Document pBm0b2Ey40XGqdE4eZeV0w3Va

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA Lmf V t u ; . <i A i t k t u r j u v M J M NVAD^JjpWER COMPANY, a /levada corporation, * Plaintiff, vs. MONSANTO COMPANY, a foreign corporation; GENERAL ELECTRIC COMPANY, a foreign corporation; WESTINGHOUSE ELECTRIC CORPORATION, a foreign corporation; and DOES I-XXV, inclusive, Defendants. No. CV-S-89-555-LDG (LRL) COPY DEPOSITION OF KENNETH ROBINSON Santa Ana, California Thursday, March 18, 1993 REPORTED BY: SHERI L. CLARK-BELL, CSR NO. 6368 JOB NO. 132165 Los Angeles 6222 W ilshire Blvd., Suite 204 Los Angeles, CA 90048 213938.2461 . Fax 213 931 3016 Orange County 2100 N. Broadway, Suite 210 Santa Ana. CA 92706 714.834.1571 Fax 714.834- 9235 San Diego 619.434.4854 Fax 619.544.9901 800.888.6949 V* Los Angeles 213.938.2461 Fax 213.931.3016 Orange County 714.834.1571 Fax 714.834.9235 San Diego 619-434.4854. Fax 619.544.9901 1.800.888.6949 CERTIFIED**' SHORTHAND REPORTERS April 12, 1993 Deborah N. Mailander BRADLEY & MERRELL c/o JONES, CLOSE & BROWN 300 South Fourth Street Suite 700 Las Vegas, Nevada 89101 Job No.132165 Please be advised that the sealed original transcript of the belowcaptioned deposition is hereby being forwarded to your office. CASE NAME: CASE NO.: WITNESS : REPORTER: Nevada Power Company vs. Monsanto Company C V -- S -- 89-- 5 5 5 --L D G Kenneth Robinson DATE TAKEN: 3/18/93 Sheri Clark-Bell The following changes should be noted: PAGE 5 5 6 6 6 6 7 10 & 13 LINE 16 18 13 18 21 22 19 FROM \ TO `Van B. Nindante Lindante in an undergraduate on the graduate 1953 1952 1968 1963 1970 1968 Add assistant "duty " was See Attached r t . - O O ./ %"f/'-c'O Cs W/ J Jill S. Rodomsky Sarnoff Deposition, Service, Inc. cc: A ll Counsel 6222 Wilshire Boulevard, Suite 204 * Los Angeles, California 90048 I 2100 North Broadway, Suite 210 Santa Ana, California 92706 Page Line No. ATTORNEY' S NOTES . 1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 4 NEVADA POWER COMPANY, ) a Nevada corporation, ) 5) Plaintiff, ) 6 vs. ) ) 7) MONSANTO COMPANY, a foreign ) 8 corporation; GENERAL ) ELECTRIC COMPANY, a foreign ) 9 corporation; WESTINGHOUSE ) ELECTRIC CORPORATION, a ) 10 foreign corporation; and ) DOES I-XXV, inclusive, ) 11 ) Defendants. ) 12 ________________________________________________________________________________ ) 13 No. CV-S-89-555-LDG (LRL) 14 15 16 Deposition of KENNETH ROBINSON, taken on behalf 17 of the Plaintiff, at 2100 North Broadway, Third Floor, 18 Santa Ana, California, commencing at 12:55 p.m., on 19 Thursday, March 18, 1993, before SHERI L. CLARK-BELL, 20 Certified Shorthand Reporter No. 6368, pursuant to Subpena. 21 22 23 24 25 2 (714)834-1571 ^Sarqoff cDepositioq^Service,^qc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 APPEARANCES : 2 3 4 For Plaintiff: 5 BRADLEY & MERRELL Attorneys at Law 6 BY: DEBORAH N. MAILNDER JOSEPH MAILANDER, Legal Assistant 7 c/o JONES, CLOSE & BROWN, Chartered 300 South Fourth Street 8 Suite 700 Las Vegas, Nevada 89101 9 10 11 For Defendant Westinghouse Electric Corporation: 12 THORNDAL, BACKUS, MAUPIN & ARMSTRONG 13 Attorneys at Law BY: PEGGY A. LEEN 14 1100 East Bridger Avenue Las Vegas, Nevada 89125-2070 15 15 17 For Defendant Monsanto Company: 18 KIRKLAND & ELLIS 19 Attorneys at Law BY: SCOTT R. BAUER 20 1999 Broadway Denver, Colorado 80202 21 22 23 24 25 (714)834-1571 arqpff cDepositiotServicc, (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 3 1 INDEX 2 WITNESS EXAMINATION PAGE 3 ROBINSON, KENNETH BY MS. MAILANDER 5 4 BY MR. BAUER 22 5 6 7 8 9 10 11 12 13 14 15 EXHIBITS FOR IDENTIFICATION 16 (None) 17 18 19 20 21 22 23 24 25 4 (714)834-1571 Sarqoff cDepositioq?ervice,cIqc (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 Santa Ana, California, Thursday, March 18, 1993 2 12:55 p.m. 3 4 KENNETH ROBINSON, 5 produced as a witness by and on behalf of the Plaintiff, and 6 having been first duly sworn, was examined and testified as 7 follows: 8 9 EXAMINATION 10 BY MS. MAILNDER: 11 Q My name is Deborah Mailander, and I represent 12 Nevada Power Company in this lawsuit against Monsanto, 13 Westinghouse and GE. 14 Could you state your full name for the record, 15 please. 16 A Kenneth Van Robinson. 17 Q And what is your current residential address? 18 A 8804 Nindante, N-i-n-d-a-n-t-e, Drive, 19 Whittier, California 90603. 20 Q Are you being represented by an attorney here 21 today? 22 A Yes. 23 Q And isthat Ms. Leen? 24 A Peggy. 25 Q Have youspoken with anyone in preparation for 5 (714)834-1571 arqoff ^eposttioq^Scrvice, ^ijc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 this deposition? 2 A Just at lunch. 3 Q Have you reviewed any documents in preparation 4 for this deposition? 5 A None. 6 Q Are you currently employed? 7 A No, ma'am. 8 Q What years were you employed at Westinghouse? 9 A From 1949 to 1990. 10 Q Would you go through your period of employment 11 at Westinghouse and tell me what position or positions 12 you've held and the approximate years for each one. 13 A 1949 to 1950 I was in an undergraduate student 14 program. 1950 I went to Portland, Oregon as a sales 15 assistant. 1952 I was made a sales engineer. 16 Q Okay. Hold on. Let me catch up here. I'm 17 sorry, what year were you a sales engineer? 18 A 1953 I was made a sales engineer. 19 Q Okay. Go ahead. 20 A That was in Portland, Oregon. In 19 -- what 21 year was it? In 1968 I was transferred to the Los Angeles 22 office as a sales engineer, 1970 to the Phoenix office as 23 district manager. That was 1968, did I say that? 1970 I 24 transferred back to Los Angeles as district manager. And I 25 was district manager in Los Angeles from 1970 to 1990 in 6 (714)834-1571 ^SarqofT GDepositioqtGServict<lqc. MEMBER NATIONAL NETWORK REPORTING COMPANIES (213)621-2653 1 d if f e r e n t p o s itio n s o f m anagem ent, d if f e r e n t p ro d u c ts . 2 Q So from 1968 to 1970 you were in the 3 Los Angeles office as sales engineer? 4 A I was in Phoenix asa district manager. 5 Q From 168 -- 6 A '68 to '70 inPhoenix, Arizona as district 7 manager, and then 1970 to 1990 in the Los Angeles office as 8 district manager. 9 Q So when did you start in Los Angeles as a sales 10 engineer? 11 A 1963. 12 Q From 1950 to 1952, while you were a sales 13 assistant, were you involved with equipment that contained 14 Inerteen? 15 A Yes. When you say "involved," I was involved 16 in helping the salesmen sell the equipment. 17 Q And could you explain a little bit more what 18 your duties were as sales assistant. 19 A Sales assistant was to assist the sales 20 engineer in communicating bids back to the factory, 21 preparing quotations, taking customer phone calls, generally 22 assistant to the sales engineer. 23 Q And what were your duties as a sales engineer? 24 A Sale of Westinghouse products to electric 25 utilities. 7 (714)834-1571 ^Sanjoff GDepositior^ervtcc,chic. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 Q And w hat ty p e o f W e stin g h o u se p r o d u c ts w ere you 2 involved in selling between 1953 and 1963? 3 A 1953 -- 4 Q That was while you were in Portland, I believe. 5 A In Portland, Oregon I was selling everything 6 from nuclear plants, turbine generators, distribution 7 transformers, watt-hour meters, lightning arresters, T&D and 8 generation equipment until 1963. 9 Q And then in 1963 in the Los Angeles office, 10 what type of equipment were you selling there? 11 A Transmission and distribution equipment, 12 watt-hour meters, transformers, capacitors, lightning 13 arresters. That was 1963 to 1967. '67 to *68 was nuclear 14 plants, turbine generators. 15 Q While you were a sales engineer in Portland and 16 in Los Angeles, did some of the distribution equipment that 17 you handled include equipment that contained Inerteen? 18 A In Portland? There were Inerteen transformers 19 in Portland. Los Angeles, I don't recall the sale of 20 Inerteen transformers. Capacitors, yes. 21 Q And what were your duties as district manager 22 in Phoenix? 23 A Supervising the sales force and responsibility 24 for the sale of Westinghouse product to electric utilities. 25 Q And were your duties essentially the same in 8 (714)034-1571 ^Sarqoff cDepositioq^Service,!qc (213) 621 -2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 Phoenix and in Los Angeles? 2 A Yes. 3 Q At any time while you were working with 4 Westinghouse was it your responsibility to inform customers 5 of potential hazards that might be associated with the 6 equipment that you sold? 7 A If I received notification from a division, I 8 would advise the customer. 9 Q Was there a particular procedure for notifying 10 customers? 11 A Yes. The division, if they recognized a 12 problem with equipment or some type of problem, they'd 13 notify the field, and we'd usually have a form letter for us 14 to send on to the customer. 15 Q And while you were at Westinghouse were you 16 ever informed from the division of any warnings that needed 17 to be passed on to customers regarding PCBs? 18 A I can't recall exactly. But when one came out, 19 letters were transmitted to the customer in regards to the 20 use of Inerteen. 21 Q And do you recall if there was an approximate 22 year when you started notifying customers -- 23 A I don't recall the years. Probably in 1970, 24 could have been mid-1970s, I don't remember. But we in the 25 field would get notification from the manufacturing 9 (714)834-1571 ^SarqpfT ^DepositiorfService^rjc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 divisions of any problems, and we would then notify the 2 customer. 3 Q During your employment atWestinghouse did you 4 have communications with Nevada Power Company? 5 A Yes. 6 Q Sir, during what period of time did you have 7 communications with Nevada Power Company? 8 A From 1970 to 1990. 9 Q So that would be while you were the LosAngeles 10 district manager? is that correct? 11 A That's right. 12 Q Do you recall the names of any of the people at 13 Nevada Power who you dealt with? 14 A Yes. Elmer Johnson, Harry Allen, Art Pearson, 15 Connie Ryan. I dealt mostly with the executives, presidents 16 and executive vice presidents. 17 MR. BAUER: Could I hear the names back. 18 MS. LEEN: Elmer Johnson, Harry Allen, Art Pearson. 19 MR. BAUER: Elmer Johnson? 20 MS. LEEN: Yes. 21 THE WITNESS: They were generally the board and 22 presidents of Nevada Power from the time I started calling 23 on them. 24 BY MS. MAILANDER: 25 Q Was there a typical transaction that you had 10 (714)834-1571 *arqpiT ^Depositioifervicc,^qc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 with Nevada Power in regards to distribution equipment? 2 MS. LEEN: Objection; overbroad. Go ahead. 3 THE WITNESS: Do you want me to answer? 4 MS. LEEN: Sure. 5 THE WITNESS: There was nothing typical. We sold our 6 distribution product to Nevada Power through Osborne 7 Electric up until about 1985, *86, '87, when we took over 8 the direct sales ourselves. They were our agents. 9 BY MS. MAILNDER: 10 Q Do you know what year you began dealing through 11 Osborne Electric with Nevada Power? 12 A I took over as district manager in 1970, and 13 the arrangements were all in place at that time. I don't 14 know how far before that time. 15 Q Did Osborne Electric handle both transformers 16 and capacitors? 17 A Yes. They handled distribution and 18 transmission equipment. We handled generation equipment 19 direct. 20 Q So did you have any dealings directly with 21 Nevada Power on distribution and transmission equipment at 22 all? 23 A Very seldom. We divided up our responsibility, 24 and the sales engineer generally handled transmission and 25 distribution equipment and I handled the generation, the 11 (714) 034-1571 ^SarqoiT ^DepositiorfService,^Iric. (213)621 -2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 contact with the top management. 2 Q And with the contacts that you did have at 3 Nevada Power, what type of service did you personally 4 provide? 5 A I don't know how to answer that. I was trying 6 to sell them equipment. That was the service. 7 Q Did you provide them with specific information S to assist them in purchasing Westinghouse equipment? 9 A We provided catalogs. They were on our mailing 10 system, and catalogs were sent to them. All updated 11 catalogs would usually be sent to them. If new equipment 12 came out, we would send them letters if we felt they were 13 interested, or if it was a product that might be of interest 14 to them. 15 Q Were you ever in a position to suggest or 16 recommend that Nevada Power purchase specific equipment from 17 Westinghouse? 18 A We suggested certain transformers, certain 19 generators, certain equipment. 20 Q Do you recall whether you ever suggested that 21 Nevada Power purchase a specific type of Inerteen equipment? 22 A No, ma'am. Capacitors probably, not 23 transformers. They were not purchasing Inerteen 24 transformers, that I am aware of, from 1970 from us. 25 Q Prior to 1979, while you were working with 12 (714)034-1571 arqoif cDepositiorcrvicc,^qc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 Westinghouse, did you have any direct physical contact with 2 equipment which contained Inerteen? 3 A At any time during my career? 4 Q Prior to 1979. 5 A Prior to 1979, yes, in Portland, Oregon. 6 Q And what type of work were you doing that 7 required you to handle Inerteen? 8 A Well, I think if there was a defective 9 transformer, I went out and looked at the defective 10 transformer and tested the transformer and probably touched 11 the side of it, and there may have been something on the 12 side of it, that's all. 13 Q Do you recall whether the transformer was 14 leaking? 15 A I don't recall. 16 Q Do you recall what type of defect there was in 17 the transformer? 18 A No, ma'am. 19 Q At the time you think you mayhave handled the 20 Inerteen, did you wear any type of protective clothing? 21 A No, ma'am. 22 Q During thetime that youworked at Westinghouse 23 were you ever advised of potential health hazards that might 24 be associated with polychlorinated biphenyls? 25 A When the letters would come out from the 13 (714)834-1571 ^SarqofT cDepositioq^Service, (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 divisions advising us to advise the customer, I would read 2 the letters and I would be aware of it from that point. I 3 was also aware of it from reading trade journals and from -4 going to conventions where it would be discussed. 5 Q Do you recall whether you attended any 6 conventions prior to 1979 where the potential hazards of 7 PCBs were discussed? 8 A I don't remember. 9 Q Do you recall whether prior to 1979 you read 10 any trade journals regarding potential hazards associated 11 with PCBs? 12 A Oh, yes. 13 Q Do you recall specifically what type of hazards 14 may have been discussed in those trade journals? 15 A Only that it was suspected cancer causing. 16 Q Do you recall what year you first read that 17 PCBs were suspected of causing cancer? 18 A I can't remember. Early '70s, possibly, late 19 '60s. I don't remember exactly. 20 Q During the time that you worked at Westinghouse 21 were you ever informed that Inerteen could be absorbed 22 through the skin? 23 A I don't know that I was -- I can't tell you in 24 exact detail when I was aware. It was advised not to get it 25 on your hands, if you could avoid it. 14 (714)834-1571 ^Sarqoff cDepositioq*Servce, (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 Q And you mentioned earlier that you did have 2 physical contact with Inerteen from a defective transformer; 3 is that correct? 4 A Yes. 5 Q Did you wear gloves at that time? 6 A No, ma'am. 7 Q So is it safe to say that any knowledge you 8 gained about -- 9 A That could have been before we were even aware 10 that Inerteen was a potential problem. 11 Q While you worked at Westinghouse were you ever 12 told that PCBs could cause serious skin irritation? 13 A I don't remember the details exactly. All I 14 can think about Inerteen was it was a possible 15 cancer-causing device. 16 Q While you worked at Westinghouse were you ever 17 informed that PCBs could be an environmental hazard? 18 A I don't remember the details of that. 19 Q Do you remember ever being informed at all that 20 PCBs could be -- 21 A Oh, I was informed in letters that came out, 22 which we would then notify all of our customers who had 23 purchased transformers, of the potential problems. If they 24 are in the letters, I was aware of it. 25 Q Do you recall while you worked at Westinghouse 15 (714)834-1571 ^SarqoiT ^Depositioq^Service,^qc. (213) 621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 ever receiving requests from customers regarding potential 2 hazards that might be associated with Inerteen? 3 A I don't recall -- 4 MS. LEEN: Objection; ambiguous. But go ahead. 5 THE WITNESS: I don't recall any request from a 6 customer of that nature. 7 BY MS. MAILNDER: 8 Q Did you ever conduct any seminars or provide 9 any instruction to Nevada Power personnel? 10 MS. LEEN: Objection? compound. 11 MR. BAUER: And vague. 12 THE WITNESS: On what subject? 13 BY MS. MAILANDER: 14 Q On Inerteen. 15 A No, ma'am. 16 Q Did you ever provide any pamphlets or 17 instruction books on Inerteen to Nevada Power personnel? 18 A If they came out from the division as part of 19 the catalogs or part of the equipment, they would have been 20 furnished. 21 Q Do you know specifically whether there were any 22 such instruction books -- 23 A All I can assume is there were definitely 24 books, but I can't tell you the name of them or the dates. 25 This was not a problem that developed on a finite day. It 16 (714)034-1571 S S arqoff cDepositioServicet7qc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 developed over a long period of time. 2 Q As part of your responsibilities as district 3 manager, would you periodically review the instruction books 4 on Inerteen that were provided to customers? 5 A No, ma'am. 6 Q Do you recall whether five to seven years ago 7 any documents relating to PCBs were sent from your workplace 8 to the legal department of Westinghouse? 9 A I don't recall that. 10 Q Do you recall whether any attorneys came to 11 your workplace and reviewed documents related to PCBs? 12 A They could have. X don't know. 13 Q Are you aware that Nevada Power has filed a 14 lawsuit against Westinghouse? 15 A Yes, ma'am. 16 Q And when did you firstbecome aware of this 17 lawsuit? 18 A Oh, about 1988, 1989, 1990, about the time I 19 was retiring X became aware of it. Mr. Pace, who was my 20 sales representative at that time calling on Nevada Power, 21 was mostly involved in the T&D equipment, and I think I was 22 aware that there was a lawsuit discussed at that time. 23 Whether it had been filed or not, I don't know. 24 Q And what was Mr. Pace's first name? 25 A Richard. 17 (714)834-1571 cS a j7o/T cDepositiorervicet^qc. (213)621 -2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 Q Are you aware whether or not Westinghouse has 2 entered into an indemnification agreement with Monsanto 3 which requires Westinghouse to compensate Monsanto for 4 litigation expenses related to the PCB litigation? 5 A I'm not aware of any. 6 Q Do you have any information relating to whether 7 Nevada Power gained -- let me start over here. 8 Do you have any information regarding when 9 Nevada Power gained information regarding potential hazards 10 associated with Inerteen? 11 MS. LEEN: Objection; overbroad. Do you mean from - 12 Westinghouse or from other sources? 13 MS. MAILANDER: I mean from other sources. 14 THE WITNESS: The problems with the Inerteen, 15 askarel, Pyrenol was well-known to the trade at certain 16 times, and it was in the newspaper, it was in the trade 17 journals, it was in conventions. They were just as aware as 18 we were and any other customer in the United States was 19 aware. It was very prominent when we all became aware it 20 was a problem. 21 BY MS. MAILANDER: 22 Q Did you at any time while you were working with 23 Westinghouse discuss potential hazards of PCBs with any 24 personnel from Nevada Power? 25 A I did not. It was never discussed. My 18 (714)834-1571 QSartipff cDepositioqjGervtce, `Tqc. (213)621 -2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 discussions were mostly with the executive vice president 2 and up. 3 Q Have you reached an agreement with defense 4 counsel to testify in this case? 5 A What do you mean have I reached an agreement? 6 Q Have you talked with them and agreed to testify 7 at trial in this case? 8 A Ms. Leen came to my home -- 9 MS. LEEN: I will instruct you not to answer 10 concerning our discussions. But if you have an agreement to 11 testify at the time of trial, say yes or no to that. 12 THE WITNESS: Oh, I'll testify. 13 BY MS. MAILNDER: 14 Q 15 counsel? Do you have a written agreement with defense 16 A No, ma'am. 17 Q Do you have an oral agreement with defense 18 counsel to testify as of today? 19 A I have no objection to testifying. 20 Q That's okay. 21 MS. LEEN: He's answered your question. There is no 22 agreement, per se. As in every case, we will determine at 23 the close of the case who we are going to call as a trial 24 witness, and Mr. Robinson may or may not be called, 25 depending on what the issues are at the time of trial. So 19 (714) 834-1571 ^Sanjoff '"DepositioTj^Servicc,`Iqc. (213) 621 -2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 that's the best we can answer for you at this time. 2 THE WITNESS: If I'm called,, I have no objection. 3 But there is no agreement, no. 4 MS. MAILANDER: Why don't we take a quick break. 5 (Recess taken.) 6 BY MS. MAILNDER: 7 Q Just a couple more questions here. 8 A Are we back on the record now? 9 Q Yes. 10 A I have to play attorney a little bit. 11 Q Do you know who Robert Kinslow is? 12 A Yes. 13 Q And do you know what position he held at 14 Westinghouse? 15 A Pardon me? 16 Q Do you know what position he held at 17 Westinghouse? 18 A He was a special sales representative working 19 for me. 20 Q Can you describe for me what the duties are of 21 a special sales representative. 22 A He was a senior sales engineer dealing with 23 important customers, major products, and was involved in the 24 sale of Westinghouse apparatus to utilities. 25 Q Do his duties differ from, say, a line salesman 20 (714)834-1571 ^arqpfT 'Depositioq^Servicc, ^qc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 or distribution salesman? 2 A No, just different grade of customers and size 3 customers, different type of equipment. 4 Q So the fact that he's called a special 5 salesman, is it special customers? 6 A A sales engineer and a special sales 7 representative did the same work. They did the same thing. 8 Q But their customers were different; is that 9 right? 10 A Some customers, yes. If it was a large 11 customer, maybe it would be a special sales representative.- 12 A smaller company might just be handled by a sales engineer. 13 But their responsibilities and duties were identical. 14 Q Is Nevada Power Company considered a large 15 customer? 16 A They were a very large customer of ours in 17 generation equipment. 18 Q And do you know for distribution equipment 19 whether Nevada Power is considered large or small? 20 A Compared to many of our customers, they were 21 small. But they are also large compared to a lot of 22 customers. 23 Q Do you know who Gary Cunningham is? 24 A Yes. 25 Q And do you know what his current residential 21 (714)834-1571 ^a rq o if GDepositioq?ervice.GIqc (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 address is or where he's currently living? 2 A I do not know. 3 Q Have you ever heard of Jeffrey Bair? 4 A No. 5 Q How about C.W.Bickerstaff? 6 A No. 7 MS. MAILNDER: All right. I have no further 8 questions at this time. Thank you. 9 MR. BAUER: I h a v e a f e w , M r . Robinson. 10 11 EXAMINATION 12 BY MR. BAUER: 13 Q As I mentioned before the deposition, my name 14 is Scott Bauer. I represent Monsanto Company in this 15 litigation. 16 You mentioned several times in your testimony 17 this morning the catalog. Do you recall that? 18 A Yes. 19 Q Would you describe the catalog for us. 20 A It's classified literature. Could be anything 21 from price lists, discount schedules, catalog sections, 22 instruction books, instruction leaflets. And there was just 23 a computerized mailing list that we would mark to send out 24 to customers. 25 As far as Nevada Power is concerned, they may 22 (714)834-1571 arqoff cDepositioq?ervicei^qc. (213)621 -2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 have had 10 or 15 sets of these catalogs. Purchasing would 2 have them, engineering would have them, the vice presidents. 3 We'd mark them for instruction -- not for instruction books, 4 but what's on new equipment. 5 Q Do you know from your work with Nevada Power 6 that there were people at Nevada Power that received the 7 Westinghouse catalog? 8 A Yes. 9 Q You described the procedure that different 10 mailing lists would go out to different people in terms of 11 what parts of the catalog would go to what -- 12 A We have a list of all the products, and there 13 would be columns of price, discount sheets, et cetera, et 14 cetera, and we could mark the name of the customer and what 15 product we wanted and what sheet we wanted to automatically 16 be sent to them that they were issued or renewed. 17 Q Were instruction leaflets in some catalogs? 18 A They were part of that list, uh-huh. 19 Q And were product brochures also? 20 A Yes, descriptive bulletins. 21 Q Do you recall something called a sales letter? 22 A Certain sales letters announcing new products 23 and things like that would go out, yes. 24 Q Do you know whether sales letters were the 25 mechanism by which Westinghouse informed customers of 23 {714)034-1571 ^SarijofF cDepositioq^Service,^qc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 potential hazards from -- 2 A 1 don't recall exactly. In that case I think 3 it would probably be a notification from the division to my 4 office and then from my office to the customer, 5 Q You mentioned 10 or 15 different copies of the 6 catalog being held. Do you know from your dealings with 7 Nevada Power that they actually had multiple copies of these 8 catalogs? 9 A Yes, they do. They did at the time I retired, 10 yes. 11 Q And is it correct that you dealt with Nevada 12 Power during the two times that you were in the Los Angeles 13 office? 14 A Yes, the total time from 1970 to 1990. 15 Q You did not in the earlier time when you were 16 in Los Angeles? 17 A No. I was working with Southern California 18 Edison at that time. 19 Q So the time period that you can tell us about 20 your personal knowledge with is 1970 until you retired? 21 A Nevada Power is 1970 to 1990. 22 Q I think you just testified earlier that there 23 were certain engineers that had catalogs? 24 A Yes. They'd request it be sent to the 25 engineering department so all engineers could use it. 24 (714)834-1571 ^SarqofT cDepositioq^Service, MEMBER NATIONAL NETWORK REPORTING COMPANIES (213)621-2653 1 Rather than sending 100 copies to 100 engineers, it would go 2 into the engineering library and there would be a set for 3 the engineering department, a set for the purchasing 4 department. And individuals would request for products that 5 they wanted to be aware of and they'd mark them specifically 6 individuals for other types of catalogs. 7 Q Do you know whether a copy of the Westinghouse 8 catalog that went to the engineering department specifically 9 contained the instruction leaflets? 10 A I don't know that we marked instruction 11 leaflets. I can't say. 12 Q The purpose of the instruction leaflets was to 13 give them to the customers, correct? 14 A Yes. 15 Q Is that correct? 16 A That's correct. 17 Q I think you also mentioned another method of 18 distribution of instruction leaflets, and that was with the 19 equipment; is that right? 20 A Some customers required instruction leaflets to 21 be shipped with the equipment. 22 Q Do you know whether that was done with the 23 equipment -- 24 A I don't recall. Certain products may have been 25 handled differently. 25 (714)034-1571 cS a r/jp /T cDcpositiorService, MEMBER NATIONAL NETWORK REPORTING COMPANIES (213)621-2653 1 MR. BAUER: That's all I have. 2 MS. LEEN: Thank you very much. 3 MS. MAILNDER: I'm sorry, I have just a couple more 4 wrap-up questions. 5 You mentioned that you knew that Nevada Power 6 received the catalog? 7 THE WITNESS: Oh, I read the catalogs up In their 8 engineering department, and I have read the catalogs up in 9 their purchasing department, and I have seen them in 10 executive offices. I have seen catalogs. 11 MS. MAILNDER: That's all I have. Thank you. 12 (Whereupon the deposition proceedings 13 concluded at 1:30 p.m.) 14 / 15 / 16 17 18 19 20 21 22 23 24 25 26 (714)834-1571 ari\pff 'Uepositioq^Service,^Iqc (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES 1 STATE OF _____________ ) ) 2 COUNTY OF ____________ ) ss. 3 4 5 6 7 8 9 I, the undersigned, say that I have read 10 the foregoing deposition and I declare, under penalty of 11 perjury under the laws of the State of California, that the 12 foregoing is a true and correct transcript of my testimony 13 contained therein. 14 EXECUTED this ________ day of _________________ 15 199 , at _____________________________________________________ 16 17 18 19 20 21 22 23 KENNETH ROBINSON 24 25 27 (714)834-1571 ^Sarqoff 'IDepositioq^Service, Iqc. (213)621-2653 MEMBER NATIONAL NETWORK REPORTING COMPANIES The undersigned Certified Shorthand Reporter of the State of California does hereby certify: That prior to being examined, the witness in the foregoing proceedings was duly sworn to testify the truth, the whole truth and nothing but the truth. That said proceedings were taken before me at the time and place therein set forth, and were taken down by me in shorthand and thereafter transcribed into typewriting under my direction and supervision; and I hereby certify that the foregoing transcript of proceedings is a full, true and correct transcript of my shorthand notes so taken. I further certify that I am neither counsel for nor related to any party to said action, nor in anywise interested in the outcome thereof. Ir hereunto subscribed my name this t SHERI CLARK BELL CSR NO. 6368 28 K enneth R obinson , 03/18/93 '60s *14:19 '67 8:13 '68 7:5,6; 8:13 7 0 7:6 '7 0 s 14:18 *86 11:7 *87 11:7 / / 26:14,15 1 10 23:1; 24:5 100 25l,l 1100 3:14 12:55 2:18; 5:2 132165 1:26 15 23:1; 24:5 18 1:24; 2:19; 5:1 19 6:20 1949 6:9,13 1950 6:13,14; 7:12 1952 6:15; 7:12 1953 6:18; 8:2,3 1963 7:11; 8:2,8,9,13 1967 8:13 1968 6:21,23; 7:2 1970 6:22,23,25; 7:2,7; 9:23; 10:8; 11:12; 12:24; 24:14,20,21 1979 12:25; 13:4,5; 14:6,9 1985 11:7 . 1988 17:18 1989 17:18 199 27:15 I 99O 6:9,25: 7:7; 10:8; 17:18; 2^1<21 1993 1:24; 2:19; 5:1 1999 3:20 1:30 26:13 2 2100 2:17 22 4:4 3 300 3:0 5 5 4-3 6 6368 1:25; 2:20 7 700 3-8 8 8 0 2 0 2 3*0 8 8 0 4 5*18 8Q1 m *.n 89125-2070 3:0 9 90603 5:19 A absorbed 14:21 actually 24:7 address 5:17; 22:1 advise 9:8; 14:1 advised 13:23; 14:24 advising 14:1 against 5:12; 17:14 agents 11:8 agreed 19:6 agreem ent 18:2; 19-3,5,10,14,17,22; 20:3 ahead 6:19; 11:2; 16:4 A llen 10:14,18 am biguous 16:4 Ana 1:23; 2:18; 5:1 A ngeles 6:21,24,25; 7:3,7,9; 8:9,16,19; 9:1; 10:9; 24:12,16 an n o u n cin g 23:22 answ er 11:3; 12:5; 19:9; 20:1 answ ered 19:21 anyone 5:25 an y th in g 22:20 apparatus 20:24 APPEARANCES 3:1 approxim ate 6:12; 9:21 A rizona 7:6 ARMSTRONG 3:0 arrangem ents 11:13 arresters 8:7,13 A rt 10:14,18 askarel 18:15 assist 7:19; 12:8 A ssistant 3:6; 7:13,18,19,22 associated 9:5; 13:24; 14:10; 16:2; 18:10 assum e 16:23 atten d ed 14:5 atto rn ey 5:20; 20:10 A ttorneys 3:3,19; 17:10 autom atically 23:15 A venue 3:14 avoid 14:25 aw are 12:24; 14:2,3,24; 15:9,24; 17:13,16,19,22; 18:1,5,17,19,19; 25:5 B back 6:24; 7:20; 10:17; 2 0 :8 BACKUS 3:0 Bair 22:3 BAUER 3:4; 10:17,19; 16:11; 22:9,12,14; 26:1 becam e 17:19; 18:19 becom e 17:16 began 11:10 beh alf 2:16; 5:5 believe 8:4 best 20:1 B ickerstaff 22:5 bids 7:20 biphenyls 13:24 b it 7:17; 20:10 b oard 10:21 books 16:17,22,24; 17:3; 22:22; 23:3 conventions 14:4,6; 18:17 copies 24:5,7; 25:1 copy 25:7 c o rp o ra tio n 1:4,11,13,14,15; 2:2,9,2; 3:0 BRADLEY 3:5 b reak 20:4 B ridger 3:14 Broadw ay 2:17; 3:20 co rrect 10:10; 15:3; 24:11; 25:13,15,16; 27:12 co unsel 19:4,15,18 COUNTY 27:2 b ro ch u res 23:19 BROWN 3:7 b u lletin s 23:20 couple 20:7; 26:3 COURT 1:1; 2:1 CSR 1:25 C unningham 21:23 C c u rre n t 5:17; 21:25 m rrp n flv C.W 22:5 do 3:7 C alifornia 1:23; 2:18; 5:1,19; 24:17; 27:11 call 19:23 called 19:24; 20:2; 21:4; 23:21 cu sto m er 7:21; 9:8,14,19; 10:2; 14:1; 16:6; 18:18; 21:11,15,16; 23:14; 24:4 custom ers 9:4,10,17,22; 15:22; 16:1; 17:4; 20:23; ,, 21:2,3,5,8,10,20,22; 22:24; 23:25; 25:13,20 calling 10:22; 17:20 CV-S-89-555-LDG 1:8; 2:0 calls 7:21 can't 9:18; 14:18,23; 16:24; 25:11 cancer 14:15,17 cancer-causing 15:15 capacitors 8:12,20; 11:16; 12:22 D dates 16:24 day 16:25; 27:14 dealing 11:10; 20:22 dealings 11:20; 24:6 career 13:3 case 19:4,7,22,23; 24:2 catalog 22:17,19,21; 23:7,11; 24:6; 25:8; 26:6 dealt 10:13,15; 24:11 DEBORAH 3:6; 5:11 declare 27:10 defect 13:16 r catalogs 12:9,10,11; 16:19; 23:1,17; 24:8,23; 25:6; 26:7,8,10 catch 6:16 cause 15:12 causing 14:15,17 defective 13:8,9; 15:2 D efendant 3:3 D efendants 1:18; 2:0 d efense 19:3,14,17 d efin itely 16:23 D enver 3:0 certain 12:18,18,19; d ep artm en t 17:8; 24:25; 18:15; 23:22; 24:23; 25:24 25:3,4,8; 26:8,9 C ertified 2:20 cetera 23:13,14 C hartered 3:7 d ep en d in g 19:25 DEPOSITION 1:21; 2:16; 6:1,4; 22:13; 26:12; 27:10 CLARK-BELL 1:25; 2:19 d escrib e 20:20; 22:19 classified 22:20 d escrib ed 23:9 CLOSE 3:7; 19:23 clo th in g 13:20 descriptive 23:20 d etail 14:24 C olorado 3:0 d etails 15:13,18 colum ns 23:13 d eterm in e 19:22 com m encing 2:18 com m unicating 7:20 developed 16:25; 17:1 device 15:15 com m unications 10:4,7 d iffer 20:25 COMPANY 1:3,10,12; 2:4,2; 3:5; 10:4,7; 21:12,14; 22:14 C om pared 21:20,21 com pensate 18:3 com pound 16:10 com puterized 22:23 co n cern ed 22:25 co n cern in g 19:10 d ifferen t 7:1,1; 21:2,3,8; 23:9,10; 24:5 d ifferen tly 25:25 d irect 11:8,19; .13:1 d irectly 11:20 d isco u n t 22:21; 23:13 discuss 18:23 discussed 14:4,7,14; 17:22; 18:25 co n clu d ed 26:13 conduct 16:8 C onnie 10:15 co n sid ered 21:14,19 contact 12:1; 13:1; 15:2 contacts 12:2 co n tain ed 7:13; 8:17; 13:2; 25:9; 27:13 discussions 19:1,10 d istrib u tio n 8:6,11,16; 11:1,6,17,21,25; 21:1,18; 25:18 DISTRICT 1:1,2; 2:1,2; 6:23,24,25; 7:4,6,8; 8:21; 10:10; 11:12; 17:2 divided 11:23 Samofif D ep o sitio n Service, Ine. DepoMcrge Index 1 Kenneth Robinson 0 3 /1 8 / 3 division 9:7,11,16; 16:18; 24:3 divisions 10:1; 14:1 docum ents 6:3; 17:7,11 DOES 1:16; 2:0 doing 13:6 done 25:22 Drive 5:18 duly 5:6 During 10:3,6; 13:3,22; 14:20; 24:12 duties 7:18,23; 8:21,25; 20:20,25; 21:13 E earlier 15:1; 24:15,22 Early 14:18 East 3:14 Edison 24:18 ELECTRIC 1:12,14; 2:2; 3:7; 8:24; 11:7,11,15 ELLIS 3:0 Elmer 10:14,18,19 employed 6:6,8 em ploym ent 6.10; 10:3 engineer 6:15,17,18,22; 7:3,10,20,22,23; 8:15; 11:24; 20:22; 21:6,12 engineering 23:2; 24:25; 25:23,8; 26:8 engineers 24:23,25; 25:1 entered 18:2 environm ental 15:17 equipm ent 7:13,16; 8-S, 10,11,16,17; 9:6,12; 11:1,18,18,21,25; 12:6,8,11,16,19,21; 13:2; 16:19, 17:21; 21:3,17,18; 23:4; 25:19,21,23 essentially 8:25 everything 8:5 exact 14:24 exactly 9:18; 14:19; 15:13; 24:2 EXAMINATION 4:2; 5 9; 22:11 exam ined 5:6 EXECUTED 27:14 executive 10:16; 19:1; 26:10 executives 10:15 EXHIBITS 4 0 expenses 18:4 explain 7:17 F fact 21:4 factory 7:20 far 11:14; 22:25 felt 12:12 few 22:9 field 9:13,25 filed 17:13,23 finite 16:25 first 5:6; 14:16; 17:16,24 five 17:6 Floor 2:17 follows 5:7 force 8:23 foregoing 27:10,12 foreign 1:10,12,15; 2:2,10 form 9:13 Fourth 3:0 full 5:14 fu rn ish ed 16:20 fu rth er 22:7 G gained 15:8; 18:7,9 Gary 21:23 GE 5:13 GENERAL 1:11; 2:8 generation 8:8; 11:18,25; 21:17 generators 8:6,14; 12:19 gloves 15:5 going 14:4; 19:23 grade 21:2 H handle 11:15; 13:7 handled 8:17; 11:17,18,24,25; 13:19; 21:12; 25:25 hands 14:25 Harry 10:14,18 hazard 15:17 hazards 9:5; 13:23; 14:6,10,13; 16:2; 18:9,23; 24:1 h ealth 13:23 h ear 10:17 heard 22:3 h eld 6:12; 20:13,16; 24:6 helping 7:16 Hold 6:16 hom e 19:8 I 111 19:12 I-XXV 1:16; 2:0 identical 21:13 IDENTIFICATION 4:0 im portant 20:23 include 8:17 inclusive 1:16; 2:0 indem nification 18:2 individuals 25:4,6 In erteen 7:14; 8:17,18,20; 9:20; 12:21,23; 13:2,7,20; 14:21; 15:2,10,14; 16:2,14,17; 17:4; 18:10,14 inform 9:4 inform ation 12:7; 18:6,8,9 inform ed 9:16; 14:21; 15:17,19,21; 23:25 instruct 19:9 instruction 16:9,17,22; 17:3; 22:22,22; 23:3,3,17; 25:9,10,12,18,20 interest 12:13 interested 12:13 involved 7:13,15; 8:2; 17:21; 20:23 involved, 7:15 irritation 15:12 issued 23:16 issues 19:25 J Jeffrey 22:3 JOB 1:26 Johnson 10:14,18,19 JONES 3:7 JOSEPH 3 0 journals 14:3,10,14; 18:17 K KENNETH 1:21; 2:16; 4:3; 5:4,16; 27:0 Kinslow 20:11 KIRKLAND 3 0 knowledge 15:7; 24:20 L large 21:10,14,16,19,21 Las 3:3 late 14:18 Law 3:3,19 laws 27:11 lawsuit 5:12; 17:14,17,22 leaflets 22:22; 23:17; 25:9,11,12,18,20 leaking 13:14 LEEN 3:5; 10:18,20; 11:2,4; 16:4,10; 18:11; 19:8,9,21; 26:2 Legal 3:17 letter 9:13; 23:21 letters 9:19; 12:12; 13:25; 14:2; 15:21,24; 23:22,24 library 25:2 lightning 8:7,12 line 20:25 list 22:23; 23:12,18 lists 22:21; 23:10 literature 22:20 litigation 18:4,4; 22:15 little 7:17; 20:10 living 22:1 long 17:1 looked 13:9 Los 6:21,24,25; 7:3,7,9; 8:9,16,19; 9:1; 10:9; 24:12,16 lot 21:21 LRL 1:8; 2:0 lunch 6:2 M ma'am 6:7; 12:22; 13:18,21; 15:6; 16:15; 17:5,15; 19:16 MAILANDER 3:6,4; 5:10,11; 10:24; 11:9; 16:7,13; 18:13,21; 19:13; 20:4,6; 22:7; 26:3,11 m ailing 12.9; 22:23; 23:10 major 20:23 m anagem ent 7:1; 12:1 m anager 6:23,24,25; 7:4,7,8; 8:21; 10:10; 11:12; 17:3 m anufacturing 9:25 March 1:24; 2:19; 5:1 m ark 22:23; 23:3,14; 25:5 m arked 25:10 MAUPIN 3 0 may 13:11,19; 14:14; 19:24,24; 22:25; 25:24 maybe 21:11 m ean 18:11,13; 19:5 m echanism 23:25 m entioned 15:1; 22:13,16; 24:5; 25:17; 26:5 MERRELL 3 5 m eters 8:7,12 m ethod 25:17 mid-1970s 9 24 MONSANTO 1:10: 2:3; 5:12; 18:2,3; 22:14 m o rn in g 22:17 m ostly 10:15; 17:21; 19:1 m ultiple 24:7 N N-i-n-d-a-n-t-e 5:18 nam e 5:11,14; 16:24; 17:24; 22:13; 23:14 nam es 10:12,17 n atu re 16:6 needed 9:16 NEVADA 1:2,3,4; 2:2,4,3; 3:5; 10:4,7,13,22; 11:1,6,11,21; 12:3,16,21; 16:9,17; 17:13,20; 18:7,9,24; 21:14,19; 22:25; 23:5,6; 24:7,11,21; 26:5 new 12:11; 23:4,22 new spaper 18:16 N indante 5:18 None 4:6 North 2:17 n o th in g 11:5 notification 9:7,25; 24:3 notify 9:13; 10:1; 15:22 notifying 9:9,22 n u clear 8:6,13 O Objection 11:2; 16:4,10; 18:11; 19:19; 20:2 office 6:22,22; 7:3,7; 8:9; 24:4,4,13 offices 26:10 Oh 14:12; 15:21; 17:18; 19:12; 26:7 Okay 6:16,19; 19:20 one 6:12; 9:18 oral 1917 Oregon 6:14,20; 8:5; 13:5 O sborne 11:6,11,15 ourselves 11:8 overbroad 11:2; 18:11 P p.m 5:2; 26:13 p.m. 2:18 Pace 17:19 Pace's 17:24 PAGE 4:2 pam phlets 16:16 Sarnoff D eposition Service, Inc. Depo Merge Index 2 K enneth Robinson --- :----------------- Srdon 20:15 part 16:18,19; 17:2; 23:18 p articu lar 9:9 p arts 23:11 passed 9:17 PCS 18:4 PCBs 9:17; 14:7,11,17; |15:12,17,20; 17:7,11; 18:23 P earson 10:14,18 PEGGY 3:5 pen alty 27:10 people 10:12; 23:6,10 jper 19:22 p erio d 6:10; 10:6; 17:1; periodically 17:3 p erju ry 27:11 perso n al 24:20 perso n ally 12:3 p erso n n el 16:9,17; 18:24 P hoenix 6:22; 7:4,6; 8:22; 9:1 p h o n e 7:21 physical 13:1; 15:2 place 11:13 P lain tiff 1:6; 2:2; 3:4; 5:5 p lan ts 8:6,14 play 20:10 please 5:15 p o in t 14:2 p o ly ch lo rin ated 13:24 P o rtlan d 6:14,20; 8:4,5,15,18,19; 13:5 p o sitio n 6:11; 12:15; 20:13,16 p ositions 6:11; 7:1 possible 15:14 possibly 14:18 p o te n tia l'9:5; 13:23; 14:6,10; 15:10,23; 16:1; 18:9,23; 24:1 POWER 1:3; 2:4; 5:12; 10:4,7,13,22; 11:1,6,11,21; 12:3,16,21; 16:9,17; 17:13,20; 18:7,9,24; 21:14,19; 22:25; 23:5,6; 24:7,12,21; 26:5 p rep aratio n 5:25; 6:3 p rep arin g 7:21 p resid en t 19:1 fresid en ts 10:15,16,22; 3:2 p rice 22:21; 23:13 P rio r 12:25; 13:4,5; 14:6,9 Probably 9:23; 12:22; 13:10; 24:3 iroblem 9:12,12; 15:10; 5:25; 18:20 ?roblem s 10:1; 15:23; 8:14 p ro ced u re 9:9; 23:9 proceedings 26:12 p ro d u ced 5:5 p ro d u ct 8:24; 11:6; 12:13; 23:15,19 pro d u cts 7:1,24; 8:1; 20:23; 23:12,22; 25:4,24 program 6:14 p ro m in en t 18:19 p rotective 13:20 provide 12:4,7; 16:8,16 provided 12:9; 17:4 p u rch ase 12:16,21 p u rch ased 15:23 gurchaping 12:8,23; 23:1; purpose 25:12 p u rsu an t 2:20 Pyrenol 18:15 Q q u estio n 19:21 q u estio n s 20:7; 22:8; q uick 20:4 quo tatio n s 7:21 R R ather 25:1 reach ed 19:3,5 read 14:1,9,16; 26:7,8; 27:9 reading 14:3 recall 8:19; 9:18,21,23; 10:12; 12:20; 13:13,15,16; 14:5,9,13,16; 15:25; 16:3,5; 17:6,9,10; 22:17; 23:21; 24:2; 25:24 received 9:7; 23:6; 26:6 receiving 16:1 Recess 20:5 recognized 9:11 recom m end 12:16 reco rd 5:14; 20:8 reg ard in g 9:17; 14:10; l6Tl; 18:879 regards 9:19; 11:1 rela ted 17:11; 18:4 relatin g 17:7; 18:6 rem em b er 9:24; 14:8,18,19; 15:13,18,19 renew ed 23:16 R eporter 2:20 re p re se n t 5:11; 22:14 rep resen tativ e 17:20; 20:18,21; 21:7,11 re p resen ted 5:20 req u est 16:5; 24:24; 25:4 req u ests 16:1 req u ire d 13:7; 25:20 re q u ire s 18:3 resid en tial 5:17; 21:25 resp o n sib ilities 17:2; 21:13 resjK m sibility 8:23; 9:4; re tire d 24:9,20 re tirin g 17:19 review 17:3 review ed 6:3; 17:11 R ichard 17:25 rig h t 10:11; 21:9; 22:7; 2509 R obert 20:11 ROBINSON 1:21: 2:16; 4:3; 5:4,16; 19:24^; 22:9; 27:0 Ryan 10:15 S safe 15:7 03/18/93 Sale 7:24; 8:19,24; 20:24 sales 6:14,15,17,18,22; 7:3,9,12,18,19,19,22,23; 8:15,23; 11:8,24; 17:20; 20:18,21,22; 21:6,6,11,12; 23:21,22,24 salesm an 20:25; 21:1,5 salesm en 7:16 Santa 1:23; 2:18; 5:1 sch ed u les 22:21 SCOTT 3:22 se 19:22 sections 22:21 seen 26:9,10 seldom 11:23 sell 7:16; 12:6 sellin g 8:2,5,10 sem inars 16:8 sen d 9:14; 12:12; 22:23 sen d in g 25:1 sen io r 20:22 sen t 12:10,11; 17:7; 23:16; 24:24 serio u s 15:12 service 12:3,6 set 25:2,3 sets 23:1 seven 17:6 several 22:16 sh eet 23:15 sh eets 23:13 SHERI 1:25; 2:19 sh ip p ed 25:21 S horthand 2:20 side 13:11,12 Sir 10:6 size 21:2 sk in 14:22; 15:12 sm all 21:19,21 sm aller 21:12 sold 9:6; 11:5 som ething 13:11; 23:21 so rry 6:17; 26:3 so u rces 18:12,13 S outh 3:0 S o u th ern 24:17 special 20:18,21; 21:4,5,6,11 S p ecific 12:7,16,21 Specifically 14:13; 16:21; spoken 5:25 SS 27:0 start 7:9; 18:7 started 9:22; 10:22 State 5:14; 27:1,11 STATES 1:1; 2:1; 18:18 S treet 3:0 stu d en t 6:13 su b ject 16:12 Subpena 2:20 suggest 12:15 suggested 12:18,20 Suite 3:8 Supervising 8:23 su sp ected 14:15,17 sw orn 5:6 system 12:10 T T&D 8:7; 17:21 ta k en 2:16; 20:5 tak in g 7:21 talk ed 19:6 te ll 6:11; 14:23; 16:24; 24:19 term s 23:10 te ste d 13:10 te stifie d 5:6; 24:22 te stify 19:4,6,11,12,18 testify in g 19:19 testim o n y 22:16; 27:12 T hank 22:8; 26:2,11 T20h:a1;t'S251:106:1;12; 61:13,:1112; 19:20; th e re in 27:13 th e y 'd 9:12; 24:24; 25:5 th in g 21:7 th in g s 23:23 t1h7i:2n1k; 13:8,19; 24:2,22; 15:14; 25:17 T h ird 2:17 THORNDAL 3:0 T hursday 1:24; 2:19; 5:1 tim e 9:3; 10:6,22: 11:13,14; 13:3,19,22; 14:20; 15:5; 17:1,18,20,22; 18:22; 19:11,25; 20:1;'22:8; 24:9,14,15,18,19 ' tim es 18:16; 226; 24:12 today 5:21; 19:18 to ld 15:12 to o k 11:7,12 to p 12:1 to tal 24:14 to u ch ed 13:10 trad e 14:3,10,14; 18:15,16 tran sactio n 10:25 tra n sc rip t 27:12 tra n sfe rre d 6:21,24 transform er 13:9,10,10,13,17; 15:2 transform ers 8:7,12,18,20; 11:15; 12:18,23,24; 15:23 T ransm ission 8:11; 11:18,21,24 tran sm itted 9:19 tria l 19:7,11,23,25 tru e 27:12 try in g 12:5 tu rb in e 8:6,14 tw o 24:12 type 8:1,10; 9:12; 12:3,21; 13:6,16,20; 14:13; 21:3 types 25:6 typical 10:25; 11:5 U u h -h u h 23:18 u n d erg rad u ate 6:13 u n d ersig n ed 27:9 UNITED 1:1; 2:1; 18:18 u p d ated 12:10 u se 9:20; 24:25 u su ally 9:13; 12:11 u tilitie s 7:25; 8:24; 20:24 V vague 16:11 Van 5:16 Sam off D eposition Service, Inc. DepoMerge Index 3 K enneth R obinson Vegas 3:3 vice 10:16; 19:1; 23:2 V S 1:8; 2:0 W w ant 11:3 w anted 23:15,15; 25:5 w arnings 9:16 w att-h o u r 8:7,12 w e'd 9:13; 23:3 w ear 13:20; 15:5 w ell-know n 18:15 w ent 6:14; 13:9; 25:8 WESTINGHOUSE 1:13; 2:9; 3:5; 6:8,11; 7:24; 8:1,24; 9:4,15; 10:3; 12:8,17; 13:1,22; 14:20; 15:11,16,25; 17:8,14; 18:1,3,12,23; 20:14,17,24; 23:7,25; 25:7 W hereupon 26:12 w h eth er 12:20; 13:13; 14:5,9; 16:21; 17:6,10,23; 18:1,6; 21:19; 23:24; 25:7,22 W hittier 5:19 Why 20:4 Will 19:9,22 WITNESS 4:2- 5:5; 10:21; 11:3,5; 16:5,12; 18:14; 19:12,24; 20:2; 26:7 w ork 13:6; 21:7; 23:5 w orked 13:22; 14:20; 15:11,16,25 w orking 9:3; 12:25; 18:22; 20:18; 24:17 w orkplace 17:7,11 w rap-up 26:4 w ritten 19:14 Y Tear 6:17,21; 9:22; 11:10; 4:16 years 6:8,12; 9:23; 17:6 you've 6:12 Sam off D eposition Service, Inc. DepoMtrge Index 4