Our Story

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

47 information.

615 Raymond Hunter (a Third Party)Cross-exam by Mr. Davison