1
 1   IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI
 2   GARY M GRAHAM and
    BEVERLY GRAHAM,
 3   
                  Plaintiffs,
 4   
             vs              Case No 105CC3892
 5   
    MISSOURI AND NORTHERN
 6   ARKANSAS RAILROAD COMPANY,
 7                 Defendant
 8   
 9             DEPOSITION OF LARRY G COX,
10   produced, sworn, and examined on Thursday,
    May 31, 2007, at 1:00 pm of that day, at
11   The Law Offices of Palmer Oliver, PC,
    205 Park Central East, Suite 511, in the
12   City of Springfield, County of Greene, and
    State of Missouri, before me,
13   Abby Lynn Wasson, RPR, CCR, and CSR, in the
    above-captioned cause; taken on behalf of
14   the Defendant
15   
16   
17   
18   
19   
20   
21   
22   
23   
24   
25   

                                                                     2
 1               A P P E A R A N C E S
 2   For Plaintiffs:   MR CRAIG R OLIVER
                      THE LAW OFFICES OF
 3                     PALMER OLIVER, PC
                      205 Park Central East
 4                     Suite 511
                      Springfield, MO 65806
 5   
    For Defendant:    MR PAUL M BROWN
 6                     THOMPSON & COBURN, LLP
                      One US Bank Plaza
 7                     St Louis, MO 63101
 8   
 9                     I N D E X
10   Testimony of
    LARRY G COX:     Direct     Cross
11   
    By Mr Brown:       4
12   
13   
    REPORTER'S
14   CERTIFICATE:  86
15   
16   
17   
18   
19   
20   
21   
22   
23   
24   Phonetic spellings are signified by:  (ph)
25   Exactly as stated:  (sic)

                                                                     3
 1   EXHIBIT       DESCRIPTION          IDENTIFIED
 2   Dft 1         Larry Cox's 5-23-2007       4-5
                  "Gary Graham's Injury
 3                 Related Economic Losses"
                  Report
 4   
    Dft 2         Social Security           11-12
 5                 Certification of Extract
                  from Records and records
 6   
    Dft 3         Schedule C Instructions      37
 7                 from the internet
 8   Dft 4         Larry Cox's handwritten      40
                  notes
 9   
10   
    (Defendant's Exhibits 1 through 4 retained
11   by the witness)
12   
13   
14   
15   
16   
17   
18   
19   
20   
21   
22   
23   
24   
25   

                                                                     4
 1       Whereupon,
 2                       LARRY G COX,
 3       being produced, sworn, and examined,
 4       testified as follows:
 5                     DIRECT EXAMINATION
 6       BY MR BROWN:
 7   Q  State your name, please
 8   A  Larry G Cox
 9   Q  Mr Cox, you understand you have been
10       endorsed as an expert witness in the case of
11       Gary Graham versus Missouri and Northern
12       Arkansas Railroad Company?
13   A  Yes, sir
14   Q  Have you brought your file with you today?
15   A  Yes, I have
16   Q  And you've also brought for me a copy of
17       reports you prepared for Mr Oliver?
18   A  Yes, sir
19   Q  Let's start and have your report marked
20            (Defendant's Exhibit 1 marked for
21       identification)
22            MR OLIVER:  Here's your exhibits
23            MR BROWN:  Oh, thanks  I would have
24       forgotten all about them
25   Q  (By Mr Brown) Mr Cox, can you identify

                                                                     5
 1       Defendant's Cox Exhibit 1 as the reports you
 2       prepared in this case?
 3   A  Yes  It's the report showing my estimation
 4       of Gary Graham's economic losses due to an
 5       injury that he sustained in 2003
 6   Q  May I see your file, please
 7   A  Yes, sir
 8   Q  I'm just going to go through and note what's
 9       in your file  As we go through it I may
10       indicate I'd like to get copies of portions
11       of it and then maybe not
12            First of all, there's a copy of your
13       report; correct?
14   A  Yes, sir
15   Q  Then there is a list of Social Security
16       data
17   A  I think that's included in my report
18   Q  Oh, that's an attachment to your report as
19       well?
20   A  I believe so  Maybe about on --
21   Q  Let me double-check and see
22   A  No  You need to go the other direction
23   Q  Other direction  It would be in the
24       appendix; right?
25   A  Yes, sir

                                                                     6
 1            MR OLIVER:  It's in there  Page 15
 2   Q  (By Mr Brown) I'm almost there  There it
 3       is  Page 15  Okay
 4            MR OLIVER:  You didn't trust him when
 5       you said it was in there