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

Case 3:02-cv-01718-RNC Document 99-21 Filed 12/13/2004 Page 1 of 2
Plaintiffs’ Local Rule 56(a)1 Statement
Exhibit 19
Extract From Deposition of Philip Kasden
April 25, 2003
page 9, line 3-12

Case 3:02-cv-01718-RNC Document 99-21 Filed 12/13/2004 Page 2 of 2
Schiavone vs Kasden
4/25/2003 Philip Kasden
Page9
1 Q. And with what sort of degree?
2 A. Bachelor of Science in business.
3 Q. And where did you go to work?
4 A. H. Kasden & Sons, Incorporated.
5 Q. Had you worked at H. Kasden & Sons,
6 Incorporated before graduating from college?
7 A. Yes.
8 Q. Summer employment?
9 A. Summer employment, yes.
10 Q. And what year did you go to work for
11 H. Kasden & Sons as a full—time employee?
12 A. I began in June of 1969.
13 Q. And where was H. Kasden & Sons at that time?
14 A. 34 Lloyd Street, New Haven, Connecticut.
15 Q. And what duties did you have with
16 H. Kasden & Sons?
17 A. Ultimately ——
18 Q. In 1969.
19 A. In 1969 some administrative. I mean, it began
20 with a learning curve of understanding the business, but
21 by, I would say, by November of 1969 cold calling sales
22 primarily in the marketing area of purchasing feedstock
23 or scrap metal for the operation.
24 Q. Did you develop any specific customers?
25 A. Yes.
Brandon Smith Reporting Service
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