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

Case 3:02-cv-01718-RNC Document 99-27 Filed 12/13/2004 Page1 0f2
Plaintiffs’ Local Rule 56(a)l Statement
Exhibit 25
Extract From Deposition of Charles Sterling
April 23, 2003
page 55, line 21-24

Case 3:02-cv-01718-RNC Document 99-27 Filed 12/13/2004 Page 2 of 2
Schiavone vs. Kasden et al
4/23/2003 Charles; Sterling
Page55
1 purchase and in what manner did they store them on site,
2 recycle on site, reclaim, whatever?
3 A. It was basically a scrap yard that handled
4 nonferrous and ferrous scrap, iron and steel scrap.
5 Nonferrous scrap being copper and aluminum and etc.
6 Specifically, whatever could be recycled or resold back
7 into the industry.
8 Q. Are you able to quantify at all a percentage
9 of the scrap business that was associated with
10 purchasing transformers?
11 A. Not really. When you say quantify, do you
12 mean one percent?
13 Q. One percent, fifty percent, ten percent.
14 A. Of total business?
15 Q. Yeah.
16 A. One percent.
17 Q. Very small then?
18 A. Insofar as the total revenues of business was
19 concerned, somewhere between one percent. Maybe higher
20 than that. At this point, 1 have no recollection.
21 Q. To the best of your recollection, 1 think you
22 testified earlier that the only transformers that Kasden
23 purchased were from Northeast Utilities or CL&P?
24 A. To the best of my knowledge.
25 Q. Do you recall whether they ever tried to
Brandon Smith Reporting Service
¤e4ecc13e-user-4e16--beee-feteiceseezc