Free Exhibit - District Court of Connecticut - Connecticut

I . Case 3:03-cv-00945-CFD Document 211-16 Filed 05/10/2007 Page1 of4 .
Collins v. Olin Corp.
_, 2-1-2005 Raymond Sims, Sr.
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
-----—---~----—- > ( . L ,
l
CLARENCE R. COLLINS, JR., ) i
ET AL, )
l
PLAINTIFFS l
)
VS. ) NO. 303CV945(CFD)
) I
TOWN OF HAMDEN AND OLIN ) I
CORPORATION, )
DEFENDANTS ) 3
) .
————-————-—----— )
DEPOSITION OF: RAYMOND L. SIMS, SR. I
4 I DATE TAKEN: FEBRUARY 1, 2005
r· m LOCATION: HALLORAN & SAGE
i ‘ 225 ASYLUM AVENUE ,
HARTFORD, CT
Reporter: KATHLEEN S. NORTON, RPR, LSR #105
BRANDON SMITH REPORTING SERVICE, LLC
44 Capitol Avenue
Hartford, CT 06106
Tel: (860) 549-1850 =
F Fax: (860) 549-1537 _,
Brandon Smith Reporting I
925a73d5-54f6-46b9-a925·21ce59f2383b

` Case 3:03-cv-00945-CFD Document 211-16 Filed 05/10/2007 Page 2 of 4
Collins v. Olin Corp.
2-1-2005 Raymond Sims, Sr.
Page 249 A
1 were the results of that test or the monitoring?
2 A It came back negative.
3 Q So there were no problems based on the
4 monitoring; is that correct? Q
5 A As far as I know.
6 Q You also indicated when we were talking about
7 market values of homes, you said there is a lot of g
8 publicity about the area. Do you recall when that 1
9 publicity started? Q
10 A Publicity concerning contamination in the
11 area or ——
12 Q Correct. _ _
13 A No, I don't remember.
14 Q Now, when you talk about publicity about
15 contamination in the area, do you also refer to the
16 middle school contamination?
17 A Well, it specifically talked about the E
18 contamination at the middle school. I didn't know T
19 anything about the other areas because at that time I l
20 hadn't had any report indicating that there were
21 specific contamination on the individual properties.
22 It wasn't until 2001 that they had mentioned about }
23 what might -— well, my particular property had some
24 contamination.
25 Q Do you believe that the contamination at the {
Brandon Smith Reporting I
925a73d5·54f6-46b9-a925-21ce59f2383b `

Case 3:03-cv-00945-CFD Document 211-16 Filed 05/10/2007 Page 3 of 4
Collins v. Olin Corp.
2-1-2005 Raymond Sims, Sr.
Page 250
1 middle school property affects the value of your
2 property?
3 A Everything in the area affects property
4 values. i
5 Q So if there is contamination at the middle
6 school, you believe that affects your property value,
7 correct? {
8 A Not only my property value but the entire l
9 area that I live in. 5
10 Q Okay. Do you own any other property in the
11 Hamden area?
U 12 A No.
T E 13 Q And do you have any plans to move in the next
14 five years?
15 A If I find something suitable that my wife
16 likes. I live —- we have an upstairs and downstairs
17 and it becomes very difficult for her to maneuver up Vx
18 and downstairs now with the use of the dryer, and so 7
19 forth, so it's a possibility. T
20 Q Are you actively looking to move now?
21 A No.
22 Q Have you had any discussions about moving? Z1
23 A With who?
24 Q With your wife. l
l 25 A Yes.
Brandon Smith Reporting _ ·
925a13ds-54f6-46b9-a925-21ce59t2383b _

0 I Case 3:03-cv-00945-CFD Document 211-16 Filed 05/10/2007 Page 4 of 4
Collins v. Olm Corp.
2-1-2005 Raymond Sims, Sr.
Page 264
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 Q
deposition of RAYMOND L. SIMS, SR., on February 1, H
5 2005, who was by me duly sworn to testify to the truth
and nothing but the truth; that he was thereupon
6 carefully examined upon his oath and his examination
reduced to writing under my direction by means of
7 Computer Assisted Transcription, and that this ,
deposition is a true record of the testimony given by »
8 the witness. `
9 is
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
12 attorney or counsel employed by the parties hereto, nor
‘ ‘ financially interested in the outcome of the action.
13
14 IN WITNESS THEREOF, I have hereunto set my hand
February 10, 2005.
15
16 Si--
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17
18 Kathleen S. Norton 2
19 0
20 Notary Public License No. 00105
My commission expires: 7-31-07
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23 l
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Brandon Smith Reporting
925a73d5-54f6-46b9-a925-21ce59f2383b