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

Case 3:02-cv-01718-RNC Document 99-22 Filed 12/13/2004 Page1 0f2
Plaintiffs’ Local Rule 56(a)1 Statement
Exhibit 20
Extract From Deposition of Philip Kasden
April 25, 2003
page 45, line 1-15

Case 3:02-cv-01718-RNC Document 99-22 Filed 12/13/2004 Page 2 of 2
Schiavone vs Kasden
4/25/2003 Philip Kasden
Page45
1 production areas on a project—to—project basis.
2 Q. And do you know how long he worked for the
3 company?
4 A. I think it was about three years.
5 Q. Do you have any idea which three?
6 A. '78 to '81, I'm guessing. He was with the
7 company at the point of the sale to Michael Schiavone,
8 so it would have been the last three years that I was a
9 shareholder.
10 Q. Did he go to work for Schiavone?
11 A. For a short period of time.
12 Q. Linda Piscatelli.
13 A. She was the controller.
14 Q. For what years?
15 A. 1970 to 1981.
16 Q. Wade Townsend?
17 A. He was a working foreman of the ferrous yard
18 and operated a crane as part of the working component.
19 Q. When you say the ferrous yard, that's to
20 distinguish him from being a metal worker who worked
21 inside of the warehouse?
22 A. That's correct.
23 Q. And so that means that Wade Townsend worked
24 outside generally?
25 A. Correct.
Brandon Smith Reporting Service
¤2a67e9¤-6715—40f9-8¤5a·9ae6a54c¤953