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Lisa Martin Day 1 Deposition

Lisa Martin Day 1 Deposition

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Published by Sharon Anderson
Lisa Martin Deposition 1 of 4
Lisa Martin Deposition 1 of 4

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Published by: Sharon Anderson on Dec 30, 2008
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06/14/2009

 
LISA
MARTIN
IN
D
EX
vs.
OF
3
DEPOSITIONOF
LISA
MARTIN.
takon
byand
on
bohalf
of
Plaintiffs,
at
7701
FrancoAvo,
So..
Edina.
Minnesota
onWednosday.January
BY
MR.
S H O ~ M A K E R :
~
Good
morning,
Ms,
Martin.
Would
you
state
your
full
and
legal
name
forthe
record?
A
Lisa
Marie
Martin.
MR.SHOEMAKER:
For
the
record,
I'm
going
tointroduce
ny
clients
that
are
here.
Kelly
Brisson
is
here
forthe
first
case,
Steinhauser,
etaI,
Mr.
Frank
Steinhauser,
and
also
Steve
Johnson.
MI.
Engel?
MR.
ENGEL:
Matt
Engel,
attorney
for
plaintiffs
in
the
third
lawsuit,
theGallagher
case.
Here
with
me
today
are
my
legal
assistant,
Tanya
Hoven,
Joseph
Collins,
Tom
Gallagher
and
SaraKubitschek.
MS.SEEBA:
Louise
Seeba
on
behalf
EXAMINATION
17,2007
commonclngat
9:30
a.m
..
beforo
Bronda
K.
Foss.
Notary
Public.
State
ofMlnnosota,
County
of
Hennepin.
4
APPEARANCES
Matthew
A.
Engel.Esquire
John
R.
Shoemaker,
EsqUire
7701
Franco
Avo.
So..
Suite
200
Edina.MN
55435
Appoarod'or
Plaintiffs
( ~ I H E R E U P O N ,
the
followingproceedings
iieredulyhad--)
*
Loulso
ToscanoSeeba,
Esqulro
City
of
St.
Paul
Offlcoof
tho
City
Attorney
750
City
Hall
&
Courthouse
15
W.
Kellogg
Blvd.
St.
Paul.MN
55102
Appoared'or
DefendantsAlsopresent:Frank
Stolnhausor.
Tom
Gallaghor,
Steve
Johnson.
JooCollins,
Sara
KUbltschok,TanyaHoven.Stovo
Magnor.
Kolly
Brisson.Troy
Allison.
Dick
L1pport
LISA
M . ~ R T I N ,
having
been
previously
dUly
sworn,
d e ~ o s e s
and
says
as
follows:
16
13
4
12
2
3
17
56789
10
11
14
18
1915
25
20
21
22
23
24
1
2
3
4567
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
1
2
Civil
No.
04-2632
JNE/SRN
s.
DEPOSITION
Thomas
J.
Gallagher.
ot
al.
Plaintiffs,
Takonon
January
17.
2007
Scheduledfor
9:30
a.m.
Appearances.
....•..••••••.
3
Sandra
Harrllal,
otal.
Plaintiffs
City
ot
St.
Paul,
etai,Dofondants.Examination:
By:
Mr.
Shoemaker
•••••
4
BRENDA
K.FOSSJENNIFER
RVANCOURT
REPORTERS
2433
IRVING
AVE,SO.MINNEAPOLIS.MINNESOTA
55405
(612)
377-6339
Stovo
Magnor.ot
ai,
Dofondants.
Steve
Magner,
et
al.
Defendants.
ObJections:
By:Ms.
Sooba
•.••.••
13.44.48,
50.51.
59.
60.
63.66.67.68.103.
108.
112.
116.118.119.120.136.143.145.146.157.
163,
184,186.187,
188.220.223.230.232.233.234,245.262,275,276.278.300.309,343.346.358,368,380.385.386.401.422,
426.439
Frank
J.
Steinhauser,
III.
ot
01.
Plaintiffs,
(Original
DoposltlonTranscriptIn
tho
possosslon
of
John
Shoomakor.
Esq.)
Caption
••••..•...•••.•••.•
Index
.•.••••....••..••
'"
2
UNITED
STATES
DISTRICT
COURT
DISTRICT
OF
MINNESOTA
Repor'or's
Certlflcafo
...••.....
450
vs.
MartinDeposition
Exhibits:
1
Doscrlptlon
ofWork
64
2
Rules
and
Procedures
202
3
Handwritten
notes
283
4
ProbableCauso
Shoet
311
5
Affidavit
of
Lachaka
Cousotte
322
6
Notos
of
12/1
0/02
hoarlng
381
7
2/5/04
CSP
note
402
8
CorroctlonNotlco
409
23
~
;:...
\,
678
9
10
11
12
13
14
1516
17
1819
20
21
22
23
24
25
r
".F""
j,
1,',23456789
10
11
1213141516
17
18
19
20
r-
"
"\
,',
: : : ~
2425
EXHIBIT 21
Case 0:05-cv-01348-JNE-SRN Document 212-16 Filed 08/20/2008 Page 1 of 25
 
7
1
2
~ Q
of
all
defendants
in
all
threecases.
Here
with
1
Q
Didyou
go
to
grade
school
in
South
St.
Paul?
me
today
is
deponent
Lisa
Martin,
Mr.
Dick
2A
Yes,
I
did.
Lippert,
and
Hr.
Steve
Magner.
3
Q
ilhatschool
was
that?
(Continuing
by
11r.
Shoemaker)
Ms.
Hartin,
you
I
ve
4A
Roosevelt.
::>
been
at
a
number
ofthe
depositions
takenhere
5
Q
Following
your
grade
school,
did
you
go
to
high
6
in
:he
last
month
ormonth-and-a-month.
6
school
iL
the
South
St.
Paul
area
as
well?
7
Correct?
7A
It
was
a
junior
high.
8A
Yes.
8
Q
And
then
a
senior
high?
9
Q
lihich
depositions
do
you
rememDer
being
at?
9A
Correct.
10
A
Officer
Dean
Koehnen,
Andy
Dawkins.
10
Q
Whatwas
the
name
of
the
senior
high?
11
Q
HoI\'
much
of
the
deposition
of
Mr.
Koehnen
were
11
A
South
St.
Paul
High
School.
12
you
present
for?
12
Q
Didyou
graduate
from
there?
13
A
I
believe
I
was
there
for
the
entire
deposition.
13
A
Yes,
I
did.
14
Q
H O ~ I
aboutfor
Mr.
Dawkins,
how
much
of
the
t ~ I O
14
Q
ilhere
did
you
live
in
South
St.
Paul
when
you
15
days
of
Mr.
Jawkins'
deposition
were
you
15
were
a
child?
16
present?16
A
I
grew
upon
4th
Avenue.
17
A
I
believe
half
of
the
first
dayand
half
of
the17
Q
ilhat
'das
:he
address
there?
18
sec:md
day.
18
A
114.
19
Q
Just
a
coupleof
introductory
instructions
here19
Q
4th
Avenue?
20
frc;c,
the
standpoint
of
helpingthe
court
20
A
South.
21
reporter
and
also
the
attorneys
with
the
21
Q
How
long
did
you
live
in
that?
22
transcript
and
your
review
ofthe
transcript
if
22
A
I
was
born
in
that
home
and
stayedthere
until
I
23
you
should
decideto
co
so.
I'm
going
to
try
23
became
married.
24
today
to
not
interrupt
your
answer.
If
you
can
24
Q
H O ~ I
long
a
period
~ I a s
that
that
you
lived
in
~
__
_o
_ t h _ e _ s _ a _ m e _ t o _ ~ l a _ i _ t
_fo_r_m_e_t_o_!_"u_ll_y_a_s_k_a
--I1-2_5
t_ha_t_r_e_s1_'
_en_c_e'_'
_
6
8
I
was
there
18
years.
Is
that
particular
structure
still
there
today?
Yes,
it
is.
Who
owns
thatstructure?
I
have
no
idea.
What
are
your
parentis
names?
Hedwig
Schlemmer.
How
doyou
spell
that?
H-E-D-Iv-
I
-G.
The
last
name?
S-C-H-L-E-M-M-E-R.
Are
your
parents
still
alive?
My
fatheris
deceased.
Where
doesyourmother
live?
In
Mendota
Heights.
What's
theaddress
there?
I
don't
know
the
actual
address.
Do
you
know
whereabouts
the
horne
is?
Off
of
110
and
Dodd.
Tell
me
about
the
jobs
that
you've
had
prior
to
high
school.
Did
you
have
any
employment
as
a
part-time
employee
at
any
time?
A
I
did.
I
was
a
dance
instructor
for
Denise
Yegal
Dance
Studio
(ph).
And
also
I
worked
as
ar.
assistant
for
SouthviewAcresNursing
Horne.
1A
2
Q
3A
4
Q
5A
6
Q
7A
8
Q
9A
10
Q
11
A
12
Q
13
A
14
Q
15
A
16
Q
17
A
18
Q
19
A
20
Q
21
22
23
24
25
question,
that
way
we
won't
have
an
overlap
and
the
court
r e ~ o r t e r
won't
be
looking
at
us
with
a
puzzlement
as
to
why
we're
double
speaking.
lid
appreciate
that.
Secondly,
if
you
don't
understand
a
question,
just
let
me
know.
It
may
be
a
confusing
q u e s t i o ~ .
Counsel
may
object
at
tines.
Wait
forthe
oJjection
:0
be
noted
and
thenanswer.
If
you
don't
unde:stand
it,let
~ e
know
and
I
will
rephrase
the
question.
Is
that
okay?
A
Yes.
Q
If
youdo
answer
a
question,
I
will
assune
you
ur.derstood
what
I
was
asking.Is
that
okay?
Yes.
Is
tiere
any
limitation
that
you
have
heretoday
from
a
standpoint
of
a
physical
or
mental
type
condition
that
would
limit
your
participation
in
a
questioning
and
answering
period?
No.
Let's
look
at
your
background.
I
want
tofind
out
alittle
nore
about
you
as
an
individual.
Where
did
yougrow
up?
A
South
St.
Paul.
Q
\1hat
year
were
you
born?
A
1967.
,t.
23
24
25
1
2
3
4
5
6
789
10
11
12
13
14
A
15
Q
16
17
1819
A
20
Q
~ '
EXHIBIT 21
Case 0:05-cv-01348-JNE-SRN Document 212-16 Filed 08/20/2008 Page 2 of 25
 
11
12
reading
samplesof
asbestos.
~
Give
the
letters
of
that
NIOSH.
A
N-I-O-S-3.
~
So
you
also
took
some
training,
not
only
40
hoursbut
the
additional
organization
that
you
mentioned,
training
from
that
organization.
Correct?
A
Correct.
~
Did
that
give
you
acertification?A
Yes.
~
What
was
the
title
of
the
certification
that
you
obtained?
AI
had
two
certifications.
Onewas
asbestos
abatement
worker
and
one
was
asbestos
abatement
supervisor.
~
How
long
did
you
maintainthose
certifications?A
Approximately,four
years.
~
Describe
the
kind
of
work
that
you
did
with
asbestos
abatement
generally.
A
We
tore
down
schools,
buildings
that
had
asbestos
in
them.
~
You
removed
certain
components
within
those
structures--A
Correct.
~
--that
were
asbestos?
1
2
3
4
5
6
7
8
9
10
11
12
13
141516171819
20
21
22
23
24
25
Q
What
typeof
jobs
did
you
have
following
higi
school?
A
Followinghigh
school,
I
worked
in
the
constructionbusiness.
I
worked
inthe
environmental
business.
I
worked
intheinsurance
business.
Q
Let's
start
in
chronological
order.
What
was
the
first
job
you
had
at
the
time
that
you
graduated
from
high
school?
A
It's
so
long
ago.
I'm
guessing
it
was
Brand
of
California.
It
was
a
construction
company.
~
\ ~ h e r e
were
they
located?
A
San
Francisco.
~
Didyou
go
to
San
Francisco?
A
Yes,
I
did.
Q
How
long
did
you
live
there?
A
Six
years.
~
What
typeof
living
arrangement
did
you
have?
A
My
husband
was
in
the
military.
Q
When
did
you
get
married?
A
1986.
Q
What
was
the
name
of
yourhusband?
A
William
Bergman.
Q
Where
did
you
get
married?
A
In
San
Francisco.
~ L .
23
24
25
9
~
Did
you
do
any
of
that
type
of
work
whenyou
1
~
Where
did
you
meet
yourhusband?
were
in
high
school
as
well?
2
A
He
was
a
friend
of
thefamily.
A
Yes.
I
worked
full-time
inhigh
school.
3
~
From
the
Minnesota
area?
Q
Where
did
youwork?
4A
Correct.
oA
Southview
Acres
Nursing
Home
at
night.
5
~
So
you
transferred
out
or
moved
out
to
6
~
What
typeof
a
position
did
you
have
there?
6
California.
What
year
was
that?
7AI
was
a
nursing
assistant.7A
1986.
8
~
That
was
full-time
during
high
school?
8
~
You
lived
there
for
six
or
seven
years
you
said?
9A
Correct.
9A
Correct.
10
Q
How
many
hours
did
you
work
a
week
there?10
~
What
did
you
do
when
you
were
there
in
11
A
At
least
43.
11
California
for
your
first
employment?
12
Q
Didyou
have
any
other
part-time
jobs
during
12
AI
believe
it
was
Brand
of
California
13
high
school?
13
Construction
Company.
14
A
Yes.
I
was
a
dance
teacher.
14
~
What
was
the
name
of
your
boss
there,
do
you
15
~
How
many
hours
did
you
do
that?
15
remember
that?
16
A
Probably
8
to
16.
16
AI
don't
remember.
17
~
How
long
did
youwork
in
the
role
as
a
dance
17
~
What
typeof
work
did
you
do?
18
instructor?
18
A
They
did
asbestos
abatement.
19
AIstarted
dancing
when
I
was
3
years
old
and
I
19
~
Did
you
have
totake
any
special
training
in
20
became
an
instructor
at
the
age
of
13.
20
order
to
work
in
the
asbestos
abatement
field
21
~
How
long
did
you
actually
work
as
ar:
instructor?
21
there
in
California?
22
A
Until
I
graduated
high
school.22
A
Yes,
I
did.
23
Q
When
you
graduated
from
high
school,
did
you
23
~
Describe
that
for
me.
24
take
employment
anywhere?
24
AI
had
to
take
a
40-hour
hazardous
material
~
_A_Y_eS_,_I_d_id_.
-+_2_5
co_u_r_se_._I_a_l_so_t_oo_k_N_I_OS_H_S_8_2_t_ra_i_n_in_g_w_h_ic_h_l_'
s_
10
1
234
5
6
7
8
9
10
11
12
13
1415161718
19
20
~ .
1
2
f
EXHIBIT 21
Case 0:05-cv-01348-JNE-SRN Document 212-16 Filed 08/20/2008 Page 3 of 25

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