1
 
 
 
         1     IN THE COURT OF COMMON PLEAS OF CHESTER COUNTY,
 
         2                        PENNSYLVANIA
 
         3
 
         4                            
 
         5
             PENNSYLVANIA MANUFACTURERS'  : CIVIL ACTION  LAW
         6   ASSOCIATION INSURANCE COMPANY:
 
         7         vs                    :
 
         8   CULBERTSON ENTERPRISES, INC : No 9203105
                                      
         9   CULBERTSON ENTERPRISES, INC,: CIVIL ACTION  LAW
             et al,                       :
        10         vs                    :
             PENNSYLVANIA MANUFACTURERS'  :
        11   ASSOCIATION INSURANCE COMPANY: No 9210391
                                       
        12        Phoenixville, Pa, Thursday, October 19, 2000
                                      
        13
 
        14                Deposition of ROBERT L CONRAD, taken
 
        15   pursuant to notice, at the law offices of Unruh,
 
        16   Turner, Burke & Frees, PC, 120 Gay Street,
 
        17   Phoenixville, Pennsylvania, on the above date,
 
        18   beginning at 10:04 am, before Donna A Bittner,
 
        19   RMRCRR

 
        20
 
        21                            
 
        22
                           DONNA A BITTNER REPORTING
        23              REGISTERED PROFESSIONAL REPORTERS
                                  61 Penn Road
        24                Voorhees, New Jersey  08043
                                 (856) 7686619
 
                           DONNA A BITTNER REPORTING
 
 
 
 
                                                               2
 
 
 
         1
             APPEARANCES:
         2
                   EDWARD A GREENBERG, ESQUIRE
         3         Daller, Greenberg & Dietrich LLP
                      Valley Green Corporate Center
         4            7111 Valley Green Road
                      Fort Washington, Pennsylvania  19034
         5                           and
                   STEPHEN R GARTNER, ESQUIRE
         6         JOHN J SELLINGER, ESQUIRE
                     380 Sentry Parkway
         7           Blue Bell, Pennsylvania 19422
 
         8               Counsel for Pennsylvania Manufacturers
                          Association Insurance Company
         9
                   JOHN J CUNNINGHAM, IV, ESQUIRE
        10         Lamb, Windle & McErlane, PC
                      23 East Market Street
        11            PO Box 565
                      West Chester, Pennsylvania  193810565
        12
                         Counsel for Culbertson Enterprises, Inc
        13
                                    
        14
 
        15
 
        16
 
        17
 
        18
 
        19
 
        20
 
        21
 
        22
 
        23
 
        24
 
 
                           DONNA A BITTNER REPORTING
 
 
 
 
                                                               3
                             Robert L Conrad
 
 
         1
 
         2                (It is hereby stipulated and agreed by
 
         3   and among counsel for the respective parties that
 
         4   sealing, filing and certification are waived; and that
 
         5   all objections, except as to the form of the question,
 
         6   are reserved until the time of trial)
 
         7                          
 
         8                 ROBERT L CONRAD, 416 Sioux Drive,
 
         9         Mechanicsburg, Pennsylvania, 17050, after having
 
        10         been duly sworn, was examined and deposed as
 
        11         follows
 
        12                          
 
        13                COURT REPORTER:  Usual stipulations,
 
        14   gentlemen?
 
        15                MR CUNNINGHAM:  Except that we'd like to
 
        16   read and sign
 
        17   BY MR SELLINGER:
 
        18     Q  Mr Conrad, my name is John Sellinger  I'm an
 
        19   attorney with PMA Insurance Company
 
        20                Can you tell me whether or not you know
 
        21   why you're here today?
 
        22     A  Yes  I understand that I'm here to talk about
 
        23   what I did for Bill Knepper for the report he did for
 
        24   Culbertson
 
 
                           DONNA A BITTNER REPORTING
 
 
 
 
                                                               4
                             Robert L Conrad
 
 
         1     Q  Did you bring anything with you today?
 
         2     A  No, I did not
 
         3     Q  Why was that?
 
         4     A  I understood that the Judge had ruled that all
 
         5   the things that you had previously requested were not