [4] - 58:1, alternative [3] - 110:5, app [1] - 115:17
70:20, 70:23, 106:6, 71:11, 89:18, 95:4 111:2, 111:12 appeared [1] - 130:25
admire [2] - 150:17, application [18] -
107:1, 111:22, 9 ambition [1] - 156:15
113:12, 120:12, 150:21 ambitious [3] - 154:2, 68:17, 110:8,
120:13, 127:23, advanced [1] - 52:7 154:3, 154:6 115:16, 115:21,
163:9, 163:10, 9 [2] - 101:24, 102:4 advice [1] - 61:2 amount [8] - 23:13, 115:25, 116:1,
1
(188 of 291)
116:2, 116:3, 116:5, Audit [1] - 118:3 142:8, 142:10, 74:22, 76:25, 130:7, bunch [1] - 180:5
116:7, 117:25, audit [15] - 8:4, 148:3, 157:21, 141:19, 155:2, bus [1] - 146:22
118:5, 123:1, 117:21, 117:22, 159:2, 164:14 160:9, 170:6 business [2] - 109:14,
133:23, 168:25, 118:1, 118:3, 118:8, Back-Offices [1] - biweekly [1] - 145:22 147:25
169:16, 172:22 122:13, 123:5, 13:24 black [3] - 86:1, 104:3, busy [1] - 34:2
applications [1] - 123:20, 123:25, background [4] - 172:20 buy [1] - 73:19
133:25 124:5, 124:16, 128:4, 145:13, blame [5] - 24:5, BY [48] - 4:16, 7:12,
appraisal [1] - 144:3 125:1, 172:17 178:17, 181:4 57:10, 57:16, 58:13, 8:20, 13:17, 14:3,
appropriate [5] - auditing [1] - 117:12 bad [2] - 36:6, 145:2 74:14 14:17, 21:22, 23:6,
131:8, 131:15, August [1] - 163:10 Barbiaux [1] - 47:9 blamed [4] - 58:12, 31:9, 34:23, 37:17,
132:6, 158:10, authority [1] - 150:19 base [10] - 11:10, 58:17, 85:12, 85:18 39:19, 47:25, 53:9,
184:10 auto [1] - 80:4 11:12, 11:13, 11:18, blind [1] - 150:20 54:25, 56:22, 58:20,
April [3] - 9:20, 9:25, Auto [1] - 118:3 11:23, 12:16, 12:18, blue [1] - 115:13 62:23, 64:13, 68:25,
71:5 automatically [1] - 15:8, 15:18, 15:19 body [2] - 9:22, 35:3 79:4, 83:21, 95:14,
arbitrator [4] - 20:18, 125:22 based [8] - 7:14, 7:18, book [1] - 156:23 97:12, 99:19,
47:4, 47:11, 184:14 available [3] - 52:4, 7:19, 19:13, 98:14, books [3] - 73:17, 101:17, 107:12,
architect [1] - 32:24 123:16, 123:17 142:9, 142:10 73:19, 73:23 117:1, 121:20,
architecture [2] - avoiding [1] - 95:21 basic [2] - 108:7, borderline [1] - 59:1 125:10, 127:18,
160:20, 160:21 aware [24] - 25:17, 122:1 born [1] - 184:7 129:8, 130:15,
area [5] - 116:13, 25:20, 28:18, 30:23, basis [1] - 123:11 boss [1] - 174:5 132:8, 132:25,
159:5, 160:24, 31:4, 58:17, 59:4, bear [2] - 166:13, Boston [1] - 164:17 143:10, 155:17,
179:8, 180:25 59:5, 65:15, 66:15, 166:18 bought [4] - 112:22, 157:9, 158:12,
argue [1] - 92:2 67:4, 67:14, 77:14, beaten [1] - 58:3 148:1, 173:15 161:10, 163:4,
arguing [2] - 77:22, 78:23, 79:1, 79:6, became [3] - 12:4, box [1] - 172:20 168:5, 170:3, 174:4,
77:24 79:16, 133:12, 89:11, 94:21 brand [4] - 33:20, 175:8, 182:9,
ASCII [1] - 46:20 137:3, 141:4, become [3] - 109:23, 87:9, 178:6, 179:2 182:25, 183:15
aspect [2] - 65:7, 143:19, 171:4, 171:6 112:14, 141:16 break [4] - 10:14, byte [1] - 46:8
178:15 awhile [2] - 6:10 beginning [11] - 7:16, 56:21, 80:19, 125:8 bytes [3] - 45:10,
assertive [1] - 156:1 Axeda [20] - 7:13, 28:18, 76:12, 76:15, breaking [1] - 27:23 46:11, 46:18
assessments [1] - 7:17, 14:19, 15:13, 76:18, 77:10, 78:6, breaks [2] - 41:23,
108:17 15:14, 125:16, 78:12, 130:7, 136:2 C
assets [1] - 148:1 126:10, 126:19, 147:22, 173:25 Brewers [2] - 145:11,
assigned [1] - 57:23 147:9, 147:11, behave [1] - 92:10 145:20 cable [4] - 125:19,
assignment [10] - 4:5, 147:21, 147:22, behavior [9] - 35:3, briefly [2] - 49:5, 128:13, 128:18,
40:8, 40:12, 40:18, 148:2, 148:3, 148:6, 58:22, 66:25, 147:1, 163:12 129:16
59:14, 60:10, 60:11, 148:20, 148:22, 153:3, 163:8, 165:6, bring [4] - 56:2, 69:17, calm [2] - 164:25,
63:8, 89:8, 94:19 149:1, 149:5, 164:16 165:20, 175:14 96:1, 178:15 166:15
assignments [3] - behind [1] - 10:22 bringing [7] - 57:22, cannot [20] - 36:5,
29:3, 154:10, 174:13 B beliefs [1] - 157:1 58:1, 58:6, 60:3, 36:8, 66:8, 66:10,
assisted [1] - 172:20 believes [1] - 157:5 60:16, 92:20, 178:20 73:19, 79:20, 80:8,
associated [1] - best [3] - 7:25, 113:16, broad [1] - 150:21
Back-Office [49] - 86:5, 93:9, 104:11,
140:12 172:21 broke [2] - 10:18,
5:22, 5:23, 11:3, 113:13, 113:16,
assumes [12] - 17:15, better [3] - 109:17, 163:5 115:20, 116:4,
12:5, 13:10, 13:19,
23:21, 37:6, 58:15, 111:6, 148:17 brought [1] - 119:4 117:2, 138:13,
13:23, 14:8, 14:21,
65:4, 67:1, 71:24, between [11] - 25:18, bug [4] - 139:15, 144:23, 171:16,
15:7, 15:14, 15:15,
80:17, 153:11, 65:17, 66:6, 69:6, 140:11, 140:15, 180:11
15:16, 33:3, 114:15,
158:5, 159:12, 69:23, 71:10, 72:17, 140:17 capability [1] - 122:23
114:17, 116:1,
179:16 121:3, 137:19, bugs [9] - 110:19, capture [6] - 43:9,
116:8, 116:10,
assumption [1] - 140:9, 154:7 112:20, 113:16, 43:18, 45:4, 46:7,
116:11, 117:3,
180:8 beyond [3] - 20:9, 113:17, 113:18, 46:10, 48:17
121:23, 133:4,
assumptions [3] - 136:9, 136:17, 176:25, 177:5 119:15, 119:20, captured [1] - 44:5
158:16, 158:17, 137:4, 137:6, big [7] - 19:7, 65:10, 141:7, 141:14 capturing [1] - 45:21
180:5 137:11, 137:24, 156:13, 166:13, build [5] - 84:20, care [1] - 108:15
ATL [1] - 103:11 138:2, 138:5, 166:14, 169:9, 126:21, 126:22, careful [1] - 165:11
attacks [1] - 104:11 138:10, 138:12, 172:17 130:22, 148:23 Carl [4] - 16:18, 16:22,
attacks' [1] - 104:1 138:17, 138:25, Biju [1] - 26:22 built [2] - 103:10, 161:16, 162:17
attend [2] - 107:14, 139:2, 139:13, Bill [1] - 82:4 147:24 Carl's [1] - 18:16
107:15 139:15, 139:19, binary [2] - 48:22, bulk [3] - 111:23, case [15] - 20:18,
audio [2] - 31:24, 140:3, 140:9, 103:1 112:5, 113:11 20:25, 21:12, 47:17,
31:25 140:14, 142:3, bit [9] - 10:22, 64:14, bullet [1] - 109:18
2
(189 of 291)
47:24, 84:21, 87:21, close [4] - 5:10, compare [1] - 43:9 160:25, 161:1 135:21, 137:14,
105:1, 105:3, 111:22, 111:23, compared [3] - 43:2, confirmed [6] - 52:19, 162:23
134:18, 135:8, 117:25 153:23, 154:1 70:3, 70:4, 70:5, continuing [2] - 36:20,
138:24, 146:8, closed [6] - 112:5, comparing [1] - 43:6 120:10, 121:22 100:25
156:18 112:15, 113:11, competent [9] - 30:24, confirming [1] - 62:15 continuous [3] -
cases [7] - 104:20, 113:13, 113:14, 99:15, 99:16, 100:2, conflicts [2] - 25:17, 25:17, 25:19, 25:25
135:5, 135:15, 128:14 106:21, 122:7, 26:1 continuously [2] -
135:21, 138:17, closely [2] - 144:9, 132:5, 156:9, 159:23 conform [1] - 108:20 41:17, 92:15
138:23 144:10 complained [1] - confused [2] - 88:1, contravention [2] -
caught [1] - 56:24 closing [2] - 111:24 119:16 167:6 80:15, 80:16
central [1] - 105:1 clothing [1] - 161:11 complaining [1] - confusing [3] - 65:5, contribution [1] -
certain [3] - 21:5, code [7] - 32:21, 136:7 67:20, 87:1 158:1
23:12, 37:12 46:21, 80:15, complete [2] - 43:20, confusion [1] - 55:24 control [12] - 8:3,
chain [2] - 103:5, 102:25, 112:22, 178:13 connect [6] - 114:18, 19:6, 102:10,
130:24 169:17, 172:20 completely [4] - 116:5, 116:10, 102:21, 102:24,
challenge [1] - 176:22 code-assisted [1] - 119:19, 119:21, 116:11, 117:3, 103:13, 122:13,
challenged [1] - 172:20 148:24, 174:24 128:18 134:20, 135:23,
150:19 coding [1] - 163:14 complex [4] - 47:23, connected [1] - 70:12 142:5, 142:7
challenges [1] - 85:1 cold [5] - 53:7, 61:20, 53:20, 65:5, 67:19 connecting [5] - controls [3] - 103:10,
chance [1] - 145:6 62:8, 72:5, 95:20 compound [6] - 7:8, 109:3, 117:10, 117:21, 138:3
changed [11] - 11:1, collect [1] - 123:2 17:14, 27:23, 60:22, 133:3, 133:15, convenient [3] -
18:7, 18:8, 24:6, collects [1] - 118:1 143:18, 163:16 138:12 123:21, 123:24,
42:7, 42:8, 45:2, coming [3] - 145:10, compromise [1] - 64:3 connection [1] - 123:4 124:23
48:3, 93:20, 148:21 145:19, 156:2 computer [4] - 43:15, connections [1] - 11:9 conversation [12] -
changes [3] - 28:24, comment [4] - 10:16, 43:16, 43:20, 120:23 connectivity [8] - 35:5, 37:9, 48:7,
69:12, 78:20 129:23, 131:9, concern [6] - 48:13, 104:14, 111:6, 63:6, 72:14, 89:12,
changing [7] - 28:22, 139:18 89:19, 95:4, 118:16, 111:8, 125:13, 90:19, 94:23, 96:1,
41:17, 42:6, 77:25, comments [1] - 56:14 118:20, 153:1 132:15, 133:13, 146:15, 146:23,
87:22, 88:13, 92:23 common [1] - 156:22 concerned [5] - 63:25, 145:25, 174:1 166:6
check [2] - 71:1, communicate [5] - 73:24, 163:7, 165:4, connects [1] - 124:13 conversations [5] -
104:10 74:18, 95:22, 153:7, 165:5 Conrath [3] - 16:18, 27:6, 49:23, 65:13,
chief [2] - 176:2, 153:8, 156:11 concerning [2] - 161:16, 162:17 153:16
176:13 communicated [2] - 51:13, 142:14 consider [5] - 57:2, convey [1] - 119:6
child/parent [1] - 86:13, 121:22 concerns [12] - 60:18, 68:5, 73:10, 97:21, cooperation [2] -
165:23 communicating [6] - 61:23, 62:9, 62:10, 171:10 55:2, 62:11
children [1] - 165:24 61:11, 69:14, 86:11, 63:23, 75:10, 90:1, consideration [1] - cooperative [1] -
choice [1] - 160:23 95:19, 96:3, 157:16 90:3, 95:19, 119:6, 141:7 55:14
chose [1] - 146:1 communication [38] - 168:18, 178:7 considered [24] - copy [3] - 107:1,
circumstances [5] - 28:12, 28:20, 61:15, concise [3] - 29:3, 11:19, 50:22, 51:16, 120:24, 152:12
18:8, 19:3, 24:3, 65:20, 69:6, 69:23, 29:11, 177:24 52:1, 56:9, 56:10, copying [2] - 16:22,
58:21, 165:18 72:22, 73:2, 74:14, conclude [1] - 131:16 58:24, 66:23, 68:14, 45:20
clarify [7] - 31:5, 75:20, 75:21, 75:24, concluded [1] - 185:4 69:18, 71:14, 71:15, core [15] - 5:16, 5:17,
34:19, 40:13, 56:21, 76:5, 83:4, 84:15, concluding [1] - 23:7 73:2, 73:12, 108:24, 5:18, 5:24, 6:9, 17:6,
78:2, 101:18, 176:15 85:12, 85:22, 86:4, conclusion [3] - 109:6, 110:4, 139:9, 23:11, 26:15, 26:16,
clarifying [1] - 36:19 86:12, 86:19, 87:6, 21:23, 98:15, 122:3 153:25, 171:13, 26:17, 26:20, 27:5,
class [1] - 175:18 87:10, 87:14, 87:17, conducting [1] - 128:1 172:9, 179:11, 76:14, 78:17, 144:1
classes [3] - 152:13, 88:6, 88:19, 88:22, confident [2] - 59:1, 182:10, 183:20 Corporation [1] -
152:19, 175:23 88:24, 89:10, 94:21, 156:1 considering [1] - 148:2
classified [1] - 115:12 96:8, 150:24, 153:4, configuration [1] - 67:24 correct [28] - 8:1,
Clear [1] - 63:7 167:9, 174:21, 56:5 consolidating [1] - 8:10, 22:8, 29:4,
clear [13] - 12:4, 22:6, 174:25, 179:9, configured [4] - 111:5 42:24, 43:8, 43:12,
24:5, 29:1, 29:3, 180:22 50:17, 54:2, 54:7, contest [1] - 82:25 44:1, 44:2, 54:18,
29:10, 41:15, 91:13, Communication [2] - 54:10 context [2] - 32:23, 68:12, 77:18, 79:15,
91:25, 92:1, 93:3, 6:20, 158:23 configures [1] - 56:6 68:8 79:16, 81:15, 81:17,
93:14, 177:24 company [13] - 15:12, confirm [16] - 28:10, continually [2] - 83:5, 84:5, 84:10,
clearance [1] - 108:21 15:13, 33:21, 60:16, 52:23, 79:5, 79:9, 41:23, 180:12 85:5, 104:16, 114:7,
clearly [6] - 41:6, 90:8, 84:21, 109:13, 79:20, 80:8, 120:7, continue [13] - 20:8, 122:21, 126:6,
91:3, 91:10, 93:2, 147:20, 153:24, 122:10, 122:11, 22:18, 23:5, 82:6, 129:21, 130:11,
108:9 156:9, 172:15, 123:23, 124:1, 92:6, 92:8, 94:9, 170:5, 183:19
client [1] - 138:14 173:14 131:7, 132:9, 157:3, 95:9, 95:10, 105:21, correctly [1] - 126:18
3
(190 of 291)
correlated [2] - Dave [26] - 4:24, defend [1] - 67:23 10:24, 27:4, 78:22, 145:9, 147:6,
154:16, 154:17 17:22, 21:8, 23:8, defending [1] - 84:20 78:23, 78:25, 79:3, 151:24, 152:11,
cost [1] - 20:10 23:10, 25:2, 25:4, definitely [1] - 21:10 101:20, 108:5, 153:7, 165:20,
counsel [1] - 92:14 26:21, 58:23, 61:18, delay [1] - 17:5 121:11, 123:12, 169:20, 169:25,
counting [1] - 9:22 64:18, 65:14, 75:9, delayed [2] - 12:14, 123:13, 125:24, 170:7, 171:16,
couple [6] - 11:5, 75:13, 88:17, 89:17, 16:11 126:12, 126:14, 175:25, 184:3, 184:4
60:15, 111:19, 90:18, 95:2, 95:23, delegate [1] - 17:8 132:13, 134:7, differentiate [2] -
116:15, 118:12, 96:6, 97:17, 98:5, delete [1] - 80:3 142:17, 142:19, 66:6, 85:10
172:23 136:8, 144:17, deliver [2] - 18:16, 142:21, 143:3, differently [7] - 19:12,
course [3] - 52:13, 161:16, 162:18 23:14 143:19, 143:20, 46:3, 54:7, 57:17,
61:3, 124:14 Dave's [2] - 101:3, delivered [3] - 16:1, 143:21, 143:25, 57:18, 96:19, 96:24
court [3] - 4:11, 22:12, 129:4 23:15, 159:6 163:17, 165:2, 176:5 differs [1] - 91:24
38:25 Davis [7] - 5:5, 17:22, delivering [1] - 31:20 detect [1] - 115:22 difficult [2] - 61:16,
covered [1] - 136:25 23:10, 24:16, 26:22, delivery [1] - 16:11 detection [3] - 171:11, 90:7
covers [1] - 135:2 32:17, 32:24 Denise [1] - 134:19 171:12, 171:13 difficulties [10] - 4:2,
crashing [1] - 103:11 day-to-day [4] - 6:9, DEP [2] - 103:11, deteriorating [1] - 26:4, 26:7, 26:24,
create [1] - 104:25 26:12, 78:22, 79:8 103:12 12:6 54:9, 55:24, 72:16,
created [4] - 133:2, days [14] - 35:7, 36:2, deploy [2] - 172:21, determined [1] - 74:25, 75:1, 75:12
133:6, 134:18, 36:5, 36:25, 37:18, 173:19 172:20 difficulty [10] - 11:3,
134:25 38:6, 38:7, 38:10, deployed [1] - 172:23 develop [3] - 12:11, 54:1, 64:17, 64:22,
creating [1] - 20:10 38:15, 70:16, deploying [1] - 173:11 76:19, 141:8 65:25, 67:8, 69:5,
criteria [3] - 16:4, 110:15, 146:17, depose [1] - 91:18 developed [2] - 42:16, 69:7, 69:13, 69:19
17:4, 17:5 163:14, 164:18 deposition [27] - 23:3, 173:5 diligently [2] - 61:23,
critical [1] - 93:19 deadline [1] - 177:2 36:17, 67:24, 68:11, developing [7] - 90:1
crux [2] - 67:21, 182:5 deal [2] - 141:17, 68:24, 81:19, 82:6, 11:14, 12:13, 45:19, dinged [1] - 85:25
culpable [3] - 64:23, 184:14 82:10, 82:14, 82:20, 118:25, 137:9, Dipti [42] - 30:8, 31:11,
74:2, 74:3 decade [1] - 66:17 82:22, 91:16, 92:7, 173:12, 173:13 32:10, 33:25, 35:13,
curious [1] - 33:9 December [9] - 36:1, 93:17, 100:19, development [5] - 36:25, 37:19, 39:8,
current [4] - 7:13, 38:17, 39:9, 39:22, 100:25, 105:14, 31:14, 129:15, 40:13, 41:14, 41:20,
7:17, 140:22, 151:25 70:15, 111:22, 106:12, 132:6, 139:21, 157:22, 42:17, 48:1, 48:2,
Current [1] - 121:23 113:12, 120:12 140:2, 162:7, 173:15 48:7, 48:14, 49:19,
Curt [7] - 34:8, 40:3, decent [1] - 149:8 162:16, 167:22, device [16] - 33:2, 55:1, 89:3, 89:6,
52:19, 70:15, 70:19, decided [1] - 173:19 182:7, 183:23, 33:4, 108:3, 108:19, 89:18, 90:13, 91:5,
70:21, 71:4 decision [1] - 10:13 185:2, 185:3 108:20, 108:22, 94:14, 94:17, 95:3,
curve [3] - 66:5, dedication [1] - Deposition [1] - 185:4 114:10, 114:18, 96:13, 97:6, 97:10,
84:12, 178:10 181:22 depositions [2] - 20:9, 115:15, 116:7, 97:15, 97:19,
default [1] - 51:13 92:9 116:9, 117:2, 123:4, 127:25, 128:10,
customer [2] - 110:16,
defect [10] - 114:17, describe [2] - 28:10, 132:21, 133:4, 128:11, 128:15,
110:19
115:8, 115:11, 102:8 137:21 128:16, 130:25,
customers [6] - 118:2,
126:23, 130:17, description [3] - devices [6] - 17:3, 138:7, 161:11
118:18, 123:17,
132:10, 132:18, 30:16, 30:17, 32:20 108:9, 109:3, 116:4, Dipti's [1] - 127:24
124:17, 136:6,
137:23, 139:8, design [9] - 17:8, 133:16, 137:16 direct [2] - 4:5, 29:2
136:13
141:23 31:21, 32:21, diagnose [1] - 110:12 directed [1] - 134:22
cut [1] - 45:7
defective [1] - 113:25 106:17, 107:18, diagram [2] - 167:3, direction [12] - 10:9,
defects [32] - 107:19, 167:4 10:10, 10:11, 11:1,
D 108:4, 108:12,
dictates [1] - 103:3 18:7, 18:8, 24:6,
108:9, 109:1, 109:5, 159:4, 176:19
109:9, 109:11, designer [2] - 31:18, difference [4] - 65:17, 29:9, 29:15, 42:8,
Dahan [2] - 161:14, 109:20, 109:24, 33:1 71:9, 137:19, 139:24 77:11, 78:20
161:17 110:1, 110:8, designers [1] - 30:2 differences [3] - directly [5] - 35:2,
daily [4] - 7:22, 89:1, 110:24, 110:25, designing [1] - 120:14 72:16, 153:6, 153:9 114:24, 119:11,
94:12, 123:11 111:7, 111:23, different [40] - 15:5, 146:12, 174:11
desk [3] - 27:14,
damn [1] - 88:11 112:24, 113:11, 22:23, 28:17, 29:7, disabled [2] - 118:5,
49:14, 118:10
data [2] - 123:7, 114:1, 114:8, despite [3] - 112:4, 30:3, 31:16, 39:12, 122:24
124:22 114:13, 114:15, 157:23, 157:25 40:11, 43:24, 45:14, disagreement [2] -
database [2] - 123:7, 115:4, 137:12, detail [9] - 10:10, 47:3, 46:15, 52:14, 52:16, 164:3, 164:20
123:20 139:4, 139:8, 47:5, 47:10, 52:20, 55:21, 65:22, 70:12, disagreements [1] -
date [4] - 8:5, 14:12, 139:11, 140:24, 90:9, 90:25, 124:7, 74:10, 81:9, 93:23, 27:2
70:21, 107:17 141:20, 141:21, 160:20 112:18, 117:13, disconnect [3] -
dated [3] - 38:14, 141:22, 142:2, 119:21, 133:24, 125:19, 128:13,
Details [1] - 160:18
121:4, 121:5 157:22 135:20, 140:1, 128:17
details [28] - 6:3,
4
(191 of 291)
disconnecting [1] - 136:9, 136:18, eight [1] - 167:22 152:22, 152:25, ExC [94] - 4:7, 4:18,
129:16 136:20, 136:24, either [11] - 49:5, 154:8, 156:8, 5:16, 5:18, 7:2, 8:8,
discovered [1] - 52:13 138:4, 138:5, 139:19 64:18, 79:24, 91:7, 156:10, 173:2, 8:9, 11:2, 11:10,
discovery [1] - 22:15 downtime [1] - 110:20 91:8, 92:25, 101:1, 173:8, 173:10, 13:25, 14:6, 14:8,
discriminating [1] - dozens [2] - 9:2 129:6, 149:23, 181:24 14:9, 14:21, 15:6,
157:6 drag [1] - 35:16 177:10, 183:13 English [2] - 46:13, 15:8, 15:10, 15:15,
discussed [2] - 11:24, drawings [1] - 120:5 elaborate [1] - 115:24 46:21 28:16, 29:6, 31:14,
146:19 drilling [1] - 92:18 elaborating [5] - Enterprise [3] - 5:20, 32:5, 32:25, 33:8,
discussing [2] - 60:7, drive [2] - 145:9, 89:14, 89:20, 94:25, 11:2, 142:9 33:13, 33:19, 39:25,
177:25 159:3 95:5, 148:7 entire [3] - 19:5, 42:12, 44:24, 50:1,
discussion [26] - 4:15, dump [2] - 45:9, 48:22 Elario [1] - 136:8 20:21, 145:21 50:13, 50:16, 50:21,
7:4, 13:3, 39:18, during [6] - 21:7, 40:4, employee [3] - entirely [1] - 8:1 54:5, 81:2, 83:3,
40:15, 41:6, 46:24, 50:2, 59:23, 166:20, 150:17, 169:5, environment [6] - 83:6, 83:7, 84:10,
49:16, 49:17, 53:8, 170:8 170:17 64:1, 85:11, 104:24, 84:14, 84:17, 84:23,
54:24, 63:14, 65:9, duty [1] - 58:1 employees [1] - 140:7, 141:21, 84:25, 85:7, 85:13,
96:5, 101:13, dynamics [3] - 27:22, 171:14 141:22 87:5, 87:21, 89:2,
102:15, 118:23, 35:15, 35:19 employment [1] - environments [1] - 89:11, 94:13, 94:22,
120:9, 120:15, 47:13 142:6 96:17, 104:12,
104:14, 107:19,
132:24, 134:10, E EMS [2] - 74:15, equipment [2] -
108:19, 111:7,
136:12, 161:9, 157:13 110:23, 124:15
174:3, 183:25, enable [1] - 104:6 erase [1] - 8:7 112:8, 116:2,
184:19 e-mail [36] - 36:4, error [2] - 104:1, 104:2 117:12, 117:18,
enabled [1] - 103:12
discussions [7] - 39:8, 39:13, 39:23, escalated [1] - 104:21 118:15, 119:7,
encompassed [1] -
48:23, 48:24, 59:8, 102:22, 103:6, 122:4, 122:8,
78:15 espionage [1] -
60:2, 64:16, 118:21, 103:21, 105:12, 125:11, 125:17,
encountered [1] - 171:15
136:14 120:7, 120:22, 129:9, 130:19,
134:22 establish [4] - 100:1,
distinguish [1] - 154:7 121:3, 121:5, 133:2, 133:14,
end [6] - 16:1, 20:20, 106:11, 106:22,
diversity [2] - 152:5, 121:13, 121:21, 136:9, 136:17,
25:11, 109:23, 107:6
174:17 122:6, 122:19, 137:4, 137:6, 137:8,
142:18, 182:7 estimating [1] - 76:24
128:10, 128:11, 137:15, 138:9,
diverted [2] - 71:12, end-of-year [1] - ethical [2] - 179:15,
128:12, 128:15, 140:6, 147:12,
165:23 25:11 181:8
128:16, 129:4, 147:20, 147:23,
diverting [1] - 179:7 ended [2] - 178:3, evaluated [2] - 30:15,
129:19, 129:23, 147:24, 168:6,
doc [2] - 134:23, 136:3 178:18 157:12
130:10, 130:24, 168:10, 168:11,
document [14] - ending [1] - 185:3 evaluation [3] - 24:15,
131:3, 131:5, 168:16, 169:19,
22:13, 31:21, 39:4, Energy [1] - 17:1 158:8, 166:22
131:13, 131:19, 170:4, 173:5,
100:2, 106:16, engineer [33] - 6:2, eventually [2] - 76:2,
136:6, 136:7, 136:11 173:11, 181:14,
106:20, 106:25, 7:22, 9:7, 10:8, 148:25
e-mailed [2] - 100:9, 181:15
107:7, 133:1, 133:5, 19:20, 29:14, 29:16, evidence [18] - 23:21,
129:1 except [1] - 160:12
133:10, 133:18, 29:24, 30:19, 45:17, 37:7, 58:16, 65:5,
e-mailing [1] - 101:8 excuses [1] - 169:21
133:21 45:18, 61:24, 71:22, 67:2, 67:18, 71:25,
e-mails [3] - 128:6, execute [2] - 43:16,
documentation [1] - 96:23, 110:14, 80:18, 153:12,
128:21, 129:2 43:17
31:19 110:15, 114:20, 158:6, 158:7,
early [11] - 6:5, 6:6, execution [1] - 31:23
documents [2] - 51:3, 149:8, 153:22, 159:12, 159:14,
6:7, 10:8, 10:9, exhibit [6] - 38:22,
143:1 154:5, 155:22, 159:15, 159:19,
10:11, 77:10, 78:18, 39:1, 39:5, 121:14,
done [21] - 36:13, 158:13, 174:18, 159:21, 179:17
78:20, 111:19, 127:9, 127:14
38:4, 44:14, 45:20, 176:3, 176:13, evidenced [1] - 65:21
142:17 Exhibit [15] - 39:10,
46:2, 46:3, 48:12, 176:14, 177:16, evident [2] - 89:11,
easily [1] - 135:14 42:10, 80:21,
49:7, 72:14, 92:11, 178:5, 178:20, 94:22
easy [1] - 122:20 100:11, 101:16,
96:17, 96:18, 96:24, 179:3, 180:22, evolve [1] - 13:14
98:3, 110:7, 140:1, edited [7] - 133:5, 101:24, 102:4,
183:1, 184:7 exact [5] - 10:24,
140:2, 173:13, 133:7, 133:10, 121:16, 121:19,
engineering [12] - 18:10, 64:6, 77:12,
173:22, 176:6 133:20, 134:4, 135:1 127:5, 129:25,
18:20, 46:5, 46:9, 107:17
dormant [5] - 165:7, educate [1] - 74:18 130:2, 134:10,
47:10, 47:13, 66:16, exactly [11] - 5:8, 9:3,
165:11, 166:5, educating [3] - 73:15, 134:13, 134:15
71:15, 71:21, 9:6, 9:25, 32:6,
166:6, 166:17 73:16, 153:5 Exhibits [1] - 127:15
108:25, 109:6, 59:14, 88:20, 117:8,
doubt [2] - 151:22, education [1] - 57:5 exist [5] - 113:5,
109:7, 173:6 148:25, 152:19,
175:22 effect [1] - 109:19 engineers [19] - 17:6, 113:6, 119:7,
164:8
down [12] - 4:11, effective [2] - 150:9, 17:9, 53:14, 116:2, 170:15, 171:21
example [5] - 88:23,
56:21, 92:19, 150:13 133:14, 133:22, existed [4] - 28:11,
110:11, 144:12,
108:11, 110:16, effort [1] - 148:5 152:6, 152:8, 28:20, 79:10, 117:17
154:1, 161:19
5
(192 of 291)
existing [17] - 11:2, facts [15] - 23:21, 79:14, 92:24, 93:21, fits [1] - 47:24 55:21
11:9, 11:18, 11:23, 37:7, 58:15, 65:5, 168:11 five [2] - 90:24, 91:1 funny [1] - 177:13
12:12, 12:16, 12:17, 67:1, 67:17, 71:25, field [6] - 51:6, 110:14, fix [13] - 40:8, 40:19, future [3] - 11:14,
13:18, 13:19, 14:8, 80:18, 153:12, 110:15, 114:20, 112:21, 112:23, 15:17, 66:11
14:21, 114:1, 114:6, 158:6, 158:17, 133:14, 138:1 113:2, 113:13, fuzzy [1] - 104:3
140:24, 141:7 159:12, 179:17, fights [3] - 25:18, 113:16, 114:3,
expand [1] - 183:20 180:8, 182:4 26:2, 26:5 119:18, 132:18, G
expect [2] - 36:8, factual [1] - 79:11 figure [13] - 35:14, 136:2, 169:15,
57:17 fail [2] - 16:13, 137:18 40:17, 55:7, 57:8, 170:13
game [1] - 145:20
expectation [2] - failed [11] - 16:3, 16:5, 59:15, 60:9, 63:8, fixed [8] - 117:7,
89:7, 94:18, 98:8, GE [46] - 5:12, 15:25,
28:12, 28:21 18:6, 66:13, 129:20, 119:20, 126:24,
130:25, 131:12, 126:25, 127:2, 136:2 164:14, 169:6, 16:4, 16:6, 17:1,
expected [1] - 12:1
131:21, 132:3, figured [1] - 54:15 169:13, 170:11, 19:8, 21:1, 21:23,
expensive [1] - 73:20
168:7, 168:17 171:19 23:15, 25:18, 26:9,
experience [5] - figuring [1] - 57:9
27:1, 36:13, 37:22,
19:20, 28:5, 39:20, failing [1] - 128:19 fill [3] - 24:19, 24:22, fixes [1] - 169:9
38:4, 60:2, 66:2,
146:24, 159:5 fails [2] - 18:21, 40:6 25:2 fixing [3] - 41:15,
68:14, 110:11,
experiencing [1] - failure [2] - 18:5, filled [2] - 144:18, 90:3, 113:4
112:19, 116:3,
115:14 18:24 145:3 flexible [1] - 97:23
124:13, 136:1,
expert [9] - 52:18, fair [6] - 74:13, filling [1] - 145:2 FMEA [1] - 32:22
151:10, 151:17,
52:24, 53:1, 70:4, 179:15, 179:18, final [4] - 24:25, 144:5, focus [4] - 7:22,
152:5, 152:22,
70:5, 70:6, 71:3 179:21, 181:8 144:13, 144:23 113:20, 137:20,
152:24, 156:9,
expertise [1] - 160:24 fairly [1] - 144:9 finally [1] - 181:2 181:14
159:6, 160:12,
explain [4] - 115:24, familiar [10] - 6:8, fine [33] - 4:24, 9:17, follow [3] - 12:24,
161:14, 169:1,
117:14, 147:17, 107:7, 116:13, 11:17, 13:7, 27:13, 47:4, 151:14
169:3, 169:4, 169:5,
157:3 119:12, 124:21, 33:6, 40:21, 43:14, followed [1] - 69:20
169:12, 170:10,
explained [1] - 16:24 133:1, 133:5, 133:9, 44:2, 44:16, 48:11, force [2] - 47:21, 93:9
170:17, 171:2,
exploit [2] - 170:18, 143:24, 146:21 49:10, 50:1, 55:22, foresight [1] - 29:2
171:14, 171:20,
171:23 far [4] - 11:25, 32:15, 57:4, 57:12, 59:10, forget [1] - 109:21 173:21, 174:17
exploitable [1] - 127:3, 143:24 61:15, 68:24, 83:1, forgot [2] - 31:24, GE's [1] - 171:17
170:23 fashion [1] - 92:10 83:22, 98:6, 102:18, 172:6 geared [1] - 153:5
Explorer [2] - 102:12, faster [1] - 12:6 105:23, 106:23, forgotten [1] - 37:11
GEHC [1] - 134:15
102:22 fault [2] - 24:9, 74:20 138:1, 144:2, form [2] - 22:7, 62:5
GEIP [47] - 5:17, 5:24,
expose [2] - 160:2 FDA [9] - 8:2, 8:4, 9:9, 153:19, 156:15, forth [1] - 72:2 6:7, 6:22, 9:22, 10:5,
exposed [4] - 150:20, 65:3, 73:25, 108:2, 157:14, 158:13, forum [1] - 105:2 10:6, 10:14, 10:18,
168:24, 169:11, 108:5, 108:8, 108:21 167:4, 182:11 forward [2] - 15:9, 10:21, 11:8, 11:11,
171:3 feature [7] - 115:10, finish [18] - 22:11, 184:22 11:17, 12:4, 12:7,
express [2] - 36:15, 117:12, 124:9, 24:1, 38:13, 51:2, foundation [2] - 12:11, 14:2, 14:18,
59:16 124:10, 126:2, 67:10, 75:6, 75:7, 41:13, 149:16 15:22, 16:5, 16:9,
expressed [10] - 126:4, 130:20 81:1, 81:10, 90:22, Foundation [2] - 6:20, 25:18, 26:18, 26:25,
48:13, 49:3, 59:19, features [4] - 115:20, 94:3, 115:19, 121:7, 158:24 27:16, 28:3, 29:6,
59:21, 64:17, 98:13, 117:13, 118:15, 148:8, 148:13, four [4] - 167:20, 78:14, 78:16, 79:5,
118:16, 119:10, 118:17 148:19, 162:14, 184:3, 184:4 142:15, 143:21,
164:5, 164:21 Federal [1] - 183:18 185:1 French [1] - 46:13 147:10, 147:16,
expressing [3] - feedback [5] - 24:18, finishing [1] - 75:1 friction [1] - 166:23 147:18, 147:23,
60:18, 75:10, 95:18 25:4, 25:11, 144:8, fired [3] - 161:17, friendly [1] - 45:11 148:22, 149:1,
extent [4] - 17:16, 144:20 162:11, 162:13 front [3] - 121:2, 157:21, 159:2,
59:7, 91:23, 127:2 feelings [1] - 36:16 firewall [2] - 173:19, 138:19, 156:2 160:15, 160:23,
eye [1] - 51:11 felt [2] - 38:1, 161:12 173:20 frustrated [2] - 63:9, 163:5, 163:19,
eye-opening [1] - female [22] - 152:6, firewalls [1] - 69:12 118:19 164:3, 164:10,
51:11 152:7, 152:8, first [21] - 9:11, 10:23, frustration [1] - 59:16 164:20
152:22, 152:25, 16:10, 16:12, 35:23, full [1] - 22:21 Gen [2] - 118:11,
F 153:7, 153:22, 53:18, 74:23, 76:18,
fully [2] - 31:12, 102:9 120:14
154:5, 154:8, 77:9, 77:17, 78:5,
function [3] - 80:3, gender [3] - 152:4,
154:13, 154:21, 83:2, 88:5, 93:23,
facing [5] - 115:15, 118:18, 122:25 152:5, 174:16
155:21, 155:24, 99:25, 109:4,
168:9, 168:17, functional [1] - 30:1 general [9] - 31:14,
174:5, 174:6, 174:7, 111:21, 130:7,
169:1, 171:20 functionality [1] - 44:4, 48:11, 55:19,
174:18, 177:15, 159:11, 168:13,
fact [1] - 159:1 120:20 118:21, 118:23,
178:5, 179:3, 180:21 180:4
functioning [2] - 134:18, 136:7,
factors [2] - 18:3, females [1] - 153:1 fiscal [1] - 106:25
120:3, 129:17 170:21
139:25 few [6] - 36:6, 79:13, fit [1] - 47:17
fundamentally [1] - generates [1] - 118:1
6
(193 of 291)
generation [1] - 12:11 102:23, 105:1, 142:20, 142:24 67:25, 68:5, 68:15, 161:12
generic [1] - 44:23 132:10, 176:18 heard [10] - 26:11, 163:7, 164:5, 165:6, incident [1] - 171:4
gist [1] - 11:16 grow [3] - 154:2, 35:8, 36:19, 42:9, 165:20 include [3] - 13:18,
given [30] - 21:17, 154:4, 154:5 44:6, 49:15, 79:13, hostility [1] - 165:17 14:20, 39:12
33:18, 52:1, 58:21, grudges [2] - 151:12, 163:24, 163:25, hour [2] - 101:3, included [2] - 42:17,
58:24, 60:14, 64:1, 151:21 177:10 167:18 130:10
81:2, 81:5, 81:6, GST [22] - 4:21, 4:22, hearing [2] - 82:21, hours [4] - 110:15, includes [1] - 123:3
82:16, 85:8, 93:12, 5:2, 6:12, 6:17, 6:22, 163:23 167:20, 167:22, including [13] - 50:4,
97:5, 111:11, 7:10, 9:20, 10:20, heavily [2] - 6:17, 7:17 169:24 58:23, 59:17, 69:9,
114:13, 138:24, 14:20, 15:24, 17:6, held [11] - 18:1, 18:25, HR [1] - 166:12 72:25, 73:10, 74:16,
138:25, 139:1, 53:13, 60:14, 60:24, 19:5, 22:1, 23:17, hum [4] - 5:19, 10:7, 80:3, 84:2, 84:11,
139:3, 139:7, 111:22, 132:10, 23:24, 85:11, 88:6, 18:18, 50:5 90:18, 174:20,
141:20, 143:11, 136:6, 147:9, 157:23, 159:7, human [2] - 45:11, 181:24
147:10, 157:24, 158:24, 176:3 159:10 48:20 inclusive [1] - 38:3
158:25, 165:18, guess [1] - 95:23 helicopter [3] - 99:23, hundred [3] - 107:24, incorrect [3] - 22:7,
171:21, 174:19, guessing [1] - 27:6 121:8 135:5, 135:14 43:12, 180:6
181:14 guide [4] - 133:18, HeliOS [2] - 50:2, hundreds [3] - 79:2, incur [1] - 20:10
Glyn [6] - 103:7, 133:22, 134:1, 129:9 109:1, 140:20 independent [2] -
103:20, 104:7, 135:19 help [21] - 12:7, 20:25, hypothetical [6] - 87:15, 87:17
105:2, 105:18 guideline [1] - 108:2 33:11, 33:14, 33:16, 21:20, 58:15, 96:21, indicate [2] - 35:1,
goal [12] - 11:19, guidelines [3] - 37:22, 33:17, 35:4, 40:3, 156:7, 181:9, 181:11 35:2
11:22, 12:15, 16:17, 108:6, 108:8 40:4, 41:1, 75:9, indicated [3] - 100:14,
16:19, 16:20, 18:16, guy [3] - 74:10, 92:17, 101:18, I 100:16, 184:21
18:19, 19:8, 19:13, 166:14, 166:15 101:23, 103:25, indication [1] - 35:23
21:24, 160:3 105:2, 134:1, 151:3, indirectly [3] - 35:2,
iCenter [4] - 118:7,
goals [3] - 16:18, 19:9, H 154:10
123:1, 123:9, 123:17
57:22, 114:24
24:7 helped [6] - 4:9, 4:19, individual [2] - 31:6,
Gran [1] - 34:8 8:8, 45:16, 128:13, idea [10] - 24:12,
156:14
great [6] - 52:11, hack [4] - 44:10, 174:20 24:14, 27:18, 68:9,
individuals [7] -
52:12, 154:21, 44:12, 44:13, 48:11 helpful [1] - 121:24 107:22, 108:7,
17:25, 23:12, 25:6,
154:22, 155:7, hackable [2] - 66:8, helping [2] - 21:7, 109:4, 166:10,
26:9, 39:21, 49:3,
155:15 66:13 37:5 168:11, 179:13
72:25
Greg [58] - 5:3, 5:11, hacked [1] - 171:7 helps [1] - 110:11 ideal [4] - 43:2, 43:4,
industrywide [1] -
17:22, 23:10, 24:10, hacking [1] - 44:11 43:10, 50:6
hesitant [1] - 92:25 156:22
24:16, 26:21, 27:7, half [4] - 14:13, 14:14, identification [9] -
hex [6] - 45:9, 46:8, infer [1] - 43:22
27:11, 32:16, 32:25, 14:15, 167:18 39:10, 42:10, 80:22,
46:10, 46:11, 46:19, influence [2] - 75:23,
33:15, 34:10, 35:1, hallway [1] - 49:24 100:11, 101:24,
48:22 175:13
35:5, 35:7, 37:2, halted [4] - 8:2, 74:1, 121:17, 127:6,
hierarchy [1] - 29:18 information [34] -
37:3, 37:20, 40:2, 125:12, 129:10 129:25, 134:11
high [8] - 17:7, 26:14, 20:6, 20:25, 21:14,
40:25, 48:8, 48:14, halting [2] - 9:8, 9:9 identified [1] - 152:23
76:16, 77:11, 78:6, 22:21, 22:22, 27:21,
49:14, 55:2, 90:15, halves [1] - 5:21 IE8 [1] - 104:1
159:4, 160:16, 27:24, 28:4, 33:20,
137:13, 137:20, hand [1] - 159:17 160:17 ignorance [1] - 71:12
33:24, 34:1, 37:1,
138:6, 142:25, handle [5] - 11:9, higher [5] - 80:10, ignored [1] - 139:8
37:21, 39:22, 74:11,
143:23, 144:3, 11:11, 31:18, 108:3, 80:11, 80:14, 103:14 illegal [5] - 177:15,
77:4, 92:16, 92:19,
144:4, 144:11, 156:10 highlighted [1] - 178:14, 178:19,
93:9, 93:13, 93:18,
144:12, 146:24, handled [1] - 108:13 115:18 179:20, 182:17
93:20, 121:25,
146:25, 150:23, happy [1] - 164:10 HIPAA [3] - 80:4, 80:5, image [2] - 124:17,
122:1, 122:13,
151:9, 151:16, haranguing [1] - 124:3 124:18
124:12, 124:16,
158:20, 158:21, 91:20 hired [1] - 57:25 immediate [1] - 11:12
141:6, 148:11,
158:22, 158:23, hard [4] - 25:21, 29:1, history [1] - 104:24 implementation [2] - 162:18, 162:24,
158:25, 159:3, 90:6, 145:8 119:22, 160:22 176:15, 176:17
HITECH [1] - 124:3
159:4, 159:7, 163:6, Healthcare [17] - implemented [3] - 6:4, initiative [8] - 149:13,
holes [1] - 51:15
163:13, 163:21, 15:25, 16:4, 16:6, 143:2, 175:4 149:18, 150:2,
home [1] - 166:10
163:25, 164:9, 21:1, 21:24, 23:16, implementing [1] - 150:3, 150:5,
honest [2] - 22:24,
166:8, 166:24, 25:18, 26:9, 27:1, 143:4 150:10, 150:12,
150:18
167:1, 167:7 37:23, 38:5, 152:5, important [4] - 9:1, 181:21
honestly [1] - 144:17
Greg's [2] - 159:24, 152:23, 152:24, 65:16, 65:18, 95:21 innovation [1] -
honesty [1] - 91:22
160:6 159:6, 161:14, improvement [1] - 176:22
hospital [2] - 114:19,
group [7] - 25:10, 174:17 115:9 input [5] - 19:20,
114:22
25:13, 29:22, hear [4] - 27:8, 27:15, inappropriate [1] - 24:16, 144:3,
hostile [8] - 67:23,
7
(194 of 291)
144:13, 149:22 integration [9] - 8:10, 107:10, 107:13, 54:21, 54:23, 56:1, 122:16, 122:17
inquiry [1] - 20:22 9:3, 9:4, 28:16, 138:17, 139:2, 56:3, 56:5, 57:22, Java [4] - 6:13, 6:17,
insert [1] - 56:2 37:23, 96:25, 139:25, 142:25, 60:13, 60:17, 64:20, 7:14, 7:17
inserted [1] - 63:21 125:14, 140:23, 160:17, 173:2, 65:20, 66:3, 69:22, Java-based [1] - 7:14
inside [11] - 102:11, 141:2 173:10, 173:14, 70:1, 70:3, 71:9, Jay [1] - 70:22
165:1, 165:14, Integration [9] - 4:8, 173:25 71:23, 75:15, 75:25, job [19] - 21:10, 24:13,
169:1, 169:3, 4:18, 33:9, 42:12, involvement [2] - 76:4, 76:5, 76:6, 30:16, 30:17, 32:19,
169:12, 170:10, 96:17, 125:12, 10:4, 10:5 76:9, 76:21, 77:1, 40:24, 57:8, 57:24,
170:17, 171:17, 129:10, 137:9, 140:7 IPv4 [6] - 50:4, 50:11, 77:15, 79:7, 79:10, 57:25, 61:24, 86:17,
172:11, 173:19 integrity [1] - 64:3 50:21, 51:10, 53:18, 79:17, 79:19, 79:24, 110:7, 110:22,
insider [5] - 171:5, intellect [2] - 149:7, 66:9 80:2, 80:9, 81:3, 154:22, 155:7,
171:10, 171:12, 149:9 IPv6 [27] - 33:10, 50:4, 81:5, 81:7, 83:4, 155:22, 155:25,
171:13, 171:22 intent [1] - 92:17 50:11, 50:21, 51:10, 84:13, 84:14, 84:15, 156:20, 158:3
Insite [69] - 4:7, 4:18, intentionally [2] - 51:12, 52:4, 52:7, 85:4, 85:6, 85:9, jobs [2] - 21:6, 137:1
5:16, 5:18, 7:2, 8:8, 57:24, 78:1 52:9, 53:12, 53:18, 85:19, 85:25, 87:4, join [1] - 38:19
11:2, 13:25, 14:6, interact [1] - 87:7 53:23, 54:12, 61:3, 87:7, 87:10, 87:14, joined [3] - 8:6, 57:21,
14:8, 14:9, 28:16, interacted [2] - 65:8, 66:7, 66:8, 87:15, 87:17, 87:18, 157:22
31:14, 32:5, 33:8, 139:13, 176:21 66:11, 66:13, 69:8, 88:12, 88:16, 88:18, judged [1] - 156:19
33:19, 42:12, 50:1, interaction [4] - 26:18, 69:12, 70:10, 70:15, 88:21, 88:22, 88:24,
89:3, 89:10, 94:14,
50:13, 81:1, 83:3, 140:9, 166:23, 167:8 70:19, 70:22, 71:3, K
83:6, 83:7, 84:10, interactions [3] - 59:4, 72:20 94:21, 95:22, 96:8,
84:25, 85:13, 96:16, 59:5, 177:7 irrelevant [19] - 17:15, 96:10, 97:14, 99:2,
104:11, 104:14, 19:17, 20:1, 20:22, 105:5, 112:17, keep [8] - 12:22,
interacts [1] - 140:14
106:1, 106:24, 20:23, 21:21, 47:19, 115:15, 117:6, 21:18, 124:11,
interested [2] - 51:24,
107:16, 107:19, 69:8, 98:21, 109:23, 117:8, 117:9, 124:16, 137:2,
90:2
111:7, 117:12, 112:14, 131:19, 118:22, 119:3, 170:21, 172:12,
interesting [1] - 51:8
117:18, 117:22, 139:11, 140:25, 119:6, 129:11, 183:8
interface [7] - 119:14,
118:2, 118:15, 141:15, 148:18, 133:19, 133:22, Kendale [4] - 5:7,
169:2, 169:10,
119:7, 122:4, 122:8, 154:20, 175:6, 135:19, 135:20, 145:12, 157:19,
170:6, 170:10,
123:25, 125:11, 178:25 135:21, 136:9, 157:23
172:11, 172:24
129:9, 130:19, issue [63] - 50:22, 136:24, 137:3, kept [2] - 41:16, 75:2
internal [3] - 136:6,
133:2, 133:13, 52:14, 52:25, 55:3, 137:5, 137:11, Kevin [1] - 70:21
171:20, 172:19
134:5, 136:8, 136:9, 58:2, 58:6, 59:6, 137:22, 138:25, kicked [2] - 11:20,
Internet [2] - 102:11,
136:17, 137:4, 65:7, 65:10, 65:12, 139:3, 139:16, 12:17
102:22
137:6, 137:8, 65:22, 66:20, 69:9, 142:12, 142:14, kind [25] - 12:18,
internet [3] - 168:25,
137:15, 138:9, 69:22, 69:24, 69:25, 143:12, 143:14, 33:25, 37:25, 38:3,
169:1, 169:11
140:6, 147:12, 70:1, 72:17, 73:11, 143:16, 149:3, 44:7, 48:11, 49:4,
interpersonal [2] -
147:20, 147:23, 74:24, 76:20, 77:16, 149:9, 150:23, 55:15, 56:9, 58:3,
157:15, 167:10
168:6, 168:16, 83:5, 83:25, 84:2, 150:24, 150:25, 59:17, 66:7, 92:20,
interrogation [1] -
169:19, 170:4, 85:12, 85:15, 88:7, 166:9, 166:10, 118:19, 125:12,
16:2
173:11, 181:14, 97:23, 102:8, 166:25, 167:9, 129:11, 137:15,
interrupt [4] - 75:4,
181:15 102:20, 104:6, 167:10, 169:6, 147:10, 160:16,
91:15, 91:19, 183:10
install [10] - 11:10, 105:7, 105:18, 169:18, 170:4, 163:6, 163:13,
interrupted [1] - 94:4
11:12, 11:13, 11:18, 114:23, 115:2, 171:21, 177:16, 164:24, 165:7,
interrupting [1] - 24:2
11:23, 12:16, 12:18, 115:22, 125:23, 178:9, 178:12, 165:8, 165:16
investigate [4] - 178:16, 178:20, kinds [3] - 19:9,
15:8, 15:18, 15:19 126:11, 126:14,
47:12, 55:15, 71:23, 178:21, 179:4, 133:19, 154:12
installed [1] - 54:20 126:16, 128:14,
105:3 181:17, 181:18
installing [3] - 133:2, 129:13, 129:15, knowing [2] - 151:7,
investigated [1] - item [2] - 115:7,
134:5 133:12, 133:13, 178:21
126:10 115:13
installment [1] - 12:13 133:16, 133:17, knowledge [51] - 7:25,
investigating [1] - itself [4] - 75:18,
instance [1] - 139:19 135:6, 135:9, 39:20, 42:2, 42:3,
69:10 118:5, 125:14, 131:4
instances [2] - 135:13, 135:16, 42:4, 42:7, 46:6,
investigation [3] - 46:7, 59:7, 66:18,
139:24, 140:18 135:18, 137:16,
53:11, 97:1, 125:16
instead [6] - 45:20,
involve [1] - 20:19
140:12, 142:22, J 66:20, 67:4, 67:15,
48:21, 113:20, 151:8, 152:11, 72:20, 72:24, 73:1,
involved [27] - 5:23, 156:22, 161:2, 73:4, 73:9, 73:13,
118:7, 121:8, 148:22 J2EE [1] - 6:13
10:13, 26:6, 35:10, 168:8, 169:10, 179:9 76:25, 79:12, 85:3,
instructed [1] - 47:2 Jacobs [3] - 5:11,
35:12, 35:16, 35:17, issues [131] - 27:3, 86:14, 97:3, 98:18,
integrate [4] - 137:15, 55:12, 78:5, 78:12, 144:5, 144:12
138:9, 140:24, 141:3 28:11, 28:20, 33:12, 98:22, 99:1, 99:17,
78:13, 78:17, 78:20, January [5] - 120:11, 107:18, 112:6,
integrates [1] - 141:1 35:25, 53:24, 54:16,
79:8, 79:14, 101:21, 121:4, 121:6, 125:11, 128:7,
8
(195 of 291)
128:22, 141:10, 32:13, 32:25, 96:22, 160:17, 176:14 106:2, 109:18, 19:23, 19:24, 19:25,
142:14, 143:12, 97:16, 131:21, 173:3 liar [2] - 92:3, 92:23 120:1, 123:11, 20:4, 29:17, 59:17,
145:17, 153:13, lead's [1] - 99:8 lie [1] - 22:20 123:20, 135:7, 66:16, 72:19, 84:11,
156:5, 157:20, leader [3] - 40:17, lies [1] - 22:16 139:15, 140:10 95:17, 96:16, 96:21,
158:9, 158:19, 40:23, 59:12 life [2] - 109:23, 136:4 looked [3] - 143:5, 136:8, 149:22,
173:6, 175:3, leaders [2] - 174:7, light [2] - 56:2, 58:2 152:10, 175:24 151:19, 151:23,
177:18, 178:2, 174:9 likability [1] - 154:16 looking [6] - 9:21, 151:24, 153:2,
179:6, 179:8, leadership [3] - 9:21, likable [1] - 166:15 20:12, 27:17, 46:17, 154:20, 156:3,
179:11, 180:24, 89:7, 94:18 likely [2] - 107:16, 109:15, 132:10 156:17, 156:18,
181:25 leads [30] - 30:24, 119:20 looks [1] - 102:22 158:2, 160:8,
knowledgeable [1] - 31:4, 37:19, 42:16, limited [1] - 122:2 low [6] - 17:9, 32:21, 160:13, 160:14,
27:5 53:13, 59:17, 61:19, line [7] - 12:13, 19:25, 76:19, 77:4, 77:15, 174:6, 175:13
known [2] - 4:24, 5:3 62:7, 64:24, 66:16, 20:21, 47:18, 66:7, 78:25 managers [31] - 17:6,
knows [7] - 31:1, 31:8, 69:16, 72:20, 72:23, 100:5, 168:14 LPIs [1] - 30:2 21:20, 23:12, 24:18,
75:14, 79:23, 98:10, 73:3, 81:4, 84:11, lines [2] - 35:11, 40:5 LSD [10] - 27:8, 29:17, 25:12, 29:25, 30:1,
131:25, 161:25 85:2, 85:9, 89:18, Linux [30] - 8:13, 31:17, 32:8, 32:10, 30:2, 64:24, 69:16,
Kuhn [8] - 5:9, 32:1, 90:15, 95:3, 95:16, 33:12, 40:22, 43:16, 33:19, 37:2, 37:19, 72:23, 73:3, 74:16,
33:25, 37:19, 42:17, 97:20, 137:13, 43:20, 44:3, 44:22, 96:22, 151:17 81:3, 84:2, 85:1,
128:12, 137:13, 141:3, 173:3, 45:3, 48:12, 48:17, LSDs [3] - 33:24, 85:9, 136:5, 155:1,
144:4 177:17, 178:8, 49:7, 55:20, 57:5, 178:8, 181:24 155:23, 157:6,
179:5, 181:23 59:10, 65:12, 65:17, lying [4] - 22:17, 174:19, 177:17,
L learn [7] - 33:21, 36:7, 66:6, 71:10, 72:17, 22:20, 92:5, 92:22 178:8, 178:16,
37:2, 37:4, 37:5, 73:23, 74:24, 75:16, 178:21, 179:5,
58:25, 74:19 85:10, 96:12, 97:9, M 179:7, 180:20,
label [1] - 106:9 180:25, 181:23
learned [2] - 26:19, 98:7, 126:20,
lack [9] - 73:3, 97:2, managing [1] - 174:12
87:18 141:24, 142:11
149:15, 153:12, mad [1] - 162:11 mandated [1] - 124:3
learning [9] - 58:10, Linux/Windows [1] -
156:3, 159:8, Madhuri [6] - 21:9, mandatory [1] -
64:22, 66:5, 73:6, 142:12
174:23, 179:8, 35:4, 35:13, 74:15, 124:10
73:7, 73:8, 84:12, list [2] - 22:17, 100:10
180:24 128:13, 162:10 manner [2] - 75:2,
178:10, 181:20 listen [2] - 61:21,
lacking [1] - 173:8 mail [36] - 36:4, 39:8, 81:10
least [3] - 36:6, 111:7, 61:25
language [2] - 6:15, 39:13, 39:23, manufacturer [1] -
144:7 listener [1] - 53:25
35:3 102:22, 103:6, 108:3
leave [6] - 35:12, 38:6, listening [17] - 52:5,
lapse [1] - 51:7 103:21, 105:12, March [3] - 38:15,
38:8, 105:16, 53:24, 54:18, 60:5,
lapses [1] - 8:3 120:7, 120:22, 113:23, 127:23
168:25, 169:10 61:23, 63:24, 66:4,
laptop [4] - 134:21, 121:3, 121:5, mark [5] - 38:22, 39:1,
leaves [1] - 25:6 66:22, 67:5, 67:13,
135:23, 145:9 121:13, 121:21, 39:4, 39:7, 121:15
leaving [1] - 22:22 70:11, 89:19, 90:1,
laptops [2] - 133:24, 122:6, 122:19, marked [12] - 39:10,
led [3] - 51:23, 52:20, 90:5, 90:17, 95:4,
142:7 128:10, 128:11, 42:10, 80:22,
53:12 96:2
large [2] - 115:15, 128:12, 128:15, 100:11, 100:12,
left [3] - 78:4, 161:14, listens [1] - 51:9
156:9 128:16, 129:4, 101:24, 109:21,
162:3 live [1] - 112:23
largely [3] - 138:1, 129:19, 129:23, 113:15, 121:16,
legal [22] - 65:2, 68:6, Livermore [1] - 103:8
139:11, 140:25 130:10, 130:24, 127:5, 129:25,
68:21, 74:14, 178:5, lives [1] - 110:22
last [11] - 14:25, 74:6, 131:3, 131:5, 134:11
178:23, 179:2, load [2] - 11:5, 12:5
101:9, 103:5, 131:13, 131:19, marking [1] - 51:3
179:12, 179:15, loaded [1] - 133:25
116:15, 145:21, 136:6, 136:7, 136:11
180:20, 181:1, log [10] - 80:4, 110:18, marks [1] - 86:1
146:16, 146:20, mailed [2] - 100:9,
181:6, 181:7, 182:2, 116:3, 117:22, Mathews [3] - 120:13,
152:14, 166:12, 129:1
182:11, 182:17, 120:19, 120:20, 121:4, 121:21
175:25 mailing [1] - 101:8
182:20, 182:21, 123:20, 124:16, Matson [3] - 120:13,
law [6] - 80:16, 124:3, mails [3] - 128:6, 121:4, 122:6
182:23, 183:16, 170:24, 171:1
178:15, 179:13, 128:21, 129:2
184:4 log-in [2] - 120:19, matter [5] - 22:18,
179:20, 184:8 main [4] - 6:12, 6:14, 43:11, 125:7, 141:5,
letter [1] - 43:25 120:20
laws [2] - 183:16, 10:25, 153:1 154:13
letting [2] - 21:14, log-out [1] - 80:4
183:18 major [2] - 149:11, mattered [1] - 9:1
37:4 logged [1] - 124:22
lawyer [1] - 182:24 168:15
level [20] - 17:7, 17:9, logging [3] - 117:11, matters [2] - 19:21,
layer [2] - 45:10, 46:17 majority [1] - 171:2
17:23, 21:7, 26:14, 117:13, 138:11 149:21
lead [17] - 29:15, 30:2, male [3] - 154:7, mean [14] - 6:1, 8:16,
32:21, 76:16, 76:19, logs [4] - 118:1, 118:3,
30:4, 30:5, 30:7, 154:13, 158:13 16:10, 18:4, 20:8,
77:4, 77:11, 77:15, 123:2, 123:25
30:8, 30:9, 30:11, manager [32] - 16:22, 21:10, 36:9, 46:9,
78:6, 78:25, 91:23, look [12] - 42:11,
30:20, 31:17, 32:12, 123:12, 159:4, 18:20, 19:18, 19:22, 47:18, 65:2, 110:10,
99:20, 99:21, 100:9,
9
(196 of 291)
122:15, 129:19, memory [6] - 49:2, minute [1] - 82:1 21:21, 68:22, 79:25, 121:1, 121:12,
174:15 93:4, 93:5, 103:25, minutes [6] - 74:6, 101:14, 157:4, 121:18, 122:5,
meaning [3] - 43:23, 104:6, 104:10 89:20, 90:24, 91:1, 163:2, 170:10, 122:9, 122:11,
46:14, 102:25 men [3] - 153:5, 153:6, 95:5, 184:23 172:11, 175:6, 122:15, 123:14,
means [8] - 86:8, 154:16 mischaracterize [2] - 180:1, 180:17 125:5, 127:7,
107:19, 115:3, mention [3] - 121:21, 67:18, 155:14 moving [1] - 171:19 127:11, 127:15,
115:6, 115:16, 140:16, 166:22 mischaracterizes [10] MR [248] - 4:10, 7:7, 128:2, 128:5,
115:24, 115:25, mentioned [16] - - 19:16, 22:4, 23:20, 8:17, 9:13, 9:18, 128:20, 128:25,
136:6 16:21, 48:8, 49:6, 37:8, 67:2, 83:10, 12:19, 13:4, 13:11, 129:5, 129:22,
meant [6] - 39:12, 49:19, 118:13, 99:10, 155:9, 13:14, 14:10, 14:15, 130:3, 130:9, 131:2,
43:22, 85:24, 93:22, 130:16, 144:11, 177:21, 182:4 14:23, 15:1, 16:7, 131:8, 131:13,
122:6 145:12, 146:12, Mischaracterizes [1] - 17:13, 19:1, 19:15, 131:18, 131:22,
meantime [2] - 12:3, 163:12, 164:6, 67:11 19:22, 20:4, 20:7, 132:2, 134:8,
12:17 164:22, 164:24, misconfigured [1] - 20:14, 20:17, 21:2, 134:14, 135:11,
measure [2] - 179:2, 165:7, 167:7, 174:16 126:20 21:11, 21:15, 22:2, 143:17, 146:4,
180:21 mentioning [2] - misconstruing [1] - 22:4, 22:14, 23:1, 147:4, 148:8,
measured [1] - 153:3 128:12, 128:16 68:21 23:19, 24:1, 28:1, 148:12, 148:17,
measuring [1] - mentor [4] - 145:21, misdoing [1] - 21:1 28:14, 29:12, 30:12, 149:15, 149:19,
174:21 146:1, 146:11 misleading [4] - 47:8, 30:22, 31:2, 34:3, 151:13, 151:15,
mechanism [6] - mentoring [1] - 93:7, 93:16, 105:19 34:6, 34:13, 34:16, 153:11, 154:18,
27:22, 27:24, 146:16 misrepresentation [1] 34:20, 36:10, 36:14, 155:5, 155:9,
123:22, 123:24, message [10] - 29:11, - 47:7 36:21, 37:6, 37:13, 155:13, 156:25,
124:24, 125:3 42:18, 42:25, 44:5, missed [3] - 7:16, 38:12, 38:20, 38:25, 157:4, 158:5,
mechanisms [3] - 46:10, 46:11, 46:12, 62:25, 163:20 39:11, 39:16, 41:9, 158:15, 159:11,
28:4, 28:9, 115:21 46:19, 46:22 missing [4] - 80:2, 41:18, 44:8, 46:25, 159:16, 159:22,
medical [20] - 108:3, met [2] - 18:19, 146:17 80:5, 93:2, 120:19 47:14, 51:2, 53:3, 160:4, 161:1, 161:3,
108:19, 108:22, Microsoft [5] - 6:18, misstate [1] - 77:25 53:20, 56:12, 56:16, 161:22, 162:6,
109:3, 110:12, 6:21, 7:14, 7:19, 56:20, 58:4, 58:14, 162:14, 162:20,
misstates [5] - 12:20,
114:10, 116:4, 136:1 59:2, 60:22, 62:2, 162:22, 163:1,
23:20, 76:10, 85:16
116:7, 116:9, 117:2, Microsoft-based [2] - 62:13, 62:17, 64:4, 163:16, 167:14,
mitigate [3] - 103:25,
123:4, 124:4, 7:14, 7:19 64:11, 65:4, 67:1, 167:17, 167:23,
104:10, 114:4
124:11, 124:15, mid [7] - 24:23, 24:25, 67:9, 68:7, 68:12, 168:2, 169:23,
mitigation [2] - 170:9,
132:20, 133:4, 25:11, 144:5, 68:16, 68:20, 70:17, 170:2, 172:1,
171:18
133:16, 137:15, 144:13, 144:21, 71:16, 71:19, 71:24, 174:23, 175:1,
mitigations [1] - 169:9
137:21 144:23 72:8, 73:14, 74:5, 175:11, 176:8,
mixing [1] - 139:17
meet [10] - 9:23, 10:2, mid-2012 [1] - 125:13 75:5, 76:10, 77:2, 176:24, 177:3,
modality [8] - 8:9,
17:5, 19:8, 19:9, 77:19, 77:21, 78:2, 177:11, 177:20,
mid-term [3] - 144:13, 8:14, 54:4, 56:5,
19:12, 21:24, 24:7, 78:7, 78:11, 79:22, 178:1, 178:24,
144:21, 144:23 136:5, 139:18,
89:1, 94:12 80:11, 80:17, 81:13, 179:16, 179:19,
mid-year [4] - 24:23, 140:22, 141:2
meeting [5] - 120:11, 81:16, 81:21, 81:25, 179:25, 180:4,
24:25, 25:11, 144:5 modifications [1] -
161:16, 161:23, 82:5, 82:8, 82:13, 180:10, 180:13,
middle [4] - 57:7, 173:17
164:11, 164:17 82:19, 83:9, 83:15, 180:17, 182:3,
91:15, 94:4, 129:14 Mohieddine [3] - 23:9,
meetings [9] - 6:9, 84:3, 84:6, 85:14, 182:6, 182:13,
might [31] - 25:5, 32:9, 26:19, 26:20
28:7, 107:14, 85:16, 86:25, 87:24, 182:18, 182:22,
33:3, 33:4, 34:1, Monday [1] - 73:24
145:22, 163:14, 90:22, 91:13, 92:12, 183:4, 183:7,
35:10, 35:12, 37:11, money [1] - 22:19
164:7, 164:23, 94:2, 94:7, 95:10, 183:13, 183:22,
48:5, 48:25, 49:18, month [4] - 57:21,
165:13, 176:19 97:2, 98:10, 98:16, 184:1, 184:9, 184:20
51:14, 88:15, 66:1, 113:19, 176:1
Mehring [13] - 4:25, 99:9, 99:14, 99:25, MS [218] - 4:13, 4:16,
108:10, 110:14, months [5] - 36:7,
17:22, 21:8, 23:8, 100:6, 100:13, 7:3, 7:5, 7:12, 8:20,
115:8, 119:9, 60:15, 70:23, 71:1
23:10, 25:2, 26:21, 100:18, 100:23, 13:1, 13:7, 13:13,
119:13, 124:14, moot [1] - 69:13
61:19, 89:17, 90:18, 101:4, 101:7, 13:17, 13:20, 13:25,
124:20, 126:19, morning [1] - 78:24
95:3, 161:17, 162:18 101:11, 101:14, 14:3, 14:13, 14:17,
139:14, 140:15, most [12] - 4:4, 5:1, 102:3, 102:16, 14:25, 17:18, 19:19,
Mehring's [1] - 58:23 141:11, 165:16, 26:18, 70:1, 70:3, 105:9, 105:13, 20:2, 20:5, 20:12,
member [3] - 76:15, 165:17, 166:7, 109:11, 114:3, 105:20, 106:4, 20:16, 20:23, 21:4,
150:10, 150:14 166:8, 166:9 114:6, 137:22, 106:10, 106:15, 21:13, 21:22, 22:13,
members [12] - 17:7, migrate [1] - 148:3 141:14, 142:1, 106:19, 107:2, 22:15, 23:6, 30:25,
23:8, 25:20, 26:16, Milwaukee [3] - 170:22 107:5, 108:11, 31:9, 31:24, 34:5,
26:17, 69:6, 69:14, 145:11, 163:9, Motioning [1] - 159:15 114:25, 116:18, 34:15, 34:18, 34:23,
69:23, 69:24, 164:18 motives [1] - 171:16 116:20, 116:24, 36:12, 36:18, 36:23,
137:14, 156:16 mine [1] - 49:14 move [13] - 6:5, 13:8, 120:16, 120:21, 37:9, 37:17, 38:23,
10
(197 of 291)
39:3, 39:7, 39:14, 167:15, 167:21, needed [22] - 11:4, next [17] - 6:6, 11:5, 41:23, 53:20, 56:12,
39:19, 41:7, 41:11, 168:5, 169:25, 12:9, 16:1, 16:6, 12:11, 12:15, 13:8, 58:4, 58:14, 59:2,
41:22, 46:23, 47:6, 170:3, 171:25, 33:21, 33:23, 37:1, 27:7, 27:14, 35:9, 67:1, 92:8, 92:15,
47:25, 53:5, 53:9, 172:5, 174:2, 174:4, 47:11, 48:3, 52:2, 40:14, 41:11, 49:15, 123:14, 143:17,
54:22, 54:25, 56:15, 175:8, 176:10, 81:1, 81:7, 83:24, 57:18, 78:21, 90:3, 149:19, 154:18,
56:19, 56:22, 56:25, 177:1, 177:8, 86:14, 97:22, 109:18, 142:19, 155:5, 163:16,
58:20, 62:5, 62:15, 177:13, 177:23, 104:15, 123:13, 165:6 174:23, 175:11,
62:20, 62:23, 63:15, 178:4, 180:2, 180:7, 126:19, 149:13, nice [3] - 47:16, 91:3, 180:12, 182:3
64:6, 64:13, 67:7, 180:11, 180:15, 154:11, 164:13, 158:1 objected [1] - 184:25
67:21, 68:4, 68:10, 180:18, 182:5, 173:7 night [1] - 101:9 objecting [1] - 47:8
68:13, 68:18, 68:23, 182:9, 182:16, needs [8] - 36:6, 59:9, Nobles [1] - 73:17 Objection [1] - 30:12
68:25, 74:8, 77:24, 182:20, 182:25, 75:16, 75:17, nobody [7] - 18:21, objection [39] - 12:19,
78:4, 78:9, 79:4, 183:11, 183:15, 100:14, 140:10, 18:25, 22:1, 51:10, 13:20, 14:10, 14:23,
80:14, 80:20, 80:24, 184:6, 184:16 164:12, 184:24 69:8, 108:15, 121:9 15:1, 19:15, 22:2,
81:14, 81:20, 81:23, multiple [1] - 50:9 negative [4] - 24:11, non [1] - 108:20 22:6, 23:19, 34:13,
82:2, 82:7, 82:11, 157:24, 157:25, nonconformance [4] - 37:6, 60:22, 65:4,
82:15, 83:1, 83:11, N 182:10 108:4, 108:16, 67:10, 71:16, 71:24,
83:14, 83:21, 84:8, negatively [1] - 154:17 109:20, 115:8 73:14, 76:10, 77:2,
88:1, 90:24, 92:11, neglecting [2] - 58:7, nonconformances [3] 77:19, 80:17, 83:9,
92:13, 94:5, 95:14, Nah [1] - 166:13
95:21 - 106:18, 107:19, 84:3, 85:14, 86:25,
97:4, 97:12, 98:12, name [3] - 30:25,
negligence [6] - 56:9, 108:12 97:2, 99:9, 105:9,
99:3, 99:11, 99:19, 100:10, 172:16
57:3, 59:1, 64:24, nonconformities [1] - 114:25, 149:15,
100:4, 100:12, named [1] - 31:7
74:2, 74:4 109:1 151:13, 153:11,
100:16, 100:21, Naresh [1] - 144:4 156:25, 158:5,
negligent [1] - 71:11 none [1] - 25:14
101:2, 101:5, Nate [13] - 5:5, 17:22, 175:12, 177:20,
network [15] - 7:23, normal [1] - 173:24
101:17, 102:13, 23:10, 24:16, 26:21, 179:16, 179:19,
42:13, 43:18, 45:10, normally [1] - 50:13
102:18, 105:11, 32:17, 32:24, 79:1, 182:13
46:17, 70:12, Nos [3] - 80:22,
105:17, 105:23, 107:15, 116:13, objections [1] - 92:20
125:19, 126:17, 121:16, 127:5
106:8, 106:13, 142:24, 143:23,
127:20, 128:13, note [6] - 19:23, 47:1, objective [4] - 11:19,
106:17, 106:23, 144:4
128:17, 129:16, 54:22, 102:3, 11:22, 16:17, 16:18
107:4, 107:10, near [1] - 4:6
132:15, 170:17, 121:18, 134:14 observation [1] - 55:1
107:12, 116:16, nearing [1] - 10:23
171:17 nothing [7] - 108:20, observed [2] - 56:18,
116:19, 116:22, neat [1] - 47:16 147:6
networking [11] - 113:2, 113:19,
117:1, 120:17, necessarily [3] - 5:20, obvious [1] - 27:12
46:7, 52:18, 52:25, 143:1, 160:6, 162:2,
120:24, 121:7, 24:8, 184:9 53:1, 70:5, 145:14, 178:19 occasion [1] - 166:25
121:14, 121:20, need [63] - 13:4, 145:17, 145:24, noticed [1] - 70:11 occasionally [1] -
125:6, 125:10, 15:16, 20:6, 20:9, 146:14, 146:18, noting [1] - 22:5 24:17
126:7, 127:4, 20:18, 22:19, 31:3, 157:20 notoriously [1] - 145:2 OEC [5] - 8:2, 8:5, 8:9,
127:10, 127:12, 31:5, 34:6, 36:21, networks [2] - 51:10 November [3] - 8:6, 9:8, 73:25
127:18, 128:3, 40:22, 41:12, 41:24,
never [14] - 16:3, 38:11, 38:19 offer [2] - 40:2
128:8, 128:23, 47:9, 51:13, 56:20,
16:11, 18:19, 29:21, NSA [2] - 171:5, 171:7 offered [7] - 33:14,
129:3, 129:7, 129:8, 59:12, 62:18, 63:16,
61:14, 78:11, 92:21, number [4] - 67:16, 40:3, 151:3, 174:17,
130:1, 130:4, 130:8, 63:17, 67:23, 74:10,
98:24, 149:9, 108:12, 115:15, 175:10, 175:16,
130:12, 130:15, 74:11, 79:25, 82:7,
158:24, 160:11, 127:14 175:19
131:6, 131:11, 82:8, 82:17, 84:23,
160:13, 167:11, numbers [2] - 108:9, offering [2] - 41:1,
131:16, 131:20, 93:17, 93:19, 93:21,
170:12 136:19 151:3
131:25, 132:8, 94:2, 98:7, 98:13,
new [29] - 9:7, 12:14, numerous [9] - 40:4, Office [49] - 5:22,
132:23, 132:25, 98:14, 100:1, 100:6,
15:9, 15:10, 31:14, 65:21, 88:15, 117:9, 5:23, 11:3, 12:5,
134:12, 143:7, 103:18, 106:4,
33:20, 33:23, 51:4, 133:22, 134:2, 13:10, 13:19, 13:23,
143:10, 146:7, 106:11, 107:5,
57:20, 58:25, 63:25, 137:5, 137:11, 14:8, 14:21, 15:7,
148:9, 148:14, 115:4, 116:21,
65:9, 69:17, 78:19, 143:21 15:14, 15:15, 15:16,
149:21, 155:12, 116:22, 120:6,
87:9, 112:16, 33:3, 114:15,
155:17, 157:2, 120:17, 120:25,
113:17, 113:20, 114:17, 116:1,
157:9, 158:12, 122:16, 131:16,
115:9, 118:25,
O
116:8, 116:10,
159:14, 159:20, 131:23, 138:14,
119:17, 119:19, 116:11, 117:3,
159:25, 161:2, 138:21, 138:22, oath [1] - 22:18
119:21, 139:20, 121:23, 133:4,
161:7, 161:10, 138:24, 139:14,
153:23, 178:6, object [30] - 7:7, 9:13, 136:9, 136:17,
161:24, 162:4, 148:10, 150:11,
179:2, 181:20 13:11, 16:7, 17:13, 137:4, 137:6,
162:9, 162:17, 161:20, 162:25,
news [1] - 115:14 20:6, 28:1, 28:14, 137:11, 137:24,
162:21, 162:24, 176:11, 177:9,
Next [1] - 90:16 29:12, 34:21, 41:19, 138:2, 138:5,
163:4, 167:13, 183:3, 184:16
11
(198 of 291)
138:10, 138:12, opinion [15] - 52:18, 89:20, 94:20, 95:5, percent [2] - 76:23 piece [6] - 5:20, 5:21,
138:17, 138:25, 52:24, 60:12, 74:1, 109:4, 134:4, 160:11 perception [1] - 69:4 29:20, 119:11,
139:2, 139:13, 75:23, 149:20, Part [1] - 39:17 perfect [1] - 29:2 124:14, 142:8
139:15, 139:19, 151:22, 152:3, participant [3] - 129:2, perfectly [1] - 45:1 pile [1] - 159:18
140:3, 140:9, 166:17, 181:3, 129:24, 131:4 perform [1] - 81:6 pilot [1] - 139:21
140:14, 142:3, 183:2, 183:3, 183:8, parts [2] - 116:6, performance [19] - place [3] - 24:5,
142:8, 142:10, 183:9, 183:14 125:23 19:11, 24:10, 24:15, 171:12
148:3, 157:21, opinions [1] - 119:10 party [3] - 88:10, 75:19, 85:21, places [1] - 7:11
159:2, 164:14 opportunity [7] - 22:8, 172:15, 173:14 106:24, 107:13, plan [38] - 13:9, 13:13,
Offices [1] - 13:24 36:15, 82:25, pass [2] - 43:25, 66:8 144:3, 156:20, 14:6, 14:7, 14:20,
official [1] - 16:12 105:15, 115:9, passed [5] - 34:8, 157:12, 157:25, 40:9, 40:19, 40:21,
Ofir [6] - 161:14, 165:22, 167:18 131:1, 131:21, 158:8, 159:24, 41:16, 42:13, 42:16,
161:17, 162:5, opposing [1] - 92:14 151:11, 151:19 160:6, 160:12, 43:5, 43:13, 43:16,
162:10, 162:11, opposite [2] - 86:10, passive [1] - 147:1 166:21, 166:22, 43:21, 44:12, 44:21,
162:12 88:10 passive-aggressive 174:10, 174:14 44:23, 45:1, 45:6,
often [4] - 27:15, optional [1] - 124:10 [1] - 147:1 period [12] - 13:21, 45:19, 48:19, 59:9,
28:24, 96:4, 123:19 options [1] - 172:13 past [10] - 28:5, 55:22, 13:22, 14:12, 14:16, 65:11, 75:1, 75:17,
old [9] - 13:9, 36:2, ordered [2] - 16:24, 89:23, 95:7, 154:14, 37:18, 57:6, 58:9, 89:2, 94:13, 137:9,
36:25, 37:18, 57:21, 16:25 166:16, 166:24, 58:10, 60:4, 83:5, 139:6, 139:12,
60:15, 103:11, original [2] - 81:5, 166:25, 167:7, 83:7, 84:25 139:14, 140:16,
111:15, 145:8 103:21 167:19 periodically [1] - 141:8, 141:15,
omit [1] - 91:8 originally [2] - 103:7, paste [1] - 45:8 136:24 141:18, 151:2, 151:5
Once [1] - 105:16 148:2 patch [1] - 126:19 perjury [2] - 22:16, plans [7] - 13:14, 15:3,
once [6] - 6:10, 45:2, otherwise [3] - 21:5, Patel [4] - 39:8, 39:9, 22:17 15:5, 31:21, 96:12,
73:17, 85:23, 126:23 105:18, 175:14 42:17, 161:11 person [36] - 4:11, 97:9, 140:20
one [53] - 4:11, 7:16, ourselves [2] - 51:14, patient [6] - 114:11, 19:4, 25:10, 25:16, platform [2] - 106:24,
10:3, 14:9, 14:22, 148:24 114:23, 115:2, 29:21, 36:5, 36:6, 147:12
18:7, 19:3, 29:21, outside [3] - 19:6, 124:12, 124:15, 36:8, 57:21, 58:5, point [52] - 8:24, 9:7,
35:5, 47:19, 49:5, 169:4, 173:20 124:18 61:21, 61:22, 64:25, 11:8, 12:10, 13:15,
50:14, 50:15, 52:3, overall [1] - 14:20 patients [1] - 110:21 69:17, 69:18, 70:8, 16:23, 29:21, 46:6,
53:14, 57:21, 58:9, overassertive [1] - pause [1] - 143:7 86:9, 86:10, 86:11, 47:12, 51:20, 53:1,
92:13, 93:2, 93:5, 180:12 peers [8] - 24:18, 86:12, 86:20, 89:25, 53:3, 57:19, 63:16,
93:22, 98:19, overconfident [6] - 153:2, 155:1, 93:19, 134:18, 64:18, 64:22, 64:23,
103:17, 105:5, 55:16, 56:11, 59:18, 155:23, 174:20, 149:17, 151:9, 65:1, 65:9, 65:25,
111:5, 111:24, 64:21, 72:7, 88:12 175:14, 180:21, 151:10, 151:11, 66:1, 67:8, 69:2,
117:14, 119:15, overlooked [1] - 139:9 180:25 151:18, 154:1, 69:4, 69:13, 69:19,
125:8, 133:20, own [4] - 18:13, 123:6, pending [4] - 42:1, 155:21, 162:21, 71:7, 71:8, 72:10,
135:3, 135:10, 160:12, 172:19 57:1, 147:14, 177:19 165:21, 166:12, 72:15, 72:22, 73:11,
137:1, 137:10, owned [1] - 147:20 People [1] - 156:23 174:1, 180:22 74:15, 75:11, 76:3,
138:13, 138:20, people [39] - 9:22, personal [18] - 17:14, 84:1, 88:9, 93:2,
141:12, 144:17, 19:17, 21:19, 67:4, 96:5, 111:6, 111:16,
144:18, 145:25,
P 10:2, 10:12, 10:15,
112:13, 119:5,
19:4, 19:11, 21:24, 67:15, 97:3, 98:18,
146:19, 152:14, 22:20, 25:5, 25:13, 98:22, 99:1, 99:17, 119:24, 122:3,
152:20, 160:10, p.m [1] - 185:4 25:15, 26:11, 26:14, 128:7, 128:22, 131:20, 132:3,
164:11, 169:9, package [5] - 43:9, 27:12, 29:2, 30:23, 153:12, 154:19, 143:23, 148:6,
169:13, 170:9, 43:10, 45:5, 45:21, 33:24, 37:19, 38:3, 157:1, 158:9, 175:4, 148:20, 183:23,
172:13, 173:10, 48:2 38:5, 38:6, 53:12, 178:25 184:22
175:24, 176:14 packet [7] - 42:13, 53:13, 55:11, 55:13, personality [1] - pointed [8] - 52:4,
online [3] - 103:25, 42:19, 43:2, 43:4, 72:9, 87:13, 119:15, 166:17 52:10, 53:23, 54:12,
104:11, 133:14 43:18, 48:17 144:9, 144:11, personally [2] - 132:3, 70:1, 70:3, 70:10,
open [2] - 51:14, page [1] - 106:6 150:18, 150:22, 150:25 136:4
57:20 pages [2] - 102:1, 160:23, 164:17, personnel [1] - 26:18 pointers [1] - 55:9
opened [1] - 135:5 116:4 171:2, 171:14, phase [2] - 78:19, pointing [2] - 139:21,
opening [1] - 51:11 papers [1] - 159:18 171:15, 173:21, 78:21 179:9
operating [8] - 8:12, parent [1] - 165:23 178:2 phases [3] - 6:6, 6:7, points [1] - 181:23
15:10, 27:22, 27:24, part [20] - 4:4, 5:16, per [2] - 43:24, 117:4 16:9 poking [1] - 170:24
28:4, 28:8, 31:16, 5:25, 6:1, 11:22, perceive [1] - 180:21 phone [1] - 25:22 poor [2] - 28:11, 28:20
130:22 23:11, 33:1, 33:2, perceived [1] - 153:2 picked [1] - 16:17 poorly [4] - 58:19,
operation [2] - 105:8, 57:25, 67:11, 74:2, perceiving [1] - picture [2] - 84:24, 75:18, 85:20, 88:19
114:10 83:2, 85:13, 89:9, 174:21 105:19 port [9] - 33:12, 50:14,
12
(199 of 291)
50:15, 50:17, 50:19, printout [2] - 105:25, 114:2, 114:6, prototyping [1] - quiet [1] - 166:9
51:4, 53:17, 54:18, 121:19 132:22, 139:19, 118:10 quite [3] - 49:22,
54:19 priorities [1] - 28:24 139:22, 139:23, prove [1] - 22:19 49:25, 90:11
ported [1] - 44:25 priority [2] - 11:13, 169:18, 170:4 provide [4] - 24:15,
portion [3] - 10:6, 28:22 productivity [1] - 47:22, 144:2, 159:23 R
33:7, 34:10 privilege [1] - 93:12 114:22 provided [2] - 20:2,
ports [6] - 15:11, problem [53] - 47:10, products [5] - 11:11, 152:4
RA [2] - 134:19, 138:3
31:15, 50:4, 50:9, 47:13, 47:14, 49:9, 44:25, 45:3, 108:3, providers [1] - 124:11
50:10, 52:16 142:11 raise [2] - 66:2, 184:13
49:21, 55:18, 56:7, providing [5] - 29:9,
position [1] - 19:13 program [4] - 30:1, raised [1] - 184:7
61:6, 65:1, 65:23, 33:20, 37:1, 37:24,
positively [2] - 59:22, 67:22, 73:4, 76:4, 52:8, 112:1, 112:2 raising [5] - 62:10,
39:21
154:16 86:4, 86:12, 86:19, programming [3] - 177:16, 178:6,
provocative [1] -
86:20, 86:22, 86:23, 6:15, 145:13, 146:13 179:4, 181:17
possible [12] - 49:22, 161:12
88:9, 99:7, 102:10, programs [1] - 79:17 ran [2] - 43:19, 136:16
49:25, 51:18, 53:15, public [3] - 168:9,
56:3, 91:7, 91:9, 102:20, 103:3, project [79] - 6:3, 6:5, randomly [1] - 50:9
168:17, 171:19
93:4, 100:21, 103:10, 103:22, 6:6, 6:22, 7:13, 7:14, rather [5] - 42:18,
pull [3] - 121:25,
123:10, 123:15, 103:23, 104:25, 7:18, 7:19, 8:8, 8:9, 110:6, 147:10,
122:12, 123:8
170:20 105:4, 110:12, 9:11, 9:22, 9:23, 150:3, 173:20
pulled [1] - 169:1
possibly [2] - 50:24, 112:18, 113:4, 10:1, 10:5, 10:11, read [34] - 42:1, 56:25,
pulls [1] - 122:1
50:25 115:6, 115:7, 10:18, 10:21, 11:20, 57:1, 62:16, 62:20,
punished [1] - 158:3
potential [4] - 112:17, 125:18, 126:24, 14:18, 14:19, 16:3, 62:22, 80:23, 83:14,
purchased [2] -
154:2, 154:4, 154:5 127:22, 130:13, 16:5, 16:9, 16:10, 85:23, 94:7, 94:8,
109:10, 111:13
potentially [4] - 130:23, 133:15, 16:14, 16:19, 16:25, 94:11, 97:4, 97:7,
pure [1] - 6:24
110:21, 114:8, 134:22, 135:22, 17:6, 17:24, 18:4, 100:4, 101:25,
purpose [1] - 23:3
170:18, 171:22 138:2, 152:24, 18:6, 18:15, 19:5, 102:1, 106:14,
put [4] - 7:5, 67:23,
161:19, 166:23, 19:7, 23:14, 23:15, 106:16, 111:18,
pounds [1] - 166:14 113:15, 163:20
167:8, 175:9, 24:4, 27:25, 28:3, 115:13, 116:12,
power [2] - 150:18,
175:15, 179:10, 28:25, 29:5, 29:7, 120:19, 120:22,
152:2
180:23 32:11, 33:1, 40:25,
Q 126:7, 126:9,
Practically [1] -
problems [17] - 12:18, 54:13, 59:13, 76:13, 127:25, 130:6,
123:10
35:19, 57:9, 61:9, 77:10, 78:12, 78:15, qualified [1] - 173:21 131:6, 147:14,
practice [8] - 46:5,
61:10, 65:24, 87:6, 78:19, 79:1, 79:3, quality [6] - 8:3, 9:10, 157:13, 172:5,
46:9, 71:15, 71:21,
113:5, 114:4, 79:6, 84:17, 85:7, 63:23, 66:3, 181:18, 172:8, 177:19
108:25, 109:6,
125:13, 134:2, 89:9, 94:20, 97:15, 181:22 readable [3] - 45:12,
109:7, 112:19
134:3, 149:11, 109:16, 142:15, questioning [3] - 48:20, 48:21
Prasad [1] - 30:8
157:17, 167:12, 142:16, 142:18, 19:25, 47:18, 91:22 reading [5] - 39:23,
prepared [3] - 176:24,
170:25, 171:19 142:20, 143:13, questions [21] - 13:6, 73:19, 73:22, 121:8,
184:22, 185:1
procedures [1] - 143:15, 143:22, 21:20, 23:4, 35:18, 125:4
present [4] - 66:12,
37:22 147:15, 152:12, 40:5, 54:3, 81:17, ready [4] - 112:9,
161:17, 164:7,
proceed [1] - 91:17 159:2, 159:6, 81:18, 81:22, 82:9, 112:11, 127:8, 149:2
164:23
process [2] - 10:14, 164:10, 174:7, 82:22, 105:15, reaffirming [1] - 27:20
presenting [1] -
141:18 174:12, 175:25, 148:18, 158:10, real [11] - 40:18,
184:25
product [28] - 8:11, 179:3 162:15, 175:7, 43:23, 65:22, 69:22,
presents [1] - 107:15
9:2, 9:4, 9:6, 11:15, projects [3] - 28:6, 180:1, 182:23, 79:11, 87:4, 89:8,
pressure [3] - 98:2,
15:17, 18:24, 31:16, 28:23, 84:17 184:4, 184:23, 92:19, 94:19, 96:10,
98:3, 164:13
33:22, 36:7, 37:1, promotion [1] - 184:25 104:5
pretty [4] - 11:25,
37:4, 37:5, 37:22, 151:11 Questra [24] - 11:10, realize [3] - 55:20,
27:10, 27:12, 72:7
37:23, 51:6, 54:2, proper [6] - 58:24, 11:14, 12:5, 15:15, 57:3, 130:10
prevent [1] - 110:20
54:8, 109:2, 113:25, 88:4, 117:17, 102:11, 102:21, realized [3] - 51:11,
previous [8] - 42:4,
126:2, 130:19, 117:18, 171:11, 103:1, 103:2, 76:3, 96:6
62:22, 80:23, 94:11,
132:15, 132:19, 173:6 103:18, 109:12, realizing [3] - 71:9,
97:7, 126:9, 166:12,
137:20, 141:3, properly [3] - 54:2, 109:16, 115:17, 143:13, 143:14
172:8
141:24, 181:21 129:18, 136:23 116:1, 118:5, 119:2, really [15] - 10:9,
primarily [1] - 109:11
production [20] - proposing [1] - 48:13 121:23, 122:23, 15:21, 55:4, 65:9,
principal [12] - 6:2,
104:17, 104:18, protect [1] - 21:1 123:6, 128:18, 101:19, 111:15,
10:8, 19:19, 29:16,
104:19, 105:4, protected [1] - 183:20 147:24, 147:25, 115:10, 121:24,
29:23, 30:19, 45:17,
105:7, 105:17, protection [3] - 164:14, 169:16 135:13, 143:2,
45:18, 53:13, 96:22,
107:20, 109:9, 103:25, 104:6, quicker [1] - 12:9 144:10, 150:16,
176:13, 184:6
111:16, 112:3, 104:10 quickly [3] - 101:1, 150:25, 155:8, 165:5
print [1] - 106:8
113:9, 113:24, protocol [1] - 50:17 154:2, 154:4 reason [10] - 10:25,
printed [1] - 120:24
13
(200 of 291)
52:22, 62:12, 112:7, 145:7 48:16, 48:22, 48:24, 109:16, 112:25, 10:10, 31:20, 143:1,
165:19, 168:20, recount [1] - 74:22 49:1, 49:9, 49:12, 113:17, 137:25 143:6, 164:3
169:20, 169:21, redirect [1] - 12:23 49:13, 49:16, 49:22, replaced [4] - 109:22, reschedule [2] -
173:7, 175:3 referenced [1] - 39:2 50:1, 52:3, 52:15, 112:8, 112:9, 112:12 100:19, 110:21
reasons [2] - 10:17, referring [4] - 59:3, 53:22, 53:24, 55:6, replacement [3] - research [1] - 135:10
145:25 71:19, 101:16, 174:8 55:9, 55:11, 55:19, 109:15, 113:25, resentment [1] -
rebuild [5] - 102:24, reflect [3] - 75:18, 59:11, 60:3, 60:7, 147:22 151:21
103:2, 103:13, 85:20, 88:19 63:6, 64:16, 65:12, replacements [1] - resisted [1] - 48:3
103:18, 103:19 reflected [3] - 156:18, 70:25, 72:1, 72:11, 15:16 resisting [1] - 49:21
rebuilding [1] - 103:17 156:19, 157:10 72:13, 72:18, 73:21, replacing [6] - 11:14, resolve [1] - 184:15
receive [1] - 129:23 reflection [1] - 155:3 78:10, 80:7, 88:20, 13:9, 13:18, 14:21, respond [1] - 25:14
received [1] - 62:10 refresh [3] - 49:2, 89:16, 90:19, 90:20, 137:1, 137:25 response [6] - 16:2,
recently [1] - 152:10 146:8, 161:24 91:5, 91:10, 91:11, replicated [1] - 119:23 43:11, 56:6, 121:5,
recess [4] - 39:6, regard [1] - 29:13 95:1, 95:25, 96:4, replied [1] - 103:6 127:24, 176:10
80:21, 125:9, 168:4 regarding [7] - 88:19, 102:9, 117:8, 118:9, reply [2] - 25:7, 105:3 responsibilities [2] -
recipient [4] - 128:6, 135:16, 135:17, 118:21, 118:22, report [3] - 115:6, 31:7, 32:19
128:21, 129:2, 129:5 135:23, 149:10, 118:23, 121:10, 123:9, 123:17 responsibility [8] -
reckless [2] - 55:16, 152:22, 177:6 125:23, 126:13, reporter [9] - 4:11, 17:11, 18:12, 23:13,
88:10 regular [1] - 28:7 126:15, 126:16, 22:12, 39:1, 54:24, 30:4, 30:11, 31:10,
recklessness [3] - regulated [2] - 64:1, 126:18, 127:1, 68:1, 94:11, 97:7, 32:20, 99:8
56:10, 64:25, 74:3 65:2 129:13, 129:15, 147:14, 172:8 responsible [22] -
recollect [1] - 184:16 reimaged [1] - 134:21 133:17, 134:6, REPORTER [6] - 68:2, 17:7, 18:1, 18:5,
recollection [2] - 138:10, 144:22, 80:19, 95:8, 101:10, 19:4, 22:1, 23:18,
related [6] - 69:3,
127:3, 164:9 144:24, 144:25, 167:25, 184:18 29:9, 29:14, 29:16,
137:23, 142:15,
recommended [1] - 145:10, 146:6, Reporter [6] - 42:1, 29:17, 29:20, 29:23,
142:16, 145:16,
148:6 146:9, 146:23, 57:1, 62:22, 80:22, 29:25, 30:3, 31:20,
151:1
148:24, 152:14, 126:9, 177:19 64:2, 97:15, 97:19,
reconnect [1] - 125:21 relationship [6] - 12:2,
152:19, 153:14, reporting [17] - 97:20, 98:19, 98:23
reconnecting [1] - 19:13, 26:4, 26:8,
153:15, 153:20, 117:11, 117:17, rest [2] - 55:7, 65:18
129:17 26:25, 161:18
153:21, 163:5, 117:18, 117:20, restart [1] - 125:22
reconvene [1] - relationships [1] -
163:17, 163:18, 118:4, 120:6,
167:13 25:22 restarting [1] - 126:18
165:2, 165:4, 166:1, 121:23, 122:4,
record [68] - 4:14, relatively [3] - 153:23, restate [1] - 83:19
166:3, 167:2, 122:14, 122:23,
4:15, 7:3, 7:4, 7:6, 178:6, 181:20 results [2] - 53:10,
167:11, 168:6, 123:22, 123:24,
13:2, 13:3, 13:5, release [5] - 10:23, 168:23
168:10, 172:16, 124:23, 125:3,
19:24, 20:15, 20:18, 16:12, 16:19, retention [5] - 152:6,
175:20, 175:21, 174:8, 174:11,
39:6, 39:17, 39:18, 168:15, 168:16 152:7, 152:22,
175:22, 176:2 174:15
46:23, 46:24, 47:1, released [8] - 51:5, 152:25, 174:18
remembering [1] - reports [2] - 118:2,
53:8, 54:24, 80:21, 111:20, 112:2, retire [2] - 112:19,
93:15 118:8
80:25, 83:8, 85:23, 158:25, 168:6, 112:24
remembers [1] - 91:3 representations [1] -
86:2, 91:14, 93:11, 168:10, 168:13, review [9] - 24:23,
remote [2] - 115:20, 46:15
101:10, 101:12, 168:14 45:22, 106:25,
123:4 reproduced [2] -
101:13, 102:3, relevant [3] - 39:24, 107:13, 127:8,
remotely [4] - 110:12, 119:8, 119:24
102:8, 102:14, 141:16, 179:1 160:12, 174:10,
102:15, 102:17, 110:13, 110:18, reproducing [1] -
reliable [1] - 118:7 174:14, 176:19
105:7, 115:3, 120:9, 110:22 118:14
reliably [4] - 116:5, reviewed [6] - 127:7,
120:15, 120:21, remove [1] - 25:25 request [3] - 16:2,
116:11, 117:3, 127:11, 127:12,
121:19, 125:9, reoccur [1] - 165:17 22:15, 115:10
117:10 127:15, 130:3,
127:4, 127:13, repeat [3] - 63:18, requested [2] - 25:11, 134:16
rely [1] - 171:16
132:24, 134:9, 83:12, 118:14 167:24
remaining [2] - reviewing [4] - 102:4,
134:10, 134:15, repeatedly [1] - 67:12 require [1] - 108:21 113:18, 130:2,
115:19, 137:14
143:9, 152:10, repeating [1] - 116:16 required [6] - 66:14, 134:12
remember [120] - 8:5,
152:13, 158:7, rephrase [3] - 155:19, 104:7, 124:9, reviews [2] - 160:7,
8:11, 8:21, 9:3, 9:6,
158:16, 158:18, 173:4, 178:4 124:10, 124:11, 176:20
9:24, 9:25, 10:3,
161:8, 161:9, 162:4, rephrased [1] - 34:18 125:3 rewinding [1] - 23:7
10:24, 18:10, 24:17,
167:25, 168:3, rephraseing [1] - requirement [10] - rewritten [1] - 48:19
24:20, 24:21, 24:22,
168:4, 174:2, 174:3, 24:24, 25:1, 37:13, 34:19 17:8, 80:2, 80:6, Rick [3] - 176:4,
175:25, 183:25, 38:9, 40:1, 41:4, rephrasing [1] - 8:7 124:3, 124:25, 176:18, 177:7
184:2, 184:18, 41:6, 42:11, 42:20, replace [11] - 11:4, 125:2, 159:4, ride [1] - 99:23
184:19, 184:21 42:21, 42:22, 45:6, 14:7, 15:6, 15:8, 163:19, 164:19 risk [2] - 108:17,
records [2] - 124:19, 48:6, 48:7, 48:15, 15:15, 15:18, requirements [5] - 172:14
14
(201 of 291)
roadmap [1] - 11:24 save [2] - 110:19, 72:8, 73:14, 74:5, 175:11, 176:8, seeking [1] - 146:11
role [6] - 17:24, 32:4, 110:21 75:5, 76:10, 77:2, 176:24, 177:3, seem [1] - 87:9
32:6, 32:20, 74:18, saved [1] - 145:8 77:19, 77:21, 78:2, 177:11, 177:20, selfish [1] - 27:16
151:25 saw [4] - 37:25, 104:4, 78:7, 78:11, 79:22, 178:1, 178:24, send [5] - 25:2, 25:8,
roles [2] - 32:18, 124:18, 130:24 80:11, 80:17, 81:13, 179:16, 179:19, 25:12, 110:14,
32:19 SC [1] - 118:3 81:16, 81:21, 81:25, 179:25, 180:4, 114:20
rosy [1] - 143:5 Scabba [2] - 168:21, 82:5, 82:8, 82:13, 180:10, 180:13, sending [1] - 29:10
roughly [2] - 8:12, 170:8 82:19, 83:9, 83:15, 180:17, 182:3, sends [1] - 25:4
87:11 schedule [8] - 97:16, 84:3, 84:6, 85:14, 182:6, 182:13, senior [2] - 23:11,
route [1] - 147:21 97:21, 97:25, 98:17, 85:16, 86:25, 87:24, 182:18, 182:22, 69:15
RSVP [63] - 5:17, 5:24, 98:23, 98:25, 90:22, 91:13, 92:12, 183:4, 183:7, sense [5] - 61:2, 61:4,
6:22, 7:13, 7:17, 101:15, 101:20 94:2, 94:7, 95:10, 183:13, 183:22, 96:15, 150:7, 150:15
9:22, 10:5, 10:18, scheduled [1] - 12:7 97:2, 98:10, 98:16, 184:1, 184:9, 184:20 sent [9] - 25:9, 25:10,
11:15, 11:20, 14:2, schedules [1] - 99:9, 99:14, 99:25, Scullen [1] - 100:22 25:15, 107:4, 120:7,
14:18, 14:19, 15:22, 174:13 100:6, 100:13, search [4] - 118:17, 128:15, 128:16,
16:5, 16:19, 17:2, schedulewise [1] - 100:18, 100:23, 135:9, 135:10, 136:6, 136:7
17:24, 18:17, 26:20, 98:8 101:4, 101:7, 135:13 sentence [1] - 111:5
27:25, 28:3, 28:16, scheduling [10] - 101:11, 101:14, second [10] - 38:21, separate [1] - 65:7
29:6, 32:25, 33:7, 97:13, 97:14, 97:22, 102:3, 102:16, 53:16, 66:1, 93:23, September [3] -
76:7, 76:8, 76:12, 97:23, 98:4, 99:7, 105:9, 105:13, 93:24, 116:22, 24:11, 163:9, 164:16
76:15, 76:21, 77:1, 99:20 105:20, 106:4, 125:8, 134:9, 140:3, series [1] - 22:20
77:5, 77:9, 78:14, scope [2] - 28:22, 106:10, 106:15, 168:15 serious [5] - 8:3,
78:15, 79:1, 79:5, 28:24 106:19, 107:2, secondhand [1] - 59:19, 62:9, 108:17,
79:20, 80:3, 109:16, screen [17] - 42:17, 107:5, 108:11, 26:12 114:17
112:1, 112:2, 112:9, 43:1, 43:3, 43:5, 114:25, 116:18, secondly [1] - 47:21 server [3] - 56:4,
112:17, 113:8, 43:7, 43:13, 44:13, 116:20, 116:24, seconds [1] - 143:8 60:13, 138:14
113:24, 118:11, 45:4, 45:7, 45:8, 120:16, 120:21, Section [1] - 134:23 servers [3] - 11:6,
119:3, 120:14, 104:4, 104:5, 121:1, 121:12, section [1] - 135:2 142:3, 142:4
137:1, 142:15, 106:21, 120:4, 121:18, 122:5, sections [1] - 135:3 service [6] - 51:9,
143:13, 143:15, 120:23 122:9, 122:11, security [52] - 7:24, 53:25, 105:8,
143:21, 147:15, screens [5] - 119:1, 122:15, 123:14, 34:9, 50:22, 51:7, 108:23, 109:2,
147:18, 148:21, 119:2, 119:17, 120:1 125:5, 127:7, 51:15, 51:16, 51:18, 115:20
148:22, 157:21, 127:11, 127:15, 53:15, 55:2, 56:3,
SCULLEN [248] - 4:10, services [2] - 6:25,
159:2, 160:16 128:2, 128:5, 60:13, 63:22, 64:20,
7:7, 8:17, 9:13, 9:18, 7:11
run [9] - 43:18, 44:21, 128:20, 128:25, 65:7, 66:2, 69:3,
12:19, 13:4, 13:11, servicing [2] - 110:22,
54:4, 55:10, 102:21, 129:5, 129:22, 69:8, 69:25, 72:21,
13:14, 14:10, 14:15, 124:14
104:11, 104:14, 130:3, 130:9, 131:2, 80:4, 81:2, 81:4,
14:23, 15:1, 16:7, set [8] - 51:9, 54:4,
142:3, 142:4 131:8, 131:13, 81:7, 84:13, 88:11,
17:13, 19:1, 19:15, 54:5, 54:7, 54:17,
running [7] - 102:11, 131:18, 131:22, 96:25, 114:9, 168:7,
19:22, 20:4, 20:7, 64:7, 112:16, 161:19
110:5, 112:12, 132:2, 134:8, 168:8, 168:17,
20:14, 20:17, 21:2, setting [3] - 10:8,
113:7, 114:19, 134:14, 135:11, 168:18, 169:5,
21:11, 21:15, 22:2, 29:10, 29:14
137:2, 140:13 143:17, 146:4, 169:18, 169:19,
22:4, 22:14, 23:1, several [28] - 7:11,
runs [2] - 142:7, 147:4, 148:8, 170:4, 170:7,
23:19, 24:1, 28:1, 10:11, 16:9, 26:10,
176:20 148:12, 148:17, 170:12, 170:14,
28:14, 29:12, 30:12, 28:25, 48:22, 50:3,
149:15, 149:19, 171:18, 171:21,
30:22, 31:2, 34:3, 54:21, 54:23, 55:6,
151:13, 151:15,
S 34:6, 34:13, 34:16,
153:11, 154:18,
172:9, 172:12, 56:13, 59:11, 65:12,
34:20, 36:10, 36:14, 172:17, 173:6, 71:8, 72:2, 73:18,
155:5, 155:9, 173:9, 173:24,
36:21, 37:6, 37:13, 74:6, 78:16, 80:1,
Sachin [6] - 5:7, 155:13, 156:25, 174:1, 178:7, 179:4,
38:12, 38:20, 38:25, 107:23, 123:8,
144:4, 145:11, 157:4, 158:5, 181:17
39:11, 39:16, 41:9, 135:4, 135:14,
157:19, 157:20, 158:15, 159:11,
41:18, 44:8, 46:25, security-related [1] - 138:17, 144:11,
157:23 159:16, 159:22,
47:14, 51:2, 53:3, 69:3 170:9, 171:15,
Sachin's [2] - 145:21, 160:4, 161:1, 161:3,
53:20, 56:12, 56:16, see [15] - 15:3, 29:6, 172:14
158:8 161:22, 162:6,
56:20, 58:4, 58:14, 36:5, 46:18, 46:19, severity [3] - 80:10,
safe [1] - 147:21 162:14, 162:20, 46:21, 48:20, 54:8,
59:2, 60:22, 62:2, 80:11, 80:14
safety [3] - 114:9, 162:22, 163:1, 100:10, 104:2,
62:13, 62:17, 64:4, share [3] - 160:7,
114:23, 115:2 163:16, 167:14, 106:4, 120:18,
64:11, 65:4, 67:1, 160:8, 160:10
sales [4] - 8:2, 9:8, 167:17, 167:23, 121:25, 153:18,
67:9, 68:7, 68:12, sheet [3] - 25:2, 25:4,
9:9, 74:1 168:2, 169:23, 157:14
68:16, 68:20, 70:17, 144:19
sat [2] - 33:13, 49:15 170:2, 172:1, seeing [1] - 100:8
71:16, 71:19, 71:24, ship [2] - 126:5,
Saturday [1] - 73:22 174:23, 175:1,
15
(202 of 291)
132:19 46:19, 46:21, 46:22, 103:14, 152:9 State [1] - 183:18 176:6, 176:20
shooting [1] - 163:10 48:2, 48:20 sort [11] - 10:9, 35:20, statement [13] - 9:15, Stuff [1] - 163:25
shop [2] - 6:17, 6:18 soft [2] - 153:4, 40:23, 57:14, 69:13, 62:3, 70:18, 74:7, subject [1] - 105:21
Short [2] - 80:21, 174:25 75:16, 83:24, 77:25, 81:24, 82:1, Subodh [1] - 26:22
125:9 software [52] - 6:14, 103:15, 105:1, 83:19, 93:21, 112:1, success [1] - 154:15
short [2] - 39:6, 168:4 6:23, 6:24, 7:21, 164:14 116:12, 117:5, 172:2 Suchecki [2] - 23:9,
shot [14] - 15:3, 42:17, 7:22, 11:6, 12:12, sorting [1] - 55:24 statement/question 26:21
43:1, 43:3, 43:5, 12:14, 17:12, 18:2, sought [1] - 149:22 [1] - 67:12 suddenly [1] - 57:12
43:13, 44:13, 45:4, 40:10, 40:19, 109:9, sounds [2] - 127:21 statements [5] - suggest [3] - 92:4,
45:7, 69:21, 104:5, 109:10, 109:12, source [3] - 102:25, 56:14, 67:17, 81:22, 146:7, 184:13
111:24 109:17, 109:22, 112:22, 172:19 92:24, 157:1 suggesting [1] - 63:2
shots [1] - 43:7 109:25, 110:6, speaking [1] - 163:13 stating [1] - 22:21 summarized [1] -
shoulder [4] - 61:20, 110:7, 110:11, speaks [2] - 131:3, status [2] - 10:17, 103:16
62:8, 72:6, 95:20 110:18, 110:23, 150:17 10:19 Sunday [2] - 73:22
shouting [1] - 27:9 111:1, 111:14, specific [19] - 7:21, stay [2] - 13:4, 105:16 support [5] - 11:18,
show [4] - 36:4, 120:8, 111:21, 112:8, 14:5, 14:12, 25:16, stayed [4] - 76:5, 76:6, 11:23, 12:16, 17:3,
153:18, 153:19 112:13, 112:14, 44:20, 50:16, 50:25, 76:9, 167:18 105:1
showed [1] - 157:10 112:17, 112:20, 79:24, 80:9, 84:22, step [1] - 13:8 Support [1] - 133:2
showing [4] - 64:25, 112:25, 113:3, 88:23, 118:22, stereotype [3] - 155:4, SupportCentral [1] -
106:1, 156:2, 181:21 113:7, 113:17, 133:17, 135:18, 156:19, 157:10 135:5
shows [1] - 110:2 113:21, 114:15, 140:18, 141:10, still [10] - 22:9, 113:4, supporting [2] -
side [16] - 26:9, 33:3, 114:17, 119:19, 143:19, 143:20, 113:5, 113:23, 11:13, 12:12
33:5, 68:14, 69:25, 124:4, 126:23, 181:12 114:1, 114:6, Suppose [1] - 45:17
115:16, 124:20, 130:17, 132:9, specifically [7] - 156:15, 167:3, suppose [1] - 86:9
137:21, 137:24, 132:19, 132:20, 13:23, 30:10, 31:6, 170:14, 171:21 supposed [13] - 30:18,
138:8, 142:1, 142:3, 138:3, 138:4, 142:8, 34:25, 145:15, stop [10] - 24:2, 38:20, 30:19, 30:21, 37:20,
156:14 142:10, 148:4, 152:15, 153:15 87:24, 91:16, 92:7, 40:8, 40:9, 40:18,
side's [1] - 74:20 173:16, 173:18 specifics [4] - 25:24, 92:15, 92:21, 54:4, 55:10, 60:21,
sides [2] - 26:13, Solaris [2] - 142:4, 28:23, 55:11, 80:7 113:18, 125:21, 132:16, 158:3, 159:3
153:8 142:10 speculation [1] - 97:3 183:22 Surgery [21] - 4:7,
sign [1] - 62:1 Solaris-based [1] - speculative [2] - stopped [10] - 10:21, 4:18, 8:2, 8:9, 8:14,
significant [1] - 136:8 142:10 86:25, 175:6 10:25, 12:4, 21:2, 8:16, 8:25, 9:8, 9:9,
similar [4] - 30:20, solely [2] - 44:15, speed [1] - 37:21 21:8, 118:9, 120:11, 9:12, 33:8, 42:12,
32:22, 119:2, 127:21 109:3 spending [1] - 73:21 125:13, 129:14, 50:2, 60:13, 73:25,
sit [4] - 27:7, 27:11, solution [3] - 12:9, spent [2] - 73:17, 74:6 149:1 96:17, 125:12,
35:8, 108:11 103:12, 103:17 spots [1] - 150:20 stopping [1] - 183:23 125:17, 129:10,
sits [1] - 176:18 solvable [1] - 65:24 SPR [2] - 106:6, 115:3 story [1] - 91:3 137:8, 140:6
sitting [3] - 73:18, solve [1] - 103:3 spreadsheet [4] - straight [1] - 103:1 surprise [2] - 36:15,
150:3, 165:6 solved [1] - 126:24 24:19, 25:5, 25:12, strategy [6] - 28:12, 141:11
situation [3] - 48:15, solving [1] - 90:2 144:20 28:21, 29:10, 29:15, surprised [4] - 36:12,
53:22, 181:10 someone [9] - 35:23, SPRs [3] - 112:4, 171:18, 172:9 37:3, 37:10, 52:8
six [3] - 70:23, 71:1, 63:14, 105:2, 112:13, 137:22 Stratton [19] - 5:3, surprising [1] - 57:13
152:14 135:22, 140:10, stab [1] - 87:3 17:23, 23:10, 24:16, surrounding [2] -
size [2] - 16:24, 16:25 142:25, 177:10, Stadium [2] - 145:11 26:21, 32:16, 33:15, 54:10, 137:6
178:15, 181:3 stage [1] - 77:11 37:20, 137:14, system [22] - 7:23,
skill [2] - 73:2, 180:23
sometime [2] - 11:4, stages [1] - 111:20 146:25, 150:23, 8:12, 10:4, 15:11,
skills [14] - 74:17,
16:20 staging [1] - 139:21 151:9, 158:20, 30:2, 31:16, 31:18,
75:24, 85:3, 86:14,
146:14, 153:4, sometimes [13] - 24:7, stake [3] - 21:6, 21:10, 158:21, 158:22, 33:1, 52:9, 54:6,
156:4, 156:11, 24:18, 24:19, 24:20, 24:13 158:23, 159:1, 54:10, 54:14,
157:15, 173:9, 54:17, 54:18, 57:15, start [8] - 51:3, 51:13, 166:24, 167:7 106:24, 107:13,
174:25, 177:18, 87:7, 111:2, 145:3, 51:22, 78:21, 91:20, Stratton's [1] - 24:10 110:12, 124:4,
180:25 150:8, 150:11, 100:20, 143:3, stressed [1] - 166:8 130:22, 136:15,
150:12 170:24 strong [1] - 99:5 137:23, 138:4,
skillset [1] - 145:14
somewhat [1] - 10:15 started [12] - 12:3, stuff [20] - 7:23, 7:24, 139:18, 173:23
slide [1] - 109:19
somewhere [2] - 5:6, 38:9, 38:11, 53:11, 43:13, 52:10, 52:13, systems [1] - 11:10
Snowden [1] - 171:4
148:23 54:1, 101:8, 148:5, 54:11, 54:12, 61:14,
SOA [1] - 6:21
soon [2] - 109:21,
SOAP [16] - 42:18, 148:20, 148:21, 61:15, 65:8, 69:25, T
112:10 172:6, 182:14 135:2, 138:5,
42:25, 43:9, 43:10,
Sorry [1] - 125:7 starting [2] - 77:11, 139:17, 145:23,
44:5, 45:5, 45:21,
sorry [3] - 102:19, 149:10, 176:4, table [1] - 159:15
46:10, 46:11, 46:12, 128:19
16
(203 of 291)
tables [1] - 123:8 87:8, 87:12, 87:15, terms [21] - 10:20, 67:19, 76:11, 78:8, timely [2] - 75:2, 81:10
targeted [1] - 174:24 87:18, 88:7, 88:8, 13:9, 14:6, 15:22, 80:23, 81:17, 83:10, title [2] - 30:5, 32:14
task [1] - 139:1 88:16, 88:18, 88:21, 15:25, 16:4, 16:6, 85:17, 87:23, 99:10, titles [1] - 32:18
tasks [2] - 40:11, 96:7, 96:10, 96:22, 16:23, 17:4, 17:11, 131:18, 155:10, today [8] - 77:12,
76:20 102:20, 115:4, 26:25, 30:15, 39:21, 155:14, 177:21, 78:10, 84:23,
team [94] - 5:16, 5:17, 125:24, 130:13, 52:12, 80:15, 84:12, 180:9 100:24, 117:10,
5:18, 5:24, 6:9, 142:14, 142:19, 85:22, 93:17, testing [25] - 32:21, 118:8, 135:21,
15:24, 17:7, 18:21, 142:22, 143:3, 117:16, 153:3, 167:9 41:16, 43:6, 43:14, 170:15
23:8, 23:11, 23:14, 143:11, 143:14, terrible [1] - 51:7 50:2, 50:8, 61:25, together [8] - 4:5,
25:20, 26:15, 26:16, 143:16, 143:24, test [81] - 31:21, 40:6, 64:2, 81:6, 81:10, 35:6, 48:5, 51:23,
26:17, 26:20, 27:5, 145:17, 146:13, 40:9, 40:19, 40:21, 96:25, 137:10, 61:4, 121:25,
27:22, 28:13, 28:15, 149:7, 149:10, 41:15, 42:13, 42:16, 137:17, 138:11, 138:20, 156:16
28:16, 28:21, 29:15, 149:12, 155:8, 43:2, 43:4, 43:5, 139:2, 139:7, tons [3] - 57:22,
29:24, 30:4, 30:5, 156:4, 156:10, 43:13, 43:16, 43:21, 139:20, 139:23, 60:16, 60:18
30:7, 30:8, 30:11, 157:12, 157:25, 43:23, 43:25, 44:12, 140:10, 141:9, took [9] - 11:25,
30:20, 30:24, 31:4, 159:5, 159:8, 173:3, 44:21, 44:23, 45:1, 143:4, 168:21, 16:11, 70:22, 127:1,
32:12, 32:13, 35:14, 176:20, 177:16, 45:6, 45:12, 45:19, 170:8, 172:20 150:5, 175:18,
35:15, 35:19, 35:25, 177:17, 177:18, 48:19, 51:4, 52:9, tests [1] - 140:21 175:20, 175:21,
42:16, 55:7, 59:12, 178:2, 178:7, 178:9, 53:10, 54:6, 54:9, text [3] - 45:8, 46:13, 175:22
59:17, 60:9, 61:19, 178:10, 178:11, 54:14, 59:9, 61:24, 48:21 tool [1] - 108:23
62:7, 63:8, 64:7, 178:16, 178:17, 62:1, 65:11, 66:8, THE [24] - 7:10, 8:19, tools [1] - 43:17
64:19, 64:24, 65:18, 178:20, 178:21, 66:13, 71:10, 71:22, 12:22, 13:22, 14:1, top [1] - 147:24
66:16, 69:6, 69:14, 179:4, 179:6, 179:8, 75:1, 75:16, 81:2, 30:14, 37:15, 53:7, topic [3] - 151:1,
69:16, 69:23, 69:24, 179:10, 180:23, 85:10, 89:2, 94:13, 77:20, 78:13, 80:13, 152:20, 166:11
72:19, 72:23, 73:3, 180:24, 181:4, 96:12, 97:9, 101:21, 83:12, 83:17, 95:12, totally [6] - 17:15,
75:3, 75:11, 75:15, 181:18, 181:22, 127:19, 127:25, 100:8, 101:15, 20:1, 47:19, 68:20,
76:14, 78:17, 81:4, 181:25 128:19, 129:20, 121:10, 127:17, 154:20, 178:25
83:24, 84:1, 84:11, technically [12] - 130:25, 131:1, 130:6, 130:14, toward [1] - 148:20
85:2, 87:5, 88:8, 35:18, 60:25, 61:5, 131:12, 131:21, 155:16, 161:5, towards [1] - 153:5
89:7, 89:18, 90:15, 65:15, 66:10, 66:18, 132:3, 137:9, 172:3, 182:24 track [2] - 124:12,
94:18, 95:3, 98:25, 117:16, 149:8, 137:17, 138:13, themselves [1] - 170:21
99:8, 131:21, 154:23, 155:15, 138:14, 138:17, 27:17 tracking [1] - 137:23
132:19, 137:13, 155:18, 157:14 139:1, 139:5, theory [2] - 47:17, traffic [1] - 169:3
140:23, 141:2, technologies [1] - 139:12, 139:14, 47:24 trail [5] - 117:22,
143:25, 144:1, 6:16 140:1, 140:7, therefore [1] - 74:3 118:8, 123:25,
150:9, 150:14, technology [8] - 6:12, 140:13, 140:16, They've [1] - 35:14 124:5, 125:1
154:10, 156:16, 7:18, 52:8, 66:9, 140:20, 141:8, thinking [2] - 59:18, trails [1] - 117:21
157:16, 178:8, 69:17, 84:12, 141:15, 141:18, 155:4 trained [1] - 21:5
181:23 145:18, 179:7 151:2, 151:5, 168:8, thinks [3] - 98:17, training [28] - 9:8,
teams [2] - 28:17, technology-based [1] 168:17 151:18, 184:23 9:10, 70:16, 70:20,
156:12 - 7:18 tested [3] - 52:15, third [2] - 172:15, 70:22, 71:5, 152:4,
technical [117] - 27:3, teddy [2] - 166:13, 173:16 173:14 152:9, 152:10,
51:1, 61:8, 61:14, 166:18 testified [14] - 8:18, third-party [2] - 152:13, 152:16,
65:23, 66:19, 66:20, telephone [1] - 136:15 21:11, 30:23, 31:3, 172:15, 173:14 152:21, 153:5,
69:7, 69:22, 72:24, television [1] - 27:15 58:16, 58:19, 67:3, thirdhand [1] - 26:12 153:14, 153:17,
73:1, 73:4, 73:9, temple [1] - 163:9 67:14, 67:16, 79:22, thoughts [1] - 41:24 173:22, 174:17,
73:13, 74:13, 74:17, ten [9] - 63:15, 63:17, 175:2, 177:5, threat [3] - 171:11, 174:19, 174:22,
74:21, 75:14, 75:15, 89:20, 95:5, 108:14, 180:18, 184:2 171:12, 171:13 174:24, 175:2,
75:21, 75:25, 76:4, 110:2, 110:3, testify [14] - 15:2, three [16] - 5:14, 12:8, 175:4, 175:10,
76:6, 76:9, 76:20, 111:10, 111:15 41:20, 72:9, 98:11, 17:25, 19:4, 21:7, 175:15, 175:18,
76:21, 76:25, 77:4, tenth [1] - 162:7 99:14, 100:2, 21:9, 23:9, 34:9, 175:25, 179:14
77:15, 78:22, 78:23, term [7] - 68:6, 68:21, 106:21, 122:5, 48:4, 51:22, 70:16, transcripts [1] - 20:11
78:25, 79:3, 79:7, 115:4, 144:13, 122:7, 128:25, 79:23, 116:6, transfer [1] - 124:15
79:10, 79:17, 79:19, 144:21, 144:23, 132:4, 132:5, 117:13, 163:13, transformers [1] -
80:9, 83:4, 83:25, 166:13 159:24, 178:1 169:24 17:2
84:1, 84:14, 85:1, terminated [1] - 12:2 testifying [4] - 8:18, throughout [1] - 60:2 translate [1] - 46:20
85:6, 85:9, 85:15, termination [1] - 34:4, 36:11, 177:3 timeframe [5] - 9:24, treat [2] - 177:15,
85:19, 85:25, 86:3, 162:19 testimony [21] - 12:21, 39:24, 41:4, 74:23, 182:2
86:5, 86:10, 86:13, terminology [1] - 19:16, 22:5, 23:20, 149:4 treated [3] - 19:12,
87:3, 87:4, 87:5, 109:21 37:8, 67:3, 67:11, timeline [1] - 164:12 58:18, 182:2
17
(204 of 291)
treatment [4] - 58:23, 92:11, 92:13, 94:5, 134:1, 134:23, 155:3, 155:4 136:3, 136:14, 142:7
58:24, 59:3, 182:10 95:14, 97:4, 97:12, 135:19, 136:3 unconsciously [3] - uses [1] - 7:10
trending [1] - 115:22 98:12, 99:3, 99:11, true [6] - 7:20, 29:5, 156:17, 156:18,
Trends [1] - 106:6 99:19, 100:4, 44:4, 86:6, 114:2, 157:10 V
trial [4] - 68:5, 68:11, 100:12, 100:16, 133:7 uncovering [1] - 54:9
68:18 100:21, 101:2, truth [16] - 20:13, under [1] - 22:17
101:5, 101:17, vague [25] - 7:8,
tricky [1] - 126:25 22:24, 60:19, 74:11, underneath [1] -
102:13, 102:18, 12:20, 13:11, 16:7,
tried [1] - 111:23 74:12, 88:2, 91:12, 120:4
105:11, 105:17, 17:14, 28:1, 28:14,
tries [1] - 183:9 92:16, 92:17, 93:1, understood [2] -
105:23, 106:8, 29:12, 30:13, 53:21,
Trivedi [40] - 8:17, 150:17, 150:22, 88:17, 96:9
106:13, 106:17, 71:16, 73:14, 77:2,
19:2, 19:23, 22:14, 160:1, 160:2, 177:9 unintelligible [2] -
106:23, 107:4, 77:6, 87:1, 104:22,
23:1, 30:22, 34:3, try [6] - 107:14, 151:15, 155:6
107:10, 107:12, 123:14, 143:17,
36:10, 38:12, 47:2, 146:14, 165:10, uninterrupted [1] -
116:16, 116:19, 149:16, 154:19,
47:15, 67:9, 67:25, 170:18, 171:22, 94:10
116:22, 117:1, 155:5, 164:9,
70:18, 72:8, 74:5, 171:23 Unix [1] - 142:3
120:17, 120:24, 177:21, 177:23,
77:21, 81:13, 82:5, trying [22] - 9:12, unless [3] - 91:11,
121:7, 121:14, 182:13
87:24, 100:13, 12:23, 34:5, 37:11, 106:22, 142:24
121:20, 125:6, vaguely [1] - 129:11
101:7, 105:10, 43:15, 49:2, 56:1, unnecessarily [1] -
125:10, 126:7, various [2] - 10:1,
105:20, 106:19, 56:2, 62:5, 64:7, 164:4
127:4, 127:10, 76:17
120:22, 121:5, 69:17, 74:9, 81:14, unnecessary [1] -
127:12, 127:18, 83:11, 119:1, 119:5, vast [1] - 171:1
125:5, 129:22, 148:10
128:3, 128:8, 126:22, 146:7, vended [2] - 112:21,
130:11, 131:14, unplugging [1] -
128:23, 129:3, 147:16, 161:19, 169:16
134:8, 148:12, 126:17
129:7, 129:8, 130:1, 161:24, 172:16 vendor [1] - 168:12
154:18, 162:6, unresolved [3] -
130:4, 130:8, turn [1] - 103:12 venting [1] - 165:24
175:1, 178:24, 110:2, 110:3, 111:10
130:12, 130:15, turned [1] - 51:12 veracity [1] - 91:22
179:25, 184:2, up [39] - 10:14, 10:18,
184:21 131:6, 131:11, TV [1] - 27:14 verify [1] - 162:25
12:22, 16:18, 25:6,
TRIVEDI [218] - 4:13, 131:16, 131:20, twice [2] - 163:2, version [2] - 54:20,
29:10, 29:14, 37:20,
4:16, 7:3, 7:5, 7:12, 131:25, 132:8, 180:19 111:21
41:1, 51:9, 54:4,
8:20, 13:1, 13:7, 132:23, 132:25, two [26] - 4:3, 5:8, versions [3] - 44:22,
54:5, 54:7, 54:17,
13:13, 13:17, 13:20, 134:12, 143:7, 5:14, 5:21, 11:19, 103:11, 133:24
57:22, 58:3, 60:3,
13:25, 14:3, 14:13, 143:10, 146:7, 12:8, 15:24, 17:12, versus [2] - 65:11,
64:7, 69:18, 92:20,
14:17, 14:25, 17:18, 148:9, 148:14, 18:2, 18:23, 21:7, 74:24
96:1, 113:21,
19:19, 20:2, 20:5, 149:21, 155:12, 21:8, 27:8, 28:17, view [3] - 69:5, 116:3,
114:19, 119:4,
20:12, 20:16, 20:23, 155:17, 157:2, 40:10, 43:6, 46:15, 121:9
122:1, 122:12,
21:4, 21:13, 21:22, 157:9, 158:12, 82:1, 87:7, 87:12, Viewer [2] - 134:20,
135:9, 138:4, 138:5,
22:13, 22:15, 23:6, 159:14, 159:20, 93:6, 108:14, 125:8, 138:3
139:17, 142:12,
30:25, 31:9, 31:24, 159:25, 161:2, 146:17, 159:7, views [7] - 17:14,
142:25, 156:2,
34:5, 34:15, 34:18, 161:7, 161:10, 163:13 19:17, 21:19, 98:21,
157:17, 161:19,
34:23, 36:12, 36:18, 161:24, 162:4, two-minute [1] - 82:1 154:19, 175:5,
163:5, 167:22,
36:23, 37:9, 37:17, 162:9, 162:17, type [3] - 66:24, 77:16, 178:25
178:16, 178:20
38:23, 39:3, 39:7, 162:21, 162:24, 108:16 Visual [1] - 103:13
update [2] - 136:1
39:14, 39:19, 41:7, 163:4, 167:13, typically [1] - 32:14 VNC [9] - 50:19,
updated [1] - 136:3
41:11, 41:22, 46:23, 167:15, 167:21, 53:25, 54:11, 54:16,
upgrade [3] - 11:7,
168:5, 169:25, 55:10, 56:4, 60:13,
47:6, 47:25, 53:5,
170:3, 171:25,
U 148:3, 149:3
53:9, 54:22, 54:25, 61:3
upgraded [1] - 172:24
56:15, 56:19, 56:22, 172:5, 174:2, 174:4, volcano [5] - 165:8,
upset [1] - 49:4
56:25, 58:20, 62:5, 175:8, 176:10, U.S [2] - 184:7, 184:8 165:11, 166:4,
urgency [2] - 150:7,
62:15, 62:20, 62:23, 177:1, 177:8, ultimately [4] - 20:21, 166:6, 166:18
150:15
63:15, 64:6, 64:13, 177:13, 177:23, 47:19, 65:14, 126:22 vulnerabilities [6] -
urgent [1] - 150:16
67:7, 67:21, 68:4, 178:4, 180:2, 180:7, um-hum [4] - 5:19, 168:24, 170:8,
usability [1] - 120:13
68:10, 68:13, 68:18, 180:11, 180:15, 10:7, 18:18, 50:5 170:22, 171:3,
180:18, 182:5, usable [1] - 118:17
68:23, 68:25, 74:8, unavailable [1] - 172:25, 173:18
182:9, 182:16, useful [3] - 117:23,
77:24, 78:4, 78:9, 136:21 vulnerability [15] -
182:20, 182:25, 118:6, 122:25
79:4, 80:14, 80:20, uncheck [2] - 103:24, 51:17, 51:18, 53:15,
183:11, 183:15, user [6] - 119:14,
80:24, 81:14, 81:20, 104:15 56:4, 66:2, 72:21,
184:6, 184:16 169:2, 169:10,
81:23, 82:2, 82:7, unchecked [1] - 104:7 80:5, 81:3, 169:19,
trivial [1] - 108:15 170:6, 170:10,
82:11, 82:15, 83:1, unclear [2] - 28:12, 170:14, 170:18,
trouble [1] - 134:19 172:23
83:11, 83:14, 83:21, 28:21 170:19, 172:12,
troubleshooting [6] - users [6] - 104:25,
84:8, 88:1, 90:24, unconscious [2] - 178:7, 181:17
133:18, 133:21, 115:17, 116:2,
18
(205 of 291)
W 47:2, 47:21, 47:22, Y

67:24, 67:25, 68:4,
68:6, 68:13, 68:15,
wait [3] - 4:10, 86:7, 75:6, 77:22, 81:18, year [17] - 14:11,
128:2 82:9, 82:22, 91:15, 14:13, 14:14, 14:15,
Walls [4] - 118:9, 91:18, 91:20, 92:1, 14:25, 24:21, 24:23,
118:13, 120:10, 92:3, 92:9, 92:15, 24:25, 25:11, 38:14,
121:22 92:22, 92:23, 98:20, 144:5, 145:21,
wants [1] - 151:23 99:1, 99:16, 100:14, 146:16, 146:20,
wasting [3] - 162:15, 100:24, 105:14, 166:12
162:20, 162:22 105:21, 106:20, years [37] - 5:1, 5:4,
watching [1] - 46:18 107:6, 107:7, 121:3, 5:6, 5:8, 5:10, 5:13,
wave [1] - 159:17 130:1, 131:15, 5:14, 9:5, 11:5,
ways [3] - 30:3, 114:4, 132:4, 158:11, 11:19, 12:8, 15:24,
184:3 158:18, 159:13, 16:14, 17:12, 18:2,
WCF [5] - 6:20, 159:16, 159:23, 18:23, 19:20, 29:8,
158:23, 159:3, 161:3, 185:1 45:2, 57:12, 78:16,
160:15, 161:2 WITNESS [24] - 7:10, 110:2, 110:3,
weak [2] - 165:21 8:19, 12:22, 13:22, 111:10, 111:15,
weaknesses [2] - 14:1, 30:14, 37:15, 116:15, 117:10,
150:20, 156:3 53:7, 77:20, 78:13, 118:6, 151:7,
wear [1] - 161:11 80:13, 83:12, 83:17, 152:14, 153:24,
web [2] - 6:25, 7:10 95:12, 100:8, 153:25, 154:14,
website [2] - 168:8, 101:15, 121:10, 159:7, 166:19,
171:20 127:17, 130:6, 168:11, 172:23
week [4] - 70:22, 71:5, 130:14, 155:16, yesterday [3] - 16:24,
106:25, 146:20 161:5, 172:3, 182:24 26:19, 106:12
week-long [1] - 71:5 Witness [1] - 101:16 yourself [1] - 77:18
weekends [1] - 73:18 woman [1] - 157:7
weekly [2] - 136:15, women [2] - 153:6, Z
145:22 154:17
weeks [2] - 11:16, word [3] - 64:6, 71:8,
zero [1] - 66:17
35:7 99:5
whole [12] - 58:3, wording [2] - 18:10,
73:18, 73:21, 73:23, 77:12
84:24, 85:15, 91:2, words [2] - 22:23,
100:5, 110:16, 46:14
112:16, 161:2, 163:7 workload [2] - 9:23,
widespread [1] - 10:2
133:13 works [6] - 40:20,
willing [1] - 58:18 40:21, 50:14, 98:6,
Windows [35] - 6:20, 117:16, 138:19
40:22, 43:15, 43:19, worse [2] - 110:6,
44:2, 44:15, 44:20, 111:3
44:21, 44:25, 45:15, write [6] - 32:21,
46:1, 46:8, 48:10, 41:14, 44:23, 45:12,
48:18, 49:7, 55:17, 139:12, 184:24
57:4, 59:10, 59:19, writing [3] - 45:13,
65:11, 65:17, 66:6, 143:5, 156:23
71:10, 72:17, 74:24, written [8] - 40:21,
75:16, 85:10, 98:6, 43:5, 43:12, 43:21,
141:21, 141:22, 44:24, 45:14, 46:13,
142:6, 142:9, 103:7
142:11, 158:23 wrongdoing [1] -
Windows-based [1] - 160:3
142:9 wrote [4] - 101:19,
Wireshark [1] - 48:17 103:6, 128:11
witness [52] - 20:24,
22:9, 23:4, 24:2,
27:19, 36:17, 38:21,
19
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Document >>> Insite2.0_3Q_2012.ppt powerpoint (I am attaching it so it is all in one

email)
>>> slide number 9

Open Issues:
465 Design Non-Conformances
means serious defects...
>>> slide number 7

2Q Review showed a massive decline in performance in February.
Investigation found that was a measurement error. A new robot was brought
online in Beijing in Feb and was skewing our numbers.
We can now see our performance is gradually getting worse as new devices are
added, which matches the reports we are getting from users.
>>> slide number 8

Not-so-Good News
We have been experiencing a large number of issues on the device-facing
side of the application. This means that even though users can get
into the Questra app, they cannot use remote service features of the
application. We have mechanisms to detect this issue, but not to do trending on it.
(230 of 291)
Insite Platform
System Performance Review
FW44 12
Data for Insite2.0 (3Q/2012)
Presenter: Nate Davis

(231 of 291)
Agenda
- Architecture Overview
- Utilization / Growth Data
- CTQ Summary and Data
- Drill-down on CTQ gaps
- SPR Summary and Data
(232 of 291)
Simple Block Diagram of Solution

Deployment Diagram
Web Servers Web Servers
Application
(Device-facing) (User-facing)
Servers
Machine Data
Database
Server
Tunneling
Servers
File Server
3
(NAS) GE Healthcare
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Insite2 Device Growth
Year New Systems Cumulative % Increase

- 79,708 Registered Devices (4k new in 2004 16 16
3Q) 2005 485 501 3031.25
2006 4360 4861 870.259481
- Double-digit growth every year 2007 8011 12872 164.8014812
- No mechanism to retire devices from 2008 11916 24788 92.57302672
2009 12710 37498 51.27481039
database when out-of-service 2010 13972 51470 37.2606539
- Will pass 100k devices by 3Q-2013 2011 15685 67155 30.47406256
2012 12553 79708 18.69257687
4
GE Healthcare
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Insite2 Modality Break-Down
Ultrasound + LCS make up 2/3 of our device population

and are both growing at increasing rates.
5
GE Healthcare
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CTQ Summary
CTQ Summary
CTQ Measured@ Specs Actual

Application Availability Topaz >= 98% 99.3%
Performance - Time to process Topaz 7 seconds 4.8 seconds

an inbound request
Application Utilization Insite 2 < 67,850 79,708

(Concurrent)
Registered
Devices
Note: CTQs from MDEX Gen 3 program (M4 in March 08)
6
GE Healthcare
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Performance CTQ Deep Dive

Performance
Performance over past 12 months
2Q Review showed a massive decline
in performance in February.
Investigation found that was a

measurement error. A new robot was
brought online in Beijing in Feb and
was skewing our numbers.
We can now see our performance is

gradually getting worse as new devices
are added, which matches the reports
we are getting from users.
Specifically, pages that do deep

searches (gathering select data from
multiple DB tables) are getting slower.
URL
Login
Device Search
Load Device Page
7
GE Healthcare
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CTQ Deep Dive

Issues / Actions
Good News
Application Uptime has been in-spec for 7 consecutive months
Not-so-Good News
We have been experiencing a large number of issues on the device-facing side of the
application. This means that even though users can get into the Questra app, they
cannot use remote service features of the application. We have mechanisms to detect
this issue, but not to do trending on it.
Ongoing Effort
Our team of volunteers meets weekly to try to isolate and address the highest impact
issues. (See attached excel tracker)
8
GE Healthcare
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SPR Trends
Changes in 3Q:
Count of id Classification
Year State Defect-Design NC Improvement Opportunity Grand Total
15 SPRs closed
2004 Assigned 2 2 4 Reviewed and dispostioned
New 4 4 8 with justification 12
2005 Assigned 5 8 13
New 6 4 10
Unacceptable Risk sprs
Resolved 1 1 2 imported incorrectly from
2006 Assigned 45 14 59
DDTS
New 32 9 41
Resolved 27 7 34
2007 Assigned 27 5 32
New 258 52 310
Resolved 18 8 26 5.2 release
2008 Assigned 9 1 10
New 6 1 7
Resolved 1 1
2009 Assigned 1 1 Open Issues:
New 5 2 7
2010 New 12 2 14
465 Design Non-
Conformances
2011 Assigned 3 3 124 Improvement Opportunity
Will be closed with justification
New 5 2 7 when RSvP program retires
Questra back-office
Grand Total 465 124 589
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Insite 2.0 Service SupportCentral Cases
Insite2 Service Ops 2012 SC Cases: 43
- 35 Open
- 8 Closed
Note: No cases closed until 3Q new staffing (Mike Walls) put in place to help
address these since last quarter
Insite ExC 2012 SC Cases: 18

- 4 Open
- 14 Closed
Note: Keeping up well on these due to helpful volunteers (Chris B, Madhuri,
Glyn)
Take-Away: Added staffing to help investigate issues is

helping to alleviate user frustration with the app. We need
to keep people assigned to this.
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Performance CTQ Deep Dive

Performance
Performance over past 12 months
**Back-up slide. Averaged by month instead of by week. **
URL
Login
Device Search
Load Device Page
12
GE Healthcare
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Case no:
17-15217
IN THE UNITED STATES APPELLATE COURT
FOR THE NINTH CIRCUIT
Madhuri Trivedi vs. U.S. DEPARTMENT OF HOMELAND SECURITY, John F. Kelly, in his
Official Capacity as Secretary of Homeland Security, U.S. CITIZENSHIP AND
IMMIGRATION SERVICES, Lori Scialabba in her Official Capacity as Director- U.S.
Citizenship and Immigration Services,
Donald Neufeld -director USCIS service center in his individual capacity,
Greggory Richardson- director TSC - in his individual capacity,
Mark Hazuda- Director NSC - in his individual capacity,
John Roth, OIG - in his individual capacity,
Maria Odom-DHS- in her individual capacity
Letter detailing GE issues, deposition, arbitration, 600 defects on 100,000 medical

devices for several years, wrongful /illegal termination and loss of immigration
and wages as a retaliation of not participating in GEs fraud scheme
_________________________________________________________________
Appellant MADHURI TRIVEDI March 4th 2017
Founder, CEO OrangeHealth( start up)

P.O. Box 8359, Fremont, CA 94537
Madhuri.orangehc@gmail.com Phone: 650-242-5135 Fax: 708-774-4859
Copy to: Patrick Hale (He just retired)

Email : pat_hale@mit.edu
Director System Design and Management (SDM) and SDM Sloan Fellow program
Massachusetts Institute of Technology and MIT Sloan school of Management
Case 17-15217 Madhuri Trivedi Page 1 of 7
(243 of 291)
Hon. Circuit Judge Clanby and Clifton,
Department of Justice needs to be renamed as Department of Injustice.

I wrote a short motion for injunctive relief upon this court and appellate
court and both judges have shown no respect, empathy and sympathy. DHS has
done TORT, intentional infliction of emotional distress and hardship. GE despite
my stellar performance to cover up their fraud illegally and wrongfully terminated
me ; along with my wages and immigration.
Judges could have looked at whole record and try to resolve..I am surprised
how tax payers money are used and how talented, honest people for doing right,
lawful thing get such treatment
Exhibit 3..all 600 defects were closed in one day without doing anything during
last few months I was there..GE argument was that they will be addressed/closed when
existing product is replaced with new product. But when defects were closed there was
no new product in existence. And GE was replacing back office software and not medical
device software. Replacing medical device software on 100,000 devices requires
RECALL from GE or FDA.
1) Deposition of Genera Eletric architect William Barbiaux taken by Madhuri

Trivedi
2) Exhibits of Deposition of GE architect William Barbiaux
3) Description of GE document
GE document describing 496 design non conformances(defects) in
PRODUCTION for several years and worst performance on medical devices
side, 100,000 medical devices including MRI, CT scan, ultrasound, LCS and
more
4) GE document describing 496 design non conformances(defects) in
PRODUCTION for several years and worst performance on medical devices

(244 of 291)
side, 100,000 medical devices including MRI, CT scan, ultrasound, LCS and
more
5) Immigration email with Dave and Nate before joining GEHC
6) After I raised serious concerns and issues in GEs performance ranking
system during my arbitration with GE, GE ended it as per new article blow.
General Electric is ending annual performance reviews

7) AAA 51 160 01260 13 Subpoena witness
Where GE CEO Mike Swinford, GE CTO Mike Harsh came to testify
8) AAA 51 160 01260 13 Subpoena document
Those male engineers who were responsible for GE product Insite Exc despite
having uncompetitive, below acceptable standards were treated favourably.
9) Security Issue in production Insite2
10) pointing out contravention of codelaw. HIPPAHITECH law
11) Medical device product didnt have audit trail and logging as confirmed by
GE architect
12) Customer internal customer Missy's complaint, where she was not able to
connect to medical devices for two months
(hence unable to do her job, unable to meet service contract obligation that GE
signs with hospitals when they buy a medical device and also purchase a
service contract worth $50k, $100k or more) and madhuri fixed immediately
within 24 hoursIt was Madhuris second week at work..Being brand new I
fixed itGEs uncompetitive staff who were not able to fix it..their EGO was
on FLAME.
13) After fixing as shown in Exhibit 13, Email was sent by GE representative
to all
regional service leaders in canada and USA.
14) Which Fortune 500 Boards of Directors are taking security seriously
This article states that after I left GE issued cyber security warning on their
products to all share holders dated back to 2010..2010 was a year when I
started working for GE first time

(245 of 291)
15) Surgery device port hacking page 1

I was able to hack product on OEC C arm surgical medical device while
testing. As William Barbuiax testified in exhibit 1 (attached here)..this was
critical and it would have been a seious issue in filed/hospitals if I would not
have raised it.
16) Surgery port hacking page 2
17) Surgery OEC C arm had several missing libraries for networking,
communicationsWhile my manager/team lead were harassing me and was
in rush to release this productbecause of me and my investigation .this
was put on hold. Without networking and connectivity libraries; Insite EXC
product cant exist as it was the core and main function of product. After that
several teams had to spent two months fixing this issues and developing
libraries..My role was to TEST this product. Develop automated /scripts
/software test plans .
In 2007, GE Healthcare entered a consent decree with the FDA which prohibited
the manufacture or distribution of surgery OEC C arms medical imaging devices
(
https://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/2007/ucm108
828.htm) . Ms. Trivedis first project for GE Healthcare was to work on finally
bringing a related product back to market. Being aware of the checkered history, I
was putting highest standards; but was punished for following quality processes.
18) Insite Production issue screen

(246 of 291)
19) As per exhibit 19 above Centicity medical product as GE used Insite Exc
and this exhibit shows Veterans hospitals signed a contract worth multi
million.
20) I was told to develop 1000 page test in 23 days that works on linux and
widows both..including developing/writing software.
21) 1000 page test document
22) My communication with GE managers about surgery hack, quality, no
networkingthis was important internal whistleblowing and I suffered more
and more retaliation and discrimination
23) My Email to General manager Dave Elario..raising and reporting concerns
and again they harassed me more and delayed my immigration.
24) Dipti Patel team/project lead at GE developed a test plans which was used on
thousands of devices
Test plan captured network traffic( life sniffing data transferred over the
internet because internet uses HTTP hyper text transfer protocol..in Diptis
test network analyzer compared screenshots (INSTEAD of comparing binary
data..this shows how poor her technical depth , knowledge and understanding

(247 of 291)
wasAnd How GE quality system, managers allowed it for years.. GE

managers also had no clue and time to know how to do it in a right technical
way)..of ideal network packet with the network packet that is under test..(For
example someone from court sends a message over internet..standards
message versus actual message)
25) GE manger perjury Lying under Oath
26) Email from Principal engineers that defect required fixing whole software, not
bandaid
27) Insite product was accessible on multiple ports which is hacking security
vulnerability. A product MUST be accessible via one PORT but it was
randomly opening multiple ports..It is like having random doors open into
your house and you have no clue who getting in/out of doors and which doors
are open because it is randomly open..This was a Hackers paradise..
28) Static code analyzer is a software that analyzes and code reviews software
against 1000 rules. FDA recommends/for some requires that for medical
devices and software for medical devices to use static code analyzer. Insite
Exc product never used static code analyzer..While writing software , they
used manual review where one person will ead code and reviewWhile being
new to team, I wrote to My manager Dave Mehring that we use static code
analyzer as it is recommended. Given Insite Exc used 15 programming
languages-.NET, C#, java, PERL, C, C++, python, and moreDave mehring
replied via email that for ten years we havent been using any quality
analyzer/static code analyzer for Insite Exc and we dont have time. It was my
third month at GE-new to GE when I ran into this. Dave Mehring was mad
and looking for ways to revenge and make me look bad.
29) GenderSpeak Email Mike Harsh- CTO of GE Healthcare about gender
sensitivity i.e. communicating with female engineers
30) I reported my concerns to GE global services CEO Mike Swinford ..But no
result came out..At arbitration hearing he said that whatever I sent to him to
report issues..He forwarded that to senior HR manager reporting to him Adam

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Holton..And he testified that Adam Holton has left GE a month before my

arbitration hearing.
Given my immigration was at stake, I was doing best to have GE address it.
Appellant
MADHURI TRIVEDI
P.O. Box 8359
Fremont, CA 94537
Madhuri.orangehc@gmail.com
Phone: 650-242-5135
Fax: 708-774-4859
March 4th 2017
CERTIFICATE OF SERVICE
I hereby certify that on this date, I caused a true and correct copy of this statement
delivered electronically to Gisela Westwater.
Dated: March 4th 2017 Respectfully submitted,

Madhuri Trivedi
__________________________________________________________________

(249 of 291)
From: Madhuri Trivedi [mailto:madhuritrivedi@hotmail.com]

Sent: Wednesday, September 21, 2011 3:51 PM
To: Mehring, David T (GE Healthcare)
Cc: Davis, Nate (GE Healthcare)
Subject: RE: Lead Engineer - 1392311
Hi David
I transferred my student visa to H1 B starting October 1, 2007. It ends September 2013 as of now(except
time I spent out of US, which can be recaptured at the time of filing so it can be pushed beyond Sept
2013 to some more...Immigration lawyers know how many days I would get and how it's counted etc so I
don't know exactly how many ).
Upon hiring, premium processing ($1000 extra fees) is available for H1 transfer where processing is done
in 15 calendar days (can take up to two months sometimes but still it's lot faster and convenient that
regular processing). It is good as I can register car and get a new license plate etc when become resident
in WI state right away.
After that; preparing PERM case for Green card takes from 2/4 months. And as long as PERM case is
filed before 365 days of visa end date, I get H1 extension beyond 2013 when case is processing.
The other scenario would be to do premium processing for PERM case which is available now as from
March 2009( I have learnt about this new development recently ) where if permanent case(PERM case-
labor certification OR I140) filing is done after "365 days before timeline" (after Sept 2012) of visa end
date ..In this case it's approved in 15 days and I get three years extension while Greencard in under
processing.
GE Healthcare is a global company and I am sure there could be solutions worked upon. I believe
this opportunity is very interesting and rewarding and being an asset for the company. I have not started
greencard process yet.
Thanking you.
Sincerely,
Madhuri
(250 of 291)
From: David.Mehring@med.ge.com
To: madhuritrivedi@hotmail.com
CC: Nathan.Davis@med.ge.com
Date: Tue, 20 Sep 2011 19:19:10 +0000
Madhuri can you please confirm the timings
You transferred from F-1 student status to H-1 in September 2007. H-1 visas have a max date of 6 years
which in your case is September 2013 (absent of any time you has spent outside the US during your 6
years in H-1 status). This means we would have to sponsorship your green card immediately upon hire
with the hope of filing PERM by September 2012 which is very risky in the conditions of approvals and
processing the Government is doing. Do you already have something in the works towards a Green
Card??
Dave
From: Davis, Nate (GE Healthcare)

Sent: Monday, September 19, 2011 11:02 AM
To: 'Madhuri Trivedi'
Hi Madhuri,
Good to hear from you again. After the interviews, we pass the information along to HR and hiring
managers, so the rest of the process is out of my hands at this point. However, I will definitely pass
along to them that you are still interested so they can contact you regarding any openings.
Sincerely,
Nate Davis
From: Madhuri Trivedi [mailto:madhuritrivedi@hotmail.com]

Sent: Sunday, September 18, 2011 1:40 PM
To: Davis, Nate (GE Healthcare)
(251 of 291)
Hello Nathan Davis,
I would like to thank you and GE Healthcare team to interview me for Lead Engineer position. I find this
opportunity interesting and rewarding. I enjoyed the phone conversation with the team and to learn
more more about the product and opportunity.
I look forward to this opportunity and next interviews.
Sincerely,
Madhuri
Subject: Lead Engineer - 1392311

Date: Wed, 27 Jul 2011 14:49:35 -0400
From: Nathan.Davis@med.ge.com
To: madhuritrivedi@hotmail.com
Hello Madhuri,
I received your rsum for the Lead Software Engineer position at GE Healthcare. I would like to setup
some time for a 30 minute phone call to talk to 2-3 members of our technical team. This will just be a
phone screen to make sure that we understand what your technical strengths are and what sort of work
you are interested in to ensure that any interviews we setup are a good fit.
If you could get back to me with the following information, I would appreciate it.
1. Will you now, or in the future, require sponsorship for employment Visa status (e.g., H-1B, visa
status)? If yes, provide details.
2. Are you willing to relocate to either the Milwaukee or Detroit area (please answer for both locations)?
3. Please provide a few options for dates/times when we could contact you via phone. Include preferred
phone number or if you would like me to setup a number you can call us at.
Thank you,
(252 of 291)
Nate Davis
Software Architect
GE Healthcare
Global Services Technologies
Phone - (262) 524-5204
email - nathan.davis@ge.com
(253 of 291)
3/4/2017 Case: 17-15217, GeneralElectricisendingannualperformancereviewsQuartz
03/04/2017, ID: 10343298, DktEntry: 17-7, Page 1 of 10
IT'S A MILLENNIAL THING
Why GE had to kill its annual

performance reviews after
more than three decades
Max Nisen August 13, 2015
Hallowed but shifting ground at GE's Crotonville management training campus (General Electric)
The annual performance review has been a ubiquitous and generally loathed
xture of the corporate world for decades. But haters can rejoice: Its nally
What Snaps IPO means, voter manipulation, dog leasing. All this and more in today's Daily
https://qz.com/428813/geperformancereviewstrategyshift/ 1/10
(254 of 291)
starting to topple. The best part? Even the company that popularized the toughest
Brief.
form of formal annual review is moving away from them.
For decades, General Electric practiced (and proselytized) a rigid system,

championed by then-CEO Jack Welch, of ranking employees. Formally known as
the vitality curve but frequently called rank and yank, the system hinged on the
annual performance review, and boiled the employees performance down to a
number on which they were judged and ranked against peers. A bottom percentage
(10% in GEs case) of underperformers were then red.
The company got rid of formal, forced ranking around 10 years ago. But now, GEs
in the middle of a far bigger shift. Its abandoning formal annual reviews and its
legacy performance management system for its 300,000-strong workforce over the
next couple of years, instead opting for a less regimented system of more frequent
feedback via an app. For some employees, in smaller experimental groups, there
wont be any numerical rankings whatsoever.
With the decision, GE joins other high-pro le companieslike Microsoft,

Accenture, and Adobethat have started dumping or have already gotten rid of
formal annual reviews. GE may not have invented stack ranking, but its the
company most identi ed with it. And given the longstanding and pervasive
in uence GE has had over the business world, its move could represent the
beginning of the end for a practice that has been at the heart of how corporations
have managed people for many decades.
It existed in more or less the same form since I started at the company in 1979,
GEs head of human resources, Susan Peters, tells Quartz. But we think over many
years it had become more a ritual than moving the company upwards and
forwards.
A century old icon, shifting rapidly

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There are few companies in America that have General Electrics legacy. Founded
Brief.
by none other than the great inventor Thomas Edison, its well into its second
century of existence. Its move to dump the annual review for large swathes of its
workforce underscores a sweeping shift underway at the blue-chip conglomerate.
Its selling off billion-dollar pieces of the lucrative nancing business that
imperiled it during the 2008 crisis and led to a too big to fail designation. Its
fundamentally restructuring to refocus on its increasingly high tech and industrial
businesses, emphasizing things like power and water infrastructure, advanced jet
turbines and imaging equipment. By the end of the transition, industrial
businesses will provide over 90% of earnings (PDF), and the only lending the
company will do will be to customers buying industrial machinery.
Its made broad changes in its management style too, under current CEO Jeff
Immelt. They mark an emphatic break from the hard-charging style Welch
embodied as CEO from 1981 to 2001. Welchs intense and widely imitated approach
made sense for the GE of yesteryear. It was a bloated industrial conglomerate that
was facing extraordinary competition from Asian manufacturers. In 1994near the
mid-point of Welchs tenurenearly 60% of GE sales came from a vast number of
industrial businesses that were becoming increasingly commoditized. That
economic reality led to obsessions with cost, ef ciency, and operational excellence,
which were embodied in Welchs management style.
Welchs rapid cost cutting and wholesale reorganization of the company led to the
nickname Neutron Jack. The companys value increased by more than $300
billion during his reign, making it the worlds largest at one point. Fortune
Magazine dubbed him the manager of the century in 1999. Along with its rank
and yank policy, GE also subscribed to Six Sigma, a manufacturing quality protocol
that worked to ruthlessly boost quality control and eliminate mistakes. Welch was
a believer in confrontation, in brutal candor, in argument, and in pushing people
extremely hard. In a lot of ways, he ran the company by sheer force of will and
personality.
(256 of 291)
Welchs
Brief. approach to management made him a legend at GE and American business
schools. Parts of his legacy remain at GE, particularly his insistence that managers
be given ownership of their businesses. But his style and focus on the annual
performance review simply doesnt work for the company or its younger workforce
any more, say GE human resources executives.
The world isnt really on an annual cycle anymore for anything. Peters told
Quartz. I think some of it to be really honest is millennial based. Its the way
millennials are used to working and getting feedback, which is more frequent,
faster, mobile-enabled, so there were multiple drivers that said its time to make
this big change.
Shes not the only one who thinks so. Theres a growing realization that the annual
review just isnt a particularly good way to manage people or to boost performance.
It leads to a tendency for HR to focus excessively on process over outcomes.
When you think of the leadership association people have with Jack Welch and
the ranking and rating, it suited a certain time, it does not suit today and todays
worker in my opinion, Adobe HR head Donna Morris, who led that companys
transition away from annual reviews and ratings, told Quartz. Its a process that
looks in the rear view mirror, thats focused on what youve done a year ago. That
just isnt current with how I think were working and how many of the employees
that were looking to attract or grow have been raised.
Welch doesnt comment on current GE practices. But as recently as 2013, he

defended the bell curve in The Wall Street Journal (paywall). He argues that rank
and yank is a pejorative term, and prefers to call it differentiation. But he argues
forcefully that candid appraisal of employees is essential, that they need to know
exactly where they stand in an organization, and that with constant
communication and feedback, it isnt as harsh as people make it out to be.
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Yes, I realize that some believe the bell-curve aspect of differentiation is cruel,'
Brief.
Welch wrote. That always strikes me as odd. We grade children in school, often as
young as 9 or 10, and no one calls that cruel. But somehow adults cant take it?
Explain that one to me.
Of course, that discounts the often highly negative experiences of employees of

some companies that took up the practice.
From The Pit to mindfulness training
The changes are palpable at GEs legendary Crotonville management training

center, the leafy campus in upstate New York where the company has sent up-and-
coming executives since 1956. The heart of Crotonville was always the Pit, the
largest of several imposing lecture halls where Welch used to deliver his
passionate, hours-long speeches, during which he expected managers to challenge
him, only to push them right back. The company recently cut an enormous window
into the formerly nearly subterranean Pit. Its trying to make the place more
modern, friendly, welcoming, and open.
The campus is also getting new buildings. One includes a studio where executives
are taught suminagashi, the Japanese art of painting on water. Theres a new two-
sided kitchen, built in a renovated carriage house, that was used to hold cooking
competitions until a tendency towards overcompetetiveness led to some
modi cations. A once clubby English-style pub at the center of campus in a
converted farmhouse called The White House is now an airy cafe and meeting
space serving craft coffee. Instead of drills on Six Sigma, executives can now take
courses on mindfulness. A string quartet and improv sessions are used to prompt
discussion about teamwork.
Its just about the opposite of what youd expect if you went by one of Welchs
bestsellers
Whator NBCIPO
Snaps sitcom
means,30 Rocks
voter parody dog
manipulation, of the place,
leasing. which
All this characterized
and more two
in today's Dailyof
(258 of 291)
the core Six Sigma values of the company as brutality and hand-shake-fulness.
Brief.
Raghu Krishnamoorthy, the longtime GE exec in charge of Crotonville, sees the

programs he runs there as essential to helping transition the company from
management by process and rigid bell curve to management enabled by mobile
phones for a new generation of employees who have different expectations. The
last generation of workers expected and were often motivated by competition.
Thats not really the case any more, he says.
Command and control is what Jack was famous for. Now its about connection and
inspiration, Krishnamoorthy recently told a group of HR executives at a
conference at the campus. In fact, were repurposing the mission of Crotonville as
a place where we inspire connection and develop people.
Management via app
The new app is called PD@GE for performance development at GE by the

admittedly acronym-happy company, and was built by a team from its large and
growing group of software engineers in Silicon Valleys San Ramon. The HR group
has been one of the rst to adopt it, including the experiment with no numerical
ratings.
Each employee has a series of near-term goals, or priorities. Managers are

expected to have frequent discussions, called touchpoints, on progress toward
those goals and note what was discussed, committed to, and resolved. The app can
provide summaries on command, through typed notes, photographs of a notepad,
or even voice recordings. The focus isnt on grading how well people are doing, but
on constant improvement.
Employees can give or request feedback at any point through a feature called
insights, which isnt limited to their immediate manager, or even their division.
Normally, you never get that feedback unless you manage to track someone down
(259 of 291)
the next day, which people rarely do, and only from a direct manager. If you wait
Brief.
for an annual review, any speci cs are probably long forgotten.
This allows me to ensure that Im in a position to change tomorrrow ,

Krishnamoorthy says, pointing at the app. But this is just the tool. The most
important thing is the conversation. [The app] makes it incumbent on me to be a
coach.
Theres an emphasis on coaching throughout, and the tone is unrelentingly

positive. The app forces users to categorize feedback in one of two forms: To
continue doing something, or to consider changing something.
Weve found that that terminology has been extremely helpful, Peters says. You
know that humans dont really like to give negative feedback, its just not
something that anybody does well, I think its just not in human nature. So if you
want the person thats working for you to improve, you have to think about it in
true coaching terms.
Managers will still have an annual summary conversation with employees around
December where they look back at the year and set goals, but its far less
consequential and fraught than the formal review the company is replacing. Its
not meant to be all that different from the conversations expected to occur
throughout the year, and entirely unlike the sort of formal review that sets
decisions on things like pay or advancement.
The rollout is going to be slow. There are about 25,000 to 30,000 people using the
new system now, and Peters estimates there will be 80,000 on board by the end of
this year. The rest will transition by the end of 2016.
The shift in how GE employees think about and track their performance mirrors
the broader transition underway at the company to substantially simplify its
business. FastWorks is a successor in many ways to Six Sigma and consciously
(260 of 291)
mimics the way that companies in Silicon Valley work. Theres a focus on rapid and
Brief.
frequent experimentation, learning from the market, only funding projects that
prove themselves, and acceptance and willingness to move on from failures.
It is a really important element of what were trying to do, which is to make a

major shift of the companys culture towards simpli cation, towards better, faster
outcomes for customers, Peters says.
A long time coming
The move by more and larger companies away from annual reviews and ratings is
well past due, say management theorists. Years of research, from both business
school professors and neuroscientists, has found that the practice is ineffective at
boosting performance, actively alienates employees, is based on a awed
understanding of human motivation, and is often arbitrary and biased. People
simply dont t neatly (pdf) on a bell curve. It ends up being an exercise in
paperwork and bureaucracy instead of an agent of change.
When you look at the evidence about stack ranking. The kind of stuff that they
were doing, which was essentially creating a bigger distribution between the haves
and the have nots in their workforce, then ring 10% of them, it just amazed me,
Bob Sutton, a professor at Stanfords Graduate School of Business told Quartz. We
looked at every peer reviewed study we could nd, and in every one when there was
a bigger difference between the pay at of the people at the bottom and the top
there was worse performance.
As much as researchers and many employees might applaud the decision, it

doesnt mean its going to be easy. Theres a reason reviews have stuck around for
so long, and its hard to overemphasize how entrenched the annual review has
become. Its the way most were raised as employees, a huge part of their workload,
and a comfortable framework to administer and to defend pay, promotion, and
(261 of 291)
ring decisions. Adobes Morris says that one of her biggest obstacles was actually
Brief.
convincing her own people that this could work.
Even if companies claim loudly that theyve done away with annual reviews and
rankings, there are often shadow rankings, where companies still do effectively
the same thing, but more informally, in the background. Meanwhile, HR executives
get particularly nervous about the pay piece, about how they can pay for
performance in the absence of a formal performance measurement system.
If you get rid of the performance ratings, how are you going to get rid of a fair and
equitable and measurable system to blame the distribution of pay on? Paul
Rubinstein, a partner in Aon Hewitts talent strategy consultancy asks, rhetorically.
Because why did performance ratings come into existence? So theres some
mechanism to force pay decisions. People wonder, which came rst the rating or
the pay decision.
Support and training on how to make pay decisions without rankings has taken a
lot of investment at Adobe, Morris says. Even within GE, theres still a sense of
con ict, which might help explain why the company seems hesitant to fully
commit to removing numerical rankings.
One thing we do know is that we will maintain our culture of meritocracy and
differentiation, Peters says. So we have to make sure what ever other aspects or
factors come into play, to make sure you still have that. Were trying to gure this
out and keep some of the fundamentals of the culture and also move to a place
where its more contemporary. I dont know what the answer on thats going to be
yet.
In early pilots, the company saw no difference in pay differentiation when

managers didnt use ratings. But it has a lot of people to convince of that, so
different pilot groups will continue doing different things until theres more
data.IPO means, voter manipulation, dog leasing. All this and more in today's Daily
What Snaps
longitudinal
(262 of 291)
TheBrief.
harshest critics of performance reviews and ratings argue that numerical
rankings and pay differentiation are perhaps the most damaging parts of the
system, and that any regime that preserves them cant hope to truly change. And
many companies like the idea of getting rid of reviews and rankings, but struggle to
follow through.
If GE has one thing going for it, its a uniquely deep bench of management talent,
and a culture that emphasizes constant improvement and helping other people
succeed. That made stack ranking less harmful at GE than it was at other
companies, according to Bob Sutton, and it might help it overcome the rockier
parts of the transition.
Although Jack believed in it like a religion, I think that they gured out [stack
ranking] was something that didnt work, that was faith based, Sutton says. One
thing I will give them credit for, going back to Jack and continuing to today, is that
theyve clearly de ned a star employee as someone who does great work and who
helps others succeed as well.
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--Forwarded Message Attachment--

From: Madhuri.J.Trivedi@ge.com
To: David.Mehring@med.ge.com
Subject: FW: Email the Facilitators - InSite 2.0 - Service Ops
Date: Tue, 20 Mar 2012 22:21:19 +0000
This is support central email..for Windows 7 IE 8 issue solving. FYI..
Best,
Madhuri
From: Capilongo, Marco (GE Healthcare)

Sent: Friday, March 09, 2012 9:57 AM
To: Trivedi, Madhuri (GE Healthcare); Livermore, Glyn C (GE Healthcare); Polacek-Ryan, Missy (GE
Healthcare)
Subject: RE: Email the Facilitators - InSite 2.0 - Service Ops
This worked. Ill explain on the call.
Marco
From: Trivedi, Madhuri (GE Healthcare)

Sent: March-09-12 10:29 AM
To: Livermore, Glyn C (GE Healthcare); Polacek-Ryan, Missy (GE Healthcare); Capilongo, Marco (GE
Healthcare)
These are full settings captured for ActiveX on my windows 7 SP1(patch already installed) with IE8 ..
similar to screenshots are sent before..
Best,
Madhuri
(273 of 291)
From: Livermore, Glyn C (GE Healthcare)

Sent: Thursday, March 08, 2012 3:57 PM
To: Polacek-Ryan, Missy (GE Healthcare); Capilongo, Marco (GE Healthcare)
Cc: Trivedi, Madhuri (GE Healthcare)
Are either of you available tomorrow Friday 9 th. If so I will set up a webex meeting we can see if we can
figure out what is going wrong. I will set up a system somewhere so that we can access it.
Glyn
From: Polacek-Ryan, Missy (GE Healthcare)

Sent: Thursday, March 08, 2012 9:38 AM
To: Capilongo, Marco (GE Healthcare); Livermore, Glyn C (GE Healthcare)
Hi,
I have also mirrored your settings (the ones displayed on the screen shot, I have
additional options) without success.
I have deleted all RAViewer programs and renamed my vncviewer.ext to

vncviewer.exe1.
Please advise on the next step.
Respectfully,
Missy Polacek-Ryan RT(R) B.S.
Interventional Invasive Applications Specialist
GE Healthcare Interventional Systems
T 800.437.1171 Option 4 (Applications Support)

(274 of 291)
E Missy.Polacek-Ryan@ge.com
www.gehealthcare.com
From: Capilongo, Marco (GE Healthcare)

Sent: Thursday, March 08, 2012 9:20 AM
To: Livermore, Glyn C (GE Healthcare); Polacek-Ryan, Missy (GE Healthcare)
Hi Glen,
No help with your settings.
1-No Raviewer anywhere on the hard drive
2-No vncviewer anywhere.
Let me know what you find as I really would like to get this working.
Thanks,
Marco
From: Livermore, Glyn C (GE Healthcare)

Sent: February-29-12 3:36 PM
To: Polacek-Ryan, Missy (GE Healthcare); Capilongo, Marco (GE Healthcare)
Hi Missy and Marco. Since you both have the same problem I have combined my responses back to you.
(275 of 291)
I dont have Windows 7 or IE 8 so I have asked a colleague to confirm she can connect and then send me
the screen captures of those. I included a picture of my IE6 settings which may be the same. I know we
have many users with this combination so it should work.
Can you check for me while I am waiting for that information.
1. Do you have RAViewer Control existing on your hard drive (normally in C:\WINDOWS\Downloaded
program files. If you do please delete it so we can reload it.
2.The RA viewer download will fail if somewhere on your hard drive you have vncviewer.exe
Please do a search for this file and if you have it temporally rename it to vncviewer.exe1
Then try the download again.
When I get the IE7 picture I will forward it to you.
Glyn

Sent: Tuesday, February 28, 2012 3:21 PM
To: Livermore, Glyn C (GE Healthcare)
Hello Glyn,
I am having problems using Insite 2 after my Windows 7 upgrade. I do have a SC case

open :http://supportcentral.ge.com/cases/sup_community_cases.asp?case_id=11519797
I have been referred to you from Alan Kuhn. Please take a look at this e-mail chain and
let me know if you can assist me, if not please let me know where to try next.
(276 of 291)

To: Kuhn, Alan (GE Healthcare)
Thanks Alan, I am back to my original errors.
I will contact Glyn Livermores team now.
Respectfully,
From: Kuhn, Alan (GE Healthcare)

To: Polacek-Ryan, Missy (GE Healthcare)
Just rechecking IE settings.

(277 of 291)
In Tools --> Internet Options --> Security tab.
In Custom settings, ActiveX controls and plug-ins section:
Automatic prompting for ActiveX controls - enable
Download of signed ActiveX controls enable
Download of unsigned ActiveX controls enable
Initialize and script ActiveX controls not marked as safe for scripting prompt
Same settings as my IE. Download works.
Make sure to log off and log back onto enterprise. I did same steps with good results.

Hi,
The RAViewer is NOT downloading when I press OK the window just disappears and I
am left with the RAViewer Control Unavailable message on the bottom of the screen.
Before I can go forward how can I get my RAViewer back if it is not auto-prompting to
install?
Missy
(278 of 291)

Sent: Tuesday, February 28, 2012 10:52 AM
To: Polacek-Ryan, Missy (GE Healthcare)
Hi,
Youre IE setting are set to prompt if the download is not safe. This is the prompt and just select
OK. The RAViewer will downloaded and the connection will commence.
If this does not help, I would open a case with the Remote Access community Glyn
Livermore is a facilitator of this community and this is really his area of expertise.
Hope this helps.

Hi,
I removed the RAViewer as requested and now this is the message that I get. Also, I
looked through the Total Access troubleshooting guide but I had no idea what I was
looking for.
(279 of 291)
I am an applications specialist for the Interventional Invasive team, I am not a computer

expert and that is why I opened a SC case with the Insite 2 experts as advised by
onsite support at the Healthcare Institute and Kurt Bahr. I need to get this program
(Insite2) working on my computer is the bottom line. I opened this case in January and
there is still no resolution and it sounds like you are telling to me
Seek out a new team for support or read the guide myself and fix the issue that no one
else has been able to.
(280 of 291)
Respectfully,
(281 of 291)

To: Polacek-Ryan, Missy (GE Healthcare); Mahajan, Navdeep (GE Healthcare)
Within windows explorer, navigate to below. Right-click on the listed RAViewer components
and select Delete in menu. Just wondering, did you read the Total Access troubleshooting
guide in the Remote Service Support community. This is not a backoffice issue but a
connectivity issue. The Remote Service site facilitators can probably help further.
http://supportcentral.ge.com/products/sup_products.asp?prod_id=49420
is the site addr. Look in Installation and Support section for the guide.
- Al
(282 of 291)

To: Kuhn, Alan (GE Healthcare); Mahajan, Navdeep (GE Healthcare)
Hi,
I am not clear on the process to remove the RAViewer do you have any type of
instructions that I can follow?
Respectfully,

Ok.
(283 of 291)
Try removing the RAViewer elements as described below. On next Insite connection, a new
RAViewer will be downloaded and installed on your laptop. This is used for the FE (laptop) side
of the connection.
- Al

Hello,
Yes, other engineers can connect to these devices when I am not able to. My workflow
as to how I attempt to remote into systems has not changed, the only
Change has been my Windows 7 upgrade. I know how to use Insite2, I had been
successfully using it for 3+ years until the Windows 7 upgrade.
Respectfully,
(284 of 291)

You are attempted to connect via the VNC Total access connection. In order to do that, the VNC
server on the product must be running. I am not familiar with the DMS product as to how the
VNC server is activated on the device, etc.
Looks like the RAViewer is being downloaded properly, so IE settings do appear correct. Can
other engineers connect to this particular device? Then that rules out a device side problem.
You might also find the downloaded RAViewer in C:\Windows\Downloaded Program

Files. Remove the RAViewer.ocs and RAViewere.inf. Lets try that next to force download of
new RAViewer module.

Hello,
I am not sure what you mean IS the VNC server running on the machine. I am not able to
access any systems using Insite 2 after my Windows 7 upgrade.
(285 of 291)
After I attempt to use Insite 2 and fail co-works are able to get into the machine that my
attempt failed on so I know for sure that it is my system that is not working properly.
Respectfully,

IS the VNC server running on the machine? Do you have similar issues with other customer
devices? Is this isolated to this particular device?

Sent: Monday, February 27, 2012 10:56 AM
(286 of 291)
Hi,
Any suggestions? I need to get this program working for customer support.
Respectfully,

Sent: Thursday, February 23, 2012 12:22 PM
Hi Alan,
I have changed the settings as instructed and I am still getting the following error
Please advise.
(287 of 291)
Respectfully,
(288 of 291)

Sent: Wednesday, February 22, 2012 2:48 PM
Hi Missy,
Try this:
You must have a newer laptop image with default IE8 settings.
You need to set the IE8 Explorer settings:
Tools --> Internet Options --> Security tab.
Set security level for this zone - to Low

(289 of 291)
Select Custom level --> ActiveX controls and plugins section. Set all settings in the section to enable
except for
Initialize and Script Acitive X Controls not marked as safe --> set to Prompt.
Restart browser.

Sent: Wednesday, February 22, 2012 2:30 PM
To: Mahajan, Navdeep (GE Healthcare)
Cc: Kuhn, Alan (GE Healthcare)
Subject: Email the Facilitators - InSite 2.0 - Service Ops
Hello,
I need assistance with Insite 2. I opened a case in January and no one has been able
to help me.
It was suggested that I e-mail the facilitators.
Please look at the attached e-mail for details.
Logged By: Polacek-Ryan,Missy

Community: InSite 2.0 - Service Ops
Case Category: A User Interface or Server Error Report
Severity: Normal
Persons Affected: Few
Solve By Date: Friday, February 03, 2012 at 3:56:00 PM
Logged On: Monday, January 30, 2012 at 3:56:56 PM
Case Url:http://supportcentral.ge.com/cases/sup_community_cases.asp?case_id=11519797
(290 of 291)
Respectfully,
(291 of 291)

Ninth Circuit Case Madhuri Trivedi v. DHS 17-15217

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Case: 17-15217, 03/04/2017, ID: 10343298, DktEntry: 17-1, Page 1 of 205

WITNESS: WILLIAM BARBIAUX 3/4/14

In the matter of the Arbitration between:

and Case No. 51 160 0126013

Tuesday, March 4, 2014

1405 Rockridge Road

Reported by Beth Zimmermann, RPR

MADHURI TRIVEDI, 1405 Rockridge Road, Waukesha, WI 53188

QUARLES & BRADY, By Sean M. Scullen, Attorney at Law, 411

Ex. No. Description Page

1 12/8/11 Trivedi E-mail Re: Insite ExC

(ORIGINAL EXHIBITS ATTACHED. EXHIBITS 3-7 AND

1 WILLIAM BARBIAUX being first duly

2 sworn on oath to tell the truth, the whole

3 truth, and nothing but the truth, was examined

4 and testified as follows:

5 EXAMINATION BY MS. TRIVEDI:

6 Q So have you given deposition before?

8 Q Did you get any deposition coaching?

9 A Depends what you mean by coaching; but, no. I

10 think I talked with Sean for about an hour,

11 but it was all around the process, like, Here

12 is what will happen, there will be a reporter

13 and questions, and answer the questions

14 honestly. So it was all of the basic what's

16 Q Would you be concerned about your job future

17 with GE if you tell the truth and if it's

18 against management or if it's exposing certain

21 Q Did I treat you with respect when I was with

24 Q You had good working relationship with me,

2 Q Things went well, without difficulties in

3 working with two of us?

4 A Yeah, for the most part. We didn't have a

5 direct assignment together, but we worked --

6 We worked near each other, so --

7 Q You worked with me on Insite ExC Surgery

9 A Right. I helped with some of it, yeah.

10 MR. SCULLEN: Just wait because the

11 court reporter can only take down one person

13 MS. TRIVEDI: This is off the

15 (Off the record discussion.)

17 Q So you and I worked -- as we spoke, you and I

18 worked on Insite ExC Surgery Integration. You

19 helped me, you said?

21 Q How long have you worked with GST?

22 A GST? Since before it was GST, so from 1993

23 until now, so that's --

24 Q That's fine. How long have you known Dave

1 A Probably 15 to 20 years, most of the time in

3 Q How long have you known Greg Stratton?

5 Q And Nate Davis?

6 A Probably 14 years, somewhere in there.

7 Q And Sachin Kendale?

8 A Probably two years. I don't know exactly.

9 Q And how about Alan Kuhn?

10 A I think close to 20 years.

11 Q And Greg Jacobs?

12 A However long he's been at GE, but I don't know

13 how many years that is.

14 Q Two, three years?

15 A Something like that, yeah.

16 Q You were in part of the Insite ExC core team,