Document Z8B6rQOab8gp7b0v7XZ3YpznZ

4. -0*CS - -O-CS -C./*n o C.3JC -CSC- M O 3a** secolo** C**C. C oC*-C' *N.. :c- :j4 :* c ir r -O f .. A-OAw. -9*)C3 >k. A !>*' : - a^ cs .A-C* .. m CC^C^AS - cc-c ^ c 4 , :.* s >-C! CM C -0 - - ' C-C :*** * ANfa^mr " CCCO* O a0 ' - O C .f 'A C. -Ow^x-S -O*-- C. - O C - Auw 4. a C * ( .c -- o -* 3 .C-t Cft* 3 -A- 1*C *- C - - -C -A* u * S - 3 ^A -a-c a r t : i c c > *Cv<*i S ^ 0 u 0 * r - -C -A C . z. -A* r CES J o n e s, J o n e s. C lose & B rown Cha-BTEILBD o 'i n > * w 3 - - 0 - ' o~ 5tvt*<T- 'u30* -*w_Cv Ba n k 9 u Z * 3 0 0 SO uT- r Cu * TM S racE T laa vbqaj. jnvaOa loi-eoae MESSAGE VIA PANAFAX UF-600 TELECOPIER: C.-0 - t 7 02' 385-2C 2 t.t::* t (702) 38-22' 7C2: J83-CC88 :a-*u. .*. vC*a .OO C AA t H DATE: _ / ~2 ? - 9/ CLIENT/MATTER: / / CZ C?'?. TO: H o u u j _ y y i . aA h \ / / . TELECOPY #: 4 ^ ^ ' / VERIFICATION#: FROM: NUMBER OF PAGES (INCLUDING COVER PAGE): ________ c J -- COMMENTS:_____________________________________________ If you do not receive all of the message, please call: ( 702) 385-4202 TRANSMISSION COMPLETED: DATE: __________________ TIME: OPERATOR: ______________________ A d m in \P an afax.frm IS O o m e t I C A S T U A C A T V . S U 'T t IA . [ N O . N tV A O A S O '- tH O tcwConc (7oai 3-i'Oiao tclccoa'Ca iron 3a oaae and who has had no direct contact whatsoever with Indepen dent Life or any of the architects or engineers involved in the construction of Independent Square. Also, Mr. Dobbins admitted in his deposition that he had no knowledge or proof that Gener al Electric did in fact carry out this policy by notifying the potential and actual customers, including Independent Life, of the relevant facts about PCBs. (See Appendix at A 1-5). Also, General Electric relies upon a portion of the depo sition of Paul Lawrence who was one of the General Electric sales engineers involved in the sale of the particular trans formers which are the subject of this lawsuit. Notably, the page of Mr. Lawrence's deposition upon which General Electric relies contains testimony that Mr. Lawrence does not recall whether General Electric's internal bulletins did in fact in struct him to tell his "customers or potential customers" as to the danger of PCBs, and he stated specifically that he has no recollection that it was done on every occasion or to Indepen dent Life, but merely believes that it was his custom to dis seminate this information (See Appendix at B 1-7). Mr. Lawrence's equivocation on this point alone mandates denial of summary judgment. Furthermore, there has been ample contrary and conflict ing evidence adduced in this case upon which a jury could (and will) conclude that General Electric did not provide an - r / / r /*/*)** /'f f c -5- - / v ~' ~