In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 3630

DECLARATION of Wedeking in Support re: (157 in 1:04-cv-04973-SAS) MOTION for Summary Judgment for Lack of Evidence Pertaining to Causation.. Document filed by Coastal Chem, Inc.. (Attachments: # 1 Exhibit #1, # 2 Exhibit #2, # 3 Exhibit #3, # 4 Exhibit #4, # 5 Exhibit #5, # 6 Exhibit #6, # 7 Exhibit #7, # 8 Exhibit #8, # 9 Exhibit #9)Filed In Associated Cases: 1:00-cv-01898-SAS-DCF, 1:04-cv-04973-SAS(Allen, Brent)

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Exhibit 7 Deposition of Glen R. Blue / March 17, 2011 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -oOo________________________________ In re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation ________________________________ Master File No. 1:00-1898 This Document Relates To: Case No. City of Fresno MDL 1358(SAS) v. Chevron U.S.A. Inc., et al., Case No. 04 Civ. 4973 ________________________________ DEPOSITION OF GLEN R. BLUE March 17, 2011 at 1:00 (1:17) p.m. Before: ERIC L. JOHNSON RPR, CSR #9771 Taken at: Fresno, California DEPOBOOK REPORTING SERVICES (800) 830-8885 Deposition of Glen R. Blue / March 17, 2011 Page 19 1 A. Pardon? 2 Q. We will try to use Exhibit 2 as we go through 3 questions. 4 A. Okay. 5 Q. How long were you associated with the station 6 at 2809 South Chestnut? 7 MS. KLEAVER: Vague. 8 THE WITNESS: I don't know the exact dates. 9 Several years. 10 11 12 I owned the station. MR. STEEVES: A. Q. You owned -- 280 -- well, 49 -- forget 2809. I have no interest in it. 13 MR. STEEVES: Excuse me. You what? 14 A. I was thinking -- it is 4090 South Chestnut. 15 Q. Right. 16 I'd like to -- I'd like to first talk about 2809 South Chestnut. 17 A. All right. 18 Q. Do you recall when you started working at Red 19 Triangle Oil Company in 2809? 20 A. What year? 21 Q. Yes. 22 A. At this location? 23 Q. Yes. 24 A. In the early '60s. 25 Q. What was your job title when you first started DEPOBOOK REPORTING SERVICES (800) 830-8885 Deposition of Glen R. Blue / March 17, 2011 Page 20 1 2 3 working there? A. I was a janitor, sales, warehouseman, whatever had to be done. We didn't wear hats back in those days. 4 Q. And how long did you work there? 5 A. Well, I have to calculate. 6 7 8 You told me a little while ago; 30-plus years? Q. So you worked there during the time period you were associated with your father-in-law's business? 9 A. Yes. 10 Q. So that would have been, I think you testified, 11 through 1989? 12 A. Yes. 13 Q. Did your job duties ever change over time? 14 Were you just a jack-of-all-trades, or did you have a 15 specific title at any point? 16 A. I worked there and did what had to be done. 17 Q. Do you recall who the operator of that station 18 19 20 21 22 was at the time you were working there? A. station. Q. That was a company-operated store -- or Red Triangle operated it. Okay. Do you recall who owned the property, the actual dirt that the -- the station was on? 23 A. Arnold Hohenshelt. 24 Q. Did Arnold own the tanks as well, the -- 25 A. He owned the complete facility. DEPOBOOK REPORTING SERVICES (800) 830-8885 Deposition of Glen R. Blue / March 17, 2011 Page 22 1 2 period you worked there? A. Run that by me again. 3 MS. KLEAVER: Same objection. 4 MR. STEEVES: Q. Do you recall if Red Oil 5 (sic) had an agreement to buy a certain brand of 6 gasoline during the time period you worked there? 7 MS. KLEAVER: Same objection. 8 THE WITNESS: I can't tell you who had the 9 10 contracts, but no doubt they did. a certain amount of gas. 11 12 They committed to buy MR. STEEVES: Q. But you can't recall the -- the company? 13 MR. PARSEGHIAN: 14 THE WITNESS: Objection; asked and answered. The company bought from various 15 people over a period -- I don't know what time frame you 16 are looking at. 17 18 19 20 21 22 MR. STEEVES: Q. Let's start with the time period in the 1980s. A. brand. Q. The biggest supplier is Exxon. That was the Then they had various rebrand gas. You said that was the biggest supplier. Were there other suppliers? 23 A. 24 delivered in? 25 Q. Did the company buy from other people or people Did the company buy from other people? DEPOBOOK REPORTING SERVICES (800) 830-8885 Deposition of Glen R. Blue / March 17, 2011 Page 23 1 A. Yes. 2 Q. Do you recall who that was? 3 A. Well, we bought from Jack Griggs Oil. 4 Q. Sorry, Jack Riggs? 5 A. Griggs, G-r-i-g-g-s. 6 Q. Griggs. 7 8 9 And do you recall the approximate time period that the company was buying from -A. I don't remember. I know we had Jim Harness. John Harness Oil Company was a supplier of Exxon 10 products. 11 everyone we bought from. 12 we went and bought from, called rebrand. 13 Q. And we -- we bought from -- I can't recall Whoever had the lowest price Are you aware of anyone else associated with 14 the station that would have personal knowledge of these 15 supply agreements? 16 MS. KLEAVER: Vague as to time. 17 THE WITNESS: I don't know who they would be. 18 MR. STEEVES: I am going to show you a few more 19 documents associated with this site at 2809. 20 will move on to the next site. 21 (Deposition Exhibit 4 marked for 22 23 Then we identification) MR. STEEVES: Q. Handing you what's been 24 marked as Exhibit 4. 25 form for Red Triangle Oil Company dated January 31st, It is a Business Plan Registration DEPOBOOK REPORTING SERVICES (800) 830-8885

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