Document 2qgeEEXKekQmBmMypRLbO9zv6
STATE OF ALABAMA IN THE CIRCUIT COURT FOR ETOWAH (Transferred from Calhoun County,
COUNTY Alabama)
SABRINA ABERNATHY, et al.,
Plaintiffs, ve rsus MONSANTO COMPANY, et al..
CIVIL ACTION NO. CV-2001-832
(Consolidated)
De f endant s.
/
DEPOSITION OF EDWARD LAMAR MASON
The deposition of EDWARD LAMAR MASON was taken before Deborah Salers Garrett, Certified Shorthand Reporter, Registered Professional Reporter, as Commissioner, commencing at 9:00 a.m. on January 2, 2002, by the Plaintiffs, at the law offices of Fite & Miller, Suite 400, SouthTrust Bank Building, Anniston, Alabama, pursuant to the stipulations set forth herein.
Regional Reporting Service, Inc.
755 Walnut Street
Gadsden, Alabama
35901-0755
HARTOLDMON0032022
2
1 APPEARANCES
2 For the Plaintiffs:
3 HARRISON COLEMAN, Esq. KASOWITZ, BENSON, TORRES & FRIEDMAN
4 1301 Avenue of the Americas New York, New York 10019
5
6 For the De f endant s:
7 EDWARD M. NEWSOM, Esq. SMITH, HELMS, MULLIS & MOORE
8 1355 Peachtree Street, NE, Suite 750 Atlanta, Georgia 30309
9 INDEX
10
1 1 Page
12 Stipulations
3
13 Reporter's Certificate
42
14
1 5 EXAMINATIONS
16 Witness: EDWARD LAMAR MASON
Page
1 7 By Mr. Coleman
4
18
19 No exhibits were marked for identification, offered or attached as exhibits hereto.
20
21
22
23
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1 STIPULATIONS 2 IT IS STIPULATED AND AGREED by the 3 parties, through their respective counsel, 4 that the deposition of EDWARD LAMAR MASON may 5 be taken before Deborah Salers Garrett, CSR, 6 RPR, as Commissioner and Notary Public, 7 Alabama at Large, at Birmingham, Alabama, on 8 January 2, 2002, at 9:00 a.m. 9 IT IS STIPULATED AND AGREED that the 1 0 signature to and reading of the deposition by 1 1 the witness is waived, the deposition to have 1 2 the same force and effect as if full 1 3 compliance were had with all laws and rules of 14 Court relating to the taking of depositions. 1 5 IT IS STIPULATED AND AGREED that it 1 6 shall not be necessary for any objections to 1 7 be made by counsel to any questions except as 1 8 to form or leading questions and that counsel 1 9 may make objections and assign ground at the 2 0 time of trial or at the time said deposition 2 1 is offered in evidence or prior thereto. 2 2 IT IS STIPULATED AND AGREED that notice 2 3 of filing by the Commissioner is waived.
REGIONAL REPORTING SERVICE, INC.
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1 STATE OF ALABAMA, ANNISTON. JANUARY 2, 2002
2
3 EDWARD LAMAR MASON.
4 after having been first duly sworn, was
5 examined and testified as follows:
6
7 EXAMINATION
8 BY MR. COLEMAN:
9 Q.
Mr. Mason, we have just been introduced.
1 0 For the record my name is Harrison
1 1 Coleman, and I represent the plaintiffs
1 2 in this case. This will be your
13
deposition taken pursuant to notice.
I
14 just want to kind of go through some
1 5 grounds rules of deposition taking.
1 6 Have you taken a deposition before?
1 7 A.
Yes.
1 8 Q.
Then you know that we are going to need
1 9 you to give a verbal response to the
2 0 questions that I ask, which means yes or
2 1 no, and just try to avoid any uh-huh or
2 2 uh-uh because she has to take down
2 3 everything we say.
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I don't foresee this taking all
that long, but if you need to take a
break at any time, just let me know, and
we'll go off the record.
If you need to
ask your attorney anything in private,
we will take a break for that too.
Let's start the deposition with
your full name, please, sir.
Edward Lamar Mason.
Where do you live now?
1102 Lakemont Drive North, Southside.
In Annis t on ?
Alabama.
How long have you lived there?
Thirty-four years.
When did you start working for Monsanto?
June of 1963.
So thirty-four years -- You have lived
there since 1966, I guess?
'67.
Between 1963 and 1967 where did you
live?
A couple of places. I lived out at
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Wellington for a while when I first got out of service. Then I lived up here at Maplewood Avenue for a couple of years. Then I moved out to Saks for six months. When you moved into the house you currently live in in 1967, were you married at the time? Yes . Areyou married now? Yes. How many children do you have? Two. What are their names?
THE WITNESS: Do I need to tell him? Does he have to have all that information?
MR. NEWSOM: He is entitled to get into a little about your background, particularly for instance if they were living in the area and might be on a jury, for instance. Nobody is going to contact them.
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My son's name is Kevin, and my daughter's name is Deanna. They lived in Anniston? Yes. They were small children when we lived down here. Do they live here now? No . Do they live in Gadsden by any chance? My daughter lives in Southside. Is she married? Yes. What is her last name? Barfield. Okay. What's your understanding as to your role as a witness or a deponent today?
MR. NEWSOM: Object to the form. You may go ahead.
I don't understand what you are getting at . Why are you here today? Just to give a deposition about this case.
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Okay. Are you retired?
Yes.
When did you retire?
1 9 9 6.
Okay. I'd like to get into a little bit
of your job history at Monsanto.
I'm
going to ask you if you will, starting
in June of 1963 through to your
retirement in 1996, if you will just go
through the job titles that you held at
Monsanto and the particular departments
that you were in for that time period.
I hired into the plant in'63 as
an
operator in the Aroclor department.
In
1970 -- '69, I went into maintenance for
a little while in '69 as an electrician.
I went back to operation in the Aroclor
for three or four months and then back
to maintenance as an electrician.
In the '72 or '73 time frame,
somewhere in that area -- No, it wasn't
either.
Let me back up.
It would have
been about '78, really, I think. In
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1978 I took a job as a foreman in the
electrical group.
I stayed as a
foreman, what they call a foreman
until -- what was the time frame with
the -- y'all probably already know the
answer to it -- when the big shutdown of
the other department over there, '88?
MR. NEWSOM:
'86? I'm not sure.
The '86 or '87 time frame, when all that
cutback went through, they made us first
level supervisors. And I remained as a
supervisor until just about a year or
two prior to my retirement, when they
made me a planner and schedular at my
request, really. That's basically it.
Okay. Beginning in 1963 when you were
hired in as an operator in the Aroclor
department through to about 1972 or '73,
besides this small stint in the
maintenance department, were you an
operator?
I was an operator.
Okay. And who were your supervisors at
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the time, during that time?
When I was hired in Burns Severson was a
supervisor, he and a gentleman named
Jack Maloy.
What was the first gentleman's name?
Burns Severson. That was supervisor.
Okay. During that entire period, that
ten or so years?
No, no.
There were some others.
I'd
really have to stretch to remember
names.
If you happen to remember them during
this deposition, if you will, just let
me know what those are.
Describe if you will -- and I know
this may be hard for you to remember,
but if you can, describe sort of your
daily responsibilities as an operator
during that period of time.
Well, the responsibility was just to run
the process equipment, making the
product that we made, the Aroclor.
And were you working inside or outside?
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Both.
What was going on outside?
Well, that is where your process
equipment was, some of it.
Some of it
was inside, but when I first started
what I was running was outside.
What equipment was that?
Chlorinators.
How do chlorinators work?
Well, it was just a tall tank that you
put biphenyl in and had a chlorine line
running to it and a cooling coil in it.
You put a certain amount of charge in
that vessel and open the chlorine up to
it and put chlorine up through it until
it was finished.
Did you then take samples for quality
purpo s e s ?
Yes, yes.
And where were the samples processed?
In the control room.
Were you responsible for running any
tests in the control room?
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Yes. We ran what we call specific
gravity.
And the specific gravity test was mainly
a quality control test?
Correct.
During that time period of 1963 to the
early '70s when you were an operator,
what was your role if and when there
were any chemical spills?
If it was in my area, if you had one,
you cleaned it up.
How was that accomplished?
Well, it would depend on what the
material was.
If it was something like
biphenyl, it solidified when it touched
the ground. And you just broke it up,
shovel it up, and put it back in the
drum and reprocess it.
What safety gear did you wear at that
t ime ?
We had gloves, safety glasses, hard
hats, steel-toed shoes, long sleeve
shirts.
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Did you launder your long sleeve shirts
yourseIf?
No .
Was that done at the plant?
The company took care of the laundry.
How about pants or trousers?
Well, had trousers, long trousers.
And were those laundered at the plant
also?
Yes.
How about any breathing apparatus?
There was breathing apparatus there.
We
each got air packs and gas masks for
emergency purposes.
You mentioned just then emergency
purposes. What are you talking about?
Well, they were there in case we had
some type of emergency. Might have had
a chlorine leak or something That was
the real danger there, was chlorine.
Did you ever witness a chlorine leak
like the one you are talking about?
Yeah. We -- I saw a chlorine leak or
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two but never had one enough that I had
to don an air pack or a gas mask to deal
with it.
What other situations besides the
emergency situations were you required
to wear some sort of breathing apparatus
if at all?
I didn't wear any unless something like
that happened.
Did you -- Did you have any
responsibility for cleaning out any of
the tanks?
I 'm t rying - -
MR. NEWSOM: We are talking about
this same general '63 to '72
time frame?
MR. COLEMAN: Yes.
I really, to be honest with you, don't
remember cleaning out any of the tanks.
Okay. Was that more a job for
maintenance?
Yeah.
If they had to have went out -
If they had to go in them for some
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reason or another, a coil have a hole in
it or something, cooling coil or
something, have to go in and repair
that, have to clean it out.
I don't
really remember any specific times to do
that .
Okay. And so besides cleanup, did you
have any other reason to go into the
tanks, you personally?
No .
Did you have any direct responsibility
for the health and safety of others in
your role as operator, or were you
primarily responsible for your own
health and safety?
Primarily responsible for my own safety.
Okay. Did you ever receive any
reprimand by your bosses for not
adhering to company policy on health and
safety?
I don't think so.
Okay.
I don't remember
it.
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Do you remember if - strike that.
Did you participate in a j ob
interview in 1963 when you were first
hired?
Yes.
Were you told anything during that job
interview about the health and safety
aspects of working around PCBs?
To be honest with you, I don't remember
whether I was or not.
And that's - -
Like I say, I'm being honest with you.
That was thirty, maybe forty years ago.
Right.
I'm going to ask you some
questions that are related back to this
long period of time.
If you don't
remember, it's okay too. Just to the
best of your ability, you need to come
up with the truthful answer.
Did you parties meet in any
meetings with Monsanto management
related to health and safety during that
period of time?
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Yes.
How frequent were those meetings?
We had safety meetings probably once a
month.
Probably more often than that.
MR. NEWSOM: Again, are we talking
about the same -
MR. COLEMAN: Yes.
MR. NEWSOM: Just so we
understand.
Do you remember the subject of those
meetings? It is a long time ago?
A lot of subjects in those safety
meetings. They covered a lot of things.
Do you remember if there were any
minutes of those meetings taken and
circulated?
I don't remember. There may have been.
I don't remember.
Do you remember during that time period
whether or not -- if there was any
discussion of PCBs or biphenyl and the
safety and health aspects of those
chemicals, working around those
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chemicals? I don't remember. There probably was, may have been. But I don't remember specifically. Do you remember reading any literature whatsoever on PCBs and the health and safety aspects of working around PCBs during that time period? No . Was there a lunchroom available in the Aroclor department? We had a lunch facility in our control room. Okay. Was it separate and apart from where you were taking the samples? It was on one -- on the other end of the room . Is that where the entire Aroclor department took their meals? Yes. Was it company policy that you eat in that area? That was the area that was provided to
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us .
You talked about some spills a little
whi1e ago.
I think you said that if
biphenyl spilled, it immediately
solidified and you then put it in drums
and then it was reused.
(Witness nods head affirmatively.)
MR. NEWSOM: You need to say yes.
Yes.
I'm sorry.
Yes.
What happened to the biphenyl that you
-- that wasn't reprocessed, if at all?
And there had to have been -- so a time
when you couldn't keep up -
Well, pretty much all of the biphenyl is
reprocessed.
Pretty much all of that
was reprocessed due to the nature of it.
You said it solidified after it hit the
ground, after it spills?
Yes.
Kind of like pouring something out
on the table and just breaking it up in
pieces and scooping it up and reusing
it .
And back to the subject of safety and
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health, were you ever shown any material
safety data sheets on the products or
chemicals that you were working around?
Yes.
Did you happen to save any of those?
What do you mean by that?
You said earlier you don't have any
documents or such in your possession.
No.
I didn't save any of that stuff for
my own personal use. Material safety
data sheets were company property and
were kept in books in the control room.
Okay. After the early '70s you said
that you -- I have actually a little gap
here. You said in 1978 you became a
foreman in the electrical group.
Correct.
There is a time period in the early
'70s, between the early ' 70s and 1978 that _ _
I was an electrician in maintenance.
Were your responsibilities plant-wide or
just the Aroclor department?
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Plant-wide. What would be your daily responsibilities particularly with regard to the Aroclor department in your role as an electrician? Just maintaining electrical equipment, everything from a light bulb going out to a motor burning up, whatever it might have been. And were you issued the same safety gear that you had as an operator in the Aroclor department? Yes. That includes gloves and safety goggles and steel-toed boots? Yes. And the long sleeve shirt and trousers? Yes. Did you ever have occasion during that period of time in your role as an electrician to use any breathing apparatus ? I don't think so.
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Are you aware of any landfills on the Monsanto property? I'm aware that they had one across the highway there, on the side of the hill. Did you have any job responsibilities of the landfill? No . Since your retirement have you attended any meetings sponsored by Monsanto regarding PCBs? I attend a retiree breakfast that they have a couple of times a year, the Quarter Century Club banquets. Since your retirement in '96 how many of these retiree breakfasts have you attended? I'd say they have two or three of them a year. They are in February or so and the other one in December, something like that. Do you know if there are minutes of those meetings kept? No, I don't know that.
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Who usually runs those meetings?
The plant manager.
Who is that now?
David Cain I guess. Ain't he the plant
manager now?
I'm not sure. Has he been the plant
manager since '96?
No.
I can't even think of his name.
S o r ry.
That's okay.
If you remember during the
deposition, let me know.
And at those retiree breakfasts,
what has been told to you about this
litigation?
Nothing has been told to us about the
litigation.
Have you talked about any other lawsuits
that are going on, Monsanto lawsuits?
When you talk about litigation and
lawsuits, we know the lawsuits are going
on .
How do you know that?
They told us they are going on, but they
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don't discuss those lawsuits with us.
Have you had your blood tested for PCBs?
Yes.
What were the results of those tests?
I don 't remembe r, but it wasn't very
much, I don't think.
Do you know who the doctor was that took
that?
Dr. Gehi .
How do you spell his name?
G-e-h-i.
When was that taken?
I can't remember.
It's been several
years ago now.
It has been since I
retired.
Have you only had one test?
Yes.
I forgot to ask this question earlier,
but how far would you say your house is,
the one you live in now and the one
you've lived in for thirty-four years,
how close is it to the plant?
Twenty-seven, twenty-eight miles.
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Do you have any knowledge of meetings
sponsored by or attended by any Monsanto
personnel with the residents of west
Annis t on ?
No .
Do you know anyone who is a plaintiff in
the lawsuits against Monsanto?
MR. NEWSOM: Let me just -- It is
not a real objection but a
clarification. He may know
them and not know they are
plaintiffs. You are just
asking the ones he knows and
knows they are -
I don't know of anybody personally who
are plaintiffs in the case. Again,
there may be some that I know, but I
don't know it.
Sure.
I just need to know if you know
it now.
Have you ever attended any meeting
sponsored by Monsanto about the health
and safety effects -- or the health and
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safety with regard to your use of PCBs
as an operator?
MR. NEWSOM: Let me just object to
the form.
I think he
testified earlier there were
monthly meetings that
probably did or may have
included PCBs.
I don't know
if this is different from
that. He may not realize -
Having already testified to
that, he may think you are
asking something else.
Specifically, do you remember attending
any meetings where PCBs and the health
and safety of those products was
discussed?
Let me expound a little bit. We had
safety meetings, and everything was
talked about in those safety meetings to
wearing Scott air packs to steel-toed
shoes to safety on the job dealing with
the products, et cetera, et cetera.
And
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during your everyday work, you were
continuously in discussion about what is
going on with the job.
So if you are
talking about meetings, depends on what
you call meetings. You could say there
was one every day.
It just makes sense
that if people are on a job they are
going to talk to them about what they
need to be doing on their job. As far
as just a sit-down meeting and this and
this and this and this, no.
It was just
routine, everyday job duties.
I'm going to ask you a couple of
questions and ask you in very general
terms if you ever learned of or were
told or have ever heard thestatements
I'm about to read. Okay? Have you ever
heard that prolonged exposure to Aroclor
vapors will lead to systemic toxic
effects?
MR. NEWSOM:
Let me object to the
form. Are you asking him
whether he recalls the
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specific words of that statement, or are you asking him something that may be, as you put it, very generally related to that? His answer could be very different, I would think, based on which way you are asking him. Repeat that question. Have you ever heard that prolonged exposure to Aroclor vapors will lead to systemic toxic effects? I've heard it. Where have you heard that? News releases, papers we had at the pi ant . Papers you had at the plant? Well, basically I'm talking about - basically that is news releases that they have posted there where EPA or somebody claims something. And where were those releases made available to you?
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Bulletin boards. Was that during your entire career there
Well, I wouldn't say during any entire
career, because after -- what was it,
'72 when we quit making it? It pretty
well went away, you know.
I mean, we
quit making Aroclors. There wasn't any
reason for me to be concerned with it.
Do you remember the specific date when
Aroclor production was shut down at the
plant ?
Not the specific date, no. Like I said,
it was somewhere around '72 I think or
something like that.
Have you ever heard that repeated bodily
contact with Aroclors may lead to a form
of skin acne?
Yes.
Did you learn that in the same manner
you learned the previous information?
Learned that throughsome
of the
discussions we've had on the job. You
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learn that through experience.
What kind of ventilation was used in the
control room?
You know, an air conditioning unit.
Were there any ventilators that sucked
air out of the room?
Nothing other than the air conditioning
unit.
Have you heard that exposure to PCBs can
cause cancer?
MR. NEWSOM: I'msorry. Would
you
read back the question?
(Requested portion of record
read.)
MR. NEWSOM: Objectto the form.
Do I need to answer?
MR. NEWSOM: Yes.
Yes, I've heard that.
Where have you heard that?
News releases, bulletins that come out
at the plant. You know, EPA put this
out.
I also heard they haven't ever
proved it either.
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Where did you hear that?
From the same bulletins.
Do you take any measures now in your
retirement to learn more about PCBs?
No .
You mentioned earlier the Quarter
Century Club banquets. What goes on at
those banquets?
We eat.
That's basically about it.
We
go for a big dinner, and there is a
little program to honor people who got
service awards. That's it.
Occasionally they have some kind of a
program, some kind of entertainment.
Is there any discussion about PCBs at
these banquets?
No .
MR. NEWSOM: I think it is more a
social organization.
MR. COLEMAN: I'm just asking.
It is not a business meeting. We've
even had a politician or two speak to
us .
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Have you ever heard that PCB exposure
can cause liver or kidney damage?
MR. NEWSOM: Ob j e c t to the form.
Not specifically that. Mostly what I've
read and heard, cancer, I think.
Have you ever been -- Have you ever been
tested for cancer?
What do you mean by that?
Have you ever -- Well, do you go to the
doctor?
I've been tested for about everything in
the book.
I don't know whether you can
call it cancer or not.
I don't know.
I
have blood work done twice a year
because of my heart condition.
Okay. What is that condition? What is
your heart condition?
I have arthrosc1erosis.
So you have blood work done twice a year
for that?
Yes .
And you have never known that the blood
work showed any --
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I've always been good, except my
cholesterol was high to start with.
All right. What other health problems
do you have?
Don't have any.
Are you aware of any tests done by
Monsanto on fish?
MR. NEWSOM: At any time?
MR. COLEMAN: Yes.
MR. NEWSOM: For any reason?
MR. COLEMAN: Yes.
MR. NEWSOM: Object to the form.
I don't know of any on fish.
I don't
know that.
Have you seen any fish advisories?
Oh, yes, I've seen those.
Under what circumstances did you see
those?
Newspaper.
And what bodies of water didthose
fish
advisories relate to if you can
remember?
Weiss Lake, Neeley Henry Lake, Logan
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Martin Lake, whichever one is down the
Coosa chain.
How about Choccolocco Creek?
Choccolocco Creek, that is part of Logan
Mart in.
How about Snow Creek?
Yes. Well, not specifically Snow Creek,
no .
What is your knowledge of any, if any at
all, soil tests done for the presence of
PCBs in the Anniston area?
MR. NEWSOM:
Object to the form.
The only knowledge I have is just to
know that EPA and the company both have
tested around the area since all of this
began,
Do you know the results of those tests?
No .
Do you recall an incident where Monsanto
management or Monsanto itself purchased
some hogs around the plant?
MR. NEWSOM:
Object to the form.
No. No. I don't know anything about
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that. In your entire career at the Anniston plant, did you have any dealings with the Krummrich plant? I went to the Krummrich plant late, just a few years before I retired, really, for a school that they had up there, maintenance type school. Are you aware of an early -- Strike that.
Are you aware of a test that was performed on the Krummrich plant employees in the '70s for lung cancer? No .
MR. NEWSOM: Object to the form. No . Have you ever heard that a study was performed in the 1970s on rats exposed to Aroclor 1260?
MR. NEWSOM: Object to the form. Yes. That's the study I think EPA or whatever it was did that said they could cause cancer in the rats.
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And did you learn -- How did you learn of that s t udy ?
That study was posted in our plant. Was there any special meeting about that particular study? No, not that I remember. So you learned of that study through bulletin board postings? Yeah. Okay. Do you remember exactly when? No . Do you remember who performed the study? No . Have you ever heard of a Dr. Renate Kimbrough? No . How about Industrial Bio-Test Laboratories? No . Have you ever heard that an eight-hour daily exposure to Aroclors is unsafe?
MR. NEWSOM: Object to the form. It fails to include any level
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of exposure, vague and ambiguous. No . How long were your shifts especially when you were an operator? Eight hours. Have you ever heard that PCB exposure has been associated with developmental or IQ problems? MR. NEWSOM: Object to the form. No . I think you said that you don't know what the results of the blood test for PCBs were. MR. NEWSOM: I think he said he didn't know exactly but it was low. I don't know exactly, but it was relatively low. Has anyone else in your family been tested? No . Did you ever work specifically with an
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incinerator at the Anniston plant? What do you mean by work with? Did you ever have any responsibility for work - When I was an electrician, we just maintained it, the controls. Were you responsible for boilers in that role also? Yes. I had direct responsibilities for boilers when I was electrical foreman. And what did that responsibility entail? Supervising the operation of the boiler. Would that include providing fuel for the boiler? Yes. What form did that fuel take? We used natural gas. We used propane gas. We used number two fuel oil, number six fuel oil. Did you ever burn any waste products? Later on. What do you mean by that? Later on we burned waste product.
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What year in specifically did that
begin?
Well, that was way after Aroclor was
shut down.
During that period of time you worked in
the Aroclor department as an operator,
you didn't have any responsibility for
the boilers ?
No .
Do you know how waste was disposed of in
your entire career at Anniston?
MR. NEWSOM: Object to the form,
overly broad.
You may answer.
Waste was handled in different ways,
depending on what it was. Some of
it
went to the landfill. Depending on what
the waste was, it may have went to a
disposal facility somewhere, Emelle or
somewhere like that.
But you never had, I think you said, any
responsibility for the landfill?
No. To be honest with you, during the
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years I worked in that plant I never
went across the street and into that
landfill, never.
I had no reason to go
there.
Did you have any responsibility for
barreling up waste?
Just I was an operator, yes. That's
what we did.
Tell me about that.
Like I said about the biphenyl. You
scooped it up with a shovel, put it back
in the barrel. You heated it up and
sucked it back into the system.
Okay.
Did you meet with anyone before
this deposition besidesthe meeting
just
before the deposition?
No .
How did you learn that your deposition
would be taken today?
Mike Kelly called me and told me.
Did y1 all have any discussion about what
this depositionwould entail?
MR. NEWSOM: Object to the form.
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He is with our firm, so that
is protected by
attorney-client relationship.
Do you still get a pension from
Mons ant o ?
I don't know how to answer that.
Let me
explain. I took a lump sum retirement
when I retired, so Monsanto doesn't pay
me a pension. I pay me a pension.
Are you still getting any benefits?
Yes. They still cover my health
benefits.
And is that for the rest of your life
that you will have that health insurance
benefit?
I will have that health insurance until
I start drawing social security, I
suppose.
I'd like to have it for the
rest of my life.
MR . NEWSOM: We'll do what we can.
MR . COLEMAN:
That s all I have .
(The deposition concluded at
10:50 a.m.)
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1 I do hereby certify that the witness 2 whose attached deposition was taken before me "3 was by me first duly cautioned and sworn to 4 tell nothing but the truth in the cause 5 aforesaid; that the testimony contained herein 6 was by me reduced to writing in the presence 7 of said witnesses by means of stenography and 8 afterwards transcribed by means of computer 9 aided transcription. The foregoing is a true 1 0 and accurate transcript of the whole of the 11 testimony given by said witness, as aforesaid. 12 I do further certify that I am not 1 3 connected by blood or marriage with any of the 14 parties or their attorneys or agents and that 1 5 I am not an employee of any of them, nor 1 6 interested in the matter of controversy. 1 7 IN WITNESS WHEREOF, I have hereunto set 1 8 my hand and affixed my notarial seal at 1 9 Gadsden, Alabama, County of Etowah, this 11th 2 0 day of January 2002. 21
Deborah Salers Garrett 2 2 Certified Shorthand Reporter
Registered Professional Reporter 2 3 Notary Public, Alabama-at - Large
My Commission expires: 3-6-05
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