Document 9J03JnBVn6xv5MDZRdxbVkk47
[
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF WEST VIRGINIA.
CHARLESTON, WEST VIRGINIA
JAMES M. ADKINS, A d m in is tra to r )
o tb* E etata o f Ralph B. A dkloa, )
Dseeasad, a t a l ,
)
; I
vs.
) P lain tiffs, )
) ) No. 81-2098
MONSANTO COMPANY, a Dal a s e r a Corpora tic ,
) ) )
) D efendant. )
Dap o s it io n o f WILEY HOGEMAN taken on b e h a lf o f th e
P lain tiffs.
R e p o rte r: M. Jo y S p rin g e r
J am es M ay R epo rtin g S ervic e
CERTIFIED SHO RTHAND REPORTERS R.R. 2 - BOX 65
EDWARDSVILLE. ILLIN O IS 62025
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF WEST VIRGINIA CHARLESTON, WEST VIRGINIA
3
4 JAMES M. ADKINS, A dm inistrator ) of the E state of Ralph E, Adkins, )
5 Deceased, et a l,
)
- ....................
6
) P lain tiffs, )
7 vs.
) ) No. 81-2098
iivi'-;
8 MONSANTO COMPANY, a Delaware C orp o ra tio n ,
) ) )
9) Defendant. )
i;
10 *...*
. ^ - V - '^ ..
11
APPEARANCES :
12
M essrs. C a lw ell, McCormick &
V ** *"
13 Peyton,
by W. S tuart C a lw ell, J r ., Esq. For P l a i n t i f f s ,
14
M essrs. Bowles, McDavid, G raff 6e
15 Love,
by Charles M. Love I I I , Esq. 1 and
Thomas E. S carr, Esq.
17 and
Deborah A. S in k ,
For Defendant.
18
19
20 IT IS STIPULATED AND AGREED by and between
21 co u n sel fo r the p l a i n t i f f s and co u n sel fo r the defendant
22 th a t the d e p o sitio n o f WILEY HOGEMAN may be taken pur
23 suant to Rule 26(a) o f the F ed eral Rules o f C iv il Pro 24 ced u re, on Ju ly 8 , 1983, a t the Radisson H o tel, Room 215, 25 9th S tr e e t and Convention P la z a , S t. L o u is, M isso u ri,
JAM ES MAY R E PO R TIN G SER V IC E
b efo re M. JOY SPRINGER, a N otary P u b lic w ith in and for
the County o f Madison, S ta te o f I l l i n o i s ; th at the
issuance o f n o tic e and dedimus is w aived, and th a t th is
d e p o sitio n may be taken w ith the same fo r c e and e f f e c t
a s i f a l l F ed eral r u le s and s ta tu to r y requirem ents had
been complied w ith.
IT IS FURTHER STIPULATED AND AGREED th a t any
and a l l o b jectio n s to a l l or any part o f th is d e p o sitio n ,
excep t ob jection s as to form o f the q u estion s askM"
` ,v V.,
answ ers g iv e n , a r e h e re b y r e s e rv e d an d may be r a i ^ t f
on th e t r i a l o f th is cau se; and th a t th e sig n a tu rS f'tff
the deponent is not waived.
YY'Y
**
WILEY HOGEMAN produced, sworn and examined on b e h a lf o f the p l a i n t i f f s , deposes and'says as follow s:
EXAMINATION BY MR. CALWELL:
(Whereupon the re p o r te r marked P la in t i f f s ' D ep osition E x h ib it #295 (Monsanto #8324372) co n sistin g of 1 page, for the pur
poses of id e n tific a tio n .)
JAM ES MAY R E P O R T IN G S ER V IC E
2
1 Q (By Mr. C a lw ell) Would you s t a t e your i
2 name, p le a s e . 3 A W iley Hogeman. 4 Q And where do you l i v e , Mr. Hogeman? 5 A Here in S t. Louis a t F a ir Oaks. Q You*re employed by the Monsanto Company? 7 A Yes..
8 Q What is i t you do fo r them? 9 A I'm the General Manager of the
10 Chemicals bus in es s . 11 Q Is th a t a corporate l e v e l p o sitio n ? - -S 12 A No, i t 1s n o t. I'm n ot an o f f icei
13 I am a se u io r manager.
14 Q Is th ere a Rubber Chemicals D iv isio n ?
15 A I t used to be a Rubber Chemials D iv is io n
16 and then we reorganized and now i t ' s c a lle d -- we have
17 Manufacturing - - w e have fu n c tio n a liz e d . We have a manu
18 fa c tu r in g fu n ctio n and a resea rch fu n c tio n , a s a le s
19 fu n c tio n , and then I run the b u sin ess group which are the
20 commercial p eop le.
21 Q Does th a t group have a name?
22
A
I t ' s the Rubber Chemicals b u sin ess group.
/
23 Q Would th a t be the same, l i k e , MIC is
24 Monsanto I n d u s tr ia l C hem icals, is th a t the same kind o f
25 o r g a n iz a tio n a l d iv is io n th a t the Rubber Chemicals group is ?
JAM ES MAY R E P O R TIN G SER VIC E
3
1 A No. The Rubber Chemicals group is one -*- t
2 o f the groups w ith in an MIC company. I t ' s one o f the 3 b u sin e sse s w ith in an op eratin g company and one o f the
4 b u sin e sses o f Monsanto Polymer Products Company. 5 Q And you're a General Manager?
A General Manager, r ig h t,
7 q How long have you been in th a t p o sitio n ? 8 A Since January 1 s t , 1981. Two and a
9 half years. 10 Q What is your ed u cation?
-.vVi--"
11 A I have a B. S. Degree in Chemistry
12 and a second B .S. Degree in Chemical E ngin eerin g from,;
13 Louisiana S ta te U n iv e r s ity .
14 Q You o r i g in a l ly from th a t area?
15 A Yes. Born, r a is e d th e r e . Never l e f t
16 u n t i l X went to work w ith Monsanto and I went in to the 17 s e r v i c e ,
18 Q Are those your on ly two Degrees?
19 A Yes. T hat's enough. One too many. 20 . Q When did you s t a r t w ith Monsanto?
21 A June 13, 1956. T hat's about 27 years ago. 22 Q During th a t period o f time from 1956 23 u n t il today have you had any co n n ectio n w ith the N itro 24 f a c i l i t y ? 25 A Not u n t i l X moved in to the Rubber
JAM ES MAY R E PO R TIN G SER VIC E
k
1 Chemicals business in January of *81. 2 Q During your employment w ith Monsanto 3 have you done any work in the area o f chlorophenols? 4 A No. 5 Q Any a s s o c ia t io n w ith 2 ,4 ,5 -T ? A No. 7 Q What kinds o fth in g s have you done 8 fo r Monsanto over the years? 9 A W ell. I started out in the T e c h a i d & l ^ 10 group in P en sacola, F lo r id a , and worked my way thr(^gh^H^ti*; 11 th a t m assive o rg a n iza tio n running many other jo b s iw ith in v;v 12 the p la n t to General S u p erinten d en t. Then from th e r ^ t^ f 13 moved to P lan t Manager o f a fila m e n t p o ly e s te r p la n t 14 and got in to Alabama, and i t was sin c e sh ut down or 15 e x ite d the fila m en t p o ly e s te r b u s in e s s , and I came to 15 S t . Louis in 1964 as the B usiness D irecto r o f the In 17 d u s t r ia l F ib ers B usiness Group and from there to General 18 Manager o f M anufacturing fo r the t e x t i l e company. I 19 ran a l l o f the m anufacturing fo r the t e x t i l e s organ iza 20 tio n and then from there to running a l l o f m arketing fo r 21 t e x t i l e s and from there over to Rubber Chemicals in *81. 22 Q Now, is 1981 your f i r s t ex p erien ce in 23 the Rubber Chemicals area? 24 A Yes. F ir s t in tro d u ctio n to th a t w orld. 25 Q And th a t would a cco u n t, th en , fo r your
JAMES MAY R E PO R TIN G SER VIC E
`(
1 beginning association with N itro fa c ility ?
2 A Uh huh ( y e s ) . 3ut the N itr o P lan t
3 d id n 't rep ort d ir e c t ly to me. I t reported through the
4 Manufacturing D iv is io n , but N itro made some o f the rubber
5 chem icals products th a t we s e l l .
6 Q And from your summary o f your exp erien ce
7 w ith Monsanto, I take i t , over the years you have had
8 no a s s o c ia t io n w ith the A g r ic u ltu r a l b u sin ess o f Monsanto?
9 A No, none w hatsoever, I w ish I <>
10 Q Now, Mr. Hogeman, your name cropped^v/Uw
*Tf 11 up on a document. I ' l l hand you w hat's been marked
12 P l a i n t i f f s ' E x h ib it #295 (Monsanto #8324372),
13 A Uh huh (y es) .
14 Q You have had a chance to look a t Ex-
15 h i b i t 2957
16 A Y es.
17 Q That appears to be a Monsanto memo-
18 randura, and your name i s shown on the d is t r ib u t io n l i s t ?
19 V.A Uh huh (y es) .
20 Q And the document r e fe r s to the N itro
21 H ealth Study Task F orce. VJhy would you be on th a t d is -
22 tr ib u tio n l i s t ? 23 A Only because I was the General Manager
;
24 of the Rubber Chemicals B u sin ess, and some o f the chem icals
25 th a t we s e l l are made in N itr o . So I would have a b u sin ess
JAMES MAY REPORTING SERVICE
6
<' ir
1 I n t e r e s t i n (,th is whole proceeding as fa r as maybe the
. * ' -O.-r^'' i*'"
j
2 eventual outcome, or whatever.
3 Q Now, in th a t con n ection how were you
4 made aware o f the form ation o f the N itr o Task Force?
5 A I didnVt have any d eta iled knw ledge
6 o f any form ation o f any Task F orce. This was done a t
7 a corporate le v e l co m p letely divorced from me or any
8 input from me. ' . 1'
9 Q R ig h t. Did you j u s t s t a r t r e c e iv ix ^ ^ : ^ '^
10 these co p ies o f the minutes o f the Task Force and.-.fchat 11 kind o f thing?
f*
12 A Yes.
V
13 Q Did you have any advance n o tic e th a t
14 you were going to s t a r t r e c e iv in g those documents?
15 A No, n ot r e a l l y . 16 Q They j u s t showed up in your m ail one day?
17 A Y es, j u s t because o f m y .p o sitio n .
18
..... . Q
Did you a sk , what in the world i s the
19 N itr o Task F orce, I 'v e j u s t g o tte n th is mail?
20 A I read some o f them and, o f co u rse,
21 th ey were s e lf-e x p la n a to r y .
22 Q So a s id e from j u s t r e c e iv in g th ese
23 documents w ith ou t w arning, I su pp ose, and reading them, 24 t h a t 's the on ly knowledge you had about the N itro Task 25 F orce, i s th a t what you re saying?
-
JAMES MAY REPORTING SERVICE
J
1
A That*s about i t . i
2 Q Do you know anybody on the d is t r ib u t io n
3 l i s t on E x h ib it 295?
4 A I know most o f them. I d o n 't know
5 some o f the people th a t th is is d ir e c t ly addressed to .
6 I know a l l o f the people th a t were cop ied in , but not
7 the addressees, not a l l of the addressees.
8 Q A ll r ig h t . You t a lk to any o f th e se
9 other fe llo w s you knew th a t were copied alon g
10 about the N itr o Task Force?
11 A Oh, y e s . We talk ed p e r io d ic a lly vt -
12 hallw ay c o n v e r sa tio n s , w hatever.
**
A*\ >A r 1?
13 Q And were they in the same s it u a t io n
14 you were in , j u s t p r e tty much ign oran t about why they
15 would s t a r t r e c e iv in g th ese documents?
16 A Oh, th ey w eren 't ign oran t as to why.
17 N eith er was I ign oran t as to why I was r e c e iv in g them.
18 I knew v ery w e ll why I was r e c e iv in g them. Simply b e
19 c a u s e o f my p o s it io n . I have an in t e r e s t in i t but no 20 d ir e c t involvem ent.
21 Q What was the purpose o f the N itr o Task 22 Force ?
23 A I'm n ot su r e . S in ce I w a sn 't asked 24 a s to what was in v o lv ed , I c a n 't answer the q u e stio n . 25 Q I f I understand what you 're sa y in g
JAM ES MAY R E PO R TIN G SER VIC E
9
1 2 3 4 5
6
7 8 9 10
11
12 13 14 15 16 17 18 19 20 21 22 23 24 25
co rrectly , then, every b it of correspondence that goes
to the N itro P la n t, then, sin c e the N itro P lan t has
some fu n ctio n w ith the rubber chem icals a sp e c ts of
Monsanto, you as a matter of co u rse, then, r e c e iv e , is
th a t what you 're sa y in g , and th a t t h is was no d if f e r e n t
than anything e ls e you would r e c e iv e from d ea lin g w ith
the N itro Plant?
A I receive a lo t of correspondence
in v o lv in g the Rubber Chemicals B usiness a s s o c ia te d -Withviki
N itr o . I d o n 't r e c e iv e a l o t o f o th e r , but on a g e n e ra lbasis I do. I f i t ' s a general plant situ a tio n , I re-
-
c e iv e i t because i t could impact my b u sin e ss. But' th ere are other businesses a t N itro a ls o besides rubber chemi-
*
c a ls , and I d on 't r e c e iv e th a t kind o f in form ation .
Q But in so fa r as inform ation th at N itro
may generate or be d ir e c te d to N itr o th a t concerns the
Rubber Chemicals B u sin ess, you would norm ally r e c e iv e
th a t, is (hat what you're saying?
X Uh huh (y es) .
. Q And the N itro Task Force was r e a l l y
no d if f e r e n t than an yth in g e l s e , and t h a t 's why you were
on the l i s t ? A
I t ' s something th at impacted the whole
J
p la n t and as a r e s u lt an yth in g t h a t 's g en era l th a t im-
p acts the p la n t I r e c e iv e , a s my a s s o c ia t e s do, because
JAMES MAY REPORTING SERVICE
9
$%
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
19
20 21 22 23 24 25
V ___
it . could Impact n ot on ly my b u sin ess but t h e ir s . It* s
for inform ational purposes.
plant?
Q
How did you know i t impacted the e n tir e
A What --
Q The N itro Task Force, A I d o n 't knew whether i t d o es.
Q Now, you j u s t sa id i t d id , you sa id i t impacted the e n tir e plant and sin c e you have s
tio n w ith a part of the p la n t yen sa id t h a t 's the-
th a t you re ce iv ed i t . A I t was a o la n t is s u e , i t ' s a
'.V.
sfJxJ 1*
q a plant issue?
W ell, do you r e c e iv e e v e ry th in g t h a t 's
A That might impact my b u s in e s s , y e s.
Q W ell, how d id yju know th a t th a t was a plant issu e that impacted the e n tir e plant?
, -- A own im pression.
T hat's my own understanding and my
Q A ll r ig h t . And what did you base th a t understanding and Im pression on?
A Common se n s e .
Q Nothing else? A No. Ju st the fa c t th a t a law su it has
been brought on by a number o f em ployees spread a cr o ss
JAMES MAY REPORTING SERVICE
V*
V
*
1C
1 the p la n tr and whether they are spread across the plant 2 I d o n 't know. I d o n 't know where th ey come from. But 3 I assume th a t. I t ' s an assum ption on my p a rt. 4 Q Is th a t why the N itro Task Force was 5 formed? A For what?
7 Q Because o f the la w su it.
8 A I d o n 't know.
9 W ell, you j u s t sa id because o f sC-J
10 brought by a number of employees --
.\V! ** * VJ- -
-
n A And I sa id I assumed a l l t h a t . 'I- c a n 't
^,v
12 f a c t u a lly say yes or no to th a t because I'm n ot knowl~n^'^-J;
13 e d g e a b le .
14 Q I understand th a t. But in your mind,
15 a t l e a s t , there must be some con n ection between the
16 la w su it or a la w su it and the N itr o Task F o rce, is th a t
17 what you 're saying?
18 A I d o n 't know. I d o n 't know when the
19 N itr o Task .Force was formed, I d o n 't know when the la w su it 20 was f i l e d ( so I c a n 't t e l l which came f i r s t ,
21 Q So you 're changing your testim on y - 22 A No. 23 Q You d o n 't have th a t im pression any more 24 about the con n ection between the la w su its and the Task 25 Force and the number o f in d iv id u a ls th a t were spread
d
JAMES MAY R E P O R T IN G SER V IC E
1
$
1 across the p lan t g iv in g you an im pression that the Task 2 Force, thenr impacted the e n tir e p la n t and th a t's the 3 reason you were on a copy l i s t ? T h at's the way I under 4 stood your testim ony. 5 A My testim on y was th a t I r e ce iv ed th is because i t ' s something that could impact the en tire plant
7 and as a r e s u lt I receiv ed i t , y es.
8 Q And I asked you why, and t h a t's the
9 ex p la n a tio n you gave me. Now, do you have a
10 ex p la n a tio n now or are you going to s t i c k w ith t h ^ j f ir a t : ^ ^ ,
11 one?
12 13
SqKx?^..A No, I ' l l s t i c k w ith what I s a i d - '.s'*'.. > '.'..r v'
Q Now, do you s t i l l r e c e iv e inform ation
14 from the Task Force?
15 A P e r io d ic a lly . Less and le s s freq u en t. 15 Q Some o f the Task Force m a te ria ls make
17 re fe re n c e to d io x in , you r e c a l l that?
18
*. A .
No.
19 Q Have you ever heard o f d io x in or
20 . '2 ,3 ,7 ,8 tatrachloroaibenzo-para-dioxin?
21 A I th in k everyone in S t. Louis has heard 22 of th a t because o f Times Beach.
23 Q When did you f i r s t hear about d io x in ? 24 A I c a n 't p in p o in t th a t. 25 Q Was i t in co n n ectio n w ith your work or
JAMES MAY R E P O R T IN G SER V IC E
1 the Task Force?
2 A To be v ery tr u th fu l w ith you, the f i r s t
3 . .time th a t d io x in made an im pression on me is Times Beach.
4 Q And how d id you lea rn about that?
5 A Newspaper. Q So your inform ation about d io x in had
7 it s g en esis, I guess, in the newspapers, right?
8 A B asically.
9 Q Has th a t been p r e tty much the source
j ' OV*. iJ f-
10 o f your In f or na t ion about dio x i n , the news paper s ? r0 r - ' :i. 11 A Uh huh ( y e s ) . 12 Q Did the N itr o Task Force have a n y th in g ; 13 to do w ith d io x in , th a t you know of? 14 A Not r e a l l y , to my knowledge. 15 Q You don' t haveany idea what i t had to 15 do w ith , rig h t? 17 A No. 18 <J Did you ev er a tta n d n n y m eetings o f the 19 N itr o Task Force? 20 A I th in k , one m eetin g , one o f the f i r s t 21 m eetin g s, and I 'm n o t sure whether i t was th a t one or n o t. 22 Q And do you know why you a tten d ed it ? 23 A Y es. Because th ey c a lle d a m eeting 24 to bring people up to date on a l l o f the a c t i v i t i e s . 25 Q Do you remember what you were brought
JAM ES MAY R E P O R T IN G SER V IC E
i:
/A
g
1 2 3 4 5 6 7
8
9 10 11 12 13 14 15
16
17 18 19 20 21 22 23 24 25
up to data on a t th a t time?
i
.* A How many p l a i n t i f f s , what chem icals w a r e i n v o l v e d and a l l o f i t . I d id n 't understand most of i t sim ply because I was rath er new. You can imagine me coming from T e x tile s in to th a t w orld.
Q When you were in T e x t ile s , did you have occasion to work w ith carbon d if u lf id e ?
A No. Q That would be true fo r H2S, I
A R ig h t.
Q That m eeting th a t you a tten d ed w h e r e - -- you were brought up to date on t h e 's ta tu s of the ikwsui^.^Vi'-' and,I assume, you're talking about the law suit that you1re being deposed in now, a s u i t brought by a number o f employees and former employees?
A Uh huh ( y e s ) . Q Is th at where you got the idea th a t t h e Task F o r c e was in resp onse to th a t law su it? - No. Q Did th a t r e in fo r c e your opinion th a t t h a t is what the con n ection was? A No. Q Have you r e c e iv e d any b r ie fin g or in form ation a t a l l from N itro regard in g 2 ,2 ,7 -,8-TCDD? A No.
JAMES MAY REPORTING SERVICE
t> %
1 Q Or Monsanto? 2 A I d id n 't hear that. 3 q You have not r e c e iv e d any inform ation 4 or b r ie fin g about 2,3,7,8-TCDD from your company, is th a t 5 right? 6 A Not me, no. 7 Q And n oth in g in co n n ectio n w iih any 8 chloracne or h ea lth , problems th a t may have been apparent 9 or present a 10 or any other 11 A T hat's r ig h t . 12 Q You have had no in form ation aboV thiai 13 from the p la n t or from Monsanto? 14 A No. 15 Q O.K. The on ly th in g you knew about 1 is what you read i n the new spapers, rig h t? 17 A About d io x in ? 18 Q Y es. 19 A' Yes. 20 Q And the N itr o Plant? 21 A I d o n 't read about theN itr o P la n t in 22 the newspapers. 23 Q Now, in con n ectio n w ith your r e c e iv in g 24 lit e r a t u r e from the N itro Task F o rce, did you r e c e iv e 25 any inform ation about Raymond Suskind?
JAM ES MAY R E P O R TIN G SER V IC E
1 A At that point --
2 ..\-Q Which point?
3 A E arly on, when I went to one m eeting,
4 and I'm n ot sure what m eeting th a t w as, whether i t was
5 the f i r s t , second, fourth or tenth or what, but I went
6 lto a m eeting and I thin k they rep orted som ething. This
7 has got to be two years a g o , and I was brand new in the
8 j o b . But I think they were ta lk in g about som ething, ^ ,
9 th a t maybe Suskind was goin g to do som ething or 10 I don' t know what the d e t a ils w ere, n Q You ever se e any o f h is s t u d ie s jo r 12 summaries o f them or an yth in g lik e that?
X
13 A No.
*
14 Q And as fa r as you know, you never
15 atten d ed any other m eetings o f the Task Force other than
16 tha t one ?
17 A I don' t th in k s o .
18 v <J You t e s t i f i e d th a t your con n ectio n
19 w ith the N itr o P lan t in your p resen t job was in the
20 b u sin ess se n se , I suppose, the economics o f the p la n t or
21 whether i t ' s probable or n o t, does th a t come under your --
22
A Uh huh ( y e s ) .
!
23 Q Did you have a con n ection w ith a fu n ctio n 24 lik e th a t in any other job you had w ith Monsanto, l i k e , 25 fo r exam ple, in the '60s? Were you in a b u sin ess --
JAM ES MAY R E PO R TIN G SER VIC E
1 A When I ran the I n d u s t r ie l F ib ers
2 Business Group in 1974 u n t il '7 6 .
3
:Q
Was th a t your f i r s t job - -
4 A In a commercial jo b , y e s, because I
5 had been in m anufacturing up to th a t p o in t.
6 Q Now, have you had any co n n ectio n w ith
7 the Krummrich Plant?
8 A Yes.
9
Q In the same posture as the
(*^s3V- 3 .
1.0 would be in r e la t io n to your job?
11 A Yes. C u rren tly . In the job I'niplii ncwv:-
,
`
12 Q And have you bean made aware o V - j-v' i*
V lw , /A T . V4-?
-' :
: *
13 t e s t in g plan or procedures regard in g a n a ly z in g Santophen 1
14 or ch lo ro d ib en zo -d io x in s?
15 No.
1 q D on't know an yth in g about that?
17 A D on't know an yth in g about i t .
18 Q You were not on any m a ilin g l i s t or 19 copied?
20 A Not to my knowledge.
21 Q And th a t would be true for1979?
22 You're not aware o f an yth in g th a t occurred in 1979 in
23 v o lv in g t e s t in g o f pentachlorophenol or orchochlorophenol? 24 A No. 25 Q For dlberizofurans oranything lik e that?
JAM ES MAY R E P O R T IN G SER V IC E
1 A D id n 't even know what they .re. D on't 2 know y e t what they a r e . 3 Q W ell, they have been in the newspapers. 4 A Maybe you 're r ig h t . 5 MR.-CALWELL: O.R., Mr. Hogeman. Thank you.
7 8 9
W iley Hogeman 10
11
12
13 14 15
l
17 18 19 20
21 22 23 24 25
JAM ES MAY R E P O R T IN G S ER VIC E
IS
1 STATE OF ILLINOIS ) ) SS.
2 COUNTY OB MADISON )
3
4 I , M. JOY SPRINGER, a N otary P u b lic , duly
5 commissioned and q u a lifie d in and fo r the County o f
6 Madison, S ta te of I l l i n o i s , do hereby c e r t i f y th a t
7 pursuant to n o tic e came b efo re me on the 8 th day o f
8 J u ly , 1983, a t the Radisson H o te l, Room 215, 9th
9 S tr e e t and Convention P la za , S t. L ou is, Missourifc^^'.cg-;
10
. v 1 v'
WILEY HOGEMAN, who was by me d uly sworn to t e s t if y : 't o
11 the tru th and n oth in g but the tru th o f h is knowledge
12 touching and concerning the m atters in c o n tr o v e r sy
13 th is ca se; th a t he was thereupon c a r e f u lly examined
14 upon o a th , and h is exam ination reduced to w r itin g
15 under my su p e r v isio n ; th a t the d e p o sitio n is a tru e
16 record o f the testim on y g iven by the w itn e s s ; and
17 sig n a tu re o f the w itn e ss was n o t w aived.
18 .1 FURTHER CERTIFY th a t I am n e ith e r a tto r n e y
19
nor cou n sel for nor r e la te d to nor employed by and
20
o f the p a rties to the a ctio n in which th is d ep osition 21 i s taken; and fu r th e r , th a t I am n o t a r e la t iv e or
22
employee o f any a tto rn ey or cou n sel employed by the
23
p a r tie s h ere to , or f in a n c ia lly in te r e s te d in the
24
a c tio n .
25
IN WITNESS WHEREOF, I have hereunto s e t my
JAM ES MAY R E P O R TIN G SER V IC E
IS
hand and a f f ix e d my n o t a r i a l s e a l on th is day of July, 1983.
Notary Public w ithin and fo r the... County of Madison, S ta te of I l l i n o i s ;
**>`
JAMES MAY REPORTING SERVICE