Free Reply to Response to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00945-CFD Document 256-3 Filed 06/12/2008 Pagei of 3 1
_, 3 _`2· I IN THE UNITED STATES DISTRICT COURT
I FOR THE DISTRICT OF CONNECTICUT
I 2
, 3
I N0. 3:03—CV—945(CFD)
4
5 CLARENCE COLLINS, JR., ET AL
6 VS ()F%Ft
w is I ..4 ...;.1
7 OLIN CORPORATION
8
9 Depceiticm ei: CHRISTOPHER K. KERIN, taken
I0 pursuant te Rule 30 cf the Federal Rules ef Civil
ll Prccedure cctcre Barbara 5. Murph?} Liceneed Shcrtherd
_,_ I2 Reporter, License Nc. 305 and Nctery Public within and
· ** I3 ter the etete of Cemueeticut, held at the efficee et
I4 Drown, Rudnick, Beriuck, Isreels, IE5 Aeylum Street,
I5 Hertford, Ccnuecticut cn June I3, 20C? ccmmcrcing at
I6 0:35 a.m.
II
IE
IQ
20
2l
DEL VECCHIO REPORTING SERVICES, LLC
22 PROFESSIONAL SHORTHRND REPORTERS
III RANDI DRIVE
23 MADISON, CT 06443
(203)245~95S3
24 (203)245—2760
_ J 25 STANFORD HARTFORD REN HAVEN
DEL VECCHIO REPORTING SERVICES, LLC


i Case 3:03-cv-00945-CFD Document 256-3 Filed 06/12/2008 Page 2 of 335
1 a. Yos, I would agree with that.
2 Q. Am I correct that it‘s your position that
3 thc discovery of contamination in neighborhood parks
4 would adversely impact the value of properties in
5 proximity to such parks?
6 A. Yes.
7 Q. and am I correct that it‘s your position
8 that the discovery of contamination at tho Hamden
Q Middle School and at some of the surrounding parks
10 including Rochforo Field and Mill Rock Park adversely
ll impacted the value of properties in the Eewhall
12 neighborhood?
13 A. Yes.
1% Q. Okay. When did you first learn that there
15 was contamination found at the Hamden Middle Sohool?
16 A. I don‘t recall when I first learned. I was
l7 aware of contamination in this neighborhood just
l8 generally living in Conneotiout. I didn’t pay too
19 much attention to specifically, you know, where it
2O was.
21 when I first was asked to do this
22 assignment, I looked at the information that was
23 provided to me and also on tno Newhall dot org
24 website.
25 And that‘s when I first started —— was
DEL VECCHIO REPORTING SERVICES, LLC


Case 3:03-cv-00945-CFD Document 256-3 Filed 06/12/2008 Page 3 of 374
1 C E R T I P I C A I E
2 I hereby certify that I am a Netary Public, in
3 and fer the state ef Ccnnecticut, duly cemmissiened
4 and qualified te administer eaths.
5 I further certify that the depcnent named in
6 the feregeing depcsitien was by me duly swern, and
I thereupen testified as appeared in the feregeing
8 depesitien; that said depcsitien was taken by me
9 stenegraphically in the presence cf ceunsel and
10 reduced te typewriting under my directicn, and the
11 fcregeinq is a ;rue and accurate transcript cf the
12 testimeny.
13 I further certify that I am neither ei ccunsel
14 ner atterney te either ef the parties te said suit,
15 ner am I an empleyee cf either party te said suit, ner
16 ef either ceunsel in said suit, ner am I interested in
17 the cutceme ef said cause.
18 Witness my hand and seal as Mctary Public this
19 13th day ef June, ZOO?.
20
21 »·/W ‘"'' FT
(//¤' -.?»·'/ E; '
2 2 I c.riéicrcZs,_Ls2rs~c—;¢ __,c
Barbara L. Murphy, {SRMX
23 Netary Public J
2d
My Cemmissien Expires:
25 June BO, 2007
DEL VECCHIO REPORTING SERVICES, LLC