EXHIBIT 3

Case: 1:20-cv-02753 Document #: 230-3 Filed: 02/07/22 Page 1 of 5 PageID #:4896
ATTORNEYS' EYES ONLY

1 IN THE UNITED STATES DISTRICT COURT

 NORTHERN DISTRICT OF ILLINOIS

2 EASTERN DIVISION

3 LKQ CORPORATION and KEYSTONE )

 AUTOMOTIVE INDUSTRIES, INC., )

4 )

 Plaintiffs, )

5 )

 vs. ) No. 1:20-cv-2753

6 )

 GENERAL MOTORS COMPANY, )

7 GM GLOBAL TECHNOLOGY )

 OPERATIONS, LLC, and GENERAL )

8 MOTORS, LLC, )

 )

9 Defendants. )

10 The videotaped videoconference deposition of

11 ANGELA CALIGIURI, called by the Plaintiff for

12 examination, pursuant to notice and pursuant to the

13 Federal Rules of Civil Procedure for the United States

14 District Courts pertaining to the taking of depositions

15 via Zoom, taken before Nicole Marie DeBartolo, Certified

16 Shorthand Reporter and Registered Professional Reporter,

17 with the witness located at 3093 Myddleton Drive, Troy,

18 Michigan, commencing at 8:00 a.m., Central Standard

19 Time, on December 20, 2021.

20

21

22

23

24

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Case: 1:20-cv-02753 Document #: 230-3 Filed: 02/07/22 Page 2 of 5 PageID #:4897
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1 certain how it is divided.

2 BY MR. BREGENZER:

3 Q Who was the buyer for the lower grill of the

4 2017 through 2019 Cadillac XT5 at the time GM was

5 sourcing the lower grill from Lacks?

6 A My understanding is that the buyer's name was

7 Zarko Ilijevski, and that's Z-A-R-K-O,

8 I-L-I-J-E-V-S-K-I.

9 Q And is Mr. Ilijevski no longer employed by GM?

10 A Correct.

11 Q Do you know when Mr. Ilijevski left GM's

12 employ?

13 A From our investigation, GM investigation, it

14 appears he left in March of 2019.

15 Q With respect to the grill bezels for the 2019

16 Chevrolet Camaro, who was the buyer at the time that GM

17 was communicating with Magna with respect to the

18 manufacture of those parts?

19 A The buyer's name was Nnaemeka Amazu, and

20 that's N-N-A-E-M-E-K-A, Amazu, A-M-A-Z-U.

21 Q Is that Mr. Amazu or Ms. Amazu?

22 A From my understanding, it is a mister.

23 Q Is Mr. Amazu still employed by GM?

24 A No.

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Case: 1:20-cv-02753 Document #: 230-3 Filed: 02/07/22 Page 3 of 5 PageID #:4898
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1 BY MR. BREGENZER:

2 Q Were any automatic deletions put on hold by

3 GM's IT group in response to the litigation hold memo

4 sent in this case?

5 MR. GOSEN: Objection, outside the scope.

6 You can answer, if you know.

7 THE WITNESS: Yes.

8 BY MR. BREGENZER:

9 Q Who put automatic deletions on hold in

10 connection with the litigation hold memo sent in this

11 case?

12 MR. GOSEN: Objection, outside the scope.

13 THE WITNESS: I don't know.

14 BY MR. BREGENZER:

15 Q Do you know what specific automatic deletions

16 were put on hold?

17 MR. GOSEN: Objection, outside the scope.

18 THE WITNESS: From my understanding, if you are

19 under a litigation hold and you were to leave the

20 company, then your computer is imaged. So that would be

21 something that is put on hold due to the lit hold.

22 BY MR. BREGENZER:

23 Q Do you know whether Mr. Ilijevski's computer

24 was scanned in connection with the litigation hold in

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1 this case?

2 A Yes.

3 Q Was it?

4 A No.

5 Q Do you know whether Mr. Amazu's computer was

6 scanned in connection with the litigation hold in this

7 case?

8 A Yes.

9 Q And was it?

10 A No.

11 Q Did the litigation hold memo sent in

12 connection with this lawsuit specifically call out RFQs

13 and RFQ responses?

14 MR. GOSEN: Objection, calls for attorney-client

15 privileged information and work product, and I instruct

16 the witness not to answer.

17 BY MR. BREGENZER:

18 Q Are you going to follow Mr. Gosen's

19 instruction?

20 A Yes.

21 Q Did any of the recipients of the litigation

22 hold memo in this case work in the purchasing group?

23 MR. GOSEN: Objection, outside the scope.

24 THE WITNESS: I'm not certain.

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Case: 1:20-cv-02753 Document #: 230-3 Filed: 02/07/22 Page 5 of 5 PageID #:4900