Free Statement - District Court of Arizona - Arizona

V IN THE UNITED STATES DISTRICT COURT
{NR) R FOR THE DISTRICT OF ARIZONA
l U—HAUL INTERNATIONAL, INC.; U—HAUL )
COMPANY OF PENNSYLVANIA; U—HAUL )
COMPANY OF FLORIDA; and REPUBLIC )
WESTERN INSURANCE COMPANY, )9
)
Plaintiffs, )
)
vs. ) No. CIV—O4—O662
- > PHX—DGC
LUMBERMENS MUTUAL CASUALTY COMPANY,)
) .
Defendant. )
_______________________ .... _________,
LUMBERMENS MUTUAL CASUALTY COMPANY,)
)
Defendant/Counter-Plaintiff,)
)
A A VS - >
1 » REPUBLIC WESTERN INSURANCE CO.; )
U—HAUL INTERNATIONAL, INC.; et al.,)
)
Counter—Defendants. )
___________________________________ )
DEPOSITION OF RICHARD MICHAEL AMOROSO
A- Phoenix, Arizona 1
January 25, 2005
` 9:l4 8..1Tl.
REPORTED BY; K91.fQ)* ..._8;»8;,9· —’-_ ,
PAMELA J. MAYER, RMR- CRR ’ GRIFFI A
Certified Court Reporter ~‘R`i» »¥ 9- I
_ Certificate NO. 50207 · A ,i__ SSQZIATES
’ :· · T court reporters
PREPARED FOR: , i
UNI TED QOURT I H U `P ` 1 _ __; {lloétg Central Avenue
1 I »:·55§?1fF*“*§g@§a§g ‘.‘,’ Ph ‘,A‘ 85012
(Original) Tmzmamw
$$8.529.9990
` F 602.264.2245
case 2;04-cv-00882-Dec D9 W I ’· ·;;;;·» 1 · - 11/21/2005 F’£”é"@g1'f@f2¥°"€'$ °°'"

DEPOSITION OF RICHARD MICHAEL AMOROSO — l-25-05 41
1 A. As I sit here right now, I can‘t think of any
2 instance where that has occurred.
3 Q. Other than the Nelson and Fernandez dispute?
4 A. Correct.
5 Q. Were you involved in any part of the
6 underwriting process leading up to the issuance of
7 policies RG99, RX99, and RU99 for the policy period
8 beginning April 1, '99?
9 A. I don't think so, because I don't think I was at
10 the company when those policies were issued. So I don't
11 think I would have been involved.
12 Q. Okay. Let me ask the same question but in
13 regard to Republic Western policies RGMM, RXMM, and RUMM
I 14 issued for the policy period beginning —— that began
15 April 1, 2000.
16 A. I don't think so, again, I think largely because
17 I didn't start at the company until July of 2000.
18 Q. Other than your attorneys, have you talked with
19 anyone about the underwriting and issuance of policies
20 RG99, RX99, RU99, RGMM, RXMM, and RUMM?
21 A. I may have. I don't recall.
22 Q. Feel free to look at any of those policies,
23 again, they're there, Exhibits 11 through 16.
24 Do those policies represent any sort of
25 insurance program?
Case 2:O4—cv—O06@@®@ 1NDs¤m1U192$1EE"<§¥€&AT|Ei@d J I/26/QQQ5 2 é°@QQ @@04

DEPOSITION OF RICHARD MICHAEL AMOROSO - l-25-O5 75
1 MR. GILL: Was there a question that he didn't
2 answer?
3 (The requested portion was read by the court
4 reporter.)
5 THE WITNESS: I stand by that answer. I've got
6 nothing further to add.
7 Q. BY MR. GILL: Have you had any discussions with
8 Holly Reed regarding this litigation?
9 A. Recent discussions?
1O Q. At any time.
11 A. It's possible. She's no longer with the
12 company. It's possible that prior to her leaving, I had
13 a conversation. I don't specifically recall any as I sit
Il 14 here right now.
15 MR. GILL: Thank you, Mr. Amoroso. No other
16 questions.
17 MR. FRAGNER: Okay.
18 (The deposition was concluded at 11:58 a.m.)
19
2O _________________________________
RICHARD MICHAEL AMOROSO
` 21
22
23
24
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C DEPOSITION OF RICHARD MICHAEL AMOROSO — 1-25-05 76
1 STATE OF ARIZONA )
C ` 2 COUNTY OF MARICOPA )
3 BE IT KNOWN that the foregoing deposition
4 was taken by me pursuant to stipulation of counsel; that
5 I was then and there a Certified Court Reporter in and
6 for the County of Maricopa, State of Arizona, and by
7 virtue thereof authorized to administer an oath; that the
8 witness before testifying was duly sworn by me to testify
9 to the whole truth; that the questions propounded by
10 counsel and the answers of the witness thereto were taken
11 down by me in shorthand and thereafter transcribed into
12 typewriting under my direction; that the foregoing pages
? 13 are a full, true and accurate transcript of all
if 14 proceedings and testimony had and adduced upon the taking
15 of said deposition, all to the best of my skill and
16 ability.
17 I FURTHER CERTIFY that I am in no way
18 related to nor employed by any parties hereto nor am I in
19 any way interested in the outcome hereof. h ?$
20 DATED at Phoenix, Arizona, this£ijC_ day of
2 1 , 2 0 0 5
22 { fl W

24 _P nf *5*Ji- M-_{ ____
0 g] Certified Co »Reporter
` 25 Certificate No. 50207
case 2:04-cv-0000§»®I;E‘;FI1E>060¥QerA5`1>$@§IA?E& 1·1/2<1¢2Q>0$ 2|=%¤?4?&Q1

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