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Sample Deposition Transcript

Sample Deposition Transcript

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SAMPLE Deposition Transcript. For study purposes only. Perform your due diligence and adjust to fit your unique situation.
SAMPLE Deposition Transcript. For study purposes only. Perform your due diligence and adjust to fit your unique situation.

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Published by: Tauheedah S. Najee-Ullah El on Feb 07, 2012
Copyright:Attribution Non-commercial

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08/07/2013

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SAMPTE
DEPOSITION
TRANSCRIPT
EXCERPT
page
18Theolherwork
with
Homecraft
had
norhing
to
do
with
this
project,
no.
Haveyou
had
any
other
contaqt
with
Peabody
Engineers?
No.
Did
Montgomery
EngineerinE
ever
serveas
district
engineer
for
Imerald
Forestl
Wedo
now, and
we
did.
When
didyou
start?
We
started
in-our
contract
is
signedbythe
district
in
either
July
or
August
of
'75.
Have
you
served
in
that
capacityon
a
continuous
basis?Yes-
I
know
this
is
rather
an
open-endd
question,but
could
youdescribe
forme
briefly
what
a
district
engineer
would
do?
On
any
project?Yes,sir-
Just
generally.
Okay.
He
generally
represents
all
of
the
engineering
needs
of
the
district
which
could
be
design
in
nature;
it
could
be
construction.
Typically
it
is
design
and
construction.
But
a
lot
ofdistrio
engineers'activitiescould
be
best
described
as
consulting,having
to
do
with
/PaEe
19
numerousdifferent
things
of
a
technicalnature
that
a
dislrict requires
be
done-
We
anend
all
of
lhe
districtboard
meetings.
We
are
available
lo
recommend
and
commenl
on
variousreguestsmadeof
the
board,
such
as
connectionsto
their
waler,
sewerage
and
drainagesystems.
I
think
youknow
that
the
district
is
only
empowered by
law
to
be
concernedwith water,
sanitary
anddrainageactivities, and thereforethat'sall
lhat's
the
scope
of my
service
for
them
alsi.
Do
you
have
an
annualcontracl
with
the
districtiNo.
I
have
an
ongoing
base
contracl
lhatrequires
that
specific
services
be authorized
as
they
come
up.
And
sotheyare
normallyauthorized
84
 
15
in
the
minutes
of
the
board meeting.
16a
Are
you
compensated on
a
project
basisl
17 A
We
are-our
contract
calls
for compensation
to
lB
us
on
an
hourly
basis, and
we have
a
fee
19
schedulethat isrevised once
a
year,
by
the
way,
20
which
mayanswer
your
question.
21a
When
didyoustart attending
the
meetings
of
the
22
Emerald
Forest
Utility
District?
23A
I
believe
June
of
'76
wasthe
first
meeting
we
24
went
lo.
25a
Would
youhavebeen
the
personin Montgomery
page
20
I
tngineering
to attend
those meetings?
2 A
Yes.
3Q
As
far
as
you
know,
have
youanendedthe
4
majority
of
the
meetingsi
5 A
Yes.
6Q
ls
thereanybody else
at
Montgomery who
would
7
have
taken
a
share
ofthe
anending
ofthose
B
meetings
in
your
place?
.9 A
Yes.
Gilbert
Flores
attended
a
number
of
the
10
meetings.
Agentleman
by
the name
ol
)erry
1l
Paquette,
P-a-q-u-st-t-e,attended
some
of the
12
meetings.
'I
3a
Where
is
Mr.
Paquettetoday?
14A
Paquette
is
also
in
business
for
himself.
15a
ls
that
here
in
Houston?
16A
lt's
here
inHouston.
17
MR
BUSSELL:
You
are
running
an
.18
apprenticeship
19
THEWITNESS: Righr- Kind
of
a
20
small
Turner,
Collie
&
Braden.
21A
His
involvement wasfar
less
than
Flores'and
22
mine.
23a
(By
Mr.
Sheehy)
Mr.
Montgomery, do
you
have
an
24
opinion
as
lo
whether
there
wereanyproblems
25
with
aline
which
was
initially
constructed
which
page
21
.l
is
the
basis
of
this
lawsuit?
2 A
Yes-
3Q
Before
wego
into
thespecificproblems
with
the
4
line,
would
you
tell
me
what
you
baie
your
8s
 
a
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aa
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7
I
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10
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121314
r5
16171819
20
21
22
232425
opinion
on?
My
opinion
isbased
onan
observationofthe
facts
of
the
physical
observationof thelineitself through the
videotapes,
reviewofthefiles; correspondence;discussions
with
otherprofessionals,contrdctors.
And
I
believethat'sthe
scope
ofthe
peopleand
thesources
that
I
would
have
talkedto
or
reviewed.I
was
notretained
specifically
to
'
reviewand
critiquethisparticularproject.
But
therewasno
wayin the
course ofbecominginvolved
with
the
district
and designing
a
replacement
line
and
becoming
the
newengineerfor thedistrict,that
I
could
not
help butdevelop
an
opinion aboutwhat
happened.
Did
youmake any
other
observalionsof the
line?
Other than throughthe videotape?No.
Did
youever
see
theline when
itwas
uncoveredl
No.When
you
indicatedthat
you
reviewedfiles,
would
rhosebe
the files
which
you
have
withyou
today?
86

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