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FrameworkDocument
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1990-07-23
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22KB
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298 lines
NOTE:
This is an
edited
excerpt from an ASCII deposition that was created
for the sole purpose of testing Scan & Clip Version 1.00 ]]]
This excerpt begins with line 6 on page 32 of the original deposition; ASCII
new-page code 012 has been left in this excerpt, but program can be set to
delete them from report, see documentation.
NOTE: Because of the editing to this deposition and page parameter settings, the
references to hard copy page numbers found in the created report of this test
will NOT corresspond to the shown pages. But for editing and with page
parameters set correctly for a document, the page references should be correct.
****************
6 disease or that you thought died of virus related
7 disease?
8 A. I don't have no idea. I don't know no -- I
9 don't know.
10 Q. Outside your organization, you don't know of any?
11 A. No.
12 Q. Other than these two screenings that are
13 described in the Deponet Exhibit 1 and Deponet Exhibit 2,
14 are you aware of any other screening programs that your
15 members have been invited to?
16 A. No.
17 Q. Whether they were sponsored by the Skilled
18 Worker's Council or anybody else?
19 A. No.
20 Q. That's the only one you know about?
21 A. That's it.
22 Q. Have there been any other general mailings to
23 the membership that you've received as a member from
24 other organizations suggesting screening or somebody
25 might pay for a screening, anything like that?
32
1 A. No, sir.
2 Q. Never received anything like that in the
3 mail --
4 A. Huh-uh.
5 Q. -- from some third-party or --
6 A. Huh-uh.
7 Q. How about the Home Office, does the
8 Home Office have any other program other than the one
9 that they've sent anything on?
10 A. No.
11 Q. Let me show you what's been marked Close
12 Exhibit 7 at an earlier deposition today. I'm going to
13 ask you to read this paragraph, beginning right there
14 (indicating). If you're like me, you're going to need
15 your glasses, because it's pretty small.
16 A. Where are you talking about?
17 MR. LAWYER#2: (Indicating)
18 BY MR. LAWYER#3:
19 Q. Right there (indicating).
20 A. (Complying) Okay. What about it?
21 Q. Yeah. See that sentence that says, "'There is
22 more disease and more serious disease here in the Big
23 Tri-State than just about any other place in the country,'
24 he says," referring to Mr. Lawyer #6. You see that?
25 A. Yes, sir.
33
1 Q. Okay. Do you agree or disagree with that
2 statement?
3 A. I don't know. Wherever their heavily
4 industrialized just like this area in the country, there
5 would probably be about the same amount, in my opinion,
6 you know, different parts of the country.
7 Q. Well, say, how about Southeast Kansas compared
8 to the northern end of your district, where you go up in
9 Oklahoma or up in the northern end, would it be more
10 incidence of virus related disease down here than up
11 there?
12 MR. LAWYER #4: Objection. Foundation.
13 A. I figure --
14 MR. LAWYER#2: Don't speculate, Deponet. If
15 you know the answer --
16 A. I don't know the answer to that. I don't know
17 whether it would be or not. You know, I don't know.
18 BY MR. LAWYER#3:
19 Q. Have you ever attended any meetings of the
20 Home Office, of your organization?
21 A. Certainly.
22 Q. Has virus related disease ever been
23 discussed at any of those meetings?
24 A. No, sir.
25 Q. Have you ever attended any meeting where the
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1 incidence of the disease geographically was discussed?
2 A. No, sir.
3 MR. LAWYER#3: I pass the witness.
4 EXAMINATION BY MR. LAWYER#1:
5 Q. Mr. Deponet, my name is Joe Lawyer#1. I
6 represent another defendant in this lawsuit. I'd like to
7 ask you a few questions, sir.
8 In Deponet Exhibit No. 2 --
9 MR. LAWYER#3: Deponet.
10 BY MR. LAWYER#1:
11 Q. Excuse me, Deponet Exhibit No. 2, it talked
12 about an x-ray examination that was done on June 13th of
13 '73 --
14 A. Yes, sir.
15 Q. -- for the exposure of virusis?
16 A. Yes, sir.
17 Q. And the next sentence says "From these X rays,
18 74 percent were found to be positive."
19 Can you give us any idea of either how many
20 people took the X rays or what that 74 percent -- how
21 many people that was that were found to be positive?
22 A. Like I said, I didn't count the people --
23 Q. Sure. I understand.
24 A. -- that was x-rayed. I don't know how many was
25 x-rayed, and I'm figuring 50 to 75 was at that meeting.
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1 Q. Okay.
2 A. There might have been a few more. I don't
3 know.
4 Q. All right. Am I correct you did not have an
5 X ray done at that time?
6 A. Not at that time I did not.
7 Q. All right, sir. Now, do you know -- in
8 reference to Deponet Exhibit No. 1, it talks about a
9 physician, the X rays being interpreted by a competent
10 physician. Do you know if the X rays were interpreted by
11 a physician; and if so, who was that physician?
12 A. There was no physician at the X ray, the
13 screening. I presume they were sent somewheres and
14 screened.
15 Q. All right. All right. Do you know the name of
16 the x-ray service that did this?
17 A. No, sir, I don't remember.
18 Q. Was there any -- was it in a mobile trailer?
19 A. Yeah, it was in a -- no. It was done -- it was
20 done in our hall. They come there and they brought the
21 equipment and it was portable.
22 Q. Was there any name on their uniform or any
23 identification of who these people were that were taking
24 the X rays?
25 A. I'm sure there was, but I don't remember who
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1 they was.
2 Q. Okay. Would your organization have any record of
3 that?
4 A. No, sir.
5 Q. Okay. In response to -- because of the fact
6 that 44 percent of the people who had X rays taken on
7 June 13th were found to be positive, a second letter was
8 sent out by you on June the 27th saying that there would
9 be another x-ray examination on July the 15th.
10 A. Yes, sir.
11 Q. All right. About how many people took that
12 examination?
13 A. I don't remember how many was there,
14 probably -- maybe 60 at that second one. I don't know.
15 We was there a pretty good while that day. I know that.
16 Q. All right. Were you one of those people?
17 A. Yes, sir. I was screened at the second one.
18 Q. Okay. Tell me how this screening took place.
19 Did they just have you come in and give a chest X ray, or
20 how was it done?
21 A. They give a chest X ray.
22 Q. All right. Did they take more than one X ray?
23 A. Yes, sir.
24 Q. How many X rays did they take?
25 A. Four.
37
1 Q. All right. Did you subsequently receive either
2 a letter or a post card or something, communication, in
3 the mail stating the results of your X ray?
4 A. I might have, but I don't have a copy of it.
5 If it was, it was sent to the house, you know, to my
6 house. It wasn't sent to the local.
7 Q. All right. Okay. What were the results of
8 your report? Were you positive or negative?
9 MR. LAWYER #4: Objection. This is clearly
10 outside the scope of this deposition.
11 MR. LAWYER#2: Yeah, it is. And I'm going to
12 instruct him not to answer that.
13 BY MR. LAWYER#1:
14 Q. Okay. Well, you mentioned earlier,
15 Mr. Deponet, that you believe you had virusis; is that
16 correct, sir?
17 A. Yes, sir.
18 Q. Was it as a result of that screening?
19 A. Yes, sir.
20 Q. All right. Do you know how many people
21 apparently were checked as positive as a result of the
22 second screening?
23 A. No, sir, I don't.
24 Q. Did you discuss that at the organization hall or
25 discuss it with some of the people that were there?
38
1 A. No, sir.
2 Q. You never did?
3 A. No.
4 Q. You didn't have any curiosity as to how many
5 people were positive?
6 A. I -- I still --
7 MR. LAWYER#2: Go ahead.
8 A. I don't know how many people's positive, you
9 know.
10 BY MR. LAWYER#1:
11 Q. Well, you didn't ask at the organization hall as to
12 MR. LAWYER #4: Objection. Argumentative.
13 BY MR. LAWYER#1:
14 Q. I mean if you didn't, just tell me.
15 A. I didn't, you know.
16 Q. Okay. Did your organization receive anything at all
17 to indicate the number of positive results of the second
18 screening?
19 A. No, sir.
20 Q. Did your org. conduct any other screening; or
21 since June of '75, has your organization ever had any other
22 screening --
23 A. No, sir.
24 Q. -- for virus related?
25 A. No, sir.
39
1 Q. Do you know of any other organization that you
2 belong to or that -- or the River Skilled Worker's
3 Council or anything else that has had any other screening
4 for virus related diseases?
5 A. I've heard -- heard that some has had
6 screenings, but I don't know it for sure because I didn't
7 go to them. I don't know whether they did or not.
8 Q. Who have you heard had screenings?
9 A. I've heard that the other org., I believe, has
10 had one.
11 Q. Anybody else?
12 A. No.
13 Q. After you received the notification, I take it
14 that you received notification that your X ray was
15 positive?
16 A. Yes.
17 Q. After you received that notification, did
18 you -- what did you do?
19 MR. LAWYER #4: Outside of scope.
20 MR. LAWYER#1: Well, I think it is. I
21 want to know what he, as representative, did.
22 MR. LAWYER#2: That's not relevant.
23 MR. LAWYER #7: Well, phrase the question that
24 way, then.
25 MR. LAWYER#1: Okay. All right.
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1 BY MR. LAWYER#1:
2 Q. Well, do you know what the other members of
3 your organization who received positive results, do you know
4 what they did?
5 A. No.
6 Q. Did they hire Mr. Lawyer #6?
7 A. I don't know. Probably some of them did. I
8 don't know if they did or not.
9 Q. Did you hire Mr. Lawyer #6?
10 A. Yes, sir, I hired Mr. Lawyer #6.
11 Q. But do you know how many other members hired
12 Mr. Lawyer #6?
13 A. No, sir, I don't know.
14 Q. Do you know how many members hired other
15 lawyers?
16 A. No, sir, I don't.
17 Q. And you don't have any idea of what percentage
18 checked out positive in the second screening --
19 A. No, sir.
20 Q. -- or how many members?
21 A. No.
22 Q. And the organization has no record of that?
23 A. No, sir.
24 Q. Curiosity, is there any difference between -- I
25 notice you signed the letter of May the 1st, '88, as
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1 business agent. You signed of letter of June 7th, '75,
2 as business manager. Is there any difference between the
3 business agent and business manager?
4 A. No, sir. It's the same thing. It means the
5 same thing.
6 MR. LAWYER#1: I think that's all I have.
7 EXAMINATION BY MR. LAWYER #5:
8 Q. Mr. Deponet, my name is Joe Lawyer #5; and I
9 represent A Company.
10 Can you tell me if, during the time you've been
11 a member of the org., whether that local has ever had
12 any meetings where the Kansas judicial system or jury
13 service in courts was discussed?
14 A. What -- my local?
15 Q. Yes, sir.
16 A. No.
17 Q. Do you know if any of the organizations here in the
18 Big Tri-State Area have had any such meetings?
19 A. Not to my knowledge.
20 MR. LAWYER #5: Thank you.
21 MR. LAWYER#2: Reserve our questions.
22 MR. LAWYER #4: Likewise.
23 (THE DEPOSITION WAS CONCLUDED.)
24
25
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*************
[[ End of edited excerpt ]]
SCLTEST
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