ML20235J127

Deposition of Rd Parks.* Vols II & III of Transcript of Rd Parks 870624 Deposition.Related Correspondence

ML20235J127
Person / Time
Site:	Three Mile Island
Issue date:	06/24/1987
From:	Parks R GENERAL PUBLIC UTILITIES CORP.
To:
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ML20235J103	List: ML20235J099 ML20235J127
References
CIV-PEN, EA-84-137, NUDOCS 8707150405
Download: ML20235J127 (23)

Text

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. CERTIFIED' COPY UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE. LAW JUDGE

. \

IN THE MATTER OF 3 GPU NUCLEAR CORPORATION, THREE MILE ISLAND NUCLEAR C v 1 Pe it ATION NO. 2 License No. DPR-73 EA 84-137 DEPOSITION OF RICHARD DALE PARKS June 24, 1987 VOLUME III BARKLEY COURT REPORTERS 4000 MAC ARTHUR BOULEVARD. SUITE 5500 REPOR' ED BY: NEWPORT BEACH. CAllFORNIA 92660 (714)752 1090 PENNY SANDER, CSR #4769 2566 OVEM.AND AVENUE. SUITE 570 FILE NO.87-248 LOS ANELES CALIFORNIA 90064 (213)202 6666 8707150405 B70713 -

PDR .ADOCK 05000320PDR G

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' 1( ACCOMMODATEDTHE WITNESS.  ;

.2-' 'O BYLMR.-HICKEY: -II.WOULD, MR. PARKS,idVST-LIKE .

3 TO ASK A FEW MOREfQUESTIONS BECAUSE ! THINK IT'WOULD BE 4 HELPFUL,'BUT-THEN l'LL BE SURE TO'STOP BY 11:30.- )

5 A WELL, IF YOU'RE SURE.WE'RE. GOING'TO' CONT'INUE' s  !

6: ON TO 11:30.THAT'l-SUGGEST WE COVER TERRITORY THAT HASN'T .)

'7- BEEN COVERED PREVIOUSLY.

8 Q WELL, LET'S GET RIGHT TO.!T THEN.

9 DO YOU-REMEMBER.BEING INTERVIEWED 18Y- I 10 DAVID FEINBERG OF THE DEPARTMENT OF.; LABOR IN'THE COURSE OF -j 1

~

11 YOUR INVESTIGATION OF YOUR. HARASSMENT' COMPLAINT?-

12 A YEP. I DO, SIR.- .

)

13 Q AND JUST TO PLACE IT IN' ALT.!ME FRAME FOR YOU, j 14 THERE ARE TWO STATEMENTS THAT.HAVE PREVIOUSLY BEEN .

15 PRODUCED, ONE DATED APRIL 20,'1983-AND'ANOTHER~ DATED 1 16 MAY 2, 1983. DO YOU RECALL THAT.YOU MET WITH MR. FEINSERG'i 17 ON OR ABOUT THOSE DATES?

18 A AT THIS POINT IN TIME, SIR, I CAN ONLY STATE i

19 THAT I MET WITH MR. FEINBERG. I REALLY COULDN'T;TELLoYOU '

20 ACCURATELY ABOUT THE DATES I MET WITH HIM.

H 21 Q ALL RIGHT. DID YOU MEET WITH HIM MORE THAN 22 TWICE?

23 A- I DON'T BELIEVE 50. AT LEAST AT[THIS P'OINT 24 IN TIME, I CAN'T RECALL THAT !~DID.

1 25 Q DID YOt1 TELL MR.-FEINBERG ON EITMER OF'THOSE:

III-76

1 OCCASIONS THAT YOU HAD PREVIOUSLY HAD IN YOUR POSSESSION 2 BUSINESS CARDS Ot1 QUILTEC STOCK WITH YOUR NAME AND THE 3 DESIGNATION OF YOU AS CONSULTANT?

i 4 A COULD YOU RUN THAT PAST ME -- PROVIDE THE 5- DEFINITION OF WHAT YOU MEAN SY "QUILTEC STOCK."

6 Q WELL, A BUSINESS -- THE BUSINESS CARD THAT 7 YOU TOLD US A3OUT YESTERDAY, MR. PARKS, THE BUSINESS CARD I

8 THAT hAS THE QUILTEC NAME AND LOGO ON IT.  ;

9 A IS THAT CONSIDERED STOCK?

l 10 Q IT'S A WORD THAT I USE.

11 A WELL, SUBJECT TO ANY OTHER DEFINITION OF THAT 12 WORD THAT YOU'RE USING THAT l'M. UNAWARE OF, I DON'T 13 RECALL, AT THIS MOMENT, IF IT CAME UP IN THE CONVERSATION l 14 OR NOT.

15 Q DID YOU TELL MR. FEINBERG, ON ANY OCCASION, 16 ABOUT YOUR INVOLVEMENT IN GETTING QUILTEC AND MR. SLONE 17 PLACED AT LILCO AT THE SHOREHAM JOB?

18 A I BELIEVE I MAY HAVE, SIR, BUT AT THIS POINT 19 IN TIME, I CANNOT RECALL IF I TOLD HIM THAT OR NOT.

20 Q DID YOU TELL MR. FEINBERG THAT YOUR RESUME 21 HAD SEEN TYPED ON QUILTEC LETTERHEAD?

22 A AGAIN, SIR, MY RECALL, AT THIS POINT IN TIME, 23 DOES NOT REALLY PROVIDE A WHOLE LOT OF DETAILS REGARDING 24 THE CONVERSATIONS THAT I HAD WITH MR. FEINBERG.

25 Q WELL, l'LL JUST ASK ONE MORE.

111-77

Y I

l'

.DIOLYOU TELL1MR. FEINBERG THAT YOUR RESUME.ON j l

2 QUILTEC LETTERHEAD WASl ATTACHED TO .THE.QUILTEC BEAVER'

.]

3 VALLEY PROPOSAL?  !

l 4 A AGAIN, SIR,'AT THIS POINT-IN ~ TIME, , I DON'.T

$ KNOW IF I TOLD HIM THAT OR NOT. I DON'T REMEMBER'IT BEING i

6 DISCUSSED OR~I-JUST DON'T REALLY RECALL. I 7 MR. HICKEY: LET ME ASK THE REPORTER.-TO MARK THIS l l

8 DOCUMENT AS THE NEXT EXHIBIT WHICH WOULD BE $7.

9 (WHEREUPON PLAINTIFF'S RESPONDENT'S 57 WAS g 10 MARKED FOR IDENTIFICATION-BY THE NOTARY PUBLIC,' AND'ARCOPY 11 IS ATTACHED HERETO.)

12 Q BY MR. HICKEY: M R '. PARKS,.I'M HAVING THE 13 REPORTER SHOW YOU A DOCUMENT WHICH HAS BEEN MARKED AS I 14 EXMIBIT 57. YOU'LL SEE THAT IT'S A' HANDWRITTEN' STATEMENT 15' ON DEPARTMENT OF LABOR PAPER THAT'S TITLED "ENTERVIEW 1 ,

16 NOTES, RICHARD PARKS, MAY 2, '83, RICHARD PARKS' HOME IS lI

{,

.. 17 GIVEN AS THE PLACE. !T'S SIX PAGES AS WE HAVE IT HERE. i 18 THE FIRST QUESTION I WANT TO A fiK YOU IS 19 WHETHER YOU'VE SEEN THAT BEFORE?

20 A I REALLY COULON'T'TELL YOU, AT THIS' POINT IN 21 TIME, IF I HAVE OR NOT. I DON'T HAVE ANY REASON FOR 22 DOUBTING THAT I HAVE. BUT 1 CAN'T REALLY SAY THAT I HAVE.

23 Q OKAY. IF .YOU'LL.LOOK AT THE PAGE, IT'S THE 24 THIRD PAGE IN, BUT IT'S MARKED NUMBER 2 AT THE TOP. DC 25 YOU SEE IT?

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. 1- A~ OKAY.

2- Q LET ME JUST SAYSTHAT IT APPEARSLFROM THE 3' EXHIBIT.THAT ON MAY 2, MR. FE!NSERG.ANDLYOU AND MR. DEVINE ..

4 DISCUSSED ATTORNEY RICHARDSON'S RESPONSES TO'YOUR' 5' COMPLAINTS.

s 6' A WOULD.YOU! START IT'OVER.AGAIN? 1. DON'T THINK J

7 I FOLLOWED EVERYT'HING YOU JUST SAID.

8 Q l WAS JUST TRYING PUT IT IN CONTEXT FOR YOU.

9 THE EXHIBIT SAYS ON THE FIRST-PAGE THAT MR.'FEINBERG, YOU, 10 AND MR. DEVINE, ON THIS DATE DISCUSSED ATTORNEY 11 RICHARDSON'S RESPONSES TO PARKS' COMPLAINTS. AND I

~

12 THOUGHT THAT MIGHT BRING THE MEETING BACK'TO YOUR M I ND .-

1 13 A CORRECT ME, IF I'M WRONG SIR, ISN'T THIS 14 NOTES OF MR. FSINBERG'S INTERVIEW WITH ME AFTER THE 15 COMPANY HAD REFUSED TO ACCEPT THE DEPARTMENT OF LABOR'S 16 FINDINGS THAT I SHOULD BE PUT BACK TO WORK?

- 17 IF I RECALL THE SEQUENCE OF EVENTS CORRECTLY, 18 SOME TIME IN APRIL, THE DEPARTMENT OF LABOR ISSUED --

19 FIRST PART OF MAY, SOMETHING LIKE THAT, THE DEPARTMENT OF 20 LABOR ISSUED A STATEMENT SAYING, YOU'4 OW, THIS IS -- THIS 21 15 WHAT WE FOUND AND ALL LIKE THAT.

22 I SEEM TO RECALL HAVING A MEETING -- IN MY 23 INITIAL INTERVIEW WITH MR. FEINBERG,' TOM DEVINE WAS NOT 24 PRESENT.

25 Q THAT MAY WELL 8E. I-MEAN THERE.IS ANOTHER III-79 I $

- _ _ _ _ _ _ = _ _ _ _ _ -

... 1

-j

-1 . INTERVIEW: REPORTED WHICH .!S' APRIL 20, AND IT JUST{SAYS' 2 IT'S A STATEMENT OF' RICHARD PARKS. IT DOESN'T INDICATE l j

.3 WHETHER MR'. DEVINE WAS PRESENT OR NOT.

y 4~ A HE WAS NOT PRESENT. NOT WITH MY INITIAL 5 ' INTERVIEW WITH MR.'FEINSERG'. ,

i 6 Q RIGHT. I 7 BUT_! WANT --

'THE' MATTER I WAS INTERESTED'IN' 8 ASKING.YOU.ABOUT WAS'ON.THE SECOND INTERVIEW.

9 A OKAY.

10 Q I. DON'T KNOW IF IT WAS BEFORE OR AFTER THE 11 LABOR DEPARTMENT INTERVIEW.

12 A OH, WELL I --

l 13 Q IT WOULD BE ABOUT THE SAME TIME, BUT l'M NOT 14 SURE EXACTLY WHEN.

15 OKAY. AT THE SECOND MEETING'WHER'E MR. .DEVINE 16 WAS PRESENT, IF YOU'LL LOOK ON PAGE -- THAT'S NUMBERED 2.

. 17 IT SAYS " PARKS' R E S P.O N S E , COMPANY'S FACTUAL DESCRIPTION 18 ABOUT AIGHT."

19 I GUESS --

PUT IT IN CONTEXT FOR YOU. YOU 20 SHOULD START ON THE PAGE BEFORE, DOWN AT THE BOTTOM OF THE 21 PAGE, " CHARGE, INTERROGATION OF. PARKS BY BECHTEL EXECUTIVE I 22 INTERNAL AUDITOR ABOUT QUILTEC MATTER WAS RETALIATORY."

23 AND THEN " COMPANY RESPONSE" IS THE NEXT ENTRY. " PROPER j 24 INQUIRY. IN JULY, AUGUST, 1982 PARKS SAID HE ARRANGED FOR 25 A BECHTEL SECRETARY TO TYPE AFTER HOURS SOME PERSONNEL 111-80

l 1- INFORMATf0N. SHEETS ON A NUMBER OF GPU-N ENGINEERS'IN 2 RESUME FORM. PARKS' PAID $75 TO HER." 1 CAN'T READ THE 3 LITTLE' WORD THAT GOES WITH'THAT.. ]

4 A I CAN'T READ ANY OF THOSE FEW LITTLE WORDS.

5" Q THEN ON THE NEXT PAGE, " PARKS' RESPONSE.

6 COMPANY'S FACTUAL DESCRIPTION ABOUT.RIGHT, FAVOR TO HIS I

7 BOSS, KING, WORKED ~ EOR AN INTERESTED TYPIST."

8 A I DON'T --

9 Q " LOOKED FOR AN INTERESTED TYPIST.

10 GAVE HER. COPY," I BELIEVE THAT'S.AN l 1

11 ABBREVIATION FOR, "OF OWN RESUME FOR FORMAT. )

1 12 THOUGHT OF SEVERAL ON TMI AND SEVERAL NOT.

l 13 MAXIMUM 8 TO 12 PEOPLE. THE TYPIST WAS 1 l

14 SOMEONE REFERRED TO HIM BY THE GIRL ORIGINALLY J

15 ASKED. YET A FORM OF HARASSMENT,'AN ISOLATED 16 INNOCENT INCIDENT SEIZED UPON FOUR DAYS 17 AFTER HE HAD COMPLAINED TO NRC ABOUT 18 BOB ARNOLD'S PERSISTENT QUESTIONING OF KING 19 ABOUT PARKS' KNOWLEDGE OF QUILTEC ACTIVITIES."

20 DOES THAT REFRESH YOUR RECOLLECTION, 21 MR. PARKS, ABOUT WHETHER YOU INFORMED MR. FEINBERG, AT j 22, LEAST AT THIS INTERVIEW, OF ANY INFORMATION ABOUT.YOUR 23 QUILTEC BUSINESS CARDS, YOUR EFFORTS AT LILCO, YOUR RESUME j 24 ON QUILTEC PAPER OR YOUR QUILTEC RESUME BEING ATTACHED TO 25 THE BEAVER VALLEY PROPOSAL?

111-81

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'i 1 A NO, IT DOES NOT.

2 Q IN THE COURSE OF YOUR MEETINGS WITH 3 MR. FEINBERG, DID HE ASK YOU TO TELL HIM ALL OF YOUR 1

4 CONTACTS OR CONNECTIONS WITH QUILTEC? l

$ A AGAIN, SIR, AT THIS POINT IN TIME, 1 COULD s

6 NOT RECALL --

OR I CANNOT RECALL THE EXACT LINE OF l i

7 QUESTIONING OR ANYTHING THAT MR. FEINBERG AND 1 DISCUSSED.

I 8 BUT I CAN TELL YOU THAT I DID NOT INTENTIONALLY TRY TO j 9 WITHHOLD OR NOT DISCLOSE ANY INFORMATION THAT I COULD l l

10 RECALL TO MR. FEINBERG. I 2 I 11 Q 00 YOU HAVE ANY OTHER RECORD OF THIS --

OF i

12 YOUR MEETINGS WITH MR. FEINBERG EITHER ON APRIL 20 OR 13 MAY 2, '83 OTHER THAN THESE TWO STATEMENTS THAT ARE PART 14 OF THE DEPARTMENT OF LABOR REPORT? l 15 A 'I THINK, AT ONE POINT IN TIME, THAT THERE WAS 16 A --

I BELIEVE IT WAS THE INITIAL INTERVIEW WHEN

. 17 TOM DEVINE WAS NOT PRESENT THAT I RECORDED THE 18 INTERVIEW --

NOT THE INTERVIEW, BUT RECORDED THE STATEMENT 19 THAT MR. FEINBERG READ OVER THE PHONE TO TOM DEVINE. BUT 20 WHEN I SAY " RECORDED," MR. FEINBERG WAS FULLY AWARE OF IT; 21 THAT I WAS HOLDING THE TAPE RECORDER RIGHT BY THE 22 MOUTHPIECE ON THE PHONE THAT HE WAS SPEAKING.

23 Q BUT YOU NO LONGER HAVE THAT?

24 A I, AT THIS POINT IN TIME, COULD NOT TELL YOU 25 WHATEVER BECAME OF THAT TAPE.

111-82

c CERTIFIED COPY-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

.O.

BEFORE THE ADMINISTRATIVE LAW JUDGE ,

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IN THE MATTER OF-- ,

GPU NUCLEAR CORPORATION, Docket No. 50-320.

THREE MILE ISLAND NUCLEAR Civil Penalty STATION NO. 2 License No. DPR-73 EA 84-137 6

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DEPOSITION OF RICHARD DALE PARKS l June 23, 1987 )

1 VOLUME II  !

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i l

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BARKLEY COURT REPORTERS 4000 MAC ARTHUR BOULEVARD. SulTE 5500 REPORTED BY:

. NEWPORT(714)7BEACH., CALIFORNIA 92660 2 1090 PENNY SANDER, O cSR a4769 FILE NO.87-244 2,ee OvERLANo AVENUE. sui 1Es70 LOS ANGELES. CALIFORNIA 90064 'l (213)202 6666

f 1 A' l' BOUGHT AND RESOLD WICKER. l 2 Q YOU'SAID-WICKER? l 1

p- 3 A WICKER, YOU KNOW, LIKE FURNITURE, THAT TYPE l kN

'4 OF THING. BOUGHT IT FROM IMPORTERS AND SOLD IT-TO THE 5 PUBLIC.

6 Q LET.ME ASK YOU TO JUMP BACK CHRONOLOGICALLY. i 7 EVEN BEFORE YOU HAD MISS RITTLE TYPE THESE RESUMES AND 8 THIS PROPOSAL, YOU HELPED QUILTEC GET STARTED AT SHOREHAM, 'q DIDN'T YOU, MR. PARKS? f 9 <

10 A YES, SIR. IF IT HAD NOT BEEN FOR'MY-

-l 11 ACTIVITIES, QUILTEC WOULD NEVER HAVE HAD'A JOB AT

'i 12 SHOREHAM.

13 Q WHAT DID YOU DO TO ASSIST THEM7 I

14 A WHEN I WAS READY TO LEAVE SHOREHAM, THE 15 ASSISTANT STARTUP TEST MANAGER'OR THE TEST MANAGER ASKED l

16 ME IF 1 KNEW OF SOMEONE THAT ME COULD REPLACE ME WITH. I 17 AND 1 TOLD HIM, WELL, I KNEW A GENTLEMAN THAT HAD HIS OWN 18 COMPANY WHO WOULD PROBABLY CONSIDER IT, AND THAT WOULD-BE l l

19 BEN SLONE. l 20 50 BEN SLONE AND TMIS GUY TALKED, AND THEY 21 MORE OR,LESS REACHED A VERBAL AGREEMENT. AND THAT 22 GENTLEMAN TOLD ME THAT IF I COULD GET A P.O. APPROVED  ;

2F BEFORE I LEFT, HE'D SIGN IT. 50 I GOT A P.O. APPROVED F OR. I

. I 24 HIM SY TAKING IT THROUGH THE REQUISITE CHAIN OF . COMMAND i 25 THERE AT SHOREHAM. 50 BEN SLONE WENT TO WORK AT SHOREHAM.

(2) l 11-203 l I

I

'~~

1 AS QUILTEC.

'2 Q AT THE TIME YOU'WERE DO!NG THAT, I ASSUME YOU 3 'WERE' AWARE OF MR. KING'S INVOLVEMENT IN QUILTEC','WERE YOU

~4 NOT? , j 5

A 1 THINK SOMEWHERE BACK'IN'1981 OR 1982 j

'6 BEN SLONE AND I HAD A' CONVERSATION THAT LEFT.ME WITH THE 7 BELIEF THAT LARRY KING MAY'HAVE'BEEN INVOLVED 11N Q U I L' T E C .

8 Q IS IT YOUR' TESTIMONY THAT ATLTHE TIME ~YOU 9 HELPSD GET QUILTEC ENSCONSED AT SHOREHAM, THAT YOU DIDN'T 10 KNOW WHAT MR. KING'S STATUS WAS IN THE COMPANY?

11 .A THAT'S BASICALLY TRUE. I WAS NOT 100 PERCENT J

12 CERTAIN OF WHAT LARRY KING'S POSITION WAS IN THE COMPANY.

13 Q DID YOU EVER ASK MR. SLONE7 14 A I DON'T RECALL, AT THIS MOMENT, IF BEN AND I 15 EVER DISCUSSED THAT. ,

16 Q EVEN IF YOU WEREN'T 100 PERCENT SURE, WHAT I

17 DID YOU UNDERSTAND WAS MR. KING'S POSITION IN THE COMPANY?

F 18 A AT THIS POINT IN TIME, I REALLY COULDN'T SAY.

19 HE'D ONLY PUT UP THE MONEY, YOU KNOW, AND LIKE PERSONAL 20 GUIDANCE, THAT TYPE OF THING.

21  :: ,Q 00 YOU RECALL SPEAKING TO A MR. TOM 22 PA!. ANTONIO AT THE SHOREHAM FACILITY ABOUTEBRINGING'SLONE

, 2 3 AND QUILTEC ON BOARD?

i 24 -

A THAT COULO HAVE'BEEN THE GENTLEMAN'S hAME.

I 25 Q RECOGNIZE THE NAME, DON'T YOU?11-204

.-.......R 1- A NO, SIR.

2 Q DID YOU EVER?

I 3 A NOT THAT ! CAN RECALL. j l

4 Q DO YOU HAVE ANY QU!LTEC BUSINESS CARDS OR 5 STATIONERY?

6 A I HAD SOME QUILTECsBUSINESS CARDS LARRY KING 7 GAVE TO ME AS A GIFT.

8 Q WHEN WAS THAT?

9 A HAD --

OH, PROBABLY RIGHT ABOUT THELSAME TIME I

10 HE ASKED ME TO GET THE TYPING DONE, RIGHT AFTER BEN SLONE l 11 WENT TO WORK AT SHOREHAM.

l 12 Q WHAT DID THE BUSINESS CARD SAY?

13 A " CONSULTANT."

i 14 Q HAD YOUR NAME ON TMEM?

15 A YES. AND I TOLD LARRY KING AT THE TIME I l 16 THOUGHT IT WAS IMPROPER BECAUSE I WASN'T EMPLOYED BY 17 QUILTEC. AND HIS RESPONSE TO ME WAS SOMETHING ALONG THE j

~ i 18 LINES THAT, YOU KNOW, HE WAS JUST DOING IT TO SHOW HIS 19 APPRECIATION FOR ME HELPING BEN OUT. l 20 Q LET ME UNDERSTAND.

21 - . TO SHOW HIS APPRECIATION TO YOU FOR HELPING 22 BEN SLONE, YOU MEAN, GET THE JOB AT LILCO?

, 23 A YES.

24 Q MR. K'ING GAVE YOU A PRESENT, RIGHT, A GIFT? .

25 A RIGHT. HE JUST GAVE ME A BOX OF BUSINESS  !

Il-210

1 CARDS..

~

2 Q THE GIFT WAS A BOX OF BUSINESS CARDS THAT 3 SAID " RICHARD PARKS, CONSULTANT FOR QUILTEC"?

4 A NO. IT SAYS "QUILTEC."

5 Q WELL, IT SAID "QUILTEC" ON THE BUSINESS 6 CARDS? 5 7 A I BELIEVE !T DID, YES.

8 Q  ! DON'T UNDERSTAND WHAT WAS WRONG WITH MY 9 STATEMENT. IT ISN'T FOR QUILTEC. IT SAYS "QUILTEC, INC.,

10 CONSULTANT, RICHARD PARKS"?

11 A NO.

12 IF I REMEMBER CORRECTLY IT HAD THE QUILTEC 13 LOGO, OKAY, WHICH, IF .I REMEMBER CORRECTLY, WAS SOME SORT 14 OF A QUILL PEN, AND HAD MY NAME ON IT AND DOWN AT THE 15 BOTTOM SAID " CONSULTANT," WHICH TO ME MEANS "I AM 16 EMPLOYED." I WAS A CONSULIANT TU THE COMPANY. AND 1 17 WASN'T.

18 Q WHY WERE YOU NOT?

19 A BECAUSE THE ADVICE'OR INFORMATION I EVER 20 HELPED THOSE GUYS WITH WAS JUST STRICTLY OUT OF THE FACT 21 THEYeWERE MY FRIENDS BECAUSE I NEVER RECEIVED ANY 22 REMUNERATION FOR ANY OF MY, QUOTE, UNQUOTE, " WORK" ON 2$ THEIR BEHALF.

24 Q WHAT DID YOU SAY TO MR. KING WHEN HE GAVE YOU 25 THIS GIFT?11-211

j'

1. A JUST'WHAT I HAVE'ALREADY SAID. I DIDN'T' 2 THINK.IT'WAS PROPER. I WASN'T AN EMPLOYEE OR CONSUL' TANT 3 IN QUILTEC.

4 Q WHAT DID YOU DO WITH THE CARDS?

5 .A I THREW THEM IN.MY DESK-AT' WORK.

6 Q WHY DID YOU 00 THAT, MR. PARKS? ,

7 A WELL, ! DIDN'T WANT TO OFFEND THE GUY BY 8 THROWING THEM AWAY. 'I DIDN'T KNOW WHAT ELSE TORDO WITH 9 THEM. I DIDN'T USE THEM. j 10 Q WAS MR. KING THERE WHEN YOU THREW THE' CARDS 11 IN YOUR DESK AT WORK?

i 12 A I DON'T BELIEVE HE WAS.

13 IF 1 REMEMBER CORRECTLY, THE --

SAY THE WHOLE <

14 EVENT HAPPENED AS 1 WAS WALKING OUT OF THE BRICK ADMIN 15 BUILDING, AND LARRY KING WAS PULLING UP. SY VIRTUE OF HIS 16 POSITION, HE COULD PARK THERE. AND HE. MOTIONED FOR ME OR 1

17 HOLLERED FOR ME. AND 1 WALKED OVER. AND'HE SAYS "HERE"

~

18 AND HANDED ME THIS BOX OF BUSINESS CARDS. AND I OPENED 19 THEM UP AND THAT'S WHAT THEY WERE. .

20 THEN THE DISCUSSION WE ALREADY TALKED ABOUT 21 HAPPENED, AND 1 WALKED ON DOWN TO MY DESK, WHICH AT THAT 22 TIME WAS DOWN AT THE GREEN ADMIN BUILDING. AND I JUST PUT. l l

25 THEM IN THE DRAWER IN MY DESK AND LEFT THEM THERE.

24 Q DID YOU TELL MR. KING WHAT YOU WERE GOING TO 25 DO WITH THE CARDS?

i

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4 1 A NO.

2 Q WHAT DID MR. KING.SUGGEST YOU DO WITH THE 3 CARDS?

4 A NOTHING.

5, Q. DIDN'T HE INDICATE TO YOU IN SOME WAY THESE 6 WERE FOR YOU TO USE, MR. PARKS? '

7 A I BELIEVE, SIR, I HAVE ALREADY ANSWERED THAT 8 QUESTION; THAT HE WAS MORE OR'LESS --

AT LEAST LEFT ME 9 WITH THE IMPRESSION THAT WAS JUST'HIS WAY OF SAYING 10 "THANKS FOR HELPING BEN OUT."

11 Q WELL, I'M ASKING YOU WHETHER MR. KING DIDN'T 12 INDICATE TO YOU IN SOME FASHION WHAT HE EXPECTED YOU TO 00 13 WITH THE CARDS?

14 A NO, SIR, HE DID NOT.

15 Q JUST GAVE THEM TO YOU AND DIDN'T GIVE ANY 16 CLUE WHAT USE YOU WERE TO MAKE.0F THEM?

17 A THAT'S CORRECT.

18 Q AND YOU TOOK THE BOX OF BUSINESS CARDS. DID 19 YOU TAKE THE WHOLE BOX AND JUST THROW IT IN YOUR. DESK OR 20 MOST OF IT OR SOME OF IT?

21 A I PUT THE BOX IN MY DESK.

22 Q WHEN WAS THAT, THAT KING GIVE YOU THIS. GIFT?

. 23' A MIDDLE OF THE YEAR, PROBABLY -- IT WAS BEFORE 24 FALL OF 1982.

25 Q SO YOU CAME BACK TO THE ISLAND MAY 0F '82.11-213

1 IT WOULD BE !M THE SUMMER OF MAY OF '82?

. i 2 A PROBABLY. I l

3 Q DID YOU.GIVE ANY THESE.QUILTEC BUSINESS CARDS

-4 TO ANYONE, MR. PARKS?

5 A I BELIEVE I GAVE ONE TO MY GIRL FRIEND, BUT I i 14

{

6 DON'T RECALL GIVING THEM TO ANYBODY IN THE BUSINESS WORLD. 1 J

7 Q ONE TO MISS QUACKENBUSH?

l 8 A RIGHT. l 9 Q AND YOUR TESTIMONY 15 THAT YOU DON'T RECALL  :

10 WHETHER YOU GAVE ANY TO ANYONE IN THE BUSINESS WORLD?

11 A  ! DON'T BELIEVE I DID, NO.

12 Q HOW LONG DID THE CARDS STAY IN YOUR DESK?

l 13 A I THINK THEY'RE --

JUST ABOUT RIGHT UP TO l i

I 14 WHEN I LEFT TMI.

15 Q DESCRIBE THE CIRCUMSTANCES WHEN YOU TOOK THEM 16 OUT.

17 A I TOOK THEM OUT AND THREW.THEM AWAY WITH THE 18 REST OF THE QUILTEC STUFF.

19 Q THIS WAS BEFORE YOU WERE INTERVIEWED BY 20 MR. HOFMANN?

i 21 .A I THINK I HAVE ALREADY TOLD-YOU BEFORE l-  !

22 DON'T RECALL EXACTLY WHEN ! THREW STUFF.AWAY, BUT I

.. 27 BELIEVE THE TIME LARRY KING WAS ESCORTED OFF THE SITE. ]

24 Q HAVE YOU EVER TOLD ANYONE BEFORE TODAY,  !

25 MR. PARKS, OTHER THAN YOUR LAWYER, OF COURSE, MR. KING HAD 11-214 4

0

1 GIVEN YOU QUILTEC BUSINESS CARDS THAT YOU KEPT UNTIL JUST 2 BEFORE -- UNT!L YOU THREW THEM AWAY WITH THE RESUME'AND 3' THE BEAVER VALLEY PROPOSAL?

4 A I DON'T KNOW IF I -- OR AT THIS MOMENT IN 5 TIME. I CAN'T RECALL TELLING ANYBODY THAT OR NOT.

6 Q YOU DON'T REMEMBER,IT APPEARING ON ANY OF 7 YOUR NRC STATEMENTS WHERE'THEY.WERE ASKING YOU ABOUT YOUR 8 CONNECTION WITH QUILTEC?

9 A I DON'T6. BUT AT THE PRESENT. TIME, l'CAN'T 10 RECALL IF IT'S IN ANY OF MY NRC STATEMENTS OR NOT.

11 Q WHEN YOU WERE TALKING TO THE NRC IN APRIL OR 12 MAY OF 1983 AND THEY ASKED YOU ABOUT YOUR QUILTEC 13 INVOLVEMENT, DID YOU FORGET TO TELL THEM ABOUT THE 14 BUSINESS CARDS?

15 A I DON'T KNOW. OR I GUESS WHAT I'M TRYING TO 16 SAY, AT THIS PRESENT TIME I CAN'T RECALL IF I TOLD THEM OR 17 NOT.

18 Q WELL, DO YOU WANT TO LOOK AT YOUR STATEMENTS, 19 THEY'RE THERE IN FRONT.0F YOU, AND SEE IF THERE'S SOME 20 REFERENCE IN THERE TO YOUR QUILTEC BUSINESS CAROS? YOU 21 MIGHT WANT TO LOOK. JUST SO YOU HAVE-THE NUMBER, 37, 38, 22 39 AND 40. BUT MOST OF YOUR QUILTEC INFORMATION IS IN 23 EXHIBIT 39, MR. PARKS.

24 A OKAY.

25 1 DON'T SEE ANYTHING SO FAR THAT REFERENCES11-215 j

1- -I T .

l DON'T THINK YOU'LL FIND.ANYTHING, 2 Q 3 MR. PARKS.

4 A YOU MAY BE RIGHT.

5 Q  ! BELIEVE YOU'RE TALKING ABOUT QUILTEC 6 BUSINESS CARDS, BUT I'ALSO ASKED'ABOUT'QUILTEC STATIONERY.

7 DID YOU HAVE ANY QUILTEC STATIONERY, AT-THIS POINT IN 8 . TIME, OTHER THAN THE STATIONERY YOU GAVE TO'RITTLE TO TYPE 9 THE RESUMES ON?

10 A I BELIEVE THERE MIGHT MAVE BEEN SOME LEFT !N 11 THE PACKAGE I HAD, BUT I COULDN'T TELL YOU, AT THIS POINT 12 IN TIME, IF THERE WAS OR NOT.

13 Q YOU DIDN'T TAKE THE EXTRA QUILTEC, STATIONERY-14 BACK TO MR. KING, DID YOU?

15 A 1 DON'T RECALL THAT I DID, NO. I MIGHT'HAVE 16 THOUGH. I DON'T REALLY RECALL AT THE MOMENT.

17 Q DO YOU HAVE ANY RECOLLECTION WHEN YOU MET 18 WITH THE LABOR DEPARTMENT, MR. FE!NBERG,~AFTER YOU FILED 19 YOUR RETALIATION CLAIM TELLING MR. FEINBERG THAT YOU HAD 20 HAD SOME BUSINESS CARDS GIVEN TO YOU BY.MR. KING WITH YOUR 21 NAMEcAND " CONSULTANT FOR QUILTEC" ON IT?

22 A I THINK YOU'RE MISCHARACTERIZING'WHAT'THE 23 BUSINESS CARDS SAY. IT DID-NOT SAY " CONSULTANT FOR 24 QUILTEC." !T JUST SAYS " CONSULTANT."

25 Q AND "QUILTEC"?11-216

1: A .RIGhT.

2 BUT TOLANSWER;YOUR' QUESTION, I CANNOTlTELL 3 YOU,LAT'THIS PRESENT. TIME,;!F MR. FEINBERG AND I DISCUSSED 4- THAT OR NOT.

5, Q l'M NOT SURE ABOUT THE' DISTINCTION ~THAT YOU 6 SEEM TO BE INSISTING ON. THE POINT YOU'RE. MAKING IS THAT-7 THE CARD DIDN'T HAVE THE WORD "FOR" ON !T; ISJTHAT~RIGHT?

8 A THAT'S TRUE.

'9 Q .THE, CARD' INDICATED, DID IT NOT,,THAT..YOU, .

10 RICHARD PARKS, WERE A CONSULTANT FOR QUILTEC, DIDN'T~ !T?

11 A UH-HUH.

12 Q DIDN'T '"O INDICATE TO ANYONE LOOKING AT 13 IT THAT RICHARD PARKS WAS A CONSULTANT FOR THE QUILTEC~

14 COMPANY? ,

15 A NOT IN MY OPINION, IT DIDN'T, NO.

16 Q WHAT DID YOU MEAN WHEN YOU SAID A CARD SAID 17 "QUILTEC, RICHARD PARKS, CONSULTANT"?

18 A JUST THAT, EXACTLY. 1 TOOK IT AT FACE VALUE.

19 THAT CARD NO MORE.MADE ME AN EMPLOYEE OR' CONSULTANT, . ! N, MY l

20 OPINION, FOR QUILTEC THAN IF YOU GIVE ME:ONE OF.YOUR 21 FIRM'S. BUSINESS CARDS WITH MY NAME AND THE. WORD 22 " CONSULTANT" ON IT. IT WOULD NOT'MAKE ME A CONSULTANT.FOR 23 QUILTEC NO MORE THAN IT WOULD MAKE ME A. CONSULTANT;FOR 24 YOUR FIRM.

25 Q. WELL, IF SOMEONE SAW A' CARD THAT SAID MY. LAW-

!!-217 j

1

-i 3 :J l FIRM'S NAME AND " RICHARD PARKS,. CONSULTANT," DO'VOU 2 BELIEVE THEY MIGHT THINK YOU WERE'A CONSULTANT EMPLOYED BY 3 MY LAW FIRM?

4 A THEY MIGHT; THEY MIGHT NOT.

]

5 Q WHAT WOULD YOU THINK IF YOU.SAW THE CARD?

6 A l'O ASK THE PERSONA 15 7 Q YOU WOULDN'T MAKE A CONCLUSION BASED ON THE-8 CARD?

9 A TRUE.

10 Q THERE WAS AN-NUS EMPLOYEE AT SHOREHAM~--

11 WELL, YOU KNEW TOM BULISCHECK, 00 YOU RECOGNIZE THE NAME, 12 WHO IS THE SITE LEAD AT SHOREHAM?

1 13 A NO, 1 DO NOT REMEMBER THE NAME. l 1

14 Q DO YOU REMEMBER TELLING SOMEONE WHO WORKED 15 FOR NUS AT SHOREHAM IN THE SUMMER OF 1982, EITHER JUST 16 BEFORE YOU RETURNED TO TMI OR SHORTLY THEREAFTER, THAT YOU 17 WERE PART OF QUILTEC? j j

18 A NO, SIR, I DO NOT.

i 19 Q DID.YOU GO BACK UP TO SHOREHAM AFTER YOU i 20 RETURNED TO EMPLOYMENT AT TM! IN MAY OF 1982?  ;

21 .A NO, SIR.

22 Q ON ANY OCCASION?

, 23 A NOT THAT I CAN RECALL, NOT AT THIS TIME.

24 Q ALL RIGHT. WITH THAT ADDITION'THEN LET ME 25 ASK YOU TO FOCUS SPECIFICALLY ON BEFORE YOU LEFT SHOREnAM.11-218

.1

.1

. J 1 YOU HAVE NO' RECOLLECTION OF SAYING TO MR. BULISCHECK'OR 2 -ANYONE ELSE AT SHOREHAM THAT YOU WERE PART OF QUILTEC?

3 A NO, 1 DO NOT.

4 Q DID YOU.HAVE ANY INDICATION FROM MR. KING,  ;

1 5 WHEN HE GAVE YOU THE. CARD, MR. PARKS, ABOUT WHAT IT WAS 6 THAT HE BELIEVED YOU HAD DONE T H'A T WARRANTED LISTING YOU 7 AS A CONSULTANT ~ON A BUSINESS CARD?

8 'A GETTING THE JOB FOR BEN SLONE UP AT SHOREHAM,  !

9 THAT WAS THE IMPRESSION I.GOT FROM HIM.

10 Q DID MR. KING EVER TALK TO YOU ABOUT DOING 11 OTHER THINGS IN THE FUTURE FOR QUILTEC?

12 A WELL, YEAH. HE ASKED ME TO GET THAT TYPING 13 DONE.

14 Q OTHER THAN THAT?

15 A NOT THAT 1 CAN RECALL AT.THE M O M E ,N T , BUT HE 3 16 MAY HAVE. HE MAY HAVE TALKED TO ME ABOUT OTHER T H I N G S-17 THAT HAD BEEN GOING ON. I KNOW -- LET ME REPHRASE THAT..

18 I CAN RECALL THAT LARRY, ON OCCASIONS, 19 MENTIONED TO ME ABOUT, YOU KNOW, MONEY'THAT BEN WAS MAYBE 20 BEING AND -- YOU KNOW, HOW THEY WERE REARRANGING THEIR 21 COMPAN.Y; AND ALL THAT. BUT AT THAT TIME' FRAME, 1 COULDN'T 22 REALLY PINPOINT.

., 23' Q l'M SORRY, I THOUGHT YOU FINISHED.

24 A l'M SAYING THE TIME FRAME THOSE CONVERSATIONS 25 TOOK PLACE, I COULDN'T REALLY PINPOINT,11-219 )

e

i 1 Q DID YOU EVER. TALK'TO MR. KING.ABOUT A 2 POSSIBLE ROLE FOR YOU IN QUILTEC IN THE FUTURE?

3 A NOT.THAT I CAN, RECALL.

4 Q. DID YOU EVER TALK.TO HIM ABOUT THE 5 POSSIBILITY OF YOU BEING ALLOWED TO PURCHASE STOCK IN 6 QUIL TEC ? '

7 A NOT THAT 1 CAN RECALL.

8 Q DO YOU REMEMBER GIVING'A COPY OF YOUR QUILTEC 9 BUSINESS CARD TO ED KITLER, MR. PARKS?

10 A I THINK ED KITLER MAY HAVE tiAD ONE OF THE-11 CARDS.

12 Q WHEN DID YOU GIVE IT TO HIM?

13 A PROBABLY THE SAME DAY I THREW THE BOX IN MY 14 DESK.

15 Q WHY DID YOU GIVE IT TO HIM?

16 A I THINK HE SAW THEM AND ASKED ME WHAT THEY 17 WERE AND 1 SHOWED HIM.

18 Q DID HE ASK FOR ONE?

19 A I DO NOT REALLY RECALL, AT THIS MOMENT, OR IF 20 I JUST "HERE, TAKE IT, GO AHEAD."-  !

21 .

.Q WHY DID YCU WANT TO GIVE MR. KITLER A COPY OF 22 YOUR QUILTEC BUSINESS. CARD?'

23 A THAT. IMPLIES 1 HAD A SPECIFIC REASON TO GIVE.

24 IT TO HIM, AND I DON'T RECALL MAKING SUCH A STATEMENT.

25 Q WELL, YOU HAD A REASON FOR GIVING HIM THE 11-220 4

2 A NO, NOT.SPECIFICALLY, NOT ONE THAT('I CAN'

-3 RECALL, AT THIS MOMENT'ANYWAY.

4 Q WHEN IS THE LAST TIME.YOU SPOKE TO E D . K I TL E R,.

5. MR. PARKS?- l 6 A I THINK PROSABLY L1'KE A. WEEK OR'SO'SINCE.I

'l 7 WAS SUSPENDED.

8 Q NOT SINCE? q l

9 A NO. J l

10 Q HAVE YOU HAD 'oY INDIRECT COMMUNICATION 11 WITH MR. KITLER MORE RECENTLY THAN A WEEK OR SO'AFTER YOU 12 WERE SUSPENDED?

l 13 A WHAT DO YOU MEAN BY " INDIRECT"? j d

14 Q WHERE SOMEONE HAS GIVEN YOU A MESSAGE TO 15 MR. KITLER OR YOU HAVE GIVEN A MESSAGE TO MR. KITLER?

16 A NO. !F I RECEIVED A MESSAGE INTENDED FOR 17 ME --

INTENDED FOR ED KITLER, THEN l'M UNAWARE OF IT.

18 Q  ! TAKE IT YOU HAVEN'T ANY WRITTEN 19 CORRESPONDENCE OR WRIT *- UnHmNICATION SHORTLY AFTER YOU 20 WERE SUSPENDED?

21 e 1A THAT'S TRUE, I HAVE NOT.

22 Q DID YOU TELL MR. JOHNSON BEFORE-YOU TEST!FIED

. 23 DURING THE DEPOSITION THIS AFTERNOON THAT YOU HAD A 24 QUILTEC BUSINESS CARD?

25 A I --

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