The following consists of testimony from the publicly available exhibits filed in Granger, et al. v. Juna Explorations, LLC. These transcripts have been excerpted and re-ordered by the Xenobiological Association, but the testimony herein concerning the tragedy of the Distal Brook Flood remains otherwise unaltered.
Excerpt from the Deposition of John Franken – Standard Date 061648
Q. Mr. Franken, as you know, my name is Arthur Kim, and I’m one of the attorneys for plaintiffs in this case. I want to thank you for coming in to talk with us today.
A. Yes. Of course.
Q. Now that we’ve gone through some of the basics of how the deposition works and talked about your background, I’d like to get into the specific events that brought you here today. Okay?
Q. After you finished piloting lunar expeditions for the USS, you said you began work at Juna Explorations, is that correct?
Q. And you were stationed on the planet of Ouron, located in the circumstellar habitable zone, or CHZ, of system JE-101, is that correct?
A. That’s correct.
Q. And Ouron is leased by the USS to Juna Explorations for its mining ventures there, correct?
Q. And when did you start operating shuttlecraft for the Juna mining colony of Ouron specifically?
A. About three and a half years ago.
Q. And what were your responsibilities as a pilot on Ouron?
MR. SRIN: Objection. Vague.
A. Can I… Do I…
MR. SRIN: You can answer. The objections are just for the record.
A. I’d pilot personnel from Juna facilities to areas off-base.
Q. When you say “off-base”, you mean you would fly from mining facilities on the body of the gigantiform to other locations on Ouron, correct?
A. That’s correct. The Juna facilities are concentrated on the organism’s hand—two on each finger, two on the thumb, and then one management facility overseeing operations at the wrist.
Q. And you would typically pilot flights to and from that management facility, the one on the gigantiform’s wrist, correct?
A. Yeah, the… Sorry. Most of the locals call it the Sleepy Giant or Giant. But that’s right. I would cover the wrist.
Q. Understood, Mr. Franken.
I’ve seen the pictures, and that nickname certainly fits. I can only imagine what an alien organism of that size looks like from above on a shuttlecraft.
A. Yeah. It’s something… I’ve come across a lot of things during my time with the USS, but nothing like him—that rocky body, the parts you can see coming out of the planet’s surface anyway, stretched out for kilometers like that. Every time I fly over it, I think of the old Earth explorers who wrote about finding God in nature. Those guys would blow their top if they—
MR. SRIN: Excuse me, Mr. Franken. I know depositions are unnatural, and you want to treat this like a conversation. But I’d ask that you please wait until Mr. Kim asks you a question. Okay?
A. Oh, yeah. Sorry.
Q. That’s okay, Mr. Franken. I know exactly what you mean.
Now, as you alluded to just now, the way I understand it, the gigantiform is partially submerged in Ouron’s surface, but segments of the skull, the hands, parts of the arms, those sit above ground, correct?
A. That’s correct. Almost like a mountain range. Several kilometers high at some points, depending on where you’re at.
Q. Okay. And how long would an average flight take, say, from one of the facilities on the gigantiform’s hand to the town of Distal Brook?
A. Well, Distal Brook was a few kilometers off from the tip of the thumb. Most folks there had some connection to Juna, so they didn’t settle too far off. The average flight was maybe an hour, hour and a half, at most.
Q. Flight ever take you more than two hours?
A. Maybe in bad weather.
Q. Ever more than three hours?
A. No. Never.
Q. And when you’re flying a shuttlecraft to or from Distal Brook, you’re typically able to see the hand of the gigantiform from up there? Meaning the wrist, thumb, fingers, are all visible to you?
A. Yes, that’s correct.
Q. And I assume you’re familiar with Purlicue Lake?
Q. Could you describe it for me, please?
A. It’s the… um… It’s the reservoir between the thumb and index finger of the Giant, where the waste from the extraction sites collects until it can be processed.
Q. Have you ever been there?
A. I only ever visited once and was never in a hurry to get back. The water there is real nasty stuff. Makes you choke and cry your eyes out, just being within a half mile of it.
Q. So pretty hazardous, you’d say?
MR. SRIN: Objection. Vague and calls for a legal conclusion and/or expert opinion.
Q. Withdrawn. Let’s switch to something else.
Mr. Franken, you were piloting a shuttlecraft to Distal Brook on Standard Date 022147, correct?
A. Yes. I was transporting a Juna Explorations employee from the wrist facility. Don’t remember his name though.
Q. I’d like to introduce a document that we’ll mark as Exhibit 19. If you could take a look at that and let me know when you’re done?
Q. What is that, Mr. Franken, if you know?
A. A flight log for that day, looks like. The passenger listed is a Dr. Mark Granger. Guess that was his name, then.
Q. And as far as you know, this log is accurate, correct?
A. As far as I know.
Q. Do you recall talking to Dr. Granger, that day, when you dropped him off in Distal Brook?
A. I think so.
Q. What did you two talk about?
A. Well, he said he was going to Distal Brook to visit his kid. I remember because our boys were about the same age. He was going to surprise his son for his tenth birthday and—
Sorry. I’m sorry. I’ve got something in my throat.
Q. It’s okay. Take your time.
A. Sorry. Anyway. He had a kid in Distal Brook, is what I remember.
Q. And according to Exhibit 19, you’d already taken off and left Distal Brook when the flood occurred, right?
A. That’s right.
Q. So the day the town flooded, you could see the black water from your shuttlecraft, right?
A. I… yeah. I saw the water come down on Distal Brook from the lake. I don’t need to tell you it… it took out the whole area at once. Houses and everything. It was like… it was like… God… I don’t even know. Just horrible.
Q. Understood. I can only imagine, Mr. Franken.
So after the flood hit the town, did you make any stops before heading back to the wrist facility?
A. After that? No. I mean, there was nothing I could do. It was all… I mean all wiped out. So I kept going and headed to the wrist facility straight away.
Q. Okay, well do you remember a few minutes ago, when you testified that your flight takes about an hour and half, and no more than three hours, and that these logs are accurate as far as you know?
A. Yeah, I remember.
Q. If you look at the Exhibit 19 again, according to the logs, your return flight from Distal Brook, based on takeoff and arrival, took almost five hours.
Why did it take so long, Mr. Franken?
A. I… I mean, I don’t… I’m not…
Q. Did you see something else while you were up there?
MR. SRIN: I think now might be a good time for a break. Mr. Kim?
Q. Okay. Let’s go off the record.
COURT REPORTER: Going off the record. The time is 9:37 AM.
Excerpt from the Deposition of Jane Yuan – Standard Date 092949
Q. So what was your reason for visiting the colony, Ms. Yuan?
A. My brother and his wife had been living there for several years. They kept telling me I should come see them. Spend a couple months and see the Sleepy Giant and all of that.
Q. And what were they doing there, your brother and sister-in-law?
A. He had a job as an electrician in a Juna facility, which was a dream come true for him. My sister-in-law tagged along on a marriage visa and started working as a teacher at the local elementary.
Q. And your brother and sister-in-law lived in the Distal Brook township?
A. Yeah. In a small neighborhood called La Roma. They loved it. They really wanted—shit. Sorry. [Inaudible.]
Q. It’s okay. Take your time. We can take a break if you’d like. Would you like tissues…
A. No. I’m fine. [Inaudible.]
Sorry. They wanted to have kids there.
Q. Okay. So you were on Ouron on Standard Date 022147, correct?
Q. What were you doing that morning?
A. My brother and I went hiking at Mammoth Peak. It’s a ridge about a couple kilometers away from Distal Brook, where on a clear day you can see the whole hand of the Giant.
Mayra, his wife, had work that day and couldn’t join. So my brother and I had breakfast and headed out before sunrise. We wanted to hit the peak before it got too hot, and we were almost there at the top when it happened. The flood.
Q. Okay. And what do you remember about the start of the flood, specifically, if you can recall?
A. I remember the ground shaking all of a sudden. I know that happened first because I fell over. And right after, there was this sound, like crashing thunder that wouldn’t stop.
My brother and I went further up to get a better view, and when we reached the peak, the water was already coming our way. I don’t know what I was expecting, but it wasn’t that. The water was—it was like this dark wall, ready to crush everything.
Q. Do you need to stop?
A. No. It’s fine.
Q. Okay. What happened next?
A. It took a few seconds, but we realized the water wasn’t going to reach us, that it was going to hit everything in Distal Brook below instead.
Then, when it started happening, the water coming into the town, I remember the other hikers around us all started yelling. And my brother was screaming, I think. This big wall of water, just, it moved past us, and then Distal Brook—all of the buildings, houses, churches, the roofs and walls all broke apart like they were made of paper. I mean, it didn’t look real.
The distance we were at, we couldn’t see the people. But I mean, you knew. You just knew that they were all getting swept away in there. And it was god awful.
Q. And then what happened?
A. My brother was losing it for a few minutes, but he calmed down. He got it in his head that Mayra might not have been in the worst of it. He said he saw the water divert around the school where she worked, so it was possible that she or others might try to get on the roof and wait out the currents. So we ran for the car. It took us almost an hour just to get back down the hill.
We drove to the edge of town. But the roads, they were all covered with that black gunk. So we pulled over, waiting for some opening where we might get through. Then others came, people who had been out of the township too. We were all standing at our cars, breathing in the fumes from the water, and I think everyone started bleeding from their noses at some point.
I remember everyone was trying to wipe the blood off their faces.
Q. Do you recall any other symptoms of exposure to the black water?
A. My eyes were burning at the time. And I started throwing up. Some of my skin, especially around my ankles, the parts that came into contact with the water, peeled off days later.
Q. Okay. And do you remember anything else about the flood after that?
A. The only other thing was the bodies. I mean, I still don’t even know if they were bodies. But these black masses started floating to the surface after a while, like lumps in stew. We tried to pull one out when it got close to us, but we couldn’t really touch the water, because of the way it burned.
There was nothing. I mean there was nothing we could do for anyone. We were all just stuck there, waiting, watching the black water carry everything off.
Q. And how long were you over there, at the edge of the town?
A. A few hours. Until a Juna Explorations team came to lift us out. And we never got to the school, not that it would have made any difference.
Q. Where did they take you after that?
A. My brother and I spent a couple of months in a facility recovering. Later, some Juna people came and talked to us. They told my brother that they were investigating, but that Mayra, and anyone else still missing, was almost certainly gone.
Then they offered him a settlement. $50,000 and free passage back to Earth. His wife, dead. House, gone. Everyone he knew, drowned. And that was $50,000 to them.
I told him not to sign, but I think after everything he went through, he just wanted it to be over with. To go back home and forget that place ever existed.
Q. And did you sign a settlement agreement too?
Q. So after your recovery, you and your brother went back to Earth?
A. Yes. I tried to take care of him for a while, but he never really adjusted to being back. And at some point, he joined the TC, and I think it only made him worse.
Q. Sorry, TC?
A. Titan Church. They’re mostly planet-bound, but they’re starting to crop up in other systems. They’re kind of—what’s the word—cultish types, obsessed with the Giant. Anything and everything Giant-related is important to them.
So after the flood, the TC really fixated on the survivors because of their connection to Ouron. They tried to get me to come with them, but I always refused. My brother, though, he didn’t have anything else. So he went right along. He attended their masses, and I think he spoke a few times about what he saw on Ouron.
To be honest, I don’t really know much more; my brother and I didn’t see each other as often once he became a member.
Q. I understand, Ms. Yuan. And, I’m sorry to ask. I already know, but I need this for the record. What happened to your brother?
A. He passed away late last year. He’d been on a lot of pain medications, because of the black water, and, one day he just, took too much, and… they just found him like that, in his tub. Still not clear if he meant to— Sorry. Just not clear what happened.
Sorry. I don’t know what I’m saying any more.
Q. It’s okay. I just want to say again that I’m very sorry for your loss. And I think this is a good time for a break, but I just want to clarify something.
You’re not a party to this lawsuit. You chose to opt out and are here as a third-party fact witness, right?
Q. So I have to ask. Why not join and sue Juna Explorations like the others?
A. No offense, but I don’t really see a point. Everything Juna touches is poison, including their money. So fuck them all to hell as far I’m concerned.
Q. Okay. Let’s take a break.
Excerpt from the Deposition of Teresa De Leon Vol. 1 – Standard Date 020650
Q. Okay, Ms. De Leon. Let’s look at Exhibit 80 again. That one. The press release regarding your promotion. It says you were elevated to managing director of Ouron on Standard Date 011341, is that right?
Q. And it mentions that you started in Juna oversight and management over a decade ago in several colonies before Ouron.
A. That’s right.
Q. And it looks like you pretty much went to work right out of university and have spent your whole career with Juna, correct?
A. Yes. That’s correct. My predecessor on Ouron, Dr. Oswald, would often say that Juna’s purpose was to advance the knowledge of the human species, push us further than we’d ever gone before, and I knew I wanted to be a part of that since I was young.
Q. So did you seek a management position on Ouron, specifically?
A. Of course.
A. Well, in all the decades that the USS has explored other systems, we’ve only ever encountered a few life forms, most of them microbial. The gigantiform is, to date, the only complex, extraterrestrial organism we’ve discovered. I don’t think there are many people who would pass up the opportunity to help Juna study it.
Q. Understood. And in addition to studying the gigantiform, Juna Explorations also extracts resources from it, correct?
A. Yes. The gigantiform’s body contains a naturally occurring element that has several applications, including as a component in Juna Explorations fuel rods.
Q. Cronesium, right?
Q. And how is the cronesium extracted? Just the basics, please.
A. Because the gigantiform’s skin is a type of hardened silicate, it requires several years of drilling. Once we’ve breached the surface, our engineers use proprietary Juna Explorations tech to scan the surrounding veins and fluid pockets.
After an extraction strategy for the site is determined, we use Oswald derricks to pump the cronesium out of the gigantiform’s veins and direct it to a processing facility, where we separate the usable cronesium from other hazardous components in a series of water tanks. From there, the cronesium is directed to another facility, and the waste is ejected.
Q. Into Purlicue Lake?
A. That’s right.
Q. And once the waste water is sent to Purlicue Lake, what do you do with it?
A. Well. The exact process for neutralizing the waste water is still being worked out. Because it’s unstable once the cronesium is removed, we can’t reinsert it into the gigantiform or move it elsewhere without great risk.
Juna is on the cusp of a cost-effective method of disposal, but until then it’s best stored in the reservoir.
Q. And you extract from several facilities on the gigantiform’s hand, right? How many Juna Explorations facilities are there on Ouron?
Q. Okay. Thank you. This is all very helpful information, so I appreciate you walking me through it.
Now, to get to more specific issues, you were managing director of Ouron during the events of the Distal Brook Flood, correct?
Q. By the way, I should ask, since we may be getting to sensitive territory, did you personally know anyone who was in Distal Brook?
A. I did not.
My position as managing director is somewhat solitary.
I rarely leave my post in the wrist facility, so I haven’t had the opportunity to visit many of the settlements.
Q. Understood. Well, my condolences nonetheless. These were your people, after all, so the loss must not have been easy.
A. Thank you.
Q. So after the Distal Brook Flood occurred, Juna conducted an internal investigation as to the cause, correct?
Q. And if you look at the investigative report previously marked as Exhibit 78 in your stack of documents there. There’s a section that’s signed by you, Ms. De Leon, right?
Q. And it says, “To the best of my knowledge, the results of the foregoing report are a complete and accurate record of the events concerning the Distal Brook township.” Do you see that?
Q. So you reviewed this and signed off on it, fair to say?
A. I did.
Q. And above that there’s a summary by the investigatory body in that last paragraph, do you see that? If so, can you read that into the record, please?
A. It says: “Based on our interviews with relevant personnel and a review of available sensory data, we conclude that the Purlicue Dam spillage was most likely caused by an unanticipated seismic event (U.S.E.), which resulted in an overflow of the Purlicue Dam. Though we recommend construction of additional bulwarks, we believe Juna Explorations took all reasonable and foreseeable measures it could have undertaken to safeguard the hazardous material.”
Q. And what might cause a seismic event of the kind referred to in that report?
A. There are many possible causes. Shift of tectonic plates under the planet surface. Unexpected rupture of a cronesium deposit in the gigantiform’s veins. Gas pockets uncovered while drilling.
Q. Okay. The report doesn’t specify, so I’ll ask you. Of those reasons you just listed, what was the cause of the U.S.E. that triggered the flooding of Distal Brook?
MR. SRIN: Objection. Calls for speculation.
A. Sorry. What?
Q. What was the cause of the U.S.E. that triggered the flooding of Distal Brook?
A. I’m… Well I wasn’t involved in the investigation, so I’m not sure I could speak to that.
Q. Okay. But you agreed with this report. So I guess my question is, how did you come to the conclusion that the Distal Brook Flood was caused by a U.S.E.?
A. Well, I had no reason to doubt the investigative body.
Q. But, to be clear, you reviewed no underlying data to support that finding, did you?
A. I did not.
Q. Okay. Let’s change gears a little bit. Could you look at the photograph in the investigative report, the visual evidence of wreckage in Distal Brook—two pages earlier.
What do you see in the background of that landscape?
A. It’s… I believe it’s the Purlicue Dam…
Q. Anything about that look strange to you?
MR. SRIN: Objection. Vague.
A. I’m not sure what you mean.
Q. Do you see any damage to the dam in that picture? Cracks, fissures, anything of that nature?
A. It’s difficult to know for sure from one photograph. But based on this… I… I mean… No. It doesn’t seem to be damaged from what I can see.
Q. Now, if the dam had cracked, it’d be a large undertaking to repair it, I assume. You’d have to call in construction teams, halt extraction at nearby facilities, if not do more?
A. I… Yes. That’s right.
Q. And as managing director of Ouron, you’d know if something as major as reconstruction of portions of the dam occurred?
Q. So to your knowledge, was the dam repaired in that fashion?
A. No… not to my knowledge. I believe… the Juna Explorations teams analyzed the damage and told us no further work was necessary.
Q. And that didn’t seem odd to you?
MR. SRIN: Objection. Vague.
A. I guess… at the time, there was a lot going on, and I trusted the process.
Q. Earlier you were talking about your responsibilities as a managing director. Is safeguarding the health and safety of the colonists one of those responsibilities?
A. I’m… yes.
Q. And you mentioned that you chose to work on Ouron because you wanted to help humankind, essentially, right?
MR. SRIN: Objection. Misstates prior testimony.
Q. So if you had the opportunity to protect your fellow man on that colony, you absolutely would have done that, right?
Q. But when Juna’s off-planet team told you Purlicue Dam didn’t need repairs, and didn’t identify any specific cause for the flood, you didn’t find that strange. Didn’t bat an eye, right?
To put it simply, you didn’t actually do anything to try to figure out what killed all of those people, did you?
MR. SRIN: Objection. Kim, this is out of line.
Q. Mr. Srin. A question is pending, and Ms. De Leon is in the middle of the answer.
Madame court reporter, read that back, please.
COURT REPORTER: To put it simply, you didn’t actually do anything to try to figure out what killed all of those people, did you?
A. I did… I did what I could.
MR. SRIN: We’re going off the record, right now. Kim. Outside.
Q. Thank you, Ms. De Leon. Let’s take a short break.
COURT REPORTER: And we’re off the record.
Excerpt from the Deposition of Charles Bailer – Standard Date 110650
Q. Mr. Bailer, did you get any daily reports about activities on Ouron?
MR. SRIN: Objection. Vague.
A. That is vague, isn’t it? I don’t know if I understand that. Ask it again.
Q. Mr. Bailer, did you get any reports about activities on Ouron?
A. Well, as CEO, I get a lot of reports. Juna Explorations has over two hundred colonies. Over three thousand research facilities. Over ten million colonist-citizens. So I’m sure I got reports, but it’s hard to know what you mean without looking at a specific document.
Q. Okay. And do you know what a “U.S.E.” is?
A. Again, I can’t be sure without reviewing documentation. Unanticipated Seismic Event, or something like that.
Q. Let’s move on to something else. Is the gigantiform dead?
MR. SRIN: Objection. Vague. Calls for legal conclusion and/or expert testimony.
A. Uh. What?
Q. Simple question. Is the gigantiform on Ouron dead? Yes or no.
MR. SRIN: Same objections.
A. It’s an organism that doesn’t meet any of the established USS criteria for life. It doesn’t metabolize, grow, adapt to its environment, respond to stimuli, or reproduce, as far as we can observe.
Q. Is it dead?
MR. SRIN: Same objections. And asked and answered.
A. Look, it meets no specific criterion for life.
Q. Interesting choice of words. Let’s take a look at the following, previously marked as Exhibit 49. This is a public document. Take a minute to read it.
A. I don’t have to. I know it. My father had a copy of this framed in our house.
Q. What is the document, Mr. Bailer?
A. It’s a press statement from Juna’s Chief Science Officer, Dr. Malcolm Oswald, from when they announced the discovery of the gigantiform.
Q. And Dr. Oswald was also the previous managing director of Ouron, correct?
A. That’s right.
Q. And he established the first extraction facilities and their protocols on Ouron thirty years ago, correct?
A. Yeah. You got it. I like this guy. He’s very prepared.
Q. Thank you, Mr. Bailer. I appreciate your confidence. Now please look at the bottom of the first paragraph. Could you read that into the record, please?
A. “This is a remarkable step forward for Juna Explorations and humanity as a whole. Already, this organism has revealed great wonders we have yet to fully understand. Our estimates, judging from the limbs that remain visible on the surface, indicate that its span may be almost 3,000 kilometers, which is larger than most countries and nearly a quarter of the diameter of Ouron itself.
“Based on our silicon dating, we believe the organism is millions of years old, and its positioning and depth in Ouron’s crust suggest it may have collided with the planet’s surface, quite violently, some time ago, after traveling for some time in the vacuum of space.”
Q. The rest of that page too, please.
A. “The organism appears humanoid, with appendages and an anatomy that suggests it may have, at one point, held itself upright. Though it, interestingly, has no oral cavity or identifiable ocular organs that we’ve been able to observe.
“Ultimately, however, based on our initial testing, the organism currently meets none of the established USS criteria for active life. It seemingly does not metabolize, grow, adapt to its environment, respond to stimuli, or reproduce. Perhaps the organism did, long ago, function in some way, but either because of its exposure in space or its impact on Ouron, that no longer seems to be the case.”
Q. What would be different, if the gigantiform were classified as life?
MR. SRIN: Same objections.
A. We have a whole legal department to figure that out. I’m the wrong person to ask.
Q. You might not be allowed, legally, to extract cronesium from the organism at all?
MR. SRIN: Same objections.
A. Look. I said I don’t know. What does this even have to do with this case? Did someone put you up to this? The TC?
Q. When you say “TC”, are you referring to the Titan Church?
A. Who else would I be referring to? Yes. The nutjobs.
MR. SRIN: Maybe we should take a break?
A. No. It’s fine. I just don’t like this religious activism invading scientific industry. It isn’t right. And you know they’re lobbying the Xenobiological Association too. So I can smell them a mile away.
You asking for them or what?
Q. Mr. Bailer. I assure you that the only people I represent are the victims of Distal Brook and their families, but let’s change topics.
I’m going to mark the following as Exhibit 161. Please take a moment to review.
What is this, Mr. Bailer, if you know?
A. It appears to be an annual seismometer output aggregation report for Ouron.
Q. And you see that first line, where it says: “Standard Date 112146”? And then next to that it says “U.S.E. registered”, right?
Q. And, next to that, there’s a reference to “B.E. engaged”.
What is B.E. a reference to?
A. I—I wouldn’t know exactly. You’d have to ask the managing director, Ms. De Leon.
Q. Okay. As you can see the document goes on with similar dates and U.S.E.s for Standard Year 46, the year prior to the Distal Brook Flood, and by my count there are about one hundred thirty-five U.S.E.s registered, or an average of ten or more, a month.
My question to you is, if these “events” occur with that kind of regularity, how could they possibly be “unanticipated”?
MR. SRIN: Objection. Calls for a legal conclusion and/or expert testimony.
A. You’d have to ask the seismometer technicians. That’s just how we classify them.
Q. I’m asking you, Mr. Bailer. If there are this many seismic events, at this frequency, your position is that Juna Explorations doesn’t anticipate them?
MR. SRIN: Same objections. And asked and answered. And harassing the witness.
A. I’m saying, I don’t know.
Q. But, to your knowledge, no employee of Juna Explorations takes the position that these seismic events can be predicted, right?
A. I… I can’t speak for every single employee. I don’t want to misstate anything.
Q. Mr. Bailer. Please stop looking at your attorney. I know Mr. Srin is about to explode in a minute, but he knows full well that you have to answer this question.
I’d also remind you again that you’re testifying under penalty of perjury.
Has any Juna Explorations employee, to your knowledge, ever asserted that these seismic events can be predicted?
MR. SRIN: This is outrageous. I’m dialing the judge’s chambers this second. Mr. Bailer, please step outside. Counsel, we’re going off the record.
COURT REPORTER: And we’re off the record.
COURT REPORTER: And we’re back on the record.
Q. Now that we’ve stretched our legs and Mr. Srin has gotten that out of his system, let’s try this again. Has any Juna employee, to your knowledge, ever asserted that these seismic events can be predicted?
A. It’s possible someone may have.
A. Dr. Malcolm Oswald.
MR. SRIN: Per our discussion, we’re going to designate this portion of the testimony highly confidential pursuant to the stipulated protective order.
[Remainder of testimony redacted.]
Excerpt from the Deposition of Teresa De Leon Vol. 2 – Standard Date 062652
Q. Ms. De Leon. Welcome back. It’s been some time. Almost a year and a half.
Q. I apologize for the delay. It took the attorneys a while to work out a second day of deposition. Nonetheless, we’re glad we were able to proceed, as I’m sure you are.
A. Yes. I’d just—I’d like this to be done.
Q. Before we start, I want to go back to some of your statements in your prior deposition, and we can refer to the transcript if you need it at any point, just let me know. Okay?
Q. The last time we spoke, you briefly mentioned the previous managing director on Ouron, Dr. Malcolm Oswald.
How well did you know Dr. Oswald, if at all?
A. Reasonably well. He stayed on for a year after I arrived to help with the transition. He taught me everything he knew about the gigantiform, the colony, and his work on Ouron before he returned to Earth.
Q. And did you ever keep in contact with him after that?
A. Unfortunately, no. He passed away, and we didn’t get a chance to connect in the intervening years.
Q. Are you aware that after his tenure on Ouron, he began writing publicly about the gigantiform?
A. I don’t think I heard that… exactly.
I’ve been told he’d declined a bit in his old age and became a bit troubled, but I’m not aware of the specifics beyond that.
Q. Were you aware that, later in life, he disavowed his work as managing director for Juna Explorations and believed that the company had engaged in unethical, abusive practices?
A. I… was not. No.
Q. Were you aware that his writing gained traction with a number of individuals on Earth, and, after his death, they started an organization dedicated to some of the tenets of his work—an organization known as the Titan Church?
A. I’ve… heard of them. But I’m not sure what this has to do with—
Q. Don’t worry. We’ll discuss that in a moment.
Now, during your last deposition I asked you if you knew anyone in Distal Brook, and you said you did not. Do you recall that discussion?
Q. I’d like to introduce the following as Exhibit 284.
What is this, Ms. De Leon?
A. It… appears to be a request for leave that I signed for an employee to attend a family event. It’s standard for me to do so for certain supervisory positions.
“Child’s birthday”, it says.
Request came from a… Dr. Mark Granger.
Q. Who is Mark Granger?
A. He is—I mean he was—a researcher who worked at the wrist facility.
Q. Were you close?
A. I wouldn’t say close, but we knew each other, yes. He was part of a team that tested cronesium applications, so I’d interact with him regularly as part of my duties as managing director.
Q. Ever meet his family?
A. I… I might have. Maybe a few times for certain special tours. I’d sometimes greet the company families on those occasions. I think I spoke to his wife.
Q. How about his kids? Meet his kids?
MR. SRIN: Objection. Harassing the witness.
A. Two boys, maybe. I’m not sure.
Q. And what happened to Dr. Granger, if you know?
A. He—excuse me.
He was in Distal Brook at the time of the flood.
Q. Meaning he died, correct?
Q. His family too, correct?
MR. SRIN: Objection. Harassing the witness!
Q. In fact, his older son died on his tenth birthday, the day of the Distal Brook Flood, correct?
MR. SRIN: Same objections. What the hell is this, Kim? Are you seriously going to try and—
I’m making it clear that we’re going to be thorough in correcting the record. I also want to remind Ms. De Leon of her responsibilities as managing director of Ouron before we revisit her other answers.
Now, I’ve tolerated your interruptions in the past, but I ask that you please refrain from this extensive commentary, which, you know as well as I do, is impermissible during your client’s testimony.
MR. SRIN: You—
Q. I mean it, counsel. Anything beyond simple objections, and I’ll be forced to file another motion for sanctions. And you know the judge will be open to granting it again.
Now, with that out of the way, please answer the question regarding Dr. Granger’s son, Ms. De Leon.
A. To my knowledge… Yes. Dr. Granger’s son was one of the victims of the flood. His school was… The Distal Brook elementary school was one of the buildings that flooded. A number of colonists, teachers, students were… from what I know… they didn’t make it out of the township.
After the last time, the deposition. What you said to me about taking care of the colonists and my responsibilities as a managing director, I—I didn’t take that lightly. Really. I took some time to go through the records of people who were in Distal Brook, to get a better sense of who was there. Fathers, mothers, kids, community members. There were… they were all… it was a lot that was lost.
I understand that better now.
And I didn’t mean to overlook any of that the last time. Really. I didn’t.
Sorry, I don’t know what I’m trying to say. And I didn’t mean to be overly… emotional about this.
Q. Thank you, Ms. De Leon. For what it’s worth, I think you’re being appropriately emotional, and I appreciate that clarification.
Please set that aside.
Now, the last time you were here, I also asked you how many Juna Explorations facilities were on Ouron. You told me eleven. I assume you were just under stress and overlooked this as well.
I’m going to allow you to correct that statement, right now, if you’d like. I strongly suggest you do.
How many Juna Explorations facilities are on Ouron?
Q. Go ahead, Ms. De Leon.
Q. Thank you. There are eleven extraction facilities on the gigantiform’s hand, and then an additional “temple facility” near what we believe to be the organism’s skull, correct?
A. How do—yes.
Q. Thank you.
Now, I told you we’d discuss the Titan Church and its connection to this matter, so let’s go back to that.
It turns out, the Church followed Dr. Oswald very closely, and they maintain quite a comprehensive collection of Oswald’s personal papers. It makes it convenient to subpoena them, in cases like this, where the opposing party is not always so forthcoming with documentation, and I’d like to share some of that documentation with you now.
Let’s enter in the following as Exhibit 300.
What is this diagram, Ms. De Leon?
A. It’s… it’s… Okay. Okay. A moment please.
Q. Are you ready to continue?
I’ll ask it again.
What is the diagram in Exhibit 300?
MR. SRIN: Objection. Document speaks for itself. Calls for specula—
A. It’s… well—
MR. SRIN: —tion.
A. It’s a draft schematic, showing the designs for a device developed by Juna Exploration for use on Ouron.
We called it the Bitemporal Electrode.
Q. And what is the “Bitemporal Electrode”?
Ms. De Leon?
What is the “Bitemporal Electrode”?
A. It is a two-part mechanism, drilled and implanted on either side of the gigantiform’s skull.
Q. And what was the purpose of the Bitemporal Electrode?
MR. SRIN: Objection. Vague.
A. The device was designed to generate a large amount of energy between the electrodes, which in turn disrupted nearby electrical activity.
Q. Meaning, electrical activity in the gigantiform’s skull?
MR. SRIN: Objection. Misstates prior testimony.
Q. If you look at the report previously marked as Exhibit 161, next to indications of U.S.E. events there are concurrent denotations for “B.E. engaged”.
Are these recording incidents where the “Bitemporal Electrode” was engaged by Juna personnel?
MR. SRIN: Objection. Document speaks for itself—
Q. Why did Juna engage the Bitemporal Electrode in these instances?
MR. SRIN: Objection. Calls for speculation.
A. Whenever we detected the beginnings of a seismic event, usually with an alarm system associated with the seismometers in the wrist facility, we would engage the electrode as a precautionary measure.
A. By disrupting electrical activity in the gigantiform, we found that we could often mitigate the seismic activity and lessen the time of the U.S.E.s or halt them altogether.
Q. In other words, you’d detect an incoming U.S.E., activate the electrode, and the U.S.E.s would lessen or stop, correct?
A. Yes. That’s often how it would go.
In your previous deposition you stated that there were several causes for a seismic event, including tectonic plates shifting, unexpected pockets while drilling, and so on.
Given what you’ve just told me about the connection between the B.E., the activity in the gigantiform, and the U.S.E.s, is it possible that the gigantiform’s body itself is a possible cause for these seismic events?
MR. SRIN: Objection. Calls for speculat—
A. Possibly. Yes.
Q. Could you repeat that?
A. Yes. Movement in the gigantiform’s body could theoretically be the cause of a U.S.E., though we’d never observed it directly before.
Q. Before Distal Brook, you mean?
Strike that. Withdrawn.
Give me a moment.
Do you remember, in your prior deposition, our discussion of photographs of the Purlicue Dam? In particular, the fact that the dam had not been visibly damaged?
Q. That’s because the dam breaking didn’t cause the flooding of Distal Brook, did it?
MR. SRIN: Objection. Calls for speculation.
A. I… Based on what I know, that does not seem likely. No.
Q. Before I get to this next question, I want to remind you of everything we discussed so far and in your prior deposition—the reason you joined Juna, your duties as managing director of the colony, and your relationship with its citizens, including your colleague, Dr. Granger.
With all that in mind, Ms. De Leon, what, based on what you know, could have caused the flooding of Distal Brook?
MR. SRIN: Mr. Kim, could we—
A. Wait, Mr. Srin. I think I should… I think I do want to answer this.
MR. SRIN: Ms. De Leon, I’d really prefer that we discuss this off the—
A. Based on the concurrent U.S.E. and the volume of water that cascaded outside the containment area, it’s… possible… again I don’t know… it’s possible that the waste water could have been displaced.
The gigantiform’s finger could have shifted, even just slightly, and that would have been enough to trigger the flooding that we observed.
MR. SRIN: Objection.
Q. What is your objection, Mr. Srin? There’s no question pending. Are you objecting to her answer?
MR. SRIN: I—withdrawn.
Q. Is that what you think happened, the gigantiform’s finger shifted?
A. I don’t… I don’t have any direct evidence to confirm that for certain, and, after my last deposition, I spent some time… trying to find records that might give a clearer picture of what occurred.
There is only, to my knowledge, a single flight report from the day of the flood, which references a fault line forming near the gigantiform’s index finger. A shuttlecraft pilot radioed for permission to investigate when he was en route to the wrist facility, but the results are heavily redacted except mentions of wreckage in the area—fallen timber that needed to be hauled and service roads to be repaired. I haven’t been able to find any more information than that.
Nevertheless, based solely on what I do know about the gigantiform’s physiology as well as our facilities and history with the organism… I… I do believe that it’s at least… capable of moving as a general matter.
Q. So, just to be clear, the day the flood occurred, you, as managing director, were at least aware of the possibility that the gigantiform could move, correct?
A. Again, only theoretically.
But yes. That’s correct.
Q. And were any of the colonist-citizens of Ouron aware of this theoretical possibility too?
A. Not to my knowledge. No.
Q. Was your colleague, Dr. Granger, or any of his family, aware of this theoretical possibility?
A. I’m— Sorry— Give me a second.
Not to my knowledge… No.
Q. And did you, or anyone else in Juna Explorations, take steps to inform anyone on Ouron of the theoretical possibility that the gigantiform could, in fact, move?
A. No. We did not.
Q. So all of those colonist-citizens who died when that hazardous material overflowed into Distal Brook, they had no idea they were risking their lives, creating a settlement so close to the organism, did they?
Q. Why didn’t Juna just tell them, any of this? Any of what you’re telling me now?
A. I… I don’t know.
Juna had been mining for decades without incident, and we believed we had an effective mechanism for minimizing any such risk. If… I mean… knowing what I know now, if I could warn them, if I could have foreseen all of this, then I would have.
I just didn’t know—
Q. Take your time.
Now, whether or not Juna had minimized risk from the gigantiform with the B.E., the organism’s movement could potentially indicate that it’s still alive, couldn’t it?
A. It could.
Q. And that classification by the USS could complicate Juna Explorations’s extraction operations, couldn’t it, Ms. De Leon?
A. Yes. It could.
Q. That could prevent the USS from extracting cronesium, a resource it relies on to produce its fuel rods and that is key to expanding its colonies?
A. It… could have that outcome, yes.
Q. So it’s in Juna’s interest to withhold any information that would lead to that outcome, isn’t it?
A. It would cause problems for Juna if that information were known to others. Yes.
Okay, Ms. De Leon.
This is… this is a lot of new information we’ve covered just now, so I’m going to want to go through this again in more detail. It also looks like Mr. Srin is signaling to me that he needs to contact his client, and he and I may have a few more things to discuss as well. But before we go off the record momentarily, I have to ask.
If Juna is suppressing the gigantiform’s movement, is it at all possible that the organism is aware of what’s happening?
A. Aware of what’s happening? I don’t…
Q. That it knows what’s going on on Ouron—what Juna is doing to its body, I mean?
A. I don’t think… I mean there’s no way to really know if… I don’t know.
Q. Never mind.
Q. Forget it.
I think that’s enough for now.
Let’s go off the record please.
COURT REPORTER: The time is 11:32 AM, and we are going off the record.
Afterword – JUNA EXPLORATIONS PRESS RELEASE – Standard Date 081652
NEW DISTAL BROOK, Ouron, and NEW YORK CITY, New York—Juna Explorations has reached a $20 billion-dollar, global settlement with the colonists affected by the Distal Brook Flood. The settlement includes dismissal of all current suits concerning or related to the flooding of the Distal Brook township. All other terms of the settlement are confidential.
“Juna Explorations stands behind the brave men and women who comprise our colonies, and we hope that, with this settlement, they, and we, can look toward a safe and secure future among the stars,” said Charles Bailer, CEO of Juna Explorations.
“My clients are relieved that they can finally move on with their lives,” said lead Plaintiffs’ counsel, Arthur Kim. “They believe, and hope, that this tragedy will instruct Juna Explorations operations going forward, so that no one else has to suffer the losses that they have suffered, and no one else will have to endure what they’ve endured.”
Second Afterword- Letter from A. Kim to X.A. Chairman Campos- Standard Date 011254
Dear Chairman Campos,
I’m writing in response to the Xenobiological Association’s request for a comment on the “historic victory” achieved by the victims of Distal Brook, as it was phrased in the letter directed to my office. I understand you would like to potentially use any such response as a postscript to a compilation you are preparing concerning the events of the flood. While I cannot discuss the substance of the settlement beyond what is publicly known, I am writing primarily to correct your characterization of the resolution of this case.
As you, and all of the USS, probably know well by now, my clients lost far more than Juna Explorations could compensate them for, and I suspect those who’ve survived will not know a semblance of peace or normalcy for many years to come. Though the dollar amount presented by Juna Explorations is impressive at a glance, it results in very little for the individual victims once costs are deducted and the settlement is divided by the tens of thousands of plaintiffs, many of whom aren’t alive to see that award anyway. The simple truth is that we only accepted the settlement because my clients could not afford, financially or emotionally, to fight the mega-colonies of Juna Explorations in court for another five years. It was for that reason that my firm abstained from collecting its full fees, as did a number of other firms involved in this case.
Meanwhile, mining operations continue on Ouron unchanged. To date, there has been no public analysis or even recognition of the “seismic” risks associated with extraction from the gigantiform. Nor are there any public investigations by the USS that I’m aware of into the classification of the gigantiform as a non-living entity.
The organization known as the Titan Church has filed for various injunctions, but those suits have yet to go anywhere as of the writing of this letter. So, for all intents and purposes, everything on the colony remains the same as it did six years ago, barring the absence of one small town and everything it once contained.
You asked for a response to include in your compilation regarding our victory, but the only response I have for you is this: