Q: Xerox. Is the machine made by the Xerox
Company? Is that why it's called Xerox?
A: No.
Q: So xerox, in the parlance that you've described,
the language that you've described, is being used
generically as opposed to describing a particular
brand; is that right?
A: All of my life I've just known people to say
xerox. It's not commonplace to use the terminology
that you're using.
Q: You mean it's more -- people say xerox instead
of photocopy?
A: If you're referring to a type of machine where
you place a piece of paper on the top and press a
button and out comes copies of it, they usually refer
to it as xerox.
Q: Have you ever heard it referred to as
photocopying?
A: Not with my generation, no.
Q: And you've never heard anybody in the Recorder's
office refer to that as photocopying; is that true?
A: I don't remember any specific instance where
that's referred to as photocopying.
Q: Have you ever heard it referred to as
photocopying in any office context?
A: I've always heard of it as xerox.
Q: Let me be clear: You've never heard of that
called photocopying; is that correct, Mr. Patterson?
A: When people speak of using a type of machine
that you described, they speak of it as could you
make a xerox of that or could you xerox this for me.
Q: But you've never heard them refer to that as
photocopying; is that correct?
A: I'm sure it's been said. I don't remember any
specific instance. What i remember is it referred to
as xeroxing a piece of paper to make additional
copies.
Q: I know. You've told us that.
Let's be very clear here. You've never heard
that process called "photocopying." Is that true or
false?
A: I'm sure the term has been used by someone.
Q: Because you've heard that or you're just
guessing?
A: I do not remember a specific instance where
someone used the term "photocopying." My generation
and people around me typically refer to placing an
image on the top of a machine and having two or three
copies come out as xeroxing.
Q: Okay. Would it be synonymous in your
understanding with xeroxing to call that
photocopying?
A: I don't know. I don't know what the legal
definition of photocopying is.
Q: I don't know if there is a legal definition.
I'm talking about what lay people say.
MR. CAVANAGH: Aren't we
asking the Ohio Supreme Court to
decide that issue?
MR. MARBURGER: No.
MR. CAVANAGH: No?
MR. MARBURGER: You might
be. I'm not.
MR. CAVANAGH: Why don't you
just call it a copy machine. Why do
you have to call it a photocopier?
BY MR. MARBURGER:
Q: I can call it anything I want to call it. I
want to see if you understand what I'm talking about.
A: I call it a xerox.
Q: Do you happen to know the names of the units
that you have that xerox? Do you happen to know what
they are -- what brand they are and what model or
unit they are?
A: I should, but right now, due to the pressure
that you're placing me under, it's not coming to
mind.
Q: I'm not placing -- am I placing you under
pressure, Mr. Patterson?
A: I think it begins with an M. I can't remember
currently.
Q: Do you feel that I'm placing you under pressure?
MR. CAVANAGH: Be honest.
A: Yes. This is not my normal environment. I'm
not a lawyer and, you know, I'm nervous that my
answers -- you will try to use in a way in which I
wouldn't intend them to be.
Q: Well, you're in control of that. If you give us
an honest, forthright, clear answer, you'll decide
whether your testimony can be used in a strange or
odd way. That's up to you, not up to me.