ML19322C834
| ML19322C834 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/20/1979 |
| From: | Goldfrank J, Mcgarry J METROPOLITAN EDISON CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001280559 | |
| Download: ML19322C834 (27) | |
Text
. _ _ _
___.__x N
P PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND
_________________x DEPOSITION of METROPOLITAN EDISON COMPANY by JOHN JAMES McGARRY, held at the Three Mile Island Nuclear Generating Station on the 20th day of July 1979, commencing at 4:20 p.m.,
before Stanley Rudbarg, Certified Shorthan'd Reporter and Notary Public of the State of.New York.
j BENJAMIN REPORTING SERVICE CERTIFIED SHORTHAND REPORTERS FIVE BEEKM.LN STREETF NEW YOrtK. NEW YORK 10038
[212] 374-1138 80 01280[N
PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND Corrections to July 20, 1979, Deposition of Johts J. McGarry Page Line Change To Read i2.
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I McGarry 22 S3.
7 2
A 0
In the parking lot of the observation center.
3 Q
You did not know who these two people were?
4 A
No, I did not.
2 I
e k y)
Q nut was the only contact you had?
5
.r 6
A That was the only contact I had.
..A 7~
1 Q
Is it correct to state
- t. hat your respon-h g
y sibilities from approximately midnight on March 28 and s
9.for about a week and a half encompassed maintenance 1'
10 concerns?
I i
11 A
Yes.
1
?
12 9
MS. GOLDFRANK:
Do you have any questions?
13 i
l' MR. YUSPEH:
I have none.
i
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l 14
)
Q I have no further questions at this time.
15 i
i
{
We would recess this deposition, we don't i
1 1
16 anticipate that we would have you come back to 17 j
ask yo'u further questions, but it is possible that 18
]
we would call you back.
19
{
A Yes.
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(The deposition was adj u ned at 4:
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John James McGarry h,
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B ENJAMIN REPOCING ScavtCE
1 i
x PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND
___________________x DEPOSI Jh of METROP"ITAN EDISON COMPANY by JOHN JAMES McGARRY, held at the Three Mile Island Nuclear Generating Station on the 20th day of July 1979, commencing at 4:20 p.m.,
before Stanley Rudharg, certified Shorthand Reporter and Notary Publi: of the State of.New York.
-L BENJAMIN REPORTING SERVICE l
CERTIFIED SHORTHAND REPORTERS l
FIVE BEEMMAN STREET j
[212} 374 1138
I i
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2 l
2 AP PEARANCE S :
3 gggggggp;;33_ggISgg_gggggggi l
4
( (-s SHAW, PITTMAN, ?OTTS & TROWBRIDGE, ESQS.
5 Attorneys for Metropolitan Edison Company 1800 M Street, N.W.
6 washington, D.C.
7 BY:
ALAN R.
YUSPEH, ESQ.
of Counsel 8
9 i
10 PRESIDENT'S COMMISSION ON THREE MILE ISLAND:
11 JOAN GOLDFRANK, ESQ.
12 Associate Ca"asel 13 14 ALSO PRESENT:
15 CLAUDIA A. VELLETRI 16 PHILIP STEARN, Consultant 17 Prer.ident's Commission 18 o0o 19 SR.,
having JOHN JAMES McGARRY 20 been duly sworn by Ms. Goldfrank, testified as 21 follows:
.h.
22 DIRECT EXAMINATION BY MS. GOLDFRANK:
23 Q
Would you state your name?
A John James McGarry, Sr.
25 Q
Could you state your current address?
S ENJAMIN REPORTING SERVICE
1 McGarry 3
2 A
1019 Clearview Drive, RD #1, Middletown, 3
4 Q
And your current employer?
n 5
A Metropolitan Edison company.
6 Q
And your current position?
7 A
Supervisor of mechanical maintenance.
8.
g Did you bring with you a resume?
9 A
Yes, I did.
10 MS. GOLDFRANK:
I would like to mark as 11 McGarry Deposition Exhibit 1 a resume of John 12 James McGarry.
U (Above-described document was marked McGarry 14 Deposition Exhibit 1 for identification.)
15 g
Did you prepare this resume?
16 A
Yes.
17 g
Did you prepare it currently?
18 A
Yes, last night.
19 g
You completed one semester of undergraduate 20 work at Temple University during the period september l
21 1965 to June 19667
~
22 A
Yes.
That was the only time I was on shore duty.
i l
23 g
Prior to that, you were in the Navy, is 24 that correct?
I 25 A
I was in the Navy then.
BENJAMIN R EPORTING SERVICE m.
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1 McGarry 4
2 Q
You. wore in the Navy then?
3 x
y...
4 Q
Was that training at Temple University 5
part of your responsibilities in the Navy?
6 A
No, I was going to school for myself.
7 Q
And how was it that you were able to attend 8
Temple University?
9 3
z.want to night school.
I was stationed at the 10 Philadelphia Naval Shipyard.
11 Q
From what date were you in the Navy?
12 A
I enlisted in the Navy September 19, 1949, and 13 I retired November 2, 1972.
14 Q
And what training did you receive while 15 you were in the Navy?
16 A
I have it all there.
May I read it off from 17 the transcript?
18 Q
Could you explain to me where you state 19 that you attent'.4d classes as a machinist's mate?
N A
Yes.
That is a basic enlisted school.
Th'a t is 1
three months.
They teach the basics of naval engineer-L 22 ing, machine shop practices and overhaul of equipment.
23 Q
And all these schools that you list that 94 you attended in the Navy, were thej ;;ught by the Navy?
j l
5 A
In some instances, yes.
Let me see.
I had B ENJAMIN R EPO RTING SERVICE
1 McGarry 5
2 civilian instructors a,t the Nuclear Power Plant 3
operator Training, which was in Arco, Idaho, and also 4
at the officers Candidate School.
b
(,
5 Q
You had civilian instructors, but they 6
were --
7 A
It was Navy-run, run by the Government.
8 Q
Could you explain what your training at 9
the basic Nuclear Power School was, from January '59 10 to June
'59, what it entailed?
11 A
The basic school was at a Navy shipyard at 12 Mare Island, California.
This school consisted of U
basic nuclear physics, basic common physics, metal-14 lurgy, basic electricity, basic chemistry, mathematics, 15 health physics.
We had also systems and components.
16 I may have missed something, but it has beer./. a while.
17 Q
Was this classroom training?
18 A
Was there any practical experience?
19 A
Not there.
Excuse me, yes, we had some basic 20 welding, and it was only a short course.
It was in 21 the afternoons.
It lasted about three weeks, two hours
--L 22 a day.
23 Q
And were you given a grade at the end of 24 this course?
l 25 A
we were given a class standing, and out of 150, B ENJAMIN REPORTING S ERVICE
-w
i I
McGarry 6
2 I was somewhere in the 80's, I don't remember.
3 Q
And what did your training from July '59 4
to January '60 at the Nuclear Power Plant Operator 5
Training comprise?
6 A
That was all plant operations training
- operate, 7
startup and run equipment.
8 Q
Was it a practical school?
9 A
Practical in what sense?
10 Q
In the sense that you actually start up?
l 11 A
Yes, we had to start all pieces of equipment, 12 including taking the reactor critical.
D Q
Was this a research reactor?
14 A
No, it was an exact duplicate of the reactors 15 installed on the let me think of the name of the 16 ship -- the ENTERPRISE.
It consisted of two reactors, 17 a complete main turbine,'which.ould be run as a 18 water wheel for a brake, so it wouldn't run away, and 19 they hed all the auxiliary equipment so that it looked 20 like the inside of the ship.
21 Q
Did it generate power?
,L 22 A
No, the power was dissipated by the water wheel, 23 the water brake.
24 Q
And how many people were in that school 25 in your particular class?
SENJAMIN R EPORTING SERVICE l
1 McGarry 7
2 A
Well, we started out with 150.
I think there 3
w-re probably 120 that completed the operator training 4
phase in my particular class.
5 Q
so there would be 120 of you working on 6
an actual reactor?
7 A
No.
It was in shift work.
we were set up in 8
crews, just like we would be on a ship, and as many 9
people as were necessary to run the plant were there, 10 plus they had trainees.
11 The job of the trainee was to go out and learn 12 the physical plant first, and then you had to sign off
^
U cards for everything you did.
You would have to go 14 out and trace out a system, and then you would go and 15 walk chrough the system with an instructor and explain 16 to them what the system was, what it did, make a drawing y
17 of the complete system when you were done, and that is 18 the same way with the controls and the other things.
19 Q
oid you have an exam at the and of this I
20 school?
21 A
You did the exam with the checkoff.
f.s L
22 Q
Were you evaluated at each checkoff?
23 A
Yes.
That is what I just explained.
You went 24 l
out and learned it, and then after you learned that, 25 you would go with an instructor, and then he would BENJAMIN R EPORTING S ERVICE
. -..-. 1
1 McGarry 8
2 check you out on the system, and if you passed, then 3
he would sign.
4 Q
So he gave you a written evaluation as to 5
each checkoff?
6 A
we a' iso took a written test along with it on 7
each thing we did, on each system.
8 Q
Was there an exam at the end?
9 x
go, te,ould have been too large an exam to give 10 all at once.
".ou checked out on systems and components.
11 Q
You did not have a cumulative exam at the 12 ends you had av aluations as you went along?
13 x
y..,
14 Q
And in July 1973, you began your employment 15 with Met Edison?
16 x
y.e.
17 Q
And what was your first position at Met 18 Edison?
19 A
I came to Met Edison in the position I now hold.
20 Q
You have held the same position for your 21 entire career?
22 A
res.
23 Q
And have you received any training while 24 at, Met Edison?
l 25 A
We received a B&W course on assembly and BENJAMIN R EPORTING S ERVICE
1 McGarry 9
2 disassembly of reactor internals.
We also received, 3
as part of that training, we also had instruction on 4
the actual physical disassembly of a reactor under Esw C-5
- guidance, we had a short school on diesel engines, 6
and we had a seal seminar, a mechanical seal seminar I
for sealing pumps.
O We had -- I don't remember if it was a one-week 9
or two-week course -- on disassembly of reactor coolant 10 pumps.
I don't remember the length of time.
11 Q
All the training --
12 A
That was by Westinghouse.
U Q
Other than that one course, was all the 14 traini.7 that you have had since at Het Edison given 15 to you by saw?
16 A
No.
The reactor assembly and disassembly was 17 given by asw.
The reactor' coolant pumps was by IO Westinghouse.
The seal seminar was by chesterton 19 company, and the diesel engine course was by Fairbanks 20 Morse.
21 Q
Is Fairbanks Morse a company?
22 A
Yes, they manufacture diesel engines.
23 Q
And would these courses have been given 2%
at various company sites?
l 25 A
No, it was done here on-site.
B ENJAMIN R EPORTIN:3 SERVICE
1 McGarry 10 2
Q Were all of these courses given at TMI?
3 A
Yes.
4 Q
Were written exams given at the end of 5
these courses?
6 A
wo.
7 Q
Was any kind of evaluation given?
8 A
wo.
9 Q
Were you asked to evaluate the course?
10 A
Yes.
11 Q
Were you asked in written form to evaluate 12 these courses?
13 x
- yee, 14 Q
And what was your opinion of these courses?
15 Why don't you go one by one?
16 A
The Westinghouse seal and pump disassembly was 17 very good.
It is all practical technical training.
I j
18 thought it was well presented.
19 The asW reactor internals assembly and disassembly 20 was outstanding, and we learned a tremendous amount.
21 We do it ourselves now.
k-22 The seal school was fair, that is, the Chesterton 23 seal school, and the diesel engine course was fair, 24 also.
But it was geared more for people who had 25 extensive training is 41erial engines.
That is a field BENJAMIN R EPORTING SERVICE
1 McGarry 11 2
unto itself, a very difficult field to master.
3 Q
was there homework assigned in these 4
courses?
(-
5 A
No.
s 6
Q were spamphlets given out?
7 3
y...
8 Q
were you asked to read these?
9 A
Ch, yes.
10 Q
would you be expected to read them during--
i 11 A
on occasion, they asked.
In the westinghouse 12 course, they asked us to do some preliminary reading 13 because they were behind when they came here.
In 14 the B&w course on the reactors, I did it because I 15 wanted to do it.
No, I don't remember that they did.
16 0
Is there any any training specifically 17 required by you as an employee in your position at 18 Metropolitan Edison.
19 would you state the question again.
20 (Previous question was read back.)
21 A
There is none required by me.
L-22 Q
Is there any. required by the Training 23 Department?
'4 A
They are starting a training course now, and I 25 know it as been laid out.
I did review it.
- Yes, BENJAMIN R EPORTING SERVICE l
l
\\
1 McGarry 12 2
there will be courses that I will have to take.
3 Q
Up until this point, there have not been 4
any that were required?
C-5 A
There have been several atempts at starting it, 6
but we didn't because we hadn't gotten to the point 7
where we could devote the time to it.
8 Q
what is the course now that has been laid 9
out that you have reviewed?
10 A
I don't remember.
11 Q
can you tell me generally what it concerns?
12 A
There were courses in management and administra-13 tion.
That is the only ones I can remember.
I can't 14 remember the technical ones.
Yes, we did have a three-15 day maintenance seminar also, Marshall Maintenance.
16 Q
who do you report to?
17 A
Don shetlin.
I8 Q
What is his title?
19 A
superintendent of Maintenance.
20 (Continued on Page 13.)
21 n
23 24 25 B ENJAMIN REPO RTING SERVICE w
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2.1.LW 1
McGarry 13
~
2 Q
And are you the supervisor of Mechanical 3
Maintenance for just Unit 27 4
A No, Units 1 and 2, the whole' island.
^
5 Q
Your resume, Exhibit 1, indicates that you 6
serve on various plant and company committees, could 7
you tell me which committees these are?
8 A
Well, they have come and gone.
We had a committee 9
on river water pumps because we were having some problem 10 with river water pumps.
I was on.that.
Then there 11 was the Tool Security committee.
I have been on others, 12 but I can't remember.
D Q
You state the committees have come and 14 gone.
Is that because these committees have been 15 created to respond to a particular problem?
16 A
Yes.
17 Q
And once that.. problem is solved, the i
18 committee dissolv'ed?
19 A Yes.
20 Q
Do you remember the particular purpose for 21 setting up two committees as you previously mentioned?
L 22 A We have had problems with our river water pumps, 23 and it was a committee to solve the technical problemt 24 that we were having at the time and it has since been 25 disbanded.
SENJAMIN R EPORTIN G SERvlCE
a e
f 1
McGarry 14 2
Q And the other committee?
3 A
Tool security committee, that hasn't been disbanded, 4
but on any large construction site, the pilferage is
('
5 unbelievable.
Millions and millions of taxpayers'
--(
6 dollars go down the drain. We were trying to solve that.
7 Q
You mean on this island with the security?
8 A
Yes.
We didn't always have this security.
9 Q
When was this security instituted?
10 A It has grown. When I first came here, we didn't I
11 have a security event inside.
It has just grown.from 12 there.
With each demand from NRC we get new things, 13 new cameras this year, new sensors next year.
It just 14 grows.
It is getting bigger and bigger.
Pretty soon 15 there will be more of them than us.
16 Q
Your resume also indicates that you interact 17 with vendors, technical representatives, other utility <
18 staffs, government agencies and the public.
19 g
y,,,
20 Q
Which particular vendors do you interact 21 with?
A Anybody that we have the equipment of--B&W.
3 Well, I could go on.
We have 500 vendors.
'*4 Q
Who Lt B&W do you interact with?
5 A
It would depend on what the problem is.
SENJAMIN R EPORTING S ERVICE
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1 McGarry 15 2
Q You would contact --
3 A
we have an on-site staff here from asw and I'm 4
always in daily. contact wi th th e m. ' It is just to see 0-5 them or things that we are working on.
s<
6 Q
would you go through them first before 7
contacting saw off site?
8 A
No, not necessarily.
We have Bsw boilers, and 9
they aren't involved in that.
I 10 Q
what would you contact the people on the 11 site for?
12 A Technical questions concerning the reactor and 13 interest in the things that they gave us, when I say 14 "they gave us," what they designed being built.
15 Q
And with respect to the other issues, would 16 you contact asw people off site?
17 A There have been occasions that I have, yes.
18 Q
Do you have contact with anybody at surns &
s 19 ace?
20 A once in a while, but not too frequently.
I do 21 have to call them for technical advice.
's 22 Q
what kind of thing did you call them for?
23 A I'm trying to think of something specific.
- Well, 24 if I needed input and we didn't have it, we might refer 25 to them and we would call them for that.
If it was B ENJAMIN R EPORTING S ERVICE l
1 McGarry 15-a 2
a technical specification that we didn't have and we 3
wanted it, we would call them because they are the 4
design architects.
^l 5
(continued on next page.)
NJ 6
7 8
9 10 11 12 13 14 15 16 17
~
18
?
19 20 21 23 24 5
i l
S ENJAMIN REPORTING SERVICE t
i
I McGarry 16 o
sm/ew Q
When you refer to " print," is th at 3.1 A
A blueprint, excuse me.
4 Q
You state "other utility staf fs."
Would
~ ~ ',
5 that be other companies such as Metropolitan Edison?
t.
6 A
Yes.
7 Q
And for what reason would you contact the 8
staffs?
9 A
Inquiring into similar problems.
They may have 10 had a similar problem and came up with a solution 11 that would help us to repair parts, do they have a 1
similar piece of equipment if we had a pump that was 13 not functioning, and we need a part for that pump.
14 We through the B&W vendor list that certain utilities 15 have those types of things and we would them and say, 16 "Do you have this part," and we would send parts back i
17 and forth; we do that all the time.
18 Q
Do you ever visit other plants?
19 A
Outside of the GPU group, no, I have not.
20 i
Q Which groups outside the GPU family have
- 1 you had contact with?
~~
A Well, I have talked to Duke Power, Oconee plant, "3
~
Florida Power & Light Bristol River, San Francisco 9~4 Municipal whatever it is, and the Rancho Seco plant.
~5 l
I have talked to them -- Consumer Power.
I can't SENJAMIN REPORTING S ERVICE l
I McGarry 17 2
2 remember all the names.
3 Q
What government agencies do you have 4
contact with?
l (es Vf '-
5 A
NRc.
I U
6 Q
'Who at the NRC7 7
A And also the state Code inspectors for boilers 0
and pressure vessels.
9 Q
Who at the NRC,would you have contact with7 10 Is there one individual?
11 A
No.
12 Q
Are there'many individuals that you have 13 contact with?
14 g
y,,,
15 Q
Are these people in King of Prussia or 16 sethesda?
17 A
I assume most of the ones I have talked to came 18 out of King of Prussia.
19 Q
And under what circumstances would you have 20 contact with the public?
01
(-
A You mean as a representative of Metropolitan
\\-
on Edison Company?
"3 Q
Yes.
94 A
I occasionally talk to people on the telephone 25 who would come in or call in and make inquiry.
I talked S ENJAMIN REPORTING SERVICE
,_..-.-.-.,___._.m.
1 McGarry 18 2
3.3 to people during the incident up here that avked ques-3 tions of me.
I don't do.$t as a daily routine, but it 4
happens whenever you work with a company, people are
~
5 bound to ask you. questions.
l 6
Q Prior to March 28, 1979, people would call you to ask you a general question, you would provide 8
them the answer?
9 3
y,,,
10 Q
You would not refer them to the public 11 information office?
19 A
It would depend on the question.
You know, I U
mean they might call up ard say, you know, "Can I. visit 14 the Island?"
Well, obviously, they couldn't that is 15 the type.
It would be a judgment thing.
Q In certain inJtances you would refer them 17 to public information?
O A
Yes.
Well, we refer them to the observation 19 center.
"O
~
Q Were you on the Island at 4:00 a.m.
on
~1 March 287 k
~~
A No, I was not.
23 Q
What time did you arrive?
'l A
When I arrived, the gate was closed.
It was
'5
~
about 10 minutes of 7:00, somewhere around 7:00 o' clock.
BENJAMIN R 2PO RTING SERVICE
I McGarry 19
.4 2
I just don't remember the exact time.
But the gate was 3
already closed and I was directed to the observation 4
center.
~'.
5 g
I now long did you stay at the observation 6
center?
7 A
Until around noon and I was directed to go home 8
and come back at midnight.
9 Q
Did you do that?
10 A
Yes, I did.
11 Q
You.came back at midnight?
12 A
Yes.
13 Q
what were your responsibilities at that 14 point?
15 A
Trying to organize, help organize the people that i
16 were there, but maintenance people.
At the time ohly l
1 l
l II the operations people were on the Island.
All of the f) 18 maintenance people were off the Island and we were 19 working from the observation center and our basic thing 20 was to, if they needed maintenance people, they would 21 call to the observation center and we would send people s.
22 over.
And that night I don't remember sending anybody 23 over.
24 Q
How long did you remain on the Island or l
25 at the observation center?
t
?
B ENJAMIN R EPO RTING SERVICE l
1 1
McGarry 20
.5 2
A We worked out of the observation center for about 3
a week and a half and then we moved back onto the 4
Island.'
c::.
5 Q
And for that week and a half your respon-6 sibilities were mainly the same?
7 x
y.
0 Q
During that period who did you report to?
9 I
A There were a number of people there.
It changed 10 from time to time.
The only one I can think of that 11 was there was Sandy Ware.
12 Q
And that is the particular individual you 13 reported to?
14 A
Yes.
15 Q
When you arrived here at approximately 7:00 16 a.m.
on March 28, who at that point told you to go home 17 and come back?
IO A
That happened around noon.
i
'9 Q
All right, at noon.
20 A
I think it was Rich Seiglit=.
H'e is the super-al visor of maintenance for Unit 2.
But I am not sure.
t oo Q
Between 7:00 a.m.
when you first arrived 23 and noon, you were just waiting at the gate?
91 A
No, at the observation center.
- 5 6
a Q
At any time were you involved with contacting BENJAMIN R EPO RTING SERVICE
I McGarry 21 9
3.6 members of the public?
3 3
4 Q
Did you contact any local official?
5 A
No.
6-Q Did you have communications with any State 7
agencies?
8 A
No.
9 Q
You indicated in your testimony earlier 10 that you did have some contact with the public on that 11 day.
What was that contact?
12 MR. YUSPEH:
Excuse me.
I don't think he 13 said that.
You can read the record back. I 14 think he made a general statement that occasionally 15 he.has contact with the public.
16 MS. GOLDFRANK And I believe he indicated 17 that on the day of the accident he did.
18 MR. YUSPEH:
Mr.'McGarry, did you have any 19 contact with the public on the day of the acci-20 dent?
01
~
{
THE WITNESS:
Two people stopped me and asked me what was going on, and I told them we 23 had a problem on the Island and I didn't have any 24 other details.
25 Q
Where did they stop you and ask you hat?
t SENJAMIN R EPORTING S ERVICE l
1
4 1
McGarry 22 o
3.
7 A
In the parking lot of the observation center.
3 Q
You did not know who these two people were?
4 A
No, I did not.
\\
5 Q
aut was the only contact you had?
6 A
That was the only contact I had.
I Q
Is it correct to state that your respon-O sibilities from approximately midnight on March 28 and 9
for about a week and a half encompassed maintenance 10 concerns?
11 3
y,,,
12
?
P.S. GOLDFRANK Do you have any questions?
MR. YUSPEH I have none.
14 G
I have no further questions at this time.
15 We would recess this deposition.
We don't 16 anticipate that we would have you come back to 17 ask you further questions, but it is possible that 18 we would call you back.
19 A
Yes.
"O
~
(The deposition was adjourned at 4:40 p.m.)
t 22 John James McGarry subscribed and sworn to before me "3
this-------day of---------
, 1979 24 l
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Notary Public B ENJAMIN R EPORTING SERVICE a w
1 23 IE9I3 3
HI;ggsg ggagg; 4
John James McGarry, Sr.
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McGARRY DEPOSITION 10 ggg,gggy;;gggggggg g3gg 11
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1 Resume of John James McGarr; 3
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l SENJAMIN R EPORTING SERVICE t
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GEBIIIIG&IE STATE OF NEW YORK
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COUNTY OF NEW YORK
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5 We, STANLEY RUDBARG, Certified Shorthand 6
Reporter and Notary Public of the State of New York, and 7
STEPHEN McCRYSTAL, a Notary Public of the State of New 8
York, do hereby cortify that the foregoing deposition 9
of JOHN JAMES McGARRY was taken before us on the 20th 10 day of July, 1979.
11 The said witness was duly sworn before the 12 commencement of his testimony that.the said testimony 13 taken stenographically by ourselves and then was 14 transcribed.
15 The within transcript is a true record of 16 the said deposition.
17 We are not related by blood or marriage to I
any of the said parties, nor interested directly or 19 indirectly in the matter in controversy, nor are we in 20 the employ of any of the counsel.
21
/
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(
IN WITNESS WHEREOF, we have hereunto set 22 our hands this______ day of __________,1979.
23 l
24 25 STANLEY RUDBARG, CSR STPHEN McCRYSTAL
\\
SENJAMlN R EPO RTING S ERVICE l
1