H , Collins ir. Oiim
6/Z8/2095 Eugeiyii Wiisoi?1
l
_._. _ ..14:.1,€ - 1 ‘.‘--»‘·: ‘ Rgg I
E UNITED STATES SISTRICT COURT {pi =-‘ /‘‘‘ E-§`L* -.:. --·. .E___ ‘·-‘‘ E I-
5 DISTRICT OF CONNECTICUT an E
~—- ~~~—— — —————————~ ~» ~~——————-—— »»~—~)
CLARENCE R. COLLINS, JR., et el.}
i
Plaintiffs, ) Civil Action No.
l i
vs. ) BOBCVQQ5 (CFD)
i
OLIN CORPORATION, et al., )
i
Defendants. 3
»» - ~»» W ~ ~— ——————————————— — - —~ - ~—————— )
DEPOSITION OF: EUGALYN WILSON
DATE: JUNE 28, 2005
HELD AT:
HALLORAN & SAGE, LL?
§w ®' ONE GOODWIN SQUARE, 225 ASYLUM STREET
HARTFORD, CONNECTICUT ·
Reporter:
Sendxe V. Semevolos, RMR, CRR, LSR #74
BRANDON SMITH REPORTING SERVICE
44 Capitol Avenue
I ` Hertford, Connecticut 06I06 i
g {860} 549~I850
` R5
Brandon Smith Reporting
Case 3:03-cv-00945-CFD Document 221 -9 Filed 08/03/2007 Page 2 of 4
, COH.i.m.s vv Ohm t --
6/23/ZOG5 Ettgztlgm Wilson
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Lgags 26 ! ?agt2
1 I Amd where did. ha muws? g E Q. Us you Imcw if }.E2—E3¢§ Shzzpsztti Street is J
Q 2 Jia. T0 â€E`@1·ri¤gt0h. 5 2 ins-ids tut outside cfthts study arse; ctmtaihcti in the I
[ 3 Qt Ami whats: is that? 3 constant 0rdct’?
‘ 4 A. ha Ccmtacticutu § 4 A. Within,
5 Q. How far away is that fmm Hamdwzn? 5 Q. You haha-zvc its within the: study arcs
6 A. About ah hour drive. 6 coaztzximzci in the consent ordcr?
7 Q. Did anyone: else live with you at 222 Morse: 7 A. Yes.
‘ 8 Street bctvvecm May cf 1989 and i993? 8 Q. What causes you to believe; its within the
9 A. My daughter wha was bum when I lived there. 9 study area covered by the consent mrdcr?
10 Q. And what is your daughtws name? 10 A. Because across thc: street @0:11 whats: that t
1 E A. Samantha. 1 1 is, the neighbor had har place tested, and its also é
12 Q. And what was hat birth dstc, or wht is har E2 within the map that was given to ma. E
I3 birth data? | 13 Q. What map are you referring tm?
14 A. 9/28/89. 14 A, A map ofthe N<=;wh.a§ivii1c neighborhood.
15 Q. Did anyone else live with you at 222 Morse 15 Q. `whszh did you receive that map?
16 Street between May mf 1989 and 1993? 16 A. I gotten one sometime ago md I gmtczn 0:1:2,
E7 A. My older daughter who came there in $990. E7 another tmc, if Tm not mistaken, its cithsr March 0;*
38 Q. And what is har name'? 18 April. T
19 A. Shakarah. 19 Q. Have you produced those-: maps in this casa?
20 Q. And what is har date: 0f hirth? 20 MR. MITCHELL: Arc they in this pile?
2} A. 7/19/82. 21 Maybe you can teh him the Baths
22 Q. And where did Shalwrah live prior to coming 22 number, 4358, Eos:}. j
23 t0 live with you at 222 Morse Street in E990‘? 23 BY MR. SANISON:
24 A. Jamaica. 24 Q. Thats the mma you believe you received
25 Q. Who was sha living widn in Eamaica? 25 recently? _ ’
Page 27 Page 29
1 A. Her grandmother. I A. Yes.
2 Q,. Vvhc-rc was Shaltrah hom? 2 Q. And was that given out at a meeting? ‘
3 A. Jamaica. 3 A. Yes —— m0. It was mailed t0 ma.
4 Q. Did anyone else live with you at 222 Morse 4 Q. That map was mailed tc: you, contained within
5 Street between May 1989 and 19939 5 43587
6 A. NO. 6 A. Yes.
7 Q. Did your daughter Samantha live with you 7 Q. D0 you recall who maiicd that to you? ‘
S from May 01* 1989 through 1993 at 222 Morse Street? 8 A. I c1cm‘t rascal} at the moment.
9 A. Yes. 9 Q. If y0u‘c§ Hip back to page 435i in that same:
10 Q. Is 222 Morse Street the cmiy property you 10 packet, which is the agenda of a May 17, 2005 mscting, ?
21 are claiming gives risc to your claims in this 11 was this also mailed t0 you? *
12 lawsuit? 12 A. Yes.
13 A. N0. 13 Q. D0 you recall when you 1`€C€i\’€2CZ$€l`1iS
14 I also 0wm -~ 14 document?
15 I\/IR, MITCHELL: You can wait for E1 I5 A. N0.
E6 question. 16 Q. Did you attend this May 17, 2805 mcetittg?
17 BY I\ȣR. SAMSON: E7 A. I was there.
18 Q. G0 ahead. 18 Q. We will get into that E1 littic more later.
19 A. {also own 132134 Shepard Street. 19 But you believe: you received at map with that packet of
20 Q. Amd when did you purchase 132 t0 134 Shepard 20 information prior to the May 17, 2005 meeting? t
2 E. Street? 21 A. Yes. 5
22 A. December 17, 2002. 22 Q. D0 you rccail discussing that map which has
23 Q. Have: you ever lived at 132 to 134 Shepard ’ 23 s Battss number of 4358 Ol} it'? D0 you recast?
24 Street? 24 discussing that map with zmyhociy'?
25 A. N0. _ _ _ _ 25 A. Yeas. Ich . _ _ _ __ _ _
8 (Pages 26 to 29}
Bmmdan Smith Reporting
Case 3:03-cv-00945-CFD Document 221 -9 Filed 08/03/2007 Page 3 of 4
5 Collins v. Olin _
6/2.8/2095 Eugalyn Wilson
i Page 138 Fage 140
I two Feet, three feet, four feet or more. would you 1 A. Yes.
2 2 agree with whatever assessment arid recommendation or 2 Q. And what is your basis tor that statement l
1 3 approval they give? Let me rephrase that. i 3 and belief'?
i 41 11 the DEP says that three feet should he 4 A. When something or someone is iabeled, there
5 removed from your property and replaced with clean 5 is always a label.
6 till, would you be comfortable ther: that that was the 6 Q. Do you have a belief as to what the 222
7 appropriate remedy for your property? 7 Morse Street property would he worth today if there
8 A. That 1 wouldnt be sure of 8 were no contamination on the property or io the area? -
9 Q. Pm sorry, 1 didnt hear that. 9 A. 1 don't1
I 1 remedy. 1 1 has little value now, what is your basis for that Q
12 Q. And why would you say you wouldnt be sure 12 statement? 1
13 of that as the remedy? 13 A. Because houses in the neighborhood that are
14 A. Because what if my area is more than -- its 14 put up for sale, they hang around inthe market for a
15 four feet. 15 while, although there is a great demand for houses.
16 Q. You've indicated that testing indicated that 16 Q. Now do those houses ultimately sell?
17 the contamination on your property was less than four 17 A. Eventually.
18 feet; correct? And I assume we are talking about 222 18 Q. And I think you‘ve indicated you don’t1
20 A. Pm within four feet or less. Pm not sure 20 is that correct? ‘
21 if mine is four feet or if its less. 21 A. '1`hat 1 don't know.
22 Q. And this is at 222 Morse Street; correct? 22 Q. So it could be all these owners are getting
23 A. Yes. 23 exactly what they are asking for their houses;
24 Q. So 1et's say the contamination goes down to 24 correct? .
25 four feet. lfthe DEP says, remove four feet of soil 25 A. Tru not sure. They are getting out of the `
Page139 Page 141 it
1 from the property and replace it with clean soil, when 1. neighborhood, too, if they can.
2 that is completed, would you be comfortable that your 2 Q. 1t's also possible —— go ahead.
3 property had been properly rernediated? 3 A. I said, they are getting out ofthe
4 A. 1*rn not sure how comfortable F11 be, but it 4 neighborhood also, if they can. -
5 makes me a little more comfortable than 1 are at this 5 Q. You also mentioned that you purchased both
6 moment. 6 of your properties at below the asking price; correct?
7 Q. Do you believe that your property value will 7 A. Yes. ’
8 return to whatever value you think the property should 8 Q. And that wasnt based on contaraination
9 have if there is no contamination? 9 concerns, was it? 1
10 A. Pm not sure. _ 10 A. No. Fm not sure ofthe motive why Shepard E
1 1 Q. And why are you not sure? 11 Street was sold, but Morse Street, at the tirhe, no.
12 Ar Because Pm just aot sure if it would be. 12 Q. Do you think it‘s possible Shepard Street
13 There would still he a stigma in the neighborhood. 13 was sold because of contamination conc§ns in the
14 Q. So even if your property is cleaned up to 14 neighborhood?
15 the standards DEP sets, and after all the testing they 15 A. Possihie.
16 indicated, we c1on't believe there is anymore concern 16 Q. At the time were you aware of such concerns?
17 over contamination on your property, do you think 17 A. Of Shepard Street? No. ;
18 there would still be a stigma? 18 Q. At the time were you aware of concerns in 1
19 A. There is always going to be a stigma ia the 19 the neighborhood generally? ‘
20 neighborhood. 20 A. Yes.
21 Q. And why do you say that? 21 Q. At the time you purchased the Shepard Street
22 A. Because of the fact that the neighborhood 22 property, you were aware of contamination concerns in
23 was contaminated. 23 the area?
2d Q. And you believe thats true regardless of 24 A. 1 was aware ofthe middle school whole
25 what cleanu occurs in the oei hborhood? 25 issue.
36(Pages13Eto141)
Brandon Smith Reporting
Case 3:03-cv-00945-CFD Document 221 -9 Filed 08/03/2007 Page 4 of 4
, Collins y. Olin
6/23/2.0% Eugaiyn Wilson.
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l Q. And that didnt prevent you from purchasing i neighbors that are in the ne? gltbofntuo-d. i
I 2 l32—-l 34 Shepard Street; correet.? 2 Q. What other neighbors have you talked with
3 A,. I wasn`ttl1in.kingtliat it was all the way ·»~· ' 3 about your concerns about loss in value ofthe =
4 that that would have become a concern. i 4 property?
5 Q. Frn sony, could you repeat that'? i 5 A. Their names?
6 A. At the time I wasn’t thinking of Shepard { 6 Q. Yes.
7 Street being a conoem. it wasnt like right in the 7 A. Sonia ?owell and I talked a lot.
8 neighborhood ofthe middle school as Morse Street is. 8 Q. Anybody else'?
9 Q. Do you have any estimate, as you sit here 9 A. Mostly her and there is one lady at 650
l0 today, of how much value you think your property has 10 Newhall Street, Muriine Wellesley.
ll lost due to contamination concerns in the area? And ll Q. Anyone else you speak to about these
l2 first lets talk about 222 Morse Street. l2 concerns?
l.3 A. it has lost a lot of value because its E E3 A. East those two people and I talk more
E4 not —— even if I think of selling right now, TQ E lél- in—deptlx.
l5 wouldnt be able to get the price I could have get for l l5 Q. And what have you and Sonia Fowell
E6 it. §6 discussed.?
E7 Q. Do you know what youd ask for that 222 E7 A. I mean, we talked about, you know, things
18 Morse Street property? 18 that we eould be doing with our property, mud if we
19 A. Never think about it. 19 chose to sell the place, you know, how would that
20 Q. You do or don‘t think about it? 20 affect us.
_ 21 A. I <§on‘t think about it. 21 Q. What type of things have you come up with?
22 Q. Do you have any idea ofhow much money would 22 A. Not able to sel}. the place, that we might
23 you get for the Morse Street property today, 23 not be able to sell the property as quick as it would
24 regardless of what you asked for'? 24 have sold had it not been contaminated.
25 A. Based on the price in the neighborhood, over 25 Q. Has Sonia ?owell given you any estimates of _
Page 143 i Fage 1-45
1 200,000. ` l what she thinks the property should be worth or what
2 Q. And you think thats below what you think 2 they are actually worth now?
3 the property should be worth today? 3 A. No.
l 4 A. It is. 4 Q. Has Murline Wellesley given you any
5 Q. And if1‘1n correct, you paid 4E ,000 for the [ 5 estimates of what the property should sell for now or
j 6 222 Morse Street property in 1995; correct? F 6 what she thinks they are actually worth because ofthe
T 7 A. Yes. 7 contamination concerns?
8 Q. How much more than 200,000 dollars do you 8 A. No.
9 think that property should sell for today? 9 Q. How often do you talk to Sonia Powell?
. IO A. I don't know; 10 A. Once in a while. Q
` ll Q. Have you consulted anyone about this ll Q. When was the last time you spoke with Sonia
` 22 question or issue? I2 Powell?
l3 A. No. Q 23 A. Maybe about three weeks ago.
. 14 Q. What do you think the 132-134 Morse { 14 Q. And was that about this case?
2 E5 Street ~— Fm sorry. What do you think the 132-134 15 A. No, not really.
16 Shepard Street property should sell for today? 16 Q. What did you speak to her two or three weeks
e E7 A. I have no idea. E7 ago?
ES Q. Do you have any idea now much value that 18 A. What did we speak about?
i 19 property has lost due to contamination concerns? 19 Q. Yes.
20 A. Neither. 2G A. We talked about the ara and general talk
. 2i Q. You don't know how much you think it`s lost? { 2l about, you know, the area and the cleanup of it and
I 22 A. No. { 22 other personal things.
23 Q. Have you discussed your concerns about the 23 Q. How often do you talk to Murline Wellesley?
24 loss in value of your property with anyone? { 24 A. Quite frequently.
[ 25 A. Pye talked about it with other concerned 25 Q3. More often than Sonia Powell?
37 (Fages 142 to M5)
Brandon Smith Reporting
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