Document B82G8JKEgBzN4kw7No8mJOw58

FILE NAME: GATX (GX) DATE: 1998 Aug 27 DOC#: GX101 DOCUMENT DESCRIPTION: Legal - Deposition of John D. Levin 1 1 IN THE COURT OF COMMON PLEAS TRUMBULL COUNTY, OHIO 2 LOIS J. MISSIK, Executrix, 3 etc. 4 Plaintiff, 5 No. 97-CV-303 6 OWENS-CORNING FIBERGLAS CORP., et al. 7 Defendants. 8 9 10 The Videotaped Deposition of John D. 11 Levin taken in the above-entitled cause before Rhonda 12 Snyder, Certified Shorthand Reporter, Registered 13 Professional Reporter, and Notary Public within and 14 for the County of Cook, State of Illinois at General 15 American Transportation Corporation headquarters, 500 16 West Monroe Street, Suite 4300, Chicago, Illinois, 17 commencing at 9:27 a.m. on Thursday, August 27, 1998. 18 19 20 21 22 23 24 CERTIFIED REPORTING COMPANY (312) 922-1666 2 1 APPEARANCES: 2 3 Swartz & Reed 4 Mr. Dean E. Swartz 1825 Jefferson Place, N.W. 5 Washington, D.C. 20036 6 (202) 429-0429 On behalf of the Plaintiff, 7 8 Thompson, Hine & Flory, LLP Mr. Stephen H. Daniels 9 3900 Key Center, 127 Public Square Cleveland, OH 44114-1216 10 (216) 566-5500 11 On behalf of the Defendants. 12 13 ALSO PRESENT: 14 Ms. Karen A. Kowalik, CLVS Legal Video Services, Inc. 15 615 Berkshire C. Schaumburg, IL 60193-3005 16 (847) 985-5776 17 18 19 20 21 22 23 24 CERTIFIED REPORTING COMPANY (312) 922-1666 1 INDEX 2 3 4 WITNESS: PAGE 5 John D. Levin 6 Examination by Mr. Swartz 5 i 8 EXHIBITS 9 EXHIBITS PAGE 10 Plaintiff Exhibit No. 13 12 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 LINE 8 LINE 9 CERTIFIED REPORTING COMPANY (312) 922-1666 4 1 THE VIDEOGRAPHER: This is Karen Kowalik of 2 Legal Video Services, Incorporated, 615 Berkshire 3 Court, Schaumburg, Illinois. I am the operator of 4 this camera. This video deposition of John Levin 5 is being taken on behalf of the plaintiffs at the 6 offices of American Transportation Company, 500 7 West Monroe, Chicago, Illinois on August 27, 1998 8 at 9:27 a.m. as indicated on the video screen. 9 This case is captioned Lois J. 10 Missik, Executrix, etc., versus Owens-Corning 11 Fiberglass Corporation. The case number is 12 97-CV-303. Will the attorneys please identify 13 themselves for the video record? 14 MR. SWARTZ: This is Dean Swartz accompanied 15 by my paralegal, Natalie Prince, on behalf of 16 Mrs. Missik. And let me just as a clarification, 17 the deposition of Mr. Levin is being taken pursuant 18 to the Notice under Rule 30(B) (3) and (5) of 19 Mr. David Anderson. And by agreement of counsel, 20 Mr. Levin will be the corporate designee for this 21 deposition. 22 MR. DANIELS: And m y name is Steve Daniels and 23 I'm here on behalf of GATX. 24 THE VIDEOGRAPHER: Thank you. Will the court CERTIFIED REPORTING COMPANY (312) Q90-1fi 5 1 reporter please identify herself and swear in the 2 witness? 3 THE COURT REPORTER: M y name is Rhonda Snyder 4 from Certified Reporting. 5 (Witness sworn.) 6 THE VIDEOGRAPHER: Thank you. Please proceed. 7 JOHN D. LEVIN, 8 having been first duly sworn was 9 examined and testified as follows: 10 EXAMINATION 11 BY MR. SWARTZ: 12 Q. Good morning, sir. Will you please 13 identify yourself for the record? 14 A . John Levin. 15 Q. And what is your business address, 16 M r . Levin? 17 A. 500 West Monroe Street, Chicago, 60661. 18 Q. And what is your current position? 19 A. Assistant general counsel, GATX 20 Corporation. 21 Q. And is it your understanding, sir, that you 22 are here as GATX's corporate representative to 23 testify about two topic areas? 24 A. Yes, it is. CERTIFIED REPORTING COMPANY (312) 922-1666 6 1 Q. And is the first topic area the operation 2 and activities of the GATX/GATC Law Department 3 including the duties and responsibilities of 4 GATX/GATC's general counsel and other in-house 5 counsel prior to 1975? 6 A. Yes, it is. 7 Q. And is the second topic area that you 8 understand you are here to testify about state or 9 federal requirements, regulations, rules, laws, 10 statutes, or standards concerning 11 industrial/occupational health and safety at 12 GATX/GATC manufacturing and repair facilities prior 13 to 1975? 14 A. Yes, it is. 15 Q. Now, for what time period prior to 1975 are 16 you prepared to testify? 17 A. From approximately 1961 to 1975. 18 Q. Have you spoken with anyone in preparation 19 for today's deposition? And that, of course, 20 excludes communications with -- 21 A. Counsel. 22 Q. -- the defendant's counsel. 23 A . Yes. 24 Q. With whom have you spoken? CERTIFIED REPORTING COMPANY (312) 922-1666 1 A. I've spoken to Michael Lyons, L-y-o-n-s, 2 who was with the GATX Law Department from 3 approximately 1970 to 1977 or 1978. And I've spoken 4 to James Glasser, G-l-a-s-s-e-r, who was with the 5 GATX Law Department from approximately 1961 to 1968. 6 Q. Where is Mr. Lyons now? 7 A. Practicing law in Pittsburgh. 8 Q. What was his position while he was with 9 GATX? 10 A. Attorney in the Law Department. 11 Q- Who was the general counsel during that 12 time period? 13 A. George W. Rothschild, R-o-f -- 14 R-o-t-h-:s-c-h-i-l-g -- d, Rothschild. 15 Q. Where is Mr. Rothschild? 16 A. He's deceased. 17 Q. And who was the general counsel that 18 preceded him? 19 A. That I don't know. 20 Q. Did you ask Mr. Glasser who the general 21 counsel was during the 1961 to 196 -- 22 A. It was also Mr. Rothschild. 23 Q. And where is Mr. Glasser presently? 24 A. He's retired from GATX. CERTIFIED REPORTING COMPANY (312) 922-1666 8 1 Q. And where is he located? 2 A. In the Chicago area. 3 Q. Other than those two gentlemen have you 4 spoken to anyone else? 5 A. I've spoken to other people in the Law 6 Department who were not here then just to see if they 7 knew of anything. 8 Q. To see if they knew anything? 9 A. That related to the earlier period. 10 Q. Right. In terms of the length of time that 11 you have been in the GATX Law Department, have you 12 been here longer than anyone else presently? 13 A. Yes. 14 Q. How long have you been in the Law 15 Department? 16 A. From1972. 17 Q. You have a tendency, as I think I often do, 18 and that's to start answering a question before it's 19 been asked. 20 A. Yes. I'll wait. 21 Q. So will you please wait until I complete my 22 question? 23 A. Yes. 24 Q. Thank you. Did you review any materials in CERTIFIED REPORTING COMPANY (312) 922-1666 9 1 preparation for the deposition today? 2 A. Yes. 3 Q. And what materials have you reviewed? 4 A. I reviewed the basically the files and 5 indexes to the files and the index to the files in 6 storage of the GATX Law Department. 7 Q. And where are those indexes to files and 8 files in storage located? 9 A. They're just a notebook. The files in 10 storage are in a notebook in the Law Department. The 11 files in the file room are on-line. They're just in 12 a WordPerfect file. 13 Q. Miss Prince and I have been here in Chicago 14 since Monday around midday reviewing materials in 15 boxes. Are any of the boxes that you have referred 16 to among those approximately 300 boxes that were made 17 available to me for review this week? 18 A. Can I speak to m y -- I'm not -- I know that 19 there were no files -- particular files in the Law 20 Department records that were responsive. I just 21 don't know if any were. May I ask my counsel if -- 22 Q. All right. Well -- 23 A. I don't specifically know the answer. 24 MR. DANIELS: And I d o n 't know what he looked CERTIFIED REPORTING COMPANY (312) 922-1666 10 1 at so I can't answer that question. 2 MR. SWARTZ: All right. 3 BY MR. SWARTZ: 4 Q. Just so that we're clear, if you don't know 5 an answer, don't hesitate to just say those simple 6 words, I do not know. 7 A. Okay. 8 Q. All right. What files did you review? 9 A. There were no files that related to that 10 period of time. 11 Q. Were there files that related to earlier 12 periods of time? 13 A. No. 14 Q. Generally speaking, what did those files 15 consist of? 16 A. In the records? 17 Q. The files that you looked at in the 18 indexes. 19 A. The index related -- the materials that we 20 have in storage relate mostly to transactions, 21 litigation involving matters having nothing to do 22 with Sharon asbestos or the like, it's rail car 23 cases. 24 Q. Did any of those cases involve occupational CERTIFIED REPORTING COMPANY (312) 922-1666 11 1 or industrial health and safety matters? 2 A. No. 3 Q. Other than those files and the indexes to 4 which you referred at the beginning of this series of 5 questions, have you reviewed anything else? 6 A. I have also reviewed some materials 7 supplied relating to health and safety issues from 8 1971. 9 Q. And this would be information in the orange 10 binder that is sitting in front of you? 11 A. That's correct. 12 Q. Now, one of thosebinders -- there are two 13 of them. One of them says Supervisor Safety Manual. 14 If my understanding is correct, one of them relates 15 to matters at GATX Terminals; is that correct? 16 A. Yes. Yes. These are both supplied by an 17 employee at GATX Terminals. One of them is limited 18 solely to GATX Terminals matters. The other is 19 generic and refers to GATX Corporation at the various 20 divisions and subsidiaries in 1971. 21 Q. With regard to the Terminals Manual do I 22 assume that that manual did not furnish you with 23 information? 24 A. That is correct. CERTIFIED REPORTING COMPANY (312) 922-1666 12 1 Q. All right. Then we won't deal with that. 2 And why don't you just push that one aside so we 3 d o n 't get confused with that as we may have already. 4 MR. SWARTZ: The binder that is sitting in 5 front of you, I'm going to have us identify that as 6 Plaintiff's Deposition Exhibit Number 13. I'm not 7 going to put this sticker on it at this time. 8 What we'll do is we'll take care of 9 this afterwards and we'll have a copy made and 10 we'll attach the sticker to that and the original 11 can be maintained by General American. Is that 12 acceptable to all? 13 MR. DANIELS: Yes. 14 (Whereupon Plaintiff Exhibit 15 No. 13 was marked for 16 identification.) 17 BY MR. SWARTZ: 18 Q. From whom did you obtain the Plaintiff's 19 Deposition Exhibit Number 13? 20 A . David Berg. 21 Q. And that's the same Mr. Berg who I deposed 22 about a month ago; isn't that correct? 23 A. That is correct. 24 Q. And this book contains information about CERTIFIED REPORTING GOMPaMv 13 1 health and safety -- occupational health and safety 2 matters? 3 A. From the period 1971. 4 Q. Did Mr. Berg tell you where he obtained 5 this? 6 A. Subsequent to his deposition and refreshing 7 his own recollection because of that, he remembered 8 that these volumes were in some place at GATX 9 Terminals. I don't know where anyone found them. 10 Q. When did you see them for the first time or 11 did you see it for the first time? 12 A. Subsequent to Mr. Berg's deposition. 13 Q. Was it yesterday? 14 A. No, no. It was -- received it I d o n 't 15 remember exactly when. A couple weeks ago. 16 Q. Why don't you tell the jury just generally 17 what's in Plaintiff's Deposition Exhibit Number 13. 18 A. It contains first a copy of the 19 Occupational Health and Safety Act of 1970. It 20 contains a brochure entitled What You Must Know About 21 The New Occupational Safety and Health Law. It then 22 contains a series of GATX memoranda. The first is 23 from J.R. Scanlon dated May 26, 1971. 24 Q. Who was Mr. Scanlon? CERTIFIED REPORTING COMPANY (312) 922-1666 14 1 A. Mr. Scanlon was the president and chief -- 2 excuse me, I 'm getting caught on my wire -- president 3 and chief operating officer of General American 4 Transportation Corporation which was -- which is 5 today known as GATX Corporation. 6 Q. And if you know was the purpose of that 7 memoranda -- memorandum to distribute the OSHA 8 statute and regulations? 9 A. The purpose of the memoranda was to notify 10 the distribution list of the new law which was new at 11 that time and attached a memoranda to it stating 12 company policy. The distribution list is -- were the 13 divisional vice-presidents. 14 Q. All right. And this was sometime in 1971? 15 A. Yeah. May 1971. 16 Q. And this was related to what perhaps would 17 be commonly known as the OSHA Act? 18 A. Yes. 19 Q. In any event, attached to that memoranda 2 0 are compliance guidelines and then just a series of 21 memoranda regarding the law and the requirements of 22 the company under the law. There is then a 23 memorandum, also from -- this is August 1971, from 24 P.A. Gatte, G-a-t-t-e, who I understood from people CERTIFIED REPORTING COMPANY (312) 922-1666 15 1 was the -- who is deceased but was the person 2 responsible for health and safety at that time. 3 Q. What was his position if you know? 4 A. That I don't know. I just -- people 5 just -- you ask who is responsible, they always 6 mentioned Mr. Gatte's name. 7 Q. All right. 8 A. Following that is some articles and then 9 some BNA reports all regarding OSHA -- 10 Q. BNA being the Bureau of National Affairs? 11 A. Affairs, correct. Additional memoranda 12 from Mr. Gatte to all locations which would be 13 throughout all the company and then copies of law -- 14 excuse me, federal regulations. 15 Q. The federal regulations setting out the 16 implementation of the Act; is that correct? 17 A. Well, the regulations of May 29, 1971 and a 18 number of pages. 19 Q. All right. Well, what is your 20 understanding of what those regulations are? 21 A. They are the standards, the federal 22 standards under OSHA. 23 Q. Were these standards -- was GATX expected 24 to know the content of these standards as it related CERTIFIED REPORTING COMPANY (312) 922-1666 16 1 to its industrial operations? 2 MR. DANIELS: Object to the form. 3 THE WITNESS: I really don't understand. 4 BY MR. SWARTZ: 5 Q. And, please, any time I ask a question that 6 you don't understand, let me know and I will attempt 7 to rephrase it. What was the purpose for 8 distributing the regulations? 9 A. That I -- I'm assuming it was to inform the 10 recipients of the requirements of the law. 11 Q. Were the recipients expected to follow the 12 requirements of the law? 13 A. The policies in here imply that it was the 14 intention of senior management to other senior 15 management to the operating management that the 16 primary responsibility for compliance with the law 17 starts with local management level. And I'm assuming 18 that the intention is that the company comply with 19 that law. 20 Q. All right, sir. What, if any, involvement 21 during any of these time periods about which you are 22 here to testify was the general counsel's office 23 involved in the General American Transportation's 24 goal to satisfy and follow the law as it relates to CERTIFIED REPORTING COMPANY (312) 922-1666 17 1 OSHA? 2 A. Can I sort of a narrative? 3 Q. Yes. 4 A. The way as all of us who have spoken to 5 which covers the period from 1961 through 1975 recall 6 the management of the Law Department, the Law 7 Department consisted of a few lawyers, as many as 8 four, a general counsel, Mr. Rothschild, who reported 9 to an executive vice-president who was also a lawyer, 10 Mr. Jack Levy, L-e-v-y. 11 The Law Department, the lawyers, were 12 used on a project as assigned. Mr. Levy and 13 Mr. Rothschild were responsible for the legal, you 14 know, management -- or the management of the legal 15 affairs of the company. They would have used the Law 16 Department as they wanted to or they would have used 17 outside counsel. 18 None of us who I have spoken to, the 19 three people, worked on safety matters. We assumed 20 that Mr. Rothschild and Mr. Levy either asked someone 21 else in the Law Department or one of the law firms 22 that would be used to get this information. 23 Q. Now, you have addressed part of the topic 24 area number two and that are federal requirements and CERTIFIED REPORTING COMPANY (312) 922-1666 18 1 regulations, laws, and statutes related to industrial 2 and occupational health and safety matters. What are 3 you able to tell the jury about state requirements, 4 regulations, rules, laws, statutes, or standards? 5 A. That I was able to find no information on. 6 I have no information on that. 7 Q. Did General American Transportation 8 Corporation have any responsibility to follow any 9 state laws? And I'm going to use that as an 10 abbreviation, that's laws, regulations, standards, et 11 cetera, et cetera concerning occupational safety and 12 health. Did it have an obligation to follow any 13 state laws prior to the passage of the Federal OSHA? 14 MR. DANIELS: Object to the form. Lack of 15 foundation. You may answer if you know. 16 THE WITNESS: I'm assuming if laws were in 17 place that we would have an obligation to follow 18 them. But I have no information regarding that 19 period of time whether there were laws and 20 regulations in place from my conversations, my 21 personal observations, and the records I was able 22 to see, 23 BY MR. SWARTZ: 24 Q. If there were Ohio regulations for the CERTIFIED REPORTING COMPANY (312) 922-1666 19 1 prevention and control of diseases resulting from 2 exposure to toxic fumes, vapors, mists, gases, and 3 dust, would you expect General American 4 Transportation Corporation to be aware of them? 5 A. I would expect that Mr. Levy or 6 Mr. Rothschild would have known of them. 7 Q. And if there were in existence the legal 8 requirements for prevention and control of industrial 9 public health hazards for the State of Ohio, would 10 you expect General American Transportation 11 Corporation to be aware of those? 12 MR. DANIELS: Object to the form. You may 13 answer. 14 MR. SWARTZ: What's the basis? 15 m r . DANIELS: Calls for a hypothetical. You 16 can answer. 17 THE WITNESS: If -- I mean I'm assuming that 18 the management in their relations with the various 19 law firms would have been aware of the legal 20 requirements to General American. 21 BY MR. SWARTZ: 22 Q. L e t 's change it from the hypothetical as 23 Mr. Daniels seems to have a problem with that. Let 24 me ask this specifically. Was General American CERTIFIED REPORTING COMPANY (312) 922-1666 20 1 Transportation Corporation aware of the legal 2 requirements for the prevention and control of 3 industrial public health hazards promulgated by the 4 Division of Industrial Hygiene of The Ohio Department 5 of Health in Columbus, Ohio? 6 MR. DANIELS: When? Object. 7 MR. SWARTZ: That became effective in 1946. 8 THE WITNESS: I have no -- I can't -- I don't 9 know. 10 BY MR. SWARTZ: 11 Q. General American Transportation Corporation 12 operated manufacturing facilities in Ohio in 1946, 13 didn't it? 14 A. Correct. 15 Q. And that facility specifically was located 16 on the Ohio-Pennsylvania border in Masury, 17 M-a-s-u-r-y, Ohio and Sharon, Pennsylvania; is that 18 correct? 19 A. Correct. 20 Q. General American Transportation Corporation 21 had facilities in other states as well other than the 22 Masury, Ohio facility, didn't it? 23 A. Correct. 24 Q. And would you expect General American CERTIFIED REDDD'nTMr 21 1 Transportation Corporation to be aware of the state 2 laws and regulations that applied to occupational 3 safety and health in each state in which it was 4 conducting industrial and/or manufacturing 5 operations? 6 A. Again I would say Mr. Levy and 7 Mr. Rothschild would have the responsibility for 8 that. I presume they were aware of the laws. 9 Q. Are there any files maintained by General 10 American Transportation Corporation that relate to or 11 that contain copies of laws, statutes, regulations 12 concerning industrial and occupational health and 13 safety? 14 A. You mean general -- you don't mean the Law 15 Department files? 16 Q. Well, first let's start with the Law 17 Department. Does the Law Department have a book or a 18 file or anything that has state occupational, safety, 19 and health regulations in it? 20 A. We have some files, obviously, that deal 21 with specific matters that may have copies of -- 22 copies of laws, but most of our source material today 23 is taken off the centralized data -- without wanting 24 to use trade names, centralized data processing like CERTIFIED REPORTING COMPANY (312) 922-1666 22 1 Westlaw and Lexus. We get most of our state 2 information that way. 3 Q. If copies -- and I ask this almost with the 4 indulgence of defense counsel and he has been nice to 5 let me go into this because one of the areas we 6 deposed you on a month ago was records and things of 7 that nature, so I don't think that it's necessarily 8 unreasonable to ask you this question because it kind 9 of overlaps with the one w e 're talking about now. 10 And certainly if there's an objection, I will not 11 pursue this further. 12 But let me ask you this. Did General 13 American Transportation Corporation maintain files on 14 state health and safety regulations at any time? 15 A. The only information I have on that are the 16 indices from the file, the materials that are in 17 storage. If you talk about are there copies of laws, 18 people have copies of regulation and files, I don't 19 know the answer to that question. It would be -- it 20 would relate to what the particular people who had 21 that responsibility have put in their files. I know 22 that there's BNA Reporters and that kind of thing. 23 Q. How far back do the BNA Reporters go if you 24 know? CERTIFIED REPORTING COMPANY (312) 922-1666 23 1 A. All I know is they're current. I do n 't 2 know how far back they go. 3 Q. All right. And those are located in the 4 Legal Department? 5 A . Some -- I d o n 't think we have -- we may 6 have a CCH Label Reporter. I know that some of the 7 subsidiaries get their own services for their own 8 people. 9 Q. Do you know whether or not General American 10 Transportation received the monthly bulletins from 11 the United States Department of Labor? 12 A. I don't know that. 13 Q. How about the Illinois Department of Labor? 14 A. I d o n 't know that. 15 Q. To which department if not the Law 16 Department would those types of documents go, that 17 is, monthly labor reports from the federal and state 18 Departments of Labor? 19 A. I don't know that. 20 Q. I believe at your previous deposition you 21 testified about where you located a copy of the 22 health hazard evaluation that NIOSH conducted in 23 Masury, Ohio? 24 A. That is correct. CERTIFIED REPORTING COMPANY (312) 922-1666 24 1 Q. In what file was that maintained? 2 A. At the time that we were responding to the 3 discovery request I went to the health and safety 4 people at General American and we went through a list 5 of index of boxes and tried to figure out which ones 6 related to health and safety and asked for them. I 7 d o n 't remember the box name or the box number, to be 8 honest. 9 There were about four or five boxes 10 that looked that were responsive. And we went 11 through them. The material in most of them was not 12 responsive. It was odd material. But in a manila 13 folder in one of the boxes was this report. 14 Q. Do you have a list of those boxes, those 15 four or five boxes? 16 A. No. 17 Q. Is there any way you can determine which 18 four or five boxes you looked at when you were 19 attempting to obtain information on occupational and 20 safety -- 21 A.Probably go back to the list and try and 22 figure out which ones they were. That's about all. 23 MR. SWARTZ: All right. Sir, I think that is 24 all. And I have attempted to keep my promise to CERTIFIED REPORTING COMPANY (312) 922-1666 25 1 make this short. 2 MR. DANIELS: I don't have anything. 3 THE WITNESS: Thank you. 4 THE VIDEOGRAPHER: This concludes the 5 deposition of John Levin. Off the record at 6 9:53 a.m. 7 (The deposition was concluded.) 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 CERTIFIED REPORTING COMPANY (312) 922-1666 26 1 STATE OF ILLINOIS 2 COUNTY OF COOK ) ) SS. ) 3 I, Rhonda Snyder, CSR, RPR, and Notary Public within and for the County of Cook and State of 4 Illinois do hereby certify that on Thursday, August 27, 1998 at the hour of 9:27 a.m. personally appeared 5 before me at General American Transportation Corporation headquarters, 500 West Madison Street, 6 Suite 4300, Chicago, Illinois, John D. Levin, in a certain cause now pending and undetermined in the 7 court of Common Pleas, Trumbull County, Ohio. I further certify that the said 8 witness was first duly sworn to testify to the truth, the whole truth and nothing but the truth in the 9 cause aforesaid; that the testimony then given by said witness was reported stenographically by me in 10 the presence of the said witness, and afterwards was transcribed via computer-aided transcription, and the 11 foregoing is a true and correct transcript of the testimony so given by said witness. 12 I further certify that the signature of the witness to the foregoing deposition was not 13 waived b y agreement of counsel. I further certify that I am not 14 counsel for nor in any way related to any of the parties to this suit nor am I in any way interested 15 in the outcome thereof. IN TESTIMONY WHEREOF, I have hereunto 16 set my hand and affixed m y notarial seal on September 4, 1998. 18 20 Rhonda Snyder, CSR, RPR 21 state of Illinois C.S.R. License No. 084-003421. 23 24 CERTIFIED REPORTING COMPANY (312) 922-1666