Free Exhibit - District Court of Connecticut - Connecticut

Case 3:03-cv-00945-CFD Document 218-16 Filed 06/29/2007 Page1 of 3
Collins v. Olin Corp.
2-1-2005 I Ellecia Sims
STATE OF CONNECTICUT J,_ fn? K, .;,: ,% ,?
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·———-——— — ------- )
)
CLARENCE R. COLLINS, JR., ET AL )JUDICIAL DISTRICT OF
PLAINTIFFS )
)
VS. ) CASE NO. 303945(CFD)
) (
OLIN CORPORATION AND THE )
TOWN OF HAMDEN, )
DEFENDANTS )
)
·—————--- - ---·-- )
DEPOSITION OF: ELLECIA SIMS
DATE TAKEN: FEBRUARY 1, 2005
LOCATION: HALLORAN & SAGE
225 Asylum Street
Hartford, Connecticut 06103
Reporter: KATHLEEN S. NORTON, RPR, LSR #105
BRANDON SMITH REPORTING SERVICE, LLC
44 Capitol Avenue
Hartford, CT 06106
Tel: (860) 549-1850
Fax: (860) 549-1537
Brandon Smith Reporting
dc71 3bca-5232-40e4-a403·a2f7a41 3ce84

Case 3:03-cv-00945-CFD Document 218-16 Filed 06/29/2007 Page 2 of 3
Collins v. Olin Corp. 2
2-1-2005 Ellecia Sims
Page 97
1 talking about, then the waking up at night and the
2 difficulty sleeping?
· 1
3 A Yes.
4 Q Again, if your yard was remediated in 1
A 5 accordance with proper, expert approved methodology,
6 and the situations down the street that you have
7 talked about, the facilities down the street were
8 taken care of, would you no longer have that stress l
9 and worry about it?
10 A Yes.
11 Q Okay. The last item you talked about, and,
12 again, we'll come back to the monetary one in a
13 moment, the last item that you talked about was
14 knowing that you could use the facilities down the
15 street.
16 A Yes.
17 Q What facilities are you referring to?
18 A Being able to take the children down to the
19 small play yard that‘s down the street.
20 Q At this time do you believe that you cannot
21 take the children down there? 2
22 A Yes.
23 Q Why? .
24 A Because they said there's contamination down
25 there in the sand and everything and I'm just afraid
Brandon Smith Reporting
dc713bca-5232-40e4·a403-a2t7a413ce84

Case 3:03-cv-00945-CFD Document 218-16 Filed 06/29/2007 Page 3 of 3
A ` Collins v. Olin Corp.
2-1 -2005 El1eciavSims
Page 127 y
1 CERTIFICATE OF REPORTER
2
. _ _ l
3 I, Kathleen S. Norton, a Registered Professional
Reporter/Commissioner within and for the State of
4 Connecticut, do hereby certify that I took the
deposition of ELLECIA SIMS, on February 1, 2005, who
5 was by me duly sworn to testify to the truth and
I nothing but the truth; that she was thereupon carefully
V 6 examined upon her oath and her examination reduced to
writing under my direction by means of Computer
7 Assisted Transcription, and that this deposition is a
true record of the testimony given by the witness.
8
` 9 I further certify that I am neither attorney nor
counsel for, nor related to, nor employed by any of the
10 parties to the action in which this deposition is taken
and further that I am not a relative or employee of any
11 attorney or counsel employed by the parties hereto, nor
financially interested in the outcome of the action.
12
13 IN WITNESS THEREOF, I have hereunto set my hand
February 14, 2005.
14
15 I i
ig Aww LJ3/gmiq
16
17 Kathleen S. Norton
18
19 Notary Public License No. 00105
My commission expires; 7-31-07
20
21
22
23
24 l
25
Brandon Smith Reporting
dc713bca-5232-40e4·a403-a2t7a413ce84