Q It is not clear from this that you reserve the right to conduct random drug tests outside of government requirements. Was that made clear to the wrestlers?

A I think it is two totally different deals. One is to conduct random drug tests and then -- and other tests in accordance with government requirements.

Q The other question is -- we're back on this particular document.

A Which document?

Q The same one.

A Okay.

Q Actually, let's go back to the testing in the May 31st e-mail. This was testing -- again, per your initial previous request, this was testing that was done to meet government requirements. Were all your -- in this set of testing, were all your -- was all your talent tested?

A Yes, yes, sir. And looking at the dates on this

Q Uh-huh.

A -- the OSHA request probably came up -­Q Uh-huh.

A between this date and this, and it was -- counsel provided to us that we probably let them know in advance that they would have do that. That looks like the timing of that, and that's why that was added as well.

Q Okay. This -- the final version of this policy, provision 6 of this, this refers to the Florida Department of Health Bureau of Epidemiology's request.

A Uh-huh.

Q Is that the -- was that the impetus for those May 31st tests?

A Yes, uh-huh.

Q Prior to your -- when did you become aware of those requirements?

A At this point, that was the first time.

Q And prior to becoming aware of those requirements and setting up the tests, the June 19th tests, were there any plans -- did TNA have any plans to conduct drug testing under this drug policy?

A I think it says we have the right to conduct random drug tests. I believe if I go back and read it, it does say that if there is any suspicion then we would random drug test. Is that the question?

Q I'm asking were there any plans to conduct the tests?

A There had not been any suspicions; and, like I said before, several times when there were suspicions we talked with the talent and they were dealt with, whether it be suspended without pay and then termination.

Q Is it your understanding that these provisions allow you only to conduct testing if there's suspicion?

A No, this says we can conduct random drug tests; and that could mean the entire roster or it could mean with suspicion.

Q Okay. And to clarify, though, there had not been any plans prior to your becoming aware of --