Free Exhibit - District Court of Connecticut - Connecticut

Case 3:03-cv-00945-CFD Document 218-10 Filed 06/29/2007 Page 1 of 4
. . Collins v. Olin Corp.
9/ 14/2005 Donna lee Johnson
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT ·
A ················ l
’ l
CLARENCE R. COLLINS, JR., ET AL ) _ l
V PLAINTIFFS, ) I
) 5
vs. _ ) No. 3-03-94$(cF¤)
)
OLIN CORPORATION AND THE ) l
TOWN OF HAMDEN, )
DEFENDANTS. > I
)
· ........ - ....... )
DEPOSITION OF : DONNA LEE JOHNSON
DATE TAKEN: SEPTEMBER 14, 2005 1
LOCATION; HALLORAN & SAGE ~
` 225 Asylum Street
L Hartford, Connecticut 06103 I
Reporter: KATHLEEN S. NORTON, RPR, LSR #105
BRANDON SMITH REPORTING SERVICE, LLC
44 Capitol Avenue Six Landmark Square
Hartford, CT 06106 Stamford, CT 06901
Tel: (860) 549-1850 (203) 316-85-91 `
Fax; (860) 549-1537 (860) 549-1537
Brandon Smith Reporting
( 990d3445—c9bc-4992-b3f9—b270d6f3c22b


Case 3:03-cv-00945-CFD Document 218-10 Filed 06/29/2007 Page 2 of 4
Collins v. Olin Corp.
9/14/2005 Donna lee Johnson
Page 116 l
2 1 answer. I
2 A Yes.
3 BY MR . FORTNER:
4 Q And gther than a cleanup, an investigation of
5 what the extent of the problem is, and a cleanup that
6 is approved by experts in the area, and public
7 participation in the process, what else are you
8 seeking as a class representative in this case?
9 A Compensation.
10 Q When you say compensation, what do you mean? j
11 A To settle the loss of property value, the
12 loss of being able to use my yard, yeah, my yard, and y
13 emotional stress, myself and my daughter.
14 Q Okay. Let's take those things one at a time.
15 The property value. When you say the loss of property
16 value, is that the loss that you have told us earlier
17 today you believe exists by virtue of the presence of
18 contamination?
19 A Yes.` y
20 Q U And if, in fact, your property is cleaned up,
21 would you agree that there would no longer be any
22 contamination there to cause a loss of property value?
23 A No, I don't think so because of the
24 structural damage to the home.
25 Q And if, in fact, the contamination is cleaned
Brandon Smith Reporting
` . 990d3445-c9bc-4992·b3f9-b270d6f3c22b

Case 3:03-cv-00945-CFD Document 218-10 Filed 06/29/2007 Page 3 of 4
Collins v. Olin Corp.
9/14/2005 Donna lee Johnson
Page ll7 1
1 up and the structural damage is repaired, would that V
1
2 address the property value diminution?
3 A I believe the value would increase again. J
4 Q Now, the lost use. Would you tell us, if you
5 could, what you used your yard for between when you
6 purchased it in December of '92 and when you first 2
7 learned of the possibility of contamination?
8 A The spring and summer months, I would have
9 cookouts for my students, my former students, the
10 school I worked at, which was Hill House High School.
11 My daughter, at that time, was a toddler, so it was a
12 nice place for her to play in the backyard, a happy
13 little pool, my little inflatable pool. My family
14 from Delaware would come up at least once a year and
15 we would have a cookout. And now, when they come up,
16 they just come in the house and we go out to eat.
17 Q Anything else?
18 A No. I just wanted to say during the summer
19 months —— well, during the winter months, I'm grateful
20 that it snows and the more snow it is. Then I feel
_ 21 that the snow will keep the possible contaminants 1
22 down, and when the spring comes and the summer, I have 1
23 a fear that what is coming up now, and therefore, I i
24 take my daughter, I take her traveling, just leave. I
25 try to leave the house weeks on end because I don't
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990d3445-csbc-4992-b3f9-b270u6f3c22b

Case 3:03-cv-00945-CFD Document 218-10 Filed 06/29/2007 Page 4 of 4
Collins v. Olin Corp. I
9/ 14/2005 Donna lee Johnson
Page 178 1
1 CERTIFICATE OF REPORTER
2 .
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 DONNA LEE JOHNSON, on SEPTEMBER 14, p
5 2005, who was by me duly sworn to testify to the truth I
and nothing but the truth; that she was thereupon I
6 carefully examined upon her oath and her examination
reduced to writing under my direction by means of
7 Computer Assisted Transcription, and that this 1
deposition is a true record of the testimony given by
8 the witness.
9
10 I further certify that I am neither attorney nor
counsel for, nor related to, nor employed by any of the
11 parties to the action in which this deposition is taken
and further that I am not a relative or employee of any i
12 attorney or counsel employed by the parties hereto, nor T 4
financially interested in the outcome of the action.
13
14 IN WITNESS THEREOF, I have hereunto set my hand
September 23, 2005.
15
0
16
17
18 Kathleen S. Norton
19
20 Notary Public License No. 00105
My commission expires: 7-31-07
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