Document RJbKBY5oG8vVnoN4Vm9Eb7rB

FILE NAME: RT Vanderbilt (RTV) DATE: 2007 July 3 DOC#: RTV253 DOCUMENT DESCRIPTION: Legal - Deposition of Thomas Rogers ANDERSON CIRCUIT COURT DE THE STATE OF KENTUCKY THIS DOCUMENT RELATES TO THE FOLLOWING CASE: JOHNNY FRANKLIN, INDIVIDUALLY, And as Administrator of the Estate of FLORA FRANKLIN, t Plaintiffs, 1 8 - against - 9 10 ;e n e r a l .m o t o r s c o r p . et al, 11 Defendants. 12 .13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO . 04-CI-00274 DEPOSITION UNDER ORAL EXAMINATION OF THOMAS ROGERS X Kimberly S. Plummer, CSR (315) 778-0187 It t) i 1 2 3 4. 5 6 7 8 9 10 11 12 13 14 13 16 17 18 19 20 21 22 23 24 20 2 Transcript of the videotaped deposition of THOMAS ROGERS, called for Oral .Examination in the above-captioned matter, said deposition being taken pursuant to Kentucky Rules of Civil Procedure, by and before Kimberly s. Plummer, Court Reporter and Notary Public in and for the State of New York; taken at the Best Western Carriage House, 300 Washington Street, Watertown, New York on Tuesday, July 3, 2007 commencing at approximately 9:30 in the forenoon. Videograpber is Joseph O'Brien from Litigation Video Services. Kimberly S. Plummer, CSR (315) 778-0187 3 1 APPEARANCES: 2 3 SALES, TILLMAN, WALLBAUM, CATLETT SATTERLEY 1900 Waterfront Plaza 4 325 West Main Street Louisville, KY 40202 5 Attorneys for the Plaintiffs 6 HAWKINS & PARNELL 7 4000 SunTrust Plaza 303 Peachtree Street, N.E. 8 Atlanta, Georgia 30308-3243 BY: LANE YOUNG, ESQ. 9 Attorneys for Defendants, RT Vanderbilt Co., Inc. 10 STOLL, KEENON, OGDEN, PLLC 11 300 West Vine Street, Suite 2100 Lexington, Kentucky 40507-1801 12 BY: PALMER G. VANCE, II, ESQ. Attorneys for Defendant, Carquest Corp. 13 14 15 16 17 18 19 20 21 22 23 24 25 Kimberly S. Plummer, CSR (315) 778-0187 4 1 A P P E A R A N C E S : (Cont'd) 2 TELEPHONICALLY APPEARING: 3 WYATT, TARRANT & COMBS 4 500 West Jefferson Street Suite 2800 5 Louisville, KY 40202 BY; REBECCA SCHUPBACH, ESQ. 6 Attorneys for Defendants, Georgia-Pacific Corporation 7 BOEHL, STOPHER & GRAVES 400 West Market Street 8 Suite 2300, Aegon Center Louisville, Kentucky 40202 9 BY: ELSABE MEYER, ESQ. Attorneys for Defendant, Honeywell International 10 REED, WEITKAMP, SCHELL & VICE 11 500 West Jefferson Street, Suite 2400 Louisville, Kentucky 40202 12 BY: RIDLEY SANDIDGE, JR., ESQ. Attorneys for Defendant, Eaton Corporation 13 THOMPSON, MILLER & SIMPSON 14 600 West Main Street Suite 500 15 Louisville, Kentucky 40202 BY: ADAM SHADBURNE, ESQ. 15 Attorneys for Defendant, Daimler-Chysler Corp., GM Corp. and Ford Motor Corp. 17 18 19 ALSO PRESENT: 20 21 22 Frederick R. Totten Appearing with Atty. Young Mrs. Rogers (Witness's spouse) 23 24 25 n Kimberly S. Plummer, CSR (315) 778-0187 5 I N D E X TO W I T N E S S WITNESS NAME PAGE NO, THOMAS ROGERS Direct Examination By Mr. Satterley 7 Cross-Exam by Mr. Young 32 Cross-Examination by Mr. Vance 54 Redirect Examination by Mr. Satterley 55 Recross-Examination by Mr, Young 62 Redirect Examination by Mr. Satterley 62 Kimberly S. Plummer, CSR (315) 778-0187 6 1 I N D E X TO E X H X B XTS 2 3 Plaintiff's Ex. Description Page No. 4 5 1-4 Photographs 6 7 8 9 10 U 12 13 14 3 5 16 17 18 19 20 23 22 23 24 25 Kimberly S,. Plummerf CSR (315) 778-0187 7 1 VTDEOGRAPHER: This begins tape number one, 2 videotaped deposition of Thomas Rogers. Today's 3 date is July 3rd, 2007. We are on the record at 4 9:38. 5 (Deposition Exhibit Nos. 1 through 4, 6 inclusive marked for identification.) 7 8 THOMAS - q ROGERS, called as a witness, 10 having been first duly sworn, 13 testified as follows: 12 13 DIRECT EXAMINATION BY MR. SATTERLEY: 34 15 Q. Please introduce yourself to the ladies and 16 gentlemen of the jury. 17 A. Thomas Rogers, 18 Q. Mr. Rogers, where do you live? 19 A. In Harrisville, New York, 20 Q. And what is your date of birth? 21 A. July 29 -- July 7th, 1934. 22 Q . That makes you 72 years old today? 23 A. Yes. 24 Q. And you'll be 73 later this year -- later this 25 month? Kimberly S. Plurnmer, CSR (315) 778-0187 8 1 A. Yes 2 Q. And are you married? 3 A. Yes. 4 Q. And what is your wife's name? 5 A. Faith. 6 Q. And how long have you and Faith been married? 7 A. 53 years. 8 Q- And how many children do you and Faith have? 9 A. Two. 10 Q. Faith is present, too. 11 Where were you born and raised? 12 A. I was born in Theresa, New York. And I was raised 13 around Theresa and Hammond and Rosie. 14 Q- How far did you go in school? 15 A. Second year of high. 16 Q. Tenth grade? 17 A. Tenth grade. 18 Q. And did you leave school to go farming? 19 A. Well, I thought I was gonna go farming but then I 20 led better ways to make a living so... 21 Q. Did there come a point in time that you went to 22 for a company called Gouverneur Talc Company? 23 A. Yeah. Q. When did you first go to work for them? A. It was April of '63, I think. Kimberly S. Plummer, CSR (315) 778-0187 9 1 Q. And what was your job title when you first went to 2 work for that company? 3 A. Laborer. 4 Q. And what type of company was this? 5 A. It was a talc company. 6 Q. And where was it located, what city or what state? 7 A. In Balmat. 8 Q. And how long did you continue to work for that 9 company? 10 A. I worked 26 years. 11 Q. And so approximately -- approximately when did you 12 leave the company? 1 13 A. Oh, November 19th, '88. 14 Q, Now, how long did you stay working as a laborer j 15 for the Gouverneur Talc Company? 1 16 A. Oh, might have been about a year probably, I 17 approximately a year. ! 18 Q. And did you -- when you were -- as a laborer did 19 you work in the talc mines themselves? 20 A. Yes. 21 Q. And after you -- or after you were a laborer what 22 was your next job assignment you got? 23 A. I -- well, I went to school, well into a 24 maintenance mechanic. 25 Q. And how long did you stay as a maintenance Kimberly S. Plummer, CSR (315) 778-0187 10 1 mechanic? oc. . Oh, probably about a year. 3 Q. nd then after as a maintenance mechanic, what was 4 your next job? 5 A. Well, I already got off maintenance mechanic. 1 6 signed on to underground stock clerk and driving truck on 7 the surface. 8 Q. And how long did you do the underground stock 9 clerk position? 10 A. Maybe three or four months; it wasn't too long. 11 Q. And then what was your next position with the 12 company? 13 A. I was a trammer. 34 Q. What is a trammer? 15 A. A trammer is --- they go into the stoker or 16 whatever they, call them and then they bring the ore out and 17 lump it into a transfer and it goes down into 700 foot level 18 o the crusher. 19 Q. If you could, because you may be the first witness 20 o explain to the jury what the mining process is, explain 21 o the folks on the jury how this mine that you worked at 22 orked, as far as getting the ore and bringing it up? 23 A. . Well, if you run on the cross cut with an Eneo, 24 he driller would fire or drop it into like a raise phonetic} and you -- put that into a car and take it out Kimberly S. Plummer, CSR (315) 778-0187 11 1 to the transfer and dump it down to 700-foot level or then 2 also you'd be a scraper man, which you would scrape it out 3 of these big stokes into the cars and do the same thing, . 4 .take it out and dump it down the transfer. 5 Q. You mentioned, was it Imco or Enco? 6 A . Enco. 7 Q. What is that? 8 A. That's a form of a front-end loader, only itfs on 9 tracks. It's got a bucket on the front. You go in and pick 10 up the other and dump it into the car. 11 Q. and how long did you work as a trammer? 12 a. All the time except what you got on the start with 13 I worked trammer. 14 >. So from about 1966 until about 1988, your job was 15 is a trammer? 16 A. Trammer, right. 17 Q. And. what's the difference between a trammer and a 18 ;craper man or are they the same thing? 19 A. They're one of the same. That's part of the 20. .rammer is scraper man and running an Enco. 21 'Q. Now, were you an hourly employee there at the 22 ompany? 23 A. Excuse me? 24 Q. Were you an hourly employee? 25 A. Yes. Kimberly S. Plummer, CSR (315) 778-0187 12 1 Q. And did you get paid in addition to hourly rate of 2 pay,, did you get paid a bonus depending on how much tonnage 3 of talc was dug up and I guess sold? 4 A. Right, yes. 5 Q. Did you work as a trammer below ground? <6 A. Yes. 7 . Q. And you mentioned the 700 level. What are the 8 various levels below ground that you would have done work 9 on? 10 A. I worked on 3 and 5 and 7 and some on 11. 11 Q. And what does that mean? Is that three -- does } t 12 that 3, 5, 7, 11, does that in any way relate to the amount i 13 of feet you're going below-ground? J 1 14 A. Right, that's what; that is, yeah. ! i 15 Q. So for example, 3 means 300 feet? j 16 A, 300, 500, 700 and 1,100. 17 Q. Were there any other levels of work that people- 18 would work on other than the 300 to 500 to 700 and 1,100 in 19 the mines that you worked in? 20 A. No, that's about as deep as it went. : 21 Q. 1,100 feet? 22 A. 7, 11, yes, I think 1,100 feet. 23 Q,, Now, could you describe for the folks on the jury 24 what the conditions were la ke with regards to working at 25 these various levels in the mines as it relates to dust? Kimberly S. Plummer, CSR (315) 778-0187 13 1 A. Well, there was a lot of dust. You do a lot of 2 --secondary blasting.' There's a"'lot of dust in the air at all" 3 the time. Of course the air currents never was right in 4 there. The air would just circle. You couldn't get away 5 from it, you know. 6 Q. When you worked back in the '60s and the '70s and 7 the '80s at this -- in this talc mine, did the company 8 provide you with any mask or respirators? 9 A. Yeah, they had throw-aways, which I used most of 10 the time. Then they had the canister type but the canister 11 type the only trouble with them is you had to wear glasses. 12 They was strict on glasses, of course that was safety. You 13 could not see wearing the canister mask. 14 Q. Why couldn't you see? 15 A. They wouldn't seal around your mouth, the air, 16 your breath would go up and they'd just fog up. 17 Q. The two types of respirators you would have been 18 provided would have been the throw-away paper ones? 19 A. Um-hrnm. 20 Q. And the canister ones? 21 A. Right. 22 Q. Did you witness other workers wearing these type 23 of respirators? 24 A. Ed Terrio (phonetic) was pretty strict on that. 25 He wore them pretty steady. Kimberly S. Plummer, CSR (315) 778-0187 14 1 Q. And what was his job there? 2 A. He wa'a a trammer, too. 3 Q. So other workers would have been using these 4 respirators as well; correct? 5 A. Right. 6 Q. Now, with regards to going down into the mines as 7 a trammer, what was the temperature like down there? 8 A. Oh, it varied. In the summertime it was nice. In 9 the winter on 3 and 5 it was pretty cool. It was going to 10 freeze the pipe lines now and then. 11 Q. So when y o u 're wearing the respirator down in this 12 cold area with the glasses, did you ever have problems with 13 steam on your glasses? 14 A. Right, yeah. 15 Q. . Did that -- how did you -- what did you do when 16 you had a respirator that you were wearing and you had your 17 glasses on and you had the steam on your glasses? 18 A. Take the respiraror off. 19 Q. Now, explain just a little bit more detail what 20 the crusher that y o u 're referring to, the crusher that's 21 used at the 700-foot level, what did that look like? 22 A. Just a big rock crushing crusher and the ore come 23 down the transfer gates, two gates -- 3 and 500-foot gates 24 and if they drawed the ore off the level and needed the 25 level, they'd raise the gates to let the ore down into the Kimberly S. Plummer, CSR (315) 778-0187 15 1 crusher. 2 Q ,, Did the -crusher. was there a crusher up on the 3 surface as well? 4 A. Yes, secondary crusher up on the surface. 5 Q. So would the crusher up at the 700 level break the 6 ore down to different sizes? 7 A, Right. 8 Q. And then would the crusher on the surface break it 9 down to even smaller sizes? 10 A. Right,, before they sent it to the mill. 11 ,Q. Now, in addition to being given a respirator or 12. throw-away paper mask, were you also, from time-to-time did 13 the company monitor -- put a monitor on you? 1i .,14 A. ?eah, we had monitor on. I d o n 't know whether the i1 1 15 company did it or OSHA dad it. Somebody put a monitor on. 16 Q. Okay. And were you, during your career, were you 1 1 given physical examinations every two years? 18 A. feah, just about that, yes. 19 Q. Now, I want to talk with you a Little bit about a ! 20 few additional things. Did you know Bill Fuller? i \ 21 A. Oh, yes. 22 Q. And how did you know Bill Fuller? 2 3 A. He worked.with me quite a few years there, Bill 24 Fuller and I were partners on the trammer. 25 I Q . And so he worked in the same mine you worked in? Kimberly S. Plummer, CSR (315) 778-0187 16 1 A. Yes, right. 2 Q- And did he do the same type of task you did, as 3 far as a trammer? 4 A. Yup. C Did he go down into the mines like you described 6 !going to the 300 and 500 and 700 levels? 7 A. Yeah. 8 Q. I want to show you what I 've marked as Exhibit 1 9 to your deposition. Do you recognize that document, sir'-* 10 A. I t 's Bill Fuller. 11 Q. ' Is that a photograph of Bill E'uiler? 12 A. Yes. 13 Q- I would -- - and does that fairly and accurately ,14 represent Bill Fuller at least in recent times? 15 A. Yeah, last I see of him. 16 MR. SATTERLEY: I'd move into evidence 17 Exhibit; 1, a photograph of Bill E'uiler. IS MR. YOUNG: We reserve our objection to 19 that. 20 Q. Was Bill Fuller present in the mines when you 21 worked there? 2? A. Yes. 23 Q. Okay. Do you know Charles, is it Minkler? 24 A. Minkler. 25 Q- Minkler? Kimberly S. Plummer, CSR (315) 778-0187 17 A . Oh, yeah. Q. And what was his job? A. 4 Q. 5 there? 6 A. Trammer. Did he work there at the same time that you worked Tup. 7 Q. I'd like to show you what's been marked as Exhibit 8 2 . Is that a photograph -- 9 A. oh, that's Charlie all right. 10 Q. Does that fairly and accurately represent Mr. 11 Minkler? L2 A. That's Charlie all right. 13 Q. . Was he present with you when you worked as a \T4 trammer down there in the mines? 15 A. Yes, yes. 16 G - I want to show you another photograph, Exhibit 3 17 and ask it you could identify that fellow for me? 18 A. Herb Conklin, 19 Q, What is was Herb Conklin's job out there at the 20 mines? 21 A. He'd been top crusher most of the time. 22 Q. Did he work -- did he work at the same mine you 23 worked at? 24 A. Yup, number one. 25 Q. And Mr. Conklin, working as a crusher, 'would he __________ ________________________________ -- Kimberly S. Plummer, CSR (315) 778-0287 18 1 work on the same levels you described, the 300 level, the 2 500 level, the 700 level? 3 A. No, he was working on the surface crusher. 4 Q. Okay. So he would be the one that's working on 5 the crusher that would make the materials, the minerals that 6 came from the mine even smaller and smaller? 7 A. Right, smaller than what it was on the 700-foot 8 level. 9 Q. Okay. Now, I want to show you a document, sort of 10 a.map and ask you if you recognize that, sir,- as Exhibit 4? 11 A. Oh, yeah. 12 Q, Does this fairly and accurately represents the 13 mining towns adjacent to the St. Lawrence River and Upstate, 14 New York? 15 A. Right. 16 Q. And does it show on this Exhibit 3 the mine where 17 you worked? 18 A. Right. 19 Q. And if you could just point out and tell me the 20 mine where you worked? 21 A. Balmat (indicating). 22 Q,, And did you work there the entire, I guess 25-plus 23 years you worked for the Gouverneur Talc Company? 24 A. Right, yup. 25 Q. And just on this map, we're today in Watertown, Kimberly S. Plummer, CSR (315) 778-0187 19 New York; correct? AO A. Right. 3 Q. And that's roughly what, 40 miles from the mines? 4 A. Approximately, yeah. 5 Q. Okay. I move into evidence Exhibits 1 through 4. 6 MR. YOUNG: We'll reserve our 7 objections. 8 Q. Now, I want to ask you some questions about a few 9 things relating to asbestos. Do you know, sir, whether IO asbestos was included in the minerals in the mines that you 11 worked at? 12 MR. YOUNG: Object to the form of the 13 question. 14 MR. SATTERLEY: Go ahead, sir. 15 A. As I was told, yes. 16 Q. Were you told that by management folks of the TT 18 A. Right. 19 Q. If you could, tell me the names of some of the 20 lanagermant folks -- well, let me ask you this question: Who 21 s Leon Typhair? 22 A. He was mine foreman there for quite a few years. 23 was the mine foreman when 1 went there. 24 Q. And as a mine foreman of the company did he advise 25 anything relating to whether there was asbestos in the Kimberly S. Plummer, CSR (315) 778-0187 20 1 mines that you worked in? 2 A. Yeah, he showed me pressed forms of it between the 3' two rocks, called it mountain leather but then he told me it 4 was asbestos, but it was -- it wasn't broke down, you know, 5 it was just like a piece of leather actually. 6 Q. And did Mr. Typhair -- did he work in the same or 7 was he in the same mine that you were in? 8 A. Yes. 9 Q, Now, who - - d o you know a personnel manager by the 10 name of Floyd? 11 A. Yes, I knew Floyd. I can't think of his last 12 name. 13 Q. Was he a management personnel from the company 14 there? 15 A. Right, he was personnel manager. 10 Q. Did- Mr. -- or did Floyd, I d o n 't know his last 17 name, did Floyd advise you anything with regards to whether 18 or not asbestos was included in the minerals in the mines 19 that you worked in? 20 MR. YOUNG: Same objection. 21 A. Yes. 22 Q. And did -- if you could just briefly tell the 23 folks on the jury what Floyd told you with regards to 24 asbestos in the minerals? 25 A. Floyd always, he confided in the men quite a bit Kimberly 3. Plummer, CSR (315) 778-0187 21 1 but he's always told us -- what he told us then he would 2 deny if we mentioned it to somebody else in theref 3 especially the management, you know, but he -- he said that 4 if he ever -- like when 1 was going out of there if I needed 5 him into court that he would -- he would testify. He would ' 6 not lie in court if they called him into court. 7 Q. nd does Floyd, last you' knew where did Floyd 8 Ilive? 9 A. Around Moira, 1 think around Lake Champlain. 10 Q. And did you know a fellow named Mullin, George 11 Mullin? 12 A. Yes. 13 Q. Was he a foreman at the company? .14 A. He was a foreman, I think over in the mill is 15 where he was located. 16 Q. And did -- as the foreman for the company, did 17 just George Mullin tell you anything about whether or not 18 the minerals in the mines was asbestos? 19 A. He never told me minerals in there was asbestos 20 until I went out of there and I was trying to get court 21 settlement, compensation and he called me up there one day 22 and told me then that he knew there was asbestos in the mine 23 and. he had a bag from when they first started. He said if I 24 needed .i.t to produce that he would let me take that to court 25 that said R.T. Vanderbilt, the best asbestos in the world. Kimberly S. Plummer, CSR (315) 778-0187 22 1 Q. And did Mr. Mullin show you that bag? 2 A. Yes, he did. 3 Q. And did that bag say R.T. Vanderbilt on it? 4 A. Yes. 5 Q,, Did it have the words asbestos on it? 6 A. Oh* yes. 7 Q. And was it printed right on the bag itself? 8 A. Yeah. 9 Q. And what was his ,-- you said he was a foreman but 10 what type of foreman was George Mullin; was he in production j 1 LI or -- i 11 12 A. I think he was in production over there; I'm j 11 j 13 pretty sure he w a s . i k14 Q. Now,' are you familiar with some products out oJ: .15 that -- the names of the products, the brand names that was IS sold from that mine? 1 17 A. Oh, yes, talc, tremolile. 18 Q. Well let. me ask you: Have you ever heard of a 19 products called Nytol 99? 20 A. I've heard them speak about it but I never -- 21 Q. I take it it wasn't your job to put any type of 22 brand names on any of the products? 23 A. No, no. 24 0, Okay. What about ceramic talc, do you know what 25 that is? Kimberly S. Plummer, CSR (315) 778-0187 I 23 1 A. Ceramic tiles, ceramic tiles? 2 Q. Ceramic talc? 3 A. Oh, ceramic talc. They used that in tile. 4 Q .. Do you know -- did you become familiar with some 5 of the customers of the Gouverneur Talc? 6 A, Mostly Florida Tile was the biggest one I know of. 7 that was their biggest customer. 8 Q. How did you know Florida Tile was the biggest 9 customer? 10 A. Management didn't deny it. They always admitted 11 that was the biggest customer. 12 Q. These people in management, do you know the names 13 of some of the folks that told you that Florida Tile was 14 there biggest customer? 15 A. Louie Zaluski told me that. Leon Typhair told me 16 that. I think George Erdman has even told me that. 17 Q Did there come a point in time when in the late 18 '70s or early '80s when there was a strike at the mines 19 there? 20 A. Yes. 21 Q. And what occurred with regards to the strike in 22 the mines as it relates to Florida Tile, if you know? 23 A. Well, they lost the contract for Florida Tile 24 because they couldn't give them talc so they, Florida Tile 25 started getting their talc from Texas Talc and we lost the Kimberly S. Plummer, CSR (315) 778-0187 24 1 contract probably for three, four years before they got it 2 back. George Erdman come right down and told -- told me 3 that it was our fault that they lost that contract because 4 we went on strike. But I told him if he'd have come across 5 what he did in the end anyway they wouldn't have lost that 6 contract. 7 Q. And eventually they got that contract back? 8 A. Right, they got the contract back. 9 Now,, with regards to -- with regards to the 10 working out there, did there come a point in time when one 11 of the executives from R.T. Vanderbilt came to the carpenter 12 shop? 13 A., Yeah. 14 Q. And tell me about that. Do you know the name of 15 that individual? 16 A. Hugh Vanderbilt. I think it was young Hugh. 17 Q. Was it Hugh Vanderbilt, Sr.? 18 A. Senior at that time. 19 Q. And when Hugh Vanderbilt, Sr. came to the 20 carpenter shop, approximately what time frame was this? 21 A. Late '70s, early '80s, somewhere in there. 22 Q. And tell the folks in the jury what occurred with 23 regards -- what did Hugh Vanderbilt tell you and the other 24 workmen at the carpenter shop? 25 A. Well, they was having quite a spell on whether Kimberly S. Plummer, CSR ' (315) 778-0187 25 1 that was going to be called asbestos or not and, of course, 2 they had their own labs I guess and they was testing against 3 NYAS and he said that in the end if all else failed he 4 padded his back pocket he says, I got a senator right here. 5 Q. He said he had a senator and he padded his back 6 pocket? 7 A. Back pocket, yes. 8 Q. And did he mention anything to you and the other 9 workers about how much money he was going to spend to fight 10 the issue of asbestos thex'e at the mines? 11 A. Oh, yeah, he didn't deny that. He had his own lab 12 and he said they just didn't come under the asbestos rule. 13 Q,, And did he say that he would spend millions of 14 dollars on that issue? j 15 MB. YOUNG: Object to the form of the 16 question. 17 A . , ^He'd spend a lot of money on it, yes. 18 Q: And was Bill Fuller there that day also? 18 A. Yes. 2C Q. And wece some of the other workmen that you -- 21 ft. Yes, Charlie Minkler was there and Herb Conklin 22 Was there, There was a lot of them there. Pretty near all 23 the miners at that time were there. 24 Q. And was the meeting, was that in the carpenter 25 shop? Kimberly 3 Plu'cuner, CSR {315) 778-0j87 26 1 A. Right. 2 Q. And was Mr. Vanderbilt, was he dressed up in a 3 suit? 4 A. Oh, yeah. 5 Q. And did -- was there concern at the mines whether 6 or not the, mines would be shut down if it was classified 7 asbestos as? 8 A. Right, that was what they was fighting for and 9 because if it was declared asbestos they'd have to close the 10 mine ,, 11 Q, And was Mr. Vanderbilt stating to the workers that 12 he was going to fight to make sure it wasn't asbestos? 13 A. Oh, yes. a -4 Q. Now, with regards to the collection of samples for 15.. analysis, were you ever involved in the collection of .16. samples in the mines for analysis by outside folks? 3 7 A. Oh, yeah. 18 Q, ,And tell the folks on the iury how that worked. 19 A, Well, NYAS,, originally they were supposed to come 20 unbeknown; they were just supposed to stop in and go down 21 and get samples wherever in the mines they wanted to but 2-2 they never did. They had the men, me and probably some 23 other ones, they'd tell them where to go to collect these 24 certain samples and mark J.t on the bag where, whatever spot 25 you'd get them like 14, 16 or 18 stoke or whatever and go * Kimberly 3. Plummer, C3R {3J5) 778-0187 . i \ | 27 1 down to the station and they'd come out and pick it up. But ! ! ] i 1 j j 2 they told us where to go get it. 3 Q,, Management told you where to go get it? 4 A. Oh, yeah, \tfhere they wanted it taken out of. n w j Q. Did you know whether where you had to go get the 6 samples, whether that was the same place where the -- where 7 the asbestos was located? 8 . MR. YOUNG: Object to the form of the 9 question. 10 A. It wasn't the same place. That was just lime -- il high lime content where they sent us to get the samples. 1 12 Q. And so where you went to get the samples, was it 13 the same place where the normal production of the talc was .:14 occurring at? 15 A. No, not entirely, no. -16 Q. Now, with regards to -- just so we're clear, you 17 v/eren't the only one that would go collect the sample of IS this material in the mine? 19 A. No, I wasn't the only one, maybe just on the level 20 I was on, .2.1 Q. Other workers, other trammers like yourself would 22 do? 23 A. Right, other levels. 24. Q. Now, just so we understand how this -- how these minerals get from the mines up to the -- on top of the earth Kimberly S. Plummer, CSF (315) 778-0187 28 1 and distributed out to, I guess, customers, .if you could 2 tell us were there. 3 Was there a location where the talc would be sent 4 to be shipped out on railcars? 5 A. Yeah, it was shipped over to the mill and then it 6 was ground up more to where it was just a fine -- real fine 7 and they would ship it out to railcars right behind the 8 mill. 9 Q, And just so I'm clear, you worked in the mine not 10 in the mill; correct? 11 a. Right, right. 12 Q. And the mill is the location where it would be put 13 into railcars to be shipped out to the customers like 14 Florida Talc? A. Yeah. 15 16 Q. Now, I want to jxist briefly ask you some questions 17 about your own personal situation and I'm not going to go 13 into any detail with it. Have you been diagnosed with 19 asbestos? 20 MR. YOUNG: Object to the form of the 21 question. 22 A. Yes. 23 Q. And have you had a biopsy done? 24 A. Yes. 25 . Q. And has the doctor, your doctor, given you the Kimberly S. Plummer, CSR (315) 778-0187 29 1 personal medical information about yourself that you have 2 asbestosis? 3 MR. YOUNG: Same objection. 4 A. Right, yes. 5 . Q. With regards to other workers out there, do you 6 know whether other workers like yourself has been diagnosed 7 with asbestosis? 8 MR. YOUNG: Same objection. 9 A. I'm not sure because a lot of them didn't go 10 through what I went through to find out. 11 Q. Do you know whether some of your co-workers have 12 developed cancer? 13 A. Yes. 14 MR. YOUNG: Same objection. 15 Q. Let me ask you some of the job classifications of 16 some of these workers, what they did. Do you know a fellow 17 named Robert Rise (phonetic)? 18 A. Yup. 19 Q. What was his job out there? 20 A. He was trammer. 21 Q. Did you work with Robert Rise? 22 A. Off and on. He was on a different level but I 23 used to work with him off and on. 24 Q. Mr. Evans, did you know, I think, is it George 25 Evans? Kimberly S. Plummer, CSR (315) 778-0187 30 A.. George Evans? I know Evans, but I don't remember George Evans. Q, What about Larry Malbouff (phonetic)? 4 A. Yes, I knew Larry Malbouff. 5 Q. What was his job out there? 6 A. He was in the lab across the road. 7 Q. In the mill? 8 A. In the mill, right. Well, separate building from 9 the mill. 10 Q. Now, l e t 's go off video for just one second. 11 VIDE06RAPHER: Off the record 10:07. 12 (Whereupon, there was an off-the-record 13 discussion.) 14 VIDEOGRAPHER: Back on the record 10:08. 15 Q. Now, sir, I'm just going to wrap it. up with a few 16 Final question s. Prior to this morning, have you ever met 17 iith me? 18 A . Nope. 19 Q. And prior to last, night when I -- well, I didn't 20 speak with you last night, I spoke with your wife, 21 ight? 22 A. Right. 23 Q. Prior to this morning, you've never spoken to rue 24 t all; correct? 25 A. Nope. Kimberly S. Plummer., CSR (315) 778-0187 31 1 Q. And with regards to this -- ail the information 2 that you've conveyed to us today, has it all been truthful, 3 to the best of your knowledge? 4 A. Yes', eKcept that picture of Bill Puller. If I 5 didn't know him, I'd never have known him in that picture. 6 0. W h o 's that? 7 A. Bill Fuller because he last, he was perfect health 8 until that picture. If X didn't know him, I would never 9 recognize him. 10 Q. Because he changed quite a bit? 11 A. Oh, I guess so. 12 Q. Has Mr. Fuller passed away now? 13 A. Yes. 3.4 Q. There's a fellow here that -- the attorney for 15 R.T. Vanderbilt, brought to this deposition, named Fred 16 Gotten (sic)? Do you see him sitting here? 17 MR. YOUNG; Totten, I'm sorry. 18 Q. I'm sorry, Totten. 19 A . Yes. 20 Q. What was Mr. Totten's position out at the company, 21 if you know? 22 A. He's an engineer at the company. 23 Q, Okay. Final question, sir. Do you have any 24 evidence at all that R.T. Vanderbilt, when they shipped this 25 talc out to Florida-Tile issued any type of warnings or Kimberly 5, Plummer/ GSR (315) 778-0187 32 1 cautions to the workers out there? 2 A. Not that I never knew of. 3 MR. SATTERLEY: Thank you, sir. I 4 appreciate your time this morning. Those are all 5 , the questions I 'm going to have right now. Let's 6 go,off the video. Some of these other attorneys 7 may have some questions for you. . 8 VIDEOGRAPHER: Off the record,' 10:10,, 9 (Whereupon, there is an off-the-record 10 discussion.) 11 VIDEOGRAPHER: Back on the record, 10:10. 12 33 CROSS-EXAMINATION BY MR. YOUNG: 14 IS Q, Mr. Rogers, I'm Lane Young. I'm R.T. Vanderbilt's 16 lawyer 3nd you and I. also met for the first time this 17 morning; is that right? 18 A. Right. 19 Q. Okay. I do need to ask you some questions. nd I 20 wanted to start with Hugh. Vanderbilt coming to the mine; you 21 told Mr. Satterley about that. Do you remember that? 22 . A. Vanderbilt coming to the mine. 23 Q. Yes? 24 A. Oh, yeah. 25 , Q. And another lawyer a long time ago had asked you Kimberly S. Plummer, CSR (315) 778-0187 33 1 about that; right? Do you remember that, way long time ago, 2 16 years ago? 3 A. Another lawyer? 4 Q. Yeah,. Mr. Setright? c v/ A. Setright; Longstreet and Setright. 6 Q. He was your lawyer, right? 1 A. Yup, one of my lawyers. 8 Q. Right. And you had made a claim against 9 R.T. Vanderbilt? 10 A. Right. 11 Q. Okay. And you had given a deposition like this in 12 a lawsuit that you filed against R.T. Vanderbilt? 13 A . Right. 14 Q. And a bunch of lawyers came and asked you 15 questions just like this? 16 A. Right. 17 Q. Pretty much ail the same stuff? 18 A. Pretty well. 19 Q.. Okay. Have you given any depositions between this 20 leposition in 1991 and today? 21 A. No. 22 Q. Okay. You told Mr. Setright, and I just want to 23 ee if you still recall this, that when Mr. Vanderbilt came 24 o the. mine that day and he was talking to everybody that 25 ou felt likb that he believed there wasn't any asbestos in Kimberly S. Plummer, CSR (315) 778-0187 34 1 . the talc; was that your impression? 2 A. Well, maybe he believed it. 3 Q. Right. 4 A. We didn't. 5 Q. But that's what he said, Mr. Vanderbilt? 6 A. Right, -he said in his lab they showed they 7 weren't, just under -- Kept under the specs being called 8 asbestos. 9 Q. Okay. And Mr. Vanderbilt was there that day to 10 tell you guys that he was fighting to prove that there 11 wasn't asbestos in the talc so that the mine wouldn't be 12 shut down and you guys could keep your jobs? 13 A. Right. 14 Q. And I assume that was something that you didn't 15 want the mine to shut down, did you? 16 A. No, didn't wart the mine to shutdown but would 17 like -to know for sure if it was asbestos. 18- Q. Okay. Did you ever go back and investigate and 19 talk to any of the folks at the lab that had looked at the 20 talc to see if it had asbestos in it, to see what they were 21 saying? 22 A. No. 23 Q. Do you know who was doing that? 24 A. Across the road, Larry Halbouff was one of them, 25 that's the main one. I knew him but I don't 'know about the Kimberly S. Plummer, CSR (315) 778-0137 35 1 other ones. 2 Q. The fellow that Mr. Satterley asked you about, Mr. 3 Malbouff? 4 A. Malbouff, I knew him. 5 O. And he worked over in the lab? 6 A. He worked in the lab. 7 Q, And he was looking at the talc to see if it had 8 asbestos in it? 9 Well, yeah, used it for whatever products they 10 , were using it, too, make sure it was used for the products. 11 Q. All right, sir. And you never went and asked him: 12 Hey, Mr. Vanderbilt, is saying there is no asbestos in the 13 talc? ,14 A. No. a 5 Q. How about Slim Thompson, did you know him? 16 A. Excuse me, again. 17 Q. Slim Thompson, he was a mineralogist for R.T. 18 Vanderbilt back then? 19 A. No, not -- don't recognize his name. 20 Q. Anybody else that you remember that you think 21 might have been looking at the talc to see if it had 22 asbestos in it? 23 A.. NO. 24 Q. Okay. How many folks were at this meeting that 25 Mr. Vanderbilt talked to? Kimberly S. Plummer, CSR (315) 778-0187 36 , 1 .A. Must have been 50, 40, 50 anyway. 2 Q. And Mr. Totten was there? 3 A. I imagine Fred was there. 4 Q. Do you remember Mr. Totten told me this morning 5 that he recalled Mr. Vanderbilt saying that they were 6 talking to the government folks about whether or not there 7 was asbestos in the talc? 8 A. Oh, yes. 9 Q. Okay. And they were talking to the government 10 folks about R.T. Vanderbilt's position that they had not 11 found any asbestos in the talc; do you remember him saying 12 that? 13 MR. SATTERLEY: Object to the form of the 14 question. 15 A. Repeat that again, please. 16 Q. Okay. Well, Mr. Totten told me that Mr. 17 Vanderbilt said that they were talking to the government 18 folks about Vanderbilt's position that there was no asbestos 19 in the talc? 20 MR. SATTERLEY: Object to the form of the 21 question. 22 Q. Do you .remember that? 23 A. I can remember similar something like that, yes, 24 b u t ... 25 Q. So Mr. Vanderbilt was telling you guys that Kimberly S. Plummer, CSR (315) 778-0187 37 c '"> o i VanderbiIt-had tested the talc and not found any asbestos in 2 it? 3 A. Yes. 4 Q. And that1s what they were talking to the 5 government about? 6 A. Yup,, 7 Q. Okay. And I take it from what you told Mr. 8 Satterley a few minutes ago that was contrary to your 9 impression at the time? 10 A. Yeah, I guess. 11 Q. Did you ever go and ask anybody at R.T. Vanderbilt 12 after that, you know, why is Mr. Vanderbilt saying there s 13 no asbe stos in the talc when I think there is? 14 : A. Mo, 1 didn't go talk to nobody about it, no. 75 Q. Who was your foreman then? 16 A* Let's see Leon Typhair and Louie Zaluski. 17 Q. Louis Zaluski? Z-A-L-U-S-K-I? 18 A. Something like that, Pollock's name. 19 Q- Have you ever talked to him about the question of 20 whether there was asbestos in the talc? 21 A. Yeah, we mulled it over. I mean, you know, we all 22 knew at was there. 23 Q. Mr. Zaluski didn't think there was asbestos in the 24 talc, did he? 25 ! A. Mo, he wouldn't admit it. Kimberly S, Plummer, CSR (315) 778-0187 38 1 Q, Well, he told you that he didn't think that there 2 was? 3 A. Yeah. 4 Q. Did you ask him why he believed that there was no 5 asbestos in the talc? 6 A. Because he was a company man. 7 Q. Do you -- how long has it been since you talked to 8 him? 9 A. Oh, I haven't talked to Louie in four, five years 10 I guess. 11 Q. He was with -- at this meeting with Mr. 12 Vanderbilt? 13 A. Yeah, he must have been there. > 14 Q. Was he down there working in the mines? 15 A. He worked in -- as a trammer before he made 16 foreman. 17 Q. Okay. So he would have been exposed to the same 18 dust as you? 19 A. Yeah, for while he was there, right. 20 Q. Okay. So do you think that, he Would expose 21 himself to something he thought was asbestos just because he 22 was a company man? 23 MR. SATTERLEY: Object to the form of the 24 question. 25 A. That was before he was a company man so he -- Kimberly S. Plummer, CSR (315) 778-0187 39 1 yeah, he worked with a fellow they called Eli Shippee. 2 Louie was pretty clever. Eli dad most of the work, you 3 know, he worked where it was bad. 4 Q. But the foremens actually went down' in the mine 5 and did work, didn't they? 6 A. No, they just walked around. Foreman didn't work; 7 they just walked around. 8 Q. They were in the mines and around the dust? 9 A. They were in the mines, tell you what to do and 10 zip, they was gone. 11 Q. Since you were thinking that it was asbestos in 12 the talc, did you wear your mask or your respirator whenever 13 you were around it? 14 A. Where we could wear, it we would, yes. *15 Q. The- gentleman that Mr. Satterley asked you about, 16 Mr. Fuller and Mr. Minkler and Mr. Conklin; do you remember 17 that? 18 A. Yeah, I remembdr all of them. I went down with 19 them, with two of them. 20 Q. Did those fellows smoke? 21 A. Which ones? 22 MR. SATTERLEY: Objection. 23 Q. Mr. Fuller, Mr. Minkler and Mr. Conklin? 24 A. Fuller, I think -- Bill is the only one I knew of 25 smoked. I don't know if Conklin did -- no, I think Fuller Kimberly S. Plummer, CSR (315) 778-0187 40 1 was the only one. Winkler didn't either. 2 Q. Did Mr. Fuller smoke a lot or do you know"? 3 A. No, not a lot but he did smoke. 4 MR. SATTERLEY: Object to the form of the 5 question. 6 Q. How .long has it been since you talked to Mr. 7 Fuller? 8 A. He died two years ago; about three years ago I 9 think, just before he died I last talked to him. 10 Q. Okay. 11 A. If I'd have known him, I wouldn't have recognized 12 him then. 13 Q. Do you know how long he smoked? .14 MR. SATTERLEY; Objection. ;15 - A, No, because I only knew him while he worked there. 1 s Q. But he smoked while he was working at the mine? 17 A. Yeah. 18 Q. And obviously you couldn't smoke and wear a mask 19 or a respirator; right? 20 MR. SATTERLEY; Objection. 21 A. No,' time to smoke, you just stopped long enough to 22 smoke and then you went back to work. 23 Q. Did .you ever see him taking the mask or respirator 24 off so he could smoke? 25 MR. SATTERLEY; Objection. Kimberly S. Plummer, CSR (315) 778-0187 41 1 . No, no I couldn't honestly say that. . 2. Q. .All right. .po.you know where Mr. Typhair, is that 3 how you pronounce it? 4 A. Leon Typhair. 5 Q. Do you know where he is now? 6 A. Yeah, dead. 7 Q. And you said that he showed you a piece of 8 .asbestos and it looked like a piece of leather? 9 A. Yeah, asbestos is compressed between rock, you can 10 ,-- it!s like a sheet of, I don't know, leather it looked 11 like, leather when you took it out. And he took it out and 12 showed me and I said: What's that and he said mountain 13 leather and I said: What's mountain leather, and he said 14 raw form of asbestos. It's compressed together. 15 Ch And Mr. Typhair wasn't a scientist or anything, 16 was he? 17 A. No, not that I know of. 18 Q. So he wouldn't have been able to make any analysis 19 of that and say it was asbestos? 20 MR. SATTERLEY: Object to the form of the 21 question. 22 A. He wouldn't -- I don't know who could tell you 23 that. 24 Q. Well, Mr. Malbouff could, right? 25 A. Yeah, he could, Larry could have. Kimberly S. Plummer, CSR {315) 773-0187 42 1 Q. Or did you ever take that piece of leather over 2 there and ask somebody to look at it and see if -- 3 A. No. 4 Q. -- if it really was asbestos? 5 A. No. 6 Qo Okay. If we went out to the mine today, do you 7 think we could get us a piece of that mountain leather? 8 A. It. would be -probably unlikely because certain spots that you could actually find it. I just happened to 10 be with him when he found it that day. 11 Q. So it wasn't all over the mine then, right? 12 A. No. .13 Q. Was it just in certain areas? A. Well, that spot where he got was in a certain 15 spot, yeah. I had never seen it before until he pointed it 16 out to me. 17 Q.'. But that was something that was not prevalent all 18 over the mine, right? 19 A. No, not in that form, 20 Q. Mr. -- Floyd who's last name you can't- remember, 21 how long has it been since you've seen him? 22 A. I haven't seen him since probably *88, since I got 23 dona work. Fred might know his last name. 24 Q., Okay. Did he actually go to court and testify for 25 you? Kimberly 5,, Plummer, CSR (315) 778-0187 43 1 A. No, he said he would if he had t o . He would not 2 lie in court, he said. 3 Q. He wasn't a scientist either, was' he? 4 A. I don't know. He was personnel manager. 5 Q. Okay. So you don't have any idea from where he 6 gathered the information that he thought there was asbestos 7-- 8 A. No. 9 Q. -- in the talc? 10 A. I have no idea. 11 Q. Was he talking about that piece of mountain 12 leather type material, too? 13 A. No. - 14 Q. Just -- - 15 A. Just the foreman. Floyd didn't. He got around 16 underground but not like he was working there, you know. 17 Q. But he did go down in the mines and was exposed to 18 the dust? 19 A. Oh, he went down. He come around and talked to 20 the men and one day a week anyway. 21 Q. So he was being exposed to what he told you he 22 thought was asbestos? 23 A. Oh, yeah, he must have been. 24 Q. Did you ask him why he was breathing this dust 25 that he thought was asbestos? Kimberly S. Plummer, CSR (315) 778-0187 44 1 A. No. . 2 Q. Okay. 3 A. It was hard to believe because one tell you it 4 was, one tell you it wasn't, so... 5 Q.- So there were other people at R.T. Vanderbilt 6 besides Mr. Vanderbilt that would tell you there wasn't 7 asbestos in the talc, right? 8 A. There were certain other people, company people. 9 Q. Who was that? 10 A. George Erdman, Chubby Bressette, Leon Typhair, I 11 guess that's his name, Chubby Bressette and Leon Typhair, 12 all the foreman, they wouldn't say it was asbestos, no. 13 Q. And then George Mullin, he's the fellow that 14 showed you the bag? IS A. Right. 16 Q. Do you remember that? That bag that he showed you 17 that had asbestos written on it, did any bags actually get 18 sold like that that you know of? 19 A. Except what he told me, they shipped -- that's 20 what they used to ship it in when they first started the 21 mill and the mine up. 22 Q. So it had asbestos on it? 23 A. Yeah, inside. 24 Q. I'm sorry, go ahead. 25 A. Best asbestos in the world, it said right on it. Kimberly S. Plummer, CSR (315) 778-0187 45 1 :Q. So it's your recollection that R.T. Vanderbilt . 2 actually sold some -materials in a bag that said best 3 asbestos in the world? 4 A. Must have because the bag was -- it was on that 5 bag that they use, shipping bag, so it had to be. 6 Q. - When was that, do you remember? 7 A. When he showed me that? . 8 Q. N o , when you think the best asbestos in the world 9 bag got sold? 10 A, Oh, that had to have been back in `48, '50, 11 somewhere in there the bag was -- according to Mullin, 12 George Mullin was telling it was back when the mine started, .13 you know, been going too long. Q. So you weren't there in '48 and '50? 15 A. No. 16 Q. So you don't know of your own personal knowledge 17 what they were doing? 18 A. No. 19 Q. All right. Was Mr. Mullin any sort of scientist? 20 A. No, I don't think so, unless he -- he could have 21 been because he went to college an awful lot, so I couldn't 22 say. 23 Q. And you don't know if anybody ever analyzed what 24 was in that bag he showed you to say whether it was asbestos 25 or not? Kimberly S. Plummer, CSR (315) 778-0187 46 1 A. No. 2 Q. And you never took that bag that said asbestos on 3 it to Mr. Setrigbt, right? 4 A. No. V Q . Did Mr. Setright ask you about that? 6. MR, .SATTERLEY: Let me place an objection. 7 Let's go off the video a second. Let's go off the 8 video. 9 VIDEOGRAPHER: Off the record, 10:27. 10. MR. SATTERLEY: You're going to now invade 11 into his attorney/client privilege with his own 12 personal attorney. , 13 . : MR. YOUNG: It's not that important. MR.' SATTERLEY: I'm just going to advise .*>15 him that he was a right under the law, he may not 16- | know that that attorney, conversations with your 17 attorney are privileged and he doesn't have a 18 right under the law to ask about that. 19 MR. YOUNG: I t 's not that important. Let's ?0 just go back to something else. 21 MR. SATTERLEY: Let's go back on the video . 22 then. - Let me move to strike that last question. 23 ,VIDEOGRAPHER: Sack on the record, 10:27. 24 BY MR. YOUNG: . 25 . Q, Mr, Rogers -- Mr, Satterley objected, so I'm going Kimberly S. Plummer, CSR (315) 778-0187 47 1 to ask you another question 2 In your lawsuit, as far as you know Mr. Typhair 3 and Mr. .Mullin and Floyd who's last name you can't remember, 4 -they weren't r- they didn't give any depositions or any 5 information to Mr, Setright? 6 A. No, 7 Q . . In your lawsuit, one of the things you were 8 claiming was that you'd been exposed to asbestos from the 9 talc at the mine, right? 10 A. Right. 11- Q. And these fellows, at least in your opinion, had 12 information that was relevant to that? ,,13 A. Oh, yes, they had to know. ' ' ;-i4 .15 Q. But you didn't give their names to Mr. Setright? MR, SATTERLEY: Objection. Once again -- 16 once again let me advise -- you're trying to 17 invade his privileged communication with his 18 personal attorney. I think it's improper since 19 his attorney is not here. So I just -- you think 20 in all fairness to -the witness, he should be 21 advised that conversations he's had with his 22 personal attorney is privileged, simply like I 23 . can't invade upon the fact that Hugh Vanderbilt 24 what he talks about with this fellow, so you don't 25 have to answer that under the law. Kimberly S. Plummer, CSR (315) 778-0187 48 1 Q. You didn't give those names to Mr. Setright? 2 A. No. 3 Q. Mr. Satterley asked you about a strike at the 4 mine? 5 A. Um-hnun. 6 Q. Exactly what year was that? 7 A. It was after that because I can't remember. 8 Q. Was there just one strike while you were working 9 there? 10 A. Yeah, I think just the one. I -- maybe went out 11 one day or something. 12 Q. Mr. Rogers, you don't know how many times NYAS or 13 the mines safety and health administration or OSHA came to 14 the mine to get samples of the talc to test it, do you? 15 A. How many times? 16 Q. Yes, sir-. 17 A. Not exactly because once -- they was random, 18 whenever they decided they wanted a sample. 19 Q. And you wouldn't always be the one that would go 20 get the samples, would you? 21 A. No. 22 Q. So you don't know where all they took samples 23 from, do you? 24 A. Right, no, I don't. 25 Q. And you told Mr. Satterley that where you took the Kimberly S. Plummer, CSR (315) 778-0187 49 1 samples from was not entirely where the talc was mined but 2 you did take samples from where the talc was mined 3 sometimes, didn't you? 4 _ A. Right. Depends on, there was cross cuts. We 5 mined it sooner or later you'd be mining it, but at times 6 they wanted the samples they'd tell you where to get them, 7 the stoke number or cross cut number, whatever. 8 Q. Do you know how many samples of R.T. Vanderbilt 9 talc had been analyzed to see if there was asbestos in it in 10 the last 40 years? 11 A. No. 12 Q. Okay. But you heard that it's been done a lot; 13 right? 14 A. A lot. 15 Q. And some people have said that there's asbestos in 16 it and some people said there's not? 17 A. Right. 18 Q. Okay, When you were working out there at the 19 mine, do you recall there was asbestos insulation in the 20 mine on the machines or the pipes or things like that? 21 A. No. 22 Q. Anybody ever tell you that? 23 A. No. 24 Q. Do you know whether or not there was 25 asbestos-containing insulation anywhere in the mines or the Kimberly S. Plummer, CSR (315) 778-0187 50 1 mills while you were there? 2 A, I don't, know about the mill site but the mines, no 3 we didn't have no insulation. 4 Q. Do you know what kind of brakes were on the 5 machines that were used out there at the mine; do you know 6 whether they had asbestos in them? 7 A. I'm not sure. They might have at one time but: 8 then they changed over to something that wasn't asbestos. 9 different organic material. 10 Q. Tell me about that. Do you remember them changing 11 out the asbestos brakes or something else? 12 A. I can remember when they changed over. 1 cannot 13 tell you the date or nothing b ut... 14 Q. But you do remember a changeover? 15 A. Right, they went to organic mostly. 16 Q. I'm sorry, go ahead? 17 A. Organic band is what they're supposed to be. They 18 said that didn't contain asbestos. 19 Q. And before that they had been using asbestos 20 brakes, as you understood it? 21 A. Some of them, yeah. 22 Q. Okay. And all those machines out there had brakes 23 on them, didn't they? 24 A. No, there's been just scraper is the only thing, 25 big tuggers were the only things that had bands on them. Kimberly S. Plummer, CSR (315) 778-0187 51 1 Q. They had big brakes.right? 2. A. Yeah, the baud is probably 3 by whatever, 3 (indicating) 4, 4 feet round. 4 .Q. And how did you stop the trammer? 5 A.. The trammer, y o u 're -- what are you referring to 6 as "a trammer? 7 Q. Yes, sir. 8 A. The scraper, well, you shut the motor down, shut 9 the switch off. : 1.0 Q; So it didn't have any brakes? 11 A. Well, it didn't what they call brakes anyhow. 12 They would engage the drums so that they wouldn't slip to *. 13 puli the other out with on the bucket. We didn't refer to ,,14 them as brakes but they were -- 15 MR. YOUNG: Can we go off the video for 16 just a second? 17 VIDEOGRAPHER: Off the record 10:34. ' 18 (Whereupon, there was an off-the-record 19 discussion.) 20 VIDEOGRAPHER: Back on the record at 10:36. 21 MR. YOUNG: Mr. Rogers, a couple more 22 questions for you. And I appreciate your time 23 this morning. 24 O'. .How long have you known Mr. Totten? 25 A. . Oh, I've known Fred ever since he come, into the Kimberly S. Plummer, CSR (315) 778-0187 52 1 mines. I c a n 't remember how long ago that. was. 2 Q. Is he a pretty good fellow? 3 A. Yeah, always liked Fred. 4 Q. . Do you have any idea what he thinks about whether 5 there's asbestos .in the talc? 6 A." I have no idea, no. We never- discussed anything 7 as far as that. 3 Q. Had Mr. Vande.rbilt ever been to the mine before 9 that you recall, other than this meeting? 10 A. Oh, yes, yes. He used to come periodically, go 11 down to 700 foot level and back out. But he -- 12 Q. He would actually go down in the mine? 13 A. He'd go down to 700 foot level. Do you know where 14 the crusher was, main station? 15 Q. And he would breathe the same dust that you guys 16 were breathing? 17 A. Ho. They kind of policed the area up when he was 18 coming. 19 Q. But there was still some dust? 20 A. There*d be some dust. 21 Q. Did you ever talk to him just one-on-one about 22 anything? 23 A. No. 24 Q-.. Okay. But he did seem to genuinely believe when 2'5 he was there that there wasnst any asbestos in the talc and Kimberly S. Plummer, CSR (315) 778-0187 53 1 he was fighting to prove that? 2 MR. SATTERLEY s Objection. '.Calls for 3 speculation, what he genuinely believed but go 4 ahead if you understand the question. 5 A. He tried to make you believe that but every -- 6 common knowledge in the mine of everybody there that he was 7 -- he was a lot of power, you know, and he could pretty 8 well, if they changed the spec he'd change his just enough 9 to stay under so they wouldn't be called asbestos. 10 Q. You said it was common knowledge in the mine. Did 11 anybody of these 50 people at the meeting raise their hand 12 and say to anybody: Well, you're saying there's no asbestos" 13 in the talc but so and so says there is, what's the deal?. 14 A. I can't remember if they did or not. 15 Q. Okay. And you never asked your foreman or anybody 16 about that? 17 MR. SATTERLEY: Objection; asked and 18 answered. 19 A. About the asbestos? 20 Q. Yes, sir. 21 A. Yeah, we talked. We talked to each other about 22 the asbestos if there's any In the mine, if they blieved 23 there were. 24 Q. And they said no? 25 A. No, not always, not all of them. Kimberly S. Plummer, CSR {315} 778-0187 54 1 Q. But some of them did? 2 A. Some of them said of course. 3 MR. YOUNG: That's all the questions I 4 have. Thank you, sir. c. 6 CROSS-EXAMINATION BY MR. VANCE: 7 8 Q. Mr. Rogers, my name is Gene Vance. I just have a 9 couple of questions for you today, sir. 10 First of all, I'm not sure this was clear from the 11 questioning earlier but you said you worked for Gouverneur 12 Talc Company; is that correct? 13 A. R.T. Vanderbilt. 14 Q. That's what I was going to ask you, if Gouverneur 15 talc was owned by R.T. Vanderbilt? 16 A. Yes. 17 Q, I just want to be clear on that. As I understand, 18 it the talc from the mines, a lot of it was shipped out in 19 railcars; is that right? 20 A. Right. 21 Q. And there would be a lot of railcars going out 22 every day? 23 A. At one time, there was a lot of them going out 24 every day. 25 Q. If you put all the brake pads on all the equipment Kimberly S. Plummer, CSR (315) 778-0187 55 1 . at that mine, took all of them, would that fill up even one 2 rail car? 3 A. No. 4 Q. Thank you, sir. O 6 REDIRECT EXAMINATION BY MR. SATTERLEY: 7 8 Q: Joe Satterley again. A couple follow-up 9 questions. On that note,- with regard to the brakes on the 10 machine, did you-ever see any dust emitted from the brakes 11 on the machines that Mr. Young was representing? 12 A. Never seen any dust, smoke maybe. 13. Q. I -mean if you compared the dust from the talc and 14 the minerals that you guys were mining to whatever dust was 15 around the brakes on machines, how did that compare? 16 A, It didn't compare actually, no. 17 Q.. With regards'to -- with regards to R.T. 18 Vanderbilt,- did anybody from R.T. Vanderbilt or Gouverneur 19 Talc Company ever advise you how many people that worked in -20 the mines died of mesothelioma? 21 A. No, they never -- * that name was never brought up 22 or whatever you call it. 23 Q. Counsel well, let me ask you: Did anybody from 24 R.T. Vanderbilt or Gouverneur Talc Mines ever tell you how cn many people from the mines, the miners and the millers died Kimberly S. Plyunmer, CSR (315) 778-0187 56 1 of lung cancer? 2 MR. YOUNG: Objection. 3 A. No, they never told us. We knew but they never 4 told us. 5 Q. How did you know? 6, A . . We knew the people personally. 7 . Q . And counsel asked questions about Mr. Fuller , 8 smoking. Did anybody from R.T. Vanderbilt or Gouverneur 9 Talc ever warn the workers, the millers, the miners that if 10 you're exposed to the minerals in the mines and you also 11 smoked your chance of getting cancer is multiplied or 12 synergistic effect? 13 MR. YOUNG: Objection. 34 A. No. 15 MR, YOUNG: Object to the form. 16 Q. Counsel asked you some questions about1who was a 17 scientist and who.wasn't a scientist. My question to you 18 isr These people that told you that it was asbestos they 19 were various management personnel, correct? 20 MR, YOUNG: Object to the form of the 21 question, 22 A. Right. 23 Q. Including Mr. Muilin, you said Mr. Typhair and 24 others? 25 A. Typhair and Bressette. There's quite a few, yes. Kimberly S. Plummer, CSR (315) 778-0187 57 1 MR. YOUNG: Object to the form of the 2 question. 3 A. But they -- 4 Q. Did you trust your employer when you worked for 5 them as ..far as them telling you the truth? 6 A. That's what was we doing, was trusting them, 7 right. 8 Q. Okay. Counsel also asked you about scientists and S I want to ask you about Mr. Vanderbilt. Did he ever come 10 out and tell you how much money he spent to hire scientists 11 to say it wasn't asbestos? 12 MR. YOUNG: Same objection, .13 A. He said he spent a lot of money in'his own . A 4 .laboratories testing himself to come up that it wouldn't be 15 asbestos, keep it under the specs. 16 Q. But did he tell you the total amount, how many 17 thousands or millions of dollars he would have spent? 18 .A.. No, he just said he spent a lot of money. 39 Q. Eli Shippee, you mentioned that he was -- was he a 20 trammer also? 21 A. Right. Pretty sure he died of lung.cancer, too. 22 Q. And he worked in the same areas of the'mine that 23 you worked? 24- A." Right. We had two -- when you run' two shifts, he 25 run the opposite shift. Kimberly S. Plummer, CSR (315) 778-0187 58 1 Q. And counsel also asked you about you making a 2 claim against R.T. Vanderbilt. Did you only make a claim 3 against them with regards to your condition after you had a 4 biopsy, a lung biopsy done? 5 A. Yes, 6 Q. And did the lung biopsy prove in your mind or did 7 the doctor, your doctor tell you you had asbestosis? 8 MR. YOUNG: Same objection. 9 A. Yes. 10 Q. He asked you a lot of questions about you filing a 11 lawsuit. Was the basis of filing a lawsuit because you had 12 asbestos in your lungs? 13 A. Yes. 14 MR. YOUNG: Objection as to form. 15 A. The Occupational Center in Syracuse said it was, 16 too. The doctors sent the biopsies out. He knew what at 17 was but he said he'd send it out to be damn sure. 18 Q. And with regards to the claim that you made 19 against R.T. Vanderbilt, if they didn't cause you to develop 20 this lung disease would you have made a claim against them? 21 MR. YOUNG: Same objection. 22 A.- No. I'm just the lucky one that's still alive. 23 Q. And finally, a.couple questions, Larry Malbouff, 24 you said he worked in the lab. He would have never worked 25 around those brakes on the machines? Kimberly S. Plummer, CSR (315) 778-0187 59 1 . A. No, no, he was never to the mines. 2 Q. Okay. 3 MR. YOUNG: I'm sorry, he was never at the 4 mines? 5 A. Never come in to the mines that I know of. 6 Q. As far'as you know, you never personally witnessed 7 him working around the machines? 8 A. Oh, no. 9 Q* The scraper the -- 10 A. No. 11 Q. And in addition to there being talc in the mines, 12 is it your understanding there was a product called 13 tremolite? 14 A. Oh, yes, tremOlite was one of the main ingredients 15 in talc. 16 Q- And are-you familiar with the product name called 17 anthophyllite? 18 A, Come again? 19 Q. Anthophyllite, do you know what that is? 20 A. No. 21 Q- Okay. Did anybody in management at R.T. 22 Vanderbilt or Gouverneur Talc tell you that anthophyllite 23 was included in the minerals in the mines?' 24 A. No, not as far as I know of. Not that I remember 25 anyway. Kimberly S. Plummer, CSR (315) 778-0187 60 1 Q. Counsel asked you questions about wearing a 2 respirator around asbestos. Back when you first started in 3 the '60s and the '70s, did you even know whether asbestos 4 could be harmful to you? 5 A. No. 6 ,Q. I mean was it -- when was the first time you 7 .learned from the company that asbestos could cause you to 8 have lung disease? 9. MR. YOUNG: Object to the form of the 10 question. 11 Q. Was it after you were diagnosed? 12 A. Must have because nobody ever told me before I got 13 lung' disease. ;14 Q. So when couns'el suggested that you or somebody 15 else may subject yourself to a danger, did you know in the 16 '60s and *703 and early "803 that even if they said it had 17 asbestos in it, did you know that it was dangerous? 18 MR. YOUNG: Object to the form' of the 19 question. 20 A. No, no. They never said it was asbestos. They 21 said it weren't asbestos. They made you believe there 22 wasn't any there, that talc, yes, you knew you'd get dust 23 b u t ... 24 Q. And final question with regards to Florida Tile. 25 Do you have any evidence that the same type of respirators Kimberly S. Plummer, CSR (31b) 778-0187 61 1 that the workers in the mines were given was' people at 2 Florida Tile, whether they were told to wear respirators 3 like that? 4. . , csj MR- YOUNG: Object to the form of the question- 6 A. No. 7 Q. You d o n 't -- let me ask the question this way; 8 Along with the talc product that was sold out on the 9 railcars,.did you see any warnings or caution statements 10 telling the end users that they should be wearing a 11 respirator like the miners use? 12 A. Repeat that again? 13 Q. Back when they shipped out the minerals in these 14 railcars to Florida Tile, did you see any warning labels 15 that would accompany that material that would have went to 16 Florida Tile to say to the Florida Tile people: Hey, you 17 should wear a respirator? 18 A. No, no. 19 MR. SATTERLEY: Thank you, sir, those are 20 all the questions I have for you. 21 MR. YOUNG: Mr. Rogers, sorry, a couple 22 more. 23 (Continued on Page 62.) 24 25 Kimberly S. Plummer, CSR (315) 778-0187 62 1 RECROSS-EXAMINATION BY MR,, YOUNG: 3. Q. You .weren't really in charge of what information 4 went from R.T. Vanderbilt to Florida Tile, were you? 5 A. No. s Q. Okay, And you don't know what was going on at the 7 Florida Tile plant; right? 8 A. Nope, 9 Q. Okay. Presumably that they would-be following 10' appropriate safety practices in their plant? 11 MR, SATTERLEY: Object to the form of the 12 question. 13 A. No idea. f:rl4 Q. Okay. And the claim that you had against R.T. VIS 16 Vanderbilt,, the lawsuit in which you gave the deposition, it never went to court, did it? 17 A. No, J d o n 't -- never went to court as far as I 18 know of. . They just said we didn't have a claim, I guess. . 19 MR. YOUNG; Thank you, sir. Appreciate you 20 coming to see us. 21 VIDEOGRAPHER: Conclude it or -- 22 23 REDIRECT EXAMINATION BY MR. SATTERLEY; 24 25 Q. Let me just ask the question this way; You did, Kimberly S. Plummer, CSR {315} 778-0187 63 1 with regards to your Workers' Compensation, you did get 2 compensated for your -- some compensation from the company, 3 though; correct? 4' MR. YOUNG: Object to the 'form of the 5 question. 6 A. Oh, I got compensation from the insurance carrier. 7 Q. The insurance carrier paid you benefits for your 8 lung disease? 9 A. Yeah, so much a week. 10 MR. YOUNG: Same objection. 11 MR. SATTERLEY: No further questions. 12 Anybody on the telephone have questions? 13 (No response.) 14 MR. SATTERLEY: With that, let's close the 15 deposition. , 16 VIDEOGRAPHER: Testimony has concluded. We 17 are off the record at 10:49. 18 MR. SATTERLEY: W e 're off the video but the 19 witness just recalled Floyd's last name is 20 Mr. Robinson. 21 22 23 24 25 Kimberly S. Plummer, CSR (315) 778-0187 64 1 CERTIFICATION 2 3 I, Kimberly S. Plummer, a Notary 4 Public for and within the State of New York, do 5 hereby certify that prior to the commencement 6 of the examination 7 THOMAS ROGERS 8 was sworn by me to testify to the truth, the 9 whole truth and nothing but truth. 10 I DO FURTHER CERTIFY that the 11 foregoing is a true and accurate transcript of 12 the testimony as taken stenographically by and 13 before hie at the time, place and on the date 14 hereinbefore set forth. 15 I DO FURTHER CERTIFY that I am 16 neither a relative of, nor employee, nor 17 attorney, nor counsel for any of the parties to 18 this action and that I am neither a relative 19 nor employee of such attorney or counsel, and 20 that I am not financially interested in the 21 action. 22 23 24 25 Kimberly S. Plummer, CSR (315) 778-0187 65 X I have read the foregoing transcript of my 2 deposition and I find it to be true and 3 accurate to the best of my knowledge and 4 belief. 5 6 7 8 9 THOMAS ROGERS 10 11 12 13 Sworn and subscribed to before me on 14 t h i s ____ ___________ day 15 of _ . ______ , 2007. 16 17 18 1.9 N o t a r y ________ ______ 20 My Commission Expires 21 22 23 24 25 Kimberly S. 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Flummer, CSR (315) 778-0187 2 2 : 3 , 2 2 : T,2 6 : 2 4 , 4 4 :1 4 ,4 4 :1 6 ,4 5 -2 , 4 5 :4 ,4 5 .5 ,4 5 .9 . 4 5 :1 1 ,4 5 :2 4 ,4 6 :2 b a g s (1 1 -4 4 :1 7 S a lm a tp ]- 9 :7 ,1 8 :2 1 b a n d P i-5 9 :1 7 ,5 1 :2 b a n d s m -5 0 :2 5 b a s is m - 5 8 :1 1 b e c o m e n i-2 3 :4 b e g in s i n - 7 :1 b e h in d n i - 2 8 :7 b e lie f n i-6 5 :4 b e lo w p j - 1 2 :5 ,1 2 :8 , 1 2 :1 3 b e n e f i t s ( 1) - 6 3 : 7 b e s t 151- 2 1 :2 5 , 3 1 : 3 , 4 5 :2 .4 5 .8 ,6 5 :3 B e s tp i- 2 : , 4 4 :2 5 b e t t e r t i l 8 :2 0 b e t w e e n (4] - 1 1 : 1 7 , 2 0 :2 ,3 3 :1 9 ,4 1 :9 b i g [41- 1 1 :3 , 1 4 : 2 2 , 5 0 :2 5 ,5 1 :1 b i g g e s t is) - 2 3 :6 , 2 3 :7 ,2 3 :8 ,2 3 :1 1 , 2 3 :1 4 B illf l- 1 5 :2 0 ,1 5 :2 2 , 1 5 :2 3 ,1 6 :1 0 .1 6 :1 1 , 1 6 :1 4 ,1 6 :1 7 ,1 6 :2 0 , 2 5 :1 6 , 3 1 :4 , 3 1 :7 , 3 9 :2 4 b i o p s i e s 113- 5 8 : 1 6 b i o p s y (4) - 2 8 : 2 3 , 5 8 :4 , 5 8 :6 b irth n i -7 :2 0 b i t [4] 1 4 :1 9 ,1 5 :1 9 , 2 0 :2 6 ,3 1 :1 0 b l a s t i n g 11 - 1 3 . 2 B o e h t[i]-4 :7 b o n u s [1] - 1 2 :2 b o r n p j - 8 : 11, 8 :1 2 b ra k e m - 5 4 :2 5 b ra k e s [1 2 1 -5 0 :4 , 5 0 :1 1 , 5 0 :2 0 ,5 0 :2 2 , 5 1 :1 ,5 1 :1 0 , 6 1 :1 1 , 5 1 :1 4 ,5 5 :9 5 5 :1 0 , 5 5 :1 5 , 5 8 :2 5 b r a n d (21- 2 2 : 1 5 , 22:22 b r e a k p i- 15 5 ,1 5 :8 b re a th n i - 1 3 :1 6 b r e a t h e 1] - 5 2 : 1 5 b r e a t h i n g [2] 4 3 : 2 4 , 5 2 :1 6 B re s s e tte p j 4 4 :1 0 , 4 4 :1 1 , 5 6 :2 5 b r ie f ly p t - 2 0 :2 2 , 2 8 :1 6 b r i n g <i] - 1 0 : 1 6 2 b r in g in g p j - 1 0 :2 2 b ro k e p i-2 0 :4 b r o u g h t p i- 3 1 :1 5 , 5521 b u c k e tiz j-1 1 :9 , 5 1 :1 3 b u ild in g p i - 3 0 :8 b u n c h p i - 3 3 :1 4 c c a n c e r w) -2 9 :1 2 , 5 6 :1 ,5 6 :1 1 , 5 7 :2 1 c a n is te r h i -1 3 :1 0 , 1 3 :1 3 ,1 3 :2 0 c a n n o t p i- 5 0 :1 2 c a p t io n e d p j - 2 :3 c a rja ] -1 0 :2 S , 1 1 :1 0 , 5 5 :2 c a r q a r f ! ) - 1 5 :1 6 c a rp e n te r [4 ]-2 4 :1 1 , 2 4 :2 0 ,2 4 2 4 ,2 5 :2 4 C a rq u e s tp ] - 3 :1 2 C a rria g e m - 2 :8 c a r r ie r s - 6 3 :6 ,6 3 :7 c a i s p ) - 1 1 :3 C a s e rn -1 :2 C a tle ttp ] - 3 :3 c a u tio n p j - 6 1 '9 .c a u tio n s p j -3 2 :1 C c c u p a d o n a ip ] - . 5 6 :1 5 C e n te r^ ] -4 :8 ,5 6 :1 5 ` c e r a m i c |3j - 2 2 : 2 4 , 2 3 .1 ,2 3 :3 C e ra m jc R i 2 3 :2 2 3 :1 , c e rta in p - 2 6 2 4 , 4 2 :8 , 4 2 :1 3 , 4 2 -1 4 , 4 4 :8 c e rtify p ] - 6 4 :5 C e r tify ^ ) - 6 4 :1 0 , 6 4 :1 5 C h a m p ia in p i > 2 1 :9 c h a n c e p i-5 6 :1 1 c h a n g e in - 5 3 :8 c h a n g e d p j - 3 1 :1 0 , 5 0 .8 ,5 0 :1 2 ,5 3 :8 c h a n g e o v e r;,! 5 0 :1 4 c h a n g in g (D -5 0 :1 0 c h a rg e [ i ] - 5 2 :3 C h a rle s p ] -1 6 :2 3 C h a r iie p ]-1 7 :9 , 1 7 :1 2 ,2 5 :2 1 C h ild r e n p i - 8 :8 C h u b b y p j-4 4 :1 0 , 4 4 :1 1 c h y s le r iij - 4 :1 6 c J rc Ie p ) -1 3 :4 C ir c u it p ] - 1 :1 c ity p i -9 .6 C iv ilp ] - 2 :5 c la im p j - 3 3 :8 ,6 8 :2 , 5 8 :1 8 ,5 8 :2 0 ,6 2 :1 4 , 6 2 :1 8 c la im in g p i - 4 7 :8 c la s s ific a tio n s p j 2 9 :1 5 c la s s ifie d p i -2 6 :6 c le a r p j 2 7 :1 6 ,2 8 :9 , 5 4 :1 0 ,5 4 :1 7 c le ri? p i - 1 0 :6 , i0 ;9 d e v e r p j - 3 9 :2 c l o s e p j - 2 6 :9 .6 3 :1 4 C e p j-3 :9 c o p ] -2 9 :1 1 c o -w o rk e rs p j - 2 9 :1 1 c o ld p ; - 1 4 :1 2 c o lle c t p j - 2 6 :2 3 , 2 7 :1 7 c o lle c tio n p j - 2 6 :1 4 , 2 6 :1 5 c o lle g e p j - 4 5 :2 1 C o m b s p i - 4 :3 c o m in g [4 j-3 2 :2 0 , 3 2 :2 2 ,5 2 :1 8 ,6 2 :2 0 c o m m e n c e m e n t;? ] 645 c o2:m10m e n c i n g p i - C o m m is s io n ;!! 6 5 :2 0 c o m m o n 3 -5 3 .6 , 5 3 :1 0 c o m m u n ic a tio n p i 4 7 :1 7 c o m p a n y p 4 j 8 :2 2 , 9 :2 ,9 :4 ,9 :5 , 9 :9 , 9 :1 2 .1 0 :1 2 ,1 1 :2 2 . 1 3 :7 ,1 5 :1 3 ,1 5 :1 5 , 1 9 :1 7 ,1 9 :2 4 ,2 0 .1 3 , 2 1 :1 3 ,2 1 :1 6 , 3 1 :2 0 , 3 1 :2 2 ,3 8 :6 , 3 8 :2 2 , 3 8 :2 5 ,4 4 :8 , 6 0 :7 , 6 3 :2 C o m p a n y is j - 8 :2 2 , 9 :1 5 ,1 8 :2 3 , 5 4 12, 5 5 :1 9 c o m p a r e (2j - 5 5 : 1 5 , 5 5 :1 .6 c o m p a re d p j - 5 5 :1 3 c o m p e n s a te d p ] - 6 3 :2 c o m p e n s a tio n p ] - 2 1 :2 1 ,6 3 :2 ,6 3 :6 C o n p e n s a tio n n j- 6 3 :1 c o m p re s s e d p i- 4 1 :9 ,4 1 :1 4 c o n c e rn p j - 2 6 :5 C o n c lu d e ;!] - 6 2 :^1 c o n c lu d e d p i - 6 3 :1 6 c o n d itio n p -5 8 :3 c o n d itio n s p j - 1 2 :2 4 c o n fid e d p j - 2 0 :2 5 C o n k lin ;^ -1 7 :1 8 , 1 7 :2 5 ,2 5 :2 1 ,3 9 :1 6 , 3 9 :2 3 ,3 9 :2 5 C o n ld lrfs p j -1 7 :1 9 C o n td p ]-4 :1 c o n ta in p i 5 0 :1 8 c o n t a i n i n g [1] - 4 9 : 2 5 c o n te n t p j - 2 7 :1 1 c o n tin u e p i-9 :8 C o n tin u e d !!]-6 1 :2 3 c o n t r a c t ^ - 2 3 :2 3 , $ 4 :1 ,2 4 :3 ,2 4 :6 , 2 4 :7 ,2 4 :8 c o n tra ry p i-3 7 :8 c o n v e rs a tio n s p j4 6 :1 6 ,4 7 :2 1 c o n v e y e d p i - 3 1 .2 c o o l p j-1 4 :9 C r p [5 j- 1 :1 0 ,3 :1 2 , 4 :1 6 ,4 :1 6 C o r p o r a tio n ^ ] - 4 :6 , 4 :1 2 c o rre c t p j -1 4 :4 , 1 9 :1 ,2 8 :1 0 ,3 0 :2 4 , 5 4 :1 2 ,6 6 :1 9 ,6 3 :3 C o tte n p j- 3 1 :1 6 C o u n s e ls - 5 5 :2 3 , 5 6 :1 6 , 5 7 :8 ,6 0 :1 c o u n s e l jsj - 5 8 : 7 , 5 8 :1 ,6 0 :1 4 ,6 4 :1 7 , 6 4 :1 9 c o u p l e r > 5 1 :2 1 , 5 4 ;9 ; 5 5 :8 , 5 8 :2 3 , 6 1 :2 1 c o u r s e p i - 1 3 :3 , 1 3 :1 2 ,2 5 :1 ,5 4 :2 C o u i t [ 2j - 1 : 1 , 2 : 6 c o u r t p j- 2 1 :5 ,2 1 :6 , 2 1 :2 0 , 2 1 :2 4 ,4 2 :2 4 , 4 3 :2 ,6 2 :1 6 ,6 2 :1 7 c ro s s p j -1 0 :2 3 , 4 9 :4 , 4 9 :7 C r o s s j 4j - 5 : 8 , 5 : 9 , 3 2 :1 3 , 5 4 :6 C r o s s e x a m | 1] - 5 : 8 C ro s s e x a m in a tio n p ] -5 ;9 , 3 2 :1 3 ,5 4 :6 c r a s h e r - ig - 1 0 :1 8 , 1 4 :2 0 .1 4 :2 2 ,1 5 1 , 1 5 :2 ,1 5 :4 ,1 5 :5 , 1 5 : 8 . 17-21,1 7 :2 5 , 1 8 :3 ,1 8 :5 ,5 2 :1 4 c ru s h in g p j 1 4 2 2 c u rre n ts p j-1 3 :3 c u s to m e r h i - 2 3 :7 , 2 3 :9 ,2 3 :1 1 ,2 3 :1 4 c u s to m e rs p j - 2 3 :5 , 2 8 :1 ,2 8 :1 3 c u t [ 2j - 1 0 : 2 3 , 4 9 : 7 c u t s [1J - 4 9 : 4 0 0 a im ie rp j-4 :1 6 D a im le r-c h y s le rp j - 4 :1 6 d a m n p j - 5 8 :1 7 d a n g e r p j-6 0 :1 5 d a n g e ro u s p j - 6 0 .1 7 d a t e 4j-7:3,7:20, 5 0 :1 3 ,6 4 :1 3 d e a d p j-4 1 :6 d e a lp j- 5 3 :1 3 d e c id e d p j - 8 :2 0 , 4 8 :1 8 d e d a r e d p i-2 6 :9 d e e p p j- 1 2 :2 0 D e fe n d a n t; ] - 3 .1 2 , 4 :9 ,4 :1 2 ,4 :1 6 D e fe n d a n ts ^ -1 :1 1 . 3 :9 ,4 :6 d e n y 3 ]-2 1 2 ,2 3 -1 0 , 2 5 .1 1 D e p o s itio n p j -1 :9 , 7 :5 ' d e p o s itio n p o ; - 2 :2 , 2 ,4 , 7 2 .1 6 :9 , 3 1 :1 5 , 3 3 :1 1 ,3 3 :2 0 ,6 2 :1 5 , 6 3 .4 5 , 6 5 :2 d e p o s itio n s p j 3 3 :1 9 ,4 7 :4 d e s c r ib e p ; - 1 2 :2 3 d e s c rib e d p j - 1 6 :5 , 1 8 :1 D e s c rip tio n ] - 6 :3 d e t a i l [2j - 1 4 : 1 9 , 2 8 :1 8 d e v e lo p p j 5 8 :1 9 d e v e lo p e d p j - 2 9 :1 2 d ia g n o s e d [aj > 2 8 :1 8 , 2 9 :6 ,6 0 :1 1 d ie d ; s j- 4 0 :8 ,4 0 :9 , 5 5 :2 0 ,6 5 :2 5 ,5 7 :2 1 d iffe re n c e p j - 1 1 :1 7 d iffe re n t p j -1 5 -6 , 2 9 2 2 ,5 0 :9 D ire c tp ) - 5 :7 ,7 :1 3 d is c u s s e d p j - 5 2 :6 d i s c u s s i o n |3j - 3 0 .1 3 ,3 2 :1 0 ,5 1 :1 9 d is e a s e h i - 5 8 :2 0 , 6 0 :8 ,6 0 :1 3 ,6 3 :8 d is trib u te d p j - 2 8 .1 d o c t o r s -2 8 :2 5 , Kimberly S. Plummer, SR {315) 778-0187 5 8 :7 d o c to re p j- 5 8 :1 6 D o c u m e n tp ]-1 :2 d o c u m e n t jz j - 1 6 :9 , 1 8 :9 d o l a i s [2) - 2 5 : 1 4 , 5 7 :1 7 d o n e p i - 1 2 :8 ,2 8 :2 3 , 4 2 :2 3 ,4 9 :1 2 , 5 8 :4 d o w n J28| - 1 0 : 1 7 , 1 1 :1 ,1 1 -4 ,1 4 :6 , 1 4 :7 ,1 4 :1 1 , 1 4 :2 3 , 1 4 :2 5 , 1 5 :6 , 1 5 :9 , 1 6 :5 , 1 7 :1 4 , 2 0 :4 , 2 4 :2 ,2 6 :6 ,2 6 :2 0 , 2 7 :1 ,3 4 :1 2 , 3 4 :1 5 , 3 8 :1 4 , 3 9 :4 ,3 9 :1 8 , 4 3 :1 7 ,4 3 :1 9 , 5 1 :8 , 5 2 :1 1 ,5 2 :1 2 ,5 2 :1 3 d ra w e d ji] -1 4 :2 4 d re s s e d m -2 6 :2 d r ill e r p ] - 1 0 :2 4 d r i v i n g p j - 10:6 d r o p p i - 1 0 .2 4 d r a m s t u - 5 1 :1 2 d u g p i - 1 2 :3 d u l y p j - 7:10 d u m p H j- 1 0 :1 7 , 1 1 :1 ,1 1 :4 ,1 1 :1 0 d u r in g p i - 1 5 :1 6 d u s tp s j -1 2 :2 5 ,1 3 :1 . 1 3 :2 ,3 8 :1 8 ,3 9 :8 , 4 3 :1 8 ,4 3 2 4 ,5 2 :1 5 , 5 2 :1 9 ,5 2 2 0 , 5 5 :1 0 , 5 5 :1 2 ,5 5 1 3 ,5 5 :1 4 , 6 0 :2 2 E e a r ly j3 i - 2 3 :1 8 , 2 4 :2 1 ,6 0 :1 6 e a rth p i - 2 7 :2 5 E a to n p j-4 .1 2 E d p j -1 3 :2 4 e ffe c t p j - 5 6 :1 2 e ith e r 2 i- 4 0 :1 ,4 3 :3 EBJ3J- 3 9 :1 , 3 9 :2 , 5 7 :1 9 E Is a b e ji]-4 :9 e m i t t e d [1] - 5 5 : 1 0 e m p lo y e e h i - 1 1 :2 1 , 1 1 :2 4 ,6 4 :1 6 ,6 4 :1 9 e m p lo y e r;-!] - 5 7 :4 E n c o p ]- 1 0 :2 3 ,1 1 :5 , 1 1 :6 ,1 1 :2 0 e n d K ] - 1 1 :8 ,2 4 :5 , 2 5 :3 ,6 1 :1 0 e n g a g e p j - 5 1 :1 2 e n g in e e r;!] -3 1 :2 2 e n fir e p i -1 8 :2 2 3 e n tir e ly 2 1 -2 7 :1 5 , 4 9 :1 5 7 :5 ,5 9 :6 ,5 9 :2 4 , 6 2 :1 7 e q u ip m e n t in - 5 4 2 5 fa r m in g ia -8 :1 8 , E rd m a n n - 2 3 :1 6 , 8 :1 9 2 4 :2 ,4 4 :1 0 f a u lt -2 4 :3 e s p e c ia lly p i - 2 1 .3 f e e t [5) - 1 2 : 1 3 , 1 2 ; I 5 . E s q - 3 :8 , 3 :1 2 ,4 :6 , 1 2 :2 1 ,1 2 :2 2 , 5 1 :3 4 :9 ,4 :1 2 ,4 :1 5 fe llo w -1 7 -1 7 , E s ta te ] -1 :5 2 1 ;1 0 ,2 9 :1 6 ,3 1 .1 4 , e t ] - 1 '1 0 3 5 :2 ,3 9 :1 .4 4 :1 3 , . E v a n s -? 9 ;2 4 , 2 9 :2 5 ,3 0 :1 ,3 0 :2 e v e n tu a lly ; - 2 4 :7 4 7.-2 4 , 5 2 :2 f e l l o w s pi 3 9 : 2 0 , . 4 7 :1 1 1 e v i d e n c e [>i]- 1 6 : 1 6 , f e l t r i - 3 3 :2 5 1 9 :5 ,3 1 :2 4 ,6 0 :2 5 f e w p j - 1 5 :2 0 ,1 S :2 3 , E x ii]-6 :3 E x a c tly ; - 4 0 .6 1 9 8 ,1 9 :2 2 ,3 0 :1 5 , 3 7 :8 ,5 6 :2 6 e x a c tly in 4 6 :1 7 f i g h t - 2 5 :9 , 2 6 :1 2 e x a m ] - 5 .8 E x a m in a tio n - 1 :1 0 , ,2:3, 5 :7 , 6 : 1 0 , '5 :- l2 ,7 :1 3 ,5 6 :6 , ' fig h tin g s i- 2 6 :8 , 3 4 :1 0 ,5 3 :1 file d m -3 3 :1 2 f ilin g - 5 8 :1 0 , 6223 5 8 :1 1 e x a m i n a t i o n isj - 5 :9 , 5 :1 1 ,3 2 :1 3 , 5 4 :6 , f ill [ i f - 5 5 :1 fin a l - 3 0 :1 6 ,6 0 :2 4 6 2 :1 ,6 4 :6 e x a m i n a t i o n s [ 1] - F in a tn -3 1 2 3 f i n a l l y [1) - 5 8 : 2 3 1 5 :1 7 . fin a n c ia lly ] - 6 4 :2 0 e x a m p le ]- 1 2 :1 5 E x c e p t ] - 4 4 :1 9 f i n e (2) - 2 8 : 6 . f ir e ) - - 1 0 :2 4 e x c e p t 121- 1 1 : 1 2 , 3 1 :4 E x c c s e (2i - 1 1 : 2 3 , F ir s t }-5 4 :1 0 f ir s t is ] - 7 :1 Q , 8 :2 4 , 9 :1 , 1 0 :1 9 ,2 1 :2 3 , 3 5 .1 6 e x e c u tiv e r i] - 2 4 :1 1 3 2 :1 6 ,4 4 :2 0 ,6 0 :2 , 6 0 :6 E x h ib its - 7 :6 ,1 6 :8 , fiv e [II -3 8 :9 1 6 :1 7 , 1 7 7 ,1 7 :1 6 , F lo r a t ij- 1 :5 8 :1 0 ,1 8 1 6 F lo rid a ? ] -2 3 :6 , E x h ib its ] -1 9 :5 | 2 3 -0 ,2 3 :1 3 , 2 3 :2 2 , E x p ire s ] - 6 5 :2 0 2 3 :2 3 ,2 3 :2 4 ,2 8 :1 4 , e x p la in [ 3 j - 1 0 :2 0 , 3 1 :2 5 ,6 0 :2 4 ,6 1 :2 , 1 4 :1 9 6 1 :1 4 ,6 1 .1 6 .6 2 :4 , e x p o s e (ii - 3 8 :2 0 6 2 :7 e x p o s e d [s i-3 8 :1 7 , F lo y d : ] -2 0 :1 0 , 4 3 :1 7 ,4 3 .2 1 ,4 7 :8 , 5 6 :1 0 2 0 :1 1 ,2 0 :1 6 ,2 0 :1 7 , 2 0 :2 3 , 2 0 :2 5 ,2 1 :7 , 4 2 :2 0 .4 3 :1 5 ,4 7 :3 F fa c t [ ij - 4 7 :2 3 fa ile d [ i j - 2 5 :3 F lo y d s H i - 6 3 :1 9 f o g n i - 1 3 :1 6 fo lk s [1 4 1 -1 0 .2 1 , 1 2 :2 3 ,1 9 :1 6 ,1 9 :2 0 , f a i r ly is i - 1 6 : 1 3 , 1 7 :1 0 ,1 8 :1 2 2 0 :2 3 ,2 3 :1 3 ,2 4 :2 2 , 2 6 :1 6 ,2 6 :1 8 , 3 4 :1 9 , fa irn e s s m -4 7 :2 0 3 5 :2 4 , 3 6 :6 ,3 6 :1 0 , F a it h - 8 :5 , 6 :6 , 8 :8 , 8 :1 0 3 6 :1 8 f o l l o w [ 1) - 5 5 : 8 fa m ilia r p i - 2 2 :1 4 . fo llo w - u p n j - 5 5 :8 2341, 5 9 :1 6 F o llo w in g ] - 1 :2 f a r [91 - 8 : 1 4 , 1 0 : 2 2 , 1 fa llo w in g p [ - 6 2 :9 1 6 :3 ,4 7 :2 , 6 2 :7 , | fo llo w s ]-7 :1 1 f o o t p ) - 1 0 .1 7 ,5 2 :1 1 , ` 5 2 :1 3 F o rd ? )-4 :1 6 fo r e g o in g p i- 6 4 :1 1 , 6 5 :1 F o re m a n ! - 3 9 :6 , fo re m a n [i3 [-1 9 :2 2 , 1 9 :2 3 ,1 9 .-2 4 , 2 1 :1 3 , 2 1 :1 4 .2 1 :1 6 ,2 2 :9 , 2 2 :1 0 , 3 7 :1 5 , 3 8 :1 6 , 4 3 :1 5 , 4 4 :1 2 ,5 3 :1 5 fo r e m e n s i n - 3 9 :4 fo n e n o o n ]- 2 :l1 fo r m p n - 1 1 :8 ,1 9 :1 2 , 2 5 :1 5 ,2 7 :6 ,2 8 :2 0 , 3 6 :1 3 , 3 6 :2 0 , 3 8 :2 3 , 4 0 :4 , 4 1 :1 4 ,4 1 :2 0 , 4 2 :1 9 , 5 6 : 1 5 , 5 6 .'2 0 , 5 7 :1 ,5 8 :1 4 ,6 0 :9 , 6 0 :1 8 ,6 1 -4 ,6 2 :1 1 , 6 3 :4 fo rm s [ ij-2 0 2 fo r th [1 1 -6 4 :1 4 fo u r p j -1 0 :1 0 ,2 4 :1 , 3 8 :9 fra m e 1-2 4 :2 0 F ra n k lin - 1 :4 ,1 :5 F re d - 3 1 :1 5 ,3 6 :3 , 4 2 :2 3 ,5 1 :2 5 , 5 2 :3 F re d e ric to n - 4 :1 9 fre e z e j -1 4 :1 0 f r o n t -1 1 .8 , 1 1 :9 f r o n t - e n d J - 1 1 :8 F u iie rr -1 5 :2 0 , 1 5 :2 2 ,1 5 :2 4 ,1 6 :1 0 , 1 6 :1 1 ,1 6 :1 4 ,1 6 :1 7 , 1 6 :2 0 ,2 5 :1 8 ,3 1 :4 , 3 1 :7 , 3 1 :1 2 , 3 9 :1 6 , 3 9 :2 3 ,3 9 :2 4 ,3 9 :2 5 , 4 0 5 ,4 0 :7 ,5 6 :7 G g a te s p j - 1 4 :2 3 , 1 4 :2 5 g a th e re d (i)-4 3 :6 G e n e ]-5 4 :8 G e n e r a l ! - 1 :1 0 g e n tle m a n ] - 3 9 :1 5 g e n tle m e n ]-7 :1 6 g e n u i n e l y t2i - 5 2 : 2 4 , 5 3 :3 G e o r g e m i- 2 1 :1 0 , 2 1 :1 7 ,2 2 :1 0 ,2 3 :1 6 , 2 4 :2 ,2 9 :2 4 , 3 0 :1 , 3 0 :2 ,4 4 :1 0 ,4 4 :1 3 , 4 5 .1 2 G e o r g i a - 3 : 8 , 4 :6 G e o rg ia -p a c ific ! 4 :6 g iv e n - 1 5 :1 1 , 1 5 :1 7 ,2 8 :2 5 ,3 3 :1 1 , 3 3 .1 9 ,6 1 :1 g la s s e s -1 3 :1 1 , 1 3 :1 2 ,1 4 :1 2 ,1 4 :1 3 , 1 4 :1 7 G m l - 4 :1 6 g o n n a ]--8 .-1 9 G o u v e rn e u r o j - 8 2 2 ,9 :1 5 ,1 8 :2 3 , 2 3 :5 , 5 4 :1 1 , 5 4 :1 4 , 5 5 :1 8 , 5 5 2 4 ,5 6 :8 , 5 9 :2 2 g o v e rn m e n t ] - 3 6 :6 , 3 6 :9 ,3 6 :1 7 ,3 7 :5 g r a d e |2i - 8 : 1 6 , 0 : 1 7 G ra v e s ] - 4 :7 g r o u n d [4[ - 1 2 : 5 , 1 2 :8 ,1 2 :1 3 ,2 8 :6 g u e s s -1 2 :3 , 1 8 :2 2 ,2 5 :2 , 2 8 :1 , 3 1 :1 1 ,3 7 :1 0 ,3 8 :1 0 , 4 4 :1 1 ,6 2 :1 8 g u y s - 3 4 :1 0 , 3 4 :1 2 , 3 6 :2 5 , 5 2 :1 5 . 5 5 '1 4 H H a m m o n d ] - 8 ;-i3 h a n d ]-5 3 :1 1 h a r d ] - 4 4 :3 h a rm fu l -6 0 :4 H a rris v ille ] - 7 :1 9 H a w k in s !- 3 :6 h e a lth p i -3 1 :7 , 4 8 .1 3 h e a r d -2 2 :1 8 , 2 2 :2 0 ,4 9 :1 2 H e r b p i- 1 7 :1 8 , 1 7 :1 9 ,2 5 2 1 h e re b y 1 -6 4 :5 h e r e in b e fo re ]- 6 4 :1 4 h ig h p ]- 8 . 1 5 , 2 7 :1 1 h im s e lf - 3 8 :2 1 , 5 7 :1 4 h ire ] -5 7 :1 0 h m m ' 2] - 1 3 : 1 9 , 4 8 : 5 h o n e s tly ]-4 1 :1 H o n e y w e ll ] - 4 :9 h o u r ly - 1 1 :2 1 , 1 1 :2 4 ,1 2 .1 H o u s e | - 2 :8 H u g h -2 4 :1 6 , 2 4 :1 7 , 2 4 :1 9 ,2 4 :2 3 , 3 2 :2 0 ,4 7 :2 3 | Id e a -4 3 .5 ,4 3 .1 0 , 5 2 :4 ,6 2 .6 ,6 2 :1 3 id e n tific a tio n ]-7 :6 Id e n tify ] - 17-17 ii j- 3 :1 2 im a g in e ] - 3 6 :3 lm c o | - 1 1 :5 im p o r ta n t -4 6 :1 3 , 4 6 :1 9 Im p re s s io n p j - 3 4 :1 , 3 7 :9 im p ro p e r ]-4 7 :1 8 (n G [ij-3 :9 in c lu d e d ] - 1 9 .1 0 , 2 0 :1 8 , 5 9 :2 3 In c lu d in g 1 -5 6 :2 3 in c lu s iv e ! ! ! - 7 :6 In d e x ) -1 :6 in d ic a tin g p i-1 8 :2 1 , 5 1 :3 in d iv id u a l ] - 2 4 :1 5 In d iv id u a lly ] - 1 :4 in f o r m a t io n [6 j - 2 9 :1 , 3 1 :1 ,4 3 :6 ,4 7 :5 , 4 7 :1 2 ,6 2 3 in g r e d ie n ts ]-5 9 :1 4 In s id e ] -4 4 :2 3 in s u la tio n ]-4 9 :1 9 , 4 9 :2 5 , 5 p .3 in s u r a n c e iz] - 6 3 :8 , 6 3 :7 in te r e s te d j - 6 4 :2 0 in te r n a tio n a l ] - 4 :9 In tro d u c e ]- 7 1 5 in v a d e - 4 6 :1 0 , 4 7 :1 7 ,4 7 :2 3 in v e s tig a te 1 -3 4 :1 8 In v o lv e d ]-2 6 :1 5 is s u e - 2 5 :1 0 , 2 5 :1 4 is s u e d )-3 1 :2 5 its e if ] - 2 2 .7 J J e ffe rs o n ] - 4 :4 , 4 :1 1 j o b 1] - 9 : 1 , 9 : 2 2 , 1 0 :4 ,1 1 :1 4 ,1 4 :1 , 1 7 :2 ,1 7 1 9 , 2 2 :2 1 , 2 9 :1 5 ,2 9 :1 9 ,3 0 :5 jo b s ) -3 4 :1 2 J o e ] - 5 5 :8 J o h n n y -1 :4 J o s e p to n -2 1 2 J i ]-4 :1 2 - J u ly i4] - 2 : 1 0 , 7 : 3 , 7 :2 1 Kimberly S. Plummer, CSP. (315) 778-0187 4 ju ry [? [-7 :1 6 ,1 0 :2 0 , 1 0 :2 1 ,1 2 :2 3 , 2 0 :2 3 , 2 4 :2 2 ,2 6 :1 8 K K e e n o n [i)-3 :1 0 k e e p p j - 3 4 :1 2 , 5 7 :1 6 K e n tu c k y ! ! - 1 :1 ,2 :4 , 3 :1 1 ,4 :8 ,4 :1 1 ,4 :1 5 k c p tp j - 3 4 :7 K im b e r iy ff - 2 :6 , 6 4 :3 k in d p ] - 5 0 :4 ,5 2 :1 7 k n o w le d g e [5 ;-3 1 :3 , 4 5 :1 6 ,5 3 :6 , 5 3 :1 0 , . 6 5 :3 k n o w n (4) - 3 1 : 5 , 4 0 :1 1 , 5 1 :2 4 ,5 1 :2 5 K y p i - 3 :4 ,4 :5 L l a b 17] - 2 5 . 1 1 , 3 0 : 6 , 3 4 :6 , 3 4 :1 8 ,3 5 :6 , 3 5 :6 ,5 3 :2 4 la b e ls ( i i - 6 1 :1 4 la b o ra to rie s m - 5 7 :1 4 L a b o re rm - 9 :3 la b o r e r s -9 :1 4 , 9 :1 8 ,9 :2 1 la b s )- 2 5 2 la d ie s p ) - 7 .1 5 U rk e p ]-2 1 :9 L a n e p i - 3 :6 ,3 2 :1 5 L a r ry is j- 3 0 :3 ,3 0 :4 , 3 4 :2 4 ,4 1 :2 5 ,5 8 :2 3 l a s t [ j - 1 6 :1 5 , 2 0 :1 1 ,2 0 :1 6 , 2 1 :7 , 3 0 :1 9 , 3 0 :2 0 , 3 1 :7 , 4 0 :9 ,4 2 :2 0 ,4 2 :2 3 , 4 6 :2 2 ,4 7 :3 ,4 9 :1 0 , 6 3 :1 9 l& te p ]- 2 3 :1 7 L a te p ] - 2 4 :2 1 Ia W |3J - 4 6 : 1 5 , 4 6 : 1 8 , 4 7 :2 5 L a w re n c g i) -1 8 :1 3 la w s u it p i- 3 3 :1 2 , 4 7 :2 ,4 7 :7 ,5 8 :1 1 , 6 2 :1 5 la w y e r s - 3 2 :1 6 , 3 2 .2 5 ,3 3 :3 , 3 3 :6 l a w y e r s J2) - 3 3 : 7 , 3 3 :1 4 le a r n e d [1 1 -6 0 :7 le a s tp ] -1 6 :1 4 ,4 7 :1 1 l e a t h e r (10| - 2 0 : 3 , 2 0 :5 , 4 1 :8 ,4 1 :1 0 , 4 1 :1 1 ,4 1 :1 3 ,4 2 :1 , 4 2 :7 ,4 3 :1 2 l e a v e |2] - 8 : 1 8 , 9 : 1 2 U e o riB i 1 9 :2 1 ,2 3 :1 5 , 3 7 :1 6 ,4 1 :4 ,4 4 :1 0 , 4 4 :1 1 le v e l [1 5 ]-1 0 :1 7 ,1 1 :1 , 1 2 :7 .1 4 -2 1 ,1 4 :2 4 , 1 4 :2 5 ,1 5 :5 ,1 8 :1 . 1 8 :2 ,1 8 :8 ,2 7 :1 9 , 2 9 :2 2 ,5 2 :1 1 ,5 2 :1 3 le v e ls ; ] - 1 2 :8 , 1 2 :1 7 ,1 2 :2 6 ,1 6 :6 , 1 8 :1 ,2 7 :2 3 L e x i n g t o r t i ; - 3 :1 1 lie P I - 2 1 :6 ,4 3 :2 llm e p y - 2 7 :1 0 ,2 7 :1 1 lin e s p j 1 4 :1 0 L it lg a t io m i - 2 :1 3 Ih re p q -7 -1 8 ,2 1 :8 l i v i n g [ 1] - 8 :2 0 i o a d e r p i - 1 1:8 l o c a t e d m -9:6 , 2 1 :1 5 ,2 7 :7 lo c a tio n [2 1 -2 8 :3 , 2 8 :1 2 L o n g s tr e e tn - 3 3 :5 lo o k p j -1 4 :2 1 ,4 2 :2 . lo o k e d P I- 3 4 :1 9 , 4 1 :8 ,4 1 :1 0 lo o k in g p i - 3 5 :7 , 3 5 :2 1 lo s t w - 2 3 :2 3 ,2 3 :2 5 , 2 4 :3 ,2 4 :5 L o U i t [ 4] ' 2 3 : 1 5 , 3 7 :1 6 ,3 8 :9 ,3 9 :2 L o u is p j - 3 7 :1 7 L o c ls v lllq s ? 3 :4 ,4 :5 . 4 :8 ,4 :1 1 ,4 :1 5 lu c k y p i - 5 8 :2 2 lu n g p i- 5 6 :1 ,5 7 :2 1 , 5 8 :4 ,5 8 :6 , 5 8 :2 0 , 6 0 :8 ,6 0 :1 3 .6 3 :8 lu n g s p j - 5 8 :1 2 M m a c h in e n ]- 5 5 :1 0 m a c h i n e s pi- 4 9 : 2 0 , 5 0 :5 , 5 0 2 2 , 5 5 :1 1 , 5 5 :1 5 , 5 8 :2 5 , 5 9 -7 m a in p i - 3 4 :2 5 , 5 2 :1 4 , 6 9 :1 4 M a i n 2) - 3 : 4 , 4 : 1 4 m a i n t e n a n c e [41 - 9 2 4 ,9 :2 5 ,1 0 :3 , 1 0 :5 M a l b o u f f [ 7] - 3 0 :3 , 3 0 :4 ,3 4 :2 4 ,3 5 :3 , 3 5 :4 ,4 1 :2 4 , 5 8 :2 3 m a n 6 ]-1 1 :2 ,1 1 :1 8 , 1 1 :2 0 ,3 8 :6 ,3 8 :2 2 . 3 8 :2 5 m a n a g e m e n t [? ]1 9 :1 6 ,1 9 :2 0 ,2 0 .1 3 , 2 1 :3 ,2 3 :1 2 ,5 6 :1 9 , 5 9 :2 1 M anagem ent Pi 2 3 :1 0 ,2 7 :3 m a n a g e r [3] - 2 0 : 9 , 2 0 :1 5 ,4 3 :4 m a p [2] - 1 8 : 1 0 , 1 8 : 2 5 m a rk p ] - 2 6 :2 4 m a rk e d p j - 7 :6 ,1 6 :8 , 1 7 :7 M a rk e t p ) - 4 :7 m a r r ie d p i - 8 :2 , 8 :6 m a s k fs ]- 1 3 :8 ,1 3 :1 3 , 1 5 :1 2 ,3 9 :1 2 ,4 0 :1 8 , 4 0 :2 3 m a te r ia l h ; - 2 7 :1 8 , 4 3 :1 2 , 5 0 :9 ,6 1 :1 5 m a te r ia ls p j - 1 8 :5 , 4 5 :2 m a tte r p j - 2 :3 m e a n [4 ]-1 2 :1 1 , 3 7 :2 1 ,5 5 :1 3 ,8 0 :6 m e a n s [1] - 1 2 : 1 5 m e c h a n ic p i - 9 2 4 , 1 0 :1 ,1 0 :3 ,1 0 :5 m e d ic a l P I-2 9 :1 m e e t i n g [5] - 2 5 : 2 4 , 3 5 :2 4 ,3 8 :1 1 ,5 2 :9 , 5 3 .1 1 m e n PI 2 0 :2 5 ,2 6 :2 2 , 4 3 :2 0 m e n tio n p i - 2 5 :8 m e n tio n e d [ 4 j - 1 1 :5 , 1 2 :7 ,2 1 :2 ,5 7 :1 9 m e s o th e lio m a P i 5 5 :2 0 m e t P I- 3 0 :1 6 ,3 2 :1 6 M e ye r p i-4 :9 m ig h t(4 j-9 :1 6 , 3 5 :2 1 ,4 2 :2 3 , 5 0 :7 m ile s P )-1 9 :3 m ill p i] -1 5 :1 0 , 2 1 :1 4 ,2 8 :5 ,2 8 :8 , 2 8 :1 0 ,2 8 :1 2 , 3 0 :7 , 3 0 :8 , 3 0 :9 ,4 4 :2 1 , 5 0 :2 M ille r p j - 4 :1 3 m ille rs p i - 5 5 :2 5 . 5 6 :9 m illio n s p j- 2 5 :1 3 , 5 7 :1 7 m ills P i-5 0 :1 m in d P ) - 5 8 :6 m in e [4 2 1 -1 0 :2 1 . 1 3 :7 ,1 5 :2 5 ,1 7 2 2 , 1 8 :6 ,1 8 :1 6 ,1 8 :2 0 , 1 9 :2 2 ,1 9 :2 3 ,1 9 :2 4 . 2 0 :7 ,2 1 :2 2 ,2 2 :1 6 , 2 6 :1 0 ,2 7 :1 8 ,2 8 S , 3 2 :2 0 ,3 2 :2 2 , 3 3 :2 4 , 3 4 :1 1 ,3 4 :1 5 ,3 4 :1 6 , 3 9 :4 ,4 0 :1 6 ,4 2 :6 , 4 2 :1 1 ,4 2 :1 6 ,4 4 :2 1 , 4 5 :1 2 ,4 7 :9 ,4 8 :4 , . 4 8 :1 4 , 4 9 :1 9 , 4 9 :2 0 , 5 0 :5 ,5 2 :8 .5 2 :1 2 , 5 3 :6 .5 3 :1 0 , 5 3 :2 2 , 5 5 .1 , 5 7 :2 2 m i n e d [3] - 4 9 : 1 , 4 9 : 2 , 49:5 m in e ra lo g is t p j- 3 5 :1 7 m in e ra ls im -1 8 :5 , 1 9 :1 0 ,2 0 :1 8 ,2 0 :2 4 , 2 1 :1 8 , 2 1 :1 9 ,2 7 :2 5 , 5 5 :1 4 , 5 6 :1 0 ,5 9 :2 3 , 6 1 :1 3 . m in e rs p j - 2 5 :2 3 , 5 5 :2 5 , 5 6 :9 ,6 1 :1 1 . M in e s p j - 5 5 :2 4 m i n e s p 9) - 9 : 1 9 , 1 2 :1 9 ,1 2 :2 5 ,1 4 :6 , 1 6 :5 , 1 6 :2 0 ,1 7 :1 4 , 1 7 :2 0 ,1 9 :3 ,1 9 :1 0 , 2 0 : 1, 2 0 :1 8 ,2 1 :1 8 , 2 3 :1 8 , 2 3 :2 2 ,2 5 :1 0 , 2 6 :5 ,2 6 :6 ,2 6 :1 6 , . 2 6 :2 1 ,2 7 :2 5 , 3 8 :1 4 , 3 9 :8 ,3 9 :9 ,4 3 :1 7 , 4 8 : 1 3 , 4 9 : 2 5 , 50:2, 5 2 :1 ,6 4 :1 8 ,6 5 .2 0 , 5 5 :2 5 ,5 6 :1 0 , 5 9 :1 , 5 9 :4 ,5 9 :5 ,5 9 :1 1 . 5 8 :2 3 ,6 1 :1 m i n i n g [4j - 1 0 :2 0 , 1 8 :1 3 ,4 9 :5 , 5 5 :1 4 M in k le r p ) -1 6 :2 3 , 1 6 :2 4 ,1 6 :2 6 ,1 7 :1 1 , 2 5 :2 1 , 3 9 :1 6 , 3 9 :2 3 , 4 0 :1 m in u te s p i - 3 7 :8 M o ira p i - 2 1 :9 m o n e y (s i-2 5 :9 , 2 5 :1 7 , 5 7 :1 Q , 5 7 :1 3 , 5 7 :1 8 m o n ito r y -1 5 :1 3 , 1 5 :1 4 ,1 5 :1 5 m o n th p ] - 7 :2 5 m o n t h s p j - 1 0 :1 0 m o rn in g S i - 3 0 :1 6 , 3 0 :2 3 , 3 2 :4 , 3 2 :1 7 , 3 6 :4 ,5 1 :2 3 m o s t p i -1 3 .9 ,1 7 :2 1 , 3 9 :2 m o s tly p j - 5 0 :1 5 Kimberly S. Plummer, CSR (315) 778-0187 M o s tly p ] - 2 3 .6 m o to r p j - 6 1 :8 M o to rp ]-4 :1 6 M o to r s p j - 1 :1 0 m o u n t a in (sj - 2 0 :3 , 4 1 :1 2 ,4 1 :1 3 ,4 2 7 , 4 3 :1 1 m o u th p i - 1 3 :1 5 m o v e p ] -1 6 :1 6 ,1 9 :6 , 4 6 :2 2 m u lle d p i-3 7 :2 1 M u llin p u - 2 1 :1 0 , 2 1 :1 1 ,2 1 :1 7 ,2 2 :1 . 2 2 :1 0 ,4 4 :1 3 ,4 5 :1 1 , 4 5 :1 2 .4 5 :1 9 ,4 7 :3 , ' 5 6 :2 3 m u ltip lie d P i- 5 6 :1 1 M u s t 12] - 3 6 : 1 , 4 5 : 4 , 8 0 :1 2 r n u s tp j - 3 8 :1 3 , 4 3 :2 3 N n a m e p g -8 :4 ,2 0 :1 0 , 2 0 :1 2 ,2 0 :1 7 ,2 4 :1 4 , 3 5 :1 9 ,3 7 .1 8 ,4 2 :2 0 , 4 2 :2 3 .4 4 -1 1 ,4 7 :3 , 5 4 :8 ,5 5 :2 1 , 5 9 :1 6 , 6 3 :1 9 N a m e p ] - 5 :3 n a m e d p i - 21:10, 2 9 :1 7 ,3 1 :1 5 n a m e s [7 ]-1 9 :1 9 , 2 2 :1 5 , 2 2 -2 2 , 2 3 :1 2 , 4 7 :1 4 ,4 8 :1 Ite m -3 :7 n e a r p i- 2 5 :2 2 n e e d p i - 3 2 :1 9 n e e d e d p j -1 4 :2 4 , 2 1 :4 ,2 1 :2 4 N e v e r -5 5 :1 2 ,5 9 :5 n e v e r [2< t i - 1 3 : 3 , 2 1 :1 9 ,2 2 :2 0 ,2 6 :2 2 , 3 0 :2 3 ,3 1 :5 ,3 1 :8 , 3 2 :2 ,3 5 :1 1 ,4 2 :1 5 , 4 6 :2 ,5 2 :6 , 5 3 :1 5 , 5 5 :2 1 ,5 6 :3 ,5 8 :2 4 , 5 9 :1 ,6 9 :3 , 5 9 :6 , 6 0 :2 0 ,6 2 :1 6 ,6 2 :1 7 H e w n - 2 ;7 , 2 :9 , 7 :1 9 ,8 :1 2 , 1 8 :1 4 , 1 9 :1 ,6 4 :4 n e x t ( a } - 9 :2 2 ,1 0 :4 , 10:11 n ic e p i -1 4 :8 n ig h t p j -3 0 :1 9 , 3 0 :2 0 n o b o d y p j-3 7 :1 4 , 6 0 :1 2 5 n o rm a l [ i j -2 7 :1 3 N o s [i - 7 :5 N o t a r y [4] 2 :6 , 6 4 :3 , 6 4 :2 5 ,6 5 :1 9 n o t e [1] - 5 5 : 9 n o th in g p j- 5 0 :1 3 ,. 6 4 :9 N o v e m b e r[i| - 9 :1 3 n u m b e r ^ ] - 7 :1 , 1 7 :2 4 ,4 9 :7 N y a s [3 j- 2 5 :3 ,2 6 :1 9 , 4 8 :1 2 N y t o lp j- 2 3 :1 9 O b r ie n [i]- 2 :1 2 O b J e c t[i7 ] - 1 9 :1 2 , 2 5 :1 5 ,2 7 :8 ,2 3 :2 0 , 3 6 :1 3 ,3 6 :2 0 ,3 8 :2 3 , 4 0 :4 , 4 1 :2 0 ,5 6 :1 5 , 5 6 :2 0 ,5 7 :1 ,6 0 :9 . 6 0 :1 8 ,6 1 :4 ,6 2 -1 1 , 6 3 :4 o b j e c t e d [ 1] - 4 6 : 2 5 O b je c tto n n o j - 3 9 :2 2 , 4 0 :1 4 ,4 0 2 0 , 4 0 :2 5 , 4 7 :1 5 ,5 3 :2 ,5 3 :1 7 . 5 6 :2 ,5 6 :1 3 ,6 8 :1 4 o b je c tio n [iq j -1 6 :1 8 , 2 0 :2 0 ,2 9 :3 ,2 9 :8 , ' 2 9 :1 4 ,4 6 :6 ,5 7 :1 2 , 5 8 :8 ,5 8 :2 1 ,6 3 :1 0 o b je c tio n s [ij 1 9 :7 o b v io u s ly m - 4 0 :1 8 o c c u rre d p i-2 3 :2 1 , 2 4 :2 2 o c c u r r in g [ i j - 2 7 :1 4 o ff-th e -re c o rd p i 3 0 :1 2 , 3 2 :9 , 5 1 :1 8 0 g d e n tu - 3 :l0 o ld [ i j - 7 :2 2 O n e e ji] - 4 7 :1 5 o n c e p i- 4 7 :1 6 ,4 8 :1 7 o n e p o j- 7 :1 ,1 1 :1 9 , 1 7 :2 4 ,1 8 :4 , 2 1 :2 1 , 2 3 :6 ,2 4 :1 0 ,2 7 :1 7 , 2 7 :1 9 , 3 0 :1 0 ,3 3 :7 , 3 4 :2 4 , 3 4 -2 5 , 3 9 :2 4 , 4 0 :1 ,4 3 :2 0 ,4 4 :3 , 4 4 :4 , 4 7 :7 ,4 8 :8 , 4 8 .1 0 ,4 8 :1 1 ,4 8 :1 9 , 5 0 :7 , 5 2 :2 1 ,5 4 :2 3 , 5 5 :1 , 5 8 :2 2 ,5 9 :1 4 o n e -o n -o n e [tj 5 2 :2 1 o n e s [51 - 1 3 : 1 6 , 1 3 :2 0 ,2 6 :2 3 , 3 5 :1 , 3 9 :2 1 o p in io n [1 1 -4 7 :1 1 o p p o s ite [ij -5 7 :2 6 O r a lp i- 1 :1 0 ,2 -2 o re [6 ]-1 0 :1 6 ,1 0 :2 2 , 1 4 :2 2 ,1 4 :2 4 ,1 4 :2 5 , 1 5 :6 o r g a n ic P i - 5 0 :9 , 5 0 :1 5 O rg a n ic e n - 5 0 :1 7 o rig in a lly [1 1 -2 6 :1 9 O s h a p i- 1 5 :1 5 ,4 8 :1 3 o u ts id e i) - 2 6 :1 6 o w n ib j - 2 5 2 , 2 5 :1 1 , 2 8 :1 7 ,4 5 :1 6 ,4 6 :1 1 , 5 7 :1 3 o w n e d [1[ - 5 4 : 1 5 p a c i f i c [ 1] - 4 : 6 p a d d e d ps- 2 5 : 4 , 2 5 :5 p a d s p j - 5 4 :2 5 P a g e p j - 5 :3 ,6 :3 , 6 1 :2 3 p a i d 13) - 1 2 : 1 , 1 2 : 2 , 6 3 :7 P a lm e r o ] - 3 :1 2 p a p e r [ 2] - 1 3 : 1 8 , 1 5 :1 2 P a r n e ll in - 3 :6 p a r t p i - 1 1 :1 9 p a rtie s fil- 6 4 - 1 7 p a r t n e r s [ 1] - 1 5 : 2 4 p a s s e d [ 1] - 3 1 : 1 2 p ay m -1 2 ;2 P e a c h tr e e ii) - 3 :7 p e o p le [l4 ] -1 2 :1 7 , 2 3 :1 2 ,4 4 :5 ,4 4 :8 , 4 9 :1 5 ,4 9 :1 6 ,5 3 :1 1 , 5 5 :1 9 ,5 5 :2 5 , 5 6 :6 , 5 6 :1 8 ,6 1 :1 ,6 1 :1 6 p e r fe c t[i] - 3 1 :7 p e r io d ic a lly [ i j 5 2 :1 0 p e rs o n a l [6 ]-2 8 :1 7 , 2 9 .1 ,4 5 :1 6 ,4 6 :1 2 , 4 7 :1 8 ,4 7 :2 2 p e r s o n a l t y p i 5 6 : 6 , 5 9 :6 p e r s o n n e l p j - 2 0 :9 , 2 0 :1 3 ,2 0 :1 5 ,4 3 :4 , 5 8 :1 9 p h o n e tic p j - 1 0 :2 5 , 1 3 :2 4 , 2 9 :1 7 , 3 0 :3 p h o t o g r a p h [4j- 1 6 :1 1 .1 6 :1 7 ,1 7 :8 , 1 7 :1 6 P h o to g ra p h s [ i l - 6 :5 p h y s ic a l^ ] -1 5 :1 7 p i c k [2] - 1 1 : 9 , 2 7 : 1 p i c t u r e (3] - 3 1 : 4 , 3 1 :5 ,3 1 :8 p ie c e [6] - 2 0 :5 ,4 1 :7 , 4 1 .8 ,4 2 .1 ., 4 2 -7 , 4 3 :1 1 p i p e p i - 1 4 :1 0 p ip e s [i]- 4 9 :2 0 p la c e (5j - 2 7 : 6 , 2 7 :1 0 , 2 7 :1 3 ,4 6 :6 ,6 4 :1 3 P l a i n t i f f s [ 1] - 6 : 3 P l a i n t i f f s [2} - 1 : 6 , ' 3 : 5 p la n t p i -6 2 :7 , 6 2 :1 0 P l a z a [2j - 3 : 3 , 3 : 7 P llc [ij- 3 :1 0 P lu m m e r P i - 2 :6 , 6 4 :3 p o c k e t p j -2 5 :4 , 2 5 :6 ,2 5 :7 p o in t [ 4 |- 8 : 2 1 , 1 8 :1 9 , 2 3 1 7 ,2 4 :1 0 p o i n t e d |1 ] - 4 2 : 1 5 p o lic e d p i - 5 2 :1 7 P p o o ll s o it [Sj- c k 's d i io n - 3 7 :1 1 0 :9 , 8 1 0 :1 1 ,3 1 :2 0 ,3 6 :1 0 , 3 6 :1 8 p o w e r [1) - 5 3 : 7 p ra c tic e s t o -6 2 :1 0 P re s e n tili -4 :1 9 p r e s e n t [31- 8 : 1 0 , 1 6 :2 0 ,1 7 :1 3 p r e s s e d [ 1] - 2 0 . 2 P re s u m a e ly rij - 6 2 -9 p r e tt y it i - 1 3 :2 4 , 1 3 :2 5 ,1 4 :9 ,2 2 :1 3 , 3 9 :2 ,5 2 :2 , 5 3 :7 P r e t t y (4) - 2 5 : 2 2 , 3 3 :1 7 ,3 3 :1 8 . 5 7 :2 1 p re v a le n t ft] - 4 2 :1 7 p r in te d p j - 2 2 :7 p r iv ile g e it) - 4 6 :1 1 p r iv il e g e d I3 i - 4 6 :1 7 , 4 7 :1 7 , 4 7 :2 2 p r o b le m s it i- 1 4 :1 2 P ro c e d u r e [ij-2 :5 p ro c e s s iti -1 0 :2 0 p ro d u c e p i-2 1 :2 4 p r o d u c t p i - 5 9 .1 2 , 5 9 :1 6 , 6 1 :8 p ro d u c tio n p j - 2 2 :1 0 ,2 2 :1 2 ,2 7 :1 3 p r o d u c t s [61 - 2 2 : 1 4 , 2 2 :1 5 ,2 2 .1 9 ,2 2 :2 2 , 3 5 :9 ,3 5 :1 0 p ro n o u n c e [i]-4 1 :3 p ro v e p j - 3 4 :1 0 , 5 3 :1 ,5 8 :6 p ro v id e [ij -1 3 :8 p ro v id e d n i - 1 3 :1 8 P u b l i c p j - 2 : 7 , 6 4 -4 , 6 4 :2 5 p u ll [1 1 -5 1 :1 3 p p u u r t IS]s u a n t -1 0 H :2 i- 2 5 ,1 :4 5: 1 3 , 1 5 :1 5 ,2 2 :2 1 ,2 8 :1 2 . 5 4 :2 5 Q q u e s tio n in g l i j 5 4 :1 1 q u e s tio n s [i9 j - 1 9 :8 . , 2 8 :1 6 , 3 0 :1 6 , 3 2 .5 , 3 2 :7 ,3 2 :1 9 , 3 3 :1 5 , 5 1 :2 2 ,5 4 :3 ,5 4 :9 , 5 5 :9 ,5 6 :7 .5 6 :1 6 , 5 8 :1 0 ,5 8 :2 3 ,6 0 :1 , 6 1 :2 0 , 6 3 :1 1 ,6 3 :1 2 q u it e [6j - 1 5 :2 3 , 1 9 :2 2 , 2 0 :2 5 , 2 4 :2 5 , 3 1 :1 0 , 5 6 :2 5 R r a i l [ 1] - 5 5 : 2 ra ilc a rs [7 )-2 8 :4 , 2 8 :7 ,2 8 :1 3 ,5 4 :1 9 , 5 4 :2 1 ,6 1 :9 ,6 1 :1 4 ra is e [3 )-1 0 :2 4 , 1 4 :2 5 .5 3 :1 1 ra is e d p j - 8 :1 1 .8 :1 2 ra n d o m ( i [ - 4 8 :1 7 r a te i n - 1 2:1 r a w p j- 4 1 :1 4 re a d i u -6 5 :1 r e a l p j - 2 8 :6 r e a lly [2j - 4 2 : 4 , 6 2 : 3 R e b e c c q ij - 4 :5 r e c a l l e d (2) - 3 6 : 5 , 6 3 :1 9 r e c e n t [ i j - 1 6 :1 4 re c o g n iz e p i - 1 6 :9 , 1 8 :1 0 ,3 1 :9 ,3 5 :1 9 re c o g n iz e d [1 1 -4 0 :1 1 r e c o l l e c t i o n 1) - 4 5 : 1 r e c o r d [13]- 7 : 3 , 3 0 :1 1 ,3 0 :1 2 ,3 0 :1 4 , 3 2 :8 ,3 2 :9 ,3 2 :1 1 , 4 6 :9 ,4 6 :2 3 . 5 1 :1 7 , 5 1 :1 8 ,5 1 :2 0 ,6 3 :1 7 R e c ro s 32j - 5 :11, 6 2 :1 R e c ro s s e x a m in a tio n p j-5 :1 1 ,6 2 :,1 R e d ire c t-!]-5 .1 0 , 5 :1 2 ,5 5 :6 ,6 2 :2 3 R e e d i|- 4 :1 0 re fe r [ ij - 5 1 :1 3 re fe rrin g p i - 1 4 2 0 , Kimberly S. Plummer, CSR (315) 778-0187 5 1 :5 r e g a r d [1] - 5 5 : 9 r e g a r d s [181- 1 2 : 2 4 , 1 4 :6 ,2 0 :1 7 ,2 0 :2 3 , 2 3 :2 1 ,2 4 :9 ,2 4 :2 3 , 2 6 1 4 , 2 7 :1 6 , 2 9 :5 , 3 1 :1 , 5 5 :1 7 ,5 8 .3 , 5 8 :1 8 ,6 0 :2 4 ,6 3 :1 r e la t e ^ ! - 1 2 :1 2 R e la te q i] -1 :2 re la te s ^ ] -1 2 :2 5 , 2 3 :2 2 re la tin g p j-1 9 :9 , 1 9 :2 5 re la tiv o p i - 6 4 :1 6 , 6 4 :1 8 re ie v a n tp ) - 4 7 :1 2 re m e m b e r p ii-3 0 - 1 , 3 2 :2 1 , 3 3 -1 ,3 5 :2 0 , 3 6 :4 ,3 6 :1 1 ,3 6 :2 2 , 3 6 :2 3 ,3 9 .1 6 , 3 9 :1 8 , 4 2 :2 0 ,4 4 :1 6 ,4 5 , 4 7 :3 ,4 8 :7 ,5 0 :1 0 , 5 0 :1 2 , 5 0 :1 4 ,5 2 :1 , 5 3 :1 4 ,5 9 :2 4 R e p e a ts - 3 6 :1 5 , 6 1 :1 2 R e p o rte r-2 6 r e p r e s e n t^ -1 6 :1 4 , 1 7 :1 0 r e p r e s e n t i n g [ 1| 5 5 :1 1 r e p r e s e n t s ( i j - 1 8 '1 2 r e s e r v e 2] - 1 6 : 1 8 , 1 9 :6 r e s p ir a to r [id -1 4 :1 1 , 1 4 :1 6 ,1 4 :1 8 ,1 5 :1 1 , 3 9 :1 2 ,4 0 :1 9 ,4 0 :2 3 , 6 0 :2 ,6 1 :1 1 ,6 1 :1 7 r e s p i r a t o r s [6] - 1 3 : 8 , 1 3 :1 7 ,1 3 :2 3 ,1 4 4, 6 0 :2 5 ,6 1 :2 re s p o n s e [i) - 6 3 :1 3 - R id te jtn - 4 :1 2 R is a ta -2 9 :1 7 ,2 9 :2 1 R iv e tti -1 8 :1 3 r o a d [2j - 3 0 : 6 , 3 4 : 2 4 R o b e rip i - 2 9 :1 7 , 2 9 :2 1 R o b in s o r ti) - 6 3 :2 0 r o c k P i -1 4 :2 2 , 4 1 :9 ro c k s [i]-2 0 :3 R o g e rs tis j - 1 :1 1 ,2 :2 , 4 :2 1 ,5 :5 , 7 2 ,7 :1 7 , 7 :1 8 ,3 2 :1 5 ,4 6 :2 5 , 4 8 :1 2 , 5 1 :2 1 ,5 4 :8 , 6 1 :2 1 .6 4 :7 , 6 5 :9 R o s iq il - 8 :1 3 ro u g h ly in -1 9 :3 ro u n d tq -5 1 :3 6 R 2 6 ] - 3 :9 , 2 1 :2 5 , 2 2 .3 ,2 4 :1 1 ,3 1 :1 5 , 3 1 -2 4 , 3 2 :1 5 , 3 3 :9 , 3 3 :1 2 ,3 5 -1 7 ,3 6 :1 0 , 3 7 :1 1 ,4 4 :5 , 4 5 :1 , 4 9 :8 ,5 4 :1 3 , 5 4 :1 5 , 5 5 :1 7 , 5 5 :1 8 , 5 5 :2 4 , 5 6 :8 , 5 8 :2 , 5 8 :1 9 , 5 9 :2 1 ,6 2 4 ,6 2 :1 4 m ie t i] - 2 5 :1 2 R u le g ij - 2 -5 r u n |3] - 1 0 :2 3 , 5 7 : 2 4 , 5725 r u n n in g n i - 1 1 :2 0 S s a fe ty p )-1 3 12, 4 8 :1 3 , 6 2 :1 0 S a le s n i - 3 :3 s a m p le p j - 2 7 :1 7 , 4 8 :1 8 s a m p le s [1 4 ]-2 6 .1 4 , 2 6 :1 6 ,2 6 :2 1 ,2 6 :2 4 , 2 7 :6 ,2 7 :1 1 ,2 7 :1 2 , 4 8 :1 4 ,4 8 :2 0 , 4 8 :2 2 , 4 9 :1 , 4 9 :2 , 4 9 :6 , 4 9 :8 S a n d id g e p j - 4 :1 2 S a tte r le y t3 9 ]- 3 :3 , 5 :7 , 5 :1 0 , 5 :1 2 , 7 :1 3 , 1 6 :1 6 ,1 9 :1 4 , 3 2 -3 , 3 2 :2 1 , 3 5 2 , 3 6 1 3 , 3 6 :2 0 , 3 7 :8 , 3 8 :2 3 , 3 9 :1 6 , 3 9 -2 2 , 4 0 :4 , 4 0 :1 4 , 4 0 -2 0 , 4 0 :2 5 , 4 1 :2 0 , 4 6 :6 , 4 6 :1 0 , 4 6 14, 4 6 -2 1 , 4 6 :2 5 , 4 7 1 5 , 4 8 3 , 4 8 :2 5 , 5 3 :2 ,5 3 :1 7 , 5 5 :6 , 5 5 :8 ,6 1 :1 9 ,6 2 :1 1 , 6 2 :2 3 ,6 3 -1 1 ,6 3 :1 4 , 6 3 :1 8 S c h e l l ( 1) - 4 : 1 0 s c h o o l f 3 ] - 8 :1 4 , 8 :1 8 ,9 :2 3 S c h u p b a c h [i]-4 :5 s c i e n t i s t t5] - 4 1 : 1 5 , 4 3 :3 ,4 5 :1 9 , 5 6 :1 7 s c i e n t i s t s [2] - 5 7 : 8 , 5 7 :1 0 s c r a p e h i - 1 1 :2 s c ra p e r [6 ]-1 1 :2 , 1 1 :1 8 , 1 1 :2 0 ,5 0 :2 4 , 5 1 :8 , 5 9 :9 s e a lm - 1 3 :1 5 S e c o n d ili- 8 :1 5 second i 3 i - 3 0 - 1 0 . 4 6 :7 , 5 1 :1 6 s e c o n d a r y ]2] - 1 3 : 2 , 1 5 :4 s e e (1 7 ]-1 3 :1 3 ,1 3 :1 4 , 1 6 :1 5 , 3 1 :1 6 , 3 3 2 3 , 3 4 .2 0 , 3 5 :7 , 3 5 :2 1 , 3 7 :1 6 , 4 0 :2 3 ,4 2 :2 , 4 9 :9 , 5 5 :1 0 , 6 1 :9 , 6 1 :1 4 , 6 2 :2 0 s e e m [ 1] - 5 2 2 4 s e n a t o r [2] - 2 5 : 4 , s 2 e 5 n :5 d j-jJ - 5 8 :1 7 S e n io r p ]-2 4 :1 8 s e n t p j - 1 5 .1 0 , 2 7 :1 1 , 2 8 :3 , 5 8 :1 6 s e p a ra te in - 3 0 8 S e r v ic e s ^ ] - 2 :1 3 s e t ] i] - 6 4 :1 4 S e tr ig h to j - 3 3 :4 , 3 3 :5 , 3 3 :2 2 , 4 6 :3 , 4 6 :5 ,4 7 :5 , 4 7 :1 4 , 481 s e ttle m e n t!!]-2 1 :2 1 S h a d b u m e p j - 4 :1 5 s h e e t!!]-4 1 :1 0 s h if t m - 5 7 :2 5 s h ifts ti] - 5 7 :2 4 s h ip p ] - 2 8 :7 ,4 4 :2 0 s h ip p e d p ] - 2 8 :4 , 2 8 :5 , 2 8 :1 3 , 3 1 :2 4 , 4 4 :1 9 , 5 4 :1 8 , 6 1 :1 3 S h ip p e e p ] - 3 9 :1 , 57 19 s h i p p i n g [ 1] - 4 5 : 5 s h o p [4] - 2 4 : 1 2 , 2 4 :2 0 , 2 4 :2 4 , 2 5 2 5 s h o w p i - 1 6 :8 , 1 7 :7 , 21 27::11 6 , 1 8 : 9 , 1 8 : 1 6 , s h o w e d 18] - 2 0 : 2 , 3 4 :6 , 4 1 :7 ,4 1 :1 2 , 4 4 :1 4 , 4 4 :1 6 ,4 5 :7 , 4 5 :2 4 s h u t [5] - 2 6 : 6 , 3 4 . 1 2 , 3 4 :1 5 , 5 1 :8 s h u td o w n p ] - 3 4 :1 6 s ic p ]-3 1 1 6 s ig n e d p i - 1 0 :6 s im ila r p ) - 3 6 :2 3 s im p ly p i -4 7 :2 2 S im p s o n p j- 4 :1 3 s ite p ] - 5 0 :2 s ittin g p ] - 3 1 :1 6 s itu a tio n p ] - 2 8 :1 7 s iz e s p j - 1 5 :6 , 1 5 :9 S lim p i- 3 5 :1 5 , 3 5 :1 7 s lip fi] - 5 1 :1 2 s m a l l e r (4j - 1 5 : 9 , 1 8 :6 ,1 6 7 s m o k e [8] - 3 9 : 2 0 , 4 0 :2 ,4 0 :3 ,4 0 :1 8 , 4 0 -2 1 , 4 0 -2 2 , 4 0 :2 4 , 5 5 :1 2 sm oked M - 3925, 4 0 :1 3 , 4 0 .1 6 , 5 6 :1 1 s m o k in g p i- 5 6 :8 s o ld [6 1 -1 2 3 ,2 2 :1 6 , 4 4 :1 8 ,4 5 :2 ,4 5 :9 , 6 1 :8 s o m e t i m e s p;- 4 9 : 3 s o m e w h e r e pj- 2 4 :2 1 ,4 5 :1 1 s o o n e r p i -4 9 :5 s o r r y (6 j - 3 1 :1 7 , 3 1 :1 8 ,4 4 :2 4 ,5 0 :1 6 , 5 9 :3 , 6 1 :2 1 s o r t [2] - 1 8 : 9 , 4 5 : 1 9 s p e c p ]-5 3 :8 s p e c s (2] - 3 4 : 7 , 5 7 : 1 5 s p e c u l a t i o n pj- 5 3 . 3 s p e l l p]- 2 4 : 2 5 s p e n d p j -2 5 :9 , 2 5 13, 2 5 :1 7 s p e n t [4 i- 5 7 :1 0 , 5 7 :1 3 , 5 7 :1 7 , 5 7 18 s p o k e n pi- 3 0 - 2 3 s p o t 13] - 2 6 : 2 4 , 4 2 :1 4 ,4 2 :1 5 s p o t s p]- 4 2 : 9 s p o u s e p ]-4 :2 1 S r p i- 2 4 :1 7 ,2 4 .1 9 S t p i - 1 8 :1 3 s t a r t pj-1 1 : 1 2 , 3 2 : 2 0 s ta r te d [5 ]-2 1 -.2 3 , 2 3 :2 5 , 4 4 :2 0 ,4 5 :1 2 , 6 0 :2 S t a t e p i - 1 :1 , 2 7 , 6 4 :4 s t a t e pj-9 : 6 s ta te m e n ts p ] - 6 1 :9 s t a t i n g pj- 2 6 : 1 1 s ta tio n p i - 2 7 :1 , 5 2 :1 4 s t a y [3] - 9 : 1 4 , 9 : 2 5 , 5 3 :9 s t e a d y pi- 1 3 : 2 5 s t e a m pj- 1 4 . 1 3 , 1 4 :1 7 s te n o g r a p h ic a lly p ]- 6 4 :1 2 s till P !- 3 3 :2 3 ,5 2 :1 9 , 5 8 :2 2 s t o c k pi- 1 0 : 6 , 1 0 : 8 s t o k e pi- 2 6 : 2 5 , 4 9 : 7 s to k e rp i -1 0 :1 5 s t o k e s p]- 1 1 : 3 S to llp ]- 3 :1 0 s t o p (2] - 2 6 : 2 0 , 5 1 . 4 S to p h e r p ] - 4 :7 s t o p p e d pi-4 0 : 2 1 S tre e t]8 ] - 2 :9 , 3 .4 , 3 :7 ,3 :1 1 ,4 :4 ,-4 7 , 4 :1 1 ,4 .1 4 s t r i c t (2] - 1 3 . 1 2 , 1 3 :2 4 s t r i k e 16] - 2 3 : 1 8 , 2 3 :2 1 , 2 4 :4 ,4 6 :2 2 , 4 8 :3 ,4 8 :8 s tu ff p j- 3 3 :1 7 s u b je c t p ] - 6Q :1 5 s u b s c r ib e d p ] - 6 5 :1 3 - s u g g e s t e d pi- 6 0 1 4 s u itp j- 2 6 :3 S u ite [ 5 ] - 3 .1 1 , 4 :4 , - 4 :8 ,4 :1 1 ,4 :1 4 s u m m e rtim e p i -1 4 .8 S u n tr u s tp ] - 3 .7 s u p p o s e d [a - 2 6 :1 9 , 2 6 :2 0 ,5 0 :1 7 ' s u rfa c e 5 ]-1 0 :7 , 1 5 :3 ,1 5 :4 ,1 5 :8 , 1 8 :3 s w itc h p j - 5 1 :9 . 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Plummer, C S R (315) 778-0187 7 1 1 :2 0 ,1 2 :5 ,1 4 :2 , 1 4 :7 .1 5 :2 4 ,1 6 :3 , 1 7 :1 4 ,3 9 :2 0 ,3 8 :1 5 , 5 1 :4 ,5 1 :5 , 5 1 :6 ,. 5 7 :2 0 T ra m m e l ) - 11: 16, 1 7 :3 trammers Hi 27:21 transeript 21-64:11, 65:1 T r a n s c r ip t ] - 2 :1 tra n s fe r w -1 0 :1 7 ,' 1 1 ;). 1 1 :4 ,1 4 -2 3 tra m o lite r a -2 2 :1 7 . 3 9 :1 3 ,5 9 :1 4 t r i e d 1) - 5 3 : 5 t r o u b le ( u - 1 3 :1 1 tr u c k fi! -1 0 :6 b w e p ] 6 4 :1 1 ,6 5 :2 t r u s t [1] - 5 7 : 4 t r u s t i n g (1J - 5 7 : 6 tr u th H ] - 5 7 '5 , 6 4 :8 , 6 4 :9 t r u t h f u l 1] - 3 1 : 2 t r y i n g 2) - 2 1 : 2 0 , 4 7 :1 6 T u e s d a y ii]-2 :1 0 t u g g e r s 1) - 5 0 2 5 T w o [ii 8 :9 t w o 8] - 1 3 : 1 7 , 1 4 : 2 3 , 1 5 :1 7 ,2 0 :3 , 3 9 :1 9 , 4 0 :8 , 5 7 :2 4 ty p e [ro j - 9 :4 ,1 3 :1 0 , 1 3 :1 1 .1 3 :2 2 ,1 6 :2 , 2 2 :1 0 ,2 2 :2 1 ,3 1 :2 5 , 4 3 .-1 2 , 6 0 :2 5 ty p e s ]!] . 1 3 :1 7 7 y p h a in i2 i -1 9 :2 1 , 2 0 :6 ,2 3 :1 5 ,3 7 ;1 6 , 4 1 :2 ,4 1 :4 ,4 1 :1 5 , 4 4 :1 0 ,4 4 :1 1 ,4 7 :2 , 5 6 :2 3 5 6 :2 5 u U m -ftm m 1 -1 3 :1 9 , 4 8 :5 u n b e k n o w n in 2 6 :2 0 U n d e r 1] - 1 - 1 0 u n d e r [3j - 2 5 : 1 2 , 3 4 :7 ,4 6 :1 5 , 4 6 :1 8 , 4 7 :2 5 , 5 3 :9 , 5 7 :1 5 u n d e r g r o u n d pj- 1 0 :6 ,1 0 :6 ,4 3 :1 6 u n d e rs to o d g - 5 0 :2 0 u n le s s it) - 4 5 :2 0 u n iik e ly m - 4 2 :8 u p O T -10:22,11:10, 1 2 :3 ,1 3 :1 6 ,1 5 :2 , 1 5 :4 ,1 5 :5 ,2 1 :2 1 , 2 6 :2 ,2 7 :1 ,2 7 2 5 , 2 8 :6 ,3 0 :1 5 ,4 4 :2 1 , 6 2 :1 7 ,5 5 :1 ,5 5 :6 , 5 5 :2 1 ,5 7 :1 4 U p s t a t e fu - 1 8 :1 3 u s e r s [ 13- 6 1 :1 0 V V a n c e ]4 ]-3 :1 2 , 5 :9 , 5 4 :6 , 5 4 :8 V a n d e rb U t[4 ? i - 3 :9 , 2 1 :2 5 ,2 2 :3 ,2 4 :1 1 , 2 4 :1 6 ,2 4 :1 7 ,2 4 :1 9 , 2 4 :2 3 ,2 6 -2 ,2 6 -1 1 , 3 1 :1 5 , 3 1 .2 4 , 3 2 :2 0 , 3 2 :2 2 , 3 3 :9 ,3 3 :1 2 , 3 3 :2 3 ,3 4 :5 ,3 4 :9 , 3 5 :1 2 ,3 5 :1 8 ,3 5 :2 5 , 3 6 :5 , 3 5 :1 7 ,-3 6 :2 5 , 3 7 :1 , 3 7 :1 1 ,.3 7 :1 2 , 3 8 :1 2 ,4 4 :5 ,4 4 :6 , 4 5 :1 ,4 7 :2 3 ,4 9 :8 , 5 2 :8 ,5 4 :1 3 ,5 4 :1 5 , 5 5 :1 8 ,5 5 :2 4 ,5 6 :8 , 5 7 :9 ,5 8 :2 ,5 8 :1 9 , 5 9 :2 2 ,6 2 :4 ,6 2 :1 5 V a n d e rb ilts p ] - 3 2 :1 5 ,3 6 :1 0 .3 8 :1 8 v a rie d ( t [ - 1 4 :8 v a r io u s [3] - 1 2 8 , 1 2 :2 5 ,5 6 :1 9 V fc e p ] - 4 :1 0 v ia a o p i- 3 0 :1 0 ,3 2 :6 , 4 6 :7 ,4 6 :8 ,4 6 :2 1 , 5 1 :1 5 ,6 3 :1 8 V id e o fii - 2 -1 3 V i d e o g r a p h e r f i 2| 2 :1 2 ,7 :1 ,3 0 :1 1 , 3 0 :1 4 ,3 2 :8 ,3 2 :1 1 . 4 6 :9 ,4 6 :2 3 ,5 1 :1 7 , 5 1 :2 0 ,6 2 :2 1 ,6 3 '1 6 v id e o ta p e d p f - 2 :1 , 7 :2 V ln e [ii- 3 :1 1 w w a l k e d pj- 3 9 . - 6 , 3 9 : 7 W a tlb a u m tu - 3 :3 w a rn i [ - 5 6 :9 w a r n i n g [1] - 6 1 : 1 4 w a r n in g s p i - 3 1 :2 5 , 6 1 :9 W a s h in g to n ]!] - 2 :9 W a te r fr o n t[ij-3 :3 W a te rto w n ] -2 :9 , 1 8 :2 5 w a y s [ 1] - 8 : 2 0 w e a r [S] - 1 3 : 1 1 , 3 9 :1 2 ,3 9 :1 4 ,4 0 :1 8 , 6 1 :2 ,6 1 :1 7 w e a r i n g (3] - 1 3 : 1 3 , 1 3 :2 2 , 1 4 :1 1 , 1 4 :1 6 , 6 0 .1 ,6 1 :1 0 w e e k ]-4 3 :2 0 ,6 3 :9 W e itk a m p (i]-4 :1 0 W e s te r-3 :4 ,3 :1 1 , 4 :4 ,4 :7 ,4 :1 1 ,4 :1 4 W e s te m ri] - 2 :8 w h o l e 1] - 6 4 : 9 w iffe ru - 3 0 :2 0 w ife 's [ i ] - 8 :4 w in te r m -1 4 :9 W itn e s s ]!) - 5 :3 w i t n e s s [S] - 7 :9 , 1 0 :1 9 ,1 3 :2 2 , 4 7 :2 0 , 6 3 :1 9 W itn e s s e s in - 4 :2 1 w i t n e s s e d [11-59:6 w o rd s [i] - 2 2 :5 w o r e p i - 1 3 :2 5 w o r k e r s 12] - 1 3 : 2 2 , 1 4 -3 ,2 5 :9 , 2 6 :1 1 , 2 7 :2 1 , 2 9 :5 ,2 9 :6 , 2 9 :1 1 ,2 9 :1 6 ,3 2 :1 , 5 6 :9 ,6 1 :1 W o rk e rs ) [1 |-6 3 :1 w o r k m e n pt- 2 4 : 2 4 , 2 5 :2 0 w o rld [4 ]-2 1 :2 5 . 4 4 :2 5 ,4 5 :3 ,4 5 :8 w r a p [1] - 3 0 : 1 5 w r i t t e n [1] - 4 4 : 1 7 W y a ttm - 4 :3 y e a r 6] - 7 :2 4 ,8 : 1 5 , 9 :1 6 ,9 :1 7 ,1 0 :2 , 4 8 :6 y e a r s [13] - 7 :2 2 ,8 : 7 , 9 :1 0 ,1 6 :1 7 ,1 5 :2 3 , 1 8 :2 3 ,1 9 :2 2 , 2 4 :1 , 3 3 :2 , 3 8 :9 ,4 0 :8 , 4 9 :1 0 Y o rk p i - 2 :7 ,2 :9 , 7 :1 9 , 8 :1 2 ,1 6 :1 4 , 1 9 :1 , 6 4 :4 y o u n g fi[-2 4 :1 6 Y o u n g 2] 3 : 8 , 4 : 1 9 , 5 :8 , 5 :1 1 ,1 6 :1 8 , 1 9 :6 ,1 9 :1 2 ,2 0 :2 0 , 2 5 :1 5 ,2 7 :8 ,2 8 :2 0 , 2 9 :3 ,2 9 :8 ,2 9 :1 4 , 3 1 -1 7 ,3 2 :1 3 ,3 2 :1 5 , 4 6 :1 3 ,4 6 :1 9 ,4 6 :2 4 , 5 1 :1 5 ,5 1 :2 1 ,5 4 :3 , 5 5 :1 1 ,5 6 :2 ,5 6 13, 5 6 :1 5 , 5 6 :2 0 , 5 7 :1 , 5 7 :1 2 ,5 8 :8 ,5 8 :1 4 , 5 8 2 1 .5 9 :3 ,6 0 :9 , 6 0 :1 8 ,6 1 4 ,6 1 :2 1 , 6 2 :1 ,6 2 :1 9 , 6 3 :4 , 6 3 :1 0 y o u is e lf[s )-7 :i5 , 2 7 .2 1 ,2 9 .1 ,2 9 :6 . 6 0 :1 5 Y u p [6 ] 1 6 :4 ,1 7 :6 , 1 7 :2 4 , 2 9 :1 8 ,3 3 :7 , 3 7 :6 y u p jtj- 1 8 2 4 Zaluski[5}-23:15, 3 7 .1 6 , 3 7 :1 7 , 3 7 :2 3 jip iU - 3 9 :1 0 Kimberly S. Plummer, CSR (315} 778-0187