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

Case 3:02-cv-01718-RNC Document 99-24 Filed 12/13/2004 Page1 013
Plaintiffs’ Local Rule 56(a)1 Statement
Exhibit 22
Extract From Deposition of Philip Kasden
April 25, 2003
page 28, line 5 to page 29, line 22

Case 3:02-cv-01718-RNC Document 99-24 Filed 12/13/2004 Page 2 of 3
Schiavone vs Kasden
4/25/2003 Philip Kasden
Page 28
1 A. Just about here.
2 Q. Would you please write scale there just so
3 we'll be able to identify it later on.
4 A. (Witness indicates.)
5 Q. Did there come a time when H. Kasden & Sons
6 began a copper recovery operation with respect to
7 recovering copper from transformers?
8 A. I'm not sure I would expect that it was
9 probably —— I mean, to the degree that the feedstock was
10 available, I expect it was always part of the process
11 from the time that the company was created.
12 Q. What do you mean to the extent that the
13 feedstock was available; can you describe that for me
14 what you mean by that?
15 A. Sure. Well, feedstock comes from different
16 sources. I would imagine at some point probably back in
17 the '30s that there was some processing of, you know, of
18 transformer, copper wire stock, that was brought in
19 depending on what companies the Kasden's were doing
20 business with at the time.
21 Q. The principal interest in the transformer is
22 the copper core; is it not?
23 A. Correct.
24 Q. And so Kasden would have split open
25 transformers and recovered the copper?
Brandon Smith Reporting Service
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Case 3:02-cv-01718-RNC Document 99-24 Filed 12/13/2004 Page 3 of 3
Schuav0ne‘vs}Casden
4/25/2003 Philip Kasden
Page29
1 A. Correct.
2 Q. And what would they have done with the casing
3 to the transformer?
4 A. Well, the casing is silicon steel —— you mean
5 the steel part?
6 Q. Yes.
7 A. It probably was —— I'm not sure what the steel
8 mill specifications were at the time, but it was
9 probably cut to steel mill specification size.
10 Q. And sold to a steel mill?
11 A. Correct.
12 Q. Just as the copper that was recovered was sold
13 to a copper smelter?
14 A. Right. And I believe the silicon steel went
15 to a different —— it was segregated from the fabricated
16 steel that the can was made of.
17 Q. Would there have been ceramics involved with
18 transformers as well?
19 A. Yeah, I guess. Sure.
20 Q. Would H. Kasden & Sons recover the ceramics as
21 well?
22 A. It wouldn't be recovered, but I guess it would
23 have to be —— would have to be segregated from the
24 steel. I mean, today a steel mill wouldn't take product
25 with ceramic on it, so I can imagine that in the '70s
Brandon Smith Reponing Service
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