Free Exhibit - District Court of Connecticut - Connecticut

V. Case 3:03-cv-00945-CFD Document 211-14 A Filed 05/10/2007 Page 1 of 4 ‘
-- _ - Collins v. Olin Corp. . .
jg i'‘‘·· 12-16-2004 . ‘ Elias Rochester A
‘ » ‘ . I 1
yi Page —l
UNITED STATES DISTRICT COURT A
DISTRICT OF CONNECTICUT
. ) . - _· Qi
_ CLARENCE R. COLLINS, JR., ET AL,)A
Plaintiffs )
‘ ) CIVIL ACTION NO: A
VS- . ) 303CV945 (CFD)
) .. _
OLIN CORPORATION, ET AL, ) A _ I j
Defendants ) _ y
) .
Deposition of ELIAS ROCHESTER, taken before
. Judith L. Kline, Certified Shorthand Reporter/Notary . “
gg Public in and for the State of Connecticut, pursuant
_£§, to notice, at the law offices of Halloran & Sage, LLP, . .
*f%Q . One Goodwin Square, 225 Asylum Street, Hartford, 4
rqi ‘ Connecticut, on December 16, 2004 at approximately _ Q
U 9:40 &.m. ·
APPEARANCES: — A A `
FOR THE PLAINTIFF: ’
BRAD J. MITCHELL, ESQUIRE V .
THORNTON & NAUMES, LLP .
A 100 Summer Street, 30th Floor . " q
Boston, MA 02110 A · *
(617) 720-1333 -— . I
A FOR THE DEFENDANT, OLIN CORPORATION: A
JOEL B. SAMSON, ESQUIRE
t HUSCH & EPPENBERGER, LLC . ·
190 Carondelet Plaza, Suite 600
A St. Louis, MO 63105-3441
(314) 480-1500 · _
FOR THE DEFENDANT, TOWN OF HAMDEN; l
L ANN CATINO, ESQUIRE ·
W%n THOMAS C. BLATCHLEY, ESQUIRE ’
.q§A’ HALLORAN & SAGE, LLP
`A? One Goodwin Square
· I Hartford, CT 06103 _ _
Brandon Smith Reporting A
A a2a290df-2e2d-44f4-840a-72bb29faa8f7

Case 3:Cl3-cv-00245-CFD Document 211-14 Filed 05/1 O/20(j7 Page 2 of 4 k
Q Collins v. Olm Corp. ‘ ‘ .
l2g16-2004 2 ` - Elias Rochester ·
Page 60 · · - . t Qi- _
E 1 A It happened —- it was last summer, was it? It 3 A
: 2 was last summer. Q Q - E
L 3 Q QSo you_believe it was the summer of 2OQ3?_ E A _ S
2`4 Q QA _ Yeah. ’ Q l p
J5 Q Do yOu know if there was news coverage of this i
6 before the summer of ZQQ3? _ A _Q , Q . f
7 ,1_A gbl don't recall1 _- l _; Q
2gB Q Do you watch the news? Q - l ` Q . 2
9 V A Sometimes. J Q 2
A10 Q . Do you watch any specific channels? Q ?¤
11 A Just ABC Nightly News sometimes, A
A 12 Q Do you watch local news coverage? 2.1R
l 13 l A Not really. l JT t
` 14 Q- Have you in the past ever watched local news . .
15 coverage? - :
o16 Q A Yeah. - Q Q _
2 17 Q Do you believe there has been a diminution in . Q
i-18 the value of your property? -V..1 - . 2 Y
2 19 A Yes, I think so. - . . R
‘ 20 Q And can you tell me why you think there has -
n' 21 been a diminution in the value of your property?
2 22 U A Well, whatls going on over at the school- 2. Q _ i
‘ 23 Q So it's whatls happening at the school that_ Q
U 24 concerns you? y·U ._e. U U _ Lx
` 25 A Yeah. . - . Q 1 lis?
Q Brandon Smith Reporting l I
.. 4 l . _ a2a290df-2e2d·44f4-$40a-72bb29faa8f7 ‘

» .. Case 3:03-cv-00945-CFD Document 211-14 Filed 05/10/2007 Page 3 of 4
_ V p Collins v. Olin Corp. . _
12-16»2004 · Elias Rochester `
if · I Page ol ‘
Q1 Q What's happening at the school?_
l 2 A A Well, they said there's contamination over
3 there. ~ ‘ l . l
U 4 Q When did you become aware that there was · I 3 S
5 contamination at the school? ‘
`6 A .About two years, probably. V
3 7 I Q yTwo years ago? U I i _ Q
8 A Yeah. Like two years. * A _ . Y
9 Q_ Is that when you became concerned? · ’
10 A Yeah.
A 11 Q 3Did you become concerned prior to purchasing
gy? 12 your house? U -
ixi · 13 A Yeah. It was on my mind, yeah. l
14 Q What were your concerns? ·
15 A If they're going to ask anybody —— like if
16 they're really going to relocate everybody. I didn't ._
17 know how bad the contamination was —— you know, how - -
18 severe it was, those kind of things. _ t _
19 Q Did you have concerns there was contamination 1
20 on your property? ` · A
* Q 21 A Yeah, yeah. , 1i‘
22 Q And this was prior to purchasing the house? » *
23 _ A Yeah. Because my parents knew about it, yeah. _ ’
_ 3 24 Q Do you know when your parents learned about
si 1 25 concerns about contamination at your property?‘
Brandon Smith Reporting `
` I ·‘ ~ - a2a290df-2e2d-44f4-840a-72bb29faa8f7

Case 3:03-cv-00945-CFD Docugen-TC21 1-14 · Filed 05/10/2007 Page 4 of 4 i ’
. - _ _ Colhns v. hn orp. _ . _ .
12-16-2004 I ‘ - Elias Rochester 1 e
Page 162 ‘ _ _-_-1
1 " in V ‘ STATE OF CONNECTICUT ‘ I Q
g it- _V I, Judith L. Kline, a Notary Public duly E `
3 commissioned and qualified in and for the State of _ Q .
Connecticut, do hereby certify that pursuant to notice 1 -
4 there came before me on the 16th day of December, 2004 i {
the following named person, to wit: ELIAS ROCHESTER, 2 1 H
5 who was by me duly sworn to testify to the truth and 3
nothing but the truth; that he was thereupon carefully 1
6 examined upon his oath and his examination reduced to . j ’
I print under my supervision; that this deposition is a j
7 true record of the testimony given by the witness. '·`
V 8 I further certify that I am neither I i
attorney nor counsel for, not related to, nor employed Q Q
9 by any of the parties to the action in which this _ I Q
_ deposition was taken. And further that I am not a ‘
10 relative or employee of any_attorney or counsel I
employed by the parties hereto, or financially V
11 interested in this action. I
12 IN WITNESS THEREOF, I have hereunto set my tow
hand and affixed my seal this 23rd day of December, ,g_€ '
I 13 2004. .
Q 14 . I
015 -
. 1
:16 C.§Zq€` Qi?7/éQ;4LL.._ U I
. 17
A 18 n ~ *1
i' n 19 - . H
I Judith L. Kline, CSR No. 014
20 o Court Reporter/Notary Public
Connecticut License No. 00090
~ 21 I .
22 _ r
My Commission Expires: I
23 November 30, 2006
24 _
Brandon Smith Reporting _ "
i a2a290df-2e2d·44f4-840a-'I2bb29faa8t7 `