7


THE STATE OF OHIO,
Ss.  MICHAEL J. CORRIGAN, J.
COUNTY OF CUYAHOGA.

IN THE COURT OF COMMON PLEAS


JAMIE FISHER, ETC.,

Plaintiffs,

Case No. 124763
V.

-nNsOLIDATED RAIL CORPORATION,

Defendant.


Deposition of RICHARD STANFORD, taken by

t))L Flairitiff as if upon examination before Lisa Hrovat,

a F-gistered Professional Reporter and Notary Public

within and foi the State of Ohio, at the offices of

bandskroner & Phillips, Co. L.P.A., 75 Public Square,

Sudte 1100, Cleveland, Ohio, on Sunday, the 5th of

February, 1989, commencing at 10:00 a.m., pursuant to

not j ce .








MIZANIN REPORTING SERVICE
PE F@TERF[ PPOFESSIONAL RFPORTFR@@
TPANISCPPT@0N

540 TERMINAL TOWER CLEVELAND, OHIO 44113 (2161 241-0331

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1 APPEARANCES:

2 Landskroner & Phillips Co., L.P.A.,
By: Lawrence Landskroner, Esq.,
3
On behalf of the Plaintiffs.
4
Gallagher, Sharp, Fulton & Norman,
5 By: Thomas Dover, Esq.,

6 On behalf of the Defendant.

7

8 - - -

9 STIPULATIONS

10 It is stipulated by and between counsel for

11 the respective parties that this deposition may be

12 taken in stenotypy by Lisa Hrovat; that her stenotype

13 notes may be subsequently transcribed in the absence of

14 the witness; that the reading and signing of the

15 deposition by the witness were expressly waived; and that

16 all requirements of the Ohio Rules of civil Procedure

17 with regard to notice of time and place of taking this

18 deposition are waived.

19 - - -

2 0

21

2 2

2 3

24

2 5

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1 RICHARD STANFORD,
2 called by the Plaintiffs for the purpose of examination,
3 as provided by the Ohio Rules of Civil Procedure, being
4 by me first duly sworn, as hereinafter certified, deposes
5 and says as follows:
6 EXAMINATION
7 BY MR.  LANDSKRONER:
8 Q. Mr. Stanford, if I ask you a question --
9 MR. DOVER: He doesn't have his file.
10 MR. LANDSKRONER: Let's do some general
11 things.
12 Q- (BY MR.  LANDSKRONER) If I should ask you some
13 questions that you are not clear -- that are not clear to
14 you or you wish to have rephrased, having some experience
15 with you before I am sure you will, and I will suggest
16 respectfully if you can answer the questions directly
17 rather than in an oblique manner we can save a lot of
18 time. So what I am saying, in essence, if you don't
19 understand me just interrupt and I will rephrase the
20 question. If I ask you a technical question, I would like
21 an answer in simplistic terms. So if you describe, for
22 example, inertia or force, mak