SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
Case No. BC-2024-087341

IN THE MATTER OF: Harlow Industries, Inc. v. Pinnacle Supply Co.

DEPOSITION OF WITNESS: Gregory Tanaka
DATE: February 14, 2024
LOCATION: Offices of Feldstein & Moorhouse LLP, 1800 Century Park East, Los Angeles, California

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EXAMINATION BY MR. CLIFFORD REEVES (Counsel for Plaintiff):

Q: Mr. Tanaka, please state your full name and current title for the record.
A: Gregory Tanaka. I serve as Director of Procurement at Harlow Industries, Inc.

Q: Mr. Tanaka, were you employed by Harlow Industries on or around March 3rd, 2023, the date referenced in Exhibit 14?
A: Yes, I was. I had been in that role since January 2021.

Q: Did you personally authorise the purchase order that is the subject of this dispute?
A: I co-signed it, yes. The original requisition came from Sandra Obi, who was then our VP of Operations.

Q: And at the time you signed, were you aware that Pinnacle Supply Co. had previously been cited by the California Department of Industrial Relations for violations at their Fresno warehouse?
A: I was not aware of that citation at the time of signing.

MS. DIANA OHLSSON (Counsel for Defendant): Objection, foundation. Counsel is characterising the citation inaccurately.

MR. REEVES: I'll rephrase. Mr. Tanaka, did you conduct any due diligence on Pinnacle Supply Co. prior to executing the agreement?
A: We ran our standard vendor review. The review was completed by our compliance analyst, Felix Drummond. He reported no red flags at the time.

Q: Let me direct your attention to Exhibit 22, a letter dated April 17, 2023, from the Hon. Margaret Solis of the Los Angeles Superior Court. Does that letter reference any prior proceeding involving Pinnacle Supply Co.?
A: Yes. It references a 2021 dispute in Alameda County.

Q: Thank you. No further questions at this time.

MS. OHLSSON: Mr. Tanaka, the Alameda County matter was resolved in favour of Pinnacle Supply Co., was it not?
A: That's my understanding.

MS. OHLSSON: Nothing further. We reserve the right to recall this witness.

COURT REPORTER: Collette Beaumont, CSR No. 12847
