Free Statement of Material Facts - District Court of Connecticut - Connecticut

Case 3:02-cv-01718-RNC Document 99-18 Filed 12/13/2004 Page1 0f2
Plaintiffs’ Local Rule 56(a)1 Statement
Exhibit 16
Extract From Deposition of Charles Sterling
April 23, 2003
page 9, line 8-10

Case 3:02-cv-01718-RNC Document 99-18 Filed 12/13/2004 Page 2 of 2
Schiavone vs. Kasden et al
4/23/2003 Charles Sterling
Page 9
1 what were your duties?
2 A. Called on customers in an attempt to get them
3 to sell us material. It is reverse sales, in effect.
4 It is actually purchasing rather than sales. A scrap
5 business operates where you buy from somebody else.
6 Q. And at that time H. Kasden & Sons was located
7 where?
8 A. On Lloyd Street in New Haven.
9 Q. Both the office and the yard?
10 A. When 1 came to work, everything was on
11 Lloyd Street.
12 Q. And there came a time later on when the yard
13 moved?
14 A. There came a time later on —- yes.
15 Q. And where did the yard move to?
16 A. To North Haven.
17 Q. And about when was that?
18 A. 1 have a feeling it was early '70s, to the
19 best of my recollection. I don't remember, frankly.
20 Sometime around there.
21 Q. And did yard operations on Lloyd Street cease
22 at that time or did they go through a transition period?
23 A. 1 think there was some kind of transition.
24 Q. But they eventually ended at Lloyd Street?
25 A. Yeah, Lloyd Street was closed and sold.
Brandon Smith Reporting Service
¤e4ee¤3e-dsdr-481e-beee-fefefeesseze