Document oDGvgR9E4BXb21B6rykeRr5EX

FILE NAME: US Gypsum (USG) DATE: January 14, 1985 DOC#: USG089 DOCUMENT DESCRIPTION: 1985 Legal - Deposition of Benjamin Miriello ------------s a F P i * ^ *.ic. . , ,, . IN THE UNITED STATES DISTRICT COURT ' [ FOR THE EASTERN DISTRICT OF TENNESSEE NORTHERN DIVISION CASE NO3 3-83-511 and 3-84-768 jc u , 1 ' \(rvV t DISCOVERY DEPOSITION OF BENJAMIN 0. MIRIELLO COUNTY OP ANDERSON, TENNESSEE --- ~ - BYRD, et u x ,, ESSEE' et 1-F GEORGE LOUIS I Plaintiffs, K vs. - i: UNITED STATES OYPSUM COMPANY, at .1., ; cT "^ f^ f i: ...... -- ------------------------------------------------------------D---e----f----e----n-- -d---a----n----t---s----.---------------_---------------'----&-- < t * '> > 1: PURSUANT TO NOTICE and COURt 'o r d ER* 14 th. above-.ntitl.d deposition tat.n on behalf of 15 the Defendant, u.s. Gypsum, at 13696 East n i f f Place, 16 Aurora, Colorado, on January 14, 1985, at 10:20 a.a., 17 before Dawn Cald.rwood, Certified Shorthand Reporter 18 and Notary Public. . 19 20 21 p p p m nr? 22 JUL 1985 23 5E0TTE 24 rCCfEAfRLOTDVIETRFPIWTEPODnOO/MrAAC_KELPRANG t ASWSOCIATES 25 SHORTHAND REPORTERS, RPR* 1554 VINE STREET DENVER, COLORADO (303) 394-2057 A faHT P / t n Ma . APPEARANCES : For the Plaintiffs: For the Defendant U.S. Gypsum: . MICHAEL Y. ROWLAND Rowland & Rowland 10 Emory Place Post Office Box 3308 Knoxville, Tennessee DARRYL G. LOWE Kennerly, Montgomery 1701 Plaza Tower Post Office Box 442 Knoxville, Tennessee & Finley Also present: Barbara Arras EXAMINATION BY MR. LOWE INDEX PAGE 3 - H I 1 IT s fOR-IDENTIFlCATTnw ----- Deposition Exhibit 1 Newspaper article from the Jersey Journal, March 3, 1936 PAGE 17 3 proceedings WHEREUPON, the following proceedings were taken pursuant to the Federal Rules of civil Procedure. MR. LOWE: This deposition of Mr. Miriello is being taken pursuant to notice for a I discovery deposition and also pursuant to the order ! of Judge Murrian of the United States District Court 1( for the Eastern District of Tennessee. 1] And if we could, we would like to go ahead 1: and attach the notices to the deposition. 13 14 that's fine. MR. ROWLAND: You brought copies, so 15 16 right? MR. LOWE: That's probably for both; oi. 17 MS. ARRAS: 18 Lytle and Shultz. it's for Anderson, Byrd, . 19 MR. ROWLAND: And noticed in two or 20 three other cases. 21 list of them. i will t-rv . U i tc? to get you a complete 22 BENJAMIN G. MIRIELLO, 23 having been first duly sworn to tell the truth, 24 testified as fo 1lows: 25 1 2 BY MR. LOWE: tAAMNATION 3 Q. Mr. Miriello, if you would, please state 4 your full name for the record. 5 A. Ben -- otherwise known as Benjamin _ 6 G. Miriello. 7 Q. 3 A. 9 Q. 10 birth. What is your present address? 2750 South xanada Way, Aurora, Colorado. If you would, please, give me your date of 11 A. April 9th, 1920. 12 Q. And that would make you, presently, 64? 13 A. Correct. 14 Q. And by whom are you employed? 15 A. I am retired from AT&T Technology. 16 Q. How long did you work for AT&T Technology? 17 A. Forty-two years. 18 Q. When did you retire? 19 A. In June of 1984. 20 Q. So you would have started for AT&T, then, 21 back in 1942? 22 A. Correct. 23 Q. Is that correct? All right. Let me go 24 back, if i could, and give me your place of birth. 25 A. Place of birth would be Jersey City, New 1 Jersey. 2 Q. And did you grow up the re ? 3 A. I did. 4 Q. Did you go to school there, 5 elementary education? 6 A. I d id . ` 0- A t ubar Xocation did you lcst work or 3 AT&T Technology? * ' I th. Kearny Works ,t K.erny, Jecsay Were you .till livin* i,, city I was . , . Mh* n dld y U " * -- y I Jersey city o 14 | the first time? A. For the flcit t u , .. after t natc.#d __ T"" m ` 17 I the actual date. ........ . I couldn't give you Q Yes. A- vou ere taxing y n.oory, and lt. not ^ 9ieer. *.11. ! ,,as married 30 years. So lee.s tak. e=K troo 30. would be the a p p r o d a r , time ! ooved out of Jersey City. Q* At age 30? A* Yes. Q* So that would nhaavwe bee . ab.out 1.950? 6 i A. Got me. i didn't r e a l ! that I had to "P " U h these '" <ates. ,,hat the he*. Barbara - Hon was born there, so he's 32. Thicty , years ago, yeah. o- DO you recall approximately when you moved to the Denver area? ' A. Some 20-odd years ago -- 1965. j Q* 1965? < A. Uh-huh. 1C o- Bow, what line of wor* did you follow .ftec 1] you finished high school? 1: A. Well, I started working for Western 13 Electric. 14 Q- you started immediately after high school? 15 A. Yes. 16 . Q. Okay. 17 Barring -- well, actually, yes. I went 18 into the service after that, while t was wording for 19 them. 20 Q- ^ u were in the service for what years? 21 A* Well, 1942 to 1945. 22 o. Do you recall what year you graduated from 23 igh school? 24 A. 1937. 25 Q* What did you do from 1937, then, to 1942? 7 A. What did I do from 1937 to 1942? Q. What line of work, or did you work? A. I worked for Macy's, Bloomlngdales , : Colgate-Palmolive. Q* Still living in Jersey City? A. Correct. o. Now, If you could, : would Ilk, to ,,k you at this time to produce for us, to tak, s look at, i aoy documents that you Intend to use or that you will K be relying upon in your deposition here today. i; Do you have anything? i: MR. ROWLAND: I have got copies of _ i : THE DEPONENT: Copies of the letter 14 that I wrote to o.S. Gypsum. is MR. ROWLAND: 16 had these (indicating). I thought you already 17 MR. LOWE: I can't anticipate what you 18 are going to use in the deposition. 19 THE DEPONENT: The letter I wrote to 20 O-S. Gypsum about my father's death, their reply, and 21 his death certificate. 22 BY MR. LOWE: 23 Q- Lee me ask you if this letter dated June 8, 24 1950, is the letter that you wrote regarding your 25 father's death? 8 A. Very much so. Q* And is that letter one . one that you intend to 'els' upon in youc testimony here today? . A. When you say -rely upon,- ho. do you mean? a- w e n , i, it youc undersl:andln5 that you jre 90ih, to be us ing this letter in your testimony here today? A- Well, i , m refer t0 t h u ! Q. And the second document is a letter dated 1C December 27th, 1 9 , which I understand to be the 1] reply to your letter? i: A. That's correct. 13 Q. And then you have shown us a copy of a 14 death certificate. The name off the deceased is 15 Raffaele, Ralph, Miriello. is that correct? 16 A. Correct. 17 a. Do you know of any other documents that you 18 have i,, your possession ,, h,, , M t,,,t yoQ 19 *111 rely upon to give yOUr testimony her. today? 20 A. N o . 21 0. Have you gotten any information, that you 22 ntend to testify about today, from relatives back in 23 lew Jersey? 24 A. I should have and could have; but t didn't. 25 9 ! 1 Q- All right, sir. Let me ask you, it r C,B> 2 please, sir, to tell me your father', main occupation 3 " you recall it from the earliest part of your : 4 childhood that you have a recollection of. 5 A. Cabinetmaker. 6 Q- And In that particular occupation, hat 7 type of thing, did he do? -- if you know- 8 A What did he do? 9 Q What type of thing, did he do? 10 A. Made chest of drawer,*-- you know, 11 furniture, woodworking. 12 Q- Would that have been primarily in the 13 Jersey City area? 14 A. Yes. 15 Q- How, was that hi, main occupation 16 throughout his adult work life history up until the 17 time of his death? 18 A. Very much so, yes. 19 0. Do you know how he came to work at the 20 Henderson Street plant? 21 A. Yes. During the depression years, jobs 22 were hard to come by. And he was forced to look for 23 employment elsewhere. 24 0. In other words, he couldn't make a living 25 to support his family as a cabinetmaker at that time. 10 auri,,g th. depression years, so he then took epl0y.ent where he could find u > b,, la, U y > ^ that period of time? f A. Correct. o- Did he, at some point ln tia. , fttc ,, r k i n g at the Henderson Street piant, then go back to his employment as a cabinetmaker after th. economy got t_ a . _ sr A. True. Q- The depression years,'from my history ll| lessons -- not from my memory -- started about 1929 " D ^ C d " h-- *"* iea when your f a th 13 | worked at the Henderson street factory? A. Somewhere or another th. date of 1933 comes 15 I into play, as far as my recollection goes. 16 0- Realising that's a long time ago -- 17 A. Correct. 18 Q- -- and that our memories aren't always the 19 best, but sitting her today under oath, your best 20 recollection is that your father worked at the 21 Henderson Street plant in 1933? 22 A. Approximately, yes. 23 a. Okay. Do you have any independent 24 recollection as to how long he worked at th. 25 Henderson Street plant? 11 A * Several years. o- in your letter you indicate that your f" h" in tH* " - ' o SCr, t pi.t in 1S35.: Wouid it be your best recollection that he worked there from the years 1933 to 1935? A. V.ah - within'that are. or years, yeah. 0- I* there some ,,ay you Can correlate th# time that he worked in the Henderson street plant with your childhood or your experiences or your ,g. oc years in school? back and do that? i, there any ,,ay [hl, any way that you can go A- Let's see. How can 1 correlate it? No, x guess my recollection would only be the fact that I 14 I remember coming home from school and having lunch is| With him when he was wotting at that plant. 0- Would that have been before you went to 17 | high school-; or do you recall? A. It would be, yeah, uh-huh. 0- Is there something about that - i,, other 20 words, you recall coming home from lunch yourself 21 bafor. you went to high school but not after you 22 started high school? 23 A- No. I just realized t came home from school 24 and had lunch with him. so it was during the 25 depress ion years. If i had to. : could sit down and 12 ( i,uce it out; but yyou aacree ttaaxxiinngg my memory someuhat 1= U your b.,t cecollec tion, as w, sie h!te t0dai" that h* We" e baC,t in' the ca bi ne tma ki ng 1 ture making occupation around 1935 or 1936? A - Uh-huh, somewhere in there. 0- Don t say *uh-huh,- if you would, for the u r t reporter. Plea,. 5,y yts ,, I* it your best recollection that he went back into his main occupation a, a cabinetmaker 10.| between 1935 and 1936? U M R 12 | date. ` R0HLA,,D: tf you know the exact 14 ^ t es. t h e DEPONENT: I don't know the exact I am approximating the dates. 15 somewhere in that area. 15 j BY MR. LOWE 17 0. NOW, you have indicated that probably the 13 beginning of his work at the Henderson Street plant ' 19 probably around 1933 . could it possibly have 20 been earlier than that? 21 *' Could it have been earlier? I really 22 couldn't say actually whether it was earlier or not. 23 But those are the immediat, dat.s that I can 24 recollect. 25 Q* I apologize for c tng insistent -- but 1933 1 2 . 935 arS thS ***** that yU feel comfortable with; is that correct? 3 * 4 after. I" that range, could be two yeara before or ' 5 0- What was the addrea, where you and y,ur 6 family lived back then? 7 * ' 218 5Cand' -r-- 8 I letters, also. -- That's on the o- All right. Do you recall ever living at 10 3 Lexington Avenue in Jersey City? U A - I lived at s Lexington Avenue in Cranford 12 not Jersey City. 13 Th4t wa* not in Jersey City? A- That wa, my fitit hone th, t t nove<J ^ 15 j after getting married. 16 M h U e y0UC fith *otk.d at the Henderson 10 | Street plant, you lived on Grand street? A. Correct. 0- And you probably recall that because it was 2 0 j in fairly close proximity to the plant? " A. very nUch so; i f , ju,t around the corner. o. was your father a cigarette smoker? A. No. He smoked an occasional cigar. 0. Your best recollection is that he did not smoke cigarettes? 14 1 A. That's for sure. 2 Q. os you recall, sic, whethec oc not youc 3 father ^ CeCeived hls wa9es in a pay envelope with 4 cash in It opposed to a cheek, oc do you recall? 5 Do you eve a ceeoUeetioh one way oc the other? 6 A. Somehow - this is v.9ue __ but r thlnk 7 was a check. 8 Q. Do you know if you oc ,ny a( 9 family -- youc bcothecs and sister, - ,,ould have a 10 sheet stub oc some sort of a pay slip -- 11 A. At this day and age? 12 Q. Yes. 13 A. No . 14 Q. -- that would show, specifically, who it 15 was that youc fathec wocked foe at the Henderson 16 Street plant? 17 A. No# by no means. 18 Q. tet me ask you. Me. Miriello: Do you smoke. 19 or have You ever smoked? 20 A. Yes, i do. 21 Q. On a regular basis? 22 A. Uh-huh. 23 Q. How much do you smoke, please, sic? MR. ROWLAND: 25 do with this case? what does that have to 15 1 t 2 LOWE i Th i <? i j Tnis 13 discovery. A ll i "" asking bin, about are his smoking habits on a daily 3 basis. f 4 MR. ROWLAND: What l,, the world d0,, 5 that have to do . lth the * " : * of this litigation? S MR- Lo w e :' it may be tied in. r d o n .t 7 thlnh I have to show i f . r.l.va.t'.t this point in \ C 16,1 I - o f t think th. Rules require me to do that. i t h e DEPONENT: Suppose I am refusing to answer? MR. LOWE: I want to ask you that. THE DEPONENT: r don't think it's n t t0 What we are talking about. personal opinion. That's my own BY MR. LOWE: 17 0. Oo you mind t e l U n g m. how long you have . 18 been a smoker? 19 A- fo, because we are not talking about me. t 20 am not being prosecuted, as such. 21 o. Did you ever receive .,,y baseball cards in 22 tobacco that your father brought home when you were a 23 boy? Do you ever remember getting anything like that? 24 A. No. 25 Q- You don't remember your father bringing 16 Cl,*t* tt** t0 the hous* King cigarettes? *' *>t at all. i already told you he was an occasional cigar smoker. . r a. When you were growing up, do you recall reading the city newspaper? A. Yes. ' Q* Was that the Jersey Journal? I A. Correct. It( a. Let me show y,,u , if j could, ple,, e( ,iC/ a copy of the Jersey Journal dated Tuesday, March the 1] 3rd' 193S' and 45lt y u i * would look at that and 1: i3t familiarise yourself with that for a minute. 13 MR. ROWLAND: How about showing me the 14 Other documents that you have got from your company IS files about his father and his employment. 16 MR. LOWE: I don't have -- as a matter 17 >f fact, there is no evidence that he ever worked for 18 J.s. Gypsum. 19 MR. ROWLAND: Yeah, there is. Right 20 're (indicating) is the evidence. 21 MR. LOWE: A search has been made, and 22 here is no evidence that he worked for the 23 .3. Gypsum Company. 24 THE DEPONENT: This (indicating) is 25 heir rely to my letter, and it says U .s . oyp.um. I can't read this; I am sorry. BY MR. LOWE: it's too - 0- Are you not able to read that print? r < A. Just the large print, yeah. t Q. Read to me, if you would, what you oan read A. What I oan read? 'Large Gypsum Firm comes Here; Jobs For Hundreds." 8 Q- Is there anything else in that article that 9 you can read? 10 A. "5100,000,000 corporation takes ' 11 50-year lease. Decision made after survey conducted, 12 say officials." 13 Q. Anything else? 14 A. "Murder trial." 15 MR. LOWE: We would ask that that or a 16 copy of that 'newspaper article be introduced and 17 admitted as Exhibit 1 to your testimony. 18 (Deposition Exhibit 1 was marked for- 19 identification.) 20 BY MR. LOWE: 21 Q. Mx. Miriello, a few minutes ago you 22 indicated -- when I was having a side conversation 23 with Mr. Rowland about employment records regarding 24 your father that the letter that we looked at was 25 an indication that your father worked for U.S. Gypsum CALDERWOOD/MACKELPRANr %ffe ek /e a a t la 1 Company. 2 C you t e n 3 talking about? which letter you ere 4 A Both. 5 o- would you show ... lB the united state, 6 Gypsum letter, where - "re it indicates that your father 7 worked for United Stah* ,, 80 states Gypsum Company? 8 A- I f , i,, tepiy to By letter. 9 0- They don-t oknowledg. la their letter to you that he worked there; do ttrey, y.u are ju,t u saying that since they did writ, you hack, that you " feSl thit'S " 13 | right? a work there, i, that 14 A. I was invited for a tour of the plant. x 13 fr * tOUC f th* their request. 15 0- They invited you for a tour of th. plant, 17 A * Yes. 18 o- IS that what you are relying upon to show " l" " 20 21 22 23 yUr f4th -'*- fOt O.S. Sypsun, A * I know he worked there. Q. I understand that you say he worked there. A * I know he worked there. All right. Sir. But is there anything, 24 other than what you iust __ . , i 25 you just pointed out in the letter, that indicates that he did, in . ' in fact, work there -- by 19 documen ts, not by what you at. ,ayi,,, but by , documen t? Do you feel there is anything in this : iett.t dated December 27. 1,S0. to you that admits or ind icatas that your father workad for United Statas Gypsum Company? * *' I don't know what you ara driving at. Q- What I am driving at -- is there any acknowledgement anywher, in this latter that statas 1< that your f.th.r did, i,, fact, work for united statas 1J Gypsum Company? 1; MR. ROWLAND: well, i think the letter 13 speaks for itself. 14 MR. LOWE! I am entitled to ask and IS have that question answered. 16 THE DEPONENT! One would think that if 17 I -rota a letter to my father's plaoe of employment 18 >nd they replied, that that, i,, itself, is an 19 acknowledgement of his being employee there. 20 MR. LOWE; 21 0- So X w i n understand, the only thin, that 22 ' " upon as evidence that your father 23 'orked at United States Gypsum Company is the face 24 hat you wrote them a letter and that they wrote back; 2 5 MR. ROWLAND; That's not correct. He 20 said he knew he worked there. to him there. BY MR. LOWE: MR. LOWE: I am asking you, sir -- THE d e p o h e n t , I used t0 btlB9 lunehe: 0- we talking now, at thl3 p o .nt> 4bout I 1< 13 i; 13 14 15 16 17 18 19 20 21 22 23 24 25 iOCO* enlS that - . r your father dld or not worle for Onrted Stat.s Gypsum Company. A - Her.-s (indicating) -another document that will t.IX you, because he d i e d `of asbestosis. 0- Is there anything on the death certificate that indicates your father worked for G.S. 0yPsUm? * here els. would he have gotten asbestosis? Q. Is -- A * On the heading of this letter -- o- t-et me finish my question first, is there anything on the death certifies*- . ctificate, anywhere, that . states United States Gypsum Company? A * No. But I am sure if you went to Dr. H u m 's records, it does list ti c r- lst U.S. Gypsum Company. a- IS there anything on the Onit.d States ypsum company letter that acknowledge, that your ather was ewer an employe, of United States Gypsum ompany? - other than t(u aet that th>y espondud to your letter. 21 A- W e U ' wouldn,` one think tha8tt iict yvoouu wrote to a company - o- Excuse ... sir. Just answer my question. an swe r . * ROWLAND! Dactyl, he's trying to . BY MR. LOWE: a- 13 there anythin, in this Utter, anywhere, that acknowledges that your father worked for United States Gypsum Company? ' - 1 I t e U i ,, 9 you, sir, that if one wrote a l; company, they would deny the letter that they l: received. And they wouldn't bother answering it and i: would say we will not concede to the fact that your X< father worked here, so w. h... no furthec if acknowledgement of your letter. 16 they are acknowledging my letter and 17 inswer ing it .,,d statin, that they are - as you can 18 fecy well read. 19 0. That is your opinion, is that correct? 20 * It would be any intelligent person's 21 Pinion. I am not knocking your intelligence. 22 0- As a matter of fast, the letters says 23 Pec ifically - and if y0,, would ollo,, ^ ^ 24 A- You are picking out - you are isolating 25 Sate men ts in the letter to try to bring out a point 22 that doesn 't e*ist, sir. Q* quoting h. Let me do this An* . S ' An,J' foc record, by from this letter t 1 C ' 1 d n0t " l * *Y right to 5,Ct 60 th* intt0<JUC" =h * .ny of these documents " - i b i t s to the plaintiffs proof in chlef_ to th " ^ WOU" Pl* " * ilt*Ct YOUr att t i o n to the second peregr.ph of th. U t t e r . . setter and see if x am reading this correctly. Too ere tati,,9 som.thing out of ,,,,text. 1 Q* Follow along -- 1 *' iOU Wint ta taka thi* ot of context. 1 0- I want you to looh ,,,d see 1{ r ,,.d lt 1 rorrectly - and * .* ehee|t of ouc 1 hows that our company did not acquire and operate 1! 't* M,w Jetsay plant here your fath.r your rather was employed 1< mtil February 28, 193s y 1936, and accordingly, his i : mPloyment or the bulk * oulk of it oust ha*, been for the la " or `'ner 0t Pttor of that plant.- 19 A - Who was th. former owner? 20 a- Srr, answer my question. 21 A * Mho was the former owner? 22 MR. ROWLAND: iAtf hnee .r.e.a.d i,.t correctly, 23 at agree he read it correctly. 24 THC DEPONENT: Because National Oypsum 25 "Pany is U.s. Oypsum Company, they are on< in t,,. 1 same. 2 3 cor rectly? h r . ROWLAND: Did he read the t,, |ng 4 5 correctly 6 7 BY MR. LOWE: t h e DEPONENT: Yes. he read it MR. ROWLAND: Okay, fin e . 8 <! h o w , you Just indicated that, i,, yotr 9 opinion. National Gypsum Company , nd 0 .s . Gypsun XO company is one and the , ,, e coaTpany. Dld t 1 1 j understand you correctly? i3 that correct? h r . ROWLAND, If you know, tell him 13 what you know. X you do,,.t know> d o n ,t tty ^ 14 guess at something. 15 THE DEPONENT: No, I don't know. 16 MR. LOWE: I would suggest to you, 13 Mr. Miriello, that what Mr. Rowland just said as 18 counsel for the plaintiff 1 this c4se would hold 19j whole true for a n for all of your testimony 20 should not queaa ,,j . . . just state what 2 1 j believe that's all. -- that you you know. i 22 MR. ROWLAND: I don't have any 23 questions on this deposition. 24 (Whereupon, at 10:56 a .m ., the 25 deposition concluded.) 24 I of my testimony *"d signature. f d th. for.9oi,,g transcript have iniioted sam. by my benjamin g . miriello Il i: STATE OF COLORADO x: CITY AND COUNTY OF DENVER : 14 15 Subscribed and sworn Co before me by 16 the said BENJAMIN s. MIRIELLO. this a 17 --- --------- 198 5 . 18 My commission expires 19 20 21 22 Notary Public 23 24 25 25 STATE OP COLORADO -- -2IfiCTE CITY AND COUNTY OF DENVER ) SS* X ' D3Wn Calde^ o d , a Certified r Shorthand Reporter P ter and Notary Publie for the state of Colorado, do hereby certifv . / certify that previous to the commencement of the e*m< nation, the said BENJAMIN g . MIRIELLO was duly sworn v*,, y "* t0 ' i f y the truth in relation to the matters in controversy between the *" d PartieS' th,t th* " deposit ion, consisting of 1 23 PS9aS' " " ln 'orthand by . and wa, 1 reduced to typewritten for, that the foregoing is a l: true transcript of the questions ashed, testimony i: given, and proceedings had, that I am not attorney n nor counsel nor in any way connected with any is attorney or counsel for any of the parties to said 16 action or otherwise interested in its event. 17 IN WITNESS WHEREOF, ! have affir.d my. 18 notarial seal t h i s ________ ay of 19 1985. ~ 20 21 22 23 ... dawn calderwood Calderwood/Nackelprang s Associates 24 rtified Shorthand Reporter and Notary Public 25 2 6 CALDERWOOD/MACKEL PRANG 6 ASSOCIATES 1554 Vine Street Denver , Colorado 80206 January 25, 1985 Mr. Benjamin Miriello 2750 South Zanada Way Aurora, Colorado 80014 Res County of Anderson, et al. vs .S. Gypsum K I b o v e - t n i t i e r i a i e lh " r n i "*' in the court Rules require that w r % M * n tcan,cribC The 1] promptly. Therefore, if you wiuiiO w tde?osil:i0ns i: sign your deposition,s please call o u - M . revlew s"d an appointment . . . 11 ur offxc to make 12 14 statute! diy* t0 COOply with the IS .z_. ' so the deposition 16 may be filed in time for trial. 17 r If you do not call for an 18 designated, we shall file appointment within the time your deposition unsigned. 19 S incerely, 20 21 Oawn Calderwood 22 fc9wifsftAenrvewdu/ PArtofKeEsLsPiRoAnNaGl 4ReApSoSrOCtIerATsES 23 M. Rowland 0. Lowe 14 Court, File 25