ML20238C804
| ML20238C804 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 06/24/1987 |
| From: | Parks R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310220 | |
| Download: ML20238C804 (89) | |
Text
ORIGINAL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE k
\
IN THE MATTER OF h GPU NUCLEAR CORPORATION' Docket No. 50-320 THREE MILE ISLAND NUCLEAR Civil Penalty S ION NO. 2 License No. DPR-73 EA 84-137
)
i D_EPO3ITION OF RICHARD DALE PARKS June 24, 1987 VOLUME III l
BARKLEY COURT REPORTERS 4000 MAC ARTHUR BOULEVARD, SUITE 5500 REPORTED BY: NEWPORT BEACH, CALIFORNIA 92660 (714)752 1090 PENNY SANDER, CAR 2566 OVERLAND AVENUE, SUITE 570 FILENo. # 4 7 6 9 LOS ANGELES, CALIFORNIA 90064 87-248 (213)202 6666 8712310220 871209 PDR ADOCK 05000320 T PDR
1 APPEARANCES:
2 FOR U.S. NUCLEAR REGULATORY COMMISSION: i 3 0FFICE OF THE GENERAL COUNSEL OF THE NUCLEAR REGULATORY COMMISSION '
4 BY: GEORGE E. JOHNSON, ESQ.
AND 5 GREGORY ALAN BERRY MAIL STOP 9604 6 WASHINGTON D.C. 20555 (301) 492-7445 7
FOR GPU NUCLEAR CORPORATION: l 8
l SHAW, PITTMAN, POTTS & TROWBRIDGE 9 A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 10 BY: J. PATRICK HICKEY, ESQ. j AND ;
11 DAVID R. LEWIS, ESQ.
2300 N STREET, N.W.
12 WASHINGTON D.C. 20037 (202) 663-8103 13 AND 14 THELEN, MARRIN, JOHNSON & BRIDGES 15 BY: KENNEDY P. RICHARDSON, ESQ. j ONE KAISER PLAZA, SUITE 1950 1 16 OAKLAND, CALIFORNIA 94612 (415) 893-5195 17 (NOT PRESENT) 18 19 20 21 1
22 23 24 25 111-3
1 I N 'D E X 2
3 EXAMINATION BY PAGE 4 MR. HICKEY .- - - - - - - - - - - - - - - --
-5
'S 6
7 E X H I B IT-S' 8
9 RESPONDENT'S DESCRIPTION INTRODUCED MARKED 10 52 CHECK LEDGER OR ACCOUNT 13' 13 LOG'OF QUILTEC 11 53 TIME RECORD OF GAITHERSBURG 27 27 12 OFFICE 13 54 HANDWRITTEN NOTES OF RICHARD 59 59 PARKS
.14 55 HANDWRITTEN NOTES OF MARK 62. 62 15 KOBI 16 56 HANDWRITTEN NOTES OF 69- 69 MRS. KING 17 57 U.S. DEPARTMENT OF LABOR 78 78' 18 INTERVIEW NOTES, 5/2/83
'19 20 e 21.
22-1 23 24-
'25 III-4 h;
1 i
1 1 UNITES STATES OF AMERICA 2 ' NUCLEAR REGULATORY COMMISSION l 3
4 BEFORE THE. ADMINISTRATIVE LAW JUDGE 5 (
l 6 1 7 IN THE MATTER OF ) ,
) DOCKET NO. 50-320 1 8 GPU NUCLEAR CORPORATION ) (CIVIL PENALTY) i
) .l; 9 (THREE MILE ISLAND S.UCLEAR STATION ) LICENSE NO.
NO. 2) ) DPR-73 10 ) EA 84-137 l
11 12 13 14 EXAMINATION OF RICHARD DALE PARKS 15 TAKEN ON BEHALF OF THE RESPONDENTS, AT !
16 4100 MAC ARTHUR BOULEVARD, NEWPORT BEACH, 17 CALIFORNIA, COMMENCING AT 9: 00 A.M., WEDNESDAY, ;
18 JUNE 24, 1987, BEFORE PENNY SANDER, CSR NO. 4769, 19 A NOTARY PUBLIC IN AND FOR THE STATE OF CALIFORNIA 20 AND COUNTY OF ORANGE.
21 22 23 24 25 III-2
l 1 RICHARD D. PARKS, 2 CALLEDJAS A WITNESS BY AND ON BEHALF OF THE RESPONDENT, 3 AND HAVING BEEN PREVIOUSLY DULY AFFIRMED BY THE NOTARY 4 PUBLIC, WAS EXAMINED ~AND TESTIFIED.AS FOLLOWS:
5
'6 EXAMINATION
- 7. BY MR. HICKEY:
8' Q MR. PARKS,.LET ME, IF I MAY CLEAR UP A COUPLE 9 0F LOOSE ENDS FROM YESTERDAY AFTERN00N'S' DISCUSSION.
10 YOU TOLD US ABOUT MR. DEVINE TALKING TO.
11 MR. AUGER BEFORE'YOUR' AFFIDAVIT WAS RELEASED IN LATE 12 MARCH 1983 TO. ATTEMPT TO VERIFY YOUR ALLEGATIONS. DID 1 13 UNDERSTAND YOU TO SAY THAT YOU ARE NOT AWARE OF MR. DEVINE l
-14 INTERVIEWING ANYONE BESIDES MR. AUGER BEFORE.YOU WENT 15 PUBLIC TO VERIFY THE ALLEGATIONS? LET ME TAKE AWAY THE 16 "D0 YOU UNDERSTAND."
17 DID MR. DEVINE, TO YOUR KNOWLEDGE, INTERVIEW.
18 ANYONE BESIDES MR. AUGER BEFORE YOU WENT PUBLIC IN AN. '
19 ATTEMPT TO VERIFY YOUR ALLEGATIONS?
20 A I THINK, SIR, WOULDN'T'IT FALL UNDER --
OR BE 21 PROTECTED UNDER THE ATTORNEY-CLIENT PRIVILEGE AND --
IF HE 22 WAS TO ADVISE ME OF WHO HE TALKED TO OR TO ANYTHING LIKE 23 THAT?
24 Q NOT ANYMORE THAN MR. AUGER.
25 A TO BE PERFECTLY HONEST WITH YOU, I COULD NOT III-5
)
1 TELL YOU, AT THIS MOMENT IN TIME, IF HE TALKED WITH OTHER 2 GENTLEMEN OR LADIES OR NOT.
3 Q YOU JUST DON'T KNOW?
4 A I JUST DON'T REMEMBER. i 5 Q DID MR. DEVINE TELL YOU WHAT AUGER SAID.TO
.l 6 HIM?
7 A IF I REMEMBER CORRECTLY, AT THE MOMhNT IT WAS (
4 8 JUST A STATEMENT CORROBORATING WHAT I HAD SAID IN MY 9 ORIGINAL AFFIDAVIT.
10 Q LET ME SEE IF I CAN CLARIFY THAT JUST A 11 LITTLE.
12 IS YOUR TESTIMONY THAT MR. DEVINE SIMPLY TOLD 13 YOU IN CONCLUSIONARY TERMS THAT MR. AUGER CORROBORATED 14 YOU?
i 15 IF THE QUESTION -- i 16 A' DO I UNDERSTAND YOU TO SAY THAT MR. DEVINE I
17 DREW A CONCLUSION THAT MR. AUGER CONCURRED WITH EVERYTHING 18 I SAID?
19 Q LET ME TRY TO MAKE THE QUESTION CLEAR FOR YOU i
20 BECAUSE I'M TRYING TO GET IT AS SHARPLY FOCUSED AS 1 CAN ]
1 21 FOR YOU. I 1
j 22 l'M TRYING TO UNDERSTAND WHETHER MR. DEVINE l l l 23 QUOTED TO YOU IN SUBSTANCE THE WORDS THAT MR. AUGER GAVE l
24 TO MR. DEVINE OR WHETHER MR. DEVINE SIMPLY TOLD YOU THE 25 CONCLUSION OF WHAT HE, DEVINE, UNDERSTOOD FROM HIS ,
III-6 l
1 CONVERSATION WITH AUGER 7 DID HE GIVE YOU THE RAW 2 CONVERSATION OR DID HE GIVE YOU THE CONCLUSION? .;
3 A WELL, IF I REMEMBER CORRECTLY, AT THE TIME, 4 AT THIS MINUTE ANYWAY, I BELIEVE I WAS THERE IN THE ROOM 5 WHEN TOM DEVINE WAS ENGAGED IN THE CONVERSATION WITH 6 JOHN; AUGER, AND I CAN'T REALLY RECALL THE EXACT WORDS THAT 7 TOM DEVINE TOLD ME.
8 Q DID YOU HEAR THE CONVERSATION, IN OTHER 9 WORDS, BETWEEN DEVINE AND AUGER?
10 A I BELIEVE IT WAS A PHONE COMMUNICATION,. SIR. j 11 Q I SEE. WHAT ROOM WERE YOU IN?
12 A SAME ROOM THAT TOM DEVINE WAS IN.
13 Q I MEAN IN WASHINGTON. I 14 A RIGHT, 15 Q DO YOU KNOW THE DATE?
16 A NOT OFF THE TOP OF MY HEAD, I DON'T. IT WAS 17 BEFORE I WENT PUBLIC THOUGH.
18 Q AND I TAKE IT YOU WERE NOT ON AN EXTENSION 19 PHONE LISTENING TO THE CONVERSATION --
LISTENING TO BOTH 20 ENDS OF THE CONVERSATION?
-21 A I CAN'T REALLY RECALL, SIR, IF IT WAS A 22 SPEAKER-TYPE PHONE OR NOT, BUT I WAS NOT ON AN EXTENSION, 23 NO.
24 Q OKAY. IT MAY HAVE BEEN A SPEAKERPHONE OR YOU 25 MAY HAVE BEEN HEARING ONLY HALF OF THE CONVERSATION; IS I
III-7
___--_-__-_-_-_-___a
I t
i 1 THAT WHAT YOU'RE SAYING? YOU DON'T KNOW7 j 2 A I JUST DON'T RECALL AT THE MOMENT.
3 Q DO YOU HAVE AN OBJECTION TO MR. DEVINE {
i 4 TELLING US WHAT MR. AUGER TOLD HIM7 5 A IN THE EXTENT THAT IT WOULD NOT COMPROMISE k
6 ANY ATTORNEY-CLIENT PRIVILEGE, I THINK THAT DECISION WOULD l
7 BE BEST REFERRED TO TOM DEVINE.
8 .Q WELL, IN THE EVENT THAT THERE IS A CLAIM THAT 9 THE INFORMATION IS PRIVLEGED, I THINK MR. DEVINE WOULD l 10 WOULD REFER IT BACK TO YOU BECAUSE THE PRIVILEGE IS YOURS, 11 IF THERE IS AN ATTORNEY-CLIENT PRIVILEGE, TO WAIVE OR NOT 12 .TO WAIVE.
l 13 A I GUESS, IF I UNDERSTAND YOUR STATEMENT l 14 CORRECTLY THEN, SIR, I WOULD SAY, YES, I'D HAVE SOME 15 PROBLEM WITH IT BECAUSE IT WOULD BE DIVULGING THE i
16 ATTORNEY-CLIENT PRIVILEGE, IF 1 UNDERSTAND YOUR PREFACE 17 CORRECTLY.
18 Q WELL, OF COURSE YOU CAN ALSO CONSULT WITH I
19 MISS ZURAS, IF YOU'D LIKE YOUR OWN COUP:SEL'S INFORMATION ]
l 20 ABOUT IT. I'M JUST TELLING YOU WHAT I GENERALLY )
I 21 UNDERSTAND THE LAW TO BE. l J
- 22. THE REASON I ASKED YOU, MR. PARKS, INSTEAD OF 23 ASKING MR. DEVINE WAS BECAUSE MY UNDERSTANDING IS THAT THE 24 PRIVILEGE, WHEN IT EXISTS, BELONGS TO THE CLIENT, RATHER l
25 THAN TO THE ATTORNEY. SO IF YOU HAD NO OBJECTION TO US --
III-8
1 l
L -1 TO MR. DEVINE TELLING US WHAT AUGER TOLD HIM, THEN ,
2 MR. DEVINE COULDN'T REALLY HAVE AN OBJECTION BASED ON 3 ATTORNEY-CLIENT PRIVILEGE.
4 A WELL, SIR, I WOULD BOW INDIFFERENCE TO THE 5 GREATER COMMAND OF THE LAWS REGARDING ATTORNEY-CLIENT 6 . PRIVILEGE. BUT IF I UNDERSDTANSTAND IT CORRECTLY, THEN 3
7 l'M GOING TO HAVE TO REFUSE YOU. I WOULD HAVE A GREAT 8 PROBLEM WITH SACRIFICING THE ATTORNEY-CLIENT PRIVILEGE.
9 Q ONE OTHER MATTER THAT WE ADDRESSED YESTERDAY 10 AFTERNOON, MR. PARKS, HAD TO DO WITH YOUR -- THE TWO 11 RESUMES WE WERE LOOKING AT. YOU RECALL ONE OF THEM WAS 12 YOUR NUS RESUME WHICH HAD A RECEIVED STAMP FROM ABOUT 13 APRIL 1982 ON IT, BECHTEL RECEIVED STAMP; AND THE OTHER 14 WAS THE QUILTEC RESUME WHICH WAS PART OF EXHIBIT 50 AND 15 DIDN'T HAVE ANY DATE. AND YOU WERE TELLING US ABOUT YOUR 16 THOUGHTS WHEN THE QUILTEC --
WHEN AN UPDATED RESUME MIGHT 17 HAVE BEEN PREPARED BEFORE YOU CAME TO THREE MILE ISLAND.
l
, 18 DO YOU RECALL THE DISCUS $10N?
1 19 A YES, I RECALL THAT DISCUSSION.
20 Q OKAY. AND I THINK YOU CAN CONFIRM THIS BY 21 LOOKING AT YOUR QUILTEC RESUME, IF YOU'D LIKE, BUT WE 22 SHOWED YOU THE LANGUAGE THAT TALKED IN YOUR QUILTEC RESUME 23 ABOUT YOU BEING --
ABOUT YOU REPORTING TO THE DIRECTOR OF 24 SITE OPERATIONS, 50 WE CONCLUDED THAT THE INFORMATION IN 25 THE QUILTEC RESUME MUST HAVE BEEN PUT TOGETHER AFTER p 111-9
1 SEPTEMBER 1, 1932 BECAUSE THAT WAS WHEN YOU GOT 2 TRANSFERRED TO SITE OPERATIONS. DO YOU REMEMBER'THAT 3 DISCUSSION?
l 4 A I REMEMBER THAT DISCUSSION, BUT I WOULD HAVE l
5 TO SAY THE CONCLUSION IS YOURS.
6 Q DO YOU THINK THAT THIS QUILTEC INFORMATION, l
L 7 ON -- THE INFORMATION ON THIS QUILTEC RESUME, WHICH IS 8 HERE IN FRONT OF YOU, THAT 1 JUST REFERRED'TO YOU WAS 9 PREPARED BY YOU PRIOR TO IT BEING ACCURATE -- PRIOR TO 10 YOUR TRANSFER TO SITE OPERATIONS?
11 A IF MEMORY SERVES ME CORRECTLY, AT.THIS 12 MOMENT, SIP, MY LAST ACT, IF YOU WILL, HAD BEEN INVOLVED 13 WITH THE PROCEDURES GROUP THAT I WAS WITH, IN OTHER WORDS, 14 WORKING WITH ED KITLER PRIOR TO THE REORGANIZATION THAT 15 OCCURRED IN SEPTEMBER. MY LAST OFFICIAL AC1 OCCURRED WITH 16 THAT GROUP SOME TIME -- OR ON ABOUT JULY 21ST, 1982, THE 17 DAY QUICK-LOOK ENDED.
18 SHORTLY AFTER THAT, SINCE WE DID NOT HAVE A 19 WHOLE LOT OF OTHER THINGS TO DO, IF I REMEMBER CORRECTLY, 20 I APPROACHED EITHER -- OH, I CAN'T REMEMBER THE MAN'S NAME 21 NOW -- RICH GALLAGHER, I BELIEVE IT WAS, OR BOB RIDER, AND 22 ASKED THEM IF IT WAS ALL RIGHT FOR ME TO GO AHEAD AND ;
23 TRANSFER ON OVER TO SITE OPERATIONS SINCE IT ALREADY HAD 24 BEEN JDENTIFIED THAT'S WHERE I WAS GOING TO GO AS PART OF 25 THE REORGANIZATION.
III-10 t_________ _ _ _ . - }
1 1 BELIEVE -- WHICHEVER OF THOSE GENTLEMEN I 2 SPOKE WITH, OR IT MAY HAVE BEEN BOTH OF THEM, AGREED TO l I
3 LET ME GO AHEAD AND TRANSFER OVER.
l 4 SO AS EARLY AS LATE JULY OR EARLY AUGUST OF i 5- 1982, I WAS FULFILLING THE ROLE AS A SITE OPERATIONS 6 ENGINEER ASSIGNED TO LARRY KING. THAT VERY WELL COULD 1
7 HAVE BEEN ABOUT THE TIME THAT I UPDATED MY RESUME.
8 Q OKAY. THAT'S UP UNTIL YOU STARTED PERFORMING .
1 l
9 DUTIES UNDER LARRY KING BEFORE THE REORGANIZATION WAS
- 10. OFFICIALLY EFFECTED ON SEPTEMBER 1?
11 A THAT'S CORRECT, SIR..
12 Q NOW YOU SAID EITHER GALLAGHER OR RIDER AND 13 YOU HAD SOME VAGUENESS ABOUT THE NAMES. MR. RIDER, I 14 THINK, WAS GENERALLY STATIONED IN GAITHERSBURG. DO YOU 15 REMEMBER THAT?
16 A HE WAS GENERALLY STATIONED IN GAITHERSBURG, 17 BUT HE WAS ON STATION AT TMI FOR A WHILE DURING THE !
18 QUICK-LOOK EVOLUTION, AND THAT'S WHY I CAN'T REMEMBER AT l l
l 19 WHICH POINT IN TIME HE WAS THERE AND/OR IF HE WAS ONE OF 20 THE PEOPLE I TALKED WITH OR MAYBE RICH GALLAGHER TALKED 21 WITH HIM, EITHER RIDER OR JACKSON, ONE OF THE HEADS OF 22 BECHTEL LIGHT OVER THE GROUP THAT I WAS ASSIGNED TO AT THE i 23 TIME, 1 SEEM TO RECALL.
24 Q YOU JUST NOW SAID MR. RIDER OR JACKSON --
25 A NO.
111-11 __
_..m__--_ 2__A
1 .Q --
AS BEING THE HEAD OF THE GROUP.
2 CKAY. I THOUGHT MAYBE YOU WERE MISSTATING 3 FOR RIDER OR GALLAGHER WHICH YOU HAD SAID BEFORE.
4 A NO. I WAS TRYING TO RECALL WHICH OF THE 5 GENTLEMAN WAS IN CHARGE OF THE GROUP. BUT I GUESS YOU j 6 COULD REALLY SAY OTHER THAN ED KITLER, WHO, OF COURSE, WAS I
7 MY IMMEDIATE SUPERVISOR, RICH GALLAGHER, PROBABLY WAS THE 8 MAN THAT I CONSIDERED TO BE THE FUNCTIONING SUPERVISOR OF 9 THAT GROUP THAT WE INTERFACED WITH ON AN ANNUAL BASIS.
10 Q WHAT IS YOUR RECOLLECTION, AS BEST YOU CAN, {
11 OF THE DATE WHEN MISS RITTLE EITHER BEGAN OR COMPLETED THE 12 TYPING THAT YOU ASKED HER TO D07
- 13. A I WOULD THINK IT WAS --
1 CAN DISTINCTLY 14 RECALL SUMMERTIME.
15 Q ANYMORE PRECISELY THAN THAT?
16 A NO. IT MAY HAVE BEEN JULY, AUGUST, SEPTEMBER 17 TIME FRAME.
18 Q WHEN YOU GOT REIMBURSED FOR THE MONEY THAT 0
19 YOU HAD PAID MISS RITTLE, DO YOU RECALL HOW SOON AFTER THE 20 JOB WAS COMPLETED YOU GOT REIMBURSED?
21 A WELL, IF 1 RECALL THE SCENARIO EXACTLY, WHEN 22 i FOUND OUT FROM ROSE THAT SHE COMPLETED THE JOB, I ASKED 23 HER HOW MUCH SHE WANTED FOR DOING THE JOB.
24 AND SHE SAID, YOU KNOW, "WHAT DO YOU THINK 25 IT'S WORTH?"
111-12
I l' "I DON'T KNOW. YOU TELL ME."'
1 2 SO SHE PICKED.A FIGURE'0F.$75, I BELIEVE IT l
3 WAS, AND I PAID.HER $75 OUT OF MY. POCKET. ]
l 4 -I THEN TOOK THOSE MATERIALS UP TO LARRY KING .
1 5- AND'SAID, "HERE, AND YOU OWE ME-75 BUCKS." )
1 6 AND 1F MEMORY SERVES ME-CORRECTLY, AT-THE 7 MOMENT, I WAS REPAID IN A VERY SHORT FAShl0N'AFTER'THAT.
8 Q DIRECTLY FROM MR. KING?
9' A I DON'T REMEMBER IF HE PAID ME CASH OR IF.HE 10 GAVE ME A' CHECK ON SOME OTHER DATE. I DON'T REMEMBER THE.
11 ACTUAL SEMANTICS OF THAT PART OF THE EVOLUTION.
12 ~Q- BUT IN ANY EVENT IT. WAS SHORTLY AFTER THE 13 COMPLETION OF MISS RITTLE'S WORK?
14 A I WOULD SAY PROBABLY WITHIN A WEEK OR.TWO 15 EASILY. .
16 MR. HICKEY: LET ME ASK THE REPORTER TO MARK 17 EXHIBIT 52, PLEASE.
18 (WHEREUPON PLA1NTIFF'S RESPONDENT'S 52 WAS 19 MARKED FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY 20 IS ATTACHED HERETO.)
21 - Q BY MR. HICKEY: MR. PARKS, YOU HAVE IN YOUR L '22' HANDS EXHIBIT 52. I'LL REPRESENT TO YOU TWO THINGS ABOUT 23 THIS EXHIBIT. FIRST 10 F ALL, IT'S PREVIOUSLY'BEEN 24 IDENTIFIED IN A DEPOSITION IN ANOTHER CASE AS THE CHECK 25 LEDGER OR ACCOUNTS-LOG OF QUILTEC. AND THE OTHER COMMENT III-13
l l 1 1'HAVE TO MAKE ABOUT THE PHYSICAL NATURE OF THE EXHIBIT, 2 IF YOU LOOK ON PAGE 2, THE CHECKS, YOU SEE OVER WHERE l'M 3 POINTING HERE, THERE'S KIND OF A LITTLE --
LOOKS LIKE i
4 THERE WAS A STICKER ON THIS PAGE THAT SAYS " CORP. MEETING S 8/11/82" AND SO ON. DO YOU SEE THAT?
6 A YES, I SEE THAT.
i 7 Q THAT'S NOT PART OF THE ORIGINAL' EXHIBIT, AND 8 THERE ARE SEVERAL OF THOSE THROUGHOUT THE COURSE. THEY'RE 9 NOT PART OF THE ORIGINAL.
10 MR. JOHNSON: WAS THIS PRODUCED IN MR. PARKS' 11 LITIGATION?
12 MR. HICKEY: NO. I BELIEVE IT WAS IN MR. KING'S 13 LITIGATION.
14 MR. JOHNSON: OKAY. THANK YOU.
15 Q BY MR. HICKEY: JUDGING FROM THE DATE YOU SEE 16 IT'S PREVIOUSLY MARKED AS AN EXHIBIT "DATE, 10/1/83" AND 17 THAT'S TO ME THE -- THAT WAS PROBABLY MR. KING'S 18 LITIGATION. ANYHOW, MR. PARKS, I WANT TO DIRECT YOUR 19 ATTENTION TO CHECK NUMBER 138. IT'S ON THE SECOND PAGE 20 ABOUT TWO-THIRDS OF THE WAY DOWN.
21 A RIGHT. I SEE IT. i 22 Q OKAY. THAT INDICATES, DOES IT NOT, THAT 23 THERE WAS A CHECK NUMBER 138 IN THE AMOUNT OF $75 ISSUED 24 TO RICK PARKS, SEPTEMBER 26, 1982 FOR TYPING SERVICES?
25 A THAT'S WHAT IT SAYS.
III-14 3
'l Q DO YOU P5LIEVE THAT'S THE CHECK THAT 2 REIMBURSED YOU FOR THE $75 YOU HAD GIVEN ROSE RITTLE?
3 A I WOULD SAY IT PROBABLY 15.
4 1 BELIEVE I SAID PREVIOUSLY I COULD NOT 5 RECALL IF LARRY KING -- HE PAID PAID ME CASH OR GAVE ME A 6 CHECK.
7 Q BUT THIS MAKES IT LOOK LIKE HE GAVE YOU A 8 CHECK?
9 A SURE DOES.
10 Q OR SOMEBODY GAVE YOU A CHECK?
11 DO YOU RECALL THAT MR. --
12 (WITNESS AND COUNSEL ARE CONFERRING.)
13 Q BY MR. HICKEY: 1 DIDN'T WANT TO ASK WHILE 14 YOU WERE TALKING ABOUT SOMETHING ELSE.
15 DO YOU RECALL THAT MR. KING, HIMSELF, GAVE 16 YOU THE CHECK, MR. PARKS, OR DID YOU JUST RECEIVE IT IN 17 THE MAIL OR HOW DID YOU GET IT?
18 A I BELIEVE, IF MEMORY SERVES ME CORRECTLY AT 19 THE MOMENT, THAT LARRY HANDED ME A CHECK.
l I 20 Q WHO HAD SIGNED THE CHECK?
21 A 1 REALLY COULDN'T TELL YOU, SIR.
22 Q WAS LARRY KING'S NAME ON THE CHECK IN ANY 23 FASHION OR MANNER?
24 A I REALLY COULDN'T TELL YOU, SIR. !
25 Q 1 DON'T HAVE ANY AORE QUESTIONS FOR YOU ABOUT 111-15
H 1 THAT. EXHIBIT,-MR. PARKS.
2 AFTER MR. KING WAS SUSPENDED ON FEBRUARY 24, 3 I.THINK WE SHOWED YOU YESTERDAY AN EXHIBIT THAT CONSISTED L 4 OF SOME 28 QUESTIONS. IT WAS EXHIBIT NUMBER 51 --
I'M 5 SORRY, I MISSTATED THAT. EXHIBIT 51 WAS THE FEBRUARY 28TH 6 LETTER FROM MR. ARNOLD TO MR. KING ASKING HIM A NUMBER OF 7 QUESTIONS. AT THE MOMENT I HAVE FORGOTTEN HOW MANY 8 QUESTIONS THERE WERE.
9 A THERE WAS A BUNCH.
10 Q AND ASKED M R . ' K I f0G TO ANSWER THEM.
y 11 AND THE EXHIBIT WHICH I INDICATED YESTERDAY 12 WAS IN THE PAPERS -- PRODUCED IN YOUR PAPERS PRODUCED TO i 13 THE NRC'AND FROM THE NRC TO US SAYS ON THE LAST LINE 14 "PLEASE PROVIDE YOUR ANSWER TO THIS LETTER IN WRITING BY 15 FOUR O' CLOCK P.M., WEDNESDAY, MARCH 2, 1981." AND THEN ON 16 THE EXHIBIT, IT'S BEEN --
THE WORD " WEDNESDAY" HAS BEEN 1
.17 CROSSED OUT AND INSTEAD " THURSDAY" IS WRITTEN IN WITH WHAT
-18 LOOKS LIKE MR. ARNOLD'S INITIALS, 50 IT APPEARS THAT< .
19 MARCH 2ND, IN FACT WAS, A THURSDAY RATHER.THAN A 20 WEDNESDAY, SIR, BUT MR. KING WAS DUE TO RESPOND TO THAT.
k; l 21 WERE YOU AWARE THAT MR. KING WAS COLLECTING g 22 INFORMATION AND MAKING EFFORTS TO PREPARE A RESPONSE TO j
- l. i 23 MR. ARNOLD'S QUESTIONS AFTER HE WAS SUSPENDED AND AFTER HE 24 GOT THE LETTER WHICH IS EXHIBIT 51?
25 A ARE YOU ASKING --
III-16 I
i
1- MR. JOHNSON: BEFORE THIS LETTER WAS SENT TO 2 MR. ARNOLD?
3 MR. HICKEY: THIS LETTER 15 FROM MR. ARNOLD TO 4 MR. KING.
5 MR.'dOHNSON: 1 MEAN BEFORE MR. --
I'M JUST --
6 'BEFORE MARCH 9TH?
7 MR. HICKEY: YES.
8 THE WITNESS: DO I UNDERSTAMD YOUR QUESTION 9 CORRECTLY IN THAT YOU'RE ASKING ME DID I KNOW OF THAT MEMO 10 OR THAT LETTER FROM BOB ARNOLD TO LARRY KING, LARRY KING'S 11 ATTEMPTS TO ANSWER THAT AT THE SAME TIME IT WAS THAT 12 OCCURRING?
13 Q BY MR. HICKEY: AT ANY TIME BEFORE THE 14 ANSWERS FINALLY WENT IN ON MARCH 9 15 A I CAN RECALL, AT THE MOMENT, LARRY KING i
16 TALKING TO ME ON, LIKE, MARCH 9TH OR MARCH 10TH --
17 Q RIGHT.
18 A --
REGARDING HIS CONVERSATIONS WITH f 1
19 BOB ARNOLD, ET CETERA, ET CETERA AS I STATE IN MY 20 AFFIDAVIT. NOW WHETHER I WAS AWARE OF WHAT WAS GOING ON 21 BEFORE THAT BY CONVERSATIONS WITH LARRY KING, I CAN'T 22 RECALL AT THIS TIME IF 1 WAS OR NOT. !
l 23 Q OKAY. I HAD MEANT TO ASK MY QUESTION A j 24 LITTLE MORE BROADLY THAN YOU JUST PHRASED IT, 50 LET ME 25 PUT ANOTHER QUESTION SLIGHTLY DIFFERENTLY.
1 111-17
1~ WHEN YOU KNEW ABOUT THIS SPECIFIC LETTER OR-2 WHAT THE SPECIFIC QUESTIONS WERE, DID YOU KNOW BEFORE 3 MARCH 9 THAT LARRY KING HAD TO PROVIDE SOME RESPONSES TO 4 QUESTIONS FROM MR. Av.NOLD?
5 A 1 BELIEVE ANYWAY, AT THIS MOMENT, MY MEMORY 6 SERVES TO RECALL THAT AT ONE POINT IN TIME LARRY KING TOLD 7 MF HE HAD TO ANSWER SOME QUESTIONS TO GPU MANAGEMENT. NOW 3 IF THAT WAS THE TYPE OF QUESTIONS HE WAS MEANING, I REALLY 9 COULDN'T TELL'YOU AT THIS TIME OR NOT.
10 Q CAN YOU PUT A DATE ON THAT, MR. PARKS?
11 A LET ME ASK YOU, AFTER HE WAS SUSPENDED?
12 Q AFTER HE WAS SUSPENDED I WAS GOING TO SAY.
13 A RIGHT.
14 Q NOW WERE YOU KEEPING IN TOUCH WITH MR. KING' 15 OR DID YOU HAVE CONTACT WITH MR. KING DURING THE TIME HE 16 WAS SUSPENDED BEFORE THE MARCH 9TH EVENING TELEPHONE CALL
, 17 THAT I GOT FROM HIM ABOUT HIS MEETING WITH ARNOLD?
18 A I BELIEVE THAT ON AT LEAST ONE OCCASION 19 MYSELF AND MY SONS WENT OVER TO HIS HOUSE, YES. IT 20 PROBABLY WOULD HAVE BEEN SHORTLY AFTER HE WAS SUSPENDED, 21' LIKE MAYBE THAT WEEKEND THAT FOLLOWED HIS SUSPENSION. I 4 22 KNOW, IF I RECALL CORRECTLY, THAT WAS ABOUT WHEN IT WOULD 23 HAVE HAPPENED, YES, BUT I BELIEVE WE ALSO SPOKE ON THE -
24 PHONE A COUPLE OF TIMES AFTER THAT TOO.
l 25 Q DID YOU HAVE MATTERS RELATING TO YOUR WORK IN 1
l 111-18 I
_ _ _ _ - - _ _ _ _ _ - - _ - - - - - _ - - - - - - _ _ _ - - . - - - - _ _ _ - - - - - - - - _ - _ - - --- - - - - - - - - - - - - - - -- a
1 THE SITE OPERATIONS DEPARTMENT THAT YOU NEEDED TO DISCUSS 2 WITH MR. KING DURING THIS TIME AFTER HIS SUSPENSION AND 3 BEFORE MARCH 9?
4 A I DON'T THINK I UNDERSTAND YOUR QUESTION.
5 Q OKAY. I WAS TRYING TO INQUIRE WHETHER WHEN 6 YOU SAID YOU SPOKE TO MR. KING ON THE TELEPHONE SOMETIMES 7 IT WAS IN CONNECTION WITH YOUR SITE OPERATIONS DUTIES? s 8 A AT SOME POINT IN TIME, 1 ATTENDED A MEETING, 9 AWD I THINK IT WAS REGARDING THE POLAR CRANE, AND 1 TOOK 10 NOTES ON IT. AND I SHOWED THOSE NOTES TO JOE CHWASTYK.
11 AND IF I RECALL CORRECTLY, AT THIS MOMENT, JOE CHWASTYK 12 . TOLD ME 10 RELAY THAT INFORMATION TO LARRY KING. 50 1 13 GUESS THAT WOULD DE THE ONLY TIME THAT I WOULD 14 SPECIFICALLY RECALL OR RECALL SPECIFICALLY SPEAKING WITH 15 LARRY ABOUT MATTERS THAT WERE GOING ON ON THE ISLAND --
16 Q WERE --
17 A -- RELEVANT TO WORK ANYWAY OTHER THAN HIS 18 SUSPENSION AND THAT 1YPE OF THING.
19 Q WERE THE OTHER TELEPHONE CONVERSATIONS THAT I
20 YOU HAD WITH MR. KING MORE OF A PERSONAL NATURE OR MORE 21 RELATED TO HIS SUSPENSION?
22 A I WOULD ONLY HAVE TO STATE, AT THIS TIME, 23 THAT'S PROBABLY THE TRUTH, YES.
1 24 Q AND HOW ABOUT YOUR VISIT TO HIM ON THE l 25 WEEKEND WITH YOUR SONS? I WHAT WAS THE PURPOSE OF THAT 4 111-19
1 VISIT?
2 A WELL, LIKE I STATED EARLIER, I BELIEVE IT 3 WAS, LIKE, THE WEEKEND. HE WAS SUSPENDED ON, LIKE, A 4 THURSDAY OR FRIDAY, SOMETHING ALONG THE END OF THE WEEK.
5 AND I BELIEVE MY SONS AND 1 WENT OVER ON THAT. WEEKEND, AND 6 I WAS STILL STRUCK BY THE --
THE WHOLE INSTANCE OF IT, YOU
-7 KNOW, WHAT WAS GOING ON. I DIDN'T REALLY UNDERSTAND WHY 8 HE WAS BEING SUSPENDED FOR SOMETHING I DIDN'T THINK HE WAS 9 CUILTY OF, SO IT WAS MORE IN THAT INSTANCE OF PERSONAL 10 _ SUPPORT, A FRIENDLY GESTURE, THAT TYPE OF THING. '
11 Q DID YOU TALK ABOUT QUILTEC WHEN YOU VISITED 12 ON THAT WEEKEND?
k l
13 A I --
AFTER LARRY KING WAS SUSPENDED, i 14 DEFINITELY BECOME A LOT MORE AWARE OF WHAT,QUILTEC WAS AND 15 A LOT MORE KNOWLEDGEABLE OF QUILTEC THAN I HAD BEEN PRIOR 16 TO THAT, YES, BUT I CANNOT RECALL ANY SPECIFIC 17 CONVERSATIONS, NOT AT THIS MOMENT.
18 Q WELL, AFTER MR. KING WAS SUSPENDED, DID YOU 19 GET INFORMATION ABOUT QUILTEC FROM --
LET ME PUT YOU UP TO 20 MARCH 9 BECAUSE THAT'S THE PERIOD WE'RE TALKING ABOUT
'21 RIGHT NOW.
22 DID YOU GET INFORMATION ABOUT QUILTEC FROM 23 ANYONE BESIDES MR. KING?
24 A NOT THAT I CAN THINK OF, AT THE MOMENT, NO.
25 Q DID YOU TALK TO MR. CHWASTYK AF1ER MR. KING 111-20
l l' WAS' SUSPENDED ABOUT QUILTEC AND BEFORE MARCH 9?
I 2 A SEEMS'TO ME THAT MY CONVERSATIONS WITH
-3 JOE CHWASTYK MOSTLY CENTERED AROUND JOE ATTEMPTING.TO 1 4 REASSURE EVERYONE THAT HE THOUGHT LARRY WAS GOING TO BE !
k 5 BACK ON THE JOB SITE IN A SHORT FASHION; THAT, YOU KNOW, 6 THIS WHOLE THING WAS JUST A MISUNDERSTANDING. AND AT ONE 7 POINT IN TIME JOE TRYING TO FIND OUT IF 1 WAS DEALING WITH I
8 THE NRC AND WARNING ME, YOU KNOW, I BETTER FIND A LAWYCR, 9 THAT TYPE OF THING BECAUSE MANAGEMENT KNEW I WAS GOING TO 10 THE NRC AND WAS GOING TO BURN ME FOR IT.
11 Q YOU MAY HAVE MEANT THAT AS AN ANSWER. LET ME 12 SEE IF I CAN GET ONE THAT'S A LITTLE MORE DIRECT.
13 IS IT YOUR TESTIMONY THAT YOU DON'T RECALL i
14 HAVING ANY DISCUSSIONS WITH MR. CHWASTYK ABOUT QUILTEC IN l
15 THE TIME PERIOD FROM KING'S SUSPENSION TO MARCH 97 16 A I THINK DURING ONE OF THE CONVERSATIONS THAT 17 I HAD WITH JOE, "'
MENTIONED SOMETHING TO ME ABOUT A 18 CONVERSATION HE HAD WITH JOHN BARTON REGARDING 19 JOE CHWASTYK'S INVOLVEMENT WITH QUILTEC.
20 MAYBE l'M NOT UNDERSTANDING EXACTLY WHAT 21 YOU'RE LOOKING FOR BECAUSE I THINK l'M ACTUALLY ANSWERING 22 YOUR QUESTION. l l
23 Q WELL, I HAD ASKED YOU EARLIER ABOUT WHETHER 24 THERE WAS ANY CONVERSATION YOU HAD WITH MR. CHWASTYK ABOUT ;
l 25 QUILTEC. AND YOUR RESPONSE WAS THAT MOST OF YOUR l 111-21
)
)
l 1 CONVERSATIONS WITH CHWASTYK CENTERED AROUND THE FACT THERE j 2 WAS A MISUNDERSTANDING AND LARRY WOULD BE BACK SOON. AND 3 i NOW AM ASKING YOU WHETHER YOU HAD ANY DISCUSSION WITH 4 CHWASTYK BETWEEN FEBRUARY 24 AND MARCH 9 RELATED TO l 5 QUILTEC.
\
6 MR. J O H N S O N.: 0THER THAN THE ONE HE JUST MENTIONED?
7 THE WITNESS: OTHER THAN THE ONE I JUST MENTIONED? l 8 Q BY MR. HICKEY: YES.
9 A THAT'S THE ONLY ONE I CAN RECALL AT THIS l 10 MOMENT. !
11 Q AND BESIDES MR. KING AND THIS CONVERSATION J
12 WITH MR. CHWASTYK, DID YOU HAVE CONVERSATIONS WITH ANYONE 13 ELSE ABOUT QUILTEC AFTER KING WAS SUSPENDED BEFORE 14 MARCH 97 15 A ANYONE?
]
! 16 .Q YES.
l 17 A 1 CAN'T RECALL, AT THE MOMENT, WHETHER OR NOT j 18 I TALKED ABOUT IT WITH LAKE BARRETT ON FEBRUARY'24TH OR 19 NOT. I MIGHT HAVE. I DON'T RECALL IF I DID OR NOT. !
d 20 Q HOW ABOUT MR. SLONE?
21 A I CAN'T RECALL, AT THE MOMENT, IF I TALKED
{
22 WITH BEN ABOUT IT OR NOT. j 23 Q HOW ABOUT ED KITLER?
24 A I DON'T BELIEVE SO.
25 I GUESS, YOU KNOW, RATHER THAN HAVING YOU 111-22
1 ASK --
ASKING ME IF "DID YOU TALK WITH THIS GUY," DID YOU 2 TALK WITH THAT GUY," I JUST CAN'T REMEMBER TALKING WITH 3 ANYBODY ELSE, NOT AT THE MOMENT.
4 Q OKAY.
5 DID YOU KNOW THAT MR. KING AND MR. LIONARONS 6 WENT TO THE LILCO PLANT AT SHOREHAM ON MARCH 1 AND 2, 7 1983, SHORTLY AFTER KING WAS SUSPENDED?
8 MR. JOHNSON: I'M SORRY, I DIDN'T CATCH THE PEOPLE 9 THAT YOU MENTIONED.
10 MR. HICKEY: KING AND LIONARONS.
11 THE WITNESS: IF I WAS AWARE OF IT WHEN IT 12 HAPPENED? I DON'T RECALL BEING AWARE OF IT NOW. I GUESS, 13 I DON'T KNOW IF I STATED THAT CORRECTLY. I DON'T KNOW, AT 14 THE PRESENT TIME, BEING AWARE OF IT WHEN IT HAPPENED, 15 ASSUMING THAT li DID HAPPEN.
16 Q BY MR. HICKEY: YOU TALKED ABOUT YOUR VISIT 17 TO MR. KING'S HOUSE ON TH WEEKEND, YOU BELIEVE, SHORTLY 18 AFTER YOU WERE SUSPENDED. 1 CAN TELL YOU THAT HE WAS 19 SUSPENDED ON THE 24TH WHICH WAS A THURSDAY OF FEBRUARY, l 20 1983, SO THAT WEEKEND WOULD HAVE BEEN THE 26TH AND 27TH, 21 JUST TO GIVE YOU A QUICK CALENDAR.
22 THE FOLLOWING WEEKEND WAS MARCH 5 AND 6, 23 SATURDAY AND SUNDAY, OF THE NEXT WEEKEND. DID YOU SEE 24 BEN SLONE AT LARRY KING'S HOME OR ANYWHERE ELSE IN THE 25 HARRISBURG AREA ON THE WEEKEND OF MARCH 5 AND 6?
111-23
i 1: A IF I D I D ,- 1 DON ' TL HAVE: ANY RECOLLECTION OF IT 2- AT THE-MOMENT.
'3 Q DO YOU RECALL ON ANY OCCASION BEING WITH 4 MR,.SLONE AND AT MR. KING'S HOUSE AFTER MR. KING'; WAS 5 SUSPENDED?
7 UP1TO THE PRESENT. TIME?
- 8. MR. HICKEY: YES.
i 9 .THE WITNESS: I CAN RCCALL MEETING'WITH BEN SLONE A
-10 COUPLE OF' TIMES'AFTER LARRY KING WAS SUSPENDED, BUT 1
- 11 : DON'T. RECALL MEETING-WITH. BEN SLONE.AT LARRY KING'S-
- 12. .AFTER -- AT' LARRY KING'S HOUSE.
'13 Q BY MR. HICKEY: WHAT ARE THE OCCASIONS.THAT 14 YOU.DO RECALL MEETING WITH.MR. SLONE? WHEN WERE.THEY, 15 FIRST OF:ALL?
16 A - WE L L', THEY WERE WHILE.I WAS SUSPENDED.
17 Q AT ANY OCCASION BEFORE YOU WERE SUSPENDED --
18 AFTER KING WAS SUSPENDED AND BEFORE YOU WERE SUSPENDED, ;
19 DID'YOU MEET WITH SLONE? k !
20 A NOT.THAT ! CAN RECALL AT THE MOMENT. I
i 22' .OUT ON SICK LEAVE ON MARCH -- OR OUT ON SICK LEAVE I THINK i
23 IS THE WAY YOU PHRASED IT. IT'S ON PAGE 40 0F YOUR j 24 AFFIDAVIT. TWO-THIRDS OF THE WAY DOWN THE PARAGRA?H 25 BEGINS WITH THAT SENTENCE. DO YOU RECALL THAT OCCASION?
111-24
1 A NO, NOT AT THE. MOMENT, BUT.I. DON'T HAVE'ANY 2 REASON.TO-DOUBT THAT STATEMENT EITHER. -l q
3L Q- .WELL, D0.YOU REMEMBER WHAT YOUR MEDICAL
- 4 . COMPLAINT:WAS?
5 A I DON'T REMEMBER THAT IT WOULD NECESSARILY )
6 HAVE BEEN A MEDICAL COMPLAINT.
7 Q OH, WELL, WHAT DO YOU MEAN WHEN'YOU SAY YOU 8 WERE OUT ON SICK LEAVE? ! ASSUME THAT MEANT YOU'WERE 9 SICK. WHAT DOES IT MEAN?
~10 A NO, IT DOES NOT NECESSARILY MEAN SICK LEAVE.
11 IF I REMEMBER CORRECTLY THE -- WE WERE ALLOWED SO MANY 12 SICK DAYS, YOU KNOW, A YEAR, A MONTH,,OR HOWEVER IT WAS 13 PRORATED. AND IN SOME INSTANCES,- MYSELF AND OTHER BECHTEL 14 EMPLOYEES, LIKED TO HAVE A DAY OFF FOR PERSONAL BUSINESS, l 15 -THAT TYPE OF THING.
16 Q OKAY. WELL, 15 IT YOUR BELIEF THAT YOU WERE 17 NOT SICK THOSE TWO DAYS?
-18 A I REALLY COULDN'T TELL YOU, AT THE MOMENT,
21 Q WHAT PERSONAL BUSINESS DO YOU THINK YOU MIGHT 22 HAVE BEEN HANDLING ON MARCH 7 AND 8?
23 A I BELIEVE I TESTIFIED YESTERDAY, SIR, THAT 24 DURING THIS TIME FRAME IN QUESTION, I HAD AN OUTSIDE 25 BUSINESS INVOLVED IN THE PURCHASE AND RESALE OF WICKER.
!!I-25 l
i I
1 Q YES.
2 A I MIGHT HAVE HAD BUSINESS, YOU KNOW, TO DEAL 3 WITH THE STATE ON SOMETHING LIKE THAT. I DON'T KNOW.
4 YOU'RE ASKING ME TO SPECULATE BACKWARDS FOUR 5 YEARS AGO_IF !.WAS SICK THOSE DAYS OR IF 1 HAS HANDLING 1
'6 PERSONAL BUSINESS OR TAKING MY SON TO THE DOCTOR OR --
1 I i
7 CAN'T REALLY.TELL YOU, AT THE MOMENT, EXACTLY WHAT I WAS j i
8 DOING. H I
9 I WOULD SUGGEST THOUGH THERE MIGHT BE MORE 10 AMPLIFICATION PROVIDED IN MY DAILY DIARY THAT 1 KEPT 11 DURING THAT TIME FRAME.
12 Q LET'S TAKE A LOOK AT THAT, EXHIBIT 11. THE 13 DATES ARE MARCH 7 AND 8. I 14 HAVE YOU FOUND THAT PAGE?
15 A IT JUST SAYS'"0FF."
16 Q IT JUST SAYS "0FF"?
17 A RIGHT.
18 Q IN ANY EVENT THOSE DATES YOU WERE --
I THINK 19 YOU TOLD US EARLIER, YOU WERE RECREATING THE FIRST DATES 20 IN THIS BOOK AFTER THE FACT; THAT YOU BEGAN THE DIARY ON 21 FRIDAY, MARCH 18 --
22 A I BELIEVE --
23 Q --
IT SAYS IN THE FRONT OF THE EXHIBIT.
'24 A I BELIEVE THAT TO BE TRUE.
25 Q SO THAT I ASSUME THAT DOESN'T GIVE YOU ANY --
111-26
(
l l' WELL, DOES THAT INDICATE TO YOU THAT YOU.WERE PROBABLY NOT j 2 SICK SINCE YOU JUST. WROTE "0FF"? j 1
3 A NO, SIR, IT DOES NOT PROVIDE ANY'FURTHER l j j 4 AMPLIFICATION, IN MY MIND, REGARDING WHAT-I WAS DOING ON I
L 5 THOSE TWO DAYS IN QUESTION.
6 MR. HICKEY: I'D ASK YOU TO PLEASE MARK THAT AS 7 EXHIBIT 53.
8 (WHEREUPON PLAINTIFF'S RESPONDENT'S 53 WAS 9 MARKED FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY 10 IS ATTACHED. HERETO.)
11 Q BY MR. HICKEY: MR. PARKS, I'M SHOWING YOU 12 WHAT'S BEEN MARKED EXHIBIT 53. IT'S A COPY OF THREE TIME 13 RECORDS FROM THE GAITHERSBURG OFFICE OF BECHTEL, AND I 14 WANT TO DIRECT YOUR ATTENTION TO THE ONE IN THE MIDDLE OF 15 0F THE PAGE WHICH SAYS IT IS FOR THE PERIOD ENDING 16 3/11/83. DO YOU SEE YOUR NAME ON.THE BOTTOM RIGHT-HAND 17 CORNER OF THAT MIDDLE FCRM?
18 A YES, I DO.
19 Q AND IF, AS I INDICATED TO YOU EARLIER, 20 MARCH 7 AND 8 WOULD HAVE BEEN MONDAY AND TUESDAY, YOU SEE 21 THAT THERE IS NO TIME ENTRY ON THE LINE FOR THOSE TWO 22 DAYS?
23 A YES, I SEE THAT.
24 Q THE LATTER PART OF THE FORM 15 WHAT I'M 25 REFERRING TO.
III-27
J :
1 A RIGHT. ;
2 Q. IF YOU WERE ON SICK LEAVE, WOULD YOU RECORD 3 THAT IN SOME FASHION ON YOUR TIME RECORD?
4 A I REALLY COULDN'T TELL YOU, AT-THIS POINT IN 5 TIME, IF'WE RECORDED --
OR'WHAT TYPE OF RECORD WE RECORDED 6 IT OR IF WE JUST PHONED GAITHERSBURG AND TOLD THEM OR l
7 WHAT.
8 MR. JOHNSON: COULD YOU REPRESENT FOR WHAT PURPOSE 9 THIS -- THESE RECORDS WERE KEPT?
I 10 MR. HICKEY: I BELIEVE THEY HAVE TO DO WITH PAY 11 PURPOSES. I REALLY DON'T KNOW.
12 Q BY MR. HICKEY: BUT DO YOU KNOW, MR. PARKS, 13 WHAT THESE RECORDS WERE FOR?
14 A IT SAYS " TIME RECORD."
f l 15 MR. JOHNSON: IT'S CONCEIVABLE IT COULD BE A CHARGE
.16 FOR BILLING A CLIENT AS WELL.
17 MR. HICKEY: YES. I DON'T KNOW.
I 18 THE WITNESS: IF I REMEMBER CORRECTLY, EVERY ONCE ;
19 IN A WHILE WE HAD TO SIGN A BUNCH OF BLANK TIME CARDS AND j i
20 SEND THEM BACK TO GAITHERSBURG, AND THEN WE PHONED IN OUR 21 TIME. THAT'S ABOUT THE ONLY THING I CAN REALLY TELL YOU.
22 Q BY MR. HICKEY: WELL, YOU KNEW, MR. PARKS, 23 DIDN'T YOU, BEFORE MR. KING MET WITH MR. ARNOLD ON THE 24 EVENING OF MARCH 9, l'LL REPRESENT TO YOU IT WAS ON THE 25 EVENING OF MARCH 9 YOU KNEW MR. KING WAS PLANNING NOT TO j 111-28 1
1 TELL MR. ARNOLD ABOUT MR. CHWASTYK'S TRIP TO BEAVER VALLEY ,
2 WITH MR. HOAG, DIDN'T YOU?
3 MR. JOHNSON: OBJECTION. IT CALLS FOR SPECULATION 4 ON THE PART OF THE WITNESS AS TO WHAT WAS IN THE STATE OF 5 MIND OF THE PERSON THAT YOU JUST INDICATED WAS MR. KING.
6 MR. HICKEY: YES.
7 MR. JOHNSON: 1 DON'T SEE HOW --
8 MR. HICKEY: l'M ASKING WHAT WAS IN MR. PARKS' 9 MIND.
- 10 THE WITNESS: WHAT WAS IN MY MIND?
11 Q BY MR. HICKEY: YOU KNEW MR. KING WASN'T 12 PLANNING TO TELL MR. ARNOLD ABOUT MR. CHWASTYK'S TRIP FOR 13 QUILTEC TO BEAVER VALLEY, DIDN'T YOU?
14 A NO, SIR, 1 DO NOT AGREE WITH THAT.
15 Q YOU DIDN'T KNOW THAT?
16 A I DO NOT KNOW WHAT LARRY KING HAD INTENTIONS 17 OF TELLING PEOPLE. IF I KNEW IT AT THE TIME, I SURE DON'T 18 RECALL IT NOW.
19 Q YOU DID KNOW THAT MR. CHWASTYK HAD BEEN TO 20 BEAVER VALLEY AROUND LATE OCTOBER OF 1982 FOR QUILTEC?
21 MR. JOHNSON
- WHAT TIME FRAME?
22 Q BY MR. HICKEY: YOU KNEW AS OF MARCH 9 OR 23 BEFORE?
i 24 A I KNEW FOR A FACT THAT JOE CHWASTYK HAD GONE I 25 TO BEAVER VALLEY, BUT WHEN I LEARNED THAT INFORMATION OR l
!!!-29
-)
1:
3 1 WHEN'I HAD-THE.INFORMATION CONFIRMED TO ME, I COULD-NOT 2 TELL YOU, AT THIS MOMENT, WHAT TIME FRAME I LEARNED THAT. ,
! 3 Q DID.YOU KNOW THAT-MR. KING DID NOT PLAN TO 4 TELL MR.' ARNOLD ABOUT MR. LIONARONS'DOING WORK FOR QUILTEC I l
1 5 AT THE STONE AND WEBSTER CHEM NUCLEAR JOB?
i 4
6' A. SIR,-YOUR STATEMENT KIND OF LEAVES ME WITH 7 THE IMPRESSION THAT YOU ASSUME OR THAT.YOU BELIEVE I KNEW ]
8 A LOT MORE THAN WHAT'I REMEMBER THAT I KNEW. AND.I 9 BELIEVE I HAVE ALREADY ANSWERED.THESE QUESTIONS.
10 I REALLY DON'T RECALL, AT THIS MOMENT, WHEN 1 11 LEARNED ALL OF THIS INFORMATION, BUT IF I LEARNED .lT 12 BEFORE LARRY KING TOLD ANYBODY, AFTER LARRY KING TOLD 13 ANYBODY, IF I READ ANY OF THE STATEMENTS SINCE THEN, OR 14 WHAT HAVE YOU, 'I JUST CANNOT, A,T.THIS POINT IN TIME, i
15 PROVIDE ANY AMPLIFYING INFORMATION FOR YOU.
16 Q WELL, LET'S SEE IF.I CAN ASK YOU ONE THAT 17 MAYBE YOU MIGHT HAVE HAD SOME MORE KNOWLEDGE ABOUT.
l 18 YOU KNEW, DIDN'T YOU, THAT MR. KING DIDN'T 19 PLAN TO TELL MR. ARNOLD ABOUT RICK PARKS' ACTIVITIES FOR 20 QUILTEC?
21 A I BELIEVE I TOLD YOU YESTERDAY THAT WHEN I l 22 FOUND OUT THAT LARRY KING DID NOT INFORM BOB ARNOLD --
23 IDENTIFYING ME AS BEING A PERSON THAT WAS KNOWLEDGEABLE OF 24 QUILTEC, THAT I TOLD HIM, AT THAT TIME, THAT HE MADE A 25 MISTAKE. HE SHOULD HAVE TOLD BOB ARNOLD BECAUSE I DID 111-30
I
- 1 KNOW ABOUT QUILTEC. j l
2 Q THAT'S NOT QUITE RESPONSIVE TO MY QUESTION.
i 3 DID YOU KNOW THAT MR. KING DID NOT PLAN TO 4 TELL MR. ARNOLD ABOUT YOUR ACTIVITIES WITH QUILTEC?
5 A I THOUGHT -- I THINK, SIR, MAYBE, YOU KNOW, 6 YOU MISUNDERSTOOD MY ANSWER.
7 I DO NOT --
OR DID NOT KNOW BEFORE LARRY KING 4
8 TOLD BOB ARNOLD THAT HE WAS NOT GOING TO TELL BOB ARNOLD 9 THAT I KNEW. I BELIEVE I PHRASED IT SUCH THAT WHEN 1 10 FOUND OUT THAT BOB -- THAT LARRY DID NOT TELL BOB ARNOLD, 11 THAT I TOLD LARRY HE'D MADE A MISTAKE BECAUSE I WAS 12 KNOWLEDGEABLE OF QUILTEC.
13 BUT YOU ASKED ME IF I KNEW BEFOREHAND OR 14 SPECULATE THAT LARRY KING WAS NOT INTENTIONALLY GOING TO 15 TELL BOB _ ARNOLD, I CAN'T DO THAT BECAUSE I DO NOT HAVE ANY l
f 16 RECOLLECTION, AT THIS MOMENT, KNOWING THAT BEFOREHAND.
1 17 Q YOU DON'T RECALL WHETHER YOU KNEW ONE WAY OR 18 THE OTHER WHAT MR. KING PLANNED TO TELL MR. ARNOLD?
19 A WHAT?
20 Q DO YOU RECALL INFORMING LARRY KING THAT WHAT 21 HE HAD TOLD BOB ARNOLD WAS INACCURATE; THAT WAS AFTER 22 MR. KING HAD MET WITH MR. ARNOLD, RIGHT?
23 A YES.
24 Q JUST SO YOU'RE CLEAR ON WHAT l'M ASKING, I'M 25 ASKING ABOUT YOUR KNOWLEDGE BEFORE MR. KING MET WITH 111-31
- r. _ _ _ _ - - _ _ _ - - - - _ - - _ _ - _ _ _ _ _ - - - _ - _ - - - - - - . - _ _ - - - _ - - - - - - , - - - - - _ _ _ _ . _ _ _ - - _ . - . . - - _ - - _ - - _ - - _ - - - - -
l l . b-1 MR. ARNOLD ON MARCH'9, 2 A NO, SIR, I DO NOTfBEL'IEVE I WAS AWARE BEFORE 3 THE' FACT THAT LARRY KING WAS'NOT GOING TO TELL BOB ARNOLD.
4- Q. WELL, YOU DID KNOW THAT IF SOME PEOPLE WANTED '
5 TO LOOK HARD ENOUGH FOR INFORMATION ABOUT YOUR INVOLVEMENT 6 WITH'QUILTEC, THERE WOULD BE.SOME INFORMATION TO BE FOUND.
7 YOU' KNEW'THAT BEFORE MARCH 9, DIDN'T YOU, MR. PARKS?-
h 8 MR., JOHNSON: OBJECTION. YOU HAVE TO BE A LITTLE 9 CLEARER. WHAT PEOPLE ARE YOU TALKING ABOUT?
~10 MR. HICKEY: ANYBODY WHO YOU WANTED TO LOOK 11 THE WITNESS: THE ONLY INFORMATION THAT ANYONE 12 COULD HAVE FOUND OUT.ABOUT MY INVOLVEMENT WITH: QUILTEC WAS
'13 - MY SUGGESTING BEN SLONE IN GETTING THE CONTRACT AT LILCO 1 14 AND'MY ARRANGING TO HAVE THE TYPING DONE AND THAT WAS-THE i
15 EXTENT OF MY. INVOLVEMENT.
16 Q BY MR. HICKEY: THAT'S NOT QUITE ACCURATE, IS 17 IT? IF SOMEONE HAD CHECKED AT BEAVER VALLEY, THEY'WOULD 18 ' HAVE FOUND A QUILTEC PROPOSAL WITH YOUR RESUME ATTACHED TO 19 IT?
'1 20 4 THAT WAS NOT SENT BY ME.
21 Q I DIDN'T SAY THAT IT WAS.
22 A WELL, YOU KNOW --
l l
23 Q. THERE WAS A RESUME WITH YOUR NAME ON IT AT j 24 BEAVER VALLEY ATTACHED TO A QUILTEC PROPOSAL, WASN'T l
25 THERE?
]
1 111-32 I L
l u
1 i
1 A SIR, I BELIEVE IF YOU HAD CHECKED OTHER POWER 2 PLANTS, YOU WOULD HAVE FOUND MY NAME IN A PROPOSAL UNDER j 3 THE LETTERHEAD OF SUNBELT TECHNICAL SERVICES.
4 MR. JOHNSON: THE PREMISE TO THE QUESTION HAS NO 5 FOUNDATION. HAS NOT BEEN ESTABLISHED THAT MR. PARKS WAS 6 AWARE THAT HIS NAME WAS IN A PROPOSAL THAT HAD BEEN 7 RECEIVED BY THE BEAVER VALLEY.
8 MR. HICKEY: WELL, IT'S BEEN ESTABLISHED THAT HIS i
9 NAME WAS ON A QUILTEC RESUME ATTACHED TO A BEAVER VALLEY j 10 PROPOSAL. AND HE MIGHT HAVE INFERRED FROM THAT THAT IT 11 MIGHT HAVE GONE TO BEAVER VALLEY; HE MIGHT NOT HAVE.
I i 12 MR. JOHNSON: YOU SHOULD HAVE ASKED HIM. !
13 MR. HICKEY: AND I THINK THE QUESTION IS CLEAR-AND 14 THE WITNESS HAS ANSWERED. ,
l 15 Q BY MR. HICKEY: WERE THERE ANY OTHER I -16 PROPOSALS AT ANY OTHER POWER PLANTS WITH QUILTEC I
17 LETTERHEAD THAT HAD YOUR NAME ON IT, MR. PARKS?
18 A IF THERE WERE, SIR, I WAS UNAWARE OF IT AT 19 THE TIME AS I AM UNAWARE OF IT AT THIS TIME. .;
20 Q NOW THEN YOU'VE TOLD US ALREADY THAT YOU GOT 21 THIS TELEPHONE CALL FROM MR. KING RECORDING ON HIS MEETING 22 WITH BOB ARNOLD AND YOU REMEMBER THAT BEING THE MEETING 23 WHICH WAS MARCH 9 WHICH WAS THE DATE OF THE MEETING?
24 A 1 BELIEVE IT TO BE ON OR ABOUT MARCH 9TH OR 25 10TH, YES.
111-33
1 Q l THINK YOUR-AFFIDAVIT SAYS IT WAS -- MAKE 2 YOU A LITTLE MORE CONFirk T ABOUT THE DATE. ON PAGE 44 --
3 A 44?
4 Q 44. "THAT A. HOME THE EVENING OF MARCH 9 5 LARRY KING CALLED AGAIN," SO ON.
6* A OKAY.
7 Q WHEN LARRY CALLED YOU, YOU'VE TOLD US, BOTM 8 IN YOUR AFFIDAVIT AND IN YOUR TESTIMONY HERE ABOUT HIS 9 COMMENTS TO YOU REGARDING MR. ARNOLD'S QUESTIONS ABOUT 10 YOU, DID YOU ASK MR. KING OR DID MR. KING TELL YOU ABOUT 11 THE REST OF HIS CONVERSATION WITH MR. ARNOLD BESIDES THE 12- PART THAT RELATED TO RICK PARKS?
l 13 A THE ONLY PART THAT I CAN RECALL OF THE 14 CONVERSATION IS WHAT I STATE RIGHT HERE IN THE AFFIDAVIT.
15 THAT'S ALL I CAN RECALL AT THIS MOMENT.
16 Q YOU WERE AWARE, WEREN'T YOU, MR. PARKS THAT 17 MR. KING WAS SECRETLY TAPE RECORDING HIS CONVERSATIONS I 18 WITH MR. ARNOLD?
19 MR. JOHNSON: WHEN7 20 MR. HICKEY: ON AND BEFORE MARCH 9 21 MR. JOHNSON: 1 MEAN THE CONVERSATIONS YOU'RE 22 TALKING ABOUT, BUT WHEN -- WHEN HE BECAME AWARE OF IT.
23 Q BY MR. HICKEY: WERE YOU AWARE ON MARCH 9 OR 24 BEFORE THAT MR. KING WAS TAPING HIS CONVERSATIONS WITH 25 MR. ARNOLD?
111-34
1 1 A 1 COULD NOT TELL YOU, AT THIS POINT IN TIME, 2 SIR, IF 1 WAS AWARE OF THAT OR NOT.
3 Q DID YOU EVER LISTEN TO MR. KING'S TAPE OF HIS 4 MARCH 9 MEETING WITH MR. ARNOLD THAT INVOLVED YOU?
5 A NOT THAT 1 CAN RECALL, SIR.
6 Q YOU DON'T HAVE ANY RECOLLECTION OF MR. KING 7 TELLING YOU IN THE MARCH 9 TELEPHONE CONVERSATION THAT HE 8 HAD MR. ARNOLD'S WORDS DOWN ON TAPE?
9 A IF HE DJD TELL ME THAT, SIR, 1 DON'T HAVE ANY 10 RECOLLECTION OF IT AT THIS TIME, NO.
11 Q DO YOU HAVE ANY RECOLLECTION, MR. PARKS, OF 12 MR. KING INFORMING YOU IN THIS TELEPHONE CONVERSATION ON 13 MARCH 9 WHAT HE HAD SAID ABOUT MR. CHWASTYK AND THE TRIP 14 TO BEAVER VALLEY -- SAID OR NOT SAID?
15 A SIR, I BELIEVE YOU ASKED ME THE SAME QUESTION 16 ABOUT THREE QUESTIONS AGO WHEN YOU ASKED ME IF --
DID 1 17 RECALL ANYTHING ELSE IN THE' CONVERSATION. I TOLD YOU, AT 18 THAT TIME, THAT THE ONLY THING THAT I CAN RECALL, AT THIS 19 MOMENT, WAS WHAT WAS TAKEN IN MY AFFIDAVIT.
20 Q WELL, NOT TO BELABOR IT, MR. PARKS, BUT 21 YOU'VE BEEN DEPOSED MUCH MORE THAN I HAVE, AND 1 THINK YOU 22 RECOGNIZE THAT IT'S NOT UNCOMMON THAT AFTER A GENERAL j 23 QUESTION DIRECTING A WITNESS TO AN AREA AND A RESPONSE 24 THAT THE WITNESS DOES NOT RECALL, SOMETIMES SPECIFIC 25 QUESTIONS HELP THE WITNESS' MEMORY TO RECALL SOMETHING 1
111-35 ,
I j
1 THAT THEY'OTHERWISE_WOULDN'T HAVE. THAT'S W H Y -1.' P U T THE
- 2. SPECIFIC' QUESTION TO YOU.
D.
3 A I' AGREE WHOLEHEARTEDLY. I HAVE EVEN 4 EXPERIENCED THAT'SAME' PHENOMENA. 'BUT NO, SIR, I DON'T:
5 HAVE ANY'BETTER' RECALL, AT THIS. MOMENT'-- 11 DON'T HAV5 ANY 6- ADDITIONALLINFORMATION THAT COMES TO MIND, AT-THIS MOMENT, 7- REGARDING-THAT CONVERSATION OTHER THAN WHAT APPEARS-lN MY 8 AFFIDAVIT.
'9 -Q DID YOU-UNDERSTAND FROM WHAT MR. KING. TOLD ;;
10 YOU ON THE TELEPHONE THE EVENING OF MARCH 9 -- DID YOU l
[ 11 VIEW THAT REPORT AS SOME KIND OF THREAT AGAINST YOU?
12 A COULD YOU REPEAT THAT, SIR?-
13 Q SURE.
1 14' MR. KING CALLED YOU ON MARCH 9 IN THE 15' EVENING, WE'VE JUST BEEN-TALKING ABOUT IT, AND TOLD YOU' 16 ABOUT HIS CONVERSATION WITH MR. ARNOLD THAT HE,JUST'HAD.
17 A -RIGHT.
18 Q DID YOU VIEW WHAT HE TOLD YOU ABOUT ARNOLD 19 ASKING'ABOUT MR. PARKS AS;,50ME KIND OF THREAT?
20 A WELL, SIR, IF 1 REMEMBER CORRECTLY, IT WAS 21 NOT JUST LIKE HE WAS ASKING ABOUT RICK PARKS. IT WAS,
- 22. LIKE, WELL " PARKS KNEW, DIDN'T HE"; "WHAT ABOUT PARKS,"
23 SOMETHING TO THAT NATURE. AND YES, i VIEWED THAT AS NOT A 24 THREAT, BUT HE --
THREAT MAY BE A BAD WORD. I VIEWED THAT 25 GPU MANAGEMENT WAS BOUND AND DETERMINED TO IMPLICATE ME IN 111-36
1 ONE FASHION OR ANOTHER AND THEREBY POSSIBLY USE THAT 2 INFORMATION AS THE PRETEXTUAL (SIC) FABRICATION FOR ,
3 REMOVING ME FROM THE JOB SITE.
4 Q WELL --
~'
5 A SO I GUESS TO SUMMARIZE IT I WOULD CONSIDER 6 IT A THREAT.
7 Q YOU KNEW LARRY KING WAS CLAIMING THAT HIS 8 INVOLVEMENT WITH QUILTEC WAS COMMON KNOWLEDGE ON THE SITE, 9 DIDN'T YOU?
10 MR. JOHNSON: WOULD YOU REPEAT THAT, SIR.
11 Q BY MR. HICKEY: YOU KNEW LARRY KING WAS 12 CLAIMING THAT HIS INVOLVEMENT WAS COMMON KNOWLEDGE ON THE 13 SITE? x 14 A I BELIEVE THAT TO BE TRUE, YES.
15 Q AND YOUR RESPONSE TO MR. KING, WHEN HE MADE 16 THIS COMMENT TO YOU ON THE PHONE, WAS THAT MR. KING SHOULD 17 HAVE TOLD MR. ARNOLD ABOUT YOUR INVOLVEMENT WITH QUILTEC 18 AND THE TYPING OF THE RITTLE RESUMES, RIGHT?
19 A YES, 1 FELT MR. KING SHOULD HAVE ADVISED HIM .
20 THAT I WAS A PERSON THAT WAS AWARE OF QUILTEC.
21 Q SO I DON'T UNDERSTAND YOUR TESTIMONY ABOUT 22 THE THREAT. WHY WAS IT DANGEROUS TO YOU IF MR. ARNOLD 23 KNEW THAT MR. PARKS WAS SOMEONE WHO KNEW ABOUT KING'S j
24 INVOLVEMENT WITH QUILTEC?
l 25 A I THINK IT WAS MORE THE WAY THE INQUIRY WAS 111-37
i 1- CHARACTERIZED TO ME THAT MADE ME BE CONCERNED, IF THAT 2 ANSWERS YOUR QUESTION. I COULD NOT UNDERSTAND'WHY --
0F-f 3 ALL'THE PEOPLE ON THE JOB SITE THAT WERE AWARE OF QUILTEC, 4 WHY BOB ARNOLD WAS SINGLING ME OUT.
5 Q DID YOU THINK THAT PERHAPS MR. ARNOLD HAD 6 LEARNED ABOUT ROSE RITTLE AND THE TYPING OF THE RESUMES?
7 A WELL, AT'THE TIME I WAS NOT --
I WAS UNAWARE 8- OF TPAT, BUT I'M AWARE OF IT NOW THAT HE WAS INFORMED OF 9 THAT BY THAT TIME FRAME, YES.
10 Q BUT WHEN MR. KING WAS TELLING YOU-ABOUT IT OR 11 SHORTLY THEREAFTER, YOU DIDN'T --
THAT DIDN'T POP INTO 12 YOUR MIND AS A POSSIBLE EXPLANATION FOR WHY BOB ARNOLD WAS 13 ASKING' LARRY KING ABOUT YOU?
14 A NO. IT SEEMED TO ME THAT BOB ARNOLD WAS
-15 SINGLING ME OUT BECAUSE I WAS AWARE OF NUMEROUS PEOPLE 16 THAT WERE AWARE OF LARRY KING'S ACTIVITIES FOR QUILTEC, 17 PUT IT THAT WAY.
18 Q WELL, MR. ARNOLD HAD ASKED LARRY KING WHO 19 THOSE PEOPLE WERE, HAD HE NOT, BOTH IN WRITING AND 20 APPARENTLY IN THIS MEETING THAT KING REPORTED?
21 MR. JOHNSON: ARE YOU ASKING WHETHER HE KNEW AT THE !
22 TIME OF THE CONVERSATION ON MARCH 9TH, 1983, OR DOES HE 23 KNOW NOW7 24 Q BY MR. HICKEY: I'M ASKING ABOUT WHAT YOU 25 KNEW ON MARCH 9TH.
111-38
a 1 A I DO NOT RECALL, AT THIS MOMENT, SIR, IF 2 LARRY --
WHO ELSE LARRY KING HAD IDENTIFIED AS KNOWING 3 ABOUT QUILTEC. 50 THAT'S WHY I FOUND IT SO IRONICAL THAT 4 BOB ARNOLD WOULD JUST HONE IN ON ME LIKE AN EXOCET 5 MISSILE.
6 Q IF YOU HAD A CONCERN, OR A QUESTION IN YOUR 7 MIND WAS PROMPTED IN PART BECAUSE IT APPEARED TO YOU THAT 8 HE WAS SINGLING YOU OUT, WOULDN'T YOU HAVE ASKED MR. KING 9 WHO ELSE BOB ARNOLD ASKED ABOUT OR KING TOLD ARNOLD ABOUT 10 THAT KNEW ABOUT QUILTEC?
11 MR. JOHNSON: YOU'RE ASKING HIS OPINION; WHAT HE 12 SHOULD HAVE BEEN DISCUSSING OR WHAT HE DID DO AT THE TIME?
13 MR. HICKEY: l'M SUGGESTING THAT IT MAY STIMULATE 14 THE WITNESS' MEMORY IF HE THINKS ABOUT WHAT LOGICALLY 15 MIGHT HAVE BEEN ASKED.
16 Q BY MR. HICKEY: DID YOU ASK MR. KING ABOUT '
17 WHO ELSE WAS NAMED?
18 A I BELIEVE I MAY HAVE ASKED LARRY KING IF 19 BOB ARNOLD ASKED HIM IF ANYBODY ELSE KNEW, I MEAN, BY I 20 NAME. "DID HE SAY, WHAT ABOUT BUBBA MARSHALL?" "DID 21 BUBBA MARSHALL KNOW" BECAUSE BUBBA MARSHALL KNEW, YOU 22 KNOW.
23 Q WHO ELSE DID YOU ASK HIM ABOUT?
24 A l'M NOT SAYING THAT I DID. YOUR STATEMENT IS 25 PREFACING THAT I DEFINITIVELY STATED THAT. I DID ASK 111-39
i 1 HIM -- I BELIEVE I STATED THAT I MIGHT HAVE ASKED HIM.
2 BUT AT THIS POINT IN T I M E', . I COULD NOT STATE WITH 3 CERTAINTY IF I DID OR NOT.
4 Q AND YOU DON'T REMEMBER WHETHER YOU ASKED OR 5 NOT? IS IT YOUR TESTIMONY THAT YOU DON'T REMEMBER WHETHER 6 MR. KING TOLD YOU WHO ELSE HE HAD IDENTIFIED AS KNOWING 7 ABOUT QUILTEC?
8 A THAT IS CORRECT, SIR. AT THIS POINT IN TIME, 9 I DO NOT RECALL IF LARRY KING, IN FACT, TOLD ME OVER THE 10 TELEPHONE EVERY PERSON HE IDENTIFIED IN THAT RESPONSE.
~11 Q HOW ABOUT ANY PERSONS THAT HE IDENTIFIED?
12 A I REALLY COULDN'T TELL YOU, AT THIS POINT IN i
13 TIME, IF HE TOLD ME OF ANY OF THEM.
i 14 Q YOUR CONVERSATION WITH MR. KING, MEETING IN 15 THE EVENING OF MARCH 9, MR. PARKS, INCLUDED MR. KING 16 INFORMING YOU --
WHAT DID MR. KING TELL YOU ABOUT WHAT HE 17 RESPONDED TO MR. ARNOLD'S QUESTIONS ABOUT WHETHER PARKS 18 KNEW?
19 A I DON'T KNOW --
I'M NOT REALLY CERTAIN, BUT I 20 THINK HE MAY HAVE TOLD BOB ARNOLD SOMETHING TO THE EFFECT 21 THAT HE WAS NOT SURE IF I KNEW OR IF HE KNEW -- I MEAN IF 22 I KNEW. I KNOW THAT'S KIND OF A CONFUSING STATEMENT. BUT 23 IF MEMORY SERVES ME CORRECTLY RIGHT NOW, I BELIEVE 24 LARRY KING TOLD BOB ARNOLD IN RESPONSE TO ARNOLD j 25 REQUESTING --
OR INQUIRING REGARDING WHETHER OR NOT I l
111-40 )
l l
l
-1 KNEW, THAT KING TOLD HIM HE WAS UNSURE IP I KNEW OR NOT.
2 AT LEAST THAT'S WHAT I SEEM TO RECALL RIGHT NOW.
3 Q AND THEN YOU SAID TO HIM IN SUBSTANCE THAT HE 4 SHOULD HAVE MENTIONED YOU BECAUSE OF THE ROSE RITTLE 5 RESUMES?
6 A I DO NOT BELIEVE I STATED THAT, SIR. I 7 BELIEVE I STATED TO LARRY KING THAT HE SHOULD HAVE JUST I 8
TOLD BOB ARNOLD THAT I WAS A PERSON AWARE OF QUILTEC.
9 Q OH, ALL RIGHT. DID KING INDICATE THAT THE 1
k l 10 REASON HE HAD NOT WAS BECAUSE HE HAD FORGOTTEN THAT YOU '
11 WERE AWARE?
12 A IF HE DID, SIR, I DON'T REMEMBER HIM MAKING 13 SUCH A STATEMENT LIKE THAT, NOT AT THIS TIME. I WOULD.
14 ONLY BE ABLE TO SPECULATE OR HAVE TO SPECULATE WHY I
15 LARRY KING DIDN'T TELL HIM.
16 Q WELL, LET ME ASK YOU THIS SPECIFIC QUESTION, 17 MR. PARKS.
r 18 DID LAkRY KING TELL YOU THAT HE DELIBERATELY 19 TRIED TO CONCEAL RICK PARKS' KNOWLEDGE OF QUILTEC FROM 20 BOB ARNOLD IN THE MEETING OF MARCH 9? {
21 A I DO NOT RECALL SUCH A STATEMENT OCCURRING IN 22 MY CONVERSATION, NOT AT THIS POINT IN TIME. I DO NOT 23 RECALL THAT.
24 Q AT ANY LATER TIME DID MR. KING TELL YOU THAT 25 HE TRIED TO CONCEAL YOUR NAME FROM BOB ARNOLD IN THE j 1
111-41 i
I 1 MEETING OF MARCH 9?
2 A I DO NOT BELIEVE THAT SUCH A CONVERSATION i
3 LIKE'THAT.EVER OCCURRED, NO. IF IT DID, I DO NOT RECALL I 4
4 AT THIS MOMENT.
I 5 Q NOW, MR. PARKS, THE NEXT DAY, MARCH 10, YOU 1 I
6 WENT TO SEE THE NRC'AT THREE MILE ISLAND, DID YOU NOT? l i
7 A YES, SIR, THAT'S CORRECT, )
8 Q AND BEFORE YOU WENT TO THE NRC, ACCORDING TO 4 9 YOUR AFFIDAVIT, YOU TALKED WITH MR. GISCHEL AND SOME .
I 10 OTHERS. DO YOU REMEMBER THAT?
l 11 A I RECALL THAT HAPPENED, YES. )
12 MR. JOHNSON: WOULD YOU POINT OUT A PAGE.
13 MR. HICKEY: YES. INDICATING TO THE WITNESS THE 14 REFERENCE ON PAGE 45. I 15 Q BY MR. HICKEY: DO YOU FIND'THAT THERE, j i
16 MR. PARKS? YOU MIGHT WANT TO READ WHAT YOU SAID THERE IN 17 THE SECOND PARAGRAPH ON PAGE 45.
l 18 A OKAY. I SEE THE STATEMENT YOU'RE TALKING l l
l 19 ABOUT.
l 20 Q IN ADDITION TO MR. HRBAC AND MR. GISCHEL, WHO l l
21 WAS THE OTHER MEMBER OF PLANT ENGINEERING THAT YOU l 22 DISCUSSED THE MEETING WITH OR DISCUSSED THE ISSUE WITH?
23 A I REALLY DON'T RECALL THE GENTLEMAN'S NAME.
24 HE WAS A RELATIVELY NEW INDIVIDUAL TO THE ORGAN!ZATION. '
25 Q WAS IT JUST ONE MEETING THAT YOU HAD WITH ALL 111-42
(.
l l
l 1 0F THESE PEOPLE TOGETHER -- HRBAC, GISCHEL, AND THE OTHER l
2 PERSON?
l 3 A I DO NOT KNOW IF IT WOULD BE PROPER TO 1
4 CHARACTERIZE IT AS A MEETING. ED GISCHEL AND CARL HRBAC l 5 AND I'WERE IN. CARL HRBAC'S OFFICE SPACE, AND THE OTHER 6 GENTLEMAN SHARED'THE OFFICE SPACE WITH CARL HRBAC. AND I l 7 WAS TALKING OVER WITH ED, AND CARL WAS PRESENT, AND I )
i 8 ASKED CARL TO GO WITH ME TO THE NRC.
]
l 9 Q AND WERE YOU ASKING ED GISCHEL'S ADVICE ON 10 WHETHER YOU SHOULD TO GO THE NRC?
4 11 A YES, I WAS TALKING IT OVER WITH ED GISCHEL i
12 AND I -- IF MEMORY SERVES ME CORRECTLY, AT THE MOMENT, I '
I 13 RELAYED TO ED GISCHEL AND, OF COURSE, IN THE PRESENCE OF l l
14 CARL HRBAC, MY CONVERSATION WITH LARRY KING THE NIGHT 1 e i 15 BEFORE AND, YOU KNOW, HOW I FELT THAT GPU CR MANAGEMENT l
16 WAS TRYING TO IMPLICATE ME TO JUSTIFY GETTING RID OF ME '
17 BECAUSE -- BUT TO ME THAT WAS LIKE THE THIRD INCIDENT OF 18 HARASSMENT OR RETALIATION THAT I WAS BEING SUBJECTED TO 1
I 19 AND I WAS STARTING TO BECOME VERY CONCERNED.
l 20 Q AND DID YOU TELL MR. GISCHEL AND MR. HRBAC l 21 AND THIS THIRD PERSON IN THE CONVERSATION WHAT YOUR 22 INVOLVEMENT WAS WITH QUILTEC?
l 23 A SIR, AT THE TIME I CONSIDERED THERE TO BE NO ]
l 24 INVOLVEMENT ON MY PART IN QUILTEC; SO THEREFORE, I
(. J l 25 CONSIDERED IT PURELY PRETEXTUAL (SIC).
l III-43 !
'1
- 1. Q LET.ME REPHRASE'IT DIFFERENTLY.
2 WHAT DID'YOU TELL THEM ABOUT YOUR. CONNECTION 13- OR NONCONNECTION WITH QUILTEC?-
4 'A I DON'T THINK IT WAS DISCUSSED. IF -IT WAS,.I i
p 5- DON'T-RECALL-AT-THIS POINT IN TIME, OTHER THAN THE FACT'I
- 6. KNEW QUILTEC EXISTED. BUT l'M OF THE BELIEF THAT THOSE
- 7. . GENTLEMEN WERE' AWARE THAT QUILTEC EXISTED ALSO.
8 ~Q THE REASON I ASKED THE QUESTION IS IF YOU 9 WERE' TELLING THESE' PEOPLE YOU WERE WORRIED ABOUT
~ 10. MR. ARNOLD TRYING TO SET UP SOME "PRETEXTUAL" BASIS TO GET
! 11 RID'0F-YOU OR RETALIATE AGAINST YOU --
12 .A I BELIEVE THAT THE GIST OF THE CONVERSATION.
13 THAT I HAD WITHzTHOSE GENTLEMEN WOULD HAVE BEEN ALONG THE:
14 LINES THAT I THOUGHT BOB ARNOLD WAS'-- OR. MANAGEMENT --
L15' YOU KNOW, I DON'T REMEMBER IF I SPECIFIED TO BOB ARNOLD 16 THAT MANAGEMENT WAS TRYING TO IMPLICATE ME ON'A CONFLICT-17 0F INTEREST LIKE THEY HAD LARRY. AND I WAS WORRIED THAT 4
18 THEY WERE GOING TO GET RID OF ME'THE SAME WAY THEY HAD
. 19- GOTTEN RID OF LARRY. t
- 20. AND I DISCUSSED IT OVER WITH ED GISCHEL AND 21 .YOU KNOW -- ED WAS A GENTLEMAN THAT I RESPECTED AND I HAD 22 A' LOT OF --
PLACED A LOT OF EMPHASIZE ON THE MAN'S ADVICE I
.23 BECAUSE I THOUGHT HE WAS A VERY LEVELHEADED, CALM, COOL 24 COLLECTED INDIVIDUAL. AND ED AGREED THAT HE THOUGHT THE l l
25 BEST THING I COULD DO WOULD BE TO GO TO THE NRC AND REPORT III-44 ,
-_ -- - 1
2 IN FACT, I EVEN ASKED HIM AS A MEMBER OF THE 3 STAFF --
IF IT WAS OKAY WITH HIM AS A MEMBER OF ED'S 4 STAFF, MEANING CARL HRBAC, IF IT WAS OK'AY IF CARL 5 ACCOMPANIED ME TO THE NRC BECAUSE MY PREVIOUS ENCOUNTERS 6 WITH THE NRC HAD LEFT ME WITH NOT A WHOLE LOT OF TRUST FOR !
7 ME, AND'I WANTED AN INTERESTED WITNESS WITH ME. i l
8 Q WELL, DID YOU TELL MR. HRBAC AND MR. GISCHEL 9 ON THIS OCCASION ABOUT YOUR GETTING THE QUILTEC RESUMES 10 TYPED BY ROSE.RITTLE?
11 A I DON'T BELIEVE THAT WE DISCUSSED'IT. IF WE 12 DON'T, I DON'T RECALL AT THE MOMENT. j l
l 13 Q DO YOU HAVE ANY BASIS FOR THINKING THAT THEY 14 OTHERWISE KNEW ABOUT YOUR GETTING THE RESUMES TYPED BY 15 ROSE RITTLE?
16 A I REALLY DON'T, TO TELL YOU THE TRUTH AT THIS I
17 POINT IN TIME, SIR, IF THEY WERE AWARE OF THAT OR NOT.
18 Q DID MR. GISCHEL INDICATE TO YOU IN THIS 1 1
19 CONVERSATION ON --
ARE WE TALKING ABOUT THE MORNING OF 1
20 MARCH 10TH BY THE WAY, MR. PARKS?
21 A IF MY RECALL IS ACCURATE, I BELIEVE IT WAS l 22 EARLY IN THE MORNING.
23 Q ! CAN JUST ASSUME IT WAS THE MORNING OF 24 MARCH 10TH. I REALIZE YOU'RE NOT CERTAIN OF THAT. !
l 25 !
IN THIS CONVERSATION ON THE MORNING OF 111-45
1 MARCH 10TH, DID MR. GISCHEL TELL YOU THAT HE HAD HAD I
2 OCCASION TO DISCUSS WITH MR. KING THE ISSUE OF CONFLICT OR i k '
3- POSSIBLE CONFLICT OF INTEREST ARISING FROM MR. KING'S i
4 QUILTEC ACTIVITIES?
5 A I DON'T RECALL, AT THIS POINT IN TIME, IF ED 6 BROUGHT THAT UP IN A CONVERSATION OR NOT. I WAS -- I HAD 7 OTHER THINGS ON MY MIND. ,
8 Q DID MR. GISCHEL OR MR. HRBAC EXPRESS ANY 9 VIEWS ABOUT WHETHER MR. KING WAS INVOLVED IN A CONFLICT OF 10 INTEREST WITH QUILTEC IN THIS CONVERSATION ON THE MORNING 11 OF MARCH 10TH?
~
12 A NOT THAT I CAN RECALL AT THE MOMENT.
14 Q SURE.
15 (RECESS.)
16 Q BY MR. HICKEY: WHEN YOU WENT ON MARCH 10 TO 17 THE NRC WITH MR. HRBAC, MR. KING, YOU TOLD THEM ABOUT THE 18 TELEPHONE MESSAGE YOU'D HAD FROM LARRY KING THE NIGHT j 19 BEFORE; AND DID YOU -- I KNOW YOU DID, BUT DID YOU? 1 20 A DID I --
21 Q DID YOU TELL THE NRC ABOUT YOUR PHONE
]
22 CONVERSATION WITH MR. KING?
23 A I BELIEVE I TOLD THEM THAT I THOUGHT I WAS l 24 ABOUT TO BE IMPLICATED IN THE WHOLE THING, SO YES, I GUESS 25- THE ANSWER TO YOUR QUESTION IS YES.
III-46
I l
i 1 Q THIS IS IN A MEETING WITH MR. WEIBE?
l !
2 A RIGHT, JOEL WEIBE. I l '3 Q DID YOU TELL MR. WEIBE ABOUT YOUR GETTING THE L
L I
4 RESUMES TYPED FOR MR. KING BY ROSE RITTLE?
i 5 A NO,. SIR. WHAT I DID WAS REQUEST AN O.1.
6 INVESTIGATION 7 Q WELL, YOU DID TELL THEM --
I ASSUME YOU 1
8 EXPLAINED TO HIM IN SOME FASHIDN WHY YOU THOUGHT YOU WERE l 9 BEING SET UP?
10 A IF MY MEMORY SERVES ME CORRECTLY, AT THIS j
- 11 MOMENT, I BELIEVE I TOLD HIM I THOUGHT I WAS BEING SET UP.
l
! 12 Q AND DID YOU KNOW WHY YOU THOUGHT THAT OR WHAT 13 THE BASIS FOR YOUR VISIT WAS?
l 14 A NO. MR. WEIBE'S RESPONSE TO ME, IF 1 CAN 15 RECALL AT THE MOMENT, WAS SOMETHING ALONG THE LINE THAT j 16 THEY WERE EXPECTING ME, THEY, BEING THE NRC, AND THAT THEY
{ 17 SUGGESTED THAT O.1. HAD ALREADY LOOKED INTO EVERYTHING AND 18 THEY CONSIDERED IT TO BE AN EMPLOYER / EMPLOYEE RELATIONSHIP 19 PROBLEM. THE MAN THEN HANDED ME A NOTE CONTAINING THE 20 DEPARTMENT OF LABOR ADDRESS IN WASHINGTON D.C. AND TOLD ME 21 TO TAKE MY PROBLEM TO THE DOL.
22 Q I WANT TO MAKE SURE YOU DIDN'T MISSPEAK I
23 YOURSELF. YOU SAID THAT MR. WEIBE SUGGESTED TO YOU THAT l i
24 0.1. HAD ALREADY LOOKED INTO EVERYTHING. IS THAT WHAT YOU l
25 MEANT TO SAY?
]
1 1
111-47
)
1 A THE NRC, 1 MEAN.
2 Q' DID Y'0U MEAN SPECIFICALLY1THE OFFICE OF' 1
3- INVESTIGATIONS?
-4 A l'BELIEVE THAT HE HAD MADE SOME, REFERENCE TO 5- IT --
THEIR OPINION, THEIR BEING THE NRC OPINION, 6 REGARDING THE' EMPLOYER / EMPLOYEE RELATIONSHIP PROBLEM HAD ,
7- BEEN CORROBORATED BY'O.l.; THAT THE WHOLE DEAL WAS AN:
l 8 EMPLOYER / EMPLOYEE. PROBLEM.
9 Q SO YOU DID NOT, IN YOUR MEETING WITH 10 MR. WEIBE, ON THE'10TH OF MARCH EXPLAIN-TO HIM ANY FACTS 3 11 ABOUT YOUR RELATIONSHIP WITH QUILTEC OR KNOWLEDGE OF :I l
12 QUILTEC?
'13 A I AM OF THE OPINION, AT THIS MOMENT IN TIME,
.14 SIR, THAT THE ENTIRE MATTER WAS NOT DELVED INTO DURING.THE ,
15 COURSE OF-OUR CONVERSATION.
16 Q .LATER --
EXCUSE ME, DID YOU WANT TO ADD 17 SOMETHING TO YOUR ANSWER? l l
18 A YES, I DID.
19 THAT WAS ONE REASON WHY I WANTED THE O.I. j 20 INVESTIGATION --
THAT'S WHY I REQUESTED IT. I KNEW THAT I l
21 WOULD BE EXONERATED OF ANY BLAME OF ANY IMPLICATION 1
22 INVOLVED WITH QUILTEC, AND 1 WANTED THE NRC TO TAKE A LOOK I
- 23 AT WHAT WAS GOING ON. .
1 24 Q AND MR. WEIBE, INSTEAD, REFERRED YOU TO THE 25 DEPARTMENT OF LABOR, RIGHT?
l 111-48 ;
w-__m--._A.-- _-m.______ -__.______-_iwa,.....,__,_-,,..m.s- - _ -- _ . , _ _ - - - - _ - - _ . - _ _ , , - . , . -- _ ..,-m. . _ - .,_______c -- _ _ _ _ _ _ _ _ _ - - __ -
1 A YES, SIR, I THINK THAT VERY ACCURATELY ,
2 CHARACTERIZES IT. HE TOLD ME TO TAKE MY PROBLEM TO THE I
3 DEPARTMENT OF LABOR.
l 4 Q AND WHEN DID YOU FIRST CONTACT OR ATTEMPT TO 1 5 CONTACT THE DEPARTMENT OF LABOR? l 1
6 A WELL, NOW IF 1 REMEMBER CORRECTLY, THAT WAS 7 ON MARCH 10TH WHEN I TALKED WITH MR. WEIBE OF THE NRC. ]
l 8 Q~ YES.
9 A AND THE VERY NEXT WEEK, I BELIEVE IT WAS, 1 10 CONCLUDED AN AGREEMENT WITH THE LAW FIRM -- LEGAL 11 REPRESENTATION. AND FROM THAT POINT ON, THE DECISION WAS 12 MADE 1 WOULD TO GO THE DEPARTMENT OF LABOR.
13 Q THE 10TH WOULD HAVE BEEN ON A THURSDAY, SO 14 YOU'RE TALKING ABOUT THE WEEK OF THAT --
BEGAN ON MONDAY 15 0F MARCH 14. SOMETIME DURING THAT WEEK YOU CONCLUDED AN 16 AGREEMENT WITH A LAW FIRM TO REPRESENT YOU?
17 A YES, SIR.
18 Q AM i UNDERSTANDING CORRECTLY THAT YOU DID 19 NOT, PRIOR TO CONTACTING THE LAW FIRM, ATTEMPT TO CONTACT 20 THE DEPARTMENT OF LABOR YOURSELF?
21 A THAT'S EXACTLY CORRECT, SIR.
22 Q IS THE LAW FIRM THAT YOU'RE REFERRING TO THAT l
23 YOU CONCLUDED AN AGREEMENT WITH THE WEEK OF MARCH 14TH THE 24 GOVERNMENT ACCOUNTABILITY PROJECT OR GAP OR 15 IT SOME 25 OTHER LAW FIRM 7 111-49
1
'2 Q WAS THERE ANY PARTICULAR REASON, MR. PARKS, 3 WHY YOU DIDN'T GO DIRECTLY TO THE DEPARTMENT OF LABOR ON 4 MARCH 10TH OR IMMEDIATELY THEREAFTER WHEN MR. WEIBE 5 REFERRED YOU TO THEM? !
6 A WELL, SIR, LATER ON THAT DAY, IF MEMORY
.k 7 SERVES ME CORRECTLY AT THIS MOMENT, I WAS WARNED BY 8 JOE CHWASTYK TO GET A LAWYER; THAT MANAGEMENT KNEW I HAD 9 GONE TO THE NRC AND WAS GOING TO BURN ME FOR IT. HE 10 SUGGESTED THAT 1 KNEW GPU LAWYERS. AND I BELIEVE MY 11 RESPONSE TO HIM WAS "THANKS, BUT NO THANKS."
l 12 Q AND YOU'RE SAYING THAT YOU HEEDED 13 MR. CHWASTYK'S ADVICE THAT YOU OUGHT TO GET A LAWYER SO 14 YOU DELAYED GOING TO THE DEPARTMENT OF LADOR UNTIL YOU 15 COULD DO THAT?
16 A I FELT, AT THAT POINT IN TIME, THAT I NEEDED 17 LEGAL REPRESENTATION.
18 Q YOU ALSO DISCUSSED IN YOUR AFFIDAVIT A 19 MEETING ON MARCH 10 WITH MR. KOBI. DO YOU KNOW JUST IN 20 THE CHRONOLOGICAL SEQUENCE OF EVENTS WHETHER YOU MET 21 MR. KOBI OR MR. CHWASTYK FIRST ON MARCH IO?
22 A I MEANT WITH MR. KOBI BEFORE I MET WITH l
23 MR. CHWASTYK.
1 24 Q AND YOU TOLD MR. KOBI ABOUT MR. KING'S !
25 TELEPHONE CALL TO YOU THE NIGHT BEFORE, DIDN'T YOU?
111-50
- - _ _ _ _ _ - i
1 A IF MEMORY SERVES ME CORRECTLY AT THIS MOMENT, 2 I BELIEVE I DISCUSSED IT WITH MR. KOBI, YES.
3 Q DID YOU ALSO TELL MR. KOBI ABOUT YOUR 4 INVOLVEMENT WITH QUILTEC?
5 A BY " INVOLVEMENT," SIR, DO YOU MEAN MY HAVING 6 TYPED THE FORMS FOR QUILTEC?
7 Q YES.
8 YOU TOLD THEM ABOUT YOUR INVOLVEMENT WITH 9 QUILTEC?
10 A SIR, 1 STATE THAT WAS MY ONLY INVOLVEMENT 11 WITH QUILTEC.
12 Q DID YOU TELL MR. KOBI ABOUT HAVING THE 13 RESUMES TYPED?
14 A SIR, MR. KOBI WAS AWARE OF IT BECAUSE HIS 15 LIVE-IN GIRL FRIEND WAS THE GIRL THAT RECOMMENDED 16 ROSE RITTLE TO ME TO HAVE IT TYPED TO BEGIN WITH.
17 Q SO YOU'RE SAYING MR. KOBI KNEW THAT 18 ROSE RITTLE HAD TYPED QUILTEC RESUMES OR JUST THAT SOME 19 FRIEND OF HIS GIRL FRIEND HAD DONE TYPING FOR YOU?
20 A I BELIEVE, IF MEMORY SERVES ME CORRECTLY AT 21 THIS POINT IN TIME, THAT MR. KOBI WAS AWARE OF THE TYPING 22 OF THOSE RESUMES, YES.
l 23 Q YOUR ANSWER IS AMBIGUOUS, MR. PARKS. DO YOU 24 BELIEVE THAT MR. KOBI KNEW THAT QUILTEC RESUMES HAD BEEN l 25 TYPED BY ROSE RITTLE OR DO YOU BELIEVE THAT MR. KOBI 111-51
- _ _ - _ _ _ _ _ _ - - _ _ _ _ t
1 SIMPLY KNEW THAT RESUMES HAD BEEN TYPED BY ROSE RITTLE?
i 2 A AT THIS POINT IN TIME, I WOULD ONLY STATE 3 THAT I DON'T RECALL ANY DIFFERENCE, AT THIS MOMENT, ANYWAY I
4 THAT MARK WAS AWARE OF THE TYPING, NO. WHETHER HE KNEW ,
5 FOR A FACT THAT THE TYPING WAS DONE ON QUILTEC LETTERHEAD .
6 OR NOT, I COULDN'T REALLY STATE AT THIS MOMENT. BUT I i 7 HAVE NO REASON TO DISBELIEVE'IT EITHER.
8 Q DID YOU TELL MR. KOBI ABOUT THE BEAVER. VALLEY 9 PROPOSAL?
10 A I DON'T RECALL, SIR, IF THAT CAME UP IN THE 11 DISCUSSION OR NOT.
12 Q DO YOU RECALL WHETHER YOU TOLD MR. KOBI THAT
, 13 YOUR RESUMES ON QUILTEC LETTERHEAD WAS ATTACHED TO THE i l
l 14 BEAVER VALLEY PROPOSAL?
15 A AT THIS POINT IN TIME, SIR, I DON'T KNOW, OR l
1 l 16 I DO NOT RECALL IF IT CAME UP IN THE CONVERSATION OR NOT.
17 Q DID MR. KOBI INDICATE ANYTHING TO YOU ABOUT l
.18 WHETHER HE THOUGHT THERE WAS A CONFLICT OF INTEREST l 19 PROBLEM FOR YOU?
20 A ABOUT THE EXTENT THAT I CAN RECALL, AT THIS 21 POINT IN TIME, REGARDING THAT CONVERSATION WITH MR. KOBI 22 WAS MR. KOBI ADVISING ME OF HOW, YOU KNOW -- I COULD GET 23 AHOLD OF SOMEBODY IN BECHTEL UPPER MANAGEMENT AND TAXE -- l 24 YOU KNOW, BRING THOSE PROBLEMS BEFORE HIM. I WASN'T EVEN 25 AWARE OF WHO THE TOP MANAGERS WERE IN GAITHERSBURG AND j I
111-52 l
I I
1 KIND OF ENLIGHTENED ME REGARDING THAT PROCESS.
2 Q' BUT MY QUESTION WAS WHETHER MR. KOB1 TALKED 3 TO YOU ABOUT ANY POTENTIAL CONFLICT OF INTEREST PROBLEM --
4 A NO, SIR, 1 THINK --
5 Q --
YOU HAD WITH QUILTEC?
6 A' I UNDERSTAND THAT YOU MAY BELIEVE THAT I DID 7 NOT ANSWER YOUR QUESTION, BUT I WAS INTENDING MY ANSWER TO 8 PROVIDE TO YOU EVERYTMING I COULD RECALL, AT THIS MOMENT, 9 THAT MARK AND'I DISCUSSED IN THAT CONVERSATION.
-10 Q DO.YOU HAVE ANY RECOLLECTION -- BY THE W A Y ,.
11 WAS THIS CONVERSATION ONE THAT TOOK PLACE DURING THE 12 COURSE OF AN OUTDOOR WALK AROUND BY THE AREA OF THE 13 COOLING TOWER?
14 A YES, .S I R , I BELIEVE IT TO BE, AT THIS MOMENT.
15- Q I BEG YOUR PARDON?
- 16 A I SAID, SIR, AT THIS MOMENT I BELIEVE THAT TO l
17- BE THE CONVERSATION IN QUESTION.
18 Q AND ABOUT HOW LONG DID YOU TALK TO MR. KOBl? I 19 A OH, MAYBE AN HOUR. l'M JUST GUESSING AT THIS 20 POINT IN TIME. I DON'T RECALL EXACTLY HOW LONG THE 21 CONVERSATION WAS.
22 Q BUT IT WAS SOMETHING MORE THAN A BRIEF !
23 FIVE-MINUTE CONVERSATION OR SOMETHING LIKE THAT?
24 A IT WAS A --
YOU KNOW, NOT A, YOU KNOW, COUPLE 25 OF QUICK COMMENTS AND THEN PARTED, BUT IT WAS NOT A REAL 111-53
.1 LONG CONVERSATION EITHER. I COULDN'T PROVIDE ANY MORE OF 2 AN IDEA, AT THIS POINT IN TIME, EXACTLY HOW LONG IT WAS.
3 Q DID YOU EXPRESS TO MR. KGBI, IN THE COURSE OF 4 THIS CONVERSATION, THE INFORMATION THAT YOU EITHER HAD 5 STOPPED DRIVING YOUR CAR TO WORK OR WERE PLANNING ON 6 STOPPING DRIVING YOUR CAR TO WORK BECAUSE OF CONCERNS OF 7 PROHIBITED MATERIAL WOULD BE PLACED IN IT?
8 A I CAN RECALL, AT THIS POINT IN TIME, BEING 9 CONCERNED ABOUT SOMETHING ALONG THAT LINE HAPPENING TO ME, i
10 BUT AT THIS POINT IN TIME, I COULDN'T TELL YOU IF I i
11 MENTIONED THAT TO MARK IN THIS CONVERSATION OR NOT. !
12 Q DID YOU, ABOUT THIS TIME, STOP DRIVING YOUR j
'l 13 CAR TO WORK FOR THAT REASON? j l
l 14 A YES, SIR. )
I 15 Q AND THE REASON WAS SPECIFICALLY WHAT7 l
16 A I WAS AFRAID DRUGS OR OTHER TYPE OF 17 PARAPHERNALIA COULD BE PLANTED IN MY VEHICLE AND GETTING l
18 ME KICKFD OFF THE JOB SITE AND/OR ARRESTED. '
19 Q I TAKE IT YOUR NORMAL PRACTICE WAS TO DRIVE j l
20 YOUR OWN CAR TO WORK BEFORE THIS?
21 A YES, SIR.
22 Q YOU WEREN'T IN A CAR POOL OR SOMETHING?
23 A NO, SIR. ,
24 ON AN INFREQUENT BASIS OTHER GENTLEMEN WOULD 25 RIDE WITH ME OR I WOULD RIDE WITH THEM, BUT NOTHING III-54
1 FREQUENT.
2 Q HOW DID YOU GET TO WORK WHEN YOU STOPPED 3 DRIVING YOUR CAR BECAUSE OF THE CONCERN?
4 A I STARTED BUMMING RIDES.
J 5 Q DID YOU HAVE A USUAL DRIVER THAT YOU RODE i l
6 WITH7 7 A NO, SIR. SOMETIMES I WOULD HAVE MY GIRL 8 FRIEND DROP ME OFF AT THE GATE AND I'D WALK. SOMETIMES I l
l 9 WOULD CATCH RIDES WITH PEOPLE LIKE BUBBA MARSHALL OR MAYBE j 1
10 EVEN MARK KOBI. THERE WERE OTHER --
I HAD NUMEROUS l
11 FRIENDS ON THE JOB SITE, SO I USUALLY M00CHED OFF THEM FOR l
12 A RIDE.
I 13 Q IN THE COURSE OF YOUR DISCUSSION WITH 14 JOE CHWASTYK LATER ON THE 10TH OF MARCH --
AND YOU MAY i
15 WANT TO LOOK AT.YOUR AFFIDAVIT JUST TO REFRESH YOUR 16 RECOLLECTION, MR. PARKS --
IT APPEARS AT THE BOTTOM OF 17 PAGE 46 AND THE TOP OF PAGE 47 --
l 18 A OKAY. l I
19- Q -- YOU INDICATE IN YOUR AFFIDAVIT THAT 20 . MR . CHWASTYK DESCRIBED HIMSELF AS COMING FROM WHAT WAS 21 PROBABLY ONE OF HIS LAST MEETINGS ON THE ISLAND, A MEETING 22 WITHIN WHICH MR. BARTON HAD ASKED HIM ABOUT QUILTEC. DID 23 MR. CHWASTYK INDICATE TO YOU IN ANY WAY DURING THIS 24 MEETING THAT HE WAS WORRIED ABOUT HIS INVOLVEMENT IN 25 QUILTEC?
111-55
l 1 A YOU MEAN -- DID I UNDERSTAND YOUR QUESTION TO 2 MEAN DID HE MAKE STATEMENTS TO ME OR ANYTHING LIKE THAT?
3 Q YES.
4 A I DON'T RECALL JOE MAKING STATEMENTS TO ME ON 5 THOSE LINES OTHER THAN WHAT I STATE IN MY AFFIDAVIT. AT 6 LEAST NOT AT THIS MINUTE I CAN'T RECALL ANYTHING ,
7 ADDITIONALLY.
8 Q WELL, DID YOU TALK TO MR. CHWASTYK ABOUT 9 GOING TO BEAVER VALLEY WITH MR. HOADE ON BEHALF QUILTEC IN 10 THIS MEETING ON MARCH 10TH?
11 A NO, SIR, NOT THAT I CAN RECALL. THE MEETING 12 WAS VERY BRIEF.
13 Q. DID MR. CHWASTYK INDICATE THAT HE KNEW THAT i
14 LARRY KING EAD NOT TOLD MR. ARNOLD ABOUT CHWASTYK GOING TO i
15 BEAVER VALLEY? !
16 A NO, SIR, NOT THAT I CAN RECALL AT THIS I
MOMENT. AS I STATED PREVIOUSLY, THE MEETING WAS VERY 17
]d 18 BRIEF IN NATURE. HE MADE HIS STATEMENT TO ME; I TOOK HIS i l
19 STATEMENT AT FACE VALUE; AND I REQUESTED TO HAVE THE REST j
20 0F THE DAY OFF. I THEN PROMPTLY LEFT THE JOB SITE.
21 Q ONE MORE SPECIFIC QUESTION, MR. PARKS, JUST )
22 SO THE RECORD IS CLEAR.
23 A SURELY.
I 24 Q DID MR. CHWASTYK INDICATE TO YOU, IN THIS 25 CONVERSATION, THAT HE WAS AWARE OF MR. KING'S WRITTEN i
III-56 j l
1 ANSWERS THAT MR. KING HAD PROVIDED TO MR. ARNOLD THE DAY 2 BEFORE? l i
-3 A IF HE DID, SIR, I HAVE NO INDEPENDENT 4 RECOLLECTION OF IT AT THIS MOMENT.
5 Q MR. CHWASTYK KNEW BY MARCH 10TH ABOUT YOUR 6 HAVING THE RESUME TYPED FOR QUILTEC, DIDN'T HE, BY I
7 ROSE RITTLE?
8 A COULD YOU --
9 MR. JOHNSON: YOU'RE ASKING WHETHER HE HAD ANY l l
10 BASIS FOR KNOWING?
11 MR. HICKEY: I'M ASKING THIS WITNESS WHETHER HE 12 KNEW.
13 MR. JOHNSON: OKAY.
14 THE WITNESS: WHETHER I KNEW WHAT?
15 Q BY MR.. HICKEY: WHETHER YOU KNEW CHWASTYK 16 KNEW?
17 A I HAVE NO IDEA, AT THIS POINT IN TIME, IF 18 MR. CHWASTYK WAS AWARE OF THAT OR NOT.
19 Q SINCE WE'VE JUST GONE THROUGH KIND OF A l
20 CHRONOLOGY OF THE DAYS AROUND MARCH 9 WHEN YOU LEARNED 21 ABOUT MR. ARNOLD'S QUESTIONS TO MR. KING, LET ME ASK YOU 22 WHETHER YOU HAVE ANY SHARPER RECOLLECTION OF WHEN YOU 23 DESTROYED THE BEAVER VALLEY PROPOSAL AND RESUMES THAT YOU 24 PREVIOUSLY TOLD US YOU DESTROYED AT SOME POINT IN TIME?
25 A WELL, I THINK " DESTROY" MAY BE OVERLY HARSH III-57
1 OR OVERLY EMPHATIC. I SIMPLY THREW THEM AWAY.
2- Q YOU MEAN IN THE WASTEBASKET?
- 3. A IN THE WASTEBASKET IN THE SITE OPERATIONS 4 BUILDING, YES.
5 Q WELL, YOU THREW THEM AWAY.
6 THE QUESTION l'M ASKING REALLY IS WHEN, 7 MR. PARKS?
8 A I BELIEVE I STATED YESTERDAY THAT IT WAS 9 PROBABLY ON OR ABOUT THE SAME TIME OR SHORTLY AFTER 10 LARRY KING WAS SUSPENDED. I HAVE NO FURTHER RECOLLECTION, 11 AT THIS MOMENT, THAT WOULD PROVIDE A MORE DEFINITIVE DATE.
12 Q YOU GOT WORD ON MONDAY MORNING, THE 14TH THAT 13 MR. HOFMANN WAS COMING TO INTERVIEW YOU; IS THAT RIGHT?
15 Q MR. KITLER GAVE YOU THAT MESSAGE AND TOLD YOU 16 IT WAS TO INTERVIEW YOU ABOUT QUILTEC, DID HE NOT?
18 IF I REMEMBER CORRECTLY, HE CALLED ME ON THE 19 TELEPHONE SHORTLY AFTER I ARRIVED AT THE OFFICE AND TOLD 20 ME WHAT TIME THE GENTLEMEN WERE EXPECTED AND WHERE I WAS l 21 TO MEET WITH THEM AT.
l 22 Q DID YOU TRY TO CONCEAL FROM MR. HOFMANN YOUR l
23 KNOWLEDGE OF LARRY KING'S ROLE IN QUILTEC?
24 A NO, SIR, 1 AM OF THE OPINION THAT I DID NOT 25 TRY TO CONCEAL KNOWLEDGE FROM MR. HOFMANN. ,
i 111-58 1
1 Q LET ME MAKE SURE YOU UNDERSTAND MY QUESTION 2 BECAUSE YOUR RESPONSE GOT SOME OF THE WORDS IN A DIFFERENT 3 ORDER.
4 I WAS ASKING WHETHER YOU TRIED TO CONCEAL 5- FROM MR. HOFMANN YOUR KNOWLEDGE OF KING'S INVOLVEMENT IN 6 QUILTEC.
7 A NO, SIR, I AM OF THE OPINION I.DID NOT 8 CONCEAL KNOWLEDGE OF MY -- MY KNOWLEDGE OF KING'S ROLE IN 9 QUILTEC.
10 IS THAT WHAT YOU'RE ASKING?
11 Q YES.
12 A NO. I AM OF THE OPINION I DID NOT TRY TO 13 CONCEAL KNOWLEDGE INTENTIONALLY FROM LEE HOFMANN.
14 Q YOU DIDN'T TELL MR. HOFMANN ABOUT YOUR RESUME 15 3EING ATTACHED TO THE BEAVER VALLEY PROPOSAL, DID YOU?
16 A IF MEMORY SERVES ME CORRECTLY, AT THIS 17 MOMENT, 5 ., I Bta! EVE I MADE STATEMENTS DURING THE l 18 INTERVIEW THAT MY RESUME MAY HAVE EVEN BEEN IN THE )
19 PROPOSAL. I COULDN'T SWEAR TO IT AT THIS MOMENT IF I DID l
20 OR NOT. i 21 MR. HICKEY: CAN I ASK THE REPORTER TO PLEASE MARK 22 THIS DOCUMENT AS EXHIBIT 54.
23 (WHEREUPON PLAINTIFF'S RESPONDENT'S 54 WAS l
24 MARKED FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY 25 IS ATTACHED HERETO.)
111-59 l
- - - - - _ _ _ _ - - - - - - ------_-____u
)
I 1 -Q BY MR. HICKEY: WHAT IS THAT DOCUMENT THAT'S 2 BEEN MARKED -- I'M SORRY. I I
3 (MR. JOHNSON AND MR. BERRY ARE CONFERRING.)
4 MR. JOHNSON: COULD YOU JUST WAIT A SECOND? )
5 Q BY MR. HICKEY: DO YOU RECOGNIZE EXHIBIT 54, 6 MR. PARKS?
7 A I BELIEVE I DO, YES. l 8 Q WHAT IS IT?
9 A IT APPEARS TO BE PARTIAL BRIEF NOTES THAT I 10 TOOK DURING MY INTERVIEW WITH MR. HOFMANN.
11 Q AND YOU TOOK THEM DURING THE COURSE OF THE ,
t 12 INTERVIEW?
13 A YES, I DID.
14 Q THIS IS THE INTERVIEW OF MARCH 14, RIGHT?
15 A I CAN RECALL -- YES, THE INTERVIFW OF 16 MARCH 14. I CAN RECALL TAKING A BRIEF SET OF NOTES, AND I 17 HAVE NO REASON, AT THIS POINT IN TIME, TO DOUBT THESE ARE !
18 NOT THE NOTES.
19 Q YOU SEE ABOUT A THIRD OF THE WAY DOWN THE 20 PAGE IT'S GOT --
THE WORDS WRITTEN "GAVE" -- CORRECT ME IF 21 1'M READING YOUR WRITING WRONG. "GAVE, MICH HAMBY, l
22 K. DRAPER, AND L.P.K." --
IS THAT WHAT THAT SAYS?
23 A THAT'S WHAT IT SAYS, YES.
24 Q DOES THAT REFRESH YOUR RECOLLECTION THAT YOU j i
25 GAVE THE NAMES OF MR. HAMBY, MR. DRAPER AND MR. KING TO i
!II-60
{
l
__ _ - - - - -- - - - - - - 1
1 MR. HOFMANN AS BEING THE RESUMES THAT --
AS BEING AMONG 2 THE RESUMES THAT ROSE RITTLE TYPED?
3 A I HAVE THE OPINION, AT THIS MOMENT, THAT I 4 TOLD MR. HOFMANN THE NAMES OF THE PEOPLE I COULD RECALL.
5 Q YES, YOU TOLD US THAT EARLIER. BUT WHAT I'M ,
i 6 ASKING YOU NOW IS WHETHER YOU RECALL THAT THE NAMES YOU 7 TOLD HIM WERE HAMBY, DRAPER AND KING?
8 A SIR, ALL I CAN STATE, BASED ON MY REVIEW OF 9 THIS' DOCUMENT -- AND THIS DOCUMENT LISTS THOSE THREE 10 GENTLEMEN, SO I WOULD HAVE TO SAY, YES, I TOLD HIM THOSE 11 THREE GENTLEMAN'S NAMES.
12 Q OKAY. AND DO YOU RECALL TELLING HIM ANY 13 OTHER GENTLEMAN'S NAMES?
14 A AT THIS MOMENT, I DO NOT SIR. I WOULD j l
15 RECOMMEND --
I GUESS WHAT I'M TRYING TO SAY, MY SET OF l
16 NOTES WERE NOT AS -- YEAH, THEY WERE NOT AS ALL 17 ENCOMPASSING AS THE OTHER GENTLEMAN'S NOTES WERE. I MEAN 18 MARK KOBI TOOK SEVERAL PAGES OF NOTES AND THE OTHER TWO 19 ! GENTLEMEN TOOK SEVERAL PAGES OF NOTES AND I WAS DOING A 20 LOT OF TALKING AND NOT A LOT OF WRITING.
21 Q AND YOU HAD ASKED THAT MR. KOBI BE THERE.
22- AND WHEN MR. KOBI WAS ALLOWED TO BE THERE, DID YOU 23 PARTICULARLY ASK MR. KOBI TO TAKE NOTES?
24 A I CAN'T RECALL IF I SPECIFICALLY ASKED 25 MARK KOBI TO TAKE NOTES OR -- OR HOW IT CAME TO BE, BUT III-61
/
\
,h, 1 I'M REASONABLY CERTAIN I ASKED HIM TO TAKE NOTES, YES.
2 MR. HICKEY: THIS IS 55.
- 3 (WHEREUPON PLAINTIFF'S RESPONDENT'S 55 WAS 4 MARKED FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY 5 IS ATTACHED HERETO.)
6 Q BY MR. HICKEY: YOU CAN LOOK THROUGH THE 7 WHOLE DOCUMENT OBVIOUSLY, MR. PARKS. WHEN YOU'RE DONE, I 8 WANT TO DIRECT YOU SPECIFICALLY TO PAGE 5. '
9 A SIR, COULD YOU CLARIFY ONE THING FOR ME? (
10 Q I'LL BE GLAD TO TRY. '
)
/
11 A l'M SURE YOU WOULD. THAT'S WHY I DIDN'T 12 HESITATE TO ASK.
13 YOU KNOW, CONSIDERING THE SHORTNESS OF THE 14 TIME, DON'T YOU THINK WE'RE KIND OF REHASHING GROUND THAT 15 WAS COVERED IN MY CIVIL PROCEEDINGS? -
l l 16 Q l DON'T THINK S0.
17 MR. JOHNSON: WHAT IS HE SUPPOSED TO BE LOOKING AT s 18 ON PAGE 5?
19 MR. HICKEY: I WASN'T AWARE THAT HE:D FINISHED 20 LOOKING AT THE EXHIBIT.
21 Q BY MR. HICKEY: DO YOU RECOGNIZE THE EXHIBIT 22 MARKED 55 AS MR. KOBI'S NOTES, MR. PARKS?
23 A I BELIEVE THEM TO BE COPIES OF MARK'S NOTES, i
l 24 YES. '
25 Q AND DID YOU FIND THE REFERENCE I GAVE YOU ON III-62
^ '
x .
3
y '
i 1 PAGE 5 WHERE THERE IS, ABOUT FIVE LINES DOWN FROM THE TOP, 2 A LETTER Q, APPARENTLY ASKED A QUESTION, AND THE WORD ,
3 "WHOSE," AND THEN A, 1 ASSUME, MEANING ANSWER. PARKS ,
4 ANSWERED L. KING, K. DRAPER AND M FOR MICKEY HAMBY. DO ,
5 YOU SEE THAT?
6 A YES, 1 D0.
7 Q DO YOU SEE ANY REFERENCE TO YOU IDENTIFYING 8 RICK PARKS' RESUME AS BEING AMONG THE QUILTEC RESUMES l 9 TYPED BY MISS RITTLE?
10 A NO, SIR, I DO NOT, NOT IN THAT PARTICULAR 11 STATEMENT.
12 BUT I REQUEST TIME TO COMPLETELY REVIEW THE
~
13 DOCUMENT TO SEE IF IT IS REFLECTED OF A SIMILAR NATURE 14 SOMEWHERE ELSE IN THIS DOCUMENT.
15 Q OKAY.
16 A l'VE COMPLETED MY REVIEW.
17 Q DO YOU FIND ANY REFERENCE IN IT, MR. PARKS, 18 TO YOU ADVISING MR. HOFMANN ON MARCH 14 THAT ONE OF THE 19 QUILTEC RESUMES WAS YOURS?
20 A NO.
21 BUT I ALSO DO NOT SEE WHERE IT COULD -- 1 22 GUESS WHAT l'M TRYING TO SAY MARK'S RECORDS HERE -- I '
23 SUGGESTED TO LARRY SINCE MY RESUME WAS A FORMAT AND THAT I .
24 GAVE MY RESUME TO ROSE AS A MODEL FOR THE OTHERS, 1 DON'T 25 SEE, YOU KNOW, ANY INSTRUCTIONS THAT I REPEATED THAT WOULD III-63
I ( .
1 HAVE PRECLUDED MISS RITTLE FROM TYPING ONE OF MY RESUMES 2 ON QUILTEC LETTERHEAD.
3 Q THAT'S NOT MY QUESTION.
4 THE QUESTION THAT I WAS ASKING ORIGINALLY WAS 5
WHETHER YOU TOLD MR. HOFMANN THAT ONE OF THE QUILTEC 6 RESUMES ROSE RITTLE TYPED WAS YOURS.
7 A I BELIEVE, AT THE MOMENT, SIR, FROM WHAT I
'8 CAN RECALL, AT THIS TIME, THAT I DID TELL HIM THAT.
9 Q OKAY. YOU DON'T FIND ANY REFLECTION OF IT IN 10 THE NOTES, BUT DO YOU HAVE A RECOLLECTION OF THAT?
11 A I BELIEVE I DID TELL HIM THAT, THAT'S 12 CORRECT. I DID NOT HAVE ANYTHING TO HIDE. .
13 Q AND DID YOU TELL HIM THAT THE BEAVER VALLEY 14 PROPOSAL HAD YOUR RESUMES ATTACHED TO IT?
15 A I DO NOT REMEMBER IF 1 --
AT THIS TIME, IF i 16 TOLD HIM THAT OR NOT. I DO REMEMBER TELLING HIM THAT 17 THERE WAS A PROPOSAL IN THAT PACKAGE AND 1 BELIEVE IT WAS 18 FROM BEAVER VALLEY, THAT TYPE OF THING.
19 Q WELL, IS IT YOUR TESTIMONY THAT YOU DIDN'T 20 BELIEVE ON MARCH 14 THAT MR. HOFMANN WAS INTERESTED IN 21 WHETHER YOUR RESUME WAS ATTACHED TO THE BEAVER VALLEY 22 PROPOSAL?
23 A SIR, AT THIS POINT IN TIME, I CAN'T RECALL IF 24 HE SPECIFICALLY ASKED ME OR NOT. I AM REASONABLY 25 CONFIDENT, AT THIS POINT IN TIME, IF THE MAN HAD ASKED ME III-64
^
i ,
1 AND I HAD A RECOLLECTION OF MY RESUME BEING IN THE 2 PROPOSAL, I WOULD HAVE TOLD HIM.
3 Q WELL, HOW ABOUT MR. CHWASTYK AND MR. SMITH 4 AND MR. FLOYD? THEIR RESUMES WERE ALL ATTACHED TO THIS 5 PROPOSAL, WEREN'T THEY? YOU CAN LOOK AND CHECK IF YOU 6 WANT.
7 A I WILL -- YOU KNOW WITHOUT BEGINNING TO WASTE 8 THE TIME TO CHECK, IF YOU TELL ME THEY ARE ATTACHED, I 9 WILL TAKE YOUR WORD AT FACE VALUE. '
10 Q YOU DIDN'T TELL MR. HOFMANN ON MARCH 14 THAT 11 THOSE GENTLEMEN'S RESUMES WERE ATTACHED TO THE QUILTEC 12 BEAVER VALLEY PROPOSAL, DID YOU?
13 A I DO NOT RECALL THAT I TOLD HIM. I TOLD THE 14 GENTLEMAN THE NAMES I COULD REMEMBER AT THE TIME.
15 Q 15 IT YOUR TESTIMONY THEN THAT YOU FORGET 16 ABOUT --
ON MARCH 14 YOU FORGOT ABOUT MR. CHWASTYK AND 17 MR. SMITH AND MR. FLOYD'S RESUMES BEING ATTACHED?
18 A IT IS MY TESTIMONY, AT THIS TIME, SIR, THAT I 19 TOLD MR. HOFMANN WHAT 1 COULD REMEMBER REGARDING THE NAMES 20 0F THE INDIVIDUALS THAT WERE IN THERE.
21 Q AND I UNDERSTAND YOUR TESTIMONY TO BE YOU 22 DIDN'T FORGET THAT YOUR RESUME WAS ATTACHED; YOU BELIEVE 23 YOU TOLD MR. HOFMANN THAT YOUR RESUME WAS ATTACHED?
24 A I CAN RECALL, AT THIS POINT IN TIME, TELLING s 25 MR. HOFMANN THAT MY RESUME WAS PROPOSED TO ROSE RITTLE TO 111-65
=
s
~
1 USE AS A GUIDELINE FOR TYPING THE OTHER RESUML'. AND I
{
l 2 HAVE REASON TO BELIEVE THAT I TOLD HIM MY RESUME WAS l
3 INVOLVED IN THAT MESS, MEANING THAT PACKAGE OF PAPERS.
4 Q THAT'S A BIT AMBIGUOUS. MY QUESTION IS l
5 WHETHER YOU TOLD MR. HOFMANN THAT YOUR RESUME WAS ATTACHED 6 TO THE BEAVER VALLEY PROPOSAL?
7 A I -- AGAIN, SIR, I BELIEVE I HAVE ALREADY "
8 ANSWERED THAT QUESTION, BUT I WILL TRY TO PUT IT VERY 9 SUCCINCTLY. FROM WHAT I CAN RECALL, AT THIS POINT IN l
10 TIME, I BELIEVE I DID TELL MR. HOFMANN THAT MY RESUME WAS 11 IN THAT PROPOSAL. BUT I DO NOT HAVE ANY PROOF OF THAT, 12 ONE WAY OR THE OTHER, AT THIS POINT IN TIME. I DO NOT 13 RECALL BEING ASKED SPECIFICALLY BY MR. HOFMANN IF MY 14 RESUME WAS ATTACHED TO THAT PROPOSAL.
15 Q DID YOU INITIALLY, IN THE MEETING WITH 16 MR. HOFMANN, TELL HIM THAT AS FAR AS THE OWNERSHIP OF l
17 QUILTEC WAS CONCERNED YOU ONLY KNEW MR. SLONE WAS A HALF i 18 OWNER AND YOU DIDN'T KNOW ABOUT THE OTHER HALF?
19 A I BELIEVE, SIR, THAT MARK'S NOTES ACCURATELY 20 REFLECT WHAT I MADE STATEMENTS TO THAT I STRONGLY 21 SUSPECTED LARRY KING TO BE THE OTHER PART OWNER, BUT I DID 22 NOT HAVE PROOF OF THAT. SOMETHING TO THAT NATURE APPEARS 23 IN MARK'S COMMENTS.
24 Q WELL, WHEN LARRY KING GAVE YOU THE PRESENT OF 25 THE QUILTEC BUSINESS CARDS, DIDN'T HE INDICATE TO YOU THAT 111-66
1 HE WAS AN OWNER OF QUILTEC?
2 A IF HE DID OR NOT, SIR, I CANNOT RECALL AT - ,,
3 THIS MOMENT, BUT I TEND TO PERSONALLY -- A PERSON CAN TELL 4 ME ONE THING, BUT I DON'T ALWAYS TAKE IT TO BE THE TRUTH 5 UNTIL I SEE IT, IF YOU UNDERSTAND WHAT I MEAN.
6 Q ARE YOU SUGGESTING THAT MR. KING TOLD YOU HE 7 WAS AN OWNER, BUT YOU DIDN'T BELIEVE HIM?
8 A THAT'S NOT WHAT I AM SUGGESTING AT ALL, SIR.
i 9 I STATED THAT I DID NOT RECALL, AT THIS MOMENT, WHETHER 10 LARRY KING MADE STATEMENTS THAT HE WAS A PART OWNER IN ____
11 QUILTEC OR NOT WHEN HE GAVE ME THOSE BUSINESS CARDS.
12 Q WHAT DID YOU MEAN BY YOUR RESPONSE A PERSON 13 CAN TELL YOU SOMETHING, BUT YOU DON'T ALWAYS BELIEVE IT s 14 UNTIL YOU SEE SOMETHING? _
15 A WELL, SIR, YOU CAN PERSONALLY TELL ME YOU OWN 16 THIS BUILDING, BUT UNTIL YOU SHOW ME THE DEED, I WOULDN'T l
17 BELIEVE IT, NOT NECESSARILY. IT DEPENDS UPON THE 18 CIRCUMSTANCES AND DISCUSSION.
19 Q YOU DIDN'T TELL MR. HOFMANN ABOUT THE GIFT OF 20 QUILTEC BUSINESS CARDS FROM MR. KING, DID YOU?
21 A I DON'T BELIEVE I DID, SIR, SIMPLY BECAUSE AT -
22 THE TIME I DIDN'T RECALL IT. I DON'T BELIEVE THOUGH, FROM 1
23 WHAT I CAN RECALL, AT THIS MOMENT, THAT MR. HOFMANN 24 QUESTIONED ME REGARDING BUSINESS CARDS, WHETHER OR NOT I 25 HAD ANY. I KNOW I DIDN'T HAVE ANY BECHTEL BUSINESS CARDS.
III-67 e
0
1 Q DID MR. HOFMANN ASK YOU, AT SOME POINT DURING 2 THE INTERVIEW, TO -- IN GENERAL TERMS, FOR ANY CONTACT OR -,
3 CONNECTION YOU HAD WITH QUILTEC -- FOR INFORMATION ABOUT -T 4 ANY CONTACT OR CONNECTION YOU HAD WITH QUILTEC?
5 A COULD YOU REPEAT THAT, SIR? Y 6 Q SURE. ,
7 l'M ASKING WHETHER MR. HOFMANN ASKED YOU A 8 GENERAL QUESTION TO TELL HIM ANY CONVERSATION YOU HAD WITH 9 QUILTEC?
10 A I BELIEVE ANYWAY, AT THIS POINT IN TIME, WHAT 11 I CAN REMEMBER IS TO ONE OF HIS LINES OF QUESTIONS I 12 ASSURED THE MAN THAT I HAD NO FINANCIAL CONNECTION, NO 13 OWNERSHIP OF ANY STOCK OR ANYTHING LIKE THAT. THAT MAY BE 14 THE TYPE OF GENERAL QUESTION YOU'RE ASKING, BUT MY MEMORY, 15 AT THIS TIME, DOESN'T SERVE TO PROVIDE ANY AMPLIFYING 16 COMMENTS.
17 Q WELL, I CAN PUT THE QUESTION THIS WAY. MAYBE 18 IT WILL BE CLEARER.
19 YOUR TESTIMONY, ! UNDERSTAND, MR. PARKS TO BE 20 THAT IN ANY EVENT YOU DIDN'T CONCEAL FROM MR. HOFMANN THE 21 FACT THAT YOU HAD QUILTEC BUSINESS CARDS, IF HE ASKED YOU 4 22 FOR IT, AND YOU DIDN'T TELL HIM ABOUT IT BECAUSE YOU 23 FORGET?
24 A THAT'S CORRECT. I AM OF THE OPINION, AT THIS l
25 TIME, AS I HAVE THE OPINION THAT I WAS NOT INTENTIONALLY 111-68
1 CONCEALING ANYTHING FROM MR. HOFMANN.
2 Q DO YOU REMEMBER CALLING LARRY KING THAT SAME 3 DAY AFTER YOU COMPLETED THE -- LET ME REPHRASE THE 4 QUESTION.
5 DO YOU REMEMBER TRYING TO CALL LARRY KING 6 THAT SAME DAY AFTER YOU COMPLETED THE HOFMANN INTERVIEW?
7 A AT THIS POINT IN TIME, SIR, I COULD NOT TELL 8 YOU ACCURATELY IF 1 DID OR NOT.
9 Q WELL, DO YOU REMEMBER SPEAKING TO GLORIA KING 10 ABOUT THE HOFMANN INTERVIEW ON MARCH 14, AFTER THE 11 INTERVIEW WAS OVER?
12 A I, AT THIS POINT IN TIME, SIR, COULD NOT l
13 ACCURATELY TELL YOU IF 1 TALKED TO HER OR NOT ON THAT DAY.
14 MR. HICKEY: ASK THE REPORTER TO MARK THIS AS THE 15 NEXT EXHIBIT WHICH IS 5 6 .,
16 (WHEREUPON PLAINTIFF'S RESPONDENT'S 56 WAS 17 MARKED FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY 18 IS ATTACHED HERETO.)
19 Q BY MR. HICKEY: HAVE YOU SEEN EXHIBIT 56 20 BEFORE THIS, MR. PARKS?
21 A NO, SIR, I HAVE NOT. .
22 Q PORTIONS OF THE DOCUMENT ARE DIFFICULT TO 23 COPY CLEARLY, BUT THE PART THAT I WANT TO REFER YOU TO I -
25 l'LL REPRESENT TO YOU TO, AT THIS TIME, THE 111-69 i
1 HANDWRITING ON THE LEFT-HAND HALF OF THE FIRST SHEET AND 2 ON THE SECOND SHEET HAS BEEN IDENTIFIED BY GLORIA KING AS 3 HER HANDWRITING.
4 AND IF YOU LOOK ON THE FRONT PAGE OF IT FOR 5 JUST A MINUTE, I WANT TO DIRECT YOUR ATTENTION ON THE DARK l
6 RIGHT-HAND SIDE OF THE FRONT PAGE. DOWN AT THE BOTTOM YOU l 7 SEE THE LETTERS OR THE WORDS "6:15, RICK 944-2421,"
l 8 APPARENTLY A TELEPHONE NUMBER, AND THEN THE WORD 9 "IMPORTANT" AND UNDERSCORED AND SO ON. DO YOU SEE THAT?
10 A YES, I SEE THAT.
11 Q WAS THAT THE TELEPHONE NUMBER THAT YOU HAD ON 12 MARCH 14? DO YOU REMEMBER?
13 A I BELIEVE IT WAS.
14 Q AND YOU SEE AT THE BOTTOM LEFT SIDE OF THE ,
15 FIRST SHEET, MRS. KING HAS WRITTEN A NOTE "THIS URGENT 16 MESSAGE EXPLAINED ON NEXT SHEET WHEN I RETURNED PARKS' 17 CALL AND MADE NOTES ACCORDINGLY." DO YOU SEE THAT?
18 A I SEE THAT.
19 Q THE SECOND PAGE OF THE EXHIBIT HAS 20 MRS. KING'S HANDWRITTEN NOTE. AND THE PART I WANT TO --
21 WELL, IT'S BRIEF. MAYBE IT'S EAS!EST JUST TO MAKE SURE 22 THAT WE'RE ALL READING THE WORDS THE SAME, I'LL READ IT 23 INTO THE RECORD AND YOU CORRECT ME. IT SAYS:
24 " RICK, 11:00 A.M. - 2:30 P.M.,
25 GRILLED BY CALIFORNIA BECHTEL AUDITOR,
111-70
s . ~
1 LEE HOFMANN. RON FILNOW OFF 20TH,"
2 I BELIEVE IT SAYS, " RICK'S BOSS FROM 3 GAITHERSBURG" OR AN ABBREVIATION FOR 4 GAITHERSBURG, MARYLAND, ANDY WHEELER.
5 TYPING WITH ROSE RITTLE. RICK (AND 6 MARK COLBY) C-0-L-B-Y "
7 I ASSUME THAT MEANS K-0-B-I; ISN'T THAT ,
8 CORRECT?
9 A I WOULD SAY THAT'S A REASONABLE ASSUMPTION. ,
10 Q QUOTE, "'EVERYBODY KNOWS I GOT BEN 11 HIS JOB AT LONG ISLAND,' CLOSE QUOTE.
12 I HELPED HIM GET HIS JOB."
13 STILL QUOTING IT SAYS:
14 "NAME ALL EAST COAST BODY SHOPS 15 SO RICK NAMED QUILTEC. ARE YOU VESTED 16 IN Q," AND THEN THERE'S A DASH, "NO. IS 17 LARRY IN Q - DON'T KNOW. IS BEN -
YES. .
18 STILL SEE HIM. RICK SEES SANFORD AT 19 8:00 A.M., TUESDAY (BECHTEL V.P.)"
20 DOES THAT REFRESH YOUR RECOLLECTION THAT YOU 21 HAD A PHONE CONVERSATION WITH MRS. LARRY KING, 22 GLORIA KING, ON THE 14TH OF MARCH IN WHICH YOU -
23 COMMUNICATED TO HER INFORMATION ABOUT YOUR HOFMANN 24 INTERVIEW 7 25 A NO, SIR, IT DOES NOT REFRESH MY MEMORY. BUT III-71 a
e
1 1 DON'T HAVE ANYTHING, YOU KNOW, MT MY DISPOSAL AT THIS 2 TIME TO DISPUTE IT EITHER.
3 Q WHY WOULD YOU HAVE TOLD MRS. KING THAT YOU '
4 TOLD HOFMANN YOU DIDN'T KNOW WHETHER LARRY WAS IN QUILTEC7 5 A SIR, I THINK THAT'S A MISCHARACTERIZATION. I 6 THINK WHAT YOU'RE SEEING THERE IS IF --
AS THIS MEMO TENDS 7 TO IMPLY THAT I DID HAVE A CONVERSATION WITH GLORIA KING,
= _
l l
8 IT APPEARS TO ME TO BE A SYNOPSIS OR HER MEMORY OF WHAT 9 WAS DISCUSSED. I HAVE NO REASON TO --
1 MEAN I DON'T HAVE 10 ANY EXPLANATION FOR WHY GLORIA WROTE THAT DOWN. I HAVE
- 11 NEVER SEEN IT BEFORE. THAT MAY HAVE BEEN HER OPINION.
12 Q BUT YOU DEFINITELY DIDN'T TELL MRS. KING THAT 13 YOU TOLD HOFMANN YOU DIDN'T KNOW WHETHER LARRY WAS IN T 14 QUILTEC?
15 A S I R, AGAIN, I REMIND YOU I HAVE ALREADY 16 STATED I DO NOT HAVE ANY RECOLLECTION, AT THIS MOMENT, OF 1
17 THAT CONVERSATION EVER OCCURRING, BUT I ALSO STATED I HAVE 18 NO REASON TO DOUBT IT EITHER --
19 Q WELL --
20 A --
BASED AFTER MY REVIEW THAT DOCUMENT.
21 Q I UNDERSTAND THAT. BUT IT'S THE CONTENT OF 22 THE CONVERSATION THAT I'M INTERESTED IN, NOT JUST WHETHER 23 IT OCCURRED.
24 ARE YOU ABLE TO TESTIFY, MR. PARKS, THAT YOU 25 DID NOT TELL GLORIA KING, IN SUBSTANCE, THAT YOU ADVISED 111-72
1 HOFMANN YOU DIDN'T KNOW WHETHER LARRY KING WAS IN QUILTEC? .
2 A I AM ABLE TO TESTIFY, AT THIS DATE, SIR, THAT 3 I HAVE NO RECOLLECTION OF THAT CONVERSATION TAKING PLACE, 4 SO I THINK IT WOULD BE UNFAIR, YOU KNOW, FOR ME TO TRY TO 5 SAY YES OR NO WHETHER I TOLD HER THAT BECAUSE I DON'T 6 RECALL A CONVERSATION OCCURRING.
7 Q OKAY. I'M NOT TRYING TO PRESS YOU BEYOND 8 WHERE YOUR MEMORY WILL TAKE YOU, MR. PARKS, BUT SOMETIMES
(
9 WITNESSES, EVEN THOUGH THEY DON'T HAVE A RECOLLECTION 10 ABOUT THE CONTENTS A CONVERSATION OR WHERE THEY WERE ON A w
11 PARTICULAR DATE, ARE ABLE TO SAY THAT THEY DEFINITELY 12 WEREN'T IN SOMEPLACE OR THEY DEFINITELY DIDN'T SAY 13 SOMETHING. THAT'S WHY I ASKED YOU THE QUESTION. ,
t 14 A I UNDERSTAND THAT. ,
l 15 CAN WE Go OFF THE RECORD A MINUTE?
16 Q SURE.
17 (CONFERENCE HELD OUTSIDE THE PROCEEDINGS.)
18 MR. JOHNSON: MR. HICKEY, I WOULD ASK YOU TO 19 REFRAIN FROM REPEATING THE CROSS-EXAMINATION QUESTIONS 20 THAT WERE ASKED BY MR. RICHARDSON IN THE BECHTEL 21 DEPOSITIONS OF MR. PARVS. TO MY UNDERSTANDING A LOT OF 22 THIS GROUND HAS BEEN -- AS YOU'VE BEEN GOING THROUGH THIS 23 MORNING HAS BEEN PLOWED THROUGH PREVIOUSLY. AND WE ARE 24 ENDEAVORING TO COMPLETE THE DEPOSITION THIS MORNING. AND ,
25 IT'S OUR POSITION THAT THE DEPOSITION ISN'T COMPLETE UNTIL 111-73
1 ALL THE EXAMINATION IS COMPLETE AND TilA T INCLUDES THE 2 OPPORTUNITY FOR ME TO HAVE DIRECT EXAMINATION. AND SO I 3 JUST ASK YOU TO NOT --
IT WAS OUR UNDERSTANDING THAT YOU l 4 UNDERSTOOD THAT AND WOULD ENDEAVOR NOT TO REPEAT 5 QUESTIONS; THEREFORE, I WOULD ASK YOU TO DO S0.
6 MR. HICKEY: WELL, I HAVE AND I WILL CONTINUE TO.
7 SO THE RECORD IS CLEAR MAYBE I WANT TO 8 INDICATE WHAT I SAID TO YOU DURING THE BREAK. IT IS NOT 9 GOING TO BE POSSIBLE FOR TO ME TO COMPLETE MY EXAMINATION 10 BY TWELVE 0' CLOCK NOON TODAY. 50 I'M ASSUMING THAT WHEN 11 WE COME CLOSER TOWARD THE HOUR WE WILL DISCUSS WITH 12 MR. PARKS SOME APPROPRIATE FUTURE DATE WHEN WE CAN RESUME 13 THE MATTER.
14 Q BY MR. HICKEY: MR. PARKS -- -
15 A SIR, IF WE'RE NOT GOING TO COMPLETE THIS 16 TODAY, I HAVE A MORE IMPOSING DEADLINE THAN ANY OF YOU l
17 GENTLEMEN DO. I SUGGEST YOU STOP NOW TO ALLOW ME --
TO ,
18 GIVE ME A FEW EXTRA MINUTES IN THE TRAFFIC TO CATCH MY 19 PLANE.
20 Q WELL, CAN WE COMPROMISE AND GO TO 11:30? YOU 21 WERE GOING TO LEAVE AT 12:00, 22 A WELL, THAT'S REALLY CUTTING IT VERY SHORT 23 TOO. I KNOW YOU'RE UNFAMILIAR WITH THE GRID LOCK SYSTEM 24 WE HAVE OUT HERE, BUT THIS FREEWAY CAN BE A BFAR EVEN --
25 YOU KNOW, RIGHT AROUND LUNCH TIME TO L.A.X. BASICALLY THE III-74
+
h
x ,
=
1 TRAFFIC IS JUST BAD ANY TIME.
2 MR. JOHNSON: LET ME ASK YOU, MR. HICKEY, HOW MUCH 3 MORE EXAMINATION DO YOU BELIEVE YOU HAVE?
4 MR. HICKEY: I THINK IT WOULD TAKE TO THE END OF 5 THE DAY AND MAYBE A LITTLE BIT MORE.
6 MR. BERRY: WHY DON'T WE GO OFF THE RECORD FOR A 7 FEW MINUTES?
8 MR. JOHNSON: OFF THE RECORD.
e 9 (DISCUSSION HELD OFF THE RECORD.) 4 10 (RECESS.)
11 MR. JOHNSON: IT'S OUR POSITION THAT THE DEPOSITION 12 FOR THIS WEEK WAS CONVENED FOR THREE DAYS AND THAT 13 REASONABLE INTERPRETATION OF THREE DAYS WOULD BE BUSINESS r
14 HOURS ON THOSE THREE DAYS. AND YOU HAVE -- UNDER THE J
15 UNDERSTANDING IN WHICH THIS DEPOSITION WAS CONVENED THAT 16 YOU HAVE APPROXIMATELY FIVE HOURS OF EXAMINATION THAT YOU 17 COULD STILL DO UNDER THE NOTICE. AND IF YOU'D LIKE TO ,
18 CONTINUE THE EXAMINATION FOR A FEW MINUTES UNTIL 19 APPROXIMATELY 11:30, THAT'S ACCEPTABLE TO US. BUT IN 20 ORDER TO ACCOMMODATE THE WITNESS, I WOULD SUGGEST THAT WE 21 ADJOURN THE DEPOSITION UNTil A SUBSEQUENT DATE SINCE 22 YOU'RE NOT GOING TO BE ABLE TO FINISH TODAY.
23 MR. HICKEY: WELL, I AGREE WITH ALL THAT EXCEPT 24 YOUR TOTALIZING OF THE HOURS. I DON'T THINK l'M LIMITED 25 TO APPROXIMATELY FIVE MORE HOURS. BUT l'LL GLAD TO III-75
~
Y 4 1 ACCOMMODATE THE WITNESS.
2 Q BY MR. HICKEY: I WOULD, MR. PARKS, JUST LIKE 3 TO ASK A FEW MORE QUESTIONS BECAUSE I THINK IT WOULD BE 4 HELPFUL, BUT THEN I'LL BE SURE TO STOP BY 11:30.
5 A WELL, IF YOU'RE SURE WE'RE GOING TO CONTINUE 6 ON TO 11:30 THAT I SUGGEST WE COVER TERRITORY THAT HASN'T 7 BEEN COVERED PREVIOUSLY.
8 Q WELL, LET'S GET RIGHT TO IT THEN.
9 DO YOU REMEMBER BEING INTERVIEWED BY 10 DAVID FEINBERG OF THE DEPARTMENT OF LABOR IN THE COURSE OF ?
11 YOUR INVESTIGATION OF YOUR HARASSMENT COMPLAINT?
12 A YEP. I DO, SIR.
13 Q AND JUST TO PLACE IT IN A TIME FRAME FOR YOU, 14 THERE ARE TWO STATEMENTS THAT HAVE PREVIOUSLY BEEN ~
15 PRODUCED, ONE DATED APRIL 20, 1983 AND ANOTHER DATED 16 MAY 2, 1983. DO YOU RECALL THAT YOU MET WITH MR. FEINBERG 17 ON OR ABOUT THOSE DATES?
18 A AT THIS POINT IN TIME, SIR, I CAN ONLY STATE 19 THAT I MET WITH MR. FEINBERG. I REALLY COULDN'T TELL YOU 20 ACCURATELY ABOUT THE DATES I MET WITH HIM.
21 Q ALL RIGHT. DID YOU MEET WITH HIM MORE THAN 22 TWICE? ,
23 A I DON'T BELIEVE SO. AT LEAST AT THIS POINT 24 IN TIME, I CAN'T RECALL THAT I DID.
25 Q DID YOU TELL MR. FEINBERG ON EITHER OF THOSE 111-76
~
v 1
OCCASIONS-THAT YOU HAD PREVIOUSLY HAD IN YOUR POSSESSION l
-2 BUSINESS CARDS ON QUILTEC STOCK WITH YOUR NAME AND THE 4 3 DESIGNATION OF YOU AS CONSULTANT?
4 A COULD YOU RUN THAT PAST ME -- PROVIDE THE 5 DEFINITION OF WHAT YOU MEAN BY "QUILTEC STOCK."
l 6 Q WELL, A BUSINESS --
THE BUSINESS C'ARD THAT 7 YOU TOLD US ABOUT YESTERDAY, MR. PARKS, THE BUSINESS CARD 1
8 THAT HAS THE QUILTEC NAME AND LOGO ON IT. I 9 A IS THAT CONSIDERED STOCK?
1 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, 1 DON'T 13 RECALL, AT'THIS MOMENT, IF IT CAME UP IN THE CONVERSATION 1
14 OR NOT. I I
15 Q DID YOU TELL MR. FEINBERG, ON ANY OCCASION, l l
16 ABOUT YOUR INVOLVEMENT IN GETTING QUILTEC AND MR. SLONE l 1
l l
l 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 1 TOLD HIM THAT OR NOT.
20 Q DID YOU TELL MR. FEINBERG THAT YOUR RESUME 21 HAD BEEN 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
l 1 DID YOU TELL MR. FEINBERG THAT YOUR RESUME ON ]
2 QUILTEC LETTERHEAD WAS ATTACHED TO THE QUILTEC BEAVER o ;
3 VALLEY PROPOSAL? '
i
- 4 A AGAIN, SIR, AT THIS POINT IN TIME, I DON'T 5- KNOW IF. I TOLD HIM THAT OR NOT. I DON'T REMEMBER IT BEING I 6 DISCUSSED OR I.JUST DON'T REALLY RECALL.
7 MR. HICKEY: LET ME ASK THE REPORTER TO MARK THIS 8 DOCUMENT AS THE NEXT EXHIBIT WHICH WOULD BE 57. !
9 (WHEREUPON PLAINTIFF'S RESPONDENT'S 57 WAS
'il 10 MARKED FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY 11 15 ATTACHED HERETO.)
12 Q BY MR. HICKEY: MR. PARKS, I'M HAVING THE 13 REPORTER SHOW YOU A DOCUMENT.WHICH HAS BEEN MARKED AS 14 EXHIBIT 57. YOU'LL SEE THAT IT'S A HANDWRITTEN STATEMENT 15 ON DEPARTMENT OF LABOR PAPER THAT'S TITLED " INTERVIEW 16 NOTES, RICHARD PARKS, MAY 2, '83, RICHARD PARKS' HOME IS-17 GIVEN AS THE PLACE.- IT'S SIX PAGES AS WE HAVE IT HERE.
18 THE FIRST QUESTION I WANT TO ASK YOU 15 19 WHETHER YOU'VE SEEN THAT BEFORE?
20 A I REALLY COULDN'T TELL YOU, AT THIS POINT IN 21 TIME, IF I HAVE OR WOT. 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. DO 25 YOU SEE IT?
111-78
1 A OKAY.
2 Q LET ME JUST SAY THAT IT APPEARS FROM THE 3 EXHIBIT THAT ON MAY 2, MR. FEINBERG AND'YOU AND MR. DEVINE 4 DISCUSSED ATTORNEY RICHARDSON'S RESPONSES TO YOUR 5 COMPLAINTS.
6 A WOULD YOU START IT OVER AGAIN7 I DON'T THINK 7 I FOLLOWED EVERYTHING YOU JUST SAID.
8 Q I 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 DISCOSSED ATTORNEY 11 RICHARDSON'S RESPONSES TO PARKS' COMPLAINTS. AND I
- 12 THOUGHT THAT MIGHT BRING THE MEETING BACK TO YOUR MIND.
-13. A CORRECT ME, IF l'M WRONG SIR, ISN'T THIS 14 NOTES OF MR. FEINBERG'S INTERVIEW WITH ME AFTER THE 15 COMPANY HAD REFUSED TO ACCEPT THE DEPARTMENT.0F LABOR'S 16 FINDINGS THAT I SHOULD BE PUT BACK TO WORK 7
'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 l
20 LABOR ISSUED A STATEMENT SAYING, YOU kNOW, THIS IS -- THIS l
l 21 IS WHAT-WE FOUND AND ALL LIKE THAT.
22 1 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 BE. I MEAN THERE IS ANOTHER l
111-79 i )
1 INTERVIEW REPORTED WHICH IS APRIL 20, AND IT JUST SAYS 2 IT'S A STATEMENT OF RICHARD PARKS. IT DOESN'T INDICATE 3 WHETHER MR. DEVINE WAS PRESENT OR NOT.
4 A HE WAS NOT PRESENT. NOT WITH MY INITIAL 5 INTERVIEW WITH MR. FEINBERG.
6 Q RIGHT.
7 BUT I WANT --
THE MATTER I WAS INTERESTED IN 8 ASKING YOU ABOUT WAS ON THE SECOND INTERVIEW.
9 A OKAY.
10 Q ! DON'T KNOW IF IT WAS BEFORE OR AFTER THE 11 LABOR DEPARTMENT INTERVIEW.
12 A OH, WELL I --
13 Q IT WOULD BE ABOUT THE SAME TIME, BUT I'M NOT 14 SURE EXACTLY WHEN.
15 OKAY. AT THE SECOND MEETING WHERE MR. DEVINE 15 WAS PRESENT, IF YOU'LL LOOK ON PAGE -- THAT'S NUMBERED 2.
17 IT SAYS " PARKS' RESPONSE, COMPANY'S FACTUAL DESCRIPTION 18 ABOUT RIGHT."
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 l I
22 INTERNAL AUDITOR ABOUT QUILTEC MATTER WAS RETALIATORY." l l
23 AND THEN " COMPANY RESPONSE" IS THE NEXT ENTRY. " PROPER 24 INQUIRY. IN JULY, AUGUST, 1982 PARKS SAID HE ARRANGED FOR l
25 A BECHTEL SECRETARY TO TYPE AFTER HOURS SOME PERSONNEL {
l 111-80 l
)
___ - - _ - - - - - - - - - - - - _ - - - - _ - - - -_ . - - - - . - _ - - - J
1 INFORMATION SHEETS [ON A NUMBER OF GPU-N ENGINEERS IN 2 RESUME l FORM. PARKS PAID $75 T O H E R . I 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.
I 6 -' COMPANY'S FACTUAL DESCRIPTION ABOUT RIGHT. FAVOR TO'HIS 7 BOSS, KING, WORKED FOR'AN INTERESTED TYPIST."
l 8 A I DON'T --
9 Q " LOOKED FOR AN INTERESTED TYPIST.
10 GAVE HER, COPY," 1 BELIEVE THAT'S AN '
11 ' ABBREVIATION FOR, "0F OWN RESUME FOR FORMAT. . '
12 THOUGHT OF SEVERAL ON TMI AND SEVERAL NOT.
'13 MAXIMUM 8 TO 12-PEOPLE. THE TYPIST WAS 14 SOMEONE REFERRED TO HIM BY THE GIRL ORIGINALLY 15- ASKED. .YET A FORM OF HARASSMENT, AN ISOLATED ,
16 INNOCENT INCIDENT SElZED UPON FOUR DAYS R 17 AFTER HE HAD COMPLAINED TO NRC ABOUT 18 BOB ARNOLD'S PERSISTENT QUESTIONING OF KING 19 ABOUT PARKS' KNOWLEDGE OF QUILTEC ACTIVITIES."
l 20 DOES THAT REFRESH YOUR RECOLLECTION, 21 MR. PARKS, ABOUT WHETHER YOU INFORMED MR. FEINBERG, AT 22 LEAST AT THIS INTERVIEW, OF ANY INFORMATION ABOUT YOUR 23 < QUILTEC BUSINESS CARDS, YOUR EFFORTS AT LILCO, YOUR RESUME 24 ON'QUILTEC PAPER OR YOUR QUILTEC RESUME BEING ATTACHED TO 25 THE BEAVER VALLEY PROPOSAL?
i 111-81
-l' A NO, IT DOES NOT.
2 Q IN THE COURSE OF YOUR MEETINGS WITH.'
3 MR. FEINBERG, DID HE ASK~YOU TO TE::L HIM ALL OF YOUR 4 CONTACTS OR CONNECTIONS WITH QUILTEC7 5 A AGAIN, SIR, AT THlS POINT IN TIME, I.COULD 6 NOT RECALL --
OR I CANNOT RECALL THE EXACT LINE OF-7 QUESTIONING OR ANYTHING THAT MR. FEINBERG AND I DISCUSSED.
8 BUT I CAN TELL YOU THAT I DID NOT INTENTIONALLY TRY TO 9 WITHHOLD OR NOT DISCLOSE ANY INFORMATION THAT I COULD 10 RECALL TO MR. FEINBERG.
11 Q DO YOU HAVE ANY OTHER RECORD OF THIS -- OF 12 YOUR MEETINGS WITH MR. FEINBERG EITHER ON APRIL 20 OR 13 MAY 2, '33 OTHER THAN THESE TWO' STATEMENTS THAT ARE PART 14 OF THE DEPARTMENT OF LABOR REPORT?
15 A 1 THINK, AT ONL 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. FEIN8 ERG 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 SPEAKINC.
23 Q BUT YOU NO LONGER HAVE THAT?
24 A I, AT THIS POINT IN TIME, COULD NOT TELL YOU I 25 WHATEVER BECAME OF THAT TAPE.
111-82 !
i l
1 i
1 Q OKAY. LET ME ASK JUST ONE MORE IN LIGHT OF I l
2 MY EARLIER COMMITMENT ABOUT YOUR PLANE SCHEDULE.
'3 YESTERDAY AFTERNOON WE HAD A DISCUSSION'ABOUT '
4 .YOUR REPRESENTATION YOU MAY RECALL. BEFORE YESTERDAY 5 AFTERNOON, DID YOU ASK MR. JOHNSON OR ANY NRC ATTORNEY TO 6 REPRESENT YOU IN CONNECTION WITH THIS DEPOSITION SESSION i i
7 OR THIS CASE?
8 A IS THAT COVERED BY YOUR WORK PRODUCT?
9 OKAY. I WANT TO MAKE SURE I WASN'T VIOLATING 10 SOMETHING 1 WASN'T AWARE OF.
11 BEFORE THIS WHOLE THING GOT STARTED --
12 Q I MEAN BEFORE YESTERDAY AFTERNOON.
13 A RIGHT.
14 --
THERE WERE DISCUSSIONS BETWEEN MR. JOHNSON 15 AND I REGARDING EXACTLY WHAT TYPE OF ROLE HE WAS TO 16 PERFORM IN THIS; WHAT TYPE OF ROLE, YOU KNOW, WHETHER IT 17 BE ATTORNEY-CLIENT PRIVILEGE, THAT TYPE OF THING. AND 1 18 HAVE AS OF YET HA) --
HAVE BEEN UNABLE TO CONTACT MY 19 ATTORNEYS TO CONFlRM THE DISCUSSIONS THAT I HAD WITH 20 MR. JOHNSON REGARCING WHAT MY RIGHTS ARE. SO AT THIS 21 POINT IN TIME, UNTIL I HAVE A CHANCE TO TALK WITH THE 22 HOBERG LAW FIRM, I RESPECTFULLY DECLINE TO ANSWER YOUR 23 QUESTION ANY FURTHER.
24 Q OKAY. JUST SO THE QUESTION IS CLEAR, l'M NOT 25 ASKING YOU ABOUT WHAT MR. JOHNSON ADVISED YOU YOUR RIGHTS 111-83
y l n; 1, ARE. IT WAS REALLY-lA VERY SPECIFIC QUESTION..
(2 DID'YOU ASK MR.'JOHNSO'N OR'ANYfNRC ATTORNEY 3 .TO REPRESENT YOU, I MEAN AS A LAWYER?
4 MR. JOHNSON: HOLD-A SECOND.- WAIT A SECOND.
5 (MR. BERRY AND MR. JOHNSON ARE CONFERRING.)
6 THE WITNESS: I ASSUME FOR ALL PRACTICAL PURPOSES 7 .THAT THE DEPOSITION IS OVER?-
8 MR.' JOHNSON: WAIT A SECOND.
9 MR. HICKEY: NOT QUITE.
10L MR.. JOHNSON: ' MR. HICKEY, YESTERDAY YOU STATED ON l
11- THE RECORD YOU ASKED THE QUESTION.SIMILAR TO THE ONE 12 YOU'RE ASKING MR. PARKS ABOUT THE NATURE OF THE STAFF'S 13 REPRESENTATION OF MR. PARKS AND WE PROVIDED AN ANSWER
.14 YESTERDAY.
15 MR. HICKEY: DIFFERENT QUESTION.
16 MR. JOHNSON: WELL, IT'S OUR-OPINION THAT THE 17 QUESTION ABOUT THE. NATURE.0F OUR REPRESENTATION OF
- 18. MR. PARKS IS PROPERLY ADDRESSED TO THE STAFF AND NOT TO 19 MR. PARKS. AND I THINK WE STATED THAT WE BELIEVE WE'RE 20' REPRESENTING HIM IN HIS CAPACITY AS A WITNESS AS PART OF 21: THE STAFF'S CASE; AND THAT COMMUNICATIONS BETWEEN 22 MR. PARKS AND STAFF ATTORNEYS ARE CONSIDERED PART OF THE 23 5(AFF'S PREPARATION OF ITS CASE. AND THOSE REQUIRES INTO l
24 THE SUBSTANCE OF THE NATURE THE ATTORNEYS' CONTACTS WITH 1
.I 25 MR.. PARKS ARE EITHER ATTORNEY -- COVERED BY 111-84 i
1 1! ATTORNEY-CLIENT PRIVILEGE OR ATTORNEY WORK PRODUCT. AND 2 WE BEblEVE THAT.MR.. PARKS ISLNOT A PROPER SUBJECT'FOR-3 FURTHER~ QUESTIONING ON THIS MATTER.
'4 MR. HICKEY: WELL, ARE.YOU TELLING MR. PARKS NOT TO 5 ANSWER 1THE QUESTION?
6: MR. JOHNSON: YES.
7 Q- BY MR. HICKEY: MR. PARKS, DO YOU WANT TO 8 ANSWER THE QUESTION? I SUGGEST.TO YOU THAT AT SOME POINT.
9; WE'RE GOING TO HAVE TO GET THE MATTER RESOLVED, AND 1 10 2 THOUGHT IT WOULD BE HELPFUL TO RESOLVE IT, YOU KNOW, WHAT
' ll- YOU WOULD ASK THE GENTLEMEN TO DO FOR YOU?
12 A I GAVE YOU THE ANSWER PREVIOUSLY. 'I
. 13 RESPECTFULLY DECLINELTO ANSWER. THE NEXT TIME I HEAR-THAT
- 14 QUESTION, MY PERSONAL LAWYERS WILL BE.PRESENT TO ANSWER 15' FOR ME.
16 MR. H I C K E Y. : OKAY.- WELL, I DID SAY WE'D STOP SO 17 YOU CAN MAKE YOUR PLANE, MR. PARKS. WE'LL SEE YOU ANOTHER 18 TIME.
19 CAN I ASK YOU, DO YOU HAVE A SCHEDULED
~ 20 VACATION OR DO YOU KNOW THAT YOU'RE GOING TO BE GONE FOR
- 21 SOME PARTICULAR PERIOD OF TIME BETWEEN NOW AND THE END OF 22' THE SUMMER?
l-23 THE WITNESS: OFF THE RECORD. IS THAT ACCEPTABLE L
24 WITH YOU? ARE WE OFF THE RECORD NOW?
25 MR. HICKEY: l'M AGREEABLE TO GOING OFF THE RECORD.
111-85
. i 1 (DISCUSSION-HELD OFF THE RECORD.)
E i 2 MR. HICKEY: MR. PARKS SAYS HE'LL WORK OUT ANY I l
3 SCHEDULES WITH HIS LAWYER, BUT HE'S NOT YOU WILLING.T-O l 4 DISCLOSE WHETHER HE HAS ANY PLANNED ABSENCES.
l 5 MR. JOHNSON: WE CAN CONTINUE ON THE RECORD. l 6 I WOULD SUGGEST THAT IT WOULD BE USEFUL FOR I
7 THE STAFF TO.KNOW FOR PURPOSES OF THE PROCEEDING HOW MUCH' I
8 MORE EXAMINATION YOU ANTICIPATE. ORIGINALLY IN THE COURSE 9 0F THE FIRST DAY'S EXAMINATION YOU INDICATED YOU BELIEVED i 10 YOU ONLY HAD TWO DAYS OF EXAMINATION. AND AT THAT --
11- MR. HICKEY: I DON'T BELIEVE I SAID THAT.
12 MR. JOHNSON: I BELIEVE WHAT YOU HAVE SAID THAT THE 13 RECORD WILL SPEAK FOR-ITSELF. AND MR. PARKS INDICATED, I 14 BELIEVE, THAT HE HAD AN ENGAGEMENT THIS AFTERNOON OR I.
15 .SOMETHING THAT WOULD REQUIRE HIM TO TERMINATE THE 16 DEPOSITION EARLIER THAN THE END OF.TODAY. AND UP UNTIL 17 11 0' CLOCK THIS MORNING, WE HAD EVERY REASON TO BELIEVE 18 IT. YOU INDICATED NOTHING TO THE STAFF COUNSEL HERE.
19 MR. HICKEY: I DON'T THINK THAT'S ACCURATE, {
20 MR. JOHNSON. IF YOU WANT TO DISCUSS IT ON THE RECORD, I'M l 21 WILLING TO, BUT I'M GOING TO CORRECT SOME OF THE f
{
22 STATEMENTS THAT YOU MADE BECAUSE I DON'T THINK THEY'RE i 23 ACCURATE.
24 IF YOU WANT TO DISCUSS IT OFF THE RECORD, j 25 l'LL BE GLAD TO DO THAT TOO. ,
III-86 i
j l
!! 31 MR JOHNSON: OKAY. DISCUSS IT OFF THE RECORD.
- 2. =(DISCUSSION HELD.OFF THE RECORD.)-
'3- (DEPOSITION ADJOURNED A T -1 1': 3 0 A.M.)-
'4 (DEPOSITION CONTINUED SINE DIE. DECLARATION E !
5- UNDER PENALTYLOF. PERJURY.ON THE FOLLOWING PAGE H E R E O F . ')
6 7-
- 8-9 10-l11' 12 13
, 14'
.15 16 l
17 i
18 1 19 20 21 22-j: 23
'24 i #25' 111-87
1- DECLARATION U ND'E R PENALTY OF PERJURY 2
7 3
4
'S I HEREBY DECLARE UNDER PENALTY OF' PERJURY' -
6 THAT THE FOREGOING-IS MY DEPOSITION UNDER' OATH; ARE THE 7 QUESTIONS. ASKED OF-~ME 'AND MY ANSWERS THERET0; THAT I HAVE READ'SAME'AND HAVE MADE'THE NECESSARY CORRECTIONS, 9- ' ADDITIONS'OR CHANGES.TO MY ANSWERS THAT I DEEM NECESSARY..
10 IN' WITNESS THEREOF, I HEREBY SUBSCRIBE-MY 11' NAME THIS- . DAY OF , 1987
- l. 12 13-14' 15 !
W 1TNE S S ~ !
16 .;
17 18 19 ,
20
' 21 i
-22 {
L 23 .l 1
24 i
! i 25 III-88
_ _ . _ _ .-.________-_________________J
1 STATE OF CALIFORNIA )
) SS.
2 COUNTY OF ORANGE )
3 4 I, PENNY SANDER, CSR 4769, A NOTARY PUBLIC OF THE 5 STATE OF CALIFORNIA, DO HEREBY CERTIFY:
6 THAT THE WITNESS NAMED IN THE FOREGOING DEPOSITION, 7 PRIOR TO BEING EXAMINED, WAS BY ME FIRST DULY SWORN; 8' THAT SAID DEPOSITION WAS TAKEN BEFORE ME AT THE 9 TIME AND PLACC HEREIN SET FORTH AND WAS TAKEN DOWN BY ME f i
10 IN SHORTHAND AND THEREAFTER TRANSCRIBED INTO TYPEWRITING 11 UNDER MY DIRECTION AND SUPERVISION; i
12 THAT SAID DEPOSITION IS A TRUE RECORD OF THE {
13 TESTIMONY GIVEN BY THE WITNESS AND OF ALL: OBJECTIONS MADE 14 AT THE TIME OF THE EXAMINATION.
15 I FURTHER CERTIFY THAT I AM NEITHER COUNSEL FOR i 16 NOR RELATED TO ANY PARTY TO SAID ACTION, NOR IN ANYWISE 17 INTERESTED IN THE OUTCOME THEREOF. h 18 IN WITNESS WHEREOF, I HAVE SUBSCRIBED MY NAME AND 19 AFFIXED MY SEAU THIS 29TH DAY OF JUNE, 1987.
20 21 '^^**#y@".^['TiTf**j 4 9
22 j/r?>U PumY SUWER noum p:suc cAuromw I
t J Gyu; caAct coONTY i g s >' my cm ex. : e.pa n. im j 24 Sam sSw0s l 0 1 25 NOTARY PUBLIC FOR THE STATE OF CALIFORNIA l i
III-89
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