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

Case 3:02-cv-01718-RNC Document 99-25 Filed 12/13/2004 Page1 0f2
Plaintiffs’ Local Rule 56(a)1 Statement
Exhibit 23
Extract From Deposition of Philip Kasden
April 25, 2003
page 30, line 5-23

Case 3:02-cv-01718-RNC Document 99-25 Filed 12/13/2004 Page 2 of 2
Schiavone vs Kasden
4/25/2003 Philip Kasden
Page30
1 and '80s it would still have to be segregated from the
2 steel.
3 Q. Was there a place in the yard that transformer
4 recovery was done?
5 A. Yeah, there was. That's been the $64
6 question. I've been trying to think of where that was.
7 I would say probably best guess would have been behind
8 the main building probably off towards the area near the
9 shear.
10 Q. How about drawing a circle and just labeling
11 it with —— that's really an estimate; correct?
12 A. Correct.
13 Q. Why don't you put a question mark after that.
14 A. (Witness indicates.)
15 Q. Do you ever recall seeing Kasden employees
16 break open any transformers?
17 A. I don‘t.
18 Q. Do you know who the transformer accounts were?
19 A. When 1 was there the only transformers that ——
20 the only place the transformers came from were a utility
21 company, and the only utility company that we were
22 dealing with at the time was Northeast Utilities.
23 Q. Did you have any responsibility for that
24 account?
25 A. I did but not in the transformer area.
Brandon Smith Reporcing Service
¤2a67e9¤-6715-40fe-Bdsa-Qaceasacusss