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 92-03105
                                    - - -
         9   CULBERTSON ENTERPRISES, INC,: CIVIL ACTION - LAW
             et al,                       :
        10         vs                    :
             PENNSYLVANIA MANUFACTURERS'  :
        11   ASSOCIATION INSURANCE COMPANY: No 92-10391
                                     - - -
        12        Phoenixville, Pa, Monday, October 16, 2000
                                    - - -
        13
 
        14                Deposition of WILLIAM D KNEPPER, 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 10:07 am, before Donna A Bittner,
 
        19   RMR-CRR
 
        20
 
        21                          - - -
 
        22
                           DONNA A BITTNER REPORTING
        23              REGISTERED PROFESSIONAL REPORTERS
                                  61 Penn Road
        24                Voorhees, New Jersey  08043
                                 (856) 768-6619
 
                           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  19381-0565
        12
                         Counsel for Culbertson Enterprises, Inc
        13
                                  - - -
        14
 
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        23
 
        24
 
 
                           DONNA A BITTNER REPORTING
 
 
 
 
                                                               3
                             William D Knepper
 
 
         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                 WILLIAM D KNEPPER, Two Caras Court,
 
         9         352 Dreshertown Road, Fort Washington,
 
        10         Pennsylvania, 19034-3009, after having been duly
 
        11         sworn, was examined and deposed as follows
 
        12                        - - -
 
        13                COURT REPORTER:  Usual stipulations?
 
        14                MR CUNNINGHAM:  That's fine, although
 
        15   I'll reserve the right for the witness to read and
 
        16   sign
 
        17                MR GREENBERG:  You're reserving it or
 
        18   exercising?
 
        19                MR CUNNINGHAM:  Reserving the right
 
        20                MR GREENBERG:  You're going to decide
 
        21   afterwards?
 
        22                MR CUNNINGHAM:  No
 
        23                MR GREENBERG:  They want to do it
 
        24                MR CUNNINGHAM:  We want to do it
 
 
                           DONNA A BITTNER REPORTING
 
 
 
 
                                                               4
                             William D Knepper
 
 
         1                MR GREENBERG:  Otherwise usual
 
         2   stipulations?
 
         3                MR CUNNINGHAM:  Fine
 
         4   BY MR GREENBERG:
 
         5     Q  Good morn