Free Brief in Opposition to Motion - District Court of Colorado - Colorado

Case 1:03-cv-02435-PSF-PAC

Document 268-6

Filed 09/29/2006

Page 1 of 2

PROCEEDINGS MR. JOHNSON: It's now 9:27, according to my clock. And Mrs. Sandle and her attorneys arrived here at about 9:24, but Mrs. Sandle wanted a few minutes to relax before we started. LILLIAN F. SANDLE, the Plaintiff herein, having been first duly sworn, was examined and testified on her oath as follows: EXAMINATION BY MR. JOHNSON: Q Mrs. Sandle, my name is -- well, before we go into that, could you please state your name and spell your last name for .the record. A My name is Lillian Faye Sandle. That's L-i-1-1-i-a-n; Faye, F-a-ye; Sandle, S-a-n-d-1-e. Q Mrs. Sandle, my name is Michael Johnson. We've met before in this case. I represent the -- the government in this case, the defendants. And this is -this is -- at this point, this remains the consolidated case. Do you understand that you're here today to give formal testimony regarding the claims and issues and causes of actions that you raised in your second amended complaint in this case? And that's the case Civil Action 03-CV-2435 and Civil Action 04-CV-0639.

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Case 1:03-cv-02435-PSF-PAC

Document 268-6

Filed 09/29/2006

Page 2 of 2

286

Q (By Ms. Pietsch) You can answer. A My -- my back -- I continued to have episodes of back injury up through '91. Q And when you injured your back in 1987, did that in any way affect your ability to perform manual tasks? A No, it did not. Q And when you reinjured your back in 1989, did that in any way affect your ability to do manual tasks? A No. I could use my hands.

Q Were there any manual tasks that your back injury affected? A No. I could -- I could use my hands, as I say, sitting at the desk and doing what I needed to do there, and to get up and walk and go get supplies and come back, but no heavy lifhng. Q Were there any other major life activities that you feel your back injury affected? A As I said, I could not go to church as often. I could not work in the community. I was always active in the community. I couldn't - I really couldn't travel much without coming home and having a spell with my back. And so I usually would catch the bus and go to Texas, but I'd come home and spend time in the bed, or I'd go to the hospital and get my shots.