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 LPA, 75 Public Square,

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

February, 1989, commencing at 10:00 am, pursuant to

not j ce 








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

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

2_


1 APPEARANCES:

2 Landskroner & Phillips Co, LPA,
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, make it in the lowest common
23 denominator so I can understand you It would be
24 appreciated
25 Let the record further direct that we had some
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1 dialogue about exhibits and the change of exhibits prior
2 to starting this deposition and I want to say on the
3 record I duly appreciate receiving the medical records
4 of the railroad people, but I want you to know even
5 though you said we got other records on the railroad
6 people, as far as preliminary actions and the like, I have
7 been informed, unless I am in error, that we got them on
8 Friday Today is Sunday, and the trial is tomorrow, and
9 to really put the curse on us, I don't know whether you
10 did this maliciously or not --
11 MR DOVER: Landskroner, shut your mouth
12 1 am getting pissed off We are going to leave right now
13 MR LANDSKRONER: Let me finish
14 MR DOVER: We filed a motion for
15 protective order and you know very well the Court ordered
16 you on Thursday -- ordered us on Thursday for the first
17 time to turn over those records We got them as quick
18 as we possibly could so we could produce them for you
19 MR LANDSKRONER: Will you let me finish
20 before you use expletives, as what I used to know in the
21 Navy And they are illegible and we can't read them
22 They are not decipherable You may have given them to
23 us, but they are illegible, so don't scream for me for
24 something
25 MR DOVER: You are screaming at me I am
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I sick of you saying T am trying to hide you from this
2 MR LANDSKRONER: Let's do this one at a
3 time so we don't have a problem with the Court either
4 MR DOVER: You know as well as I do, that
5 we opposed turning over the personnel records of the
6 railroad crew I am calming down When the Court
7 ordered us to on Thursday, for the first time, produce
8 those records, we got those records, had them federal
9 expressed as quick as we could and turned them over to
10 you on Friday I then, in order to get not only the
11 personnel records, I then requested the medical records
12 I had to call the medical director of Conrail personally
13 in Detroit, Michigan to federal express those records,
14 and I brought you those records as soon as I possibly
15 could
16 MR LANDSKRONER: Let me respond in a very
17 cold and dispassionate manner
18 MR DOVER: Good
19 MR LANDSKRONER: With regard to the
@O medical records, I said you brought them here today it
21 is now 10:00 or 10:30 on a Sunda