Document MG7BJKJ6evQGVb96mOb7edQOy

1 TORGER S. OAAS 2 ATTORNEY AT LAW Post Office Box 76 3 Lewistown, Montana 59457 (406) 538-2338 4 5 WILLIAM E. BERGER ATTORNEY AT LAW 6 P.O. Box 506 7 Lewistown, Montana 59457 (406) 538-9272 8 Attorneys for Plaintiffs 9 10 11 12 JON OLDENBURG ATTORNEY AT LAW 505 West Main; Suite 309 Lewistown, Montana 59457 (406) 538-2242 CRAIG BUEHLER ATTORNEY AT LAW 505 West Main; Suite 210 Lewistown, Montana 59457 (406) 538-2466 RECEIVED MAR 2 8 2007 BROWNING KALECZYC BERRY &HOVEN, PC 13 MONTANA TENTH JUDICIAL DISTRICT COURT, FERGUS COUNTY 14 15 MARTY PAULSON, WILLIAM J. HAUGEN, HARRY FELTON, RAY 16 ROBISON and WARD BURLEIGH, 17 President; BURLEIGH ANGUS RANCH, INC., Individually and For all 18 Persons Similarly Situated, Cause No. DV-2004-55 Hon. Kurt Krueger 19 Plaintiffs, 20 V. 21 22 MONSANTO CHEMICAL COMPANY n/k/a PHARMACIA, 23 MONTANA DEPARTMENT OF FISH, WILDLIFE AND PARKS, 24 and JOHN DOE PAINT COMPANIES 25 and DISTRIBUTORS I through X, PLAINTIFFS' SEVENTH SET OF DISCOVERY REQUESTS TO DEFENDANT, MONSANTO CHEMICAL COMPANY n/k/a PHARMACIA 26 Defendants. [ 1i 7 HARTOLDMON0029134 1 TO: PHARMACIA CORPORATION f/k/a MONSANTO CHEMICAL 2 COMPANY and their attorneys, DANIEL HOYEN; CATHERINE LAUGHNER; ADAM 3 MILLER: 4 YOU WILL PLEASE TAKE NOTICE that Defendant, PHARMACIA CORPORATION, is hereby required, pursuant to Rules 33, 34 and 36 of the Montana 5 Rules of Civil Procedure, to serve upon the undersigned within thirty (30) days after service of this notice, their answers in writing and under oath to the following. 6 The information requested herein is not restricted to your personal knowledge, but 7 includes information in the possession of your attorneys and extends to information which you or your attorneys can obtain upon reasonable inquiry. These discovery requests shall 8 be deemed continuing so as to require supplemental answers to be filed promptly upon obtaining further information between the time answers are served and the time of trial. 9 GENERAL DEFINITIONS AND INSTRUCTIONS "Defendant" means PHARMACIA CORPORATION f/k/a MONSANTO 10 CHEMICAL CO. and all other persons acting on their behalf. "Document" or documents" is used herein within its broadest sense as used in Rule 34(a)(1), and thus includes without limitation originals and non-identical copies of letters, telegrams, memoranda, reports, 12 drafts, notes, summaries or records of conversations and interviews, minutes of meetings, diary entries, notebooks, agreements, printed publications, drawings and sketches, graphs, 13 charts, photographs, brochures, intra and inter-company communications, marginal 14 comments, sales literature, computer inputs, outputs and tapes, and all other writings, including tapes, phone records, and electronic and other data compilations from which 15 information can be obtained, translated, if necessary, by plaintiff through detection devices into reasonably usable form. 16 "Communication" means the transmission, sending and/or receipt of information of any kind by and/or through any means including, but not limited to speech, writings, 17 language (machine, foreign or otherwise), computer electronics of any kind, magnetic tape, 18 video tape, photographs, graphs, symbols, signs, magnetic disks, sound, radio and/or video signals, telephone, teletype, telecommunication, telegram, microfilm, microfiche, 19 photographic film of any type and/or other media of any kind. "Identify" as applied to a communication means that the following information 20 shall be provided: (a) the date(s) on which such communication took place; 21 (b) the location(s) at which such communication took place; 22 (c) all persons having knowledge of such communication; (d) the date, author, addressee and type of each document (e.g., letter, 23 memorandum, telegram, chart, computer input and output, photograph, sound reproduction, etc.) referring and/or relating to such communication and the last known 24 custodian(s) and location(s) of each document. "Identify" as applied to a document means that the following information shall be 25 provided: 26 (a) the date appearing on such documents, and if no date appears thereon, the answer shall so state and shall give the date or approximate date such document was prepared; HARTOLDMON0029135 1 (b) the identifying or descriptive code number, file number, title or label of such document; 2 (c) the general nature or description of such document (i.e., whether it is a 3 letter, memorandum, drawing, etc.) and the number of pages of which it consists; (d) the name of the person who signed such document, and if it was not signed, 4 the answer shall so state and shall give the name of the person or persons who prepared it; (e) the name of the person to whom such document was addressed and the 5 name of each person other than such addressee to whom such document or copies thereof were given or sent; 6 (f) the name of the person having possession, custody or control of such 7 document; (g) whether or not any draft, copy, or reproduction of such document contains 8 any postscript, notation, change, or addendum not appearing on the original of said document, and if so, the answer shall give the description as herein defined of each such 9 draft, copy or reproduction; (h) if any such document was, but is no longer, in defendant's possession or 10 subject to its control, state what disposition was made of it and when; (i) if the person's present whereabouts are unknown to defendant, state all information known to defendant that reasonably may be helpful in locating said person (for 12 example; spouse's name, children's names and addresses; and the names and addresses of other known relatives). 13 `Identify" as applied to a natural person means to give the following information; 14 (a) full name; (b) present or last known home address; 15 (c) present or last known business address and telephone number; (d) title or occupation; 16 (e) present or last known employer; (f) if the person had ever been employed by defendant, state all employment 17 positions which the person has held with defendant and the dates of each such employment 18 position; and (g) if the person's present whereabouts are unknown to defendant, state all 19 information known to defendant that reasonably may be helpful in locating said person (for example; spouse's name; children's names and addresses; and the names and addresses of 20 other known relatives). "Representative" as applied to a legal entity means any officer, agent, employer or 21 other person acting on behalf of that legal entity. 22 If any document is not produced on the grounds of attorney-client privilege or attorney work product, please furnish the following information with respect to each such 23 document: (a) State the date of the document; 24 (b) State the subject matter of the document; (c) Identify the persons who prepared the document; 25 (d) Identify all persons who received the document; 26 (e) Identify all persons who are in the possession or control of the document; (f) State in meaningful terms the privilege(s) claimed. 3 HARTOLDMONOQ29136 1 The terms '`relating to5* or `'relate to55 shall mean, consist of, refer to, reflect on, arise out of, or be in any way or manner legally, factually, or logically connected with the 2 matter discussed. 3 The term "person5" shall mean any natural person, governmental body, governmental agency, corporation, general or limited partnership, joint venture, and/or any 4 other form of business organization or association, whether or not said person is a party to this action or in any way connected to a party in this action. 5 The term "nature55 as in the nature of something shall mean the essence or characteristics of the thing. 6 The term "basis55 or "`bases55 as in the bases for some allegation shall mean the 7 cause, grounds or reasons for such allegation. When stating the basis or bases for any allegations, identify each and every communication and document and set forth each and 8 every- act and statement on which you rely. When stating the basis or bases for an allegation identify each person who possesses knowledge of facts, which relate to your 9 answer and give the substance of the knowledge he possesses. The term '`meeting55 shall mean and include any contemporaneous presence of any 10 natural persons, whether or not such presence was by chance or prearranged, or whether or 11 not the meeting was formal or informal or in connection with some other activity. The term "communication" shall mean and include any transmission or exchange of 12 information other than fact to face, between two or more persons, whether orally or in writing, and including without limitation any conversing, discussing or propounding of 13 views or ideas by means of any document, telephone, telex, telecopies, cable, video or 14 audio transmission device or some other electronic or other medium Without limitation of the term "possession, custody, or control, "a document is 15 deemed to be within your possession, custody or control if you physically possess the document or a copy thereof or if you have access to or the right to secure a document or a 18 copy thereof from any other person or public or private entity having physical possession thereof. 17 Big Spring Creek means that water course that is the subject of this litigation as 18 identified in the risk assessments done by Camp, Dresser & McKee. 19 REQUEST FOR PRODUCTION NO. 15: Please produce a copy of all 20 "Publications - Selected Technical Reports (sole or major author)55 identified 21 beginning on page 9 through page 13 of Appendix A to the expert report of Neil S. 22 23 Shifrin/Gradient Corporation dated July 20. 2006. A copy of the listing of the 24 documents described above is incorporated herein by reference. 25 RESPONSE: 26 REQUEST FOR PRODUCTION NO. 16: Please produce a copy of the 4 ifi-... ... HARTOLDMON0029137 1 transcript of the Daubert Hearing in Keilum et al. v. Kuhiman Corp. et al. identified 2 as No. 10 in Neil S. Shifrin's testimony of past four years in Appendix B to the 3 expert report of Neil S. Shifrin/Gradient Corp. dated July 20, 2006. A copy of this 4 5 list showing item No. 10 is attached hereto and incorporated by reference herein. 6 RESPONSE: 7 REQUEST FOR PRODUCTION NO, 17: A copy of the deposition of Neil S. 3 Shifrin taken in Keilum et al.v. Kuhiman Corp. et al. identified as No. 17 to the list 9 10 of depositions given by NSS contained in Appendix B to the expert report of 11 NSS/Gradient Corp. dated July 20, 2006. A copy of the description of this 12 deposition from Appendix B is attached hereto and incorporated by reference 13 herein. 14 15 RESPONSE- 16 INTERROGATORY NO. 9: On page 9 of the expert report of Louis Wilde 17 dated July 21, 2006 he indicated that he has analyzed as an expert witness the 18 effects of contamination of streams and rivers on property values "a number of 19 times". 20 21 Please identify by title of court and cause the cases to which Mr. Wilde is 22 referring to as well as the identity of counsel for all of the parties involved in those 23 cases. 24 ANSWER: 25 28 REQUEST FOR PRODUCTION NO, 18: Please produce the expert witness5 5 ;7 HARTOLDMON0029138 1 reports prepared by Mr. Wilde for the cases described above and as mentioned on 2 page 9 of his report in this case. 3 RESPONSE: 4 5 DATED this 2% day of March, 2007. 6 i/ \\ 7 Wy. y-OiXA. 8 TORGER ^AAS 9 Co-Counsel for Plaintiffs 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 6 HARTOLDMON0029139 1 2 CERTIFICATE OF SERVICE This is to certify that the foregoing was duly served upon the following counsel of 5 record via nU. eS. Postal Sendee on *thuisc 0f March, 2007: 4 Daniel Hoven Catherine A. Laughner 5 Browning, Kaleczyc. Berry' & Hoven P.O. Box 1697 6 Helena, MT 59624 7 Maxon R. Davis 8 Davis. Hatley, Haffeman & Tighe P.O. Box 2103 9 Great Falls, MT 59403 10 Paul D. Johnson 11 Assistant Attorney General P.O. Box 201440 12 Helena, MT 59620-1440 13 Thomas M. Carney 14 Jerry' K. Ronecker Adam Miller 15 Husch & Eppenberger, LLC 190 Carondelet Plaza, Suite 600 18 St. Louis, MO 63105 17 Stephen R. Brown 13 Garlington, Lohn, Robinson P.O. Box 7909 19 Missoula, MT 59807 20 Michael Black Attorney at Law 21 P.O. Box 2338 22 Missoula, MT 59806-2338 23 24 25 26 7 ... . HARTOLDMON0029140 Neil S. Shifrin, page 9 Shifrin. NS. 1984. "Oils from micrpalgae." Biotechnology for the Oil and Fat Industry (Eds: C. Rutledge er a/.). Am. Oil Chem. Soc. Press. Shifrin, NS; and Chisholm, SW. 1981. "Phytoplankton lipids: interspecific differences and environmental influences." Journal ofPhycot. 17:374-384. Shifrin, NS; Chisholm, SW. 1980, "Phytoplankton lipids." Algae Biomass: Production and Use (Eds: G. Shelef and C.J. Seeder), Elsevier North Holland Biomedical Press, Amsterdam. Shitrin, NS. 1480. "The measurement of dissolved organic carbon released by phytoplankton." Estuaries 3(3):230-233. . Publications - Selected Technical Reports (Sole or Major Author) 2005. "Historical Operations and Linkage to Environmental Contamination at the Keene, NH Former MGP." Prepared for McLane, Graf. Raulerson & Middleton, P.A. September. 2005. Expert Report: Historical Practices and Environmental Conditions at Four Brooklyn Union Gas Former MGPs: Coney Island. Greenpoint, Clifton, and Citizens." (Three Volumes) Prepared for Dickstein, Shapiro, Morin & Oshinsky, LLP. September. 2005. "Rebuttal Report: Historical Contamination at the Manchester, NH Former MGP." Prepared for McLane, Graf, Raulerson & Middleton. August. 2005. "Supplemental Expert Report: Historical Contamination at the Manchester, NIi Former MGP." Prepared tor McLane, Graf, Raulerson & Middleton. April. 2005. "Amended Expert Report: Historical Practices and Environmental Conditions at Four Boston Gas Former MGPs: Commercial Point, South Boston, Braintree & Everett," (Two Volumes) Prepared for Dickstein, Shapiro, Morin & Oshinsky. March. 2005. "Perchlorate at Olin's Morgan Hill Flare Plant (Paitnisano, et al v Oiin Corporation, et ai)" Prepared for llusch & Eppenberger, LLC. February. 2005. "Capitol Cleaners PCE Spill Study Report, Dover Gas Light Superfimd Site [US BPA ID ?? DED9S0693550; DE-0057/DE-1018], Dover, Delaware. (Three Volumes) Prepared for FirstE n e rgy. jan uary. 2004. "Expen report: Historical Contamination at the Nashua, NH Former MGP [re: Energy-North Natural Gas, Inc. v. Century Indemnity Co.}" Prepared for McLane, Graf, Raulerson & Middleton, October. 2004. "Historical Practices and Environmental Conditions at Four Boston Gas former MGPs: Commercial Point, South Boston, Braintree, & Everett (Two volumes) (Expert report)." Prepared for Dickstein, Shapiro, Morin, & Oshinsky. November. 2004. "Standard of Care for Arsenic at the Ottawa Glass Plant," Prepared for Pepper Hamilton, LLP. August, 2004. "Supplemental Affidavit of Dr. Neil S. Shifrin." Submitted to United States District Court, District of Massachusetts, Civil Action No. 02-12062RWZ. May. 2004. "Historical Practices and Environmental Conditions St. Augustine Former MGP." Prepared for McKenna, Long & Aldridge. March. 2004. "Expert Report Historical Contamination at the Manchester, NH Former MGP." Prepared for McLane, Graf, Raulerson & Middleton, P.A. March. HARTOLDMON0029141 Neil S. Shifrin, page 10 2004. "Affidavit of Dr. Neil S. Shifrin." Submitted to United States District Court, District of Massachusetts, Civil Action No. 02-12062RWZ. February. 2003. "Expert Report Historical MGP amt PCB Contamination Releases at Consolidated Edison Astoria. NY Facility." Prepared for Dickstein, Shapiro, Morin, & Oshinsky. October. 2003. "Expert Report Historical Practices and Environmental Conditions at Three Consolidated Edison Former MGPsi Hunts Point, Pelham, and West IS1" Street." Prepared for Dickstein, Shapiro, Morin, & Oshinsky. October. 2003. "Affidavit of Dr. Neil S. Shifrin [re: Energy-North Natural Gas, Inc. (Nashua MGP) v. The Home- Insurance Co.]." Submitted to New Hampshire Superior Court, Hillsborough, Northern District, Civil No. 99-E-0075. January 15. 2003. ''Affidavit of Dr, Neil S. Shifrin [re: EnergyNorth Natural Gas, Inc. (Dover MGP) v. American Home Assurance Co., et al,]." Submitted to US District Court, District of New Hampshire, Civil No. C-99-502-JD. May 2. 2002. "Rochester Gas and Electric Corporation's East and West Station Former Manufactured Gas Plants - Response Action Recoverable Costs." Prepared for Saul Ewing, LLP. November 14. 2002. "Supplemental affidavit of Dr. Neil S. Shifrin [re: EnergyNorth Natural Gas, Inc. (Laconia MGP) v. Lloyd's, Underwriters at London, et at]." Submitted to US District Court, District of New Hampshire, Civil No. 97-064-M. November 4. 2002. "Expert Report Historical Contamination Releases at the Dover, NH former MGP." Expert report prepared for Me Lane, Graf, Raulerson and Middleton, P.A. October 15. 2002. "Expert Report Historical Contamination at the Nashua, Nil Fortner MGP." Expert report prepared for McLune, Grnf, Raulerson and Middleton, P,A. October 3. 2002. "Affidavit of Dr. Neil S. Shifrin [re: EnergyNorth Natural Gas, Inc. (Nashua MGP) v. Century Indemnity Co., et al.j." Submitted to US District Court, District of New Hampshire, Civil No. 99-049-M. September 12. 2002. "Affidavit of Dr. Neil S. Shifrin [re: EnergyNorth Natural Gas, Inc. v. Lloyd's, Underwriters at London, et al. ]." Submitted to US District Court, District of New Hampshire, Civil No. 97-064-M. July !2. 2002. "Affidavit of Dr. Neil S. Shifrin [re: EnergyNorth Natural Gas, Inc. v. Lloyd's, Underwriters at London, et at,]," Submitted to US District Court, District of New Hampshire, Civil No. 97-064-M. July 9. 2002. "Riverfront Development Sire Remedy Scoping Study." Prepared for Kansas City Port Authority. Kansas City, Missouri. May 28. 2002. "United Gas Improvement Company and the Manchester, NH MGP." Expert report prepared for MeLane, Graf, Raulerson and Middleton, P.A. May 14. 2002. "Affidavit of Dr. Neil S. Shifrin [re: EnergyNorth Natural Gas, Inc. v. Associated Electric & Gas Insurance Services, Lid., et al.]." Submitted to US District Court, District of New Hampshire, Civil No. 0-95-591-B. March 8. 2001. "Historical waste practices of (he Rexnord/Chain Beit Company, Springfield, Massachusetts." Expert report prepared for Roberts, Carroll, Feldstein and Peirce. August 29. HARTOLDMON0029142 Neil S. Shifrin, page 11 200i, "Kaiser-Nelson Steel and Salvage Company MGP Demolition Allocation of Environmental damages." Expert report prepared for Fitzgerald, McGroarty and Lipari, P.A. August 13. 2001. "Pfizer's Ledyard and Vigo Landfills." Expert report prepared for Dickstein, Shapiro, Morin and Oshinsky (New York, NY); McCarter and English (Newark, NJ), January 22. 2000. "New Jersey Natural MGP Demolition." Expert report prepared for Fitzgerald & McGroarty, P.A. November 28, 2000. "Accurate Die Casting: NCP Consistency of the Environmental Response Actions." Expert report prepared for LeBoeuf, Lamb, Greene & MacRae, LLP. June 2. 2000. "Dover Gas SuperfonJ Site Proposed Plan to Implement a Natural Attenuation Protocol." Expert report prepared for Saul, Ewing, Remick, and Saul LLP. May 31. 2000. "Long Island Lighting Company Seven Former MGPs: Historical Practices and Environmental Conditions." Expert report prepared for Dickstein, Shapiro, Marin & Oshinsky. May 26. 2000. "Dover Gas Superfund Site Supplemental Report," Expert report prepared for Saul, Ewing, Remick and Saul LLP. January' 20. 1999. "Release Dates at A-Z Automotive." Expert report prepared for New Jersey, Department of Environmental Protection. October 15. 1999. "Energy North's Former Concord, New Hampshire MGP: Historical practices and environmental conditions." Expert report prepared for McLane, Graf, Raulerson, and Middleton. .September 29. 1999. "Preliminary Report on Allocation of the Nease Superfund Response Costs." Expert report prepared for Spriggs and Hollingsworth (Washington, DC), June 10. 1999. "Energy North's Former Messer Street MGP, Laconia, New Hampshire: Historical practices and environmental conditions," Expert report prepared for McLane, Graf, Raulerson, and Middleton, January 8. 1998. "PCBs and the Sangamo Electric Company." Expert report prepared for Howrey & Simon (Washington, DC), March 31. 1998. "Historical Waste Practices of the Manufactured Gas Industry, South jersey Gas Company, and its Predecessors. Volume i: MGP History and Practices and Volume II: Individual Site Descriptions (13 Sites)," Expert reports prepared for Nugent, Fitzgerald, McGroarty & McFadden (Linwood, NJ). January 14. 1997. "The Role of Triangle Wire Company's Waste in the Buckeye Reclamation Landfill." Expert report in cost allocation litigation. September 12. 1996. "Expert Report, Rhone Poulenc, Inc. v. International Insurance Company and International Surplus Lines Insurance Company." Report on Superfmid cost recovery for 5 sites. 1994, Report on Environmental Cleanup Costs and Liabilities at 45 Gas field Sites. Confidential report to client. 1994 Affidavit on Cost Allocation Among PRPs at the Fields Brook Superfmid Site. 1994, Affidavit on PCB Toxicity and Biodegradability in Support of PRP Cost Allocation Arbitration at the Fields Brook Supertlmd Site. HARTOLDMON0029143 Neil S. Shifrin, page 12 1993. Remedial Action Plan for a Former Manufactured Gas Plant Site (Muskegon, Mi). 1993. "Historical Waste Practices of industry and South Jersey Gas Company's Kirkman Boulevard MGP." Expert Witness Report Prepared for Nugent, Fitzgerald, McGroarty & McFadden. July 1. 1993. "Report Prepared on Behalf of Howrey & Simon for H.M. Holdings, Inc. v. Lumbermens Mutual Casualty Company ei a!., No. L-96187-87 (NJ. Super. Ct. Law Div.)." Expert Witness Report on PCBs in paper manufacturing. March 30. 1989. "Lake Ontario TCDD Bioaeetumtlauon Study." Final report of research program by US EPA, NY DEC, NY DOH and Occidental Chemical Corporation, presented to the US District Court of Western N Y. 1988. "Potential Contaminant Loadings to the Niagara River from US Hazardous Waste Sites." Report to the US EPA. February 29. 1987. "Description of the Falls Street Tunnel Database." Report to the City of Niagara Falls. 1987. "Cost Apportionment for a Site with Several PRPs." Confidential report prepared for client counsel in regards to a dioxin CERCLA site in Missouri. 1987. "Plans and Protocols for the Lake Ontario TCDD Bioaccumulation Study." Report to US EPA, Region II (9 volumes). 1985. Affidavit describing the environmental chemistry of the Hyde Park Landfill (Niagara Falls, NY) and the remedial plan effectiveness monitoring programs. Civil Action No. 79-989, US District Court for Western NY. November 1985. 1984. Affidavit describing the technical aspects of the landfill remediation plan. United States of America, et a/., Plaintiffs v Hooker Chemicals and Plastics Corporation et a!., (S-Area Landfill). Civil Action No. 79-988, US District Court for Western NY. April 1984, 1981 - 1990. Over 50 technical reports and reviews for US EPA regarding confidential settlement negotiations of hazardous waste landfill remediations in Niagara Falls, NY. Topics include chemical migration in ground water, landfill remedies, environmental monitoring, and the bioconcentration of hazardous chemicals in fish. 1981. "Ground Water Protection by Recharge Zone Management." Report to the Office of Water Research and Technology, US Department of the Interior, NT1S Publication PB82-197948, 1981. "Municipal Wastewater Control Technology - Research Strategy 1981 - 1985." Report to the US Environmental Protection Agency, Office of Research and Development, Washington, DC. ~ 1980. Phytoplankton Lipids: Environmental Influences on Production and Possible Commercial Applications. Ph.D. Thesis, MIT, Cambridge, MA. 1976, "The Impact of the Federal Water Pollution Control Act (PL91-500) on the Charles River and Boston Harbor," Report to the National Commission on Water Quality by Environmental Research and Technology, Inc. (available through NTFS). 1976. "Final Report on the Charles River/Storrow Lagoon Demonstration Plant." Report to the Commonwealth of Massachusetts, Metropolitan District Commission, Boston, MA. HARTOLDMON0029144 Neii S, Shifrin, page 13 1976. "Pretreatment Guidance Manual for State and Areawide (208) Water Quality Planning Agencies." Report to the US Environmental Protection Agency, Water Planning Division, Contract No. 68-01-3559. HARTOLDMON0029145 Appendix B Neil S. Shifrin, Ph.D. Paulson et al. v. Monsanto Chemical Co, et al. Gradient corporation HARTOLDMON0029146 HARTOLDMON0029147 * Witness for party noted w/ .1 5 I % I ! I i.. V2i E "3 I I? SI & r- a i3 / is! 5I 'i i .1 II. V. I I 2 1 <4 s: o ! s S3 i 4 1 Cr< < 5 s Neil S. S iiifirm , P h i). - lesiim oiiv o f Pasi 4 Years ' Witness for party noted wI ` ** P: Protected; P I: Probably Protected; N: Not Protected; C: Confidentiality Agreement; A; Transcript Available at Gradient (blank: unknown) HARTOLDMON0029148 ............ i .............. .................. . ..................................... ...... ............... Name _______ Phone 005, Jun Boston Gas Co. U S. District Court o f ii/b/B Keyspan Massachusetts, C ivil Deposition Standard o f uan.% MGP insurance claim (Boston MGPs) Davfd L. Bikind. Esq. 202-785-9700 Energy Delivery Action No. CGG2G62RWZ New England* v v *5 HARTOLDMON0029149 * Witness for party noted w /" ** P: Protected; P I: Probably Protected; N: Not Protected, C: Confidentiality Agreement; A: Transcript Available at Gradient {blank: unknown)