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[...]
much energy was being transferred?
Q. Well, that was going to be my next question, was did you have any --
A. No.
Q. -- measurement?
A. No, no method.
Q. Just so I ask the whole question.
A. That's what it seems like, you're going in that direction.
Q. I am, but I am trying to go there incrementally. Let me just ask. Was there any method to measure the amount of energy or power that was being provided by Leonardo to the J.M. Products side of the Doral warehouse?
A. No. No.
Q. We had looked at a picture this morning that showed the hoses that were going into the system so that water could be added into the system. I believe that's Exhibit 4. Do you know whether there was any measurement of the water that was flowing through the hoses into the system?
A. I don't know.
MR. ARAN: Objection to form.

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MR. CHAIKEN: Objection to form.
MR. NUNEZ: Object to the form.
BY MR. PACE:
Q. I will ask the question again, just so I can cover any objection. Maybe not. Can you take a look for me at Exhibit 4.
A. Yes.
Q. There -- we see hoses in Exhibit 4, correct?
A. Yes.
Q. Am I correct that you testified this morning that those are hoses for water to go into the system?
A. As I recall, yes.
Q. My question is are you aware of any measurement that was made of how much water was bring placed into this system through those hoses?
A. No.
Q. Are you aware of any measuring device that existed to determine that?
A. No.
(The document referred to was thereupon marked Bass Exhibit 16 for Identification, a copy of which is attached hereto.)
BY MR. PACE:

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Q. I'm going to hand you what's been marked as Exhibit 16. We're actually going back in time now, back to January of 2015. Just a few questions on this. Just take a second. One is, does this refresh your recollection as to whether Reinaldo lived there?
A. I told you sometimes he lived -- he slept in the office so I don't know that he lived there permanently.
Q. Okay.
A. He was an immigrant, so.
Q. There was a flow meter for the water that was being provided by --
A. Yeah, everybody has one. Don't you have one?
Q. I know. I'm just --
A. Yeah.
Q. -- getting clear here. Hold on. This is the flow meter from Miami sewer?
A. Yeah.
Q. Miami-Dade sewer?
A. It was outside the building. I don't think it's from the sewer though.
Q. Water. Just the water.
A. Thank you.

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(The document referred to was thereupon marked Bass Exhibit 17 for Identification, a copy of which is attached hereto.)
BY MR. PACE:
Q. Handing you what's marked as Exhibit 17. We have a few documents on this, though may be able to probably shortcut this after I talk to you about some of these. There were a couple of -- I see the Banana PI version. There was also something called the BeagleBone. Just generally can you tell me what was the work that you were doing with Fulvio Fabiani?
A. This was pretty much the main reason I was hired, was -- where my engineering part came from, is to design the future robotic control system for the reactor and for whatever we use on the reactor. If you want to know what a Banana Pi is, it's a little Linux based card that does -- it does ethernet, it does -- has video controller on it, It has keyboard controller on it. It has USB. It's about that big and the target was to be able to put in a more compact reactor and take care of all the control things necessary and we went through a selection process. Fulvio is a very, very

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cognizant engineer of control systems, so we went through a selection process for the Banana Pi. Sorry, the Raspberry Pi, which is really the name of the processor based out of England. Then when China came up with one called the Banana Pi, then we finally settled on BeagleBone Black. If you look it up on the Intemet it' a reality.
Q. I know. They are unusual names but they all exist.
A. Yes, and it's made by Texas Instruments and it's a US product and has lots of documentation. I wrote a lot of code and we were getting ready for a design to actually implement that board.
MR. CHAIKEN: Just for the record, Chris, were going to designate that response as highly confidential, attomeys' eyes only. I guess we can do this after the fact as it relates to all his testimony but I just want to make sure the record is clear.
BY MR, PACE:
Q. Fair enough. Having ultimately settled on the BeagleBone, was that -- this is a system for controlling what in connection with the E-Cats, the amount of electricity that went into the E-Cats, the amount of water that went into the E-Cats to be

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heated, everything?
A. This was a control --
MR. CHAIKEN: Object to form. Sorry, you can answer.
THE WITNESS: Hub?
MR. CHAIKEN: I objected to form. You can answer.
THE WITNESS: It was a system. If could be coarse in the description, it has gazuntas and had gazoutas, allright. It's the way control processors work, is they have monitored inputs that can be digital in, digital out - sorry, digital in or analog in and it can control digital out. In other words, it can read a sensor and it can control a servo, move an arm, tum a motor. That was the function of it and all control processors are like that. So whatever you put on the other end, it doesn't make a difference, as to turning water on and off. measuring temperature. diverting turning a valve back and forth, thats what they do.
BY MR. PACE:
Q. Okay.

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A. The center brain of it is fexible.
Q. So what were these ones designed to do? The ones that you were working on, what was going to be on the other end, the digital out?
A. I don't know. Fulvio just gave me the description of what we had to start with, allright, and how many points of digital in, how many points of digital out, how much analog input and that was where we were working along. He said this is what we see that were going to need. So I can't tell you what the direct output was and I can't even tell you what the direct input is, but the inference is obviously was measuring temperature, pressure, things like that.
Q. You say the inference, Is that because --
A. The inference of a control system and what it does.
Q. I am saying are you -- is it your belief that this was going to be used in connection with the E-Cats?
A. Yes.
Q. All right. Was it ever put in use in connection with the E-Cats?
A. We didn't get that far.

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Q. All right. is this something you're still working on connection with the E-Cats?
A. Directly right now, no.
Q. When did you stop working on that?
A. When things fell apart with the whole Industrial Heat deal.
Q. Would that be roughly spring of 2016?
A. Yes.
Q. Is it possible that this system was going to be used for something other than the E-Cat?
A. Could have been, yes. Could have been used on the other side of the steam side. It's a general purpose. That's the whole idea of these things.
Q. That's all I was trying to understand too.
A. Yeah.
Q. From your standpoint it was a general purpose device and it didn't have to necessarily be used with an E-Cat, they may have been working on something else thatit could be used for?
A. That's correct
Q. And the main person working on this was -
A. Me.

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Q. Was you with Fulvio Fabiani?
A. Well, with his advice, actually, I guess you could say, because he's done a lot of major control systems. He's designed the control system for the big E-Cat. He gave me concepts to deal with and constraints and said this is what we're looking for later on.
Q. Okay. You said that was the main reason that you were hired?
A. Pretty much, yeah.
Q. Did Fulvio Fabiani work for J.M. Products?
A. No.
Q. - Any time you bought equipment or material for this project, this main project you were working on, would the cost have to be approved by either Andrea Rossi or by Fabiani?
A. Uh-huh.
MR. NUNEZ: Object to form.
BY MK. PACE:
Q. I want to come up with a shorthand for this project that you were working on. What can I call it that we can agree to on a -- did you have a name for the project? Was

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there a --
A. BeagleBone.
Q. Okay.
A. We called it the BeagleBone.
Q. BeagleBone project?
A. Yeah, BeagleBone is fine. I suggest you look on the Internet and see what it does too. You will have a far better idea.
Q. I actually did look at it just the other day.
A. Okay.
Q. As well as the Raspberry, which is actually spelled R-A-S-P-B-E-R-R-Y, right? There is a P that gets snuck in there, I think.
A. Yeah, and the Pi is not something that tastes good.
Q. Right.
A. It's the Greek letter Pi.
Q. You had testified this morning, I believe, that one of the other things you worked on when you were working with J.M. Products and Andrea Rossi was measuring temperature in piping.
A. Piping? Well, temperature, yeah, measured temperature.
Q. What projects -- what were you involved

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in with J.M. Products or Andrea Rossi for measuring -- other than the BeagleBone project were you involved with measuring temperatures for anything?
A. Occasional checking to see what was going on on our side, looking at the flow meter and looking at the temperature of the steam.
Q. So there were temperature gauges on the J.M. Products side?
A. Yes.
Q. Where were those located?
A. They were outside of the chamber sitting on a table.
Q. And where would -- where were the sensors, the temperature sensors attached?
A. Obviously went through the wall and they were tapped into the serpentine.
Q. So if we can -- I know I keep sending you back here. If you can go back to Exhibit 2, the temperature sensors are in this piping somewhere?
A. Yeah, I think they are -- I think you can't see them because I think they go up the other end. I didn't install the sensors in there. I only had access to the meters outside that measured

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that.
Q. Did you keep track of that information?
A. No, just -- it was just an observation to look at it from time to time.
Q. So if you can do me a favor and look at Exhibit 4. I don't know if you can see it from here either, but I'm just going to see if that helps just because it's a different angle.
A. See what?
Q. Where the temperature sensors go into the piping.
A. They are buried inside of the insulation obviously to know what the temperature was.
Q. I'm sorry, if you look at the top of that picture.
A. Yeah.
Q. You see the little piece of metal there that's attached to the wood?
A. Yeah.
Q. And there is a wire that comes in the top of that?
A. That is something to do I think with the water -- the water system that was meant for something and I don't recall. I didn't put it in there. I never had anything to do with it.