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, P.C., 120 Gay Street,
 
        17   Phoenixville, Pennsylvania, on the above date,
 
        18   beginning at 10:04 a.m., 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, P.C.
                      23 East Market Street
        11            P.O. 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