Document V3YjMj0pMZ8j9mVqqv15oYDpK

T. Marmor J Page 13. Page 15 1 that the witness' testimony not be 2 permitted in: any of the Wise and Julian 3 cases and if other counsel wish to join, 4 I'm sure they will state additional: 5 objections: . 6 MS. NIELSEN: Christina Nielsen- 7 on behalf-of the-O'Brien.-Law Firm 8 plaintiffs will join in the objection. 9 MR..GIANARIS: Ted Gianaris on 10 behalf of Simmons plaintiffs joins. 11 Just to make the record clear. 12 there is just one misstatement. It was - 13 Judge Mendelson made the Order on- 14 Friday:-Judge Byron was on trial. 15 ;For the record, my fiimiilted a 16 Motionto Quash on Friday because the 17 original disclosure was,,in'my-mind, 18 inadequate.- -The judge ordered that a 19 deposition transcript be provided by the 20 end of the business day. On Friday, I 21 was provided with-trial testimony on 22 Friday. -When Lgot-home^onrSaturday. to 23 read it, realized it'Was not a 24 deposition, but wais trial testimony. 25 Obviously-trial testimony does not. flush - 1 provided to plaintiffs in the interim. 2 and I think the list that Mr. Gianaris 3 referred to is a subset of the larger 4 list that was previously provided to 5 plaintiffs' counsel. This is not a new 6 list. It is just a specification, a 7 breaking out of our larger list. 8 MR. KAY: Do you have a Proof of 9 Service that the deposition transcript 10 was provided to the plaintiffs? We 11 never got those. 12 MS. ROSENBERG: I believe this 13 was provided yesterday. I don't have 14 the Proof of Service with me. 15 MR. KAY: Monday before the day 16 of the deposition? . s 17 MS. ROSENBERG: That's:correct. 18 MR. KAY: To Wise and Julian? 19 MS. ROSENBERG: I believe to all 20 plaintiffs. 21 MR. GIANARIS: We can deal with 22 all this later. Let's proceed. 23 EXAMINATION BY 24 MR. GIANARIS: 25 Q. Please state.your name, sir. Page 14: Page 16 1 out someone's opinions in the. .way that a 2 discovery-deposition does for many 3 reasons. So, we object that-it's in 4 violation of the judge's order^ this : 5 deposition and-this. witness, this6 witness'testimony. . 7 In addition; I received on my 8 chair Monday morning ^Supplemental 9 Disclosurein which. for the first time;. . 10 I saw thatlf)r.`Marmor would-speak " 11 specifically about certain. Illinoisand . 12 M issouri media-`coverage, regulations-,' et 13 cetera. Lobject to this since I saw'-it 14 the day before the deposition. 15 .1 object tothe deposition ifthe 16 professoris going to rely on Exhibits 17 UCC-M-I through 216 for the reason that 18 the majority of them-had not been 19 disclosed or produced previously. 20 MS. ROSENBERG: I would like to 21 note for the record that I do believe 22 the curriculum vitae was provided on 23 Friday along with the Supplemental 24 Disclosure. 25 The deposition testimonyhas been 1 A. Theodore Marmor. 2 Q. Mr. Marmor, where dp you live? 3 A. New Haven, Connecticut.. 4 Q. What is your address? 5 A. 139 Armory Street. It's actually 6 Hamden, which is the associated town. 7 Q. Where do you-work?- 8 A. At Yale-University. 9 Q. What do you'do there? ' ' 10 A. I'm a professor of political 11 science, professor of public policy and12 management and adjunct professor of law. 13 Q. How long have you been at-Yale? 14 A. Since 1979. 15 Q. What is your expertise? 16 A. My expertise is in'three areas; 17 one is the area of describing and understanding 18 public policy, particularly regulation. The 19 second area is an understanding of historical 20 disputes about public health and medical care. 21 and the third is a general area of social 22 insurance that is collective arrangements to 23 try to compensate people for the risks of life, 24 both industrial risks and unemployment and the 25 like. 4 (Pages 13 to 16) POHLMAN REPORTING COMPANY (314)421-0099