4fa6d10f-1b57-4792-8165-7477ea361ab3
CHARLES LINKE
AREA WIDE REPORTING & VIDEO CONFERENCING
Page 1
IN THE CIRCUIT COURT OF RALLS COUNTY
STATE OF MISSOURI
JACOB HEIMER, )
)
Plaintiff, )
)
vs )
) No 08RL-CV00047
CONTINENTAL CEMENT COMPANY,)
LLC, RK RUTLEDGE )
CONSULTING, LLC, VERNON L )
GOEDECKE COMPANY, INC, )
REFRA-PRODUCTS CO, INC, )
and AVRO TOWER CRANES, )
INC, )
)
Defendants )
---------------------------
DISCOVERY DEPOSITION OF CHARLES LINKE
April 22, 2009
10:00 am
June Haeme: RMR, CRR, CSR # 084-003038
Area Wide Reporting and Video Conferencing
301 West White Street
Champaign, Illinois 61820
8007476789
4fa6d10f-1b57-4792-8165-7477ea361ab3
CHARLES LINKE
AREA WIDE REPORTING & VIDEO CONFERENCING
Page 2
1 INDEX
2
APPEARANCES:
3
For the Plaintiff:
4 Brett K Gorman
Attorney at Law
5 Schmiedeskamp, Robertson, Neu & Mitchell
525 Jersey Street
6 PO Box 1069
Quincy, IL 62306-1069
78
APPEARANCES VIA VIDEOCONFERENCE:
9 For the Defendant RK Rutledge Consulting, LLC:
Kenneth L Halvachs
10 Attorney at Law
Boyle Brasher, LC
11 5000 West Main Street
PO Box 23560
12 Belleville, IL 62223-0560
13 For the Defendant Vernon L Goedecke Co:
Louis J Leonatti
14 Attorney at Law
Leonatti & Baker
15 123 East Jackson Street
PO Box 758
16 Mexico, MO 65265-0758
17 For the Defendant Continental Cement Co:
James R Howard
18 Attorney at Law
Brown & James, PC
19 1010 Market Street, 20th Floor
St Louis, MO 63101
20
For the Defendant Refra-Products Co, Inc:
21 Allison Stoll
Attorney at Law
22 Rabbitt, Pitzer & Snodgrass, PC
100 S 4th Street, Suite 400
23 St Louis, MO 63102
24
4fa6d10f-1b57-4792-8165-7477ea361ab3
CHARLES LINKE
AREA WIDE REPORTING & VIDEO CONFERENCING
Page 3
1 For the Defendant AVRO Tower Cranes, Inc:
Brendan Simaytis
2 Attorney at Law
Williams, Venker and Sanders, LLC
3 Bank of America Tower
100 North Broadway, 21st Floor
4 St Louis, MO 63102
5
6
EXAMINATION BY
7
Mr Halvachs 5, 88
8 Mr Howard 60
Ms Stoll 69
9 Mr Leonatti 71
10
EXHIBITS:
11
No 77 71
12
13
14
15
16
17
18
19
20
21
22
23
24
4fa6d10f-1b57-4792-8165-7477ea361ab3
CHARLES LINKE
AREA WIDE REPORTING & VIDEO CONFERENCING
Page 4
1 STIPULATION
2
3
4 IT IS HEREBY STIPULATED AND AGREED by and
5 between all parties to this suit, through their
6 respective attorneys, that the discovery deposition
7 of CHARLES LINKE may be taken for discovery
8 purposes, pursuant to the provisions of the Code of
9 Civil Procedure and Rules of the Supreme Court, at
10 the offices of Area Wide Reporting Service, 301 West
11 White Street, Champaign, Illinois, on April 22,
12 2009, before June Haeme, Certified Shorthand
13 Reporter, Registered Merit Reporter, Certified
14 Real-time Reporter and Notary Public, and upon oral
15 interrogatories only
16
17 This deposition is taken for discovery
18 purposes and the same or any part thereof may be
19 introduced into evidence for any purpose for which
20 such depositions are rendered competent by statute
21 or rule of court and without foundational proof
22
23
24
4fa6d10f-1b57-4792-8165-7477ea361ab3
CHARLES LINKE
AREA WIDE REPORTING & VIDEO CONFERENCING
Page 5
1 (Commencing at 10:06 am)
2 CHARLES LINKE,
3 having first been duly sworn, testified as follows:
4 EXAMINATION BY
5 MR HALVACHS:
6 Q Would you state your name for the record
7 please?
8 A Charles Linke
9 Q And what is your current address, sir?
10 A My office address in Champaign is 1416
11 Hollycrest Drive, Champaign, Illinois
12 Q And is it Dr Linke?
13 A It is
14 Q All right Doctor, my name is Ken
15 Halvachs I don't know if you remember me but --
16 it's probably been 20 something years, but I've
17 deposed you before, and I'm going to ask you a few
18 questions today regarding your analysis of Jacob
19 Heimer, okay?
20 A Yes, sir
21 Q And we have been provided a curriculum
22 vitae of you dated July the -- well, it just says
23 July of 2008 Is that your current curriculum
24 vitae?
4fa6d10f-1b57-4792-8165-7477ea361ab3
CHARLES LINKE
AREA WIDE REPORTING & VIDEO CONFERENCING
Page 6
1 A Yes, sir I update my vitae once a year
2 on my birthday, July 1, so we're two months and days
3 away from a new one, but there are no additions that
4 relate to the issue at hand
5 Q All right You're a professor emeritus;
6 is that correct?
7 A Yes, sir
8 Q How long has it been since you were
9 full-time teaching at the University of Illinois?
10 A For full-time teaching, about seven years
11 Q All right And you operate a business
12 involving your consulting; is that right?
13 A Yes, sir
14 Q And I have it here somewhere, but what is
15 the name of that business?
16 A Economics Et Cetera Incorporated
17 Q And are you the sole shareholder of that
18 company?
19 A I am
2