3 could redevelop the property?
4 A Well, again, at that particular moment in time,
5 first of all, that pro forma was put into place —
6 I prepared that for Mrs. Hundley on the 12th, so
7 that pro forma on the 8th was not in existence. I
8 had not even done any research on that pro forma
9 on the 8th.
10 Secondly, any information along those lines
11 would have been confidential information for
12 Mrs. Hundley.
13 Q Let me — I think we — Let me understand what
14 you’re saying. You’re saying that — The building
15 rates that you quoted, that’s not confidential,
16 right? You quoted the cost per square foot for
17 Ms. Hundley to build the property on the
18 Garniers’. That’s not confidential, right?
19 A That — That pro forma is confidential.
20 Q What part of that pro forma is confidential?
21 A The fact that it is addressed to Mrs. Hundley and
22 for the sole purpose of providing Mrs. Hundley
23 information that she might require, you know, to
24 make a decision on whether she wished to purchase
25 a property or not. The information that I used is
26 based on known selling figures of attached units
27 in the market at that time. Those selling figures
28 individually, if somebody wants to research them,
29 are available.
30 Q Can I get you to turn to page 179 of Exhibit
31 number 2, so that we’re all clear of what we’re
32 talking about.
33 There’s a February 12th, 2007 document.
34 That’s what we’re — Sorry, Mr. Hunter. [Pause]
35 A Yes.
36 Q That’s the document you’re talking about?
37 A Yes, it is.
38 Q And that’s February 12th, 2007?
39 A That’s correct.
40 Q Okay. And I don’t see anywhere here that it’s
41 addressed to Ms. Hundley. Do you?
42 A Whether it has an address or whether it’s
43 addressed specifically to Mrs. Hundley or not,
44 that was information that was made available to
45 Mrs. Hundley, specifically for Mrs. Hundley, and
46 that is what I would consider the confidential
615 Raymond Hunter (a Third Party)Cross-exam by Mr. Davison