Free Statement of Material Facts - District Court of Connecticut - Connecticut

Case 3:02-cv-01718-RNC Document 99-28 Filed 12/13/2004 Page1 0f4
Plaintiffs’ Local Rule 56(a)1 Statement
Exhibit 26
Rule 30(b)(6) Deposition of
Northeast Utilities Service Company
page 73, line 22 to page 74, line 4

Case 3:02-cv-01718-RNC Document 99-28 Filed 12/13/2004 Page 2 of 4
WML Schdavone‘vsl§asden
5/13/2003 Nusco (Volume H)
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
Q'·t¢‘%w ’ ' v
JOSEPH A. SCHIAVONE
CORPORATION AND MICHAEL
SCHIAVONE
PLAINTIFFS
VS. No. 302—CV—1718 (RNC)
PHILIP KASDEN, NORTHEAST
UTILITIES SERVICE COMPANY
DEFENDANTS Volume II
I CONTINUED DEPOSITION OF: Rule 30(b)6 DEPOSITION OF
NUSCO
Taken before Kathleen S. Norton,
Registered Professional Reporter, Lic./Reg.
No. 00105, and Notary Public in and for the State of
Connecticut, pursuant to Notice, at the offices of
KOSLOFF & HARDING, 28 North Main Street, West
Hartford, Connecticut, on May 13, 2003, commencing
at 2 : O O p . m .
BRANDON SMITH REPORTING SERVICE, LLC
44 Capitol Avenue
r Hartford, CT 06106
Tel: (860) 549-1850
Fax: (860) 549-1537
Brandon Smith Reporting Service
rosaasm-04rd-4670-8068-saswarszezv

Case 3:02-cv-01718-RNC Document 99-28 Filed 12/13/2004 Page 3 of 4
Schiavone vs Kasden
5/13/2003 Nusco (Volume H)
Page 73
1 that I speak to?
2 A Someone that deals with the sale of scrap
3 material.
4 Q Do you know who that would be?
5 A At the present time, it's Nick Foligno.
6 Q Did you talk to Nick Foligno in advance of
7 coming here today?
8 A I talked to him.
9 Q Did you talk to him in preparation for your
10 appearance here today?
11 A No.
12 Q How long has Nick ——
13 A Foligno; F—O—L—I—G—N—O.
14 Q How long has he worked for Northeast Utilities?
15 A I don't know.
16 Q Do you know which entity at Northeast Utilities
17 he works for?
18 A Right now, he works for purchasing.
19 Q Is purchasing different from CL&P?
20 A I don't know.
21 Q He works for ——
22 A Purchasing is a department.
23 Q Of what company?
24 A Northeast Utilities.
25 Q Northeast Utilities. CL&P is a subsidiary
Brandon Smith Reporting Service
f09d8Gf4-O4fd—4670-8068-5a577af5Z2e27

Case 3:02-cv-01718-RNC Document 99-28 Filed 12/13/2004 Page 4 of 4
Schiavone vsliasden
5/13/2003 Nusco ( Volume H )
Page74
1 company of Northeast Utilities?
2 A Yes.
3 Q Does CL&P have its own Purchasing Department?
4 A No.
5 Q Do any of the subsidiary companies of Northeast
6 Utilities have their own Purchasing Department?
7 A Not that I know of.
8 Q Are you familiar with the structure of
9 Northeast Utilities in the '70's.
10 A It's been awhile.
11 Q Would Northeast Utilities have the same
12 structure with respect to purchasing in the
13 '70's as it does today?
14 A I'm not sure.
15 Q Who is Robert Hale?
16 A I don't know.
17 (Plaintiff's Exhibit No. 51,
18 02000901, marked for
19 identification.)
20 BY MR. HARDING:
21 Q I'm going to show you what has been marked as
22 Exhibit 51. Have you seen this document
23 before?
24 A I don't think so.
25 Q Who is R.L. Hale?
Brandon Smith Reporting Service
fO9d86f4-04fd-4670-8068-5a577af52e27