Craig Stevens Transcript

1
Craig Stevens 1/31/2019
1 IN THE COURT OF COMMON PLEAS OF SUSQUEHANNA COUNTY

2 PENNSYLVANIA, CIVIL DIVISION
3 -----------------------------------
4 CABOT OIL & GAS CORPORATION and
5 GASSEARCH DRILLING SERVICES
6 CORPORATION,
7 Plaintiffs,
8 v. Case No. 2017-936-CP
9 CHARLES F. SPEER LAW
10 FIRM, P.A., EDWARD CIARIMBOLI,
11 CLANCY BOYLAN, FELLERMAN &
12 CIARIMBOLI, and RAY KEMBLE,
13 Defendants.
14 -----------------------------------
15 Alexandria, Virginia
16 January 31, 2019
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25 (Title continued on the following page.)
Casamo & Associates 703 837 0076 www.casamo.com

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1 TITLE (continued):
2
4 Video Deposition of:

5 CRAIG L. STEVENS,
6 called for examination by counsel on behalf of the
7 Plaintiffs, pursuant to Notice, at the Law Offices
8 of Buchanan, Ingersoll & Rooney, 1737 King Street,
9 Alexandria, Virginia, at approximately 8:59 a.m.,
10 before Rebecca Monroe, a certified Verbatim
11 Reporter, and a Notary Public in and for the
12 Commonwealth of Virginia, when there were present on
13 behalf of the respective parties:
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1 A P P E A R A N C E S
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3 ON BEHALF OF THE PLAINTIFFS:

4 AMY BARRETTE, ESQUIRE
5 MATTHEW C. PILSNER, ESQUIRE
6 Buchanan, Ingersoll & Rooney, P.C.
7 One Oxford Centre, 301 Grant Street
8 20th Floor
9 Pittsburgh, Pennsylvania 15219
10 (412) 562-3921
11
12 COLE DELANCEY, ESQUIRE

13 Cabot Oil & Gas Corporation
14 2000 Park Lane
15 Suite 300
16 Pittsburgh, Pennsylvania 15275
17 (412) 249-3850
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25 (Appearances continued on the next page.)

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1 APPEARANCES (continued):
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4 ON BEHALF OF THE DEFENDANTS CHARLES F. SPEER, EDWARD

5 CIARIMBOLI, CLANCY BOYLAN, AND FELLERMAN AND
6 CIARIMBOLI:
7 BRIAN DOUGHERTY, ESQUIRE
8 Scanlon, Howley & Doherty, P.C.
9 217 Wyoming Avenue
10 Scranton, Pennsylvania 18503
11 Brian@shdlawfirm.com
12
13
14 ON BEHALF OF THE WITNESS:

15 RYAN C. POSEY, ESQUIRE
16 Posey & Lebowitz
17 3221 M Street, Northwest
18 Washington, D.C. 20007
19 (202) 643-2525
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24
25 (Appearances continued on the next page.)

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1 APPEARANCES (continued):
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3 ON BEHALF OF THE DEFENDANT RAYMOND KEMBLE (via

4 telephone):
5 RICHARD RAIDERS, ESQUIRE
6 Raiders Law, P.C.
7 606 North 5th Street
8 Reading, Pennsylvania 19601
9 (484) 509-2715
10
11 ALSO PRESENT:
12 WILLIAM CASAMO, VIDEOGRAPHER
13 CHARLES THIES, SENTINEL INTEGRATED SERVICES
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1 C O N T E N T S
2
3 WITNESS: PAGE
4 CRAIG L. STEVENS
5 Examination by Ms. Barrette. . . . . . . . . . 8
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7 DEPOSITION EXHIBITS: PAGE

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9 #2. . . . . . . . . . . . . . . . . . . . . . . . 18
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11 #4. . . . . . . . . . . . . . . . . . . . . . . .114
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1 CONTENTS (continued):
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3 DEPOSITION EXHIBITS: PAGE

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1 P R O C E E D I N G S
2 - - - - - - - - - - -
3 THE VIDEOGRAPHER: This is the video
4 deposition of Craig Stevens in the matter of Cabot
5 Oil & Gas Corporation and Gassearch Drilling
6 Services Corporation versus Charles F. Speer, Speer
7 Law Firm, P.A., Edward Ciarimboli, Clancy Boylan,
8 Fellerman and Ciarimboli, and Raymond Kemble, in the
9 Circuit Court of Fairfax County, miscellaneous
10 action number CM 2018-568.
11 This deposition is being held on
12 January 31st, 2019, beginning at 8:59 a.m. The
13 address is 1737 King Street, Alexandria, Virginia
14 22314. My name is Bill Casamo, I'm the videographer
15 representing Casamo & Associates.
16 Counsel will now introduce themselves and
17 whom they represent.
18 MS. BARRETTE: Amy Barrette and Matt
19 Pilsner from Buchanan Ingersoll. We represent the
20 plaintiffs in this case, Cabot Oil & Gas Corporation
21 and Gassearch Drilling Services.
22 Also here today is Cole DeLancey, he is the
23 senior in-house counsel for Cabot Oil & Gas.
24 MR. DOUGHERTY: Brian Dougherty on behalf
25 of defendants Charles Speer, Speer Law Firm, Edward

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1 Ciarimboli, Clancy Boylan, Fellerman and Ciarimboli.

2 MR. RAIDERS: Rich Raiders, Raiders Law
3 P.C., on behalf of defendant Ray Kemble.
4 MR. POSEY: And good morning, I'm Ryan
5 Posey and I'm here on behalf of Mr. Stevens, the
6 witness.
7 MS. BARRETTE: I also want to note for the
8 record that also Charles Thies is here in the room
9 present for the deposition. Given the contentious
10 nature of some of the pleadings that were recently
11 filed in the case, we felt that it would be prudent
12 to have security here in the event anything would
13 happen during the deposition, so...
14 THE VIDEOGRAPHER: Also present is the
15 court reporter, Rebecca Monroe. Would you please
16 swear in the witness.
17 Whereupon,
18 CRAIG STEVENS,
19 a witness, called for examination, having been first
20 duly sworn, was examined and testified as follows:
21 EXAMINATION BY COUNSEL FOR PLAINTIFFS
22 BY MS. BARRETTE:
23 Q. Good morning, Mr. Stevens. We were just
24 first introduced a few moments ago, my name is Amy
25 Barrette, I represent Cabot Oil & Gas.

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1 Before we get started, do you happen to

2 have a gun on you today?
3 A. No, I do not.
4 Q. Okay.
5 MR. POSEY: And just for the record, I need
6 to make a couple of preliminary objections that the
7 rules require me to make the objections on the
8 record with the deposition still to proceed. I'm
9 going to object that this deposition and the
10 subpoena duces tecum -- duces tecum was overly
11 broad, that it was improperly served on Mr. Stevens,
12 that he was able to involve counsel only two days
13 ago and I haven't had an opportunity to fully
14 prepare with counsel before this and that the
15 plaintiff in the case refused to reschedule to allow
16 counsel to get up to speed.
17 It's also unclear to us what information
18 Mr. Stevens would have that would not be available
19 to the parties themselves. We object that it's
20 overly broad and places an undue burden on
21 Mr. Stevens to provide information that's in the
22 hands of the parties or other third parties that
23 might be less burdensome.
24 He's objected to both the manner and method
25 of the service, that it's a fishing expedition and

11
1 not related to the claims asserted against the

2 lawyer defendants or Mr. Kemble. Please note our
3 continuing objection reasserted in all of these
4 questioning.
5 With that here -- with that said, we're
6 here today in good faith and Mr. Stevens will
7 testify subject to these continuing objections and
8 has brought with him today documents that were in
9 his possession responsive to the requests.
10 BY MS. BARRETTE:
11 Q. Mr. Stevens, have you ever been deposed
12 before?
13 A. No.
14 Q. Have you ever given testimony under oath
15 before?
16 A. Yes.
17 Q. Okay. And can you tell me where you
18 testified under oath?
19 A. In Susquehanna County courthouse for some
20 property matters.
21 Q. When you say "property matters," were those
22 relating to the litigation concerning your
23 grandmother and her mental capacity to enter into a
24 lease agreement?
25 A. Yes.

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1 Q. Any other Susquehanna County places you

2 testified under oath?
3 A. Not that I can recall.
4 Q. Now, when you testified under oath -- oh,
5 let me ask you this. When you testified before the
6 different senate assemblies in, like, before the
7 EPA, are you sworn in at those?
8 A. No.
9 Q. Well, I'd like to, before we get started
10 with the deposition, give you a little bit of
11 background, what a deposition is like, how it goes.
12 I don't know if you discussed this with your
13 attorney, but I like to walk through this with
14 witnesses.
15 A. Okay.
16 Q. So today I'll be -- my job here is to just
17 ask the questions, you're just -- your job is to
18 just to answer. I ask that during the deposition
19 if -- one of the things we do in normal
20 conversation, if you can anticipate where I'm going
21 with the question, you may start to answer before
22 I'm finished. I just ask that you wait until I'm
23 finished so the court reporter can get an accurate
24 transcription of what we're saying.
25 If we're both talking, it makes it very

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1 difficult for her to get everything accurately. If

2 at any time you need to take a break, let me know,
3 we'll take a break. The only thing I ask is if
4 there's a question pending, that you answer the
5 question before we take the break.
6 If you need a drink, if you need to use the
7 restroom, whatever, just let me know. We have
8 coffee, water, things of that nature, soda, if you'd
9 like anything. If at any time I ask a question that
10 you don't understand or that seems confusing to you,
11 please let me know, I'll try to rephrase it so that
12 it's clear that you understand the question that I'm
13 asking. Okay?
14 A. Yes.
15 Q. And that's another thing, if you're going
16 to answer yes or no, I just ask that you answer
17 verbally so that we can get it on the record, a lot
18 of times people shake their head and nod and we just
19 need to have a verbal answer so that we get it on
20 the record. Okay?
21 A. Yes.
22 Q. Now, did you --
23 (Stevens Deposition Exhibit #1 was marked
24 for identification.)
25 BY MS. BARRETTE:

14
1 Q. I'm handing you what's been marked for

2 identification purposes as Cabot Exhibit Number 1.
3 Do you recognize this document?
4 A. Yes.
5 Q. And did you draft this document?
6 A. Yes, I worked in conjunction with -- let me
7 look it over. Yes -- well, with the aid of Bill
8 Huston.
9 Q. And who typed up the document?
10 A. Who typed it up?
11 Q. Yes.
12 A. Bill Huston.
13 Q. And who filed the document?
14 A. I filed the document.
15 Q. And is that your signature that appears on
16 the next to the last page?
17 MR. POSEY: Objection. You can answer if
18 you know.
19 THE WITNESS: Next to the last page?
20 BY MS. BARRETTE:
21 Q. Yes.
22 A. Yes.
23 Q. And the last page, is that also your
24 signature?
25 A. Yes.

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1 Q. Okay. Now, you said you drafted this in

2 conjunction with Mr. Huston, correct?
3 A. Yes.
4 Q. Okay. Now, I'd like to turn your attention
5 to page -- or paragraph 56. And in paragraph 56 you
6 state, We've heard that an eight-hour deposition
7 with Cabot's attorney makes water boarding seem like
8 a vacation at Disneyland; do you see that?
9 MR. POSEY: I'm going to object to this
10 entire line of questioning. I don't see what this
11 has to do with the facts of the case as the
12 complaint that you've sent to us. I'm going to just
13 have a continuing objection. You can answer these
14 questions if you know.
15 MS. BARRETTE: Okay. Excuse me, before you
16 answer. Mr. Posey -- Attorney Posey, I'm going to
17 say on the record speaking objections are not
18 permitted. If you have an objection, you can state
19 that, that you object, but if you're going to take
20 up our time throughout this deposition with speaking
21 objections, I'm going to object to that.
22 MR. POSEY: The rules require that I make
23 objections in a short and nonargumentative manner
24 and I've done that. All I said was I object to this
25 line of questioning and continuing objection.

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1 MS. BARRETTE: Well, we'd like to get done

2 with the deposition today. Okay.
3 BY MS. BARRETTE:
4 Q. So is -- did I read that correctly,
5 paragraph 56, Mr. Stevens?
6 A. Paragraph 56?
7 Q. Yes.
8 A. Yes.
9 Q. Okay. Well, I just want to assure you that
10 today's deposition will be much more pleasant than
11 water boarding, but --
12 A. I guess.
13 Q. But I'm curious, who did you hear that from
14 that an eight-hour deposition with Cabot's attorney
15 makes water boarding seem like a vacation at
16 Disneyland?
17 A. I've heard it from many people that have
18 been deposed by you.
19 Q. And who would those people be?
20 A. People involved in the previous lawsuit,
21 Mr. Kemble, Mr. Ely, and others.
22 Q. Who are the others?
23 A. I believe Eric Roos.
24 Q. Did you say "Vera Cruz"?
25 A. Eric Roos.

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1 Q. Oh, Eric Roos. So Mr. Kemble, Mr. Ely --

2 when you say Mr. Ely, are you referring to Scott
3 Ely?
4 A. Yes.
5 Q. And Eric Roos, correct?
6 A. Yes.
7 Q. Anybody else?
8 A. Not that I recall.
9 Q. Okay. Would it surprise you to know that I
10 did not depose Mr. Kemble or Mr. Roos?
11 A. I did not know that.
12 Q. Yes.
13 A. Your -- but your name is not here, it says
14 with Cabot's attorney.
15 Q. Okay.
16 A. So it doesn't say Ms. Barrette.
17 Q. Okay. Good. So you're referring to
18 something else then?
19 A. I'm guessing, yes.
20 Q. You're guessing? You signed the document,
21 correct?
22 A. Yes, but it says Cabot's attorney, it does
23 not put a name there.
24 Q. Okay. So you didn't know who you were
25 referring to there?

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1 A. I didn't know who was going to depose me

2 today.
3 (Stevens Deposition Exhibit #2 was marked
5 BY MS. BARRETTE:
6 Q. Okay. Mr. Stevens, I'm handing you what's
7 been marked for identification purposes as Cabot's
8 Exhibit Number 2, do you recognize this document?
9 A. Yes.
10 Q. And this is a copy of the subpoena in this
11 case. I understand that you're claiming that the
12 subpoena was not properly served, but this is a copy
13 of the subpoena that you are responding to today
14 here, correct?
15 A. No, it is not. That's -- that looks like
16 the 26th day of October. Today is not the 26th day
17 of October.
18 Q. But this is the subpoena that's at issue,
19 correct?
21 you know.
22 THE WITNESS: I -- this is the subpoena?
23 BY MS. BARRETTE:
24 Q. Yes.
25 A. Oh, no, I thought there was a date of

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1 today's date on the one that I'm responding to.

2 This is the -- it says October 26th on it, so this
3 looks like an older document. All these -- that's
4 from October, so...
5 Q. That is correct. And you understand we had
6 a motion to compel that we filed, correct?
7 A. Correct.
8 Q. And the Court entered an order compelling
9 you to appear on today's date for the deposition,
10 correct?
11 A. Yes, on December 7th that was the date that
12 I got the compel order. This is -- this is from
13 October.
14 Q. That's correct. The judge issued an order
15 and she changed the date to January 31st, correct?
16 A. Correct.
17 Q. And you recall I handed that to you at the
18 courthouse, correct?
19 A. Correct.
20 Q. Now, did you gather documents in response
21 to a subpoena today?
22 A. Yes.
23 Q. And are you saying that you don't know
24 whether this is the subpoena that you were gathering
25 documents responsive to?

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1 A. I'm saying I came here today because of the

2 judge's order on December 7th that was for January
3 31st. None of this has January 31st on it so I
4 didn't recognize it as the subpoena for today.
5 Q. Okay. I understand that. So you did
6 gather documents in response to this subpoena
7 though, correct?
8 A. Yes.
9 Q. Okay. Now, your attorney objected to the
10 deposition today on the grounds that I believe you
11 said that you did -- had just retained counsel and
12 did not have adequate time to prepare, is that
13 correct?
14 A. Yes.
15 Q. Now, you understood that you were under a
16 court order to appear today for this deposition back
17 on December 7th, correct?
18 A. Yes.
19 Q. And the judge actually gave you additional
20 time, you said you would -- at the hearing you
21 stated that you would need additional time to gather
22 all the records, correct?
23 A. Yes.
24 Q. I think -- I believe you said 30 to 60
25 days, correct?

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1 A. Yes.
2 Q. And the judge gave you that additional
3 time, correct?
4 A. Yes.
5 Q. And all during that time up until two days
6 ago you could have retained an attorney, correct?
8 you know.
9 THE WITNESS: I didn't have access to one,
10 it just became available this week.
11 BY MS. BARRETTE:
12 Q. When you say "it just became available this
13 week," what do you mean?
14 THE WITNESS: I --
15 MR. POSEY: Objection. I'm going to
16 instruct you not to disclose anything discussed with
17 counsel.
18 BY MS. BARRETTE:
19 Q. I'm not asking you what you disclosed with
20 counsel, I'm asking you how did an attorney -- what
21 did you mean an attorney just became available this
22 week?
23 MR. POSEY: Objection.
24 THE WITNESS: I've been trying to find one
25 since December 7th, but I don't have funds and I was

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1 not able to find one until just this week.

2 BY MS. BARRETTE:
3 Q. Okay. And how did -- how were you trying
4 to find an attorney prior to two days ago?
5 MR. POSEY: Objection. Privileged.
6 MS. BARRETTE: The efforts that Mr. Stevens
7 took to find an attorney are not privileged.
8 MR. POSEY: Absolutely they are.
9 MS. BARRETTE: No, they are not privileged.
10 MR. POSEY: Discussions with any attorney
11 or prospective attorney are privileged. I'm going
12 to instruct him not to answer this question.
13 MS. BARRETTE: I'm not asking him about
14 conversations that he had with attorneys. I'm
15 asking him what he did. I understand that you are
16 likely -- let me ask you this.
17 BY MS. BARRETTE:
18 Q. Were you contacted by Mr. Posey's law firm?
19 A. Was I contacted, no.
20 Q. Okay. Did another organization retain
21 Mr. Posey for you?
23 MS. BARRETTE: What is the objection?
24 MR. POSEY: How is this relevant in any way
25 to the -- to the matter of the --

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1 MS. BARRETTE: You raised the objection at

2 the beginning of this deposition and I am exploring
3 an objection that you raised. So it is relevant
4 because you made it relevant.
5 BY MS. BARRETTE:
6 Q. Now, Mr. Stevens --
7 MS. BARRETTE: Could you read that question
8 back, please.
9 BY MS. BARRETTE:
10 Q. Let me ask you, did another organization
11 find an attorney for you?
12 A. It was a referral from another attorney.
13 Q. You said that you did not have funds to get
14 an attorney, is someone else paying for Mr. Posey to
15 represent you today?
17 instruct you not to answer.
18 MS. BARRETTE: On what grounds?
19 MR. POSEY: It invades the attorney-client
20 privilege.
21 MS. BARRETTE: Whether he is paying
22 personally for an attorney does not invade the
23 privilege. You know what the attorney-client -- the
24 attorney-client privilege is communications between
25 you and your client where you are giving or

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1 receiving legal advice. So I don't think asking him

2 who is paying for his attorney violates the
3 privilege.
4 MR. POSEY: Okay. I'm instructing him not
5 to answer.
6 BY MS. BARRETTE:
7 Q. Is someone else paying for your counsel
8 today?
9 A. I've been instructed not to answer by my
10 attorney, so...
11 Q. How many different attorneys did you reach
12 out to in your efforts to get an attorney for
13 today's deposition?
15 you know.
16 THE WITNESS: Half a dozen.
17 BY MS. BARRETTE:
18 Q. And is Food & Water Watch paying for your
19 attorney today?
20 MR. POSEY: Objection. I instruct you not
21 to answer.
22 MS. BARRETTE: And the basis?
23 MR. POSEY: It invades the attorney-client
24 privilege, the payment arrangements, the
25 communications we've had. I'm instructing him not

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1 to answer.
2 BY MS. BARRETTE:
3 Q. Mr. Stevens, during the December 7th
4 hearing with Judge Azcarate, you stated that you did
5 not -- I believe your exact words were I have
6 nothing to do with Mr. Kemble, correct?
7 A. That -- I was cutoff there, I had
8 90 seconds in the four minutes, so that was not the
9 entire sentence.
10 (Cabot Deposition Exhibit #3 was marked for
11 identification.)
12 BY MS. BARRETTE:
13 Q. Okay. Mr. Stevens, I've handed you what's
14 been marked for identification purposes as Cabot
15 Exhibit Number 3, it's a copy of the transcript in
16 front of Judge Azcarate. At page 7 of the
17 transcript, it's a miniscript, if you look at page 7
18 in the lower left. You start off by discussing --
19 you say there are 34 things including bank records
20 for years and also e-mails for eight years, this is
21 34, and the judge says okay. And you say and I am
22 not a named party and I have nothing to do with
23 Mr. Kemble. Do you see that?
24 A. And then she jumps right in before I ended
25 that sentence.

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1 Q. So there was more you were going to say?

2 A. Yes, ma'am. I had four total minutes in
3 motions court. And I read my own portion out and
4 it's 90 total seconds, that's in my ample
5 opportunity that you told judge -- to respond was
6 90 seconds in a motions court.
7 Q. So the -- so the truth is you do have
8 things to do with Mr. Kemble, correct?
9 A. That is not what my -- the rest of my -- my
10 statement was going to be in this --
11 Q. Okay.
12 A. -- in court.
13 Q. Okay. Let's turn back to Exhibit 2 -- oh,
14 before we do that. Exhibit 1, which you filed in
15 Susquehanna County court, did you try to be truthful
16 in your statements here to the Court?
17 A. I always try to be truthful.
18 MR. DOUGHERTY: Attorney Barrette, just --
19 just for the record, what -- what are we referencing
20 with Exhibit 1?
21 MS. BARRETTE: I'm so sorry.
22 MR. DOUGHERTY: That's all right.
23 MS. BARRETTE: We are representing his
24 answer. I can give you a copy.
25 MR. DOUGHERTY: No, that's all right.

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1 MS. BARRETTE: As a matter of fact, I have

2 an extra copy. Pass that down.
3 BY MS. BARRETTE:
4 Q. I'd like to -- looking at paragraph 5, you
5 state that lacking any court order I have been
6 stalked and harassed across state lines by agents of
7 Cabot Oil & Gas since June 20th, under threat of
8 financial sanctions and jail, despite that I'm not
9 accused of having broken any laws.
10 What were you referring to about agents of
11 Cabot stalking and harassing you?
12 A. Well, they attempted to serve me, I see
13 from the paperwork that I eventually received
14 starting from June 20th and then somebody realized I
15 was not -- no longer living there for the last four
16 and a half years, that I've lived in Northern
17 Virginia. Then somebody, I guess, attempted to drop
18 paperwork off while I was on vacation for two weeks
19 and when I came back there was no mailed notice.
20 I didn't find the supposed original
21 documents, but there was also no mailed notice, so
22 that's what I'm saying I -- I -- I'm feeling like
23 they -- I'm being chased across state lines for
24 something that I have nothing to do with.
25 Q. Well, here you say you are being stalked

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1 and harassed?
2 A. I consider that -- I consider it harassment
3 when I have nothing to do with the case. I'm a
4 nonparty person, I did live in Susquehanna County,
5 they went -- I was told by my -- by my renters they
6 went to the house and bothered people where I don't
7 live anymore and then came across state lines, which
8 is exactly what I said, to come and find me at my
9 home here and then did not properly serve me or find
10 me there, even though the claim is made that I was
11 served properly.
12 Q. Okay. So when you're saying stalked and
13 harassed because I'm just being -- want to try and
14 get this clear for the record because you did file
15 this with the court --
16 A. Yes, ma'am.
17 Q. -- making assertions that Cabot's agents
18 were stalking and harassing you, you are referring
19 to an attempted service of a subpoena at your prior
20 home in Susquehanna County and attempted service of
21 a subpoena on you at your residence in Virginia,
22 correct?
23 A. Correct.
24 Q. Now, you also say that you were under the
25 threat of financial sanctions and jail. Who

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1 threatened financial sanctions against you?

2 A. It looks like every filing that I have from
3 your office tells what can happen if you don't -- if
4 I do not show up for my subpoena, if I miss a court
5 date. And by the way, I was threatened with arrest
6 by Judge Azcarate twice in four minutes, so I was
7 stalked, harassed, and threatened with arrest.
8 Q. Okay. But you're not saying that Cabot's
9 agents were threatening you with financial sanctions
10 or jail?
11 A. My appearance here today is I consider
12 stalking and harassment. I have nothing to do with
13 this case. I have nothing to do with Mr. Kemble
14 signing an agreement of any kind with your company.
15 I have nothing to do with him potentially violating
16 that. So I consider this entire affair stalking and
17 harassing, personally.
18 Q. And so back to my question, there have been
19 no threats by anybody from Cabot to -- and no
20 threats of financial sanctions or jail, correct?
21 A. Cabot is the reason I'm here today, so any
22 actions that happen to me in the last seven months
23 were directed by Cabot. So, yes, I believe that
24 Cabot is responsible for my stalking and harassing,
25 those people that came to stalk and harass me or

30
1 come and serve me were directed by your company that

2 you work for.
3 Q. So do you have any -- let me ask you this
4 way, anybody from Cabot, any agent of Cabot directly
5 threaten you with some type of financial sanctions?
6 A. I believe this entire basis is designed to
7 get me dragged into it, which I'm not interested in
8 being in. But, yes, I believe that I'm under
9 financial -- I'm already under financial stress
10 having to find a lawyer for something I have nothing
11 to do with some -- in a case that's being done in a
12 county that I haven't lived in for five years.
13 So, yes, I would agree that -- I would -- I
14 would think that that is stalking, harassing, and I
15 have been threatened both -- both -- in both
16 counties I was threatened as a -- as a defendant by
17 the sheriff's processing from Susquehanna County,
18 and I called him, he's a friend of mine, why I was
19 listed as a defendant not a witness on the
20 documentation.
21 So stalked, harassed, and threatened, yes.
22 Q. Okay. You said you were under financial
23 stress because you had to get an attorney, are you
24 paying for your own attorney?
25 MR. POSEY: Objection. Same as before, I

31
1 instruct you not to answer.

2 MS. BARRETTE: Your client raised it, he
3 made it relevant. He just said he is under
4 financial stress because he had to get an attorney.
5 THE WITNESS: This whole process has
6 caused --
7 MR. POSEY: Hold on. I'm instructing you
8 not to answer the question.
9 BY MS. BARRETTE:
10 Q. I'd like to turn to Exhibit 2, which is the
11 subpoena and if you could turn to -- toward the
12 back, the section that says categories of documents.
13 On the first one, the first category calls for
14 documents or electronic records that refer or relate
15 to communications between you and any of the lawyer
16 defendants. Did you bring any documents with you
17 today responsive to that request?
18 A. I don't recall finding any documents or
19 communications that will answer that question.
20 Q. The second request -- did you look for
21 them, did you look for documents?
22 A. I have none.
23 Q. So you're saying you don't have any?
24 A. Looked for them, did not find them, I have
25 none.

32
1 Q. Okay. And where did you look?

2 A. I looked at any papers that I have or -- I
3 don't have any electronic records going back that
4 far.
5 Q. Do you have a computer?
6 A. Yes.
7 Q. How long have you had that computer?
8 A. It's fairly new, my previous laptop broke.
9 Q. And when did you get the new computer?
10 A. In the last few months.
11 Q. What e-mail -- what's your e-mail address?
12 A. Clscraigstevens, C-R-A-I-G-S-T-E-V-E-N-S,
13 @earthlink.net.
14 Q. Now, for EarthLink you're able to access
15 your e-mail that's hosted by an outside server,
16 correct? That's not maintained only on yours, you
17 can access it remotely from any computer, correct?
19 you know.
20 THE WITNESS: I have no idea. I'm not a
21 computer person.
22 BY MS. BARRETTE:
23 Q. So number 2, it says, Produce all documents
24 that refer or relate to communications between you
25 and Kemble. Did you bring anything responsive to

33
1 that request?
2 A. No, I don't recall finding any documents or
3 communications.
4 Q. So you didn't -- didn't bring any
5 responsive to that, correct?
6 A. Nope.
7 Q. Do you ever e-mail with Mr. Kemble?
8 A. No.
9 Q. What about text message, do you exchange
10 text messages?
11 A. No.
12 Q. Number 3 says, Produce all documents that
13 refer or relate to communications between you and
14 any person concerning Mr. Kemble. Did you find any
15 documents that were -- that are responsive to that
16 request?
17 A. I don't recall finding any documents or
18 communications related to that request.
19 Q. So you have nothing with any other third
20 party discussing Mr. Kemble, is that correct?
21 A. I just answered, I don't recall finding any
22 documents or communications related to that request.
23 Q. Number 4 says, Produce all documents that
24 refer or relate to communications between you and
25 any person concerning the past or present condition

34
1 of Kemble's water supply; do you see that?

2 A. Yes.
3 Q. Do you have any documents -- did you bring
4 any documents responsive to that request?
5 A. I don't recall any documents or
6 communications relating to that question.
7 Q. So you don't have any -- no e-mails, no
8 communications, no correspondence with any other
9 third person talking about Mr. Kemble's water
10 supply, correct?
11 A. That is my answer.
12 Q. Number 5 asks you to produce all documents
13 that refer or relate to the February 28th, 2018,
14 press conference held at the Dimock Post Office,
15 including but not limited to the following documents
16 discussed at the press conference:
17 One, the notice of claim against the
18 Commonwealth; two, the letter to the Attorney
19 General, Josh Shapiro, enclosing a private criminal
20 complaint outlining a conspiracy between state and
21 private actors to poison the air, land, water and
22 people since the first horizontal well was drilled
23 February 20th, 2006.
24 Do you have any documents related to that
25 press conference?

35
1 A. I do not have any documents related to that

2 press conference.
3 Q. Who arranged that press conference?
4 A. I have no idea, I wasn't present.
5 Q. You weren't there for that?
6 A. No, I was not.
7 Q. Did you ever -- did you ever read the
8 notice of claim against the Commonwealth that's
9 mentioned there?
10 A. I did not create and have not seen these --
11 what you're asking. I have -- don't recall or found
12 any documents or communication related to that.
13 Q. So you're familiar with the February 28th,
14 2018 press conference though, correct?
15 A. After the fact it was in the paper, but I
16 was not present so...
17 Q. Okay.
18 A. The newspaper.
19 Q. And you never discussed that with
20 Mr. Huston?
21 A. I would -- I was unaware it was happening
22 and I was no -- was in Northern Virginia at the
23 time.
24 Q. Did Mr. Huston ever discuss this notice of
25 claim against the Commonwealth document?

36
1 A. I have no discussion that -- with anybody

2 about those documents, I wasn't there, I didn't know
3 it was being done.
4 Q. Prior to the press conference did you know
5 that Mr. Huston was drafting out this notice of
6 claim against the Commonwealth?
7 A. The same, I don't recall finding -- or
8 having any communication with him about that
9 document.
10 Q. Did you ever have any communications with
11 Mr. Huston about the Attorney General -- the letter
12 to the Attorney General that supposedly enclosed a
13 private criminal complaint?
14 A. You should ask Mr. Huston, I have no
15 communication about that.
16 Q. So your answer is you've never discussed
17 that with Mr. Huston?
18 A. Never discussed, I have no communication,
19 but -- discussion possibly but not -- not before it,
20 after. When it was in the paper I called and asked
21 about what was happening.
22 Q. And what did he tell you?
23 A. He didn't -- he didn't let me know
24 anything, I guess it was a private document that was
25 produced by him. So I have no -- no idea what it

37
1 said.
2 Q. And he didn't tell you what it said?
3 A. No, he didn't share it. It's a private
4 criminal complaint it says.
5 Q. I see that's what it says, but I'm asking
6 you did Mr. Huston share with you what he wrote in
7 that criminal complaint?
8 A. No.
9 Q. Number 6, Produce all documents and/or ESI
10 that -- before we get -- back this up.
11 Are you saying that you had -- I just want
12 to make sure I'm clear. You had nothing to do with
13 the notice of claim against the Commonwealth?
14 A. It's not my notice of claim, so I don't
15 know what the notice of claim is, I didn't write it.
16 Q. Okay. And with respect to number 2, the
17 letter to the Attorney General, Josh Shapiro, are
18 you saying that you had no involvement in drafting
19 or creating that document?
20 A. Not that I -- no, not that I know -- have
21 any recollection of.
22 Q. Okay. Number 6 asks you to produce all
23 documents and/or ESI that refer or relate to any
24 speaking engagements or events at which Kemble
25 spoke, including but not limited to conferences,

38
1 seminars, symposiums, summits, presentations,

2 demonstrations, and hearings from August 13th to the
3 present; do you see that?
4 A. Yes.
5 Q. Did you have any documents or anything
6 responsive to Mr. Kemble's appearance at different
7 events and speaking?
8 A. I do not have any documents and -- or
9 communications related to that.
10 Q. Number 7 it says, Produce all documents
11 and/or ESI that refer or relate to efforts by you to
12 support and/or arrange or facilitate in any manner
13 any of Kemble's speaking events from August 3rd,
14 2013 to present; do you see that?
15 A. Yes.
16 Q. Do you have any documents or information
17 responsive to that request?
18 A. No, it's repeating the same question,
19 Number 6.
20 Q. Now, did you ever engage in any type of
21 efforts to facilitate Mr. Kemble speaking at any
22 events?
23 A. No, I'm not -- I'm not a booking agent for
24 Mr. Kemble.
25 Q. Okay. So you've never been involved in any

39
1 way in taking him anywhere or arranging for him to

2 speak at any conferences or any events, is that
3 true?
4 A. If Mr. Kemble is traveling with me, we've
5 been good friends for nine years, so -- but he makes
6 his own arrangements in what he does.
7 Q. Numbers [sic] 8 asks to produce all
8 documents and/or ESI that refer or to -- relate to
9 or reflect payments received by you and/or Kemble
10 from any person in connection with Kemble's
11 attendance at any speaking event from August 3rd,
12 2013, to present; do you see that?
13 A. Yes.
14 Q. Did you bring any documents responsive to
15 that?
16 A. I don't have any documents or
17 communications relating to Mr. Kemble's speaking
18 engagements or attendance.
19 Q. But this specifically asks for documents
20 that reflect payments received by you or Kemble from
21 any other person, which includes -- person is
22 defined as organization, group, corporation -- in
23 connection with Kemble's attendance at any speaking
24 events?
25 A. I have no documents or communications

40
1 related to that question.

2 Q. Have you ever received any payments from
3 any person in connection with Mr. Kemble's
4 attendance at any speaking events?
5 A. No.
7 any third person or corporation or company in
8 connection -- having anything to do with Mr. Kemble?
10 you know.
11 THE WITNESS: It's a broad question. I --
12 no, I don't -- I don't have any documents or
13 communications related to that, same answer.
14 BY MS. BARRETTE:
15 Q. My question is a little different. It's
16 not asking if you have them, I'm asking if you have
17 ever received any payments from any third person --
18 other person or corporation or entity in connection
19 with Mr. Kemble?
20 A. No.
22 any companies that you passed through to Mr. Kemble?
23 A. No.
24 Q. Have you ever made any payments to
25 Mr. Kemble?

41
1 A. Clarify what payment means.

2 Q. Exchange of money, did you ever pay
3 Mr. Kemble any money?
4 A. Clarify for what, we've been friends so.
5 Q. For anything?
6 A. Well, not for any speaking engagements or
7 what you're inferring here. We're friends, so
8 I've -- I borrowed money from him and he's borrowed
9 me from me, but nothing related to the question
10 you're asking.
11 Q. So you're saying that you guys are friends,
12 he has lent you money, you have lent him money, is
13 that correct?
14 A. Yes, yes.
15 Q. Okay. Like how often do you lend
16 Mr. Kemble money?
17 A. Oh, I haven't for years, but I've known him
18 for nine years.
19 Q. So you're saying you haven't lent him any
20 money for years?
21 A. I'm saying that as friends for nine years,
22 we have helped each other out in the past.
23 Q. So I'm just trying to get an understanding,
24 how frequently would you help each other out.
25 Well, let me ask you this, how frequently

42
1 have you made payments to Mr. Kemble over the past

2 nine years?
3 A. I did not say I made payments, you're
4 saying that.
5 Q. So you didn't make payments, so you call it
6 helping him out as a friend, correct?
7 A. I call it he's a mechanic, he's worked on
8 my vehicles before, and I have other things that he
9 would need, so that's -- that's friends back and
10 forth, it has nothing to do with payments to each
11 other.
12 Q. Okay. So you said he was your mechanic.
13 So are you saying that you paid him for mechanic
14 services?
15 A. I have before, yes.
16 Q. Is that for a vehicle that you own?
17 A. Yes.
18 Q. Okay. And what other type of money
19 exchange did you do for Mr. Kemble, like what other
20 ways did you give him money?
21 A. No exchange of money, mostly it was --
22 it -- just like anybody else would with a friend if
23 they needed a few extra dollars or for something or
24 if I did, that's friends, and it was not any large
25 sums of anything.

43
1 Q. So when you're saying needed a few extra

2 dollars as friends, are you talking about like we're
3 out together, we go to Dunkin' Donuts, and I buy him
4 a coffee, is that the type of money you're talking
5 about?
6 A. It could be any range, it's what friends
7 would normally do when somebody is in need of money
8 or the other person.
9 Q. But you said it wasn't any type of large
10 amounts, correct?
11 A. Correct.
12 Q. And what do you consider a range of large?
13 A. That's different for everybody else, but it
14 depends on what kind of issue it is, so...
15 Q. Right. You used the word "large," you said
16 it wasn't any large amount. So I'm trying to
17 understand what your meaning of large is?
18 A. To me, large is something over $20, but
19 nothing -- no large amounts of money.
20 Q. Okay. So -- so you've never given
21 Mr. Kemble any large amounts of money, meaning over
22 $20?
23 A. No, I'm saying that's what I consider a
24 large amount of money if your -- money back and
25 forth between friends would be something like that.

44
1 Q. Okay. So I just want to clarify though,

2 you used the word "large," you said there were no
3 large money given to Mr. Kemble. So I'm assuming
4 you're saying no large amounts over $20, is that
5 correct?
6 A. I'm saying that the entire last three or
7 four questions related to me doing the scheduling
8 and paying him, so, no, there was no large amounts,
9 this is money between friends, we're like going out
10 or -- or just needing money back and forth, but not
11 what the previous questions were leading up to into
12 this one.
13 Q. Right. I'm not asking -- I don't want you
14 to confuse this question that I'm asking as being
15 part of any other question, this is separate and
16 aside. I'm trying to figure out if you have ever
17 given Mr. Kemble money and you said not any large
18 amounts.
19 So I asked you to clarify large and you
20 said between friends I would consider over $20
21 large. So I'm trying to understand based on what
22 you said whether you have given Mr. Kemble money for
23 anything in amounts over $20?
24 A. Not that I can recall.
25 Q. And when I say "you," you understand I'm

45
1 meaning you or any, like, company or business you

2 might own, you understand that, correct?
3 A. I thought "you" means me.
4 Q. Oh, well, let me -- let me rephrase then.
5 When I say "you," I mean -- so, for example, do you
6 own any businesses or -- let me ask you that, do you
7 own any other business?
8 A. I'm self-employed, I own my own business,
9 yes.
10 Q. And what's the name of your business?
11 A. Clean Life Systems.
12 Q. What does Clean Life Systems do?
13 A. It's a marketing company, market and sales.
14 Q. Okay. What do you market and sale?
15 A. Water and air treatment systems, I've been
16 with the company for 15 years and had the company
17 itself for 30 years.
18 Q. Okay. So you've been with Clean Life
19 you -- wait, let me --
20 A. Owned.
21 Q. You've owned.
22 A. Clean Life Systems.
23 Q. So you've owned Clean Life Systems for how
24 long?
25 A. 30 years, 1989.

46
1 Q. And what specifically does Clean Life

2 Systems do?
3 A. Sales and marketing of high-tech water and
4 air treatment systems.
5 Q. High-tech air and water systems?
6 A. Mh-hum.
7 Q. The air and water systems, those are -- if
8 I understand correctly, are those manufactured by
9 another company?
10 A. Yes.
11 Q. And what company is that?
12 A. Voloara, V-O-L-O-A-R-A.
13 Q. And since 2000- -- starting back in 2010 to
14 the present, has Clean Life Systems -- has that been
15 its business, marketing and sales of high-tech air
16 and water systems?
17 A. Yes, and I do consulting also. I mean,
18 it's -- basically the business is marketing and
19 sales, so marketing also. Sales, marketing.
20 Q. Okay. When you say consulting, what type
21 of consulting do you do?
22 A. I do consulting for other businesses.
23 I'm -- I'm allowed to franchise my business, so I
24 consult with others on their businesses.
25 Q. That consulting, is it in connection with

47
1 the high-tech air and water systems?

2 A. It's comprehensive, I do consulting for
3 anybody that needs it.
4 Q. Okay. Can you give me some examples of the
5 consulting that you do through Clean Life Systems?
6 A. Some examples of consulting?
7 Q. Mh-hum.
8 A. I can do anything from educational outreach
9 on issues that are important for people, to doing --
10 I do seminars where I set up the equipment and show
11 people how to market it. So it's any number of
12 consulting and educational issues.
13 Q. Okay. So let me break that down. So you
14 say seminars where you set up the equipment, are you
15 talking about the high-tech air and water systems?
16 A. That's -- yeah, that's something. Yes.
17 Q. Are there other things that you set up?
18 A. Well, that's the equipment that I market,
19 so that's what I do.
20 Q. Okay. Now, you said educational outreach?
21 A. Yes.
22 Q. What type of educational outreach do you
23 do?
24 A. On any number of subjects.
25 Q. Well, let's walk through them. What

48
1 have -- since 2010, as -- in your capacity with

2 Clean Life Systems, what type of education and
3 outreach have you -- consulting have you done?
4 A. Any -- I've had firsthand experience after
5 living up in Pennsylvania on issues of private
6 property issues, pipeline installation issues,
7 private property issues, so I've been asked to speak
8 on those before.
9 Q. So you said you've been asked to speak on
10 private property issues?
11 A. Yes.
12 Q. And you've been asked to speak on pipeline
13 issues?
14 A. Yes.
15 Q. And are you saying that you do consulting
16 in connection with the pipeline issue or private
17 property issue?
18 A. I speak -- I'm self-employed, so I can go
19 speak on the matters wherever I want to go and speak
20 on the matters.
21 Q. I understand. Are you -- are there other
22 things that you -- so you started with you said
23 issues related to private property and pipelines,
24 correct, as part of your education outreach?
25 A. Yes.

49
1 Q. Are there other things that you have done

2 as a consultant -- other educational outreach things
3 you have done?
4 A. That's normally what I do, it's private
5 property issues.
6 Q. What about water contamination issues?
7 A. It can include that, but I'm not -- my
8 water was -- I had a problem from a pipeline
9 installation, so -- in my yard. So that's what I
10 talk about on water contamination issues for myself.
11 Q. Any other -- so that's the only time you
12 talk about water contamination issues as a paid
13 consultant is in connection with your pipeline
14 issues?
15 A. I didn't say other people pay me, I said I
16 go and do that. I'm self-employed, so I'm able to
17 go and speak wherever I want to, whenever I want to,
18 to whomever I want to, and I did not say that other
19 people pay me or do not pay me, that's my business.
20 So it's on other issues -- well, that's the issues,
21 private property, pipeline installation, or problems
22 associated with. And, yes, in some cases water
23 quality issues and it's mostly related to pipeline
24 installation.
25 Q. Okay. So I might have been confused and I

50
1 apologize. I thought when you said you were doing

2 educational outreach as a consultant for Clean Life
3 Systems you were being paid for that?
4 A. Well, it's my business, so if I want to
5 go -- if I'm asked to go somewhere and I can do it
6 by getting some compensation or going just do it
7 because it's local and I want to go educate people,
8 so that's all part of my -- on the business side.
9 Q. Okay. So let me make sure I understand
10 this. Well, let me just clarify. Are you paid to
11 do consulting on these issues of private property
12 and pipeline -- I'll just for clarification purposes
13 I'll call them environmental issues.
14 Are you paid by -- is Clean Life Systems
15 paid to do that type of consulting?
16 MR. POSEY: I'm going to just insert an
17 objection to this entire line of questioning as I
18 don't see how it deals with the complaint and the
19 issue. You can answer if you know.
20 THE WITNESS: It -- I don't see the
21 relevance either. I'm not -- it's my business and
22 I'm self-employed so I can do what I want, where I
23 want, when I want to, so...
24 BY MS. BARRETTE:
25 Q. Well, I totally -- and I totally understand

51
1 that. I'm asking a very simple question.

2 Is Clean Life Systems paid to do consulting
3 on what we've discussed is environmental issues,
4 pipeline issues, water quality issues, water
5 contamination from pipelines?
6 A. I'm not sure what the relevance it has to
7 the case that I'm being brought in here for.
8 Q. It will become relevant pretty clear so I'm
9 going to ask you the question again.
10 Does Clean Life Systems receive
11 compensation for doing what you've described as
12 consulting on pipeline water quality issues or
13 private property issues?
14 A. I have been before, yes.
15 Q. Are you currently paid to do that type of
16 consulting work?
17 A. (No response.)
18 Q. When I say "you," I'm referring to Clean
19 Life Systems.
20 A. I have been, yes.
21 Q. Are you currently paid to do that type of
22 consulting work?
23 A. Yes.
24 Q. And who pays you to do that type of
25 consulting work?

52
1 MR. POSEY: Same objection. You can answer

2 if you know.
3 THE WITNESS: Catskill Mountainkeepers.
4 BY MS. BARRETTE:
5 Q. Okay. Catskill Mountainkeeper, who else?
6 A. Catskill Mountainkeepers is the -- that's
7 on the -- mostly that's on the pipeline issues and
8 the water quality issues from pipeline installation.
9 Q. Who else pays Clean Life Systems for
10 consulting on anything that let's call environmental
11 issues?
12 A. Well pay -- nobody else pays me, but...
13 (Phone ringing.)
14 MS. BARRETTE: Is that me? I apologize.
15 BY MS. BARRETTE:
16 Q. Okay. So you're saying that nobody else
17 other than Catskill Mountainkeeper pays Clean Life
18 Systems for any type of consulting?
19 A. Right.
20 Q. Do they -- do any other organization
21 groups -- do any other groups like Catskill
22 Mountainkeeper pay you for anything -- pay Clean
23 Life Systems for anything?
24 A. No.
25 Q. Now, when I say -- let's start back,

53
1 starting back in 2010. When did Catskill

2 Mountainkeeper start making payments to Clean Life
3 Systems?
4 A. Not until recently. I have a pipeline
5 right-of-way and a gas lease, so I've always had my
6 own money plus my business, so...
7 Q. Okay. When you say recently -- Catskill
8 Mountainkeeper hasn't started paying you until
9 recently, how recently was that?
10 A. In the last few years.
11 Q. Let's -- were they paying -- was Catskill
12 Mountainkeeper paying Clean Life System in 2016?
13 A. Yes.
14 Q. Was Catskill Mountainkeeper paying Clean
15 Life Systems in 2015?
16 A. No.
17 Q. Do you have any -- do you have a contract
18 with Catskill Mountainkeeper?
19 A. No.
20 Q. Does Clean Life Services have a contract
21 with Mountainkeeper?
22 A. I don't know who Clean Life Services is.
23 Q. Oh, Clean Life Systems, I'm sorry.
24 A. No.
25 Q. Other than Clean Life Systems, do you own

54
1 any other business?

2 A. No.
3 Q. Does Clean Life Systems have any type of
4 contract with any other organization at all?
5 A. No.
6 Q. When Catskill Mountainkeeper pays Clean
7 Life Systems, how do they -- how does -- how do they
8 pay you? How do they pay the company?
9 A. How do they pay me?
10 Q. Yes.
11 A. They send a check.
12 Q. And this is in addition to the business
13 that Clean Life Systems does with respect to the
14 high-tech air and water, correct?
15 A. It's separate but it goes to the same --
16 it's part of my consulting sales and marketing.
17 Q. Okay. Now, when you do the consulting and
18 sales and marketing with respect to the high-tech
19 air and water systems, how is Clean Life Systems
20 paid in connection with that type of work?
21 A. It's direct sales and also wholesale
22 distribution sale -- money. So I'm able to
23 franchise so it's both retail and wholesale.
24 Q. So if I understand then correctly, you
25 would be paid a commission from -- if I understand

55
1 what you're saying, you're paid a commission from

2 the company that you're actually saling and
3 marketing for?
4 A. Correct.
5 Q. And then you may also be paid directly from
6 individuals for the purchase of the equipment that
7 you're marketing?
8 A. Correct. It's retail and wholesale.
9 Q. Now, if an individual is paying Clean Life
10 Systems, for example, a private purchase of that --
11 like a retail purchase of it from Clean Life
12 Systems, how would they pay you?
13 A. They pay me with any form of payment, cash,
14 check, charge.
15 Q. Okay. So you have people who pay cash for
16 that -- the equipment?
17 A. Oh, yes.
18 Q. Okay. And how much -- how much does the
19 equipment cost?
20 A. It's a range from $60 to a few thousand
21 dollars, it's a multiple line.
22 Q. Now, do you have people -- have people --
23 individuals paid cash for like thousands -- thousand
24 dollar pieces of equipment?
25 A. Oh, yes.

56
1 Q. So people have paid your company cash,

2 thousands in cash for a piece of equipment?
3 A. Yes, on -- my water system is $2,200
4 retail, so yes.
5 Q. What type of accounting system does Clean
6 Life Systems use?
8 you know.
9 THE WITNESS: What type of accounting
10 system?
11 BY MS. BARRETTE:
12 Q. Mh-hum.
13 A. Just my own, I just keep track of the sales
14 and do it monthly and then report it on my financial
15 statement.
16 Q. Okay. And so do you use QuickBooks?
17 A. For -- no, I don't -- I just -- I'm an old
18 school, so I just have a ledger and write it out and
19 then fill out the papers when I need to send it to
20 whoever needs to see them.
21 Q. Do you keep copies of your -- your ledgers?
22 A. Do I keep copies?
23 Q. Mh-hum.
24 A. They're usually 3 by 5 -- just 3 by 5
25 cards, so...

57
1 Q. They're usually through what?

2 A. Just on -- written out on paper and then
3 converted to documents if I have to do something for
4 state or federal. So I don't use -- I don't use an
5 electronic system to put the information into.
6 Q. Okay. So if I understand you correctly
7 then, you just keep a written record, for example,
8 if Attorney Posey wanted to buy a system from you,
9 you would just -- would you document like who
10 purchased the system and how much it costs --
11 A. Yes, normally.
12 Q. -- or what would -- what would you
13 document?
14 A. Yes.
15 Q. And how long do you keep those records of
16 who purchased the equipment?
17 A. How long? As long as necessary for income
18 tax purposes and...
19 Q. Now, if someone is going to purchase a --
20 for example, if somebody is going to purchase a
21 $2,200 water system from Clean Life Systems retail
22 and they are going to pay you cash for that, what
23 type of documents do you have to show who purchased
24 the equipment, what equipment you've supplied, that
25 type of thing? What type of records do you have?

58
1 A. I'm wondering what this line of questioning

2 has to do with Mr. Kemble's lawsuit. I'm kind of
3 thinking about it right now.
4 Q. Well, I'm sure you are. And I'm going
5 to -- so I'm going to ask you again. When you have
6 a $2,200, for example, cash sale for a piece of
7 equipment, and you get the cash in, what type of
8 records do you have to show what type of equipment
9 someone bought and where that equipment went?
10 A. I have receipts for anybody that buys
11 anything.
12 Q. When you say you have a receipt, what do
13 you mean?
14 A. A receipt if they purchase something from
15 me.
16 Q. And does that include a receipt if they
17 purchase it in cash?
18 A. It would.
19 Q. Excuse me?
20 A. It would normally, yes.
21 Q. And do you keep copies of your receipts?
22 A. Normally, yes.
23 Q. And then if I understand you correctly, if
24 someone purchased a system from you -- from what I'm
25 gathering the way this is sold, then you would have

59
1 to purchase it from the -- Voloara, correct?

2 A. Correct.
3 Q. And would Clean Life System then be
4 purchasing it from Voloara?
5 A. Normally, yes.
6 Q. So there would be records then if you
7 received, say, a cash inflow of, you know, $2,200
8 for a piece of equipment, then there should be a
9 corresponding outflow of money to Voloara for that
10 piece of equipment for the person, correct?
11 A. Normally, yes.
12 Q. When you say "normally," are there cases
13 where there would not be?
14 A. That would be normal procedure, so yes.
15 Q. Did you provide any of the high-tech air
16 and water quality systems to anybody in Dimock?
17 A. Did I provide?
18 Q. Yes.
19 A. One -- one person.
20 Q. Who is that?
21 A. Mr. Kemble.
22 Q. Did he pay you for that?
23 A. No.
24 Q. Or did he pay Clean Life System for that?
25 A. No.

60
1 Q. So you provided that for free?

2 A. No, just in trade for.
3 Q. In trade for what?
4 A. Services and also a jacuzzi that he has
5 there that he's not using.
6 Q. You say in trade for services, for what
7 type of services?
8 A. Well, no, I mean if -- this trade for the
9 equipment was for the jacuzzi.
10 Q. Oh, okay. How long ago did you give him
11 that system or did you trade that system for him?
12 A. A couple of years ago.
13 Q. Was it in 2015?
14 A. No, probably '14.
15 Q. So since 2014, Mr. Kemble has had a
16 high-tech air and quality -- water quality treatment
17 system in his home, correct?
18 A. Yes.
19 Q. And is the high-tech water quality
20 treatment system, is that connected to his well?
21 A. No.
22 Q. And what is it connected to, just the water
23 buffalo?
24 A. That your company installed, yes, back in
25 2010.

61
1 Q. And the high-tech air system, that -- what

2 does that do?
3 A. It basically knocks down any particulate in
4 the air, cure odors, does the whole building.
5 Q. Back to the cash payments, how frequently
6 do people pay Clean Life Systems in cash?
7 A. How frequently? It depends on -- it's hit
8 or miss whether they're using credit cards, write a
9 check or cash. So it just depends on the show or
10 event I'm doing.
11 Q. Well, let me ask you this, is it more
12 common that people are paying with check or credit
13 card than they are with cash?
14 A. It's probably both. I mean, check less,
15 either cash or card.
16 Q. Okay. Have you ever received any -- has
17 Clean Life Systems ever received cash from any
18 organizations like Catskill Mountainkeeper?
19 A. Cash, no.
20 Q. I'd like to go back to the subpoena. I
21 think we discussed Number 9, you said you didn't
22 have any documents reflecting communications from
23 Mr. Kemble, correct?
24 A. No, I -- (inaudible.)
25 THE REPORTER: I didn't hear the answer.

62
1 THE WITNESS: Correct.

2 BY MS. BARRETTE:
3 Q. And Number 10, you had no documents or ESI
4 that refer or relate to communications between you
5 and any person concerning Kemble's participation in
6 speaking engagements, correct?
7 A. Correct.
8 Q. So just to make sure I'm clear, you don't
9 have any e-mails or any correspondence between you
10 and anybody, say, like Emily Wurth talking about
11 Mr. Kemble speaking anywhere?
12 A. No.
13 Q. No communications between you and anybody,
14 like Jan Lamoss (phonetic) or Hope For Peace about
15 Mr. Kemble speaking anywhere?
16 A. I don't know who the second person was you
17 said, but no, don't have any documentation or
18 communications.
19 Q. So Number 11 asks you to produce documents
20 or ESI sufficient to show your sources of income for
21 the years 2013 through the present, do you see that?
22 A. Yes.
24 that request?
25 A. Yes, I did.

63
1 Q. Okay. Number 12, and we're going to get to

2 that, but I want to get through -- see what you've
3 brought so far. Number 12 asks you to produce all
4 documents and/or ESI that refer or relate to Cabot
5 or GDS including but not limited to documents and/or
6 ESI relating to your efforts to generate litigation
7 against Cabot or GDS; do you see that?
8 A. Yes.
9 Q. Do you have any documents responsive to
10 that?
11 A. I didn't find any documents or
12 communication in my possession.
13 Q. Now, you have in the past undergone efforts
14 to try to generate litigation against Cabot,
15 correct?
16 A. No.
17 Q. You haven't done anything to try to get any
18 litigation or have anybody bring litigation against
19 Cabot?
20 A. No.
21 MR. POSEY: Objection. Asked and answered.
22 BY MS. BARRETTE:
23 Q. Is that no?
24 A. Restating the question is not going to
25 change the answer, it's no.

64
1 BY MS. BARRETTE:
2 Q. I just want to make sure I'm clear that --
3 A. It is no.
4 Q. Okay. Number 13 asks to produce all
5 documents and/or ESI between you and any person that
6 refer or relate to the lawyer defendants' efforts to
7 generate litigation against Cabot or GDS; do you see
8 that?
9 A. Yeah.
10 Q. And were you involved in any effort -- or
11 do you have any documents responsive to that
12 request?
13 A. I do not.
14 Q. Number 14 asks you to produce any and all
15 documents and/or ESI that refer to, relate to, or
16 regarding Energy in Denial; do you see that?
17 A. Yeah.
19 that request?
20 A. I did not. I don't have any in my
21 possession.
22 Q. And what's Energy in Denial?
23 A. It's a parody site that Attorney Speer set
24 up that I have had nothing to do with since the day
25 I signed a piece of paper that I want -- as you

65
1 probably are aware, if you Google my name on Energy

2 in Depth or Natural Gas Now there is a lot of your
3 supporters that don't have a very high opinion of
4 me. So this is -- Energy in Denial is a parody site
5 that was going to be set up to -- in response to
6 that.
7 Q. When you say "your supporters," you don't
8 mean like me, Amy Barrette, you're referring to
9 Cabot?
10 A. Cabot, yes.
11 Q. Okay. So you said Energy in Denial is a
12 parody that was set up by Charlie Speer?
13 A. Yes.
14 Q. And why was -- do you know why it was set
15 up?
16 A. In response -- well, not just myself but to
17 others that were being -- basically still are if you
18 look at any of the sites that support your company,
19 still attacked every single day. You can go in
20 there today and probably find a story about me from
21 just the last few days. So I'm just curious whether
22 they're getting paid by Cabot themselves because
23 they seem to be supporting them quite a bit.
24 So this was a parody website and an
25 organization that Mr. Speer set up. He did

66
1 everything. And to my knowledge it's -- he's got

2 all the information on that, you can ask him.
3 Q. So tell me how do you know that Mr. Speer
4 set it up?
5 A. How do I know? Because I signed a piece of
6 paper that he set it up. He was putting it -- he
7 set it up, I signed a piece of paper that said I
8 would be a part of it, then it disappeared and I've
9 never seen anything from it, never done anything
10 with it. So you'll have to ask Mr. Speer what
11 happened with that and what it is because I have no
12 idea.
13 Q. Well, who asked you to be a part of setting
14 it up?
15 A. Who? Mr. Speer did.
16 Q. And when was that?
17 A. That was in 2013, I believe. I don't -- I
18 don't have any of the documents, they took the one
19 document I signed and I've never seen anything from
20 it since.
21 Q. So can you explain for me like were you
22 meeting with Mr. Speer, how did this come about that
23 he said, Hey, I want to set up a parody website and
24 will you sign this?
25 A. Mr. Speer -- I retained him for problems

67
1 with my property, so anything to do with that would

2 be attorney-client as far as retaining him for my
3 issues and so that's how I had -- had known him.
4 Q. And I'm not asking about any communications
5 that you had with Mr. Speer or Attorney Speer about
6 legal representation that he did for you. I'm
7 asking in -- can you -- so that's how you met him,
8 you retained him in connection with property issues,
9 correct?
10 A. Correct.
11 Q. When you say property, are you referring to
12 the -- the property that you inherited?
13 A. Property that I own that I bought from the
14 rest of my family, yes.
15 Q. And what property is that?
16 A. That is the house homestead property at
17 1527 Silver Creek Road in Silver Lake township.
18 Q. Okay. So you were having issues with that
19 and that's when you retained Mr. Speer for that, you
20 said around 2013, correct?
21 A. Yeah, '11 was the house -- '12 -- late '12,
22 early '13.
23 Q. And then at some point unrelated to your --
24 your property, Mr. Speer asked you to participate in
25 setting up a parody website?

68
1 MR. DOUGHERTY: Objection. He stated he

2 was represented, he had retained Mr. Speer and was
3 representing him at the time. There is no
4 distinction whether or not related or unrelated to
5 the property he's alleging Mr. Speer was his counsel
6 at the time so any communications are privileged.
7 MS. BARRETTE: Attorney-client
8 communications refer to communications between a
9 person and their counsel that are either made for
10 the purpose of receiving legal advice or for the
11 purpose of giving legal advice.
12 MR. DOUGHERTY: His testimony was that
13 Energy in Denial was set up in conjunction with his
14 retaining Mr. Speer regarding the issues he had on
15 his property.
16 MS. BARRETTE: No, I believe he
17 testified -- the record will show he testified that
18 he said he met Mr. Speer when he had retained him
19 for his property. That's how he originally met him.
20 MR. DOUGHERTY: Right. So he was retained,
21 he was his attorney, and in that capacity they set
22 up Energy in Denial, that's what his testimony was.
23 So that any communications regarding that are
24 attorney-client privileged.
25 BY MS. BARRETTE:

69
1 Q. Was Energy in Denial set up -- was

2 Mr. Speer providing you with legal advice in
3 connection with setting up Energy in Denial?
4 A. Legal advice, no, it was a parody site,
5 that's what my understanding was going to be because
6 I was the target of a massive amount of what I would
7 call support from the people that are pro drill and
8 pro pipeline, so it was done to counteract that, I
9 guess, and that's what it was supposed to be set up
10 for by -- I don't know anything beyond that. You
11 have to ask Mr. Speer.
12 Q. What about the Energy in Denial Twitter
13 account?
14 A. I don't even know how to -- I don't even
15 have Twitter, so I have no idea about that.
16 Q. Okay. So you didn't set up the Energy in
17 Denial?
18 A. I did not set up any part of it, not one
19 bit.
20 Q. And the frack -- did Mr. Speer tell you
21 that he was setting up an Energy in Denial Twitter
22 account?
23 MR. DOUGHERTY: Objection. Attorney-client
24 privilege as to what Mr. Speer told him. He
25 indicated he was represented at the time.

70
1 BY MS. BARRETTE:
2 Q. Mr. Stevens, any attorney -- let me ask you
3 this. You said that the whole Energy in Denial
4 thing was not in connection with receiving any type
5 of legal advice from Mr. Speer, correct?
6 A. It was done at the time that he was looking
7 at representing me for the damage to my property, so
8 I don't -- I don't know how to discern between the
9 two, if I'm retained -- retained him for one thing
10 and we're doing something else at the same time, I
11 have no idea, you'll have to ask his -- his counsel.
12 Q. Okay. Did you get legal advice in
13 connection with the Energy in Denial parody site?
14 A. Legal advice? I don't know. I mean, I
15 don't know. It was being set up as a corporation,
16 that's what it looked like it was being set up as,
17 but I don't know if that constitutes legal advice,
18 you'll have to ask his counsel.
19 Q. And so is -- did you have any discussions
20 with Attorney Speer as to -- let me back this up.
21 You -- I think you said your understanding
22 was that the Energy in Denial website was being set
23 up to defend you against what you perceived as
24 attacks by pro industry people against you?
25 A. And others, yes, not just me, but there was

71
1 many others in -- you can look at any of those sites

2 today if you want to, they're -- they've got quite a
3 few people they don't like because we have a
4 difference of opinion.
5 Q. Were you involved at all with the setting
6 up the Fracking Senseless website?
7 A. Not at all, I don't even know how to set up
8 a website.
9 Q. And how was it that you initially met
10 Mr. Speer to have -- to retain him as your counsel?
11 A. He came into the area in late 2011, it
12 might have been earlier than that, early 2011, I'm
13 just trying to remember exactly when, but came into
14 the area and on referral from some -- one of the
15 neighbors, I'm not sure who, as somebody who was
16 meeting with people that -- that had questions about
17 issues that were happening in the area.
18 Q. And when you first met him, was it at a
19 group meeting or how was it?
20 A. It was a group meeting, yes.
21 Q. Okay. And what was discussed at that group
22 meeting?
23 A. If it was awhile ago, I'm just trying to
24 remember exactly what -- I don't know exactly what
25 was discussed, but it was just generally about any

72
1 problems associated with oil and gas drilling

2 activity in the area and whether people were having
3 negative -- I mean, that's generalizing it, I don't
4 know exactly, it's been six years ago I think.
5 Q. Okay. And were either -- was Attorney
6 Ciarimboli present for those meetings?
7 A. No, I think it was Charlie and the other
8 attorney from Atlanta and I don't remember his name,
9 but not Mr. Ciarimboli -- Ciarimboli or Fellerman or
10 Boylan.
11 Q. Okay. Now, aside from the issues with your
12 property pipeline, that Silver Lake property, did
13 Mr. Speer represent you in any other capacity?
14 A. Mr. Speer did not, but Fellerman &
15 Ciarimboli did.
16 Q. And what did they represent -- how did --
17 when did they represent you?
18 A. The water hydrant.
19 Q. Now, at the time when Mr. Speer was
20 representing you in 2013, did he tell you that he
21 was representing Mr. Kemble?
22 MR. DOUGHERTY: Objection. Attorney-client
23 privilege. You just asked him at the time Mr. Speer
24 was representing him did he tell you.
25 MS. BARRETTE: Exactly. Whether he's --

73
1 MR. DOUGHERTY: That's classic

2 attorney-client privilege.
3 MS. BARRETTE: No. Classic
4 attorney-client -- attorney-client privilege has
5 a -- has a very specific definition.
6 MR. DOUGHERTY: I understand what
7 attorney-client privilege is.
8 MS. BARRETTE: Yes, it's communications for
9 the purpose of receiving legal advice. Whether he
10 was told he was representing Mr. Kemble is not
11 attorney-client privilege.
12 MR. DOUGHERTY: It certainly is.
13 BY MS. BARRETTE:
14 Q. Let me ask you this --
15 MR. POSEY: I agree. I'm going to instruct
16 you not to answer any questions about what any of
17 your attorneys told you during the course of their
18 representation.
19 BY MS. BARRETTE:
20 Q. Did you know that Attorney Speer was
21 representing Mr. Kemble?
22 A. I believe Mr. Speer was representing me
23 before anybody else. I was one of the first people.
24 The water hydrant issue was from 2000 and late 2011
25 and early 2012, that's when I was represented. So I

74
1 think I was one of the first clients he had in the

2 whole area, but that was the water hydrant issue.
3 Q. Okay. Did there come a time when you
4 learned that Mr. Speer was representing Mr. Kemble?
5 A. He was no longer associated with me at that
6 point, so I have no idea what the -- what that
7 transition time was. He did the water hydrant with
8 me and then I asked him to look at my property issue
9 which didn't go anywhere, so that was the end of
10 that.
11 Q. Did there come a time though that you
12 learned that he was representing Mr. Kemble?
13 A. Eventually in the future, but, yeah, I
14 don't -- there was a -- there was a transitionary
15 time, but I don't know that either one of them were
16 anywhere from when I stopped and when he started
17 with him, but I don't know when that time frame was.
18 Q. Did you refer Mr. Kemble to Mr. Speer?
19 A. No.
20 Q. And at some point you learned that
21 Mr. Speer was representing Mr. Kemble, correct?
22 A. Yes.
23 Q. Okay. And when was that?
24 A. I'm not sure, 2013, 2014, maybe even into
25 '14.

75
1 Q. So paragraphs Number 15 and 18 through the

2 subpoena, those refer all to things like Fracking
3 Senseless, the Fracking Senseless YouTube, and if I
4 understand your testimony you hadn't -- don't know
5 anything about --
6 A. Ask Mr. Speer, I have no knowledge of
7 anything that went beyond me signing a piece of
8 paper and it went away and nothing else.
9 Q. Okay. So Number 19 talks about Produce all
10 documents and/or ESI that refer or relate to the
11 Kemble 2009 action; do you see that?
12 A. Yeah.
14 that request?
15 A. I didn't find any documents that -- or
16 communications that relate to that in my...
17 Q. Okay. Number 20, Produce all documents or
18 ESI that refer or relate to the Kemble 2017 action.
19 Did you have any documents that refer or relate to
20 that action?
21 A. I do not, nor was I involved in it.
22 Q. Okay. Did Mr. Kemble tell you he was
23 bringing a second litigation against Cabot?
24 A. I didn't hear anything again until I read
25 it in the newspaper, honestly that's what -- the

76
1 first I saw was a story in the newspaper about it,

2 but I didn't hear about an action being done.
3 Q. Okay. So prior to reading about it in the
4 newspaper you had no idea that Mr. Kemble was suing
5 Cabot again in 2017?
6 A. I had no knowledge that that was being
7 filed and I found out in the newspaper like I just
8 stated.
9 Q. Now, you said you had no knowledge that it
10 was being filed, did you have knowledge that
11 Mr. Kemble was considering another litigation?
12 A. I have -- I don't have any recollection of
13 Mr. Kemble telling me anything about that. So if
14 that was happening, it was being done without my
15 knowledge.
16 Q. Number 21, paragraph 21 says, Produce all
17 documents or ESI that refer or relate to the past or
18 present condition of Kemble's water supply including
19 but not limited to water sample results and letters
20 interpreting water sample results; do you see that?
21 A. Yes.
23 that request?
24 A. I brought some, including the one that you
25 saw when you were -- saw me in Philadelphia.

77
1 Q. Okay. And that's when you were at the

2 Marcellus Shale Coalition meeting, correct? It was
3 Marcellus Shale Insight?
4 A. Yeah, in Philadelphia, yes, when you
5 represented yourself as a car salesperson to me.
6 Q. And you were there were with Mr. Kemble,
7 correct?
8 A. With a large group of people. Mr. Kemble
9 happened to be one of them.
10 Q. And the test results you actually had were
11 Mr. Kemble's, correct?
12 A. Yes.
13 Q. So any documents that you have that you
14 brought, were those received from Mr. Kemble?
15 A. No, most everything I brought you is public
16 record documents that I have, like the COAs
17 (phonetic) and the COSAs (phonetic) and the letters,
18 they're all from either DEP or your vice president
19 of your company, I -- I carry things that are
20 basically public record, that way, you know, I can't
21 be attacked like I am now for doing something I
22 didn't do.
23 Q. But for the -- with respect to the water
24 test results, did you ever receive any water test
25 results from Mr. Kemble?

78
1 A. Yes, well before any other -- well before

2 2012, so I have -- I got results from a couple of
3 different people there between the 10 -- 2010, 2012
4 range of time. I needed to know what was happening
5 there myself before I made any decisions on whether
6 there's a problem or not, so I asked for documented
7 evidence just like you would.
8 Q. And it -- in other words, you asked for
9 documentary evidence because if you were going to be
10 making statements about something you wanted them to
11 be accurate, correct?
12 A. Because I didn't believe it. Because I
13 was -- I signed a lease and let them put a pipeline
14 across my property so I had to prove -- they had to
15 prove -- I had to be proven that there was a
16 problem. So, yes, I required them to show me things
17 and that was done in the time between 2010 and 2012.
18 Q. And again, you would want to see things,
19 you would want to see proof of it before you made
20 statements because you would want your statements to
21 be accurate and truthful, correct?
22 A. Yes, yes, as much as possible.
23 Q. Do you know what benzene is?
24 A. What benzene is, yes.
25 Q. What's benzene?

79
1 A. It's a highly cancer causing chemical that

2 can come out -- it can be in water or it can be out
3 in the air in exhaust from a compressor station
4 or -- or a C&G filling station.
5 Q. And what about toluene, do you know what
6 that is?
7 A. Toluene is also -- it's part of BTEX,
8 B-T-E-X, benzene, toluene, xylene, ethylbenzene I
9 think is the other one, I'm not really positive, I'm
10 not a chemist, but --
11 Q. But also considered cancer causing,
12 correct?
13 A. BTEXs are highly volatile.
14 Q. And is my understanding correct, you would
15 not want to drink water that had benzene or toluene
16 in it, correct?
17 A. Correct.
18 Q. And you would not consider water that had
19 benzene or toluene in it safe to drink, correct?
20 A. I don't --
21 MR. POSEY: I'm going to object, you can
22 answer if you know.
23 THE WITNESS: I have no idea, but I
24 wouldn't -- I wouldn't drink it.
25 BY MS. BARRETTE:

80
1 Q. And would you consider water that had

2 benzene or toluene in it to be contaminated?
4 you know.
5 THE WITNESS: If it didn't preexist in it,
6 then I guess that's a contaminant in water, yes,
7 from what I've read.
8 BY MS. BARRETTE:
9 Q. Well, benzene and toluene don't naturally
10 occur in water, correct?
11 A. I -- I'm guessing that's the case, I don't
12 seem to have any over on the other side of town from
13 there, so I guess it doesn't naturally occur in
14 water.
15 Q. Now, Number 22, it asks you to produce all
16 documents or ESI that reflect or relate to the
17 settlement; do you see that?
18 A. Yes. Clarify please, I don't know what
19 settlement you're talking about.
20 Q. Well, it's defined up front in the
21 subpoena, that's the settlement in 2012 between
22 Mr. Kemble and Cabot Oil & Gas. Did you ever --
23 A. I didn't -- I don't recall finding any
24 documents or communications related to that
25 settlement. I've never -- is that the one that's

81
1 redacted and sealed perhaps?

2 Q. Did -- did you ever see a copy of the
3 settlement between Cabot --
4 A. No.
5 Q. -- and Mr. Kemble?
6 A. I have not.
7 Q. Mr. Kemble never showed it to you?
8 A. Nothing, not that I recall.
9 Q. Did Mr. Kemble ever discuss it with you?
10 A. I know he was under some form of agreement
11 because most of his neighbors are under the same or
12 the same type of agreement.
13 Q. But that's -- my question is did Mr. Kemble
14 ever discuss his settlement agreement with you?
15 A. Not aspects, just that I'm guessing that
16 he -- well, I -- I don't know what it was, but I
17 know that many other people were on one before he
18 was, because that's when people stopped talking in
19 the area.
20 Q. Right.
21 A. You know that as well as I do.
22 Q. Right. My question is did Mr. Kemble ever
23 discuss his settlement agreement with you?
24 A. I don't understand the question. The --
25 what it says exactly or just that there is one?

82
1 Q. We'll start with first that there is one.

2 A. I was aware that he was under a settlement
3 agreement, yes.
4 Q. And did you ever ask him what was in the
5 settlement agreement?
6 A. No, it was just like everybody else,
7 they're not allowed to disclose it, I'm imagining.
8 I've never signed one, but I know that you're not
9 supposed to disclose any parts of it.
10 Q. So you and Mr. Kemble are good friends and
11 you've never asked him, Hey, what -- what's in your
14 you know.
15 THE WITNESS: I -- if I asked him, he
16 wasn't going to tell me, I know that. I have not
17 seen it or have not been given information on it.
18 BY MS. BARRETTE:
19 Q. Okay. So I have videotape.
20 A. Okay.
21 Q. That we can pull up.
22 A. Okay.
23 Q. Where Mr. Kemble was actually -- it's when
24 ITV was at Mr. Kemble's home, you were there
25 discussing with Mr. Kemble the settlement agreement

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1 with the reporters. Now I'm going to ask you again,

2 did you ever have any conversations with Mr. Kemble
3 about his settlement agreement?
4 MR. POSEY: I'm going to object. If you
5 want to show him the video, go ahead. He said he
6 doesn't know.
7 THE WITNESS: When -- what date was this?
8 How many years ago was that?
9 MS. BARRETTE: 2000 -- what was it, '14?
10 What was the date of the video?
11 THE WITNESS: So five years ago.
12 MR. PILSNER: September 11, 2013.
13 THE WITNESS: I don't recall.
14 MS. BARRETTE: When was is?
15 MR. PILSNER: September 11, 2013.
16 BY MS. BARRETTE:
17 Q. September 11th of 2013, do you remember ITV
18 being at Mr. Kemble's home?
19 A. No, that's six years ago. I've got a
20 fairly decent memory, but six years ago, no.
21 Q. You don't remember meeting with reporters
22 at Mr. Kemble's home?
23 A. I've done that a few times.
24 Q. Let me ask you this, did you ever have an
25 occasion to have to seek medical attention as a

84
1 result of being near Mr. Kemble's water?

2 A. Not medical attention, no.
3 Q. Did you ever have an occasion where you
4 started to go blind in connection --
5 A. I have had a reaction to the water before
6 that was eye -- eye watering, yes.
7 Q. No, have you ever started to go blind as a
8 result of --
9 A. I could not see because my eyes were
10 watering. So if that's what you're asking me, yes,
11 that's --
12 Q. Let me finish my question so we can get it
13 on the record.
14 A. Okay.
15 Q. Have you ever had an occasion where you
16 started to go blind from smelling Mr. Kemble's
17 water?
19 you know.
20 THE WITNESS: I don't know what blind
21 means, I could not see if my eyes are watering, but
22 going blind, no. Nothing that was permanent
23 damage -- permanently damaging.
24 BY MS. BARRETTE:
25 Q. So you're saying that you had an occasion

85
1 where you smell Mr. Kemble's water and your eyes --

2 or smelled his water and your eyes started to water?
3 A. Correct.
4 Q. And how long did that eye watering last, do
5 you recall?
6 A. Five or ten minutes.
7 Q. But it didn't damage -- you didn't seek any
8 medical attention?
9 A. No.
10 Q. Okay. So back to the settlement agreement,
11 are you aware that the settlement agreement
12 contained a -- what you refer to as a gag order on
13 Mr. Kemble?
15 THE WITNESS: I have --
16 MR. POSEY: You can answer if you know.
17 THE WITNESS: I have no idea, that -- it's
18 sealed and redacted, so I don't know what it
19 contains, none of my business.
20 BY MS. BARRETTE:
21 Q. Mr. Kemble never told you that he was under
22 an order that he couldn't speak about the settlement
23 or about water quality or anything like that?
24 A. I didn't -- I wasn't present when he signed
25 it, I don't know the aspects of it, so I have no

86
1 knowledge of what he can or can't do and neither

2 does anybody right now because it's redacted and
3 sealed in the courtroom, so I guess I'm here because
4 of that, but I'd sure like to see it, you know, do
5 you have a copy of that for me to see it, I'd like
6 to review it if you -- if you have one.
7 BY MS. BARRETTE:
8 Q. Well, let me ask you, you said that you
9 knew the other neighbors were under a -- what you
10 call a gag order, correct, because they stopped
11 talking, correct?
12 A. Not just that, it was in the newspaper.
13 Q. Okay. So it was in the newspaper that
14 people that settled with Cabot were under a gag
15 order, is that what you're saying?
16 A. Yes, it's been in the paper many times
17 about people that sign settlement agreements.
18 Q. Okay. And you were aware that Mr. Kemble
19 signed a settlement agreement, correct?
20 A. I had heard that he was one of the last
21 people to do it, yes.
22 Q. Okay. And did you ever wonder why he was
23 still able to be out talking if everyone else had a
24 settlement agreement with the gag order?
25 THE WITNESS: I --

87

2 you know.
3 THE WITNESS: I didn't sign it, I don't
4 know what was -- what was in it, so how would I
5 know -- how would I know if somebody was violating
6 something I have no -- I don't have access to.
7 BY MS. BARRETTE:
8 Q. No, I understand that. My question is
9 though, did it ever make you wonder why if everyone
10 else had a gag order they could talk and Mr. Kemble
11 did not, did you ever wonder why he was able --
12 MR. POSEY: Same objection.
13 THE WITNESS: What Mr. Kemble does is none
14 of my business.
15 BY MS. BARRETTE:
16 Q. I understand that. But I'm asking you from
17 a curiosity aspect, didn't you ever wonder to
18 yourself, Well, why does Mr. Kemble, if he has a
19 settlement agreement, why is he able to talk and no
20 one else is?
21 MR. POSEY: Objection. Calls for
22 speculation. You can answer if you know.
23 THE WITNESS: I have no idea why he would
24 or wouldn't do something.
25 BY MS. BARRETTE:

88
1 Q. I'm not asking if you know why he did or

2 didn't. I'm asking did it ever occur to you -- did
3 it ever strike you as odd or occur to you that he
4 was able to talk even though he had entered a
7 THE WITNESS: Never thought about it.
8 BY MS. BARRETTE:
9 Q. Number paragraph 23 in the subpoena it asks
10 for documents or ESI that refer or relate to actions
11 by you to induce, persuade, or encourage Kemble to
12 bring litigation against Cabot or GDS after
13 July 2012; do you see that?
14 A. Yes.
16 that request?
17 A. I do not.
18 Q. 24, Produce documents that refer or relate
19 to actions by the lawyer defendants to induce,
20 persuade, or encourage Kemble to bring this
21 litigation against Cabot or GDS after July 2012; do
22 you have anything responsive to that?
23 A. I do not.
24 Q. Number 25, Produce all documents and/or ESI
25 that refer or relate to Kemble appointing you

89
1 limited power of attorney, including documents that

2 evidence the transfer sale of any of Kemble's
3 property; do you see that?
4 A. Yes, I have a copy of it with me, I'm sure
5 you have one too.
6 Q. So the only thing you have is a copy of the
7 power of attorney?
8 A. Yes. I've never transferred any property
9 or sale of any property that was done because
10 Mr. Kemble was going under anesthesia and surgery,
11 so I was asked as his friend to take care of things
12 if he doesn't come out of it.
13 Q. Number 26 asks you to produce all documents
14 or ESI that refer, relate, or reflect to the
15 purchase of a truck by you and/or Mr. Kemble to
16 deliver water. Did you bring documents responsive
17 to that request?
18 A. I have it handwritten by me because I
19 couldn't find it; but yes, there's a handwritten in
20 there that that's a truck that I purchased and how
21 much money it cost and when it was.
22 Q. Okay. Number 2- -- oh, wait, let me back
23 that up. The truck, there have been conflicting
24 things in the public that I read that either
25 Mr. Kemble purchased the truck or you purchased it

90
1 together or you purchased it, but who actually

2 purchased the truck?
3 A. I wrote a check out to Fernwood Auto Sales,
4 so I purchased the truck.
5 Q. And you have documentation for that
6 correct?
7 A. I just have what I wrote because I could
8 not find it. That was 2011, so we're talking eight
9 years ago.
10 Q. Okay.
11 A. So I've been -- I tried to find it, but I
12 couldn't, so I just handwrote something there for
13 you that said I purchased the truck for 3,500 --
14 $3,500 at that date range, about January of 2012
15 because you asked for it, I wanted to make sure you
16 had something from me to make sure that I affirmed
17 that I purchased it.
18 Q. Okay. And -- all right. And that was
19 January of 2012?
20 A. Yes.
21 Q. Number 27, Produce all documents and/or EIS
22 that refer or relate to or reflect the installation
23 and/or purchase by you of a water hydrant in
24 Montrose, including but not limited to invoices of
25 the cost of water taken from the hydrant and

91
1 documents evidencing payment for the water.

2 Did you bring documents responsive to that
3 request?
4 A. I brought a bill because I have no other
5 documentation that was installed at no charge by
6 Pennsylvania American Water Company twice. So I
7 have no installation charge documents or removal and
8 installation. I have just a copy of a bill to show
9 that I own the hydrant, it's in my name, and it
10 shows there's water use from it.
11 Q. Number 28 says, Produce all documents
12 and/or ESI that refer or relate to or reflect money
13 received through the YouCaring site Last Man
14 Standing in Dimock, Ray Kemble, organized by you
15 including, but not limited to bank or other
16 statements showing the receipt of funds; do you see
17 that?
18 A. Yes.
20 that request?
21 A. I have no information. Once again, my name
22 was put on that, but I didn't set it up, I didn't
23 receive any funds. I have no idea where the funds
24 went to, I believe it was to Mr. Kemble, but I
25 didn't receive anything or set that up, but I know

92
1 my name was put on it.

2 Q. Okay. Do you know who set the YouCaring
3 up?
4 A. I'm not positive -- I don't know for sure.
5 I just know that my name was put on it, but -- and I
6 didn't mind, it's not a big problem, but I have no
7 part of setting it up and I have no -- no knowledge
8 of exactly where the money was going.
9 Q. Okay. Who did you suspect set that up?
10 A. I'm not sure, there were a few people that
11 were talking about doing it, but I don't know who --
12 who exactly set it up.
13 Q. Okay. Who were the people talking about
14 doing it?
15 A. Either Bill Huston or I'm really not sure.
16 There was a couple of people talking about doing it,
17 but I don't have the wherewithal to set up a website
18 so I'm -- or a fundraising site, so I did not do any
19 of it.
20 Q. Okay. You said Bill Huston, you said there
21 were a couple people talking about, who were the
22 other people?
23 A. Yeah, I'm just trying to think now who --
24 there was two or three people that said they were
25 going to do it, I think there was somebody out in

93
1 Upstate New York that was talking about doing it,

2 but I'm -- I'm not positive, but I know that Bill
3 was one of the people considering setting it up for
4 him.
5 Q. Did Emily Wurth talk about setting up a
6 site for Mr. Kemble?
7 A. No, I never had any communication with her
8 about website setup.
9 Q. Did you ever have any communications with
10 Emily Wurth about setting up fundraising for
11 Mr. Kemble?
12 A. I -- I have no recollection or don't have
13 any documentation for that.
14 Q. Did you ask Mr. Kemble, Hey, who -- that
15 has my name on it, it looks like I'm soliciting
16 money for you? Did you ask him who set it up?
17 A. I don't know that's soliciting money if my
18 name is on it. My name is on it just because I was
19 well known in the area to help raise funds, but no
20 I -- I didn't have anything to do with it except for
21 my name is written on it.
22 Q. And, right, your name is on it, on a site
23 that is soliciting donations for someone; and is my
24 understanding correct you didn't ask Mr. Kemble who
25 set that up?

94
1 A. I mean, I think it was Bill, but I can't

2 tell you for sure, so we'd have to ask either
3 Mr. Kemble or somebody else because I'm not exactly
4 sure who set it up.
5 Q. Okay. Number 29 says, Produce all
6 documents for ESI that refer or relate to
7 communications between you and any person affiliated
8 with or working with Food & Water Watch; do you see
9 that?
10 A. Yup.
12 that request?
13 A. I do not have any documents or
14 communications.
15 Q. Okay.
16 A. Is my position on that.
17 Q. Did you ever do any consulting for Food &
18 Water Watch -- well, did Clean Life Systems ever do
19 any consulting for Food & Water Watch?
20 A. No, my -- Catskill Mountainkeeper is the
21 one that I'm working through, there was more
22 pipeline eliminated.
23 Q. Okay. And was Clean Life Systems ever paid
24 by Food & Water Watch?
25 A. If anything, got maybe some travel money or

95
1 something for going to a location, but not -- not

2 the same as the relationship with Catskill
3 Mountainkeeper.
4 Q. Okay. So if my understanding is correct,
5 Food & Water Watch, if I understand what you said,
6 Food & Water Watch may have paid you travel
7 reimbursement, but they weren't paying you, like,
8 consulting fees?
9 A. Correct.
10 Q. Number 30, Produce all documents or ESI
11 that refer or relate or reflect payments to you from
12 Food & Water Watch; did you bring any documentation
13 that show that?
14 A. Which one are you reading?
15 Q. Number 30.
16 A. I don't have any documentation related to
17 that.
18 Q. Okay. Well, let me ask you this, when you
19 received the documentation -- or when you receive
20 the money in from like Mountainkeeper, do you have
21 any system where you record how much you're
22 receiving in?
23 A. Any system that I record, I get a check, I
24 put it in the bank.
25 Q. Okay.

96
1 A. I don't know what you mean by that.

2 Q. Well, does Mountainkeeper give you a 1099?
3 A. Do they give me a 1099?
4 Q. Mh-hum.
5 A. Yes.
6 Q. Have you ever received a 1099 from Food &
7 Water Watch?
8 A. Not that I know of, no.
9 Q. Okay.
10 A. I believe there's a -- there's a maximum
11 amount -- I don't -- I believe there's a maximum
12 amount needed to be given before a 1099 is generated
13 and if anything was done, it was below that number.
14 Q. Okay. Okay. Produce all documents under
15 ESI that refer to, relate to, or reflect payments to
16 Kemble from Food & Water Watch; do you see that? Do
17 you have any documents that show that?
18 A. I do not.
19 Q. And if I understand you correctly, the only
20 payments that Clean Life System would have made to
21 Mr. Kemble would have been for things like between
22 friends that were, like, under $20?
23 A. If it's a payment it was for something that
24 we were -- he was working on for me or doing
25 something like that, so if it's just -- yes, back

97
1 and forth would be low dollars.

2 Q. Okay. Or -- or it would have been
3 something like the auto repair for your car,
4 correct?
5 A. Yes.
6 Q. Okay. Let's see. Number 32, Produce all
7 documents and/or ESI that refer or relate to any
8 agreement between you and any of the lawyer
9 defendants; do you see that?
10 A. Yes.
11 Q. Do you have any documents that --
12 responsive to that?
13 A. No, I don't have any documents or
14 communication related to that.
15 Q. Number 33 asks to produce all documents
16 and/or ESI that refer or relate to any agreement
17 between you and Food & Water Watch; do you see that?
18 A. Yes.
19 Q. And you understand "you" meaning Clean Life
20 Systems, as well, correct?
21 A. Yes, I believe that --
22 MR. POSEY: I'm going to object to that,
23 the "you" in the definitions doesn't refer to Clean
24 Life Systems or businesses or anything like that,
25 but for the purposes of this deposition if you want

98
1 to ask him about both, go right ahead.

2 BY MS. BARRETTE:
3 Q. So do you have any documents that refer or
4 relate to any agreement between Clean Life Systems
5 and Food & Water Watch?
6 A. I don't have any documents or
7 communications relating to that question.
8 Q. Okay. And just back so when I talk about
9 payments, like for example, Number 30, Produce all
10 documents that refer or relate or reflect payments
11 to you from Food & Water Watch. Has -- let me --
12 just to make sure. Has Food & Water Watch ever made
13 any payments to Clean Life Systems other than what
14 you said was travel reimbursement?
15 A. Not that I recall.
16 Q. Okay. Number 34, asks to -- documents
17 sufficient to show your employers for the years 2013
18 through the present; do you see that?
19 A. Yup.
20 Q. And did you bring documents responsive to
21 that request?
22 A. My -- the records I brought show that I'm
23 self-employed, so I'm my own employer for the last
24 quite a few years.
25 Q. Okay. I want to ask you about the water

99
1 truck, did you -- you said you wrote out the check
2 and you purchased the truck, correct?
3 A. Yes.
4 Q. Is the truck in your name?
5 A. No.
6 Q. Whose name is the truck in?
7 A. Mr. Kemble.
8 Q. Okay. So you gifted the truck to him?
9 A. Well, it's still technically mine, but he
10 had the insurance and the commercial business, so we
11 had to put it through him. I could not have insured
12 it, so...
13 Q. Okay. What kind of commercial business did
14 Mr. Kemble have?
15 A. He had A-1 Tire and Towing.
16 Q. Okay. All right. And that was pretty
17 honorable of you to actually buy them a water truck,
18 I will say that. That was -- that was pretty
19 honorable. And you --
20 A. My dad was a first responder for 63 years
21 and my brother 30 years, so when I see somebody that
22 needs help, I don't ask if I should run into the
23 fire, I just go in and do it. So I saw some people
24 needing help and I decided to step up like nobody
25 else would.

100
1 Q. Yeah, well, not many people would use their

2 own money like that to purchase someone else a water
3 truck.
4 And you used your own money for that,
5 correct?
6 A. Yes.
7 THE VIDEOGRAPHER: Excuse me, we're coming
8 close to me needing to change the media.
9 MS. BARRETTE: Okay.
10 THE VIDEOGRAPHER: I've got about five
11 minutes, do you want to --
12 MS. BARRETTE: It's a good -- take a break.
13 THE VIDEOGRAPHER: It's good. Going off
14 the record at 10:52.
15 (Off the record.)
16 THE VIDEOGRAPHER: Back on the record at
17 11:15.
18 BY MS. BARRETTE:
19 Q. Okay. Mr. Stevens, we are back on the
20 record. During the break -- well, you understand
21 you're still under oath, correct?
22 A. Yes.
23 Q. And you understand that oath obligates you
24 to tell the truth, correct?
25 A. Yes.

101
1 Q. And you are under oath during the first

2 part of the deposition, correct?
3 A. Yes.
4 Q. Do you wish to change any of the responses
5 that you gave previously?
6 A. Not -- not that I know.
7 Q. Well, were you -- were you answering
8 questions?
9 A. To the best of my ability to be truthful, I
10 was trying to be, yes.
11 Q. Okay. And during the deposition or during
12 the break, other than the moment when you were
13 discussing the documents with your -- your attorney,
14 did you have any other communications with your
15 attorney about what was going on in this deposition?
16 A. What was going on in it?
17 Q. Yes, or about the deposition.
18 A. Not that -- I mean, I don't know that we
19 related to the deposition itself.
20 Q. Yes, did you have any communication.
21 A. I -- I didn't think about it.
22 Q. Okay. So your answer is yes, you were
23 answering questions during the first morning part of
24 this deposition truthfully, correct?
25 A. Yes. To the best of my ability, yes.

102
1 Q. Okay. Do you -- have you entered into a

2 joint defense agreement with any other person
3 related to this case?
4 A. Joint defense agreement?
5 Q. Yes.
6 A. Not that I know of. A joint defense
7 agreement, no.
8 Q. And in connection with looking for an
9 attorney did you have any communications with anyone
10 from Food & Water Watch about the need for an
11 attorney?
12 A. All I did was put the word out that I'm
13 looking for an attorney so it was -- I'm not sure
14 who responded, but I let everybody know I'm in need
15 of it because I realized that it was going to get --
16 getting more serious than I thought it was
17 originally.
18 Q. And when you said you let everybody know,
19 who -- who was everybody?
20 A. I just asked for help. I mean, there's a
21 whole group of us that are -- that are in the same
22 boat. I, you know, I've got -- you've got Bill,
23 Julanne, all these people that are in the same boat
24 as we are. So I put the word out I needed help.
25 Q. Well, there's -- there's two people. You

103
1 say all these people, there are two; Bill Huston,

2 Julanne Skinner, and you; that's the only people
3 we've subpoenaed. Are there others that you're
4 saying are in the same boat?
5 A. Well, not the nonparty witnesses that I
6 know of. Those are the only nonparties I know of.
7 Well, when I went from having a subpoena sent that I
8 didn't believe was served properly to -- to standing
9 in front of a judge in Fairfax County, it got more
10 real to me than I thought it was going to be before
11 that, so...
12 Q. And when you say you put this word out for
13 help, did you communicate with anyone at Food &
14 Water Watch about the need for help seeking an
15 attorney?
16 A. I don't -- what the relevance is. I put it
17 out to everybody that I needed help because once I
18 realized that it was serious.
19 Q. Okay. And did you receive any
20 communications back? I'm not talking about from a
21 lawyer, but from any -- what I'll refer to as
22 activist organizations like Mountainkeeper, Frack
23 Action, you know, Water Defense; did any of them
24 contact -- contact you?
25 A. About an attorney.

104
1 Q. About an attorney?
2 A. Not -- not any of the ones you named.
3 Q. Which ones contacted you about an attorney?
4 MR. POSEY: I'm going to object to the
5 relevance, but you can answer if you know.
6 THE WITNESS: Yeah, I've got responses from
7 Food & Water Watch, Catskill -- literally responses
8 like were -- we would look for one, because I
9 didn't -- I don't know any attorneys, hadn't had a
10 need for one for years.
11 BY MS. BARRETTE:
12 Q. Okay. So Food & Water Watch was looking
13 for one, Catskill, anyone else?
14 A. That's probably the two.
15 Q. And did either of those organizations say
16 that they would pay for an attorney for you?
17 MR. POSEY: I'm going to object. I don't
18 see how this is relevant to the breach of contract
19 by Mr. Kemble or the attorneys representing
20 Mr. Kemble. This is becoming oppressive and totally
21 outside the scope of anything relevant to your case
22 in Pennsylvania.
23 MS. BARRETTE: Are you done now?
24 MR. POSEY: I would hope that you're done
25 because this is an inappropriate line of

105
1 questioning.
2 BY MS. BARRETTE:
3 Q. Did either Food & Water Watch or Catskill
4 offer to pay for an attorney for you?
5 A. My attorney said it's --
6 Q. Your attorney did not instruct you to
7 answer -- did not not instruct you to answer that.
8 Communication with Food & Water Watch or Catskill is
9 not privileged.
10 Did someone from Food & Water Watch or
11 Catskill tell you that they would pay for an
12 attorney for you?
13 A. I have been offered assistance, yes.
14 Q. Who offered you assistance?
15 A. Well, both but...
16 Q. So both Food & Water Watch and Catskill
17 said they would pay for an attorney for you?
18 A. They would help me secure legal help, yes.
19 Q. Was that in an e-mail correspondence?
20 A. No, verbal.
21 Q. And who at Food & Water Watch verbally said
22 to you that they would help you with a lawyer?
23 A. I'm not sure, maybe Emily would have,
24 but...
25 Q. And who at Catskill Mountainkeeper said

106
1 they would help you secure counsel?

2 A. Catskill is Wes Gillingham usually.
3 Q. How -- how did it come about that you met
4 Mr. Kemble?
5 A. How did I meet him?
6 Q. Mh-hum.
7 A. After -- actually, it was the Sautners that
8 I met there first back in 2010 when I moved there,
9 and then in a group type of setting there was other
10 people from the Carter Road area and Ray was there,
11 so that's where I originally met him. It was just
12 as a group of people along the Carter Road area at
13 an event or gathering.
14 Q. And when was that, do you recall?
15 A. It would be like spring of 2010, I moved
16 there in January 2010. So spring of 2010.
17 Q. Now, from the spring of 2010 up until about
18 I want to say mid 2012 you spent time traveling with
19 Mr. Sautner, correct?
20 A. Yes.
21 Q. And Mr. Sautner was frequently seen
22 carrying a jug of brown water around, correct?
23 A. Correct, his own water.
24 Q. And at some point did there come a time
25 when your relationship with Mr. Sautner changed?

107
1 A. Yes.
3 A. After you bought their -- Cabot bought
4 their house and they signed an agreement I'm
5 guessing.
6 Q. And when you say you're guessing, what --
7 what happened with the relationship with you and
8 Mr. Sautner, how did it change?
9 A. How did it change? They were leaving the
10 area and I was staying, so I believe they moved to
11 New York, but I'm not positive.
12 Q. And you were angry with them for settling,
13 correct?
14 A. Angry, no, that was a decision they made.
15 Q. And do you recall posting on
16 Julie Sautner's website about them settling?
17 A. I don't post on anybody's website.
18 Q. You don't recall posting on her Facebook
19 account?
20 A. I don't post on anybody's Facebook as far
21 as Julie Sautner or Craig Sautner.
22 Q. Back in 2012 you didn't post?
23 A. I don't -- I don't put negative -- you will
24 not find a negative thing from me on any post that I
25 put on Facebook.

108
1 Q. Did --
2 A. Communication device to me.
3 Q. Did you tell Ms. Sautner not to worry, that
4 you would continue carrying the jug of water around?
5 A. Tell her I was going to continue?
6 Q. Mh-hum.
7 A. No, I -- it's not their water I was
8 carrying around.
9 Q. All right. So you stopped carrying their
10 water around in 2012, correct?
11 A. I'm trying to think if I had his old jug,
12 but it changed pretty rapidly after that because I
13 knew that they were interested in continuing to go
14 around, so I stopped. That was...
15 Q. Okay. And at that point you needed to find
16 somebody new to go around, correct?
17 A. Correct.
18 Q. And how did it come about that you ended up
19 with Mr. Kemble to go around with?
20 A. To go around with, that wasn't ending up,
21 that was just me going places and if he attended, he
22 attended if he drove me, he rode with me, but there
23 was no -- there was no starting up anything, so...
24 Q. Did you ask him to attend any events with
25 you?

109
1 A. If I notified him that I was going

2 somewhere where he wanted to go, then he could come
3 with me as -- in the car, so that's basically how it
4 would happen. I didn't schedule anything with him.
5 Q. But did you ask him to attend events with
6 you?
7 A. I offered for him to be able to come if he
8 wanted to, but I didn't ask him to attend.
9 Q. Now, did you ever have any understanding of
10 what Mr. Kemble's employment was?
11 A. He owns a business, that's all I knew, that
12 he owned a business that's attached to his property.
13 Q. Now, Mr. Kemble has done frequent videos
14 where he claimed that he was a former gas worker,
15 that he went undercover to work for the natural gas
16 industry to try to find out information about
17 fracking and chemicals and dumping; do you recall
18 anything about that?
19 A. I've heard that before, I know that he
20 drove a water truck. I saw the water truck in his
21 driveway before, but I don't know anything about the
22 circumstance or how he -- I mean, I didn't have any
23 knowledge before that about the circumstance or how
24 he got started doing it.
25 Q. Do you know how long he drove the water

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1 truck?
2 A. From what I hear, just under four years,
3 three and a half or four years.
4 Q. When I say drove a water truck, I'm talking
5 about driving an actual water truck for an industry?
6 A. Hauled a water truck for industry, yes. So
7 three and a half to four years I was made aware that
8 that's the length of time, but I have no knowledge
9 of when he started or when he ended, that's just
10 somebody else saying it.
11 Q. Did he tell you that he drove a truck for
12 that long -- a water truck?
13 A. Yeah, from what I've heard him say and my
14 presence, three and a half years, four years, three
15 and a half to four years.
16 Q. And, you know, Mr. Kemble had often in his
17 speeches said that he observed like illegal dumping
18 and things like that, do you recall that? Do you
19 recall him saying that?
20 A. I've heard him say it before, but I have no
21 direct knowledge because I wasn't present with
22 whatever I saw, it must have been during his work
23 when he was working.
24 Q. Well, that would have been a pretty big
25 deal to know about though, correct? If he was

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1 actually witnessing companies doing illegal dumping,

2 I mean, isn't that something you would have looked
3 into?
4 A. I don't follow.
6 you know.
7 THE WITNESS: I have no knowledge of it.
8 I'm not on the road with truck drivers, I have no
9 knowledge of what they are or aren't doing.
10 BY MS. BARRETTE:
11 Q. Well, aren't you interested in getting the
12 facts behind that?
14 you know.
15 THE WITNESS: I -- no, I'm not interested
16 for the fact that I didn't -- it didn't involve me
17 and I wasn't going to follow around vehicles to find
18 out what they were doing.
19 BY MS. BARRETTE:
20 Q. But if you heard -- let me say -- let me
21 ask you this way. And I'm just going to -- and I'm
22 not characterizing you and I'm not trying to but I
23 guess I will.
24 You -- you are an activist, correct?
25 A. Realist.

112
1 Q. Okay. So you're a realist, but you -- one

2 of the things that you do is you go out trying to
3 educate people about the dangers of the use of
4 hydrocarbons, hydraulic fracturing, pipeline
5 infrastructure, correct?
6 A. Yes, stressing on --
7 MR. POSEY: Objection. You can answer, if
8 you know. Go ahead.
9 THE WITNESS: Stressing on property owners
10 because that was my first experience with the
11 problems and issues that come from it. But I don't
12 ever tell anybody not to do it, I just tell them
13 what my -- I don't -- I don't tell them what to do
14 with the property, I just tell them what has
15 happened to me and others.
16 BY MS. BARRETTE:
17 Q. Correct. And one of the things you talk
18 about is water contamination, correct?
19 A. Yes.
20 Q. And you have Mr. Kemble who is saying that
21 he has observed illegal dumping and is my
22 understanding correct that you never asked him the
23 details about that?
24 A. I wasn't concerned about that portion of
25 it, I know that happens. I've heard it from other

113
1 people that that happens, where even in Southwestern

2 PA where a truck will just pull up in a field and
3 open their valve up and dump whatever the contents
4 of a truck, but I never saw it, so it's hearsay to
5 me. So if it's hearsay I don't -- I don't go after
6 hearsay, I want proven document evidence, otherwise
7 I'm not going to repeat it.
8 Q. So at some point did Mr. Kemble tell you
9 that his water was contaminated?
10 A. Well, tell me or I witnessed the water
11 coming out black and different colors and things, so
12 more like I saw what happened in front of my own
13 eyes. He didn't have to tell me anything.
14 Q. And when you say you saw the water come out
15 black, describe for me what incident you're talking
16 about?
17 A. I've been at his house where I put a bucket
18 outside and put a hose into it and it comes out
19 clear and the next thing you know the bucket is jet
20 black with balls of gel and all kinds of different
21 odors, so I've been -- I'm going to make sure I see
22 something before I say something about there is
23 something strange here. So I witnessed it
24 firsthand, I didn't have to be told by anybody.
25 Q. Okay. Now, had you -- so you said you met

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1 Mr. Kemble in 2010, correct?

2 A. Yup.
3 Q. So you did not know Mr. Kemble prior to --
4 or you did not understand or had no firsthand
5 knowledge of what the condition of his water was
6 like prior to meeting him in 2010?
7 A. Absolutely not, I moved to my property in
8 January of 2010 and knew nobody, not one person
9 except for a few local family members, otherwise I
10 was a stranger in town.
11 Q. So you don't know if his water actually
12 would come out like that when he'd run his well
13 prior to Cabot drilling, correct?
14 A. Correct, did not witness his water before
15 that time.
16 Q. Now, did there come a time -- and I've seen
17 videos, and this goes back to the purchase of the
18 truck. And I'm going to keep your tabbed copies.
19 MS. BARRETTE: 4?
20 MR. PILSNER: Yup.
22 identification.)
23 BY MS. BARRETTE:
25 identification purposes as Cabot Exhibit 4. What is

115
1 this document?
2 A. I had to hand write it because I couldn't
3 find a receipt because it was so long ago, still
4 searching for what area that might have been in, but
5 so I just hand wrote Fernwood Auto Sales, $3,500 as
6 a guesstimate, it's right around that amount, what
7 the date, it was January 2012, and what type of
8 vehicle it was.
9 Q. Okay. And as you testified earlier, you
10 purchased this truck with your own money --
11 A. Yes.
12 Q. Well, let me -- let me finish.
13 As you testified earlier, you said that you
14 purchased this truck with your own money, correct?
15 A. Correct.
16 Q. And what was the purpose of the purchase of
17 this truck, the water truck?
18 A. The purchase of the purchase of the
19 water -- the purchase of the water truck was that on
20 November 30th, 2011, Cabot Oil & Gas was allowed by
21 the Commonwealth of Pennsylvania to stop delivering
22 water to the 11 families in Dimock, Pennsylvania,
23 that's a known fact. I've put the documents in
24 there to show that too.
25 And so going into Christmas, that's what

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1 really got me, was them going into Christmas, those

2 families without any delivered water, I decided to
3 step up when nobody else would and got a hydrant
4 installed, bought a flatbed truck and started water
5 deliveries again. So that was -- that's what people
6 do when they care about their neighbors.
7 Q. And you said you started the water
8 deliveries. Were you actually the one doing the
9 water deliveries?
10 A. No, Ray drove the trucks. I don't have
11 knowledge of how to drive a truck full of water.
12 Q. Okay. And was Mr. Kemble volunteering to
13 do this -- these water deliveries that --
14 A. No, I paid him $500 a week and all the
15 expenses came out of that, the gasoline, the water,
16 costs, all of that came out of the $500 a week
17 because before that it was well, you know, it's $100
18 a day per delivery when it's professional delivered.
19 Ask Ken Morcom how much Cabot has spent on his
20 deliveries for five and a half years, you'll find
21 out it's a big number.
22 So I figured at $3,000 a month for $100 a
23 day per family getting delivered, that we were doing
24 it for a couple thousand for -- for the entire
25 group. So it was the only way I figured it could be

117
1 done. So that's the way I did it. That's -- and

2 Ray had to be compensated, he was delivering to
3 everyone, so I did that also out of my own pocket.
4 Q. Okay. Let me back this up. When I asked
5 you earlier if you had paid Mr. Kemble any money,
6 you said, no, nothing other than like $20 among
7 friends?
8 A. That was loaning back and forth, but paying
9 $500 a week to deliver water was a totally
10 different -- he was delivering water -- replacement
11 water, so I didn't correlate the two on what I was
12 saying. I -- when we were talking about money back
13 and forth between friends, that was not between
14 friends. He was doing a service, I paid him $500 a
15 week to do it so I didn't understand earlier that we
16 were extrapolating it to the water delivery.
17 Q. Okay. Earlier when I asked about any
18 payments to Mr. Kemble we included payments for
19 services and you said like payments when he fixed
20 your truck and then you said loans back and forth,
21 exchanges, and you never mentioned paying for water
22 deliveries, but now you're saying you paid him
23 actually 500 a month?
24 A. A week.
25 Q. Oh, 500 a week?

118
1 A. Yes.
2 Q. Okay.
3 A. The expenses alone were probably half of
4 that in gas and things.
5 Q. Okay. And were you using your own money to
6 pay for that --
7 A. Yes.
8 Q. -- that water?
9 Okay. So let me back up. This 500 a week
10 that you were paying Mr. Kemble --
11 A. Yes.
12 Q. -- was that for the actual purchase of the
13 water or just for the -- him delivering water?
14 A. Delivering -- well, it was all part of the
15 water getting delivered to the group of people, all
16 together, the water bill, the gasoline to do it,
17 the -- every part of it, the hours that they're
18 going to do it.
19 Q. Well, the water -- you handed me a separate
20 copy of a water bill, so I just want to make sure
21 we're getting things clear so there's no mistakes.
22 The water bill that you handed me was for
23 PA American Water, that was in your name, correct?
24 A. Yep.
25 Q. Are you saying Mr. Kemble pays that water

119
1 bill?
2 A. No, I paid the water bill and the gasoline
3 expenses out of that separately from the $500 that
4 was for the delivery of the water.
5 Q. Okay. So the $500 a week was strictly for
6 him delivering the water and then you also paid
7 separately for the water bill directly to pay
8 American Water and you paid for gas and things?
9 A. It came out of the -- the gas, the expenses
10 for the truck came out of the -- the dollars, the
11 $500.
12 Q. Okay.
13 A. Just not the water bill, that was a
14 separate issue.
15 Q. Okay. And how many families did Mr. Kemble
16 deliver to?
17 A. All the people that Cabot was allowed to
18 stop delivering to, so I believe we were at 10 or 11
19 households.
20 Q. And does Mr. -- and did those deliveries,
21 you said they started I believe you said in 2012,
22 correct?
23 A. Yeah, it was a little bit -- January the
24 truck was set up, but I think February or March of
25 2012.

120
1 Q. And since -- over time, has the amount of

2 people that Mr. Kemble has delivered water to
3 changed?
4 A. Yes.
5 Q. Okay. And so the -- currently how many
6 people does he still deliver water to?
7 A. One.
8 Q. And who is that?
9 A. His own house.
10 Q. Okay. In 2017, how many people was
11 Mr. Kemble delivering to?
12 A. The larger group of people stopped after
13 the settlement agreement probably went down to half
14 a dozen after 20 -- September 2012 and then it
15 dwindled down to just one and that was probably in
16 about 2015 or '16 was to Ray.
17 Q. So after 2012 it went down to six when
18 people settled and then you said in around 20, what,
19 '15?
20 A. 2015, yes, '15 or '16 I can't -- I don't
21 know exactly when, but...
22 Q. So 2015 or 2016, it was just -- he was only
23 delivering to his own home?
24 A. Correct.
25 Q. Okay. So when he was only delivering to

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1 his own home, did you stop paying him the 500 a
2 month?
3 A. Yeah, there was no money involved with him
4 just doing his own and so that -- I stopped paying,
5 you know, earlier than that because there -- it
6 dwindled down to a few people, but we had other
7 people kicking in, because Franklin Forks then was
8 borrowing the truck to get water. So there are
9 other areas that the -- that the water truck
10 serviced, but not the same group of people that it
11 originally started with.
12 Q. Okay. So you had Franklin Forks using
13 that?
14 A. That was WPX slash Williams over there.
15 Q. And that's the Tammy Manning family,
16 correct?
17 A. Yes. And they -- they got water tanks
18 installed very nicely as good neighbors like Cabot
19 did for the people in Dimock that was done by WPX in
20 Franklin Forks.
21 Q. Okay. And who else was getting water
22 deliveries other than the people in Franklin Forks?
23 A. Just the two there and then Ray and I
24 believe there was a handful of others, but I have to
25 remember who exactly in Dimock, maybe -- at that

122
1 time, that's when there was about six and it

2 dwindled down after, Franklin Forks had about four,
3 and then everybody else figured out getting their
4 own water. I don't know what it was, but we just
5 had -- the truck was basically idle except for
6 hauling water to Ray's house.
7 Q. Okay. So when did the Franklin Forks
8 people stop getting water?
9 A. 2014 probably. 2013 to 2014 range when
10 they were using the truck.
11 Q. Okay. And you had said something about
12 other people kicking in.
13 A. Those people, I mean, they had to pay their
14 own gas and they had to -- they had to do -- you
15 know, the expenses were having to be shared since it
16 was going a lot further distance than before, so...
17 Q. Okay. So they -- so at that point were you
18 still paying -- were you still paying in 2013 and
19 '14 Mr. Kemble to deliver water to them?
20 A. It became more of -- of a group effort
21 because they didn't want me to continue doing it, so
22 someone would pitch in for gas, the local neighbors
23 were doing that.
24 Q. Oh, local neighbors?
25 A. Yes. They paid their own expenses, the

123
1 Franklin Forks people, the gasoline, and we had to

2 figure out the water bill and things like that.
3 Q. Okay. So let me -- and when you said they
4 didn't want you doing that anymore, who is "they"?
5 A. The local neighbors realizing that I was
6 basically footing the bill for a couple years there.
7 Q. So the local neighbors realized that you
8 were footing the bill?
9 A. Mh-hum.
10 Q. Okay. And they decided they didn't want
11 you to have to pay anymore so they were going to --
12 A. I couldn't continue, so they -- they -- you
13 know, I just told them I can't continue doing it so,
14 of course, other people started to step up. It's
15 amazing what happens when you set an example for
16 people to do the right thing, so they did it.
17 Q. And if I'm understanding you correctly, you
18 were not receiving assistance from any other
19 organization to pay Mr. Kemble that 500 a month,
20 correct?
21 A. Not organizations, people, I was getting --
22 starting to get donations from all over the
23 Northeast, people were sending me some money to --
24 towards the truck, it all went towards the truck
25 expense, but not organizations to speak of, it was

124
1 individuals.
2 Q. What individuals were sending you money?
3 A. People from New York State that had come
4 down and seen what was going on, got 500 from here
5 and 200 from there, so we were able to keep the
6 water hydrant paid for and assist in doing it.
7 Nobody was getting paid then, it just dropped off
8 because I couldn't support it.
9 Q. But so you're saying somebody from New York
10 gave you $500 for water?
11 A. A bunch of people from Upstate -- from all
12 over New York started sending in $50 here and $100
13 there to -- towards the truck, it went straight to
14 the water -- water bill and to the -- and to the
15 truck itself.
16 Q. And how did they make those payments to
17 you?
18 A. Just anything. If they're in the area,
19 cash, they send a check over, something like that.
20 I'd put it right to the bill for the water,
21 something like that.
22 Q. And did those, I would call them donations,
23 so to speak, did -- did those stop in 2014 or when
24 Mr. Kemble was only the sole person getting water?
25 A. Yeah, it dwindled down because there was

125
1 not anybody else receiving it. So it wasn't fair to

2 have anybody do it, so it became more my
3 responsibility for the water bill and whoever was
4 using the truck, gasoline, but that was about it.
5 Q. Did Food & Water Watch ever pay the water
6 bill?
7 A. No, I've paid the water bill or we did
8 locally who paid the water bill since it's been
9 installed. My name is on it, they send me the bill.
10 Q. Did Food & Water Watch ever reimburse you
11 for the water bill?
12 A. Not -- not reimbursing for anything really,
13 they're -- the main reimbursements were coming from
14 either the local community or people from New York
15 State. So there was no water bill reimbursement
16 except for the cash or checks that came in.
17 Q. When you say people from New York State, do
18 you mean like Julia Walsh?
19 A. Julia Walsh never gave any money to me.
20 We're talking like just individuals, people that
21 knew the situation, they'd come and see what's
22 happened, they wanted to help, that sort of -- it
23 was individual donations.
24 Q. And Julia Walsh group Frack Action never --
25 am I understanding correct, her -- Frack Action

126
1 never gave any money to you?

2 A. No, they brought in the big truck, December
3 6th of 2011, as you guys are aware of a giant truck,
4 but -- well, I'm not saying that -- I'm saying they
5 didn't give me money directly, but I'm sure they
6 advertised for people, that's why we started to get
7 people to send in money from New York State, was the
8 New York State groups, I'm sure, let it be known,
9 that we needed help.
10 So that's -- I wondered why all the sudden
11 there was $50 showing up and $100 and $500, that was
12 why I'm sure they were promoting it to say that we
13 needed help.
14 Q. When you say "showing up," what do you mean
15 showing up?
16 A. Just mailed to me, money mailed to me so I
17 could pay the bills for the truck.
18 Q. Okay. So you were getting just cash money
19 in the mail?
20 A. Just checks or cash if they're in the area,
21 yes.
22 Q. Okay. But just so I'm clear, Frack Action
23 never -- when I say you, Frack Action never made any
24 payments to Clean Life Systems?
25 A. No, I -- not that I recall. Nobody from

127
1 groups really, it was individuals that I was getting

2 the checks from.
3 Q. Okay.
4 A. I just believed that the promotion of it
5 was from those -- the larger groups promoted what
6 was happening and then we got donations from
7 individuals.
8 Q. Okay. Did you issue a 1099 to Mr. Kemble?
9 A. I did not. I put -- I took the -- it's on
10 my taxes, it was shown the cash that was coming in
11 and going out to me. So I -- I did not issue a 1099
12 to him.
13 Q. So you reported cash in and going out on
14 your taxes, but you didn't give him anything -- so
15 that's 2,000 a month that you were paying him for
16 services and you did not provide him with any tax
17 information so that he could report that, correct?
18 A. Right. I had took the tax hit and I paid
19 the expenses out of any money that was coming in, I
20 put it on my -- the money was put on my side. The
21 only reason to do a 1099 is to take the liability
22 from me or the person doing it and send it to the
23 other person. So I kept the liability since he was
24 doing all the deliveries and paying expenses out of
25 it.

128
1 Q. Did you consult with an attorney before

2 making a decision not to make his -- that 2,000 a
3 month reportable for him?
5 instruct you not to answer that.
6 BY MS. BARRETTE:
7 Q. Did you tell Mr. Kemble that he didn't have
8 to pay tax on that money?
9 A. I didn't instruct Mr. Kemble what to do
10 with the money or not to do with it.
11 Q. Do you know if Mr. Kemble was receiving
12 payments from anyone else -- any other group or any
13 other person to deliver the water?
14 A. Not that I know of.
15 Q. So you're not aware of Mr. Kemble receiving
16 money from, for example, Water Defense Fund?
17 A. I have no idea if Mr. Kemble was getting
18 money from somewhere else, that wasn't going through
19 me, so I wasn't aware of it.
21 identification.)
22 MS. BARRETTE: I want to go back to the --
23 well, let me just do this.
25 identification.)

129
1 MS. BARRETTE: How many copies did they

2 make?
3 MR. PILSNER: They're supposed to make
4 five.
5 MS. BARRETTE: Okay. I need one there.
6 Sorry.
7 BY MS. BARRETTE:
9 been marked for identification purposes Cabot
10 Exhibit 5 and Cabot Exhibit 6, those are two
11 documents that you brought today, one is the July 7,
12 2008 water test result from -- includes a letter
13 from T.S. Calkins, cover letter is dated July 7,
14 2008, and then there is a report date of -- on the
15 next page of Northeastern Environmental
16 Laboratories, Inc., a report date of 6/20/2008. It
17 indicates it's a well water sample taken on May 28,
18 2008, for Raymond Kemble, and that's Exhibit 5,
19 Cabot Exhibit 5.
20 Cabot Exhibit 6, I'm just going to have you
21 explain it. It appears to be just a listing -- some
22 handwriting that says Ray Kemble PA DEP water test
23 redacted.
24 Start with Cabot Exhibit Number 5, where
25 did you get this document?

130
1 A. I got it from Ray Kemble.

2 Q. And did you review this document?
3 A. I've looked at it, I don't know how to
4 exactly review everything on it, but I've looked at
5 the document.
6 Q. Okay. And you understand that this is his
7 predrill test results, correct?
8 A. Correct.
9 Q. And you understand that his predrill test
10 results indicated that he had the presence of
11 benzene and toluene in his water predrill, correct?
13 you know.
14 THE WITNESS: I have no idea. I get
15 confused by the limits and the numbers on this, I
16 just left this as a predrill test copy.
17 BY MS. BARRETTE:
18 Q. Okay. Well, you have stood up on video in
19 front of committees and said that Mr. Kemble -- I
20 mean holding this exact document saying that
21 Mr. Kemble's water tested completely fine and there
22 was nothing in his water. So did you actually --
23 did you look at the document before you -- you
24 made -- testified before these committees?

131
1 you know.
2 THE WITNESS: I have no idea, I don't --
3 .002 looks like a pretty small number so you guys
4 are the ones that have done thousands of water
5 tests, Cabot has, so I'm wondering if that's
6 reflective of a very low number or very high, I
7 don't know.
8 BY MS. BARRETTE:
9 Q. Okay. So let me make sure I understand
10 this. Earlier you said, we were talking, I asked
11 you if you knew what benzene was and what toluene
12 was and you said they were cancer causing -- highly
13 cancerous I believe you said BTEX and that you
14 wouldn't drink water that had it in it, and here we
15 have Mr. Kemble's predrill test before any drilling
16 was done showing that he had benzene and toluene in
17 his water and yet you stood up in front of these
18 regulatory bodies and said that his water was
19 totally fine before drilling, correct?
21 you know.
22 THE WITNESS: Yeah, I have no idea what
23 you're getting at. I see very, very low numbers
24 .002, that's in the thousandth range. So what -- do
25 you have a copy of the one -- you guys did tests

132
1 every week, where is the copy showing it after the

2 testing, maybe it was above .002.
3 So I'm not -- I'm not a water expert as far
4 as looking at testing data, but those look like low
5 numbers unless somebody can educate me that it's a
6 high number.
7 Q. So it's a -- is a low number of benzene
8 acceptable to you, is that what you're saying?
9 A. I don't know, is a low number of methane
10 acceptable?
11 Q. I'm asking you is a low number of benzene
12 in someone's water acceptable to you?
14 THE WITNESS: No --
15 MR. POSEY: You can answer, if you know.
16 THE WITNESS: Yeah, I -- I have absolutely
17 no idea what the -- what the allowance is because
18 there are allowance with every chemical in any kind
19 of water.
20 BY MS. BARRETTE:
21 Q. Does having an allowance of a chemical in
22 water make it acceptable to you to be in the water?
24 you know.
25 THE WITNESS: I would rather if it was my

133
1 water said 000, but I don't know what the levels are
2 that they would call acceptable.
3 BY MS. BARRETTE:
4 Q. I understand that, Mr. Stevens. But you
5 were giving testimony before committees,
6 governmental agencies and committees saying that
7 Mr. Kemble's water was fine beforehand; the truth is
8 you didn't know if his water was fine beforehand,
9 correct?
11 you know.
12 THE WITNESS: I was -- I didn't know him
13 beforehand. All I know is from the condition I saw
14 when it was different.
15 BY MS. BARRETTE:
16 Q. That's right. So when you stood up at a
17 hearing and you held up this test result and said
18 his water was fine, you had no idea what you were
19 talking about, correct?
21 you know.
22 THE WITNESS: Well, mostly we're looking at
23 zero hydrocarbons, that's what I usually look at
24 unless it says no hydrocarbons detected. So that is
25 one aspect of what I looked at for -- because I know

134
1 right now there is no drilling there because of

2 hydrocarbons. So if there's zero, then that's one
3 aspect of this test that was changed -- I guess
4 changed. I don't know these levels. I wouldn't
5 know, I'd have to get a water expert and consult
6 them on exactly what .002 or any of these is, but...
7 Q. But -- and you're not a water expert,
8 correct?
9 A. I'm not a water quality expert, no.
10 Q. Even though you sell high quality water
11 treatment systems?
12 A. It's used as potable water, so it has to be
13 safe going in.
14 Q. And you had no idea what these numbers
15 meant and you didn't understand them when you were
16 testifying about them in front of the senate
17 committees, correct?
19 you know.
20 THE WITNESS: I never testified in front of
21 a senate committee before. I don't know what you're
22 referring to. Can you --
23 BY MS. BARRETTE:
24 Q. The New York Assembly, did you testify in
25 front of the New York Assembly?

135
1 A. Oh, senate committee there. I thought you

2 meant U.S. like here.
3 Q. Yeah, no.
4 A. I misunderstood the question.
5 Q. You testified in front of the senate
6 committee, correct? Or the assembly in New York?
7 A. Yes.
8 Q. And you held up this water test, correct?
9 A. I -- that was when? 2012, 2011, so seven
10 years ago, I'm not sure which water test I held up.
11 MS. BARRETTE: Can you pull up the video,
12 please. It's -- and you can go to the 13-minute
13 mark. Okay. And for the record we are showing a
14 video of Mr. Stevens' testimony. It's a panel --
15 the testimony -- it's panel Number 13, testimony
16 January 10th, 2013, in front of the New York
17 Assembly, it's a hearing on fracking regulations.
18 BY MS. BARRETTE:
19 Q. Mr. Stevens, that's your picture, correct?
20 A. Yes.
21 Q. Okay. And that says -- identifies you as
22 the president and founder of Energy in Denial, Inc.,
23 correct?
24 A. They did there, yes.
25 Q. Okay. And when you say "they," do you know

136
1 whose video that came off of?

2 A. I don't know who put it in. I had a Clean
3 Life Systems -- or I mean I had Patriots and Oil and
4 Gas Shales in, so I don't know why it says president
5 and founder of Energy in Denial.
6 Q. Well, that's your friend Bill Huston's blog
7 site video?
8 A. Yeah, but I had already put in Patriots For
9 Oil and Gas Shales was already existing, which is
10 what I was using, so I don't know why it -- that was
11 in there. It was mislabeled, but...
12 Q. Mr. Huston just mislabeled it?
13 A. I have no idea. You'll have to ask him.
14 Q. How -- did you ever tell Mr. Huston that
15 you had set up Energy in Denial?
17 THE WITNESS: I -- I don't know if he knew.
18 I didn't know him then. I didn't really know him in
19 2013.
20 BY MS. BARRETTE:
21 Q. So Mr. Huston would just come up with
22 Energy in Denial on his own?
23 A. I have no idea.
24 Q. Okay. Go ahead with that.
25 (The video was played for the record.)

137
1 BY MS. BARRETTE:
2 Q. Okay. Now, you heard what you just said,
3 absolutely nothing in the water, correct? And you
4 held up a copy of the predrill, correct?
5 A. I believe I said no methane in -- I thought
6 we were going to talk about methane.
7 Q. We're going to talk about methane too in a
8 minute.
9 A. Okay. Good.
10 Q. But can you just answer my question, you
11 said there was nothing in his water, correct?
12 A. That's what I said.
13 Q. And sitting here today, you're saying you
14 didn't understand these numbers, correct?
15 A. I -- those were low enough where I was told
16 or assumed that those numbers were acceptable levels
17 detection limit whatever that means so, yeah, I
18 didn't have any idea that this would be considered
19 contaminated water.
20 Q. Okay. So you had no idea that having a
21 detectible levels of benzene and toluene in a
22 predrill sample would indicate contaminated water,
23 correct?
25 you know.

138
1 THE WITNESS: I'm not a water expert, so...

2 BY MS. BARRETTE:
3 Q. Okay. Now, you say that there was no
4 methane detected in the water, correct?
5 A. That's what it says here, no hydrocarbons
6 detected, yes.
7 Q. That's not my question, Mr. Stevens. You
8 said on there, there was no methane detected in the
9 water, correct?
10 A. Prior to your --
11 Q. What you said on the video, you said
12 holding up this predrill sample, you said there was
13 no methane detected in the water, correct?
14 A. Correct.
15 Q. Can you show me on this document, Cabot
16 Exhibit Number 5, where there was a test for the
17 dissolved methane in water?
18 A. It says no hydrocarbons detected right at
19 the bottom --
20 Q. And what --
21 A. -- there.
22 Q. -- what that says, field notes, LEL, lower
23 explosive limit, monitoring performed with a LEL
24 monitor.
25 Do you know what an LEL monitor is?

139
1 A. It tests for lower explosive limits so

2 that's -- I guess I learned it's below 27 milligrams
3 per liter.
4 Q. And when -- when you use an LEL meter,
5 where are you testing for the methane?
6 A. I have no idea, I've never used one.
7 Q. So you don't even understand what LEL --
8 what this LEL meter was testing or where or how,
9 correct?
10 A. I'm not an expert on testing for methane.
11 Q. Okay. Now, do you have an understanding
12 or -- so I guess it would come to a surprise to you
13 to know that using an LEL meter you are actually
14 testing for methane in the air?
16 you know.
17 THE WITNESS: I -- I -- yeah, I don't know,
18 so...
19 BY MS. BARRETTE:
20 Q. And there's no test on here that shows what
21 the dissolved methane is in water that shows that
22 his water was being tested for dissolved methane,
23 correct?
25 you know.

140
1 THE WITNESS: I don't have any idea. It

2 looks like not included in this, that portion was
3 not included in this.
4 BY MS. BARRETTE:
5 Q. Okay. So you don't know if there was
6 dissolved methane in Mr. -- Mr. Kemble's water when
7 you stood up there and said that in front of the New
8 York Assembly, correct?
10 you know.
11 THE WITNESS: I don't know.
12 BY MS. BARRETTE:
13 Q. Is that how you do consulting, you consult
14 and make statements to government officials about
15 things that you really don't know about?
17 you know.
18 THE WITNESS: I try to be as informed as I
19 can, but it's hard to keep up with how much damage
20 was done in that area. So everybody had different
21 tests, every home had a different level of
22 everything. So very hard to keep up with.
23 BY MS. BARRETTE:
24 Q. This is -- you are here focusing in that
25 video on Mr. Kemble's water. If you were going to

141
1 speak about Mr. Kemble's water, wouldn't it have

2 been prudent to make sure that you knew and
3 understood the test results about Mr. Kemble's
4 water?
6 you know.
7 THE WITNESS: I -- I've seen methane in his
8 water, so the testing data -- this was prior to
9 that, but after that massive -- I mean, bubbles -- a
10 lot of bubbles in glasses of water.
11 BY MS. BARRETTE:
12 Q. And you -- and you also said that you never
13 saw Mr. Kemble's water prior to 2010, correct?
14 A. Well, that's from 2013, the video, correct?
15 Q. That's correct.
16 A. Okay. That's after the fact. But, no, I
17 did -- had not seen his water before 2010.
18 Q. So you don't know if there -- you could see
19 methane bubbling in his water prior to 2010,
20 correct?
21 A. Correct.
22 Q. Okay. Now, I'd like to talk about Cabot
23 Exhibit Number 6. Could you explain -- is that your
24 handwriting at the top?
25 A. Yes.

142
1 Q. And can you explain what this is?

2 A. This was DEP testing of the entire Carter
3 Road area, each one next to there had a name but it
4 was redacted because DEP protects the -- so the list
5 that is marked -- the asterisked ones were Ray
6 Kemble.
7 Q. And how do you know that?
8 A. He -- he told me and so I -- I -- he marked
9 it, so I just took his word that that's his --
10 because we can't -- I couldn't see it, there was no
11 name next to it.
12 Q. So you just took Mr. Kemble's word that
13 these test results reflected his water?
14 A. That those asterisked items were reflecting
15 his -- I don't see any names on here so -- it's
16 redacted, so that's what I got it from and that's
17 what I was told.
18 Q. And so you were using this to demonstrate
19 contamination in Mr. Kemble's water, correct?
20 A. To demonstrate contamination stating that
21 this is Ray -- this is Ray Kemble's water, that I
22 was told this is Ray Kemble's water and the
23 asterisked items were from his tests.
24 Q. And you have no idea, in truth, whether
25 this even reflects Mr. Kemble's water?

143
1 A. Well, I understand there's copies of

2 unredacted, but they weren't made available, so I
3 have to take his word for it.
4 Q. So, again, my question is you have no idea
5 whether this -- the asterisks represent Mr. Kemble's
6 water?
7 A. No.
8 MR. POSEY: Objection. Already asked and
9 answered. You can --
10 THE WITNESS: Yeah, I'm taking his word for
11 it, so...
12 BY MS. BARRETTE:
13 Q. So that's a yes, you have no idea, correct?
14 A. Yes.
15 Q. Now, you are aware Mr. Kemble has had other
16 water tests done on his water, correct?
17 A. Correct.
18 Q. Have you seen those test results?
19 A. No, I have not accessed them. I know that
20 all of the people in the area there had tons of
21 tests, but I haven't seen any done by any of the
22 government agencies, that's the only one I really
23 would look at. They're all redacted, so...
24 Q. And so did you ever ask Mr. Kemble for a
25 copy of his test results?

144
1 A. No, I don't have any other copies of his --

2 of his test results besides those and that's just
3 marked.
4 Q. My question is did you ever ask him for any
5 other copies of his test results?
6 A. No.
7 Q. Why not?
8 A. If I had these and that's what he had
9 marked, so I just took those.
10 Q. And so even though he had other test
11 results done by the EPA and by ATSTR, you never
12 asked him to see copies of those results, correct?
14 THE WITNESS: Yeah, the EPA and ATSTR were
15 marked, were not put names on either, there -- they
16 have a special nomenclature for it, so I don't know
17 which ones of those were whose. So, no, I didn't.
18 BY MS. BARRETTE:
19 Q. Are you aware Mr. Kemble just had test
20 results done in 2017 by both the DEP and again by
21 ATSTR?
22 A. I heard that they were testing in the area,
23 so...
24 Q. And are you aware that they gave him copies
25 of his test results?

145
1 A. I haven't -- I didn't review those. I

2 haven't seen them.
3 Q. And did you ask Mr. Kemble for them?
4 A. There was no reason for it.
5 Q. There was no reason for it? Wouldn't you
6 want to see if the water got better?
7 A. He'll -- I guess he would tell me if the
8 water was better or not.
9 Q. Wouldn't that be important for you to know
10 that -- if his water turned up clean by the DEP?
11 A. I mean, I --
13 you know.
14 THE WITNESS: So I've gotten to the point
15 in ten -- nine years of I don't care what the water
16 test said, if I go turn the water on and it comes
17 out smelling like a skunk, brown and bubbly, then
18 there's a problem. I'm not going to be a -- I don't
19 have to be Bill Nye, the science guy, to figure out
20 there might be some problems with the water.
21 So so many tests were done at so many
22 different parameters that I just go by the visual,
23 by the odor, color, taste, clarity. Of course, I
24 didn't taste it, but I'm just looking at what
25 parameters of change would be noticed and that's

146
1 what I see when I go to somebody's house to look at

2 their water. A lot of them have a lot of test
3 results.
4 Q. And you have no idea whether anything about
5 the color or clarity of Mr. Kemble's water is the
6 result of Cabot's operations, correct?
7 A. Do I know? I know that the claim is the
8 change was made after the fact, but did I see the
9 water before, no.
10 Q. So you didn't see the water before, you
11 haven't looked at any test results other than the
12 two that we've just looked at, and yet you're going
13 around the country with a jug of water claiming that
14 Cabot, in particular, has contaminated Mr. Kemble's
15 water, correct?
17 you know.
18 THE WITNESS: Yeah, I'm -- I'm -- First
19 Amendment says I can speak, so I've been -- the
20 other sites we mentioned have been abused a lot for
21 everything I'm doing, so I'm sure that's Cabot's
22 supporters. So I'm going around and my free speech
23 rights says I can go and talk about water quality
24 issues wherever I want to.
25 BY MS. BARRETTE:

147
1 Q. That's right. And earlier I had actually

2 talked to you about looking at records and you said
3 yes, you would want to look at the records to make
4 sure that the statements you were making were
5 truthful and accurate, correct?
6 A. Correct.
7 Q. And now as we sit here today we know that
8 you didn't even understand the records, you haven't
9 looked at any recent records, but yet you're still
10 going around and telling people and holding up a jug
11 of water and telling people that Cabot has
12 contaminated people's water, correct?
14 THE WITNESS: That video was from six years
15 ago, so. I mean, that's a pretty old video if you
16 want to -- I mean --
17 BY MS. BARRETTE:
18 Q. I could pull up a more recent one.
19 Are you saying that you're not going around
20 with a jug of Dimock water and telling people
21 that --
22 A. That's not Mr. Kemble's water, so...
23 Q. Okay. So whose -- so you're -- now, you're
24 not taking Mr. Kemble's water around anymore?
25 A. You're just -- you assumed that, I

148
1 didn't -- you never asked me that question.

2 Q. Well, we have video that's labeled Ray
3 Kemble's water on it that you're holding.
4 Whose water are you carrying around
5 recently?
6 A. Whose water?
7 Q. Mh-hum.
8 A. Yeah, the Ely family before, they also
9 signed a nondisclosure with you.
10 Q. Okay. So you were recently in D.C. holding
11 up a bottle of -- oh, was that Virginia -- recently
12 I have a photo of it, holding up a bottle of Dimock
13 water, whose water was that?
14 A. That's the Elys.
16 BY MS. BARRETTE:
17 Q. That was --
18 MR. POSEY: Can we go off the record for
19 just a moment.
20 MS. BARRETTE: No, I'd like to finish this
21 line of questioning.
22 MR. POSEY: I'd like to speak to you about
23 this line of questioning.
24 MS. BARRETTE: Okay. All right. Let's --
25 MR. POSEY: Can -- would you mind stepping

149
1 out?
2 THE VIDEOGRAPHER: Off the record?
3 MR. POSEY: Yes. I mean, actually --
4 THE VIDEOGRAPHER: Off the record at 12:10.
5 MR. POSEY: I'd like to have this
6 discussion on the record, but I want Mr. Kemble to
7 step out.
8 THE VIDEOGRAPHER: Okay. So you want to
9 stay on the video record as well?
10 MR. POSEY: Yes, please.
11 THE VIDEOGRAPHER: Okay. Sure. We're back
12 on, we're still on the record at 12:10.
13 MR. POSEY: Can you make a proffer as to
14 where this is going? The complaint you sent
15 yesterday has to do with actions in 2017, what he's
16 doing in 2019 with a bottle of water seems to be
17 a -- part and parcel of what he claims is the
18 fishing expedition in this case of -- this is not
19 discovery related to whether Mr. -- Mr. Kemble
20 breached his agreement in 2017, whether the -- the
21 lawyers did something to aid and abet that. This is
22 about something you're talking about in 2019 of a
23 nonparty who has nothing to do with this case.
24 MS. BARRETTE: This nonparty is probably
25 going to be part of this case very soon.

150
1 MR. POSEY: Okay.

2 MS. BARRETTE: I'll -- let me explain to
3 you.
4 MR. POSEY: Well, that is totally
5 inappropriate to take his nonparty discovery
6 deposition. This is to annoy, oppress -- oppress
7 and burden him. And if that's the case, then I
8 demand that we cease this deposition right now.
9 MS. BARRETTE: Based on these statements --
10 MR. POSEY: Excuse me.
11 MS. BARRETTE: No, we're not going to cease
12 this deposition right now.
13 MR. POSEY: Excuse me. I demand that we
14 suspend it until such time as I can make the
15 appropriate motion to the court. That's what -- in
16 Rule 4:5 it says that I have the right upon demands
17 for -- upon -- to annoy, embarrass, or oppress the
18 deponent -- you're telling me you're -- you've told
19 me specifically you intend to make him a party.
20 He's not --
21 MS. BARRETTE: I did not say I intend to
22 make him a party.
23 MR. POSEY: You -- you --
24 MS. BARRETTE: Based on what he is saying
25 here now, he is -- first of all, I don't even need

151
1 to give you a proffer for a deposition. That's the

2 first thing.
3 MR. POSEY: You do when --
4 MS. BARRETTE: I don't need to give you a
5 proffer. You can make your record and then you can
6 take it to the court if you think I've been
7 embarrassing or annoying him or oppressing him.
8 This all ties in together to the fact that he took
9 Mr. Kemble around, he helped him get to these
10 different places with the help of the attorney
11 defendants.
12 So this is all part of it and the fact that
13 he has no knowledge, he never even looked at
14 Mr. Kemble's test results, it's all relevant and
15 it's going to become even more relevant in a few
16 minutes. So I think the fact --
17 MR. POSEY: You're trying to --
18 MS. BARRETTE: -- that you're trying to
19 stop this deposition now is inappropriate.
20 Look, I don't find it surprising that Food
21 & Water Watch or Catskill Mountainkeepers is paying
22 your bills. Okay. So we're not going to suspend
23 the deposition.
24 MR. POSEY: Okay.
25 MS. BARRETTE: We're going to continue --

152
1 MR. POSEY: The rule says that --

2 MS. BARRETTE: -- and we're going to finish
3 up with my questioning.
4 MR. POSEY: -- on the demand of the
5 objecting party or deponent, the taking of the
6 deposition shall be suspended for the time necessary
7 to make a motion for an order -- a protective order.
8 So we are suspending it.
9 MS. BARRETTE: And then -- no, we're not
10 going to suspend it.
11 MR. POSEY: It shall be suspended.
12 MS. BARRETTE: Then we're going to call the
13 court because you're trying to obstruct the
14 obtaining of evidence in this case. You are going
15 to be just as guilty as the rest of them trying to
16 obstruct evidence.
17 MR. POSEY: You just identified that you
18 are trying not to obtain evidence in this case, but
19 to obtain evidence in a new case, a different case
20 against my client.
21 MS. BARRETTE: I am not trying to obtain
22 evidence in a new case.
23 MR. POSEY: And you are doing this on no
24 notice, we've been in the case for 48 hours and you
25 would not extend the schedule so we could understand

153
1 what this case was about. You're trying to make him

2 a party to this case and that's totally
3 inappropriate. That's not what discovery is for.
4 If you need to go out and investigate and
5 make him a -- find facts to make him a party to the
6 case, you can do that on your own time. That's not
7 what the discovery is for and the court will see it
8 that way too.
9 MS. BARRETTE: Then I will stop asking
10 questions about this line of questions on the water
11 in 2017 and I will go back to the relevant time
12 period.
13 MR. POSEY: Thank you.
14 MS. BARRETTE: All right.
15 MR. POSEY: Yes.
17 BY MS. BARRETTE:
18 Q. Mr. Stevens, I'm going to turn to the
19 allegations in the complaint in this case.
20 MS. BARRETTE: And you all will have to
21 share this. What number am I on?
22 MR. PILSNER: 7.
24 identification.)
25 BY MS. BARRETTE:

154
1 Q. I'm handing you a copy of Cabot Exhibit

2 Number 7. This is a copy of the complaint that
3 Cabot filed in this case against Charles Speer,
4 Speer Law Firm, Attorney Ciarimboli, Clancy Boylan,
5 and Fellerman & Ciarimboli, and Mr. Kemble.
6 When Mr. Kemble receives -- or did at any
7 time after Cabot filed the litigation, did
8 Mr. Kemble talk to you about this complaint?
9 A. Talk about it?
10 Q. Mh-hum.
11 A. I knew it was in because it was in the
12 newspaper.
13 Q. Okay. Did you ever have any conversations
14 with Mr. Kemble about it?
15 A. Yeah, just that he had had something filed
16 against him and he was not very happy with it.
17 Q. Okay. And did you attempt -- you attended
18 the hearing in December of 2017, correct?
19 A. Absolutely not. I was not even in town.
20 Q. Did you not go to any of the hearings in
21 Mr. Kemble's litigation?
22 A. I've not been to one.
23 Q. Okay. During his testimony he said that
24 you were trying to help him find a lawyer to
25 represent him in this case, is that true? He

155
1 testified on the stand that you were trying to help

2 him?
3 A. Absolutely.
4 Q. Okay. And what efforts did you take to try
5 to help Mr. Kemble find a lawyer?
6 A. Just -- same, put out a need for help.
7 Q. Okay. And did any of the organizations
8 that responded to your request for help to help you,
9 were you able to line up an attorney for Mr. Kemble?
10 A. Not any of the organizations, it was
11 separate.
12 Q. Okay. How -- did you -- in fact, were you
13 able to find someone to represent Mr. Kemble?
14 A. I didn't find them.
15 Q. Who did?
16 A. I don't know, but they did find somebody.
17 Q. Okay. And are you saying you didn't have
18 any involvement in that?
19 A. I did not get involved in who they found,
20 but I know they did find somebody.
21 Q. After the litigation was filed -- well, let
22 me back that up.
23 So let's start, if you go to paragraph 103
24 of the complaint, it's on page 18. Paragraph 103 we
25 start to -- we're discussing this false and

156
1 misleading and unsubstantiated statements that

2 Mr. Kemble made about the past or present condition
3 of his water quality.
4 Number -- or letter A, Mr. Kemble is
5 talking about after the drilling and fracking the
6 water went bad, he didn't have anything with his
7 water prior to the drilling. He says now I have a
8 problem with the water, GD Industry did it. And
9 that is a video by ITV from the United Kingdom, it's
10 September 11th, 2013.
11 Do you recall being present for that --
12 that interview?
13 A. I'm not sure. Six years ago, I don't
14 recall, but...
15 Q. Okay. We're going to pull it up, see if we
16 can refresh your recollection.
17 Prior to being handed this complaint now,
18 did you ever have an opportunity to read the
19 complaint?
20 A. Yes, I have multiple copies that you have
21 had sent to me. Each time it's getting -- my stack
22 is this tall now from the documents, but I think
23 this is -- this is in it.
24 Q. Okay. Prior to my sending the
25 correspondence to you, had you ever received or

157
1 reviewed a copy of the complaint?

2 A. Yes, I saw one prior to coming to me, but
3 much later than when it was originally put in.
4 Q. Okay.
5 MS. BARRETTE: We're going to -- right now,
6 for the record, we're going to show the video Ray
7 Kemble interview about his contaminated water by ITV
8 from the United Kingdom, and it's dated
9 September 11, 2013.
11 BY MS. BARRETTE:
12 Q. Can I have you take a look at the people
13 and let me know if you recall.
15 BY MS. BARRETTE:
16 Q. Do you recognize anybody on here?
17 A. I can't see anybody. I can only see the
18 back of --
19 MS. BARRETTE: Can you stop and can you go
20 to -- go to about 8:49.
22 BY MS. BARRETTE:
23 Q. Do they look familiar to you?
24 A. I don't know if I was there.
25 Q. Okay.

158
1 MS. BARRETTE: Can you put a stop on that.

2 BY MS. BARRETTE:
3 Q. So those people don't look familiar, you
4 don't know if you were there?
5 A. No.
6 Q. Could you go to -- just go a little bit
7 further.
9 THE WITNESS: This one.
10 BY MS. BARRETTE:
11 Q. So do you recall being there now?
12 A. Yes -- (inaudible.)
13 THE REPORTER: I'm sorry, I can't hear. I
14 can't hear your answer over the video.
15 THE WITNESS: Oh, sorry. Yes, I -- now I
16 do. I didn't remember seeing her -- the lady and I
17 couldn't tell from the back of their heads from the
18 beginning of the video.
19 BY MS. BARRETTE:
20 Q. Now, are you saying you had an experience
21 where you got Mr. Kemble's water on it and it shrunk
22 your skin?
23 A. Well, it got on my hand, the back of my
24 hand, and it tightened up -- it tightened up the
25 skin just completely, totally different from what

159
1 the other one was, it was not wet, yes.

2 Q. Okay. All right. Do you recall how the --
3 how you ended up at Mr. Kemble's that day?
4 A. September 11, 2013. No, not positive. I
5 mean, I lived in the area still, so I might have
6 even been down there or did -- somebody was coming
7 down, so they wanted to talk to other people.
8 Usually when somebody comes in to do interviews,
9 they want to talk to other people besides one
10 person, so that may have been the case, but I don't
11 remember exactly. I don't recall exactly why I
12 really was there or when -- what the circumstance of
13 getting me there was.
14 Q. Okay. So you don't know, you know, how you
15 got there, you don't know if somebody called you,
16 told you to be there, you just --
17 A. Yeah, I'm not positive because I did live
18 there at the time so it would have been local.
19 Q. Okay. All right. Do you know Brent
20 Jennings?
21 A. Yes.
22 Q. How do you know him?
23 A. Same, just know him from being a local
24 person, elected official over in Great Bend
25 Township.

160
1 Q. Okay. Do you recall having a video

2 conversation of you and Mr. Jennings and Mr. Kemble
3 about Kemble's water supply?
4 A. I've heard about -- yes, I think I've seen
5 a video of it.
6 Q. Okay. And what was the purpose of that
7 video?
8 A. We're just sitting around talking, so I'm
9 not sure even who shot the video. I don't know if
10 that was Pierce Groggins (phonetic) or I don't know
11 who, but it was just three of us sitting around
12 talking.
13 Q. Okay. And was the purpose of that video
14 for it to be put out to the public?
15 A. I have no idea. I don't do -- I don't get
16 filmed to get -- to be put out. I mean, if somebody
17 films it and puts something out I'm not usually even
18 acknowledgeable of it until I see it until it gets
19 put out, so I don't know what the purpose of that.
20 Q. So it wasn't planned that you and
21 Mr. Jennings were there at Mr. Kemble's house with
22 him talking about his water supply?
23 A. Yeah, no. No, not planned by me, so I
24 don't know if that was something that was going on,
25 but I was just present.

161
1 Q. Okay. Did you attend -- in 2013, did you

2 attend the Catskill Mountain Farm Fest in Woodstock,
3 New York?
4 A. Yes.
5 Q. Okay. And was Mr. Kemble there with you?
6 A. Yes, I believe so.
7 Q. Okay. And did you drive up together?
8 A. I'm not sure because I think -- I don't
9 know if I drove up or if he drove -- no, I think
10 separate, separate vehicles.
11 Q. Okay. And were you paid for your
12 attendance at the Mountain Keeper Barn Fest [sic]?
13 A. No.
14 Q. Were you paid for any travel or anything in
15 relation to that?
16 A. No, I was invited, it's an event that
17 usually costs money and I was invited to go.
18 Q. All right.
19 Did Julanne Skinner ever give you cash or
20 give CLS cash in connection with -- or for any
21 purpose?
22 A. Julanne, no, not that I recall.
23 Q. Let's do this.
24 MS. BARRETTE: Am I on 8?
25 MR. PILSNER: 8.

162

2 identification.)
3 BY MS. BARRETTE:
4 Q. Mr. Stevens, I've handed you what's been
5 marked for identification purposes as Cabot Exhibit
6 Number 8. Do you recognize this document?
7 A. Yes.
8 Q. And what is it?
9 A. It's a power of attorney.
10 Q. And do you know who prepared this document?
11 And that's your signature on the last page, correct?
12 A. Correct.
13 Q. And --
14 A. I'm not positive, that may have been
15 Julanne Skinner, but I don't know who created it, I
16 just know I was present and signed it.
17 Q. Okay. And what is your -- this was signed
18 on August 25th, 2017, correct?
19 A. Yes.
20 Q. And that was a week after -- or shortly
21 after Cabot filed a lawsuit against Mr. Kemble,
22 correct?
23 A. I'm not sure when the date was, but it had
24 nothing to do with that.
25 Q. Okay. So how did it come about that you

163
1 became his power of attorney?

2 A. Mr. Kemble was going in for surgery in the
3 near future after this point so he asked if I would
4 be power of attorney in case something happened.
5 Q. What type of surgery was he going in for?
6 A. I don't -- I don't know that that's any of
7 my business, but he was going in for surgery going
8 to be under anesthesia. So he would never -- he had
9 never been under anesthesia that I knew -- that he
10 said, so I offered to be power of attorney in case
11 something happened.
12 Q. Did he tell you what type of surgery he was
13 having?
14 A. On that one, I'm not positive. I know
15 there was something on his arm that he was getting
16 taken care of.
17 Q. And have you -- based on this power of
18 attorney, you know, this says it gave you the rights
19 to -- to handle any property, including selling,
20 disposing of any real property. Is my understanding
21 correct based on what you testified earlier that you
22 have not sold or transferred any property?
23 A. Correct.
24 Q. Okay. Do you recall in the summer -- I
25 believe it was the summer of 2017 having a group of

164
1 people come to clean up Mr. Kemble's property?

2 A. Yes, there was a group of people cleaning
3 up the property.
4 Q. And who were they?
5 A. Just friends from New York State.
6 Q. Who were those friends?
7 A. I think Bob Nielsen had a group of students
8 that said they would come down to help, so he had a
9 bunch of young people come and help, do some yard
10 work and outside work.
11 Q. And they hauled off some vehicles off of
12 Mr. Kemble's property that day, correct?
13 A. I'm not positive, I don't -- I didn't -- I
14 don't think I was there when that happened. I was
15 there earlier than that.
16 Q. Did Mr. Kemble tell you anything about
17 Mr. Nielsen taking property of his to New York?
18 A. That, he could have, I don't remember.
19 That was a couple years ago, but I don't know
20 anything about what -- what he gave Bob or not.
21 Q. Okay. Now, is this a durable power of
22 attorney, I mean, is this continuing or was there an
23 end date on this? Have you revoked the power of
24 attorney?
25 A. I have not revoked it, but I have not used

165
1 it either. So it's still -- I guess it's still in

2 existence.
3 Q. Okay.
4 A. It's been filed but I -- like I said, I've
5 never acted on it.
6 Q. Okay. It's now 12:31, I think we can take
7 a quick break for lunch. I think 45 minutes, is
8 that enough? Is that enough for everybody?
9 MR. DOUGHERTY: Yeah, that's fine.
10 MS. BARRETTE: Okay. All right.
11 THE VIDEOGRAPHER: Off the record. Off the
12 record at 12:31.
13 (Whereupon, at 12:31 p.m., a lunch recess
14 was taken.)
15
16
17
18
19
20
21
22
23
24
25

166
1 AFTERNOON SESSION
2 (1:17 p.m.)
4 1:17.
5 BY MS. BARRETTE:
6 Q. Mr. Stevens, we're now back on the record,
7 you understand you're still under oath?
8 A. Yes, ma'am.
9 Q. Okay. And you understand -- well, let me
10 ask you this, do you have any answers that you would
11 like to change from the previous questions that you
12 answered? Anything you want to change?
13 A. Not that I know of, but, you know, no.
14 Q. Okay. And while you were at lunch and on
15 break did you have any discussions with your
16 attorney about the substance of this deposition or
17 anything going on --
18 A. No.
19 Q. -- with the depo?
20 A. No.
24 identification.)
25 BY MS. BARRETTE:

167
1 Q. Do you recognize this document?

2 A. Yes.
3 Q. Okay. What is this document?
4 A. This was a filing done in response to
5 the -- well, asking for a February 4th hearing
6 that -- I just want to make sure. Yeah, it was in
7 the filing asking for an order for a hearing in --
8 on February 4th and to have the motion to quash and
9 let me make sure what page this is. Yeah, motion to
10 quash, motion for protection order, motion for
11 sanction. Yes.
12 Q. Okay. So this is -- this is -- my
13 understanding is this is a motion -- is that your
14 signature on the front page, let me ask you that.
15 A. Yes.
16 Q. Okay. And if this appears to be a motion
17 to quash, motion for a protection order, a motion
18 for sanction by you directed to the Court of Common
19 Pleas in Susquehanna County, correct?
20 A. Correct.
21 Q. You signed the document back, correct?
22 A. Yes.
23 Q. I just want to make sure.
24 A. This one, yes.
25 Q. Okay. That is your signature?

168
1 A. Yes.
2 Q. All right. That appears after
3 paragraph 41?
4 A. Yes.
5 Q. Who drafted this document?
6 A. I also worked on this with myself and Bill
7 Huston.
8 Q. Okay. Who actually did the typing of the
9 document?
10 A. He put the captioning and I basically did
11 the words that I wanted put on it and then signed it
12 and printed it out.
13 Q. Okay. Did he help you draft any of the
14 language in the document?
15 A. Some.
16 MR. POSEY: I'm going to object to this
17 line of questioning. You can answer.
18 THE WITNESS: I -- yeah, both. It was --
19 language with basically more people on it.
20 BY MS. BARRETTE:
21 Q. Okay. And who filed the document?
22 A. I filed the document.
23 Q. Okay.
24 (Cabot Deposition Exhibit #10 was marked

169
1 BY MS. BARRETTE:
4 Exhibit Number 10. Do you recognize this document?
5 A. Actually, no, I recognize the last page
6 where I signed it, but -- yes, I mean, I recognize
7 the last page if it's attached to these two then --
8 I never saw this as complete.
9 Q. Okay. So is my understanding then the only
10 thing that you've seen previously is page 3 where --
11 where you've signed as the incorporator?
12 A. Yes.
13 Q. Okay. Where were you when you signed this
14 document, do you recall?
15 A. I'm not positive if it was at my house
16 or -- I'm not sure. It could have been at my house
17 or Mr. Kemble's, but I thought it was at my house on
18 Silver Lake or Silver Creek -- (inaudible).
19 THE REPORTER: I'm sorry, I'm having a lot
20 of trouble hearing you.
21 THE VIDEOGRAPHER: That's fine actually.
22 THE REPORTER: Just keep your voice up.
23 THE WITNESS: Okay. Thank you.
24 I'm not positive because it was awhile ago
25 but it could have been at my house or at

170
1 Mr. Kemble's house.

2 BY MS. BARRETTE:
3 Q. What was your understanding of why you were
4 signing this document?
5 A. As I stated earlier it was basically a
6 parody document for a rebuttal to Energy in Depth,
7 which would have been attacking me and others for
8 years before that.
9 Q. Okay. Is my understanding then that the --
10 well, let me ask you this. Did you understand by
11 signing this that you were actually incorporating a
12 corporation in Pennsylvania?
13 A. This is --
15 you know.
16 THE WITNESS: I -- I know what it said, but
17 I didn't know that this was going to become -- I
18 don't -- I guess I didn't even think when I signed
19 it I thought we were just making some entity up, but
20 I didn't have any idea it was just going to be this
21 detailed.
22 BY MS. BARRETTE:
23 Q. Okay. When you said they had -- you had an
24 idea they were making some entity up, what do you
25 mean?

171
1 A. I -- I just thought it was going to be like

2 a website or something to answer the onslaught of
3 negative things about anything that I was doing and
4 others, but I never -- I know one day I did not ever
5 do anything within it, even though this is set up as
6 a corporation, I never did anything beyond signing
7 this piece of paper.
8 Q. And who asked you to sign this piece of
9 paper?
10 A. Well, it was brought through Ciarimboli's
11 name is on here, Fellerman & Ciarimboli, but there
12 was no -- it was just presented, it was -- the whole
13 team of lawyers; it was Speer, Ciarimboli,
14 Fellerman. I don't think Boylan was there -- was
15 with them then, but it was just basically their
16 response.
17 They were saying it was a response to the
18 Energy in Depth site, so it set something up where
19 we could put contradictory information to show our
20 side kind of thing, but I -- I never did anything
21 beyond signing this piece of paper. As a matter of
22 fact, that is not my writing here on the executed,
23 that's my signature, but that is not my writing on
24 the 16th day of November, I did not write that.
25 Q. Okay. Did there come a time when you had

172
1 what I would say a falling out with the lawyer

2 defendants?
3 MR. POSEY: I'm going to --
4 MR. DOUGHERTY: Objection to any
5 conversations between lawyer defendants and
6 Mr. Stevens.
7 MR. POSEY: I reiterate that objection and
8 instruct you not to discuss any discussions that
9 were for the purposes of legal advice with the
10 attorneys.
11 THE WITNESS: Okay.
12 BY MS. BARRETTE:
13 Q. So let me ask you again. Did there come a
14 time when you had a falling out with -- or when you
15 ended your relationship with the attorney
16 defendants?
17 A. Yes, I -- I ended my relationship just
18 because we didn't move forward with anything that I
19 had worked with them or asked them to work on.
20 Q. Okay. And when did that happen?
21 A. This was '12, November -- beginning of 2013
22 probably.
23 Q. Okay. Do you know a Julanne Skinner?
24 A. Yes.
25 Q. And how do you know her?

173
1 A. Just as a local person that lives in

2 Montrose. So an elected official -- she was an
3 elected official and rural counselor, but just part
4 of a friends group there.
5 Q. Did you say part of a friends group?
6 A. No, just of friends, like Ray and other
7 people. She knew a lot of the people that I knew,
8 so we met through that.
9 Q. And did there come a time when you learned
10 that she was working for Charlie Speer?
11 A. Yes.
13 A. That was when I -- well, when I was asking
14 them if they'd work on the problems that happened on
15 my property. So she was working with them at the
16 time to intake information to give to them, I guess,
17 as an intake person.
18 Q. Do you know -- now, I'm not asking you what
19 communications you had, but were your communications
20 to Charlie Speer, were those done through Julanne
21 Skinner?
22 A. I don't recall. I know that the
23 documentation and intake and then it went to whoever
24 was working on it, I'm -- I'm not sure. So she was
25 just the intake person that took all the

174
1 documentation.
2 Q. Do you know if she acted as an intake
3 person for anybody else, any other residents in
4 Montrose, PA?
5 A. I have no idea.
6 Q. Now, you said Mr. Kemble knew Julanne
7 Skinner, correct?
8 A. Yes.
9 Q. Do you know anything about the nature of
10 their relationship?
11 A. No, I mean, I know it's -- they've been
12 friends for longer than I knew both of them, they've
13 known each other.
14 Q. How long have you been friends -- or let me
15 ask you this, do you know Bill Huston?
16 A. Do I know him? Yes.
17 Q. And how long have you known Mr. Huston?
18 A. Well, personally known as far as
19 friendswise, probably not until about 2014, but he
20 was around earlier than that, a filmmaker. So he
21 was at events that I was at, but I didn't really
22 know him. I just recognized that he was at earlier
23 events.
24 Q. Okay. And you said you then became friends
25 with him in 2014?

175
1 A. Knowing him more than just somebody that I

2 would see at events, yes.
3 Q. Do you know how long Mr. Huston has been
4 living with Mr. Kemble?
5 A. I have no idea the length of time or what.
6 No, I don't know.
7 Q. I want to just back up a little bit and get
8 some background information that we typically get in
9 the beginning of depositions. Did you graduate from
10 high school?
11 A. Yes.
12 Q. And what year did you graduate high school?
13 A. 1978.
14 Q. And where did you attend high school?
15 A. I went to two, University High School in
16 Irvine and then I finished at Tustin High School in
17 Tustin, California.
18 Q. And is my understanding that you grew up
19 and spent your -- you know, I would say elementary
20 through high school years living in California?
21 A. 46 years.
22 Q. Okay.
23 A. 1960 to 2006.
24 Q. Now, did you -- did you go to college?
25 A. I did two years of junior college, but no

176
1 degree, didn't finish my AA, but I have just a

2 few -- I was a few credits short but it didn't
3 excite me going to college.
4 Q. And what were you studying?
5 A. General, just getting ready to go if I
6 wanted to go to a third and fourth year.
7 Q. And what university or college was that at?
8 A. It was Orange Coast College, it's a
9 two-year college in Costa Mesa, California.
10 Q. Now, after the time you spent at Orange
11 Coast College, did you obtain any other type of
12 formal education or training?
13 A. No.
14 Q. Following your time at -- after Orange
15 Coast College, I want to talk a little bit about
16 your work history, employment history. Where did
17 you first start working?
18 A. I mean, I started working at 10 or 12 years
19 old locally doing delivery thing, but my first real
20 job was a place called Ocean Scientific in Anaheim,
21 California, made medical diagnostic testing
22 equipment. I started there, within two years I was
23 running their system test department without a --
24 didn't have a -- a degree, but I was running their
25 system test department.

177
1 Q. And how long were you with Ocean

2 Scientific?
3 A. From 1984 until '90, so about six -- six
4 and a half years.
5 Q. And what did you do after -- after
6 leaving -- well, at some point you left Ocean
7 Scientific, correct?
8 A. Yes.
9 Q. And why did you leave Ocean Scientific?
10 A. 1989 I started Clean Life Systems and began
11 marketing for the -- it was a different company but
12 same air and water.
13 Q. And what were -- is -- you described
14 your -- your -- kind of your job with your marketing
15 with Clean Life Systems as high-tech air and water
16 systems, is that what you were doing when you first
17 started in '89?
18 A. Yes, it was -- it was a different company
19 and they had less high-tech equipment, but it was
20 the same thing, it was water and air systems.
21 Q. Okay. And from '89 forward, has that been
22 like your primary, you know, occupation is doing the
23 marketing and consulting for the air and water
24 purifying systems?
25 A. No, for a few years I did it full-time and

178
1 then I -- in 1992 I started working at my

2 brother-in-law's electronic store that he owned and
3 his dad owned called Action Electronics, it doesn't
4 exist anymore, A-C-T-I-O-N, in Santa Anna,
5 California.
6 Q. Okay. All right. And how long did you
7 work there?
8 A. I stayed there from '92 until '98.
9 Q. Okay. And then what did you do?
10 A. Went to another electronic store closer to
11 my house in Costa Mesa called Marvac, M-A-R-V-A-C.
12 And I worked there from '98 to I think 2002, about
13 four years, three years.
14 Q. And then what did you do after your time at
15 Marvac?
16 A. I start -- I went back into the business
17 full-time about 2003, 2004.
18 Q. When you say "back into the business"
19 your --
20 A. To -- instead of working for somebody else,
21 I went back into the Clean Life Systems business
22 full-time.
23 Q. Okay. And so since 2004, have -- have you
24 done that full-time completely or did you go back
25 and do something else?

179
1 A. I had other work when I -- when I moved

2 from California in '06. I moved because my father
3 got diagnosed with esophogeal cancer in 2006,
4 terminal. And so I picked up my wife, my ex is from
5 Herndon. So I moved the kids and her back here,
6 moved to Reston area and then spent the next year
7 taking -- going up, back and forth and taking care
8 of my dad.
9 So when I got here, I got a job at UPS
10 driving a truck just to have insurance and the
11 things you get when you get into a new location.
12 Q. Okay. And in 2006, were you staying in
13 Pennsylvania or were you staying in Herndon?
14 A. I was living -- I've lived in -- I had
15 lived in Reston. It was in Reston. She's from
16 Herndon, but we lived in Reston from '06 until 2010
17 when I moved up to the house in Pennsylvania.
18 Q. Now, you had said your -- your -- let me
19 back this up. Okay. So -- so since the time --
20 okay. You were driving -- working for UPS, how long
21 did you work for UPS?
22 A. About two years.
23 Q. Two years. So that would have been like
24 2008-ish or --
25 A. Maybe close to nine. Maybe a couple -- two

180
1 and a half years, almost -- almost 2009.

2 Q. Okay. And what happened after 2009?
3 A. Back into more full-time on the business
4 side.
5 Q. Okay. And how long -- now since then,
6 since 2009 have you been mainly focused on the air
7 and water quality systems?
8 A. Yes, yes.
9 Q. Now, you had mentioned your ex, are you
10 currently divorced?
11 A. We're still married but separated for ten
12 years. We just -- we have two boys so neither one
13 of us had the need to finalize it, but we will
14 sometime in the near future.
15 Q. And is -- so I'll just call her your wife,
16 and is that Jenny?
17 A. Yes.
18 Q. And she lives in Reston as well?
19 A. Yes, she lives -- I actually moved into the
20 house that she and the kids were in, she got another
21 house nearby. So we live very close to each other.
22 Q. So the house that you are currently living
23 in, who owns that house?
24 A. A landlord.
25 Q. Okay. Who's your landlord?

181
1 A. Bill, if I can remember his last name. We

2 never see him so -- Bill Wright, W-R-I-G-H-T.
3 Q. Okay. And that's Bill and Carol Wright?
4 A. I think so. I've only seen her name on --
5 if mail comes there by accident for some...
6 Q. Does your brother Mark own any property in
7 Reston?
8 A. No.
9 Q. Okay. And do you -- after your father
10 passed away, could you explain to me like you said
11 you owned the homestead, like the family homestead,
12 the piece of property with the house on it, correct?
13 A. There's two properties there. There's the
14 house property which is about 1.09 acres. Then
15 about a half a mile up the road there's a 115-acre
16 property.
17 When my father passed away, my bother and
18 sister and I inherited his third, so that was
19 one-ninth ownership each. They live -- you know,
20 they live in California, my sister, and my brother
21 in Mississippi. So we had a one-ninth ownership
22 interest and ended up purchasing after -- a few
23 years after that the rest of the ownership interest
24 of the house from the rest of the family. So it's
25 now owned by my brother and sister and I.

182
1 Q. Okay. Is that house paid off completely?

2 A. Yes.
3 Q. Okay. Did you ever have to pay any rent or
4 any type of, you know, money to any of your family
5 members in connection with that house?
6 A. Well, I didn't -- my sister and I did not
7 put the money up, my brother did.
8 Q. Okay.
9 A. And his wife just because they had it. But
10 I did basically pay him back for that. So it was
11 like a loan -- it was like a loan and then I paid it
12 back because I was living there.
13 Q. And with respect to the 115-acre parcel, is
14 that -- that's owned by the three of you now?
15 A. Yes, my aunt and uncle -- we sold -- they
16 sold their interest last year to us.
17 Q. Okay. So in 2010, if my understanding is
18 correct, you moved into the homestead property on
19 the 1.09-acre place, correct?
20 A. Yes.
21 Q. And how long did you live there?
22 A. I lived there for -- from January of 2010
23 to September of 2014. So I guess a little over four
24 years.
25 Q. And where did you move in September of

183
1 2014?
2 A. To Herndon, Virginia, back up here, closer
3 to my kids.
4 Q. And is -- is that the reason that you moved
5 to be closer to your children?
6 A. Yeah, it's been almost five years with
7 seeing them maybe every other week and then a
8 weekend every other. So, yeah, it was to be closer
9 to them.
10 Q. Okay. So if my notes are correct, since
11 2009, you have been pretty much full-time dedicated
12 to the Clean Life Systems as far as the air --
13 marketing and consulting for the air and water
14 treatment, correct?
15 A. 2000- -- yeah, so 2009, that was my
16 primary, yes.
17 Q. Okay. And did that change -- so you said
18 you started doing some other type of consulting as
19 well with respect to property and -- property rights
20 and I think you said contamination from pipelines,
21 correct?
22 A. Yes.
23 Q. Okay. When did that type of consulting
24 work start?
25 A. Well, after the -- well, I didn't consult

184
1 for anybody, I did it on my own because I had a

2 pipeline right-of-way and a gas lease so, as you
3 know, you guys are in the business of giving people
4 some good money for giving their -- giving their
5 property, so I got quite a bit of money from the gas
6 lease and the -- not a ton, but enough money where I
7 was self-supportive and was able to go out and kind
8 of do my own thing.
9 Q. And when did you start doing the consulting
10 for property rights and the pipeline type of work?
11 A. Almost immediately moving there because
12 my --
13 Q. Well, I mean consulting for -- being paid
14 by people for it?
15 A. Oh, well, it started off, as I said
16 earlier, that people would give gas money or put you
17 up somewhere because you are coming to the area. So
18 it wasn't really financial, but then it became where
19 I was asked to go to different places, more places,
20 so that became having to ask for more than just
21 expenses. So I would say that was probably 2015 --
22 I mean it's 2014, 2015, probably.
23 Q. Okay. And in that time period I think if
24 my -- if I'm remembering correctly, you said that
25 you were doing that consulting for Catskill

185
1 Mountainkeeper?
2 A. Yes.
3 Q. Okay. And did you have a set, like,
4 consulting amount per month, was it based on how
5 many times you would go out and do things, how
6 did -- how was that arrangement?
7 A. It became pretty steady working with that
8 and just in my business also on the side, but it was
9 basically a monthly that I would mail them an
10 invoice for.
11 Q. Okay. So you would actually send them an
12 invoice for the -- the work that you did --
13 A. In a month.
14 Q. -- correct?
15 A. Yes, just month to month.
16 Q. Okay. And what was the -- in 2014, what
17 was the monthly, like, an average monthly for an
18 invoice?
19 A. Is that --
20 MR. POSEY: I'm going to object. You can
22 THE WITNESS: It's private financial
23 record, I'm not really interested in sharing with
24 everybody.
25 BY MS. BARRETTE:

186
1 Q. I understand you're not, but we're at a

2 deposition and it's a discovery deposition, so what
3 was the average monthly in 2014?
4 A. About $4,000.
5 Q. Okay. Now, when was -- so you were doing
6 that as well as selling retail, the water systems,
7 and doing the consulting like acting as a
8 representative for the company for a commission
9 base?
10 A. Correct.
11 Q. When was the last time you actually sold
12 retail products, a retail system to someone?
13 A. I've been doing -- still been doing shows.
14 I do trade shows usually every couple of months, so
15 I've been doing it steadily all along. Instead of
16 doing every day going out, like I was doing before
17 with it, I'll do a show once every other month just
18 to -- because it's something I do and I'm good at,
19 so that's kind of why I kind of split the time.
20 Q. So you think you might do like one show
21 every other month?
22 A. Yes.
23 Q. And how frequently -- can you -- do you
24 recall though, like, in 2018, do you recall
25 approximately how many of these systems you sold?

187
1 A. No, I don't.
3 you know.
4 THE WITNESS: Yeah, I don't know. Because
5 I haven't done my final -- that's next week, do my
6 final income information, so I'm not sure.
7 BY MS. BARRETTE:
8 Q. Do you know Wenonah Hauter?
9 A. What's the last name?
10 Q. Hauter?
11 A. No.
12 Q. Hauter?
13 A. Oh, Hauter, yes.
14 Q. Okay. And how do you know her?
15 A. She's the director of Food & Water Watch.
16 Q. Have you any -- ever done any consulting
17 for her that you were paid for?
18 A. No, I'm -- no, it was Catskill
19 Mountainkeeper is the one that does it, but I've
20 done work with them and, as I said, got compensation
21 for expenses.
22 Q. In -- in your answer to our motion for
23 clarification, you had stated -- and I think it's
24 Number 1 -- Exhibit Number 1, you had stated to the
25 Court that you were out in California visiting

188
1 family at the time that we supposedly served the

2 subpoena, correct?
3 A. Yes, ma'am.
4 Q. Was there any other purpose for your trip
5 when you were out in California?
6 A. Another purpose?
7 Q. Mh-hum.
8 A. No, I went on a preplanned trip to visit my
9 daughter lives there and my son and my daughter has
10 my two grandkids, so that was the purpose of the
11 trip.
12 Q. Did Mr. Kemble come out there?
13 A. I saw him at an event towards the end on
14 Tuesday. He was at an event that I was invited to,
15 but I didn't know, I didn't travel with him. I went
16 out on my own and came back.
17 Q. Have you ever assisted Mr. Kemble with
18 things like purchasing plane tickets or ordering
19 plane tickets?
20 A. No.
21 Q. The event that you were out there with
22 Mr. Kemble, can you tell me what event that was?
23 A. It was a movie screening.
24 Q. The movie screening for what?
25 A. You mean the name of the movie?

189
1 Q. Mh-hum.
2 A. Called Blowout, I believe.
3 Q. Is that the Blowout Who's Next that Hope
4 For Peace put together?
5 A. Correct.
6 Q. Can you tell me anything about Food & Water
7 Watch's involvement with that?
8 A. I don't know of their involvement in it. I
9 don't have any idea of their direct involvement in
10 that.
11 Q. Okay. Who arranged for you -- in
12 November 25, 2013, who arranged for you to speak
13 with -- at the U.N.?
14 A. Sisters of Mercy -- U.N. Sisters of Mercy
15 they're called, it's a Catholic Nun group that
16 reached out to me and put -- was able to get me
17 in there. That's who was there hosting me.
18 Q. Okay. And earlier you had mentioned a
19 group, Marcellus -- Marcellus Patriots For Land
20 Rights, correct?
21 A. There's two, that was my original,
22 Marcellus Patriots For Land Rights and then Patriots
23 from the Oil and Gas Shales came from that because
24 that was more the Marcellus focus instead of other
25 areas.

190
1 Q. Are those independent businesses you own or

2 just --
3 A. It's a card.
4 Q. Okay. Have you formed corporations for
5 either of those?
6 A. No, just something to give them that has my
7 name on it.
8 Q. Now, in -- you won an award in -- it was in
9 2015, the Frack Tracker Sentinel Award?
10 A. Yes, ma'am.
11 Q. And during that -- in accepting that award,
12 they -- they published an interview with you?
13 A. Okay.
14 Q. And one of the answers that you gave, you
15 stated, Well, here is the interesting thing, when I
16 moved here there were about 50 people that would
17 show up at public meetings to discuss their
18 firsthand experiences. These were people from
19 Dimock, PA and other surrounding areas. Besides
20 that, there really was no collective organization --
21 organizing in Northeast Pennsylvania, but we found
22 that by telling our stories we brought the interest
23 of organizations like New Yorkers Against Fracking
24 and Mark Ruffalo's group Water Defense, they started
25 to adopt us.

191
1 What did you mean when you said "they

2 started to adopt us"?
3 A. Just becoming interested, they had no idea,
4 but they had a big interest in finding out what was
5 planned to be brought to New York. So "adopting"
6 means coming to find out firsthand and then that's
7 what I understand, that's what I was putting in
8 there, was adopting us like becoming interested
9 enough to start sending people to see what was
10 happening.
11 Q. Okay. And you said I and other families
12 started to travel all over, not only in New York,
13 but also in New Jersey and Ohio to educate people,
14 do you see that -- or I mean did you say that, do
15 you recall saying?
16 A. Yes.
17 Q. Okay. And do you know what other families
18 were traveling with you?
19 A. Not with me, I'm just saying other families
20 were going elsewhere. I know that people were going
21 to -- they're from New Jersey or from elsewhere. So
22 I didn't really travel at that time with many
23 people, although the Sautners were probably the ones
24 that I traveled with the most during that short
25 period of time, but other than that, I traveled

192
1 mostly with myself.

2 Q. Okay. And what about traveling with
3 Mr. Kemble from 2012 do 2015, how often would you
4 say you traveled with Mr. Kemble?
5 A. Not very much at all. Not that -- the
6 traveling with him started mostly after probably '13
7 or '14 even. This in the last four years or so.
8 Q. Okay. And it's -- you talk about -- you
9 said I took -- I was meant to take these stories
10 further out, I took them to all these state houses;
11 North Carolina, Florida, Maryland, New York, New
12 Jersey, Ohio.
13 In taking those stories out and in talking
14 about them, is that part of the consulting you were
15 doing and being paid for by Catskill Mountainkeeper?
16 A. No, that award was in 2015, so I was
17 talking about prior to that where I was basically
18 self funded.
19 Q. Okay.
20 A. Between '10 and probably '13 or '14.
21 Q. Now, when you're out, in speaking and
22 talking about, you know, water issues and things
23 like that, are you -- is that what you would define
24 as your consulting work for Catskill Mountainkeeper?
25 MR. POSEY: I'm going to object. Same

193
1 objection as earlier. You can answer if you know.

2 THE WITNESS: I mean, that's -- any part of
3 it. I -- and I make my own schedule, I go wherever
4 I want to go. So, you know, I'm not directed to go
5 anywhere.
6 BY MS. BARRETTE:
7 Q. No, I understand, that. I'm just trying to
8 figure out, you had mentioned you were receiving
9 like 4,000 a month from them on average, so I was
10 trying to figure out what -- what you provide them
11 for that money?
12 A. Going out and educational outreach is what
13 I call it, educating people as to what to expect
14 when this shows up, good or bad. I mean, I have
15 landowners that actually want to know. Some of them
16 want to move forward with it. So I just let them
17 know what -- I have personal experience, I call it
18 educational outreach.
19 Q. Okay. And does that include going and
20 meeting with, like, the different people and the
21 people that you met with down in Florida, things
22 like that, is that part of it?
23 A. Well, yes, there are already people who are
24 concerned about things and you come down and educate
25 them and then they do with that information whatever

194
1 they want.
2 Q. Okay.
5 BY MS. BARRETTE:
8 Exhibit Number 11. This is a snap from Mr. Huston's
9 blog and he has published an e-mail from you. This
10 was in October of 2016 where you were asking for
11 donations for Mr. Kemble for funeral expenses for
12 his brother.
13 A. Yes.
14 Q. Is that -- taking a look at that, that
15 is -- was that an e-mail that you had sent out
16 for -- on behalf of Mr. Kemble?
17 A. It's an e-mail I crafted, I didn't send it
18 out. This is -- Bill Huston put it out.
19 Q. Okay. So you never e-mailed this to
20 anybody?
21 A. No, it's gone straight to -- the top --
22 this section I created.
23 Q. Okay. When you --
24 A. So if you mean somebody, I might have sent
25 it out to some of the people that I know personally

195
1 that are in that area to help out, but I did not

2 caption it and put it out on a blog, that was
3 Mr. Huston.
4 Q. Okay. Now, at the very end you say Ray has
5 been on the leading edge for eight years in
6 Pennsylvania, New York, California, Florida,
7 Maryland, Colorado and more; what are you talking
8 about there?
9 A. Those are places that I know, not
10 necessarily went with him, but that he has gone to.
11 Pennsylvania of course, New York of course,
12 California, Florida, Maryland, and Colorado. So
13 these are places that I know, either heard about or
14 was with him, that he visited.
15 Q. Okay. Did you ever visit any places in New
16 York with Mr. Kemble?
17 A. New York not really, that was with the
18 Sautners, but Ray very little in New York actually.
19 Q. Okay. What about California, did you ever
20 attend any events in California?
21 A. California, yes. In January of 2013 I was
22 asked to come out. I was asked by Environment
23 California and then I -- Ray was invited but that
24 was separate from me, we didn't fly together, he's
25 in a different area. And then another person from

196
1 Colorado was brought out.

2 Q. And in that -- when you're asked to fly out
3 to places like that, I mean, do you actually
4 purchase and pay for your own tickets?
5 A. On that it was expenses covered so they --
6 they paid for the flight and staying there and it
7 was two days or something. So, no, I didn't have to
8 pay expenses there.
9 Q. Okay. What about Florida, have you
10 traveled to Florida with Mr. Kemble?
11 A. Twice. I've been down there quite a bit,
12 but Ray has gone down twice in the last five years.
13 Q. Okay. And were you with him on those two
14 occasions?
15 A. I -- he drove down himself once and then he
16 drove down in my vehicle on another time.
17 Q. Okay. And when -- what time was it that he
18 drove with you?
19 A. January -- I'm trying to remember. It was
20 2017, I think it was spring 2017, but I have to look
21 again. It might have been fall, I'm just -- I've
22 got to look at it, but I believe it was 2017.
23 Q. Okay. And in -- did you travel with
24 Mr. Kemble to Charlottesville, Virginia?
25 A. Charlottesville -- oh, no, I think he drove

197
1 him -- I drove from here and then he drove himself

2 there.
3 Q. And who arranged for that meeting?
4 A. That is a group in Virginia that is -- it
5 was basically set up as a -- as a conference, but
6 I'm trying to remember it was a -- it was quite a
7 few groups that put it together, so I'm not really
8 sure who the lead group was but it's just groups
9 from Virginia centric.
10 Q. Okay. And did you have anything with
11 helping those -- having to do with helping
12 Mr. Kemble to get to that meeting in
13 Charlottesville?
14 A. No, that was separate. He was separately
15 invited I believe.
16 Q. Okay. What about in Maryland, what -- what
17 do you know about Mr. Kemble attending places in
18 Maryland?
19 A. I attended some with him and some without,
20 but mostly at -- what I did was there was a DEC
21 hearing there that they were having and then another
22 one at the capital. So I think twice with him
23 there.
24 Q. And so you traveled twice to Maryland?
25 A. He came himself, because I'm already here,

198
1 I'm local. So he drove himself, I just attended the

2 same things that he was attending.
3 Q. Okay. Colorado, what do you know about
4 what he attended in Colorado?
5 A. Colorado was a big like conference of
6 learning about gas issues and I'm not sure -- I
7 didn't travel with him, he flew -- of course, he
8 flew out there. And so I don't know anything about
9 that as far as his part of it.
10 Q. Okay. What is Groundswell Rising?
11 A. It's a film that was made by Renard Cohen,
12 it's in Pennsylvania.
13 Q. Okay. And does Mr. Kemble appear in that?
14 A. I'm trying to remember if -- if he does,
15 it's limited but yes, I believe he's in it. I'm in
16 it quite a bit.
17 Q. Okay. And how -- how was it that
18 Mr. Kemble came about to be in that?
19 A. What I understand --
20 Q. If you know.
21 A. What I understand, Mr. Cohen went around
22 and just filmed people at their places. He came to
23 my house in -- it's sort of -- sort of a township,
24 but I'm not positive how he got connected with Ray
25 to do any filming with him, but I thought it was

199
1 mostly group things. But I'm not really sure how he

2 did it, he's kind of -- he spent two years going
3 around all over Pennsylvania, New York, and
4 everywhere else and filming.
5 Q. Okay. And you've been identified as the
6 community outreach coordinator for that -- that
7 film. Is that how you've held yourself out as
8 community outreach coordinator?
9 A. Well, what -- I don't know what the title
10 means, but all I did was promote it in the area for
11 film screenings like in our area and the north in
12 the Southern Tier of New York. So I guess that's
13 what he's calling community outreach coordinator.
14 Q. Okay. And did you also present it down in
15 Florida with Food & Water Watch?
16 A. Yes. Well, they sponsored the tour, but I
17 just went down with the film, yes.
18 Q. And were you paid by Food and Water Watch
19 to do that?
20 A. I don't think at that time, what it was --
21 was they -- basically everything was covered. I
22 think I had room and my wife drove down for most of
23 it, I don't know if I flew down for the -- flew down
24 for that one, but expenses covered.
25 Q. Okay. Okay. Earlier I had asked you about

200
1 Julia Walsh and you said you had never received any
2 payments from her, either you or Clean Life Systems,
3 that you've never received any payments from Julia
4 Walsh, correct?
5 A. I -- if -- yes, that's -- that's what I
6 said.
7 Q. And that in her organization, Frack Action,
8 you said you've also never received any payments
9 from them, correct?
10 A. Not that I can remember, no.
11 Q. Okay. Have you ever received any payments
12 from Mark Ruffalo or Water Defense Fund, you or CLS?
13 A. I'm not sure if that was part of the water
14 truck. Possibly from the water truck.
15 Q. What do you mean from the water truck?
16 A. For the water truck, for water delivery and
17 truck. So I'm just trying to remember if I got
18 something from Water Defense.
19 Q. I'm confused, I thought you said you used
20 your own money to pay for that?
21 A. No, I'm talking about expenses once it kept
22 going after it was going for a while. So that's
23 when I might have gotten help from that. That was
24 part of the money that came in from out of state.
25 Q. Okay. So you think you might have received

201
1 money from Water Defense or Mark Ruffalo?

2 A. It was 2013, so I'll have to look back to
3 see what -- I believe that was 2013 or 2012, so I'll
4 have to look back to see what was sent out or who
5 from.
6 Q. Okay. And when you say for the water, are
7 you talking about for the actual price of the water
8 or are you talking about the 500 that you were
9 paying Mr. Kemble per week?
10 A. I think just keeping the truck going
11 because, obviously, I need to maintain it, so it was
12 probably a little of everything for the truck, for
13 the gas. So I'm not positive, I have to look to see
14 what came in and when for what.
15 Q. Okay. And considering we had discussed
16 earlier we're talking about large amounts and you
17 said you thought anything over $20 was a large
18 amount. Are we talking about potential large
19 amounts of money you received from Water Defense
20 Fund?
21 A. It's possible that it was -- I'm not sure.
22 I have to look to see but I don't recall the exact
23 amounts, but it could be -- yeah, it's larger than
24 what we talked about with -- between Ray and myself.
25 Q. Okay. What about like upwards of like

202
1 $500?
2 A. Oh, that's possible. I mean, with --
3 either 500 could be reasonable or more, I don't
4 know. I don't have the records in front of me, so.
5 Q. Is -- would that have been like a
6 recurring, like monthly, you know, $500 -- let me
7 just be flat out. Were they paying you to pay
8 Mr. Kemble?
9 A. I did the first two -- we started in
10 February of 2012, so I paid the first probably
11 eight -- eight months or a year and then that's when
12 I said outside people came in to help out because I
13 couldn't continue it with my own money.
14 Q. Okay. So after the first eight months to a
15 year, then you were receiving outside money?
16 A. That's what I remember, yes, it just --
17 basically it just couldn't keep it going.
18 Q. Okay. So essentially now what you're
19 saying is that 500 a month was actually paid -- or
20 500 a week was now paid by other groups outside of
21 Pennsylvania?
22 A. After -- yeah, after I started it and got
23 it going, then it became a larger expense than I
24 could do.
25 Q. Okay. What groups were paying for the

203
1 water?
2 A. I don't -- I'm not positive.
3 Q. Or what groups were paying the 500?
4 A. Yeah, I'm not positive because we got --
5 some were in from donations that were direct from
6 people and then some came in from -- and so I'm not
7 really sure who it was, but I'd have to look back in
8 the records to see, but I was getting assistance
9 from a more -- from private donations and then some
10 were from groups, but I'm not positive exactly all
11 of them.
12 Q. Okay. Now, when we were talking about this
13 earlier you didn't mention that, that you were
14 getting this money from groups. Is this something
15 you're just remembering now or how is this coming
16 up?
17 A. I -- it -- like I said, it's five years
18 ago, six years ago, so I'm just trying to remember
19 it here, I don't have the documentation in front of
20 me. But as -- I've been honest and forthright here
21 and I asked everything -- or answer everything with
22 you, I hope you're taking into consideration we're
23 talking five or six years ago. So if you have some
24 different information, I'll be glad to corroborate
25 it if -- if we've got it, but it's a long time ago

204
1 and I'm just trying to help.

2 Q. Okay. Okay. So earlier we had said that
3 the -- in 2012 at the Shale -- the Shale Insight in
4 Philadelphia, you were there with Mr. Kemble,
5 correct?
6 A. Yeah. Well, I was there with the entire
7 group there, but yes, Mr. Kemble was there.
8 Q. Okay. And did you have anything to do with
9 having him come down to Philadelphia?
10 A. No, as a matter of fact came separately and
11 I did not -- I think he was invited by the people
12 who were organizing it.
13 Q. Okay. Do you recall a trip with Mr. Kemble
14 to Albany, New York for a speaking event?
15 A. Refresh -- is there a timeline or am I --
16 I'm not -- I'm not sure.
17 Q. Yeah, I'm sorry, January 30th of 2013.
18 A. January 30th, 2013. Normally if there was
19 an event in Albany I would not be drive -- I mean,
20 normally we drove separately if it was some event
21 that we're both going to. Either -- he doesn't like
22 to drive with other people and driving is -- pretty
23 much drives himself.
24 Q. Okay. Now, you had said that you recalled
25 going to the Catskill Mountain Barn [sic] Fest in

205
1 Woodstock, New York, but I believe you said you

2 didn't have anything to do with Mr. Kemble attending
3 that, correct?
4 A. I drove -- he drove the water truck and he
5 drove it -- I think the water truck was driven out
6 separately than another vehicle. I brought another
7 vehicle. I believe that's -- I'm still trying to
8 remember, that was from 2013, I believe, so it's six
9 years ago, but I'm just doing recollection, if
10 that's -- I'm not sure, but I think that's the case.
11 Q. Okay. Earlier I had asked you about the
12 press conference, that Dimock press conference in
13 February --
14 A. Yes.
15 Q. -- in front of the Post Office. And
16 Mr. Huston talked about -- he actually does a blog
17 post about it and he identifies you. You said you
18 didn't have anything to do with it, you didn't know
19 what those letters were about, is that still your
20 position that you don't know what those letters were
21 about or what he was filing?
22 A. It was done straight from Mr. Kemble, so
23 knowing of it, but -- so didn't know what he was
24 filing. I was not present at it, even though I've
25 been told I was there by quite a few people but I

206
1 was not present. I was in Virginia.

2 But I found out about it after it became a
3 big story the actual -- what was happening because
4 it was in the newspaper, I guess, there right away,
5 so...
6 Q. All right. You said you -- you know it
7 came straight from Mr. Kemble?
8 A. Well, it was from Ray, I don't know who
9 crafted it with him, but...
10 Q. Okay. Do you have any understanding as to
11 why Mr. Huston would have listed you as a media
12 contact in connection with that press conference?
13 A. I have no idea. I was not there, so I
14 would be a bad -- bad person to talk to since I
15 wasn't at the event.
16 Q. Okay. Now, you are aware that Mr. Kemble's
17 lawyer is seeking to withdraw from this lawsuit,
18 correct?
19 A. I've heard that, yes.
20 Q. Do you have any understanding as to why?
21 A. I'm not positive, but I'm not sure whether
22 it's mutual or one sided or the other. I really --
23 I'm not delving into it. I really -- I don't really
24 want to get involved as far as I'm concerned.
25 Q. Okay. Have you talked to Mr. Kemble about

207
1 that?
2 A. He's expressed frustration to me but not to
3 the point where we're talking -- he's talking about
4 specifics, so...
5 Q. Okay. What kind of frustrations has he
6 expressed to you?
7 A. He's not -- I'm sure he's not happy with
8 the circumstance of what's happening to him or
9 what's being done, I can imagine. So all I can be,
10 as his friend, sympathetic. So that's as far as I
11 can get involved in his.
12 Q. But what has he said to you?
13 A. I'm sure he's -- he's had a lot of health
14 challenges, his brother died, we know that -- you
15 just had that there. So this is, I think, a lot for
16 him to go through. So I'm not really sure what his
17 beef is with anybody else, but he's not confiding
18 anything about the case to me, but he's just
19 confiding in his own personal feelings about being
20 upset and nervous and things like that. So I don't
21 know what the exact problem is going on.
22 Q. Okay. Well, you understand that, you know,
23 all of this is going on right now is because
24 Mr. Kemble decided to sue Cabot again, correct?
25 A. I --

208

2 you know.
3 THE WITNESS: I -- yeah, that's what I'm
4 hearing, but I don't know that from firsthand.
5 BY MS. BARRETTE:
6 Q. Okay. Did you have any conversations with
7 Mr. Huston about drafting discovery to send to
8 Mr. -- or Attorney Raiders in this case?
9 A. Discussions about drafting discovery, no,
10 but asking about -- questions about who might be
11 somebody to talk to or to do something. So that I
12 had a conversation with, but I didn't draft any
13 document or put anything together.
14 Q. Okay. So you recall having conversations
15 with Mr. Huston about, if I understand what you're
16 saying, you had conversations with Mr. Huston about
17 when you say who to talk to, are you talking about
18 who to subpoena, who to depose?
19 A. Who would be able to speak on the other --
20 Ray's side. So I guess -- but I didn't draft
21 anything or do anything else besides that, just
22 thinking of people that might be interested in
23 giving their opinion.
24 Q. You mean giving their opinion in court?
25 A. I have no idea. I mean, just -- just

209
1 somebody to have it -- just -- it just seemed to me

2 Ray is basically on his own. That's -- he's got --
3 he's on his own and he's got the previous lawyers
4 are on another side. So I can see his position was
5 pretty upset so I was just thinking about people
6 that -- when I think about that, I'm just thinking
7 about people like even myself that can -- that can,
8 you know, offer whatever I can. But, like I said,
9 I'm not -- I can't help him, I'm not a lawyer so I
10 can't help him with any of the...
11 Q. Yeah. Do you have any understanding of why
12 everybody has bailed on Mr. Kemble?
14 you know.
15 THE WITNESS: I don't know. It would be
16 speculation on my part, so I have no idea.
17 BY MS. BARRETTE:
18 Q. You can speculate.
20 BY MS. BARRETTE:
21 Q. It's a -- it's a deposition.
22 A. You're saying -- I heard you say "bailed,"
23 I don't know about "bailed," but --
24 Q. Well, you --
25 A. It seemed like everybody in the community

210
1 has been silenced by your company, so that's

2 different than bailed. There is -- there's a
3 difference between evaporation and -- so I don't
4 know if -- I don't know if I would use the term
5 "bailed." I would think that he lost contact with
6 most of his neighbors because they can't talk
7 anymore just like he's not supposed to talk. So
8 I -- that's all I could say on it, so I wouldn't --
9 I don't know if I would use the term "bailed."
10 Q. Okay. Well, you -- you attended -- or you
11 were with Mr. Kemble, he allowed you to use samples
12 of his water to hold up at different events, you
13 know, you were at his home and doing interviews with
14 him in -- with different people. You haven't been
15 to one of his hearings though, correct?
16 A. No.
17 Q. So you haven't been in court to support him
18 one time, correct?
19 A. No, I'm busy with my family and it's a -- I
20 have an electric car now, it's about a 20-hour round
21 trip to go up there so I was not able to make it.
22 Q. Okay. Did you have any conversations with
23 Attorney Raiders about this case?
24 A. About the case?
25 Q. About any -- well, when is the last time

211
1 you spoke with Attorney Raiders?

2 A. Speaking with him, I wasn't, it was -- I
3 was talking to Ray and I guess he was there,
4 present. So I spoke to him there just about how I'm
5 kind of upset about how Ray is feeling and whatever,
6 but that's the last time I communicated with him.
7 Q. Okay. So you said -- you told Mr. -- or
8 Attorney Raiders that you were upset about the way
9 Ray was feeling?
10 A. About how that he has to go through this.
11 I was just feeling sympathetic about Ray having to
12 go through all this and what it might be doing to
13 him stresswise and everything else. I was asking
14 him to do his job and help him out, that's what I
15 basically said, I'm pretty sure.
16 Q. Okay. And did you threaten some type of
17 sanctions or reporting Attorney Raiders to the bar
18 association?
20 you know.
21 THE WITNESS: I -- I'm not sure what I
22 said. It was a conversation, so I was upset, so I'm
23 not sure exactly what I said.
24 MS. BARRETTE: What are we on?
25 MR. PILSNER: 12.

212

3 BY MS. BARRETTE:
4 Q. Okay. Are you aware that Mr. Huston has
5 sent an e-mail to Attorney Raiders talking about
6 discovery that should be served in this case?
7 A. Probably best that I read that.
8 Q. You've been handed what's been marked for
10 Do you recognize that document?
11 A. I don't recall seeing it in this form, but
12 I know that these are some of the names that I just
13 said in the pack, but I'm not sure if it was sent to
14 me or not or if I saw it.
15 Q. So it is -- it says on page 2, which is
16 kind of the end of the e-mail, it says -- it says
17 thank you, William Huston, next friend, with Craig
18 Stevens, power of attorney for Raymond Kemble. Do
19 you see that?
20 A. Yes.
21 Q. Did you authorize Mr. Huston to send this
22 on your behalf?
23 A. Not necessarily. So I'm -- I'm finding
24 today -- learning about a lot of things my name was
25 put on that I didn't necessarily approve, but he was

213
1 right, Craig Stevens POA, but I -- I didn't put the

2 document together or draft it, so I wouldn't say I
3 gave him my permission, but...
4 Q. Did you know anything about that he would
5 be -- prior to him sending this e-mail, did you know
6 that he was going to be sending something like this?
7 A. No, no.
8 Q. Do you understand that he's identified you
9 as a defense witness?
10 A. I don't know where that came from, I've
11 never discussed about being a defense witness,
12 but...
13 Q. So Number 3, it says, Have you filed a
14 motion to quash for any of Cabot's discovery
15 requests against Mr. Kemble or any of the witnesses
16 for the defense, Julanne Skinner, Craig Stevens, or
17 Bill Huston; do you see that?
18 A. Yep.
19 Q. So did you ever tell Mr. Huston you were
20 going to be a witness for the defense?
21 A. No, matter of fact I think -- I'm -- I'm
22 reading this now because I hadn't seen it, we happen
23 to be the three nonparty witnesses, but I wouldn't
24 call my witness for the defense. I'm not defending
25 myself against anything but --

214
1 Q. No, the --
2 A. No, I didn't know this.
3 Q. The defense meaning the witnesses for
4 Mr. Kemble?
5 A. Am I a nonparty person or am I a witness
6 for Mr. -- I don't understand what I'm doing here
7 today if I'm a -- I thought I was a nonparty person
8 that you're deposing. But I wouldn't consider
9 myself a witness for the defense.
10 Q. Here at this particular deposition you are
11 a nonparty witness, it's a discovery deposition.
12 A. Right.
13 Q. But were you intending for future when this
14 goes to trial, if it should get to trial, are you --
15 have you identified yourself to Mr. Huston as a
16 witness for the defense?
18 you know.
19 THE WITNESS: No. Matter of fact, I'm not
20 very happy being here for six or eight hours, so I
21 really don't want to spend a lot of time driving
22 back up to Susquehanna County to be a part of it.
23 So, no, I was not interested in that.
24 BY MS. BARRETTE:
25 Q. Okay. Number 10, Mr. -- Mr. Huston talks

215
1 about a large team of Lawyers Guild attorneys on the

2 case. Someone said on the first call, Cabot doesn't
3 have deeper pockets than we do. And then he asked,
4 What happened to this team and those deep pockets.
5 Were you on that initial call?
6 A. I might have been on that, yes.
7 Q. Okay. Who was -- who all were -- who all
8 was on that call?
9 A. Well, I think it was the people that
10 eventually picked up the case, I don't know what.
11 Q. Who are the people that eventually picked
12 up the case?
13 A. Well, one of them is on the phone right
14 now.
15 Q. Yeah, Attorney Raiders. Who else?
16 A. Right. I -- I don't know all the people, I
17 don't know all the names. He would know better
18 because he was on the phone, but I know his name,
19 but I don't know the other lawyers that were on the
20 call or the other people that were on the call.
21 Q. Okay. And you recall the --
22 MR. RAIDERS: I'm going to object to
23 further questions on this for privilege purposes.
24 MS. BARRETTE: Well, there is no privilege
25 because as you've repeatedly said Mr. Stevens is not

216
1 your client. So if he was on the call

2 participating, there is no privilege.
3 MR. POSEY: I'm going to also object,
4 the -- to the extent -- actually, I need to confer
5 off the record with my client for one minute about a
6 privilege issue about this specifically, whether to
7 instruct him not to answer or to allow this to go
8 forward. Can we go off the record?
9 MS. BARRETTE: Sure. That's fine.
11 (Off the record.)
13 2:33.
14 BY MS. BARRETTE:
15 Q. Okay. Mr. Stevens, before we took a break
16 your counsel here today wanted to take a break to
17 try to determine whether you had a privilege issue
18 with respect to that phone call. I'd like to go
19 back and talk about that phone call.
20 What all was discussed -- or let me first
21 start this. Attorney Raiders was on the call, you
22 were on the call, Mr. Huston was on the call; do you
23 recall any of the other people who were on that
24 phone call?
25 A. There were other attorneys, I don't

217
1 remember the names, but I think there was another

2 five total that I remember.
3 Q. Do you know where they were from?
4 A. No, they're all -- from what I could hear,
5 they were all over the place, Pennsylvania and New
6 York, I believe, but I don't know because I
7 wasn't -- didn't ask, didn't do a rollcall of where
8 people were from.
9 Q. Okay. And originally when we were talking,
10 you had said that you were out there trying to find
11 attorneys for -- or an attorney for Mr. Kemble to
12 represent him in this case when he was first sued by
13 Cabot, correct?
14 A. When he was first sued by them?
15 Q. Mh-hum. Well, he was only sued one time by
16 us?
17 A. Right, but I'm just trying to figure out
18 the wording there, so...
19 I mean, yeah, when he was sued he was
20 trying to figure out how to find somebody to help
21 him.
22 Q. Okay. And was this phone call part of your
23 efforts to help him obtain counsel?
24 A. The phone call was not even set up by me,
25 but it -- but I was on it just because I was trying

218
1 to help him, but, yeah, trying to -- trying to

2 get -- find him some kind of counsel.
3 Q. Who set up the phone call?
4 A. Well, I'm not positive, I think Ray himself
5 found somebody that he had a contact with that had
6 brought on other people on the phone to help out,
7 but I didn't set up the phone call. I was just on
8 the phone call.
9 Q. Okay. And Mr. Huston was on the phone call
10 as well, correct?
11 A. Yes.
12 Q. Were you all -- were you with Mr. Huston at
13 the time of the call?
14 A. No.
15 Q. So is this a situation where people had
16 dialed in?
17 A. Yes.
18 Q. So do you recall the statement someone
19 said, Cabot doesn't have deeper pockets than we do?
20 A. I believe I heard the statement, but I
21 don't know who -- I don't remember. There were six
22 other people on the call, so I'm not positive who
23 said it.
24 Q. Now, in the rest of the -- do you recall
25 having any other phone calls, you had mentioned the

219
1 one phone call with Attorney Raiders where you were

2 expressing dissatisfaction over the way Ray was
3 feeling, there's this call. Do you recall having
4 any other conversations with attorneys, not in
5 connection with representing you, but with
6 representing anybody else in this case?
7 A. No.
8 Q. Okay. Now, after paragraph 11, Mr. Huston
9 goes on, Mr. Kemble wants to know in his words what
10 the fuck is going on. And he says, Rich Raiders, in
11 bold, if you blow this case either by negligence,
12 incompetence or corruption, Mr. Kemble will become
13 very unhappy. And then he goes on to give two
14 directives. He said that Mr. Kemble will be sending
15 a list of discovery requests over the next few days
16 and he's saying that Mr. Kemble directs you to put
17 these on your letterhead and send these over to
18 Cabot's attorney and opposing counsel is required
19 within 24 hours of your receipt. Do you see that?
20 A. Yes.
21 Q. Okay. Did you have any discussions with
22 Mr. Huston about discovery that would be sent to
23 Attorney Raiders?
24 A. No, just in what we talked about earlier
25 which was some ideas of who -- who might be

220
1 interested in doing something.

2 Q. Okay. When you said who might be
3 interested in doing something?
4 A. Just being supportive or whatever.
5 Q. Do you mean -- I'm not sure what you mean
6 who might be interested in being supportive?
7 A. There's a -- I'm looking past this, there
8 is a big giant list so I don't know what the reason
9 to have the people on here, there's elected
10 officials, there's all this. So just -- I don't
11 know.
12 I mean, Ray was expressing he was not happy
13 with the way they were going so, like I said, I
14 don't know if you've been around him very much, but
15 I don't like being around him when he's unhappy,
16 like he's in here too. So he was not happy, so that
17 was the purpose of trying to figure out...
18 Q. Okay. And he said after -- he said after
19 Mr. Kemble -- he wanted him to file -- submit a
20 motion to quash as well. And then he said, Please
21 forward your e-mail of these to opposing counsel, to
22 Mr. Kemble, Craig Stevens, and me; do you see that?
23 A. Yes.
24 Q. Did you ask Mr. Huston to have the proof of
25 discovery sent to you?

221
1 A. No.
2 Q. Were you working with Mr. Huston to try to
3 direct discovery in this case?
4 A. No.
5 Q. Now, did Mr. -- do you know did Mr. Kemble
6 recently have surgery?
7 A. Did he have -- recently have?
8 Q. Yes.
9 A. I mean, that's Ray's business, but that I
10 know of, yes.
11 Q. Okay. And when was that?
12 A. I think a couple weeks ago.
13 Q. Okay. And what type of surgery was it?
14 A. I -- I don't get involved in his medical
15 matters.
16 Q. You didn't ask him?
17 A. Well, I know it was lower abdominal, but I
18 don't know exactly what they were doing, so...
19 Q. Okay.
20 A. It was not -- if you want on -- on here
21 "unhappy" make it caps because he's not doing very
22 good so -- not fun to watch.
23 Q. What do you mean "unhappy"?
24 A. He's in bad shape.
25 Q. What do you mean "bad shape," bad shape

222
1 about what?
2 A. Bad shape physically.
3 Q. And when did that start?
4 A. When he had lower abdominal surgery a
5 couple weeks ago.
6 Q. Prior to that, I mean, he seemed like he
7 was in pretty good shape looking at the video of him
8 out at the Blowout Who's Next premier?
9 A. Honestly still that was another surgery
10 just prior to -- not to -- I mean, months before,
11 but not too close and then this one has been a
12 secondary one, so. No, he wasn't -- he wasn't in
13 very good shape there either.
14 Q. Okay. But he still made the trip?
15 A. I -- I didn't -- I didn't set any of that
16 up, so I didn't know he -- I didn't know until I was
17 there at the -- I was invited separately to the
18 screening because I was nearby about 30 miles away.
19 Q. I understand. But even though you said he
20 wasn't in very good shape then, he still made the
21 trip, flew all the way out to California, correct?
22 A. He got out to California somehow.
23 Q. Okay. Now, did you have -- so this Raymond
24 Kemble subpoena list for discovery on the back, did
25 you have anything to do with identifying people on

223
1 that list?
2 A. I'd have to look at it to see. I offered a
3 few, like, the elected officials at the top, DOH and
4 then federal, but not to send out something like
5 this, just to -- as ideas on...
6 Q. On who to subpoena?
7 A. Not to subpoena, just to have referenced.
8 I mean, you have EPA there, you have the Department
9 of Health, you have -- like I said, I didn't produce
10 this document. I didn't know it was going out. I
11 didn't know it was being copied and I didn't know my
12 name was written -- put on this, the POA, so I'm not
13 really sure what...
14 Q. Okay. Okay. Now, recently Mr. Huston
15 posted on his Facebook naming you again. He posted
16 an article about he has Breaking, Pittsburgh
17 Post-Gazette, PA Attorney General Josh Shapiro is
18 investigating the oil and gas industry. He said I
19 was in Harrisburg on May 4, 2017, by the way.
20 Were you in Harrisburg with him at that
21 time?
22 A. Yes.
23 Q. Okay. He goes on to say that the leaders
24 in this, meaning the investigation, have been you,
25 Ron Gulla and Ray Kemble. Let me mark this.

224

3 MS. BARRETTE: What are we? 12?
4 MR. PILSNER: 13.
5 MS. BARRETTE: 13.
6 BY MS. BARRETTE:
7 Q. Were you -- was Mr. Kemble present there as
8 well?
9 A. Yes.
10 Q. Okay. In 2017, who were you talking to?
11 A. The Attorney General's Office.
12 Q. Okay. And was -- is Mr. Huston's statement
13 correct that the leaders in getting this
14 investigation going -- the article talks about an
15 investigation of Range Resources. Were you one of
16 the leaders, you, Ron Gulla, and Ray Kemble in
17 getting this investigation against Range Resources?
18 A. No, I've been asking for an attorney --
19 meeting with the attorney general since 2010, so
20 this was seven years into it, but -- yeah, that was
21 the meeting was general and it was interviews to me
22 and others that came to find out more about what's
23 happening out in the field. So he's saying leaders,
24 but it's just -- I asked for a meeting and I was
25 given a meeting that day on May 4th, 2017.

225
1 Q. Okay. At that meeting, did you advise them

2 that you were paid thousands of dollars a month by
3 activist groups?
4 A. They didn't ask anything about getting
5 paid. They were very interested in my firsthand
6 knowledge of my own property because all I brought
7 there for myself, talking about for myself was the
8 damage to my property and that my property had never
9 been cleaned up and they informed me that the
10 statute of limitations on property damage is 20
11 years not five years like water.
12 So I learned some things from going there,
13 but my interview with them was private. They won't
14 even tell you anybody that was there, they will not
15 give out any information. They won't tell us if
16 there's any -- anything going forward. But I will
17 just tell you that they -- they were interested in
18 mine just because of the property damage part of it
19 itself.
20 Q. Okay. My question is -- is a little --
21 maybe you didn't understand it. At the time you
22 were down there talking to them, did you tell them
23 that you were being paid thousands of dollars a
24 month by environmental activist groups?
25 A. It didn't matter -- they didn't ask it and

226
1 it didn't matter. It was on my -- it was -- that

2 had nothing to do with me talking about my private
3 property being contaminated. That was -- that was
4 of more interest to them.
5 And, by the way, they came to my property
6 about seven months later, drove out and the team to
7 see what was -- what had happened to the property.
8 So that was the second meeting. And I had a third
9 meeting just a couple of months ago where I was
10 asked to come back to the building, so that's three.
11 So obviously they took me seriously and
12 they didn't ever ask me one word about my financial
13 situation or where -- anything that was happening,
14 so...
15 Q. But didn't you say earlier that you were
16 being paid by Catskill Mountainkeeper to talk about
17 the damage that happened to your property and
18 pipeline contamination?
19 A. To educate people about the potential
20 problems, yes, but what I went there for was my
21 own -- the -- what happened to my property which has
22 still not been resolved.
23 Q. Do you have -- are you claiming that your
24 water was contaminated by something that happened on
25 your property?

227
1 A. Well, my water -- they blew out my creek

2 eight times, I'm the Number 1 property in the
3 Commonwealth of Pennsylvania to have eight -- only
4 one to have eight blowouts in two and a half months.
5 The -- (unintelligible) -- have -- every three days
6 and then it became two and a half months that my
7 creek ran like the Mississippi.
8 So that's why I think they were interested
9 because I had a -- it was -- putting in the -- and
10 your gas goes through it by the way, Cabot's gas
11 goes through it. It's a ways from midstream, which
12 is now the Williams, that goes across my family's
13 property. You're welcome.
14 And so -- well, I'm just saying that's part
15 of the process of you guys getting it out. So I get
16 pegged as this bad guy to everybody, but somehow our
17 family let the pipeline get put in, but in the
18 process they really had some problems installing it
19 behind my house. And so that was my claim, was
20 my -- the water quality in the back creek behind my
21 house was damaged and there was interest from, you
22 know, everybody. The EPA came out, the DEP came
23 out, and then the AG's office was interested.
24 Q. And that happened when?
25 A. 2011.

228
1 Q. Okay. And are you saying that the water

2 still doesn't run clear?
3 A. Well, I didn't talk about my water problems
4 from --
5 Q. I'm talking about the water, you said it --
6 it -- you had inadvertent returns when you were --
7 they were drilling under the stream, correct?
8 A. Yeah, but -- no, I'm not talking about --
9 they have not -- the water is clear now, but there
10 is still drilling right on the -- on every rock, you
11 can scrape the mud right off your finger -- come off
12 on your fingernails still.
13 So there is still debris there, and that
14 was behind my house, not my big property where they
15 had another huge problem up there. So I had both
16 properties, that was my introduction to them.
17 Doing -- blowing my creek eight times and then a few
18 months later they went up and had some more problems
19 on my big property.
20 Q. Okay. And you're not attributing that in
21 any way to Cabot, correct?
22 A. Oh, no.
23 Q. Okay. Now, earlier when we were talking
24 about the consulting payments that you were
25 receiving you said you were receiving them from

229
1 Catskill Mountainkeeper and you said you had never

2 received any from Frack Action or Julia Walsh or
3 Food & Water Watch, correct?
4 A. Yes, but I'm just -- like I said, I'm
5 trying to recall so I'd have to look at my records
6 to see exactly where any payments came from before
7 Catskill Mountainkeepers. I didn't bring those, I
8 brought my total financials but not my individual
9 line item.
10 Q. Right. Are you saying now that you think
11 you remember getting paid from Food & Water Watch?
12 A. I would have to look and see, but there is
13 a possibility that there was some monetary and I'm
14 not sure who from and then we co-mingled the truck
15 information, which is separate from that, that
16 wasn't for anything I'm doing now. So I'm not
17 positive, I'd have to -- I'd have to review.
18 Q. Right. You had said -- I think you -- I
19 believe you said specifically you weren't getting
20 consulting payments from them, but you were getting
21 payments for travel from Food & Water Watch,
22 correct?
23 A. I know I got travel expenses, yes.
24 Q. Okay. Are you changing your testimony now
25 to say that you received consulting from them as

230
1 well?
2 A. I have to look to see because the time
3 frame was if there was any, it was short before
4 Catskill Mountainkeeper. So I just have to -- I'd
5 have to look to see. I -- I'm not positive.
6 Q. Food & Water Watch was paying you, correct?
7 They were paying you thousands of dollars a month,
8 correct?
9 A. I --
11 BY MS. BARRETTE:
12 Q. You're under oath, Mr. Stevens.
14 you know.
15 THE WITNESS: Yeah, I mean, there was a
16 transition period where it went from getting
17 expenses and then it went to Catskill
18 Mountainkeeper, but I'm not sure there was some
19 payments then that I'm -- now that you're bringing
20 it up, that was between the expense money and
21 Catskill Mountainkeepers, but it's been Catskill
22 Mountainkeepers basically for the last few years.
23 Q. And the reason it's Catskill
24 Mountainkeepers is because Food & Water Watch was
25 trying to hide the fact that they were paying you

231
1 and so they are now paying Catskill Mountainkeepers

2 who then funnels the money to you, correct?
3 A. Well, I don't --
5 you know.
6 THE WITNESS: I don't know that that's
7 happening. I know that it's a group of -- it's a
8 group of the groups, not specifically one that I
9 know of, but I know I invoice Catskill
10 Mountainkeeper and they send me the money. So where
11 that comes from on the other end of the funnel, I'm
12 not positive.
13 Q. So when you say a group of the groups, what
14 are you talking about?
15 A. Well, there was a larger amount of groups,
16 I mean, from what I understand. So it's more than
17 one group in the Catskill Mountainkeepers is -- is
18 basically the one that I invoice for...
19 Q. So you invoice, but you know that there are
20 larger groups that are contributing to them to pay
21 you, correct?
22 A. I haven't heard exactly, but I know that's
23 a possibility.
24 Q. What do you mean you haven't heard exactly?
25 A. I don't know exactly where the funds come

232
1 from, except for when I send an invoice to Catskill

2 Mountainkeepers, that's where the check comes from,
3 so...
4 Q. How did it come about that your invoice --
5 who did you deal with when you were told to start
6 invoicing Catskill Mountainkeeper?
7 A. Catskill Mountainkeeper called me. So --
8 and said that they would be able to do the invoicing
9 and have me send it to them, so that's where I got
10 communicated with them.
11 Q. Who in particular? Who was the person?
12 A. I'm not positive. Usually it's Wes
13 Gillingham that I communicate with, but I'd have to
14 find out who it was that called me to say that --
15 start sending an invoice there.
16 Q. Okay. And what conversations did you have
17 with Mark Ruffalo about being paid this consulting
18 fee?
19 A. With Mark Ruffalo?
20 Q. Mh-hum.
21 A. I don't think Mark is aware of all this
22 going on, but I'm not positive.
23 Q. You don't think Mr. Ruffalo is aware that
24 you're being paid thousands of dollars from the
25 company that he's on the board of?

233
1 A. I've never talked to him directly about

2 payments to me.
3 Q. Okay.
5 MR. PILSNER: Mh-hum.
8 BY MS. BARRETTE:
11 Exhibit 14. Okay. This is a series of checks from
12 Food & Water Watch to you to Clean Life Systems,
13 November, December of '13, January of '14, February
14 of '14, March of '14, May of '14, June of '14, and
15 August of '14.
16 The payment January 1st of 2013 was $3,000,
17 it was page 1 and at the bottom it references a Food
18 & Water Watch contract; do you see that?
19 A. Which one?
20 Q. The very first page.
21 MR. POSEY: I'm going to object to the line
22 of questioning in this exhibit as I have no idea how
23 these documents were obtained. I -- I understand
24 from Mr. Stevens that he didn't provide his -- these
25 checks or his financial information and didn't

234
1 authorize this.
2 Go ahead. You can answer the question if
3 you know.
4 THE WITNESS: I -- so page 1?
5 BY MS. BARRETTE:
6 Q. Page 1, the very first page, there's a
7 check from Food & Water Watch to Clean -- to Craig
8 L. Stevens that you deposited in Clean Life
9 Systems, dated November 22nd, 2013 in the amount of
10 $3,000 and it references a Food & Water Watch
11 contract; do you see that?
12 A. Yes.
13 Q. Okay. Earlier --
14 A. Where do I read this?
15 Q. Food & Water Watch contract is down in the
16 memo line.
17 A. Okay. Got it.
18 Q. Okay. Now, earlier I'd asked you if you
19 had a contract with Food & Water Watch, you said no?
20 A. I -- yeah, I didn't realize that there was
21 a contracted -- that I was sending them -- okay. So
22 I was wrong earlier.
23 Q. So you do have a contract with Food & Water
24 Watch?
25 A. I don't -- I don't now. I think this is,

235
1 what, seven or eight months, I said there was a

2 transition, but I didn't realize. I didn't have a
3 chance to pull information here.
4 Q. Okay. The next check in December of '18 of
5 2013, there's a $3,000 payment from Food & Water
6 Watch to Clean Life Systems, care of Craig Stevens
7 and the memo line reads for services rendered
8 December 1st through the 31st.
9 What services were you rendering to Food &
10 Water Watch?
11 A. Well, I was just doing the same work I'm
12 doing now.
13 Q. And that is?
14 A. Just educational outreach.
15 Q. So going around and talking about
16 contamination, trying to stop the oil and gas
17 industry, correct?
19 you know.
20 THE WITNESS: The same thing I spoke about
21 earlier, I haven't changed what I'm doing.
22 BY MS. BARRETTE:
23 Q. Okay. Okay. And there appears to be a
24 check from Food & Water Watch to you for $325.15; do
25 you see that?

236
1 A. Yes.
2 Q. Is that one of those travel reimbursements?
3 A. Travel expense, yeah.
4 Q. Okay. Yeah. Then there's -- the next page
5 there's a check, January 7th, 2014, in the amount of
6 $3,000, the memo line says invoice for January 2014?
7 A. Okay.
8 Q. At any time when you were out doing the
9 community outreach, did you tell any of the people
10 you were speaking to that Food & Water Watch was
11 paying you thousands of dollars a month?
12 A. They knew I was being compensated but I
13 didn't share who I was being compensated by.
14 Q. How did they know you were being
15 compensated?
16 A. They -- people ask, what do you -- how --
17 why are you doing this and how are you doing it, I
18 said because I'm being supported by groups that are
19 interested in getting the -- our side of the story
20 out.
21 Q. I've never seen -- in all the research I've
22 done, I've never seen you ever make that public
23 statement to any reporters.
24 Did you ever tell any of the reporters that
25 you've spoken to that you were paid thousands by

237
1 Food & Water Watch?

3 you know.
4 THE WITNESS: Did I ever tell them?
5 They've asked and I've said yes, but maybe that
6 didn't make the story line.
7 BY MS. BARRETTE:
8 Q. Can you turn the page, do you see there's a
9 check in the amount of 136.09, February 21st, 2014.
10 Now, earlier I had asked you does Food & Water Watch
11 ever pay the water bills, you said no. And the memo
12 line, Food & Water Watch is paying the water bill
13 there, correct?
14 A. Yeah, I mean, I guess that's one, one water
15 bill, but I don't remember it, so I'm just realizing
16 it for the first time here. I've been getting water
17 bills for eight years, so...
18 Q. Okay. The next check is dated 3/28/2014 in
19 the amount of $3,000, do you see that?
20 A. Yes.
21 Q. Okay. And it says for April 1st to April
22 30th, 2014?
23 A. Okay.
24 Q. What type of services were you providing
25 then?

238
1 A. It's the same -- same thing I've been

2 doing.
3 Q. And at any -- any time when you said you've
4 been meeting with the Attorney General's Office
5 since 2010, at any time did you tell them that you
6 were being funded by environmental activist groups?
7 A. No, they didn't ask.
8 Q. Okay. The next page, the check is dated
9 May 8th, 2014, in the amount of $6,000 from Food &
10 Water Watch, and it's for services May 1st through
11 May 12th of 2014. Did your rates go up?
12 A. No, I don't know what that one is. It
13 might have been two put together. Let's see. Yeah,
14 I'm not positive why that one was two times.
15 Q. How much of this money that you were
16 receiving from Food & Water Watch did you pay
17 Mr. Kemble?
18 A. 2014, none.
19 Q. And no money paid to him in 2014?
20 A. Nope. The only time I gave Mr. Kemble
21 money was in 2012 for water -- delivering water from
22 the water truck, but 2014 was doing nothing with
23 him.
24 Q. Okay. Have you been making the house
25 payments or the loan payments for Mr. Kemble?

239
1 A. Been making the loan payments? I have made

2 a couple, but I'm not making the house payments on a
3 regular basis.
4 Q. Okay. So two seconds ago you said you
5 haven't made any payments to Mr. Kemble since 2012
6 or 2013, now you're saying you are making payments
7 to Mr. Kemble?
8 A. To him or --
9 MR. POSEY: Objection. Go ahead and answer
10 if you know.
11 THE WITNESS: Yeah, I'm not paying
12 Mr. Kemble, I'm paying the house payment.
13 BY MS. BARRETTE:
14 Q. Oh, so you're -- I see what you're saying.
15 So you're actually -- you split that and -- okay.
16 So what other bills were you paying on Mr. Kemble's
17 behalf?
18 A. I have paid an electric bill before and a
19 few other bills. He's disabled and it's wintertime,
20 so I'm not sure what the question is, if he's a
21 friend of mine and he needs help, I can -- I'm
22 allowed, I believe, to pay whatever I want to to
23 help out.
24 Q. Okay. June of 2014, the next page shows
25 you receiving 4,000 from Food & Water Watch and the

240
1 memo line says Craig Stevens contract; do you see

2 that?
3 A. Yeah.
4 Q. And again, earlier you testified there was
5 no contract, correct?
6 A. I did not -- I misspoke then. I didn't
7 know when the transition to Mount -- or
8 Mountainkeeper was, so obviously you do.
9 Q. So who were you -- who did you negotiate
10 with at Food & Water Watch to obtain these monthly
11 payments?
12 A. Who with?
13 Q. Mh-hum.
14 A. Well, I'm not sure who set it up exactly.
15 It's normally through their -- I'm guessing it's
16 through their financial side, whoever handles their
17 money.
18 Q. Well, who did you speak to at Food & Water
19 Watch about receiving compensation?
20 A. Normally that would be Emily.
21 Q. And is that who you first talked to about
22 getting paid by Food & Water Watch?
23 A. They offered me to be able to do it because
24 they realized I had been doing it for four years on
25 my own, so -- but, yeah, I didn't approach them.

241
1 Q. So Emily Wurth approached you about having

2 Food & Water Watch pay you money?
3 A. I was told if I wanted to continue the
4 work, then I would be supported by the groups that
5 are interested in the work that I'm doing.
6 Q. Okay. And when you say -- and that all
7 came through Emily Wurth?
8 A. From Food & Water Watch, so I'm not sure
9 what the decision-making process was, but that's who
10 I talked to.
11 Q. Okay. But that was -- Emily Wurth is the
12 one you had your conversations with about you
13 receiving compensation to be able to go out and
14 continue your work around the country?
15 A. Yes.
16 Q. And, again, in August of 2014, there is
17 another check for $3,000 to you from Food & Water
18 Watch and the memo line says August contract, do you
19 see that?
20 A. Yes, but I'm -- each one of them says
21 contract now so I just believe that's -- it's not a
22 contract, it's sending in the -- I guess -- I
23 thought it would say invoice, but contract. I
24 didn't put agreement contract every single month,
25 like this is showing, I just sent them an invoice

242
1 just like I do with Catskill Mountainkeeper.

2 Q. Okay. And how did -- who -- who determined
3 the amount that you would be paid?
4 A. I did. I asked for an amount that would
5 cover my expenses and everything else. This is
6 total, so I don't get expense money.
7 Q. I'd like to talk to you about the cash
8 payments that you were receiving. Who -- which
9 groups were paying you in cash?
10 A. What cash payments?
11 Q. Some very substantial cash payments. Are
12 you saying you don't recall any substantial cash
13 payments?
14 A. Which -- when are we talking about? I have
15 to know what time frame it is.
16 Q. Well, it's starting in 2012 through 2017.
17 A. That's my money and might want to figure
18 out where the money is coming from, I signed a gas
19 lease for $50,000 and then I got a pipeline
20 right-of-way, so that's my own money. I'm putting
21 it away myself instead of putting it into a bank.
22 So I was raised by somebody who said keep some at
23 home and keep some in the bank, so that's my own
24 money. You'll also see it being put back in again
25 if you keep following that trail it goes right back

243
1 in my bank account again, so...

2 Q. Okay. And so are you saying that the cash
3 amounts coming in -- the large cash amounts, you're
4 saying that's your own money coming back in?
5 A. That's my own money.
6 Q. Okay. Did Food & Water Watch, how did it
7 come about that you switched to receiving money from
8 Catskill Mountainkeeper?
9 A. I didn't switch, it was offered because I'm
10 guessing -- I don't know why. They just said that I
11 got a call from Catskill Mountainkeeper that they
12 said they -- to send an invoice there now, that was
13 my --
14 Q. Did you talk to Emily about that, about why
15 you were now going to be sending it to Catskill
16 Mountainkeeper?
17 A. I wasn't concerned about it, I just sent it
18 to a different one so I'm not sure that I had a
19 conversation with her. The conversation I had with
20 Catskill Mountainkeeper calling me and saying that I
21 can invoice them starting the following month.
22 Q. Okay. But you understood though that that
23 money would still be coming from Food & Water Watch,
24 correct?
25 A. I didn't know that that was all theirs, I

244
1 didn't know what was the total coming from anywhere,

2 I just knew that I could invoice Catskill
3 Mountainkeepers.
7 MR. PILSNER: 15.
8 BY MS. BARRETTE:
9 Q. I don't want to give you that one, that's
10 my notes. I'm handing you what's been marked for
11 identification purposes as Cabot Exhibit Number 15,
12 do you recognize that document or do you recognize
13 the -- the images that appear on the document?
14 A. Yes.
15 Q. Okay. Now, these are examples of payments
16 that you were receiving from Catskill
17 Mountainkeeper, correct?
18 A. Correct.
19 Q. And the very first page is December 3rd,
20 2015, and that Catskill Mountainkeeper amount
21 they're paying you $4,000 and the re line says
22 December invoice Food & Water Watch reimbursement;
23 do you see that?
24 A. Yeah.
25 MR. POSEY: I'm going to reiterate the

245
1 objection to this line of questioning. You can

3 THE WITNESS: I'm reading what it says.
4 BY MS. BARRETTE:
5 Q. Okay. And when you saw that, what do --
6 did you ask them, like anything about it? Did you
7 say why are you reimbursing Food & Water Watch?
8 A. No, what I assumed was it was when they
9 switched it over. I assumed that that meant I'm
10 sending an invoice to Catskill Mountainkeeper, so I
11 didn't know what that meant, I thought it was the
12 changeover because this is the first one, I believe,
13 that I got.
14 Q. Okay.
15 A. (Unintelligible.)
16 Q. Okay. The next one is another example of
17 July 27, 2016, $4,000 and it's also saying -- the re
18 line there says consulting Food & Water Watch
19 reimbursed; do you see that?
20 A. Yeah.
21 Q. And then the next one is an example from
22 March 28th of 2017 in the amount of $4,000 stating
23 April consultant for reimbursement by Food & Water
24 Watch; do you see that?
25 A. Yes.

246
1 Q. Okay. And so it was your understanding

2 that the money was actually really coming from Food
3 & Water Watch?
4 A. I -- I wasn't sure. I thought it was, so I
5 was sending an invoice to Catskill Mountainkeeper,
6 so I wasn't sure that either all or how much part of
7 it was coming over from them, so I don't know the
8 answer to that, that seems -- that's an internal
9 thing for them.
10 Q. Okay. Did you ever tell Mr. Kemble that
11 you were being paid by Food & Water Watch and
12 Catskill Mountainkeeper?
13 A. Tell him that?
14 Q. Mh-hum.
15 A. He knows I was being supported, but I
16 didn't get specific.
17 Q. Were they supporting him as well, do you
18 know?
19 A. Not that I know of.
20 Q. I guess that's what I'm talking about,
21 they -- he was out doing the same type of outreach
22 and speaking and talking and now the poor man is
23 disabled and having to beg for money on the Internet
24 and Food & Water Watch is nowhere to be found to
25 support him, right?

247

2 you know.
3 THE WITNESS: I have no idea Mr. Kemble's
4 financial arrangement with anybody else so I don't
5 have any idea.
6 MS. BARRETTE: Stapler.
7 MR. PILSNER: Stapler?
8 MS. BARRETTE: Yeah.
9 MR. PILSNER: Upstairs.
10 MS. BARRETTE: Oh, perfect.
13 BY MS. BARRETTE:
16 Exhibit 16. No less than three times throughout the
17 deposition I asked if you were receiving money from
18 a group called Frack Action or from Julia Walsh and
19 each time you said no.
20 MR. POSEY: Same objection as previous --
22 MR. POSEY: -- as to these checks.
23 BY MS. BARRETTE:
24 Q. The first is a -- well, the first one is an
25 incoming payment from Action Center, Inc.; do you

248
1 see that?
2 A. Mh-hum.
3 Q. Okay. What were they paying you for?
4 A. They were renting my house.
5 Q. Okay. And how long did they rent your
6 house?
7 A. For about a year.
8 Q. Okay. And who was -- who was in charge of
9 Action Center, Inc.?
10 A. I'm not sure on Action Center. I know that
11 Alex Lotorto was the one living at the house.
12 Q. Okay. And the 750 that appears in this
13 check -- most of the time they pay you in cash,
14 correct?
15 A. No. For rent, no.
16 Q. Mh-hum.
17 A. No. And Action Center is not -- is not
18 Frack Action, it's -- Action Center is in
19 Philadelphia, Pennsylvania where the check is
20 initiated from.
21 Q. So you're saying that Action Center, Inc.
22 has been paying you for a year for rent in checks?
23 A. I don't get -- I wasn't getting cash from
24 them, I got a reimbursement on check for the -- for
25 the people living there, that's what I remember.

249
1 I've got to look and see, but I didn't get cash from
2 them, not that I know of.
3 Q. Okay. This is just one month, one check,
4 you said -- how long was Mr. Lotorto living there?
5 For a year?
6 A. Yeah.
7 Q. Is he still there?
8 A. No.
9 Q. Okay. Is anybody renting the property now?
10 A. Yes.
11 Q. Who is renting the property now?
12 A. Bill Huston -- or not Bill Huston, Bill
13 Gear and his girlfriend, Wendy.
14 Q. Okay. The next page is a wire transfer in
15 June 6 -- 16, 2015 from Julia Walsh from Frack
16 Action. What was Julia Walsh paying you for?
17 A. That was one of my air units.
18 Q. So Julia Walsh was paying you for an air
19 unit?
20 A. Yes, and she still has it.
21 Q. Okay. Has she paid you other money?
22 A. Not that I know of, but I know this was an
23 air unit.
24 Q. Okay. Has Julia Walsh ever given you cash
25 payments?

250
1 A. Cash, no.
2 MS. BARRETTE: I need to take a quick
3 break.
4 THE VIDEOGRAPHER: Going off the record at
5 3:19.
6 (Off the record.)
10 3:42.
11 BY MS. BARRETTE:
12 Q. I've handed you what's been marked for
13 identification purposes as Cabot Exhibit 17, these
14 are two additional checks to you from Food & Water
15 Watch, one is for November of 2013, one is in April
16 of 2014. These both show that Food & Water Watch
17 was actually paying the water bill for the water
18 deliveries too, correct?
19 MR. POSEY: Same objection. You can answer
20 if you know.
21 THE WITNESS: That was not to me. That was
22 to Matthew Manning, who is not Craig Stevens, so...
23 BY MS. BARRETTE:
24 Q. Oh, I'm sorry, Matthew Manning, he signed
25 that over to you, correct?

251
1 A. He signed it over to me?

2 Q. Mh-hum. Yeah, he endorsed the check over
3 to you, correct?
4 A. I'm not familiar with this.
5 Q. It shows the 259 from Food & Water Watch
6 that they paid to Matthew Manning being deposited
7 into your account, correct?
8 A. I -- I guess. I'm confused on it, but I
9 don't remember it to be honest.
10 Q. Yeah, if you look at -- if you look to the
11 right.
12 A. Okay.
13 Q. The back of the check is there.
14 A. Oh, okay. Got it. Yeah.
15 Q. Okay.
16 A. I didn't see that.
17 Q. That's okay. And that shows Matthew
18 Manning signing the check over to you, correct?
19 A. (Inaudible.)
20 THE REPORTER: I'm sorry, I didn't hear
21 you.
22 THE WITNESS: Yes. Sorry.
23 BY MS. BARRETTE:
24 Q. And Matthew Manning, that's Tammy Manning's
25 husband, correct?

252
1 A. Yes.
2 Q. And they are the Franklin Forks couple?
3 A. Yes.
4 Q. And do you know what other payments Food &
5 Water Watch was making to them?
6 A. I have no -- no idea.
9 BY MS. BARRETTE:
10 Q. Mr. Stevens, I'm handing you what's been
11 marked for identification purposes as Cabot
12 Exhibit 18.
13 MR. DOUGHERTY: Thank you.
14 BY MS. BARRETTE:
15 Q. These are copies of checks from Frack
16 Action Fund, which is Julia Walsh's group. The
17 first one is January 24th, 2012, in the amount of
18 $4,000; do you see that?
19 A. Mh-hum.
20 Q. And that was right about the time that you
21 purchased the water truck, correct?
22 A. Let's see, January 2012, yeah.
23 Q. Yeah. And it was actually Frack Action
24 Fund that purchased the water -- gave you the money
25 for the water truck, correct?

253
1 A. No, I used my own cash to pay for the

2 truck.
3 Q. And what were they reimbursing you for the
4 truck?
5 A. I don't believe so here, no. I don't know
6 what the -- I'd have to look to see what the 4,000
7 was for.
8 Q. What the $4,000 was for?
9 A. Right.
10 Q. Do you have records that is going to show
11 what that 4,000 was for?
12 A. I have to look at it, that's -- we're
13 talking seven years ago.
14 Q. And I had asked you earlier if you had ever
15 received payments or CLS had ever received payments
16 from Frack Action Fund and you said no.
17 A. Yeah, no.
18 Q. So there in 2013 Frack Action Fund paid you
19 another $1,000, correct?
20 A. Yup.
21 THE REPORTER: Can you keep your voice up?
22 THE WITNESS: Yes.
23 BY MS. BARRETTE:
24 Q. And Frack Action Fund paid you another --
25 you deposited it into your account another 3,200 in

254
1 September of 2016, correct?

2 A. Yes.
3 Q. So you were receiving $4,000 a month from
4 Catskill or whoever, another 3,200 in a month from
5 Frack Action Fund, was that all part of your
6 consulting?
7 A. Well, as I stated earlier, the money from
8 Catskill Mountainkeeper didn't start until 2015 or
9 later. So that has nothing to do with the first
10 one, that's from 2012. And the $1,000 one was
11 from -- was from 2013, that was before I was
12 receiving any reimbursement from any other entities
13 so it wasn't at the same time of getting something
14 else from somebody.
15 Q. What about September of 2016?
16 A. I'd have to look to see what that one was.
17 9/9/2016. I can't remember. I'd have to look at
18 it.
19 Q. Now, what records would you look at to go
20 back and check to see what that payment was for?
21 A. Just my own -- whatever I put that in as an
22 item for what it was used for.
23 Q. Okay. So you keep track of when payments
24 come in, you keep track of what they're used for?
25 A. I -- I don't -- like I said, I don't

255
1 recognize this one for -- yeah, I don't know enough

2 to look it up.
3 Q. You had said for the first eight months you
4 were paying for the water deliveries by your -- you
5 know, on your own, correct? Using your own money?
6 A. I said I paid for the truck, wrote the
7 check out for it.
8 Q. Mh-hum.
9 A. And then I paid Mr. Kemble for months, so
10 I'd have to look to determine how many months,
11 but -- so I don't know whether that -- I don't
12 think that -- I don't know that that was related,
13 it's not the same amount of money, it's 4,000
14 instead of 34-something, so I'm not positive, I'm
15 not sure.
16 Q. So was that -- was that money, that $4,000
17 that you received from Frack Action in January 24th,
18 2012, were you paying that to Mr. Kemble?
19 A. No, did not. Nope.
20 Q. And you had no discussions with Julia Walsh
21 about paying money to Mr. Kemble, is that correct?
22 A. As far as any of this, I don't have any
23 idea what it's from. I don't know if the four was
24 part of the water delivery issue or not, but the
25 timing is close so I have to find out what that was

256
1 for.
2 Q. Now, why were you paying Mr. Kemble $500 a
3 week when the EPA was delivering water?
4 A. It wasn't delivering water, they only
5 delivered to four people. There was six other
6 people that weren't getting water delivered
7 including Ray.
8 Q. Do you have an understanding as to why the
9 EPA only selected four to deliver water to?
10 A. I don't get involved in that decision, I
11 just was helping out the people who were left out.
14 MS. BARRETTE: What's the --
15 MR. PILSNER: 19.
16 BY MS. BARRETTE:
19 Exhibit 19, it shows a check that you received from
20 Penn Environment Research and Policy Center; do you
21 see that?
23 BY MS. BARRETTE:
24 Q. And that's in the amount of 1,200 on
25 October 10, 2013; do you see that?

257
1 A. Yes.
2 Q. And what was Penn Environment Research and
3 Policy Center paying you for?
4 A. That was the same people paying me I
5 believe for the rent, the Penn Environment Research
6 Center and Policy Center was the -- Philadelphia.
7 I believe that was the rental because that
8 was during the time period in 2013.
9 Q. So was the rent 600 a month or was it
10 1,200, what was the rent?
11 A. Well, for them it was -- it went from 750
12 to 1,000, but I don't know why it would be 1200, so
13 I'd have to look to see why. But, yeah, it's
14 Penn -- Penn Environment and -- Research and Policy
15 Center is on -- is in Philadelphia so that's -- that
16 was part of the rent for the house.
19 MS. BARRETTE: What number are we on?
20 MR. PILSNER: 20.
21 BY MS. BARRETTE:
22 Q. Okay. Mr. Stevens, I've handed you what's
24 Exhibit Number 20 and that's another wire transfer
25 in from Julia Walsh of Frack Action in the amount

258
1 of, this time, $500?

2 A. Yes, a second air unit, she has two.
3 Q. Okay. So the first one was 570 and
4 the second one was 500?
5 A. Yeah, because I had to have the other one
6 shipped so it was more money. This one I had, so it
7 was $500.
8 Q. Okay.
9 A. But I charge at cost for the machines,
10 they're normally 800.
11 Q. I just want to back up for a second when
12 you were talking about 2012, that time frame when
13 you said you were using your own money to pay
14 Mr. Kemble to deliver water. Is it your testimony
15 that you were unaware that he was receiving
16 thousands of dollars from other groups?
17 A. I have no knowledge of that.
18 Q. Okay.
19 A. It didn't come into the equation, I'm -- he
20 was being paid to drive a truck, so I didn't know of
21 anything else coming into it.
22 Q. But you were unaware whether he was being
23 paid by these other groups as well, correct?
24 A. Absolutely, I didn't know anything about
25 that.

259
1 Q. I'm pretty sure I am finished. I just want

2 to consult with my co-counsel for a minute, then we
3 should be done.
4 THE VIDEOGRAPHER: Off the record?
5 MS. BARRETTE: Yes, thanks.
7 (Off the record.)
9 4:02.
10 BY MS. BARRETTE:
11 Q. Okay. Mr. Stevens, I just have a few more
12 questions. Recently there were articles about the
13 fracking ban in Florida and I believe there were
14 several articles about you down there, we even have
15 video of you down in Florida meeting with different
16 government entities and legislatures; were you
17 instrumental in having fracking banned in Florida?
18 A. Not -- well --
19 MR. POSEY: Objection. You can answer.
20 THE WITNESS: I don't know if I was
21 instrumental, I went down and basically told them
22 what my experiences were.
23 BY MS. BARRETTE:
24 Q. And who -- when you say you told them,
25 what -- what government -- government officials did

260
1 you meet with in Florida?

2 A. Anybody that was interested in talking to
3 somebody who's experienced it firsthand. So it
4 could have been anyone from representatives to all
5 the way up.
6 Q. Okay. And the same out in California, you
7 met with government elected officials out in
8 California, correct?
9 A. 2013, yes.
10 Q. Okay. And the same thing, you were talking
11 to them about what you experienced at your place and
12 same thing like with Ray Kemble and his water,
13 correct?
14 A. Yeah, personal experience. Mine was more
15 on the property side always.
16 Q. Okay. And we had the -- the video of you
17 in front of the New York Assembly, that where you
18 were specifically holding up Ray Kemble's water and
19 talking about his water contamination issues,
20 correct?
21 A. Correct.
22 Q. Okay. And that was in front of elected
23 officials, correct?
24 A. Correct.
25 Q. Same thing in Harrisburg, you went down, I

261
1 believe, and met with elected officials in

2 Harrisburg as well, correct?
3 A. Appointed, I don't usually meet with
4 elected officials in Harrisburg. So I'm -- not
5 really elected officials, mostly appointed like the
6 Department of Health or the agencies.
7 Q. Okay. And did you meet with Governor Wolf?
8 A. No.
9 Q. Okay. Did you meet with -- strike that.
10 Did you happen to attend the cop21 summit
11 with Mr. Kemble in Paris?
12 A. Nope. Never been out of the country
13 besides Canada and Mexico.
14 Q. Okay. Now, in 2017 -- February 2017 you
15 were speaking at the house of delegates hearing in
16 Annapolis, correct?
17 A. House of delegates hearing?
18 Q. Mh-hum.
19 A. Yes.
20 Q. Okay. And there you were talking about
21 water contamination and issues like that, correct?
22 A. All aspects, pipeline and just all -- all
23 aspects.
24 Q. All right. At this time, I don't have any
25 more questions.

262
1 MS. BARRETTE: Attorney Dougherty, do you

2 have any questions?
3 MR. DOUGHERTY: I don't have any questions,
4 no.
5 MS. BARRETTE: Okay. Attorney Raiders, do
6 you have any questions?
7 MR. RAIDERS: No, I don't.
8 MS. BARRETTE: Okay. All right. And I
9 don't know if your counsel has any questions for
10 you.
11 MR. POSEY: No.
12 MS. BARRETTE: All right. That's it. We
13 can go off the record.
14 THE VIDEOGRAPHER: Deposition is concluded.
15 Going off the record at 4:07.
16 (Reading and signature not waived.)
17 (Whereupon, the proceedings at 4:08 p.m.
18 were concluded.)
19
20
21
22
23
24
25

263
1 COMMONWEALTH OF VIRGINIA AT LARGE, to wit:

2 I, REBECCA MONROE, Court Reporter and
3 Notary Public in and for the Commonwealth of
4 Virginia at Large, and whose commission expires
5 August 31, 2021, do certify that the aforementioned
6 appeared before me, was sworn by me, and was
7 thereupon examined by counsel; and that the
8 foregoing is a true, correct, and full transcript of
9 the testimony adduced.
10 I further certify that I am neither related
11 to or associated with any counsel or party to the
12 proceeding; nor otherwise interested in the event
13 thereof.
14
15
16
17 ________________________________
18 Rebecca Monroe
19 Notary Public
20 Commonwealth of Virginia at Large
21 Notary No. 7243327
22
23
24
25

264
1 DEPOSITION ERRATA SHEET

2 Job No. 72931
3 Case Caption: Cabot Oil & Gas v. Speer Law Firm, et
4 al
5 Deposition Date: January 31, 2019
6 DECLARATION UNDER PENALTY OF PERJURY
7 I declare under penalty of perjury that I
8 have read the entire transcript of my Deposition
9 taken in the captioned matter or the same has been
10 read to me, and the same is true and accurate, save
11 and except for changes and/or corrections, if any,
12 as indicated by me on the DEPOSITION ERRATA SHEET
13 hereof, with the understanding that I offer these
14 changes as if still under oath.
15 Signed on the ___ day of__________, 20____.
16 ___________________________________
17 (CRAIG STEVENS)
18 Subscribed to and sworn before me this ___ day of
19 __________, 20__, in ______________________.
20 ___________________________
21 (Notary Public)
22 My commission expires:___________, 20___.
23 Notary Public Registration No.
24
25

265

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4 Page No._____Line No._____Change to:______________

5 __________________________________________________
6 Reason for change:________________________________
8 __________________________________________________
11 __________________________________________________
14 __________________________________________________
17 __________________________________________________
20 __________________________________________________
22
23 SIGNATURE:_______________________DATE:___________
24
25

266

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5 __________________________________________________
7 Page No._____Line No._____Change to:_____________
8 __________________________________________________
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23 SIGNATURE:_______________________DATE:___________
24
25

1
WORD INDEX 1,200 256:24 233:4, 6, 11, 13, 14, 225:10 257:17, 20,
257:10 14, 14, 14, 15 24 264:15, 19, 22
<$> 1.09 181:14 15 6:22 45:16 200 124:5
$1,000 253:19 1.09-acre 182:19 75:1 120:19, 20 2000 3:14 46:13
254:10 1:17 166:2, 4 244:4, 7, 11 73:24 83:9
$100 116:17, 22 10 6:17 62:3 15219 3:9 183:15
124:12 126:11 78:3 119:18 1527 67:17 20007 4:18
$2,200 56:3 57:21 168:24 169:4 15275 3:16 2002 178:12
58:6 59:7 176:18 192:20 153 6:14 2003 178:17
$20 43:18, 22 214:25 256:25 16 6:23 120:16, 2004 178:17, 23
44:4, 20, 23 96:22 10:52 100:14 20 244:6 247:11, 2006 34:23
117:6 201:17 103 155:23, 24 16 249:15 175:23 179:3, 12
$3,000 116:22 1099 96:2, 3, 6, 12 162 6:15 2008 129:12, 14,
233:16 234:10 127:8, 11, 21 166 6:16 16, 18
235:5 236:6 10th 135:16 168 6:17 2008-ish 179:24
237:19 241:17 11 6:18 62:19 16th 171:24 2009 75:11 180:1,
$3,500 90:14 67:21 83:12, 15 17 7:4 250:7, 13 2, 6 183:11, 15
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25 106:2 151:21 characterizing 109:22, 23 159:12 118:21 126:22
161:2 184:25 111:22 207:8 228:2, 9
187:18 192:15, 24 charge 55:14 CIVIL 1:2 client 23:25 31:2
204:25 226:16 91:5, 7 248:8 claim 28:10 152:20 216:1, 5
229:1, 7 230:4, 17, 258:9 34:17 35:8, 25 clients 74:1
21, 21, 23 231:1, 9, CHARLES 1:9 36:6 37:13, 14, 15 close 100:8
17 232:1, 6, 7 4:4 5:13 8:6, 25 146:7 227:19 179:25 180:21
242:1 243:8, 11, 9:8 154:3 claimed 109:14 222:11 255:25
15, 20 244:2, 16, Charlie 65:12 claiming 18:11 closer 178:10
20 245:10 246:5, 72:7 173:10, 20 146:13 226:23 183:2, 5, 8
12 254:4, 8 Charlottesville claims 11:1 CLS 161:20
caused 31:6 196:24, 25 197:13 149:17 200:12 253:15
causing 79:1, 11 chased 27:23 CLANCY 1:11 Clscraigstevens
131:12 check 54:11 4:5 8:7 9:1 32:12
cease 150:8, 11 55:14 61:9, 12, 14 154:4 CM 8:10
Center 247:25 90:3 95:23 99:1 clarification 50:12 Coalition 77:2
248:9, 10, 17, 18, 124:19 232:2 187:23 COAs 77:16
21 256:20 257:3, 234:7 235:4, 24 Clarify 41:1, 4 Coast 176:8, 11, 15
6, 6, 15 236:5 237:9, 18 44:1, 19 50:10 co-counsel 259:2
Centre 3:7 238:8 241:17 80:18 coffee 13:8 43:4
centric 197:9 248:13, 19, 24 clarity 145:23 Cohen 198:11, 21
certainly 73:12 249:3 251:2, 13, 146:5 COLE 3:12 8:22
certified 2:10 18 254:20 255:7 classic 73:1, 3 collective 190:20
certify 263:5, 10 256:19 Clean 45:11, 12, college 175:24, 25
challenges 207:14 checks 125:16 18, 22, 23 46:1, 14 176:3, 7, 8, 9, 11, 15
chance 235:3 126:20 127:2 47:5 48:2 50:2, color 145:23
change 63:25 233:11, 25 247:22 14 51:2, 10, 18 146:5
100:8 101:4 248:22 250:14 52:9, 17, 22 53:2, Colorado 195:7,
107:8, 9 145:25 252:15 12, 14, 20, 22, 23, 12 196:1 198:3, 4,
146:8 166:11, 12 chemical 79:1 25 54:3, 6, 13, 19 5
183:17 265:4, 7, 132:18, 21 55:9, 11 56:5 colors 113:11
10, 13, 16, 19 chemicals 109:17 57:21 59:3, 24 come 28:8 30:1
266:4, 7, 10, 13, 16, chemist 79:10 61:6, 17 94:18, 23 66:22 74:3, 11
19 children 183:5 96:20 97:19, 23 79:2 89:12 106:3,
change: 265:6, 9, Christmas 115:25 98:4, 13 126:24 24 108:18 109:2,
12, 15, 18, 21 116:1 136:2 145:10 7 112:11 113:14
266:6, 9, 12, 15, 18, CIARIMBOLI 164:1 177:10, 15 114:12, 16 124:3
21 1:10, 12 4:5, 6 178:21 183:12 125:21 136:21

9
139:12 162:25 63:12 93:7 97:14 completely 130:21 consider 28:2, 2

164:1, 8, 9 171:25 101:20 105:8 158:25 178:24 29:11, 16 43:12,
172:13 173:9 108:2 182:1 23 44:20 79:18
188:12 193:24 communications comprehensive 80:1 214:8
195:22 204:9 23:24 24:25 47:2 consideration
226:10 228:11 31:15, 19 32:24 compressor 79:3 203:22
231:25 232:4 33:3, 13, 18, 22, 24 computer 32:5, 7, considered 79:11
243:7 254:24 34:6, 8 36:10 9, 17, 21 137:18
258:19 38:9 39:17, 25 concerned 112:24 considering 76:11
comes 113:18 40:13 61:22 62:4, 193:24 206:24 93:3 201:15
145:16 159:8 13, 18 67:4 68:6, 243:17 conspiracy 34:20
181:5 231:11 8, 8, 23 73:8 concerning 11:22 constitutes 70:17
232:2 75:16 80:24 93:9 33:14, 25 62:5 consult 46:24
coming 100:7 94:7, 14 98:7 concluded 262:14, 128:1 134:5
113:11 125:13 101:14 102:9 18 140:13 183:25
127:10, 19 157:2 103:20 173:19, 19 condition 33:25 259:2
159:6 184:17 community 76:18 114:5 consultant 49:2,
191:6 203:15 125:14 199:6, 8, 133:13 156:2 13 50:2 245:23
242:18 243:3, 4, 13 209:25 236:9 confer 216:4 consulting 46:17,
23 244:1 246:2, 7 companies 40:22 conference 34:14, 20, 21, 22, 25 47:2,
258:21 111:1 16, 25 35:2, 3, 14 5, 6, 12 48:3, 15
co-mingled 229:14 company 29:14 36:4 197:5 198:5 50:11, 15 51:2, 12,
commercial 99:10, 30:1 40:7 45:1, 205:12, 12 206:12 16, 22, 25 52:10,
13 13, 16, 16 46:9, 11 conferences 37:25 18 54:16, 17
commission 54:25 54:8 55:2 56:1 39:2 94:17, 19 95:8
55:1 186:8 263:4 60:24 65:18 confiding 207:17, 140:13 177:23
264:22 77:19 91:6 19 183:13, 18, 23
committee 134:21 177:11, 18 186:8 conflicting 89:23 184:9, 13, 25
135:1, 6 210:1 232:25 confuse 44:14 185:4 186:7
committees compel 19:6, 12 confused 49:25 187:16 192:14, 24
130:19, 24 133:5, compelling 19:8 130:15 200:19 228:24 229:20, 25
6 134:17 compensated 251:8 232:17 245:18
COMMON 1:1 117:2 236:12, 13, confusing 13:10 254:6
61:12 167:18 15 conjunction 14:6 contact 103:24, 24
Commonwealth compensation 15:2 68:13 206:12 210:5
2:12 34:18 35:8, 50:6 51:11 connected 60:20, 218:5
25 36:6 37:13 187:20 240:19 22 198:24 contacted 22:18,
115:21 227:3 241:13 connection 39:10, 19 104:3
263:1, 3, 20 complaint 15:12 23 40:3, 8, 18 contained 85:12
communicate 34:20 36:13 37:4, 46:25 48:16 contains 85:19
103:13 232:13 7 50:18 149:14 49:13 54:20 67:8 contaminant 80:6
communicated 153:19 154:2, 8 69:3 70:4, 13 contaminated
211:6 232:10 155:24 156:17, 19 84:4 102:8 80:2 113:9
communication 157:1 161:20 182:5 137:19, 22 146:14
35:12 36:8, 15, 18 complete 169:8 206:12 219:5

10
147:12 157:7 8, 13 22, 23 107:13 21 263:8

226:3, 24 cop21 261:10 108:10, 16, 17 corrections 264:11
contamination copied 223:11 110:25 111:24 correctly 16:4
49:6, 10, 12 51:5 copies 56:21, 22 112:5, 17, 18, 22 46:8 54:24 57:6
112:18 142:19, 20 58:21 114:18 114:1, 13, 14 58:23 96:19
183:20 226:18 129:1 143:1 115:14, 15 118:23 123:17 184:24
235:16 260:19 144:1, 5, 12, 24 119:22 120:24 correlate 117:11
261:21 156:20 252:15 121:16 123:20 correspondence
contentious 9:9 copy 18:10, 12 125:25 127:17 34:8 62:9 105:19
Contents 6:25 25:15 26:24 27:2 130:7, 8, 11 156:25
7:1 113:3 81:2 86:5 89:4, 6 131:19 133:9, 19 corresponding
continue 108:4, 5 91:8 118:20 134:8, 17 135:6, 8, 59:9
122:21 123:12, 13 130:16 131:25 19, 23 137:3, 4, 11, corroborate
151:25 202:13 132:1 137:4 14, 23 138:4, 9, 13, 203:24
241:3, 14 143:25 154:1, 2 14 139:9, 23 corruption 219:12
continued 1:25 157:1 140:8 141:13, 14, COSAs 77:17
2:1 3:25 4:1, 25 CORPORATION 15, 20, 21 142:19 cost 55:19 89:21
5:1 6:25 7:1 1:4, 6 3:13 8:5, 6, 143:13, 16, 17 90:25 258:9
continuing 11:3, 7 20 39:22 40:7, 18 144:12 146:6, 15 Costa 176:9
15:13, 25 108:13 70:15 170:12 147:5, 6, 12 178:11
164:22 171:6 154:18 162:11, 12, costs 57:10
contract 53:17, 20 corporations 190:4 18, 22 163:21, 23 116:16 161:17
54:4 104:18 correct 15:2 17:5, 164:12 167:19, 20, counsel 2:6 8:16,
233:18 234:11, 15, 21 18:14, 19 19:5, 21 174:7 177:7 23 9:21 10:12, 14,
19, 23 240:1, 5 6, 7, 10, 14, 15, 16, 181:12 182:18, 19 16 20:11 21:17,
241:18, 21, 22, 23, 18, 19 20:7, 13, 17, 183:10, 14, 21 20 24:7 68:5, 9
24 22, 25 21:3, 6 185:14 186:10 70:11, 18 71:10
contracted 234:21 25:6 26:8 28:22, 188:2 189:5, 20 106:1 216:16
contradictory 23 29:20 32:16, 200:4, 9 204:5 217:23 218:2
171:19 17 33:5, 20 34:10 205:3 206:18 219:18 220:21
contributing 35:14 41:13 42:6 207:24 210:15, 18 262:9 263:7, 11
231:20 43:10, 11 44:5 217:13 218:10 counselor 173:3
conversation 45:2 48:24 54:14 222:21 224:13 counteract 69:8
12:20 160:2 55:4, 8 59:1, 2, 10 228:7, 21 229:3, counties 30:16
208:12 211:22 60:17 61:23 62:1, 22 230:6, 8 231:2, country 146:13
243:19, 19 6, 7 63:15 67:9, 21 235:17 237:13 241:14 261:12
conversations 10, 20 70:5 74:21 240:5 243:24 COUNTY 1:1
22:14 83:2 77:2, 7, 11 78:11, 244:17, 18 248:14 8:9 11:19 12:1
154:13 172:5 21 79:12, 14, 16, 250:18, 25 251:3, 26:15 28:4, 20
208:6, 14, 16 17, 19 80:10 85:3 7, 18, 25 252:21, 30:12, 17 103:9
210:22 219:4 86:10, 11, 19 90:6 25 253:19 254:1 167:19 214:22
232:16 241:12 93:24 95:4, 9 255:5, 21 258:23 couple 10:6
converted 57:3 97:4, 20 99:2 260:8, 13, 20, 21, 60:12 78:2 92:16,
coordinator 199:6, 100:5, 21, 24 23, 24 261:2, 16, 21 116:24 123:6
101:2, 24 106:19, 164:19 179:25

11
186:14 221:12 cure 61:4 deals 50:18 DELANCEY 3:12

222:5 226:9 curiosity 87:17 debris 228:13 8:22
239:2 252:2 curious 16:13 DEC 197:20 delegates 261:15,
course 73:17 65:21 December 19:11 17
123:14 145:23 currently 51:15, 20:2, 17 21:25 deliver 89:16
195:11, 11 198:7 21 120:5 180:10, 25:3 126:2 117:9 119:16
COURT 1:1 8:9 22 154:18 233:13 120:6 122:19
9:15 12:23 19:8 cutoff 25:7 235:4, 8 244:19, 22 128:13 256:9
20:16 26:3, 6, 12, decent 83:20 258:14
15, 16 27:5 28:15 <D> decided 99:24 delivered 116:2,
29:4 150:15 D.C 4:18 148:10 116:2 123:10 18, 23 118:15
151:6 152:13 dad 99:20 178:3 207:24 120:2 256:5, 6
153:7 167:18 179:8 decision 107:14 deliveries 116:5, 8,
187:25 208:24 damage 70:7 128:2 256:10 9, 13, 20 117:22
210:17 263:2 84:23 85:7 decision-making 119:20 121:22
courthouse 11:19 140:19 225:8, 10, 241:9 127:24 250:18
19:18 18 226:17 decisions 78:5 255:4
courtroom 86:3 damaged 227:21 DECLARATION delivering 115:21
cover 129:13 damaging 84:23 264:6 117:2, 10 118:13,
242:5 dangers 112:3 declare 264:7 14 119:6, 18
covered 196:5 data 132:4 141:8 dedicated 183:11 120:11, 23, 25
199:21, 24 date 18:25 19:1, deep 215:4 238:21 256:3, 4
crafted 194:17 9, 11, 15 29:5 deeper 215:3 delivery 116:18
206:9 83:7, 10 90:14 218:19 117:16 119:4
CRAIG 2:5 6:4 115:7 129:14, 16 defend 70:23 176:19 200:16
8:4 9:18 107:21 162:23 164:23 DEFENDANT 5:3 255:24
212:17 213:1, 16 264:5 9:3 30:16, 19 delving 206:23
220:22 234:7 DATE: 265:23 Defendants 1:13 demand 150:8, 13
235:6 240:1 266:23 4:4 8:25 11:2 152:4
250:22 264:17 dated 129:13 31:16 64:6 88:19 demands 150:16
C-R-A-I-G-S-T-E- 157:8 234:9 97:9 151:11 demonstrate
V-E-N-S 32:12 237:18 238:8 172:2, 5, 16 142:18, 20
create 35:10 daughter 188:9, 9 defending 213:24 demonstrations
created 162:15 day 18:16, 16 defense 102:2, 4, 6 38:2
194:22 64:24 65:19 103:23 128:16 Denial 64:16, 22
creating 37:19 116:18, 23 159:3 190:24 200:12, 18 65:4, 11 68:13, 22
credit 61:8, 12 164:12 171:4, 24 201:1, 19 213:9, 69:1, 3, 12, 17, 21
credits 176:2 186:16 224:25 11, 16, 20, 24 70:3, 13, 22
Creek 67:17 264:15, 18 214:3, 9, 16 135:22 136:5, 15,
169:18 227:1, 7, days 10:12 20:25 define 192:23 22
20 228:17 21:5 22:4 65:21 defined 39:22 DEP 77:18
criminal 34:19 196:7 219:15 80:20 129:22 142:2, 4
36:13 37:4, 7 227:5 definition 73:5 144:20 145:10
Cruz 16:24 deal 110:25 232:5 definitions 97:23 227:22
degree 176:1, 24

12
department 177:13 directly 30:4 55:5 distance 122:16

176:23, 25 223:8 designed 30:6 119:7 126:5 distinction 68:4
261:6 despite 27:8 233:1 distribution 54:22
depends 43:14 detailed 170:21 director 187:15 DIVISION 1:2
61:7, 9 details 112:23 directs 219:16 divorced 180:10
depo 166:19 detected 133:24 disabled 239:19 document 14:3, 5,
deponent 150:18 138:4, 6, 8, 13, 18 246:23 9, 13, 14 17:20
152:5 detectible 137:21 disappeared 66:8 18:8 19:3 35:25
depose 17:10 detection 137:17 discern 70:8 36:9, 24 37:19
18:1 208:18 determine 216:17 disclose 21:16 57:9, 13 66:19
deposed 11:11 255:10 82:7, 9 113:6 115:1
16:18 determined 242:2 disclosed 21:19 129:25 130:2, 5,
deposing 214:8 device 108:2 discovery 149:19 20, 23 138:15
deposited 234:8 diagnosed 179:3 150:5 153:3, 7 162:6, 10 167:1, 3,
251:6 253:25 diagnostic 176:21 186:2 208:7, 9 21 168:5, 9, 14, 21,
Deposition 2:4 dialed 218:16 212:6 213:14 22 169:4, 14
6:7 7:3 8:4, 11 died 207:14 214:11 219:15, 22 170:4, 6 208:13
9:9, 13 10:8, 9 difference 71:4 220:25 221:3 212:10 213:2
12:10, 11, 18 210:3 222:24 223:10 244:12, 13
13:23 15:6, 20 different 12:6 discuss 35:24 documentary 78:9
16:2, 10, 14 18:3 24:11 38:6 40:15 81:9, 14, 23 172:8 documentation
19:9 20:10, 16 43:13 78:3 190:17 30:20 62:17 90:5
23:2 24:13 25:10 113:11, 20 117:10 discussed 12:12 91:5 93:13 95:12,
97:25 101:2, 11, 133:14 140:20, 21 21:16 34:16 16, 19 173:23
15, 17, 19, 24 145:22 151:10 35:19 36:16, 18 174:1 203:19
114:21 128:20, 24 152:19 158:25 51:3 61:21 71:21, documented 78:6
150:6, 8, 12 151:1, 177:11, 18 184:19 25 201:15 213:11 documents 11:8
19, 23 152:6 193:20 195:25 216:20 19:20, 25 20:6
153:23 162:1 203:24 210:2, 12, discussing 25:18 27:21 31:12, 14,
166:16, 23 168:24 14 243:18 259:15 33:20 82:25 16, 18, 21 32:23
186:2, 2 194:3 difficult 13:1 101:13 155:25 33:2, 12, 15, 17, 22,
209:21 212:1 Dimock 34:14 discussion 36:1, 23 34:3, 4, 5, 12,
214:10, 11 224:1 59:16 91:14 19 149:6 15, 24 35:1, 12
233:6 244:4 115:22 121:19, 25 Discussions 22:10 36:2 37:9, 23
247:11, 17 250:7 147:20 148:12 70:19 166:15 38:5, 8, 10, 16
252:7 256:12 190:19 205:12 172:8 208:9 39:8, 14, 16, 19, 25
257:17 262:14 direct 54:21 219:21 255:20 40:12 57:3, 23
264:1, 5, 8, 12 110:21 189:9 Disneyland 15:8 61:22 62:3, 19, 23
265:1 266:1 203:5 221:3 16:16 63:4, 5, 9, 11 64:5,
depositions 175:9 directed 29:23 disposing 163:20 11, 15, 18 66:18
Depth 65:2 170:6 30:1 167:18 dissatisfaction 75:10, 13, 15, 17,
171:18 193:4 219:2 19 76:17, 22
describe 113:15 directives 219:14 dissolved 138:17 77:13, 16 80:16,
described 51:11 139:21, 22 140:6 24 88:10, 15, 18,
24 89:1, 13, 16

13
90:21 91:1, 2, 7, DOUGHERTY duces 10:10, 10 EDWARD 1:10

11, 19 94:6, 11, 13 4:7 8:24, 24 duly 9:20 4:4 8:7, 25
95:10 96:14, 17 26:18, 22, 25 68:1, dump 113:3 effort 64:10
97:7, 11, 13, 15 12, 20 69:23 dumping 109:17 122:20
98:3, 6, 10, 16, 20 72:22 73:1, 6, 12 110:17 111:1 efforts 22:6 24:12
101:13 115:23 165:9 172:4 112:21 38:11, 21 63:6, 13
129:11 156:22 252:13 262:1, 3 Dunkin 43:3 64:6 155:4
233:23 dozen 24:16 durable 164:21 217:23
DOH 223:3 120:14 dwindled 120:15 eight 25:20 90:8
Doherty 4:8 draft 14:5 168:13 121:6 122:2 195:5 202:11, 11,
doing 44:7 47:9 208:12, 20 213:2 124:25 14 214:20 227:2,
50:1 51:11 61:10 drafted 15:1 3, 4 228:17 235:1
70:10 77:21 168:5 <E> 237:17 255:3
92:11, 14, 16 93:1 drafting 36:5 earlier 71:12 eight-hour 15:6
96:24 109:24 37:18 208:7, 9 115:9, 13 117:5, 16:14
111:1, 9, 18 116:8, dragged 30:7 15, 17 121:5 EIS 90:21
23 117:14 121:4 drill 69:7 131:10 147:1 either 50:21
122:21, 23 123:4, drilled 34:22 163:21 164:15 61:15 68:9 72:5
13 124:6 127:22, DRILLING 1:5 170:5 174:20, 22 74:15 77:18
24 146:21 149:16 8:5, 21 72:1 184:16 189:18 89:24 92:15 94:2
152:23 171:3 114:13 131:15, 19 193:1 199:25 104:15 105:3
176:19 177:16, 22 134:1 156:5, 7 201:16 203:13 125:14 144:15
183:18 184:9, 25 228:7, 10 204:2 205:11 165:1 190:5
186:5, 7, 13, 13, 15, drink 13:6 79:15, 219:24 226:15 195:13 200:2
16, 16 192:15 19, 24 131:14 228:23 234:13, 18, 202:3 204:21
205:9 210:13 drive 116:11 22 235:21 237:10 219:11 222:13
211:12 214:6 161:7 204:19, 22 240:4 253:14 246:6
220:1, 3 221:18, 258:20 254:7 elected 159:24
21 228:17 229:16 driven 205:5 early 67:22 71:12 173:2, 3 220:9
235:11, 12, 21 drivers 111:8 73:25 223:3 260:7, 22
236:8, 17, 17 drives 204:23 EarthLink 32:14 261:1, 4, 5
238:2, 22 240:24 driveway 109:21 earthlink.net 32:13 electric 210:20
241:5 246:21 driving 110:5 edge 195:5 239:18
dollar 55:24 179:10, 20 204:22 educate 50:7 electronic 31:14
dollars 42:23 214:21 112:3 132:5 32:3 57:5 178:2,
43:2 55:21 97:1 drop 27:17 191:13 193:24 10
119:10 225:2, 23 dropped 124:7 226:19 Electronics 178:3
230:7 232:24 drove 108:22 educating 193:13 elementary 175:19
236:11 258:16 109:20, 25 110:4, education 48:2, 24 eliminated 94:22
donations 93:23 11 116:10 161:9, 176:12 Ely 16:21 17:1, 2,
123:22 124:22 9 196:15, 16, 18, educational 47:8, 3 148:8
125:23 127:6 25 197:1, 1 198:1 12, 20, 22 49:2 Elys 148:14
194:11 203:5, 9 199:22 204:20 50:2 193:12, 18 e-mail 32:11, 11,
Donuts 43:3 205:4, 4, 5 226:6 235:14 15 33:7 105:19
194:9, 15, 17

14
212:5, 16 213:5 entity 40:18 40:4 108:24 Excuse 15:15

220:21 170:19, 24 109:5 174:21, 23 58:19 100:7
e-mailed 194:19 Environment 175:2 195:20 150:10, 13
e-mails 25:20 195:22 256:20 210:12 executed 171:22
34:7 62:9 257:2, 5, 14 eventually 27:13 exhaust 79:3
embarrass 150:17 environmental 74:13 215:10, 11 Exhibit 13:23
embarrassing 50:13 51:3 52:10 everybody 43:13 14:2 18:3, 8
151:7 129:15 225:24 82:6 102:14, 18, 25:10, 15 26:13,
Emily 62:10 93:5, 238:6 19 103:17 122:3 14, 20 31:10
10 105:23 240:20 EPA 12:7 144:11, 140:20 165:8 114:21, 25 128:20,
241:1, 7, 11 243:14 14 223:8 227:22 185:24 209:12, 25 24 129:10, 10, 18,
employer 98:23 256:3, 9 227:16, 22 19, 20, 24 138:16
employers 98:17 equation 258:19 evidence 78:7, 9 141:23 153:23
employment equipment 47:10, 89:2 113:6 154:1 162:1, 5
109:10 176:16 14, 18 55:6, 16, 19, 152:14, 16, 18, 19, 166:22, 23 168:24
enclosed 36:12 24 56:2 57:16, 24, 22 169:4 187:24
enclosing 34:19 24 58:7, 8, 9 59:8, evidencing 91:1 194:3, 8 212:1, 9
encourage 88:11, 10 60:9 176:22 ex 179:4 180:9 224:1 233:6, 11,
20 177:19 exact 25:5 130:20 22 244:4, 11
ended 25:24 Eric 16:23, 25 201:22 207:21 247:11, 16 250:7,
108:18 110:9 17:1, 5 exactly 28:8 13 252:7, 12
159:3 172:15, 17 ERRATA 264:1, 71:13, 24, 24 72:4, 256:12, 19 257:17,
181:22 12 265:1 266:1 25 81:25 92:8, 12 24
endorsed 251:2 ESI 37:9, 23 94:3 120:21 EXHIBITS 6:7
Energy 64:16, 22 38:11 39:8 62:3, 121:25 130:4 7:3, 9
65:1, 4, 11 68:13, 20 63:4, 6 64:5, 134:6 159:11, 11 exist 178:4
22 69:1, 3, 12, 16, 15 75:10, 18 203:10 211:23 existence 165:2
21 70:3, 13, 22 76:17 80:16 221:18 229:6 existing 136:9
135:22 136:5, 15, 88:10, 24 89:14 231:22, 24, 25 expect 193:13
22 170:6 171:18 91:12 94:6 95:10 240:14 expedition 10:25
engage 38:20 96:15 97:7, 16 examination 2:6 149:18
engagements esophogeal 179:3 6:5 9:19, 21 expense 123:25
37:24 39:18 41:6 ESQUIRE 3:4, 5, examined 9:20 202:23 230:20
62:6 12 4:7, 15 5:5 263:7 236:3 242:6
enter 11:23 essentially 202:18 example 45:5 expenses 116:15
entered 19:8 88:4 et 264:3 55:10 57:7, 20 118:3 119:3, 9
102:1 ethylbenzene 79:8 58:6 98:9 123:15 122:15, 25 127:19,
entire 15:10 25:9 evaporation 210:3 128:16 245:16, 21 24 184:21 187:21
29:16 30:6 44:6 event 9:12 39:11 examples 47:4, 6 194:11 196:5, 8
50:17 116:24 61:10 106:13 244:15 199:24 200:21
142:2 204:6 161:16 188:13, 14, exchange 33:9 229:23 230:17
264:8 21, 22 204:14, 19, 41:2 42:19, 21 242:5
entities 254:12 20 206:15 263:12 exchanges 117:21 experience 48:4
259:16 events 37:24 38:7, excite 176:3 112:10 158:20
13, 22 39:2, 24 193:17 260:14

15
experienced 260:3, fairly 32:8 83:20 Fest 161:2, 12 11 107:24 108:15

11 faith 11:6 204:25 109:16 111:17
experiences fall 196:21 field 113:2 115:3 116:20
190:18 259:22 falling 172:1, 14 138:22 224:23 151:20 153:5
expert 132:3 false 155:25 figure 44:16 154:24 155:5, 13,
134:5, 7, 9 138:1 familiar 35:13 123:2 145:19 14, 16, 20 191:6
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60:10 85:4 214:21 21 11

24
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meeting 66:22 189:1 217:15 115:10, 14 117:5, 173:2 174:4
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77:2 83:21 114:6 240:13 246:14 123:23 124:2

25
morning 9:4, 23 needing 44:10 204:14 205:1

101:23 <N> 99:24 100:8 217:5 260:17
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16, 17, 17 187:22 21 92:1, 5 93:15, 107:23, 24 171:3 206:4
213:14 220:20 18, 18, 21, 22 99:4, negligence 219:11 nicely 121:18
motions 26:3, 6 6 118:23 125:9 negotiate 240:9 Nielsen 164:7, 17
Mount 240:7 142:3, 11 171:11 neighbors 71:15 nine 39:5 41:18,
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12 204:25 188:25 190:7 121:18 122:22, 24 179:25
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52:5, 17, 22 53:2, 223:12 neither 86:1 nomenclature
8, 12, 14, 18, 21 named 25:22 180:12 263:10 144:16
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95:3, 20 96:2 names 142:15 never 35:19 15:23
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185:1 187:19 215:17 217:1 43:20 66:9, 9, 19 148:9
192:15, 24 226:16 naming 223:15 80:25 81:7 82:8, nonparties 103:6
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24 231:1, 17 necessarily 195:10 171:4, 6, 20 181:2 49:4 57:11 58:20,
232:2 244:3 212:23, 25 194:19 200:1, 3, 8 22 59:5, 11
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182:25 193:16 152:6 229:1 233:1 20 258:10
moved 106:8, 15 need 10:5 13:2, 6, 236:21, 22 261:12 normally, 59:12
107:10 114:7 6, 19 20:21 42:9 new 32:8, 9 93:1 North 5:7 192:11
179:1, 2, 5, 6, 17 43:7 56:19 107:11 108:16 199:11
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movie 188:23, 24, 150:25 151:4 8 134:24, 25 Northeastern
25 153:4 155:6 135:6, 16 140:7 129:15
moving 184:11 180:13 201:11 152:19, 22 161:3 Northern 27:16
mud 228:11 216:4 250:2 164:5, 17 179:11 35:22
multiple 55:21 needed 42:23 190:23 191:5, 12, Northwest 4:17
156:20 43:1 78:4 96:12 13, 21 192:11, 11 Notary 2:11
mutual 206:22 102:24 103:17 195:6, 11, 15, 17, 263:3, 19, 21
108:15 126:9, 13 18 199:3, 12

26
264:21, 23 247:1, 20 250:19 oh 12:4 17:1

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183:10 244:10 12:2, 4 100:21, 23 11:7 15:17, 21, 23 55:17, 25 60:10
Notice 2:7 27:19, 101:1 166:7 obligates 100:23 89:22 117:25
21 34:17 35:8, 24 230:12 264:14 observed 110:17 122:24 135:1
36:5 37:13, 14, 15 object 10:9, 19 112:21 148:11 158:15
152:24 15:9, 19, 21, 24 obstruct 152:13, 16 184:15 187:13
noticed 145:25 79:21 83:4 97:22 obtain 152:18, 19, 196:25 202:2
notified 109:1 104:4, 17 168:16 21 176:11 217:23 228:22 239:14
November 115:20 185:20 192:25 240:10 247:10 250:24
171:24 172:21 215:22 216:3 obtained 233:23 251:14
189:12 233:13 233:21 obtaining 152:14 Ohio 191:13
234:9 250:15 objected 10:24 obviously 201:11 192:12
number 8:10 20:9 226:11 240:8 OIL 1:4 3:13
14:2 18:8 25:15 objecting 152:5 occasion 83:25 8:5, 20, 23 9:25
32:23 33:12, 23 objection 11:3 84:3, 15, 25 27:7 72:1 80:22
34:12 37:9, 16, 22 14:17 15:13, 18, occasions 196:14 115:20 136:3, 9
38:10, 19 47:11, 25 18:20 21:7, 15, occupation 177:22 189:23 223:18
24 61:21 62:3, 19 23 22:5, 22, 23 occur 80:10, 13 235:16 264:3
63:1, 3 64:4, 14 23:1, 3, 16 24:14, 88:2, 3 Okay 10:4 11:17
75:1, 9, 17 76:16 20 30:25 32:18 Ocean 176:20 12:15 13:13, 20
80:15 88:9, 24 40:9 50:17 52:1 177:1, 6, 9 15:1, 4, 15 16:2, 9
89:13, 22 90:21 56:7 63:21 68:1 October 18:16, 17 17:9, 15, 17, 24
91:11 94:5 95:10, 69:23 72:22 80:3 19:2, 4, 13 194:10 18:6 20:5, 9 22:3,
15 96:13 97:6, 15 82:13 84:18 256:25 20 24:4 25:13, 21
98:9, 16 116:21 85:14 87:1, 12, 21 odd 88:3 26:11, 13 28:12
129:24 131:3, 6 88:6 111:5, 13 odor 145:23 29:8 30:22 32:1
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154:2 156:4 20 134:18 136:16 offered 105:13, 14 44:1 45:14, 18
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169:4 187:24, 24 140:9, 16 141:5 223:2 240:23 49:25 50:9 52:5,
194:8 212:9 143:8 144:13 243:9 16 53:7 54:17
213:13 214:25 145:12 146:16 office 29:3 34:14 55:15, 18 56:16
227:2 244:11 147:13 148:15 205:15 224:11 57:6 60:10 61:16
257:19, 24 170:14 172:4, 7 227:23 238:4 63:1 64:4 65:11
Numbers 39:7 187:2 193:1 Offices 2:7 67:18 69:16
130:15 131:23 208:1 209:13, 19 official 159:24 70:12 71:21 72:5,
132:5 134:14 211:19 214:17 173:2, 3 11 74:3, 23 75:9,
137:14, 16 230:10, 13 231:4 officials 140:14 17, 22 76:3 77:1
Nun 189:15 235:18 237:2 220:10 223:3 82:19, 20, 22
Nye 145:19 239:9 245:1 259:25 260:7, 23 84:14 85:10
261:1, 4, 5 86:13, 18, 22

27
89:22 90:10, 18 184:23 185:3, 11, 16, 22 261:7, 9, 14, organizing 190:21
92:2, 9, 13, 20 16 186:5 187:14 20 262:5, 8 204:12
94:5, 15, 23 95:4, 189:11, 18 190:4, old 56:17 108:11 original 27:20
18, 25 96:9, 14, 14 13 191:11, 17 147:15 176:19 189:21
97:2, 6 98:8, 16, 192:2, 8, 19 older 19:3 originally 68:19
25 99:8, 13, 16 193:19 194:2, 6, Once 91:21 102:17 106:11
100:9, 19 101:11, 19, 23 195:4, 15, 103:17 186:17 121:11 157:3
22 102:1 103:19 19 196:9, 13, 17, 196:15 200:21 217:9
104:12 108:15 23 197:10, 16 one-ninth 181:19, outflow 59:9
112:1 113:25 198:3, 10, 13, 17 21 outlining 34:20
115:9 116:12 199:5, 14, 25, 25 ones 104:2, 3 outreach 47:8, 20,
117:4, 17 118:2, 5, 200:11, 25 201:6, 131:4 142:5 22 48:3, 24 49:2
9 119:5, 12, 15 15, 25 202:14, 18, 144:17 191:23 50:2 193:12, 18
120:5, 10, 25 25 203:12 204:2, onslaught 171:2 199:6, 8, 13
121:12, 21 122:7, 2, 8, 13, 24 205:11 open 113:3 235:14 236:9
11, 17 123:3, 10 206:10, 16, 25 operations 146:6 246:21
126:18, 22 127:3, 207:5, 22 208:6, opinion 65:3 71:4 outside 32:15
8 129:5, 8 130:6, 14 210:10, 22 208:23, 24 104:21 113:18
18 131:9 135:13, 211:7, 16 212:4 opportunity 10:13 164:10 202:12, 15,
21, 25 136:24 214:25 215:7, 21 26:5 156:18 20
137:2, 9, 20 138:3 216:15 217:9, 22 opposing 219:18 overly 10:10, 20
139:11 140:5 218:9 219:8, 21 220:21 Owned 45:20, 21,
141:16, 22 147:23 220:2, 18 221:11, oppress 150:6, 6, 23 109:12 178:2,
148:10, 24 149:8, 13, 19 222:14, 23 17 3 181:11, 25
11 150:1 151:22, 223:14, 14, 23 oppressing 151:7 182:14
24 153:16 154:13, 224:10, 12 225:1, oppressive 104:20 owners 112:9
17, 23 155:4, 7, 12, 20 228:1, 20, 23 Orange 176:8, 10, ownership 181:19,
17 156:15, 24 229:24 232:16 14 21, 23
157:4, 25 159:2, 233:3, 9, 11 order 19:8, 12, 14 owns 109:11
14, 19 160:1, 6, 13 234:13, 17, 18, 21 20:2, 16 27:5 180:23
161:1, 5, 7, 11 235:4, 23, 23 85:12, 22 86:10, Oxford 3:7
162:17, 25 163:24 236:4, 7 237:18, 15, 24 87:10
164:21 165:3, 6, 21, 23 238:8, 24 152:7, 7 167:7, 10, <P>
10 166:9, 14 239:4, 15, 24 17 P.A 1:10 8:7
167:3, 12, 16, 25 241:6, 11 242:2 ordering 188:18 P.C 3:6 4:8 5:6
168:8, 13, 21, 23 243:2, 6, 22 organization 9:3
169:2, 9, 13, 23 244:15 245:5, 14, 22:20 23:10 p.m 165:13 166:2
170:9, 23 171:25 16 246:1, 10 39:22 52:20 54:4 262:17
172:11, 20, 23 247:14, 21 248:3, 65:25 123:19 PA 113:2 118:23
174:24 175:22 5, 8, 12 249:3, 9, 190:20 200:7 129:22 174:4
177:21 178:6, 9, 14, 21, 24 251:12, organizations 190:19 223:17
23 179:12, 19, 20 14, 15, 17 254:23 61:18 103:22 pack 212:13
180:2, 5, 25 181:3, 256:17 257:22 104:15 123:21, 25 page 1:25 3:25
9 182:1, 3, 8, 17 258:3, 8, 18 155:7, 10 190:23 4:25 6:3, 7, 25
183:10, 17, 23 259:11 260:6, 10, organized 91:14 7:3 14:16, 19, 23

28
15:5 25:16, 17 155:23, 24 168:3 pay 41:2 49:15, 124:16 126:24

129:15 155:24 219:8 19, 19 52:12, 22, 128:12 200:2, 3, 8,
162:11 167:9, 14 paragraphs 75:1 22 54:8, 8, 9 11 228:24 229:6,
169:5, 7, 10 parameters 55:12, 13, 15 20, 21 230:19
212:15 233:17, 20 145:22, 25 57:22 59:22, 24 233:2 238:25, 25
234:4, 6, 6 236:4 parcel 149:17 61:6 104:16 239:1, 2, 5, 6
237:8 238:8 182:13 105:4, 11, 17 240:11 242:8, 10,
239:24 244:19 Paris 261:11 118:6 119:7 11, 13 244:15
249:14 265:4, 7, Park 3:14 122:13 123:11, 19 249:25 252:4
10, 13, 16, 19 parody 64:23 125:5 126:17 253:15, 15 254:23
266:4, 7, 10, 13, 16, 65:4, 12, 24 66:23 128:8 182:3, 10 pays 51:24 52:9,
19 67:25 69:4 70:13 196:4, 8 200:20 12, 17 54:6 118:25
paid 42:13 49:12 170:6 202:7 231:20 Peace 62:14 189:4
50:3, 10, 14, 15 part 44:15 48:24 237:11 238:16 pegged 227:16
51:2, 15, 21 54:20, 50:8 54:16 66:8, 239:22 241:2 PENALTY 264:6,
25 55:1, 5, 23 13 69:18 79:7 248:13 253:1 7
56:1 65:22 94:23 92:7 101:2, 23 258:13 pending 13:4
95:6 116:14 118:14, 17 149:17, paying 23:14, 21 Penn 256:20
117:5, 14, 22 25 151:12 173:3, 24:2, 7, 18 30:24 257:2, 5, 14, 14
119:2, 6, 8 122:25 5 192:14 193:2, 44:8 53:8, 11, 12, PENNSYLVANIA
124:6, 7 125:7, 8 22 198:9 200:13, 14 55:9 61:12 1:2 3:9, 16 4:10
127:18 161:11, 14 24 209:16 214:22 95:7 117:8, 21 5:8 48:5 91:6
182:1, 11 184:13 217:22 225:18 118:10 121:1, 4 104:22 115:21, 22
187:17 192:15 227:14 246:6 122:18, 18 127:15, 170:12 179:13, 17
196:6 199:18 254:5 255:24 24 151:21 201:9 190:21 195:6, 11
202:10, 19, 20 257:16 202:7, 25 203:3 198:12 199:3
225:2, 5, 23 participate 67:24 230:6, 7, 25 231:1 202:21 217:5
226:16 229:11 participating 236:11 237:12 227:3 248:19
232:17, 24 236:25 216:2 239:11, 12, 16 people 13:18
238:19 239:18 participation 62:5 242:9 244:21 16:17, 19, 20 28:6
240:22 242:3 particular 146:14 248:3, 22 249:16, 29:25 34:22 47:9,
246:11 249:21 214:10 232:11 18 250:17 255:4, 11 49:15, 19 50:7
251:6 253:18, 24 particulate 61:3 18, 21 256:2 55:15, 22, 22 56:1
255:6, 9 258:20, 23 parties 2:13 257:3, 4 61:6, 12 69:7
panel 135:14, 15 10:19, 22, 22 payment 24:24 70:24 71:3, 16
paper 35:15 parts 82:9 41:1 55:13 91:1 72:2 73:23 77:8
36:20 57:2 64:25 party 25:22 96:23 233:16 78:3 81:17, 18
66:6, 7 75:8 33:20 150:19, 22 235:5 239:12 86:14, 17, 21
86:16 171:7, 9, 21 152:5 153:2, 5 247:25 254:20 92:10, 13, 16, 21,
papers 32:2 56:19 263:11 payments 39:9, 20 22, 24 93:3 99:23
paperwork 27:13, Pass 27:2 40:2, 6, 17, 21, 24 100:1 102:23, 25
18 passed 40:22 42:1, 3, 5, 10 53:2 103:1, 2 106:10,
paragraph 15:5, 5 181:10, 17 61:5 95:11 96:15, 12 112:3 113:1
16:5, 6 27:4 Patriots 136:3, 8 20 98:9, 10, 13 116:5 118:15
76:16 88:9 189:19, 22, 22 117:18, 18, 19 119:17 120:2, 6,

29
10, 12, 18 121:6, 7, 114:8 124:24 72:12 78:13 145:14 163:3

10, 19, 22 122:8, 127:22, 23 128:13 94:22 112:4 177:6 207:3
12, 13 123:1, 14, 159:10, 24 173:1, 184:2, 10 226:18 poison 34:21
16, 21, 23 124:3, 17, 25 174:3 227:17 242:19 Policy 256:20
11 125:14, 17, 20 195:25 206:14 261:22 257:3, 6, 14
126:6, 7 143:20 214:5, 7 232:11 pipelines 48:23 poor 246:22
147:10, 11, 20 personal 193:17 51:5 183:20 portion 26:3
157:12 158:3 207:19 260:14 pitch 122:22 112:24 140:2
159:7, 9 164:1, 2, personally 23:22 Pittsburgh 3:9, 16 POSEY 4:15, 16
9 168:19 173:7, 7 29:17 174:18 223:16 9:4, 5 10:5 14:17
184:3, 14, 16 194:25 place 176:20 15:9, 16, 16, 22
190:16, 18 191:9, persuade 88:11, 20 182:19 217:5 18:20 21:7, 15, 23
13, 20, 23 193:13, Philadelphia 260:11 22:5, 8, 10, 21, 22,
20, 21, 23 194:25 76:25 77:4 204:4, places 10:20 12:1 24 23:14, 16, 19
198:22 202:12 9 248:19 257:6, 15 108:21 151:10 24:4, 14, 20, 23
203:6 204:11, 22 Phone 52:13 184:19, 19 195:9, 30:25 31:7 32:18
205:25 208:22 215:13, 18 216:18, 13, 15 196:3 40:9 50:16 52:1
209:5, 7 210:14 19, 24 217:22, 24 197:17 198:22 56:7 57:8 63:21
215:9, 11, 16, 20 218:3, 6, 7, 8, 9, 25 plaintiff 10:15 73:15 79:21 80:3
216:23 217:8 219:1 Plaintiffs 1:7 2:7 82:13 83:4 84:18
218:6, 15, 22 phonetic 62:14 3:3 8:20 9:21 85:14, 16 87:1, 12,
220:9 222:25 77:17, 17 160:10 plane 188:18, 19 21 88:6 97:22
226:19 236:9, 16 photo 148:12 planned 160:20, 104:4, 17, 24
248:25 256:5, 6, physically 222:2 23 191:5 111:5, 13 112:7
11 257:4 picked 179:4 played 136:25 128:4 130:12, 25
people's 147:12 215:10, 11 157:10, 14, 21 131:20 132:13, 15,
perceived 70:23 picture 135:19 158:8 23 133:10, 20
perfect 247:10 piece 56:2 58:6 pleadings 9:10 134:18 136:16
performed 138:23 59:8, 10 64:25 PLEAS 1:1 137:24 139:15, 24
period 153:12 66:5, 7 75:7 167:19 140:9, 16 141:5
184:23 191:25 171:7, 8, 21 181:12 pleasant 16:10 143:8 144:13
230:16 257:8 pieces 55:24 please 9:15 11:2 145:12 146:16
PERJURY 264:6, Pierce 160:10 13:11 23:8 80:18 147:13 148:15, 18,
7 PILSNER 3:5 135:12 149:10 22, 25 149:3, 5, 10,
permanent 84:22 8:19 83:12, 15 220:20 13 150:1, 4, 10, 13,
permanently 84:23 114:20 129:3 plus 53:6 23 151:3, 17, 24
permission 213:3 153:22 161:25 POA 213:1 152:1, 4, 11, 17, 23
permitted 15:18 211:25 224:4 223:12 153:13, 15 168:16
person 28:4 233:5 244:7 pocket 117:3 170:14 172:3, 7
32:21 33:14, 25 247:7, 9 256:15 pockets 215:3, 4 185:20 187:2
34:9 39:10, 21, 21 257:20 218:19 192:25 208:1
40:3, 7, 17, 18 pipeline 48:6, 12, point 67:23 74:6, 209:13, 19 211:19
43:8 59:10, 19 16 49:8, 13, 21, 23 20 106:24 108:15 214:17 216:3
62:5, 16 64:5 50:12 51:4, 12 113:8 122:17 230:10, 13 231:4
68:9 94:7 102:2 52:7, 8 53:4 69:8 233:21 235:18

30
237:2 239:9 preliminary 10:6 6, 13 138:10 process 31:5

244:25 247:1, 20, premier 222:8 141:8, 13, 19 227:15, 18 241:9
22 250:19 256:22 prepare 10:14 156:7, 17, 24 processing 30:17
259:19 262:11 20:12 157:2 192:17 Produce 32:23
Posey's 22:18 prepared 162:10 213:5 222:6, 10 33:12, 23 34:12
position 94:16 preplanned 188:8 private 34:19, 21 37:9, 22 38:10
205:20 209:4 presence 110:14 36:13, 24 37:3 39:7 62:19 63:3
positive 79:9 130:10 48:5, 7, 10, 16, 23 64:4, 14 75:9, 17
92:4 93:2 107:11 present 2:12 5:11 49:4, 21 50:11 76:16 80:15
159:4, 17 162:14 9:9, 14 33:25 51:13 55:10 88:18, 24 89:13
163:14 164:13 35:4, 16 38:3, 14 185:22 203:9 90:21 91:11 94:5
169:15, 24 198:24 39:12 46:14 225:13 226:2 95:10 96:14 97:6,
201:13 203:2, 4, 62:21 72:6 76:18 privilege 23:20, 23, 15 98:9 223:9
10 206:21 218:4, 85:24 98:18 24 24:3, 24 69:24 produced 36:25
22 229:17 230:5 110:21 156:2, 11 72:23 73:2, 4, 7, products 186:12
231:12 232:12, 22 160:25 162:16 11 215:23, 24 professional
238:14 255:14 199:14 205:24 216:2, 6, 17 116:18
possession 11:9 206:1 211:4 Privileged 22:5, 7, proffer 149:13
63:12 64:21 224:7 9, 11 68:6, 24 151:1, 5
possibility 229:13 presentations 38:1 105:9 promote 199:10
231:23 presented 171:12 pro 69:7, 8 70:24 promoted 127:5
possible 78:22 president 77:18 probably 60:14 promoting 126:12
201:21 202:2 135:22 136:4 61:14 65:1, 20 promotion 127:4
possibly 36:19 press 34:14, 16, 25 104:14 118:3 proof 78:19
200:14 35:2, 3, 14 36:4 120:13, 15 122:9 220:24
Post 34:14 205:12, 12 206:12 149:24 172:22 properly 18:12
107:17, 20, 22, 24 pretty 51:8 99:16, 174:19 184:21, 22 28:9, 11 103:8
205:15, 17 18 108:12 110:24 191:23 192:6, 20 properties 181:13
posted 223:15, 15 131:3 147:15 201:12 202:10 228:16
Post-Gazette 183:11 185:7 212:7 property 11:20, 21
223:17 204:22 209:5 problem 49:8 48:6, 7, 10, 17, 23
posting 107:15, 18 211:15 222:7 78:6, 16 92:6 49:5, 21 50:11
potable 134:12 259:1 145:18 156:8 51:13 67:1, 8, 11,
potential 201:18 previous 16:20 207:21 228:15 12, 13, 15, 16, 24
226:19 32:8 44:11 problems 49:21 68:5, 15, 19 70:7
potentially 29:15 166:11 209:3 66:25 72:1 72:12, 12 74:8
power 89:1, 7 247:20 112:11 145:20 78:14 89:3, 8, 9
162:9 163:1, 4, 10, previously 101:5 173:14 226:20 109:12 112:9, 14
17 164:21, 23 169:10 227:18 228:3, 18 114:7 163:19, 20,
212:18 price 201:7 procedure 59:14 22 164:1, 3, 12, 17
predrill 130:7, 9, primary 177:22 proceed 10:8 173:15 181:6, 12,
11, 16 131:15 183:16 proceeding 263:12 14, 16 182:18
137:4, 22 138:12 printed 168:12 proceedings 183:19, 19 184:5,
preexist 80:5 prior 22:4 28:19 262:17 10 225:6, 8, 8, 10,
36:4 76:3 114:3, 18 226:3, 5, 7, 17,

31
21, 25 227:2, 13 purpose 68:10, 11 59:16 60:16, 16, 17 212:5 215:15,

228:14, 19 249:9, 73:9 115:16 19 85:23 134:9, 22 216:21 219:1,
11 260:15 160:6, 13, 19 10 146:23 156:3 10, 23 262:5, 7
prospective 22:11 161:21 188:4, 6, 180:7 227:20 raise 93:19
protection 167:10, 10 220:17 quash 167:8, 10, raised 23:1, 3
17 purposes 14:2 17 213:14 220:20 31:2 242:22
protective 152:7 18:7 25:14 50:12 question 12:21 ran 227:7
protects 142:4 57:18 97:25 13:4, 5, 9, 12 range 43:6, 12
prove 78:14, 15 114:25 129:9 22:12 23:7 29:18 55:20 78:4 90:14
proven 78:15 162:5 166:22 31:8, 19 34:6 122:9 131:24
113:6 169:3 172:9 38:18 40:1, 11, 15 224:15, 17
provide 10:21 194:7 212:9 41:9 44:14, 15 rapidly 108:12
59:15, 17 127:16 215:23 233:10 51:1, 9 63:24 rates 238:11
193:10 233:24 244:11 247:15 81:13, 22, 24 RAY 1:12 9:3
provided 60:1 250:13 252:11 84:12 87:8 98:7 91:14 106:10
providing 69:2 256:18 257:23 135:4 137:10 116:10 117:2
237:24 pursuant 2:7 138:7 143:4 120:16 121:23
prudent 9:11 put 17:23 57:5 144:4 148:1 129:22 130:1
141:2 78:13 91:22 92:1, 225:20 234:2 142:5, 21, 21, 22
Public 2:11 77:15, 5 95:24 99:11 239:20 148:2 157:6
20 89:24 160:14 102:12, 24 103:12, questioning 11:4 173:6 195:4, 18,
190:17 236:22 16 107:23, 25 15:10, 25 50:17 23 196:12 198:24
263:3, 19 264:21, 113:17, 18 115:23 58:1 105:1 201:24 206:8
23 124:20 127:9, 20, 148:21, 23 152:3 209:2 211:3, 5, 9,
published 190:12 20 136:2, 8 168:17 233:22 11 218:4 219:2
194:9 144:15 155:6 245:1 220:12 223:25
pull 82:21 113:2 157:3 158:1 questions 12:17 224:16 256:7
135:11 147:18 160:14, 16, 19 15:14 44:7, 11 260:12, 18
156:15 235:3 168:10, 11 171:19 71:16 73:16 RAYMOND 5:3
purchase 55:6, 10, 182:7 184:16 101:8, 23 153:10, 8:8 129:18
11 57:19, 20 189:4, 16 194:18 10 166:11 208:10 212:18 222:23
58:14, 17 59:1 195:2 197:7 215:23 259:12 Ray's 122:6
89:15 90:23 208:13 212:25 261:25 262:2, 3, 6, 208:20 221:9
100:2 114:17 213:1 219:16 9 reach 24:11
115:16, 18, 18, 19 223:12 227:17 quick 165:7 250:2 reached 189:16
118:12 196:4 238:13 241:24 QuickBooks 56:16 reaction 84:5
purchased 57:10, 242:24 254:21 quite 65:23 71:2 read 16:4 23:7
16, 23 58:24 puts 160:17 98:24 184:5 26:3 35:7 75:24
89:20, 25, 25 90:1, putting 66:6 196:11 197:6 80:7 89:24
2, 4, 13, 17 99:2 191:7 227:9 198:16 205:25 156:18 212:7
115:10, 14 252:21, 242:20, 21 234:14 264:8, 10
24 <R> Reading 5:8 76:3
purchasing 59:4 <Q> RAIDERS 5:5, 6 95:14 213:22
181:22 188:18 quality 49:23 9:2, 2, 2 208:8 245:3 262:16
purifying 177:24 51:4, 12 52:8 210:23 211:1, 8,

32
reads 235:7 110:18, 19 126:25 169:4, 5, 6 212:10 98:3, 10 103:21

ready 176:5 156:11, 14 157:13 244:12, 12 255:1 referenced 223:7
real 103:10 158:11 159:2, 11 recognized 174:22 references 233:17
163:20 176:19 160:1 161:22 recollection 37:21 234:10
Realist 111:25 163:24 169:14 76:12 93:12 referencing 26:19
112:1 173:22 186:24, 24 156:16 205:9 referral 23:12
realize 234:20 191:15 201:22 record 9:8 10:5, 71:14
235:2 204:13 208:14 8 13:17, 20 15:17 referring 17:2, 17,
realized 27:14 212:11 215:21 26:19 28:14 57:7 25 27:10 28:18
102:15 103:18 216:23 218:18, 24 68:17 77:16, 20 51:18 65:8 67:11
123:7 240:24 219:3 229:5 84:13 95:21, 23 134:22
realizing 123:5 242:12 100:14, 15, 16, 20 reflect 39:9, 20
237:15 recalled 204:24 135:13 136:25 80:16 89:14
really 79:9 92:15 receipt 58:12, 14, 148:18 149:2, 4, 6, 90:22 91:12
116:1 125:12 16 91:16 115:3 9, 12 151:5 157:6, 95:11 96:15
127:1 136:18 219:19 10, 14, 21 158:8 98:10
140:15 143:22 receipts 58:10, 21 165:11, 12 166:3, reflected 142:13
159:12 174:21 receive 51:10 6 185:23 216:5, 8, reflecting 61:22
184:18 185:23 77:24 91:23, 25 10, 11, 12 250:4, 6, 142:14
190:20 191:22 95:19 103:19 9 259:4, 6, 7, 8 reflective 131:6
195:17 197:7 received 27:13 262:13, 15 reflects 142:25
199:1 203:7 39:9, 20 40:2, 6, records 20:22 refresh 156:16
206:22, 23, 23 17, 21 59:7 61:16, 25:19 31:14 32:3 204:15
207:16 214:21 17 77:14 91:13 57:15, 25 58:8 refused 10:15
223:13 227:18 95:19 96:6 59:6 98:22 147:2, regarding 64:16
246:2 261:5 156:25 200:1, 3, 8, 3, 8, 9 202:4 68:14, 23
reason 29:21 11, 25 201:19 203:8 229:5 Registration
127:21 145:4, 5 229:2, 25 253:15, 253:10 254:19 264:23
183:4 220:8 15 255:17 256:19 recurring 202:6 regular 239:3
230:23 265:6, 9, receives 154:6 redacted 81:1 regulations 135:17
12, 15, 18, 21 receiving 24:1 85:18 86:2 regulatory 131:18
266:6, 9, 12, 15, 18, 68:10 70:4 73:9 129:23 142:4, 16 reimburse 125:10
21 95:22 123:18 143:23 reimbursed 245:19
reasonable 202:3 125:1 128:11, 15 refer 31:14 32:24 reimbursement
reasserted 11:3 193:8 202:15 33:13, 24 34:13 95:7 98:14
Rebecca 2:10 228:25, 25 238:16 37:23 38:11 39:8 125:15 244:22
9:15 263:2, 18 239:25 240:19 62:4 63:4 64:6, 245:23 248:24
rebuttal 170:6 241:13 242:8 15 68:8 74:18 254:12
recall 12:3 17:8 243:7 244:16 75:2, 10, 18, 19 reimbursements
19:17 31:18 33:2, 247:17 254:3, 12 76:17 85:12 125:13 236:2
17, 21 34:5 35:11 258:15 88:10, 18, 25 reimbursing
36:7 44:24 80:23 recess 165:13 89:14 90:22 125:12 245:7
81:8 83:13 85:5 recognize 14:3 91:12 94:6 95:11 253:3
98:15 106:14 18:8 20:4 157:16 96:15 97:7, 16, 23 reiterate 172:7
107:15, 18 109:17 162:6 167:1 244:25

33
relate 31:14 248:25 251:9 representatives 16 167:4 171:16,

32:24 33:13, 24 254:17 260:4 17
34:13 37:23 remembering represented 68:2 responses 101:4
38:11 39:8 62:4 184:24 203:15 69:25 73:25 77:5 104:6, 7
63:4 64:6, 15 remotely 32:17 representing 8:15 responsibility
75:10, 16, 18, 19 removal 91:7 26:23 68:3 70:7 125:3
76:17 80:16 Renard 198:11 72:20, 21, 24 responsible 29:24
88:10, 18, 25 rendered 235:7 73:10, 21, 22 74:4, responsive 11:9
89:14 90:22 rendering 235:9 12, 21 104:19 19:25 31:17
91:12 94:6 95:11 rent 182:3 248:5, 219:5, 6 32:25 33:5, 15
96:15 97:7, 16 15, 22 257:5, 9, 10, request 31:17, 20 34:4 38:6, 17
98:4, 10 16 33:1, 16, 18, 22 39:14 62:23 63:9
related 11:1 rental 257:7 34:4 38:17 62:24 64:11, 18 75:13
33:18, 22 34:24 renters 28:5 64:12, 19 75:14 76:22 88:15, 22
35:1, 12 38:9 renting 248:4 76:23 88:16 89:16 91:2, 19
40:1, 13 41:9 249:9, 11 89:17 91:3, 20 94:11 97:12
44:7 48:23 49:23 repair 97:3 94:12 98:21 98:20
68:4 80:24 95:16 repeat 113:7 155:8 rest 26:9 67:14
97:14 101:19 repeatedly 215:25 requests 11:9 152:15 181:23, 24
102:3 149:19 repeating 38:18 213:15 219:15 218:24
255:12 263:10 rephrase 13:11 require 10:7 Restating 63:24
relating 11:22 45:4 15:22 Reston 179:6, 15,
34:6 39:17 63:6 replacement required 78:16 15, 16 180:18
98:7 117:10 219:18 181:7
relation 161:15 report 56:14 reschedule 10:15 restroom 13:7
relationship 95:2 127:17 129:14, 16 research 236:21 result 84:1, 8
106:25 107:7 reportable 128:3 256:20 257:2, 5, 14 129:12 133:17
172:15, 17 174:10 reported 127:13 residence 28:21 146:6
relevance 50:21 Reporter 2:11 residents 174:3 results 76:19, 20
51:6 103:16 9:15 12:23 61:25 resolved 226:22 77:10, 24, 25 78:2
104:5 158:13 169:19, 22 Resources 224:15, 130:7, 10 141:3
relevant 22:24 251:20 253:21 17 142:13 143:18, 25
23:3, 4 31:3 51:8 263:2 respect 37:16 144:2, 5, 11, 12, 20,
104:18, 21 151:14, reporters 83:1, 21 54:13, 18 77:23 25 146:3, 11
15 153:11 236:23, 24 182:13 183:19 151:14
remember 71:13, reporting 211:17 216:18 retail 54:23 55:8,
24 72:8 83:17, 21 represent 8:17, 19 respective 2:13 11 56:4 57:21
121:25 158:16 9:25 23:15 72:13, respond 26:5 186:6, 12, 12
159:11 164:18 16, 17 143:5 responded 102:14 retain 22:20
181:1 196:19 154:25 155:13 155:8 71:10
197:6 198:14 217:12 responder 99:20 retained 20:11
200:10, 17 202:16 representation responding 18:13 21:6 66:25 67:8,
203:18 205:8 67:6 73:18 19:1 19 68:2, 18, 20
217:1, 2 218:21 representative response 19:20 70:9, 9
229:11 237:15 186:8 20:6 51:17 65:5,

34
retaining 67:2 Ron 223:25 Sautner's 107:16 236:6 237:21

68:14 224:16 save 264:10 240:1 241:18, 20
returns 228:6 room 9:8 199:22 saw 76:1, 25, 25 244:21 245:3, 18
review 86:6 Rooney 2:8 3:6 99:23 109:20 Scanlon 4:8
130:2, 4 145:1 Roos 16:23, 25 110:22 113:4, 12, schedule 109:4
229:17 17:1, 5, 10 14 133:13 141:13 152:25 193:3
reviewed 157:1 round 210:20 157:2 169:8 scheduling 44:7
revoked 164:23, 25 Ruffalo 200:12 188:13 212:14 school 56:18
Rich 9:2 219:10 201:1 232:17, 19, 245:5 175:10, 12, 14, 15,
RICHARD 5:5 23 saying 12:24 16, 20
right 25:24 26:22, Ruffalo's 190:24 19:23 20:1 27:22 science 145:19
25 43:15 44:13 Rule 150:16 152:1 28:12 29:8 31:23 Scientific 176:20
52:19 58:3 68:20 rules 10:7 15:22 37:11, 18 41:11, 177:2, 7, 9
81:20, 22 86:2 run 99:22 114:12 19, 21 42:4, 13 scope 104:21
90:18 93:22 98:1 228:2 43:1, 23 44:4, 6 Scott 17:2
99:16 108:9 running 176:23, 24 48:15 52:16 55:1 Scranton 4:10
115:6 123:16 rural 173:3 84:25 86:15 scrape 228:11
124:20 127:18 RYAN 4:15 9:4 103:4 110:10, 19 screening 188:23,
133:16 134:1 112:20 117:12, 22 24 222:18
138:18 147:1 <S> 118:25 124:9 screenings 199:11
148:24 150:8, 12, safe 79:19 134:13 126:4, 4 130:20 sealed 81:1 85:18
16 153:14 157:5 sale 45:14 54:22 132:8 133:6 86:3
159:2, 19 161:18 58:6 89:2, 9 137:13 147:19 searching 115:4
165:10 168:2 sales 45:13 46:3, 150:24 155:17 second 31:20
178:6 206:4, 6 15, 19, 19 54:16, 158:20 171:17 62:16 75:23
207:23 213:1 18, 21 56:13 90:3 191:15, 19 202:19 226:8 258:2, 4, 11
214:12 215:13, 16 115:5 208:16 209:22 secondary 222:12
217:17 228:10, 11 salesperson 77:5 219:16 224:23 seconds 25:8
229:10, 18 242:25 saling 55:2 227:14 228:1 26:4, 6 239:4
246:25 251:11 sample 76:19, 20 229:10 239:6, 14 section 31:12
252:20 253:9 129:17 137:22 242:12 243:2, 4, 194:22
261:24 262:8, 12 138:12 20 245:17 248:21 secure 105:18
right-of-way 53:5 samples 210:11 says 17:13, 22 106:1
184:2 242:20 sanction 167:11, 19:2 25:21 31:12 security 9:12
rights 146:23 18 32:23 33:12, 23 see 15:8, 10 25:23
163:18 183:19 sanctions 27:8 37:4, 5 38:10 27:12 34:1 37:5
184:10 189:20, 22 28:25 29:1, 9, 20 76:16 81:25 38:3, 14 39:12
ringing 52:13 30:5 211:17 91:11 94:5 50:18, 20 56:20
Rising 198:10 Santa 178:4 129:22 133:24 62:21 63:2, 7
Road 67:17 Sautner 106:19, 135:21 136:4 64:7, 16 75:11
106:10, 12 111:8 21, 25 107:8, 21, 138:5, 18, 22 76:20 78:18, 19
142:3 181:15 21 108:3 146:19, 23 150:16 80:17 81:2 84:9,
rock 228:10 Sautners 106:7 152:1 156:7 21 86:4, 5 88:13
rode 108:22 191:23 195:18 163:18 212:15, 16, 89:3 91:16 94:8
rollcall 217:7 16 213:13 219:10 96:16 97:6, 9, 17

35
98:18 99:21 selling 163:19 159:4 182:23, 25 83:3 85:10, 11, 22

104:18 113:21 186:6 254:1, 15 86:17, 19, 24
125:21 131:23 seminars 38:1 series 233:11 87:19 88:5
141:18 142:10, 15 47:10, 14 serious 102:16 120:13
144:12 145:6 senate 12:6 103:18 settling 107:12, 16
146:1, 8, 10 153:7 134:16, 21 135:1, 5 seriously 226:11 setup 93:8
156:15 157:17, 17 send 54:11 56:19 serve 27:12 28:9 seven 29:22
160:18 175:2 124:19 125:9 30:1 135:9 224:20
181:2 191:9, 14 126:7 127:22 served 10:11 226:6 235:1
201:3, 4, 13, 22 185:11 194:17 18:12 28:11 253:13
203:8 209:4 208:7 212:21 103:8 188:1 shake 13:18
212:19 213:17 219:17 223:4 212:6 Shale 77:2, 3
219:19 220:22 231:10 232:1, 9 server 32:15 204:3, 3
223:2 226:7 243:12 service 10:25 Shales 136:4, 9
229:6, 12 230:2, 5 sending 123:23 28:19, 20 117:14 189:23
233:18 234:11 124:2, 12 156:24 serviced 121:10 shape 221:24, 25
235:25 237:8, 19 191:9 213:5, 6 SERVICES 1:5 222:2, 7, 13, 20
238:13 239:14 219:14 232:15 5:13 8:6, 21 shape, 221:25
240:1 241:19 234:21 241:22 42:14 53:20, 22 Shapiro 34:19
242:24 244:23 243:15 245:10 60:4, 6, 7 117:19 37:17 223:17
245:19, 24 248:1 246:5 127:16 235:7, 9 share 37:3, 6
249:1 251:16 senior 8:23 237:24 238:10 153:21 236:13
252:18, 22 253:6 Senseless 71:6 SESSION 166:1 shared 122:15
254:16, 20 256:21, 75:3, 3 set 47:10, 14, 17 sharing 185:23
25 257:13 sent 15:12 103:7 64:23 65:5, 12, 14, SHEET 264:1, 12
seeing 158:16 149:14 156:21 25 66:4, 6, 7, 23 265:1 266:1
183:7 212:11 194:15, 24 201:4 68:13, 21 69:1, 9, sheriff's 30:17
seek 83:25 85:7 212:5, 13 219:22 16, 18 70:15, 16, shipped 258:6
seeking 103:14 220:25 241:25 22 71:7 91:22, 25 short 15:23 176:2
206:17 243:17 92:2, 9, 12, 17 191:24 230:3
seen 35:10 66:9, sentence 25:9, 25 93:16, 25 94:4 shortly 162:20
19 82:17 106:21 SENTINEL 5:13 119:24 123:15 shot 160:9
114:16 124:4 190:9 136:15 171:5, 18 show 29:4 47:10
141:7, 17 143:18, separate 44:15 185:3 197:5 57:23 58:8 61:9
21 145:2 160:4 54:15 118:19 217:24 218:3, 7 62:20 68:17
169:10 181:4 119:14 155:11 222:15 240:14 78:16 83:5 91:8
213:22 236:21, 22 161:10, 10 195:24 setting 66:13 95:13 96:17
selected 256:9 197:14 229:15 67:25 69:3, 21 98:17, 22 115:24
self 192:18 separated 180:11 71:5 92:7 93:3, 5, 138:15 157:6
self-employed separately 119:3, 10 106:9 171:19 186:17, 20
45:8 48:18 49:16 7 197:14 204:10, settled 86:14 190:17 250:16
50:22 98:23 20 205:6 222:17 120:18 253:10
self-supportive September 83:12, settlement 80:17, showed 81:7
184:7 15, 17 120:14 19, 21, 25 81:3, 14, showing 91:16
sell 134:10 156:10 157:9 23 82:2, 5, 12, 25 126:11, 14, 15

36
131:16 132:1 25 182:6 155:16, 20 159:6, speculation 87:22

135:13 241:25 Sisters 189:14, 14 8, 15 160:16 209:16
shown 127:10 sit 147:7 175:1 178:20 speech 146:22
shows 91:10 site 64:23 65:4 194:24 208:11 speeches 110:17
139:20, 21 186:13, 69:4 70:13 91:13 209:1 217:20 speed 10:16
14 193:14 239:24 92:18 93:6, 22 218:5 242:22 SPEER 1:9 4:4
251:5, 17 256:19 136:7 171:18 254:14 260:3 8:6, 6, 25, 25
shrunk 158:21 sites 65:18 71:1 somebody's 146:1 64:23 65:12, 25
sic 39:7 161:12 146:20 someone's 132:12 66:3, 10, 15, 22, 25
204:25 sitting 137:13 son 188:9 67:5, 5, 19, 24
side 50:8 80:12 160:8, 11 soon 149:25 68:2, 5, 14, 18
127:20 171:20 situation 125:21 sorry 26:21 53:23 69:2, 11, 20, 24
180:4 185:8 218:15 226:13 129:6 158:13, 15 70:5, 20 71:10
208:20 209:4 six 72:4 83:19, 20 169:19 204:17 72:13, 14, 19, 23
236:19 240:16 120:17 122:1 250:24 251:20, 22 73:20, 22 74:4, 18,
260:15 147:14 156:13 sort 125:22 21 75:6 154:3, 4
sided 206:22 177:3, 3 203:18, 198:23, 23 171:13 173:10, 20
sign 66:24 86:17 23 205:8 214:20 sources 62:20 264:3
87:3 171:8 218:21 256:5 Southern 199:12 spend 214:21
signature 14:15, skin 158:22, 25 Southwestern spent 106:18
24 162:11 167:14, Skinner 103:2 113:1 116:19 175:19
25 171:23 262:16 161:19 162:15 speak 39:2 48:7, 176:10 179:6
SIGNATURE: 172:23 173:21 9, 12, 18, 19, 19 199:2
265:23 266:23 174:7 213:16 49:17 85:22 split 186:19
signed 17:20 skunk 145:17 123:25 124:23 239:15
64:25 66:5, 7, 19 slash 121:14 141:1 146:19 spoke 37:25
78:13 82:8 85:24 small 131:3 148:22 189:12 211:1, 4 235:20
86:19 107:4 smell 85:1 208:19 240:18 spoken 236:25
148:9 162:16, 17 smelled 85:2 speaking 15:17, 20 sponsored 199:16
167:21 168:11 smelling 84:16 37:24 38:7, 13, 21 spring 106:15, 16,
169:6, 11, 13 145:17 39:11, 17, 23 40:4 17 196:20
170:18 242:18 snap 194:8 41:6 62:6, 11, 15 stack 156:21
250:24 251:1 soda 13:8 192:21 204:14 stalk 29:25
264:15 sold 58:25 163:22 211:2 236:10 stalked 27:6, 25
signing 29:14 182:15, 16 186:11, 246:22 261:15 28:12 29:7 30:21
75:7 170:4, 11 25 special 144:16 stalking 27:11
171:6, 21 251:18 sole 124:24 specific 73:5 28:18 29:12, 16,
silenced 210:1 soliciting 93:15, 246:16 24 30:14
Silver 67:17, 17 17, 23 specifically 39:19 stand 155:1
72:12 169:18, 18 somebody 27:14, 46:1 150:19 Standing 91:14
simple 51:1 17 43:7 57:20 216:6 229:19 103:8
single 65:19 71:15 87:5 92:25 231:8 260:18 Stapler 247:6, 7
241:24 94:3 99:21 specifics 207:4 start 12:21 25:18
sister 181:18, 20, 108:16 110:10 speculate 209:18 52:25 53:2 82:1
124:9 132:5 129:24 155:23, 25

37
176:17 178:16 staying 107:10 story 65:20 76:1 summit 261:10

183:24 184:9 179:12, 13 196:6 206:3 236:19 summits 38:1
191:9 216:21 steadily 186:15 237:6 sums 42:25
222:3 232:5, 15 steady 185:7 straight 124:13 supplied 57:24
254:8 step 99:24 116:3 194:21 205:22 supply 34:1, 10
started 10:1 12:9 123:14 149:7 206:7 76:18 160:3, 22
48:22 53:8 74:16 stepping 148:25 strange 113:23 support 38:12
84:4, 7, 16 85:2 STEVENS 2:5 stranger 114:10 65:18 69:7 124:8
109:24 110:9 6:4 8:4 9:5, 18, stream 228:7 210:17 246:25
116:4, 7 119:21 23 10:11, 18, 21 Street 2:8 3:7 supported 236:18
121:11 123:14 11:6, 11 13:23 4:17 5:7 8:13 241:4 246:15
124:12 126:6 16:5 18:3, 6 22:6 stress 30:9, 23 supporters 65:3
176:18, 22 177:10, 23:6 25:3, 13 31:4 146:22
17 178:1 183:18 70:2 100:19 stressing 112:6, 9 supporters, 65:7
184:15 190:24 129:8 133:4 stresswise 211:13 supporting 65:23
191:2, 12 192:6 135:14, 19 138:7 strictly 119:5 246:17
202:9, 22 153:18 162:4 strike 88:3 261:9 supportive 220:4,
starting 27:14 166:6 169:2 students 164:7 6
46:13 53:1 172:6 194:6 studying 176:4 supposed 27:20
108:23 123:22 212:18 213:1, 16 subject 11:7 69:9 82:9 129:3
242:16 243:21 215:25 216:15 subjects 47:24 210:7
state 15:6, 18 220:22 230:12 submit 220:19 supposedly 36:12
27:5, 6, 23 28:7 233:9, 24 234:8 subpoena 10:10 188:1
34:20 57:4 124:3 235:6 240:1 18:10, 12, 13, 18, sure 37:12 50:9
125:15, 17 126:7, 247:14 250:22 22 19:21, 24 20:4, 51:6 58:4 62:8
8 164:5 192:10 252:10 256:17 6 28:19, 21 29:4 64:2 71:15 74:24
200:24 257:22 259:11 31:11 61:20 75:2 86:4 89:4 90:15,
stated 20:21 25:4 264:17 80:21 88:9 103:7 16 92:4, 10, 15
68:1 76:8 170:5 stood 130:18 188:2 208:18 94:2, 4 98:12
187:23, 24 190:15 131:17 133:16 222:24 223:6, 7 102:13 105:23
254:7 140:7 subpoenaed 103:3 113:21 118:20
statement 26:10 stop 115:21 Subscribed 264:18 126:5, 8, 12 131:9
56:15 218:18, 20 119:18 121:1 substance 166:16 135:10 141:2
224:12 236:23 122:8 124:23 substantial 242:11, 146:21 147:4
statements 26:16 151:19 153:9 12 149:11 156:13
78:10, 20, 20 157:19 158:1 sudden 126:10 160:9 161:8
91:16 140:14 235:16 sue 207:24 162:23 167:6, 9,
147:4 150:9 stopped 74:16 sued 217:12, 14, 23 169:16 173:24
156:1 81:18 86:10 15, 19 187:6 197:8
stating 142:20 108:9, 14 120:12 sufficient 62:20 198:6 199:1
245:22 121:4 98:17 200:13 201:21
station 79:3, 4 store 178:2, 10 suing 76:4 203:7 204:16
statute 225:10 stories 190:22 Suite 3:15 205:10 206:21
stay 149:9 192:9, 13 summer 163:24, 25 207:7, 13, 16
stayed 178:8 211:15, 21, 23

38
212:13 216:9 15 48:2 50:3, 14 233:1 240:21 72:20, 24 75:22

220:5 223:13 51:2, 10, 19 52:9, 241:10 82:16 94:2
229:14 230:18 18, 23 53:3, 15, 23, talking 12:25 100:24 105:11
239:20 240:14 25 54:3, 7, 13, 19, 34:9 43:2, 4 108:3, 5 110:11
241:8 243:18 19 55:10, 12 56:6 47:15 62:10 112:12, 12, 13, 14
246:4, 6 248:10 57:21 59:16 61:6, 80:19 81:18 113:8, 10, 13
255:15 259:1 17 94:18, 23 86:11, 23 90:8 128:7 136:14
surgery 89:10 97:20, 24 98:4, 13 92:11, 13, 16, 21 145:7 158:17
163:2, 5, 7, 12 126:24 134:11 93:1 103:20 163:12 164:16
221:6, 13 222:4, 9 136:3 177:10, 15, 110:4 113:15 188:22 189:6
surprise 17:9 16, 20, 24 178:21 117:12 125:20 213:19 225:14, 15,
139:12 180:7 183:12 131:10 133:19 17, 22 236:9, 24
surprising 151:20 186:6, 25 200:2 149:22 156:5 237:4 238:5
surrounding 233:12 234:9 160:8, 12, 22 246:10, 13
190:19 235:6 192:13, 17, 22 telling 76:13
suspect 92:9 195:7 200:21 147:10, 11, 20
suspend 150:14 <T> 201:7, 8, 16, 18 150:18 190:22
151:22 152:10 T.S 129:13 203:12, 23 207:3, tells 29:3
suspended 152:6, tabbed 114:18 3 208:17 211:3 ten 85:6 145:15
11 take 13:2, 3, 5 212:5 217:9 180:11
suspending 152:8 15:19 89:11 224:10 225:7, 22 term 210:4, 9
SUSQUEHANNA 100:12 127:21 226:2 228:5, 8, 23 terminal 179:4
1:1 11:19 12:1 143:3 150:5 231:14 235:15 test 77:10, 24, 24
26:15 28:4, 20 151:6 155:4 242:14 246:20, 22 129:12, 22 130:7,
30:17 167:19 157:12 165:6 253:13 258:12 9, 16 131:15
214:22 192:9 216:16 260:2, 10, 19 133:17 134:3
swear 9:16 250:2 261:20 135:8, 10 138:16
switch 243:9 taken 90:25 talks 75:9 214:25 139:20 141:3
switched 243:7 129:17 163:16 224:14 142:13 143:18, 25
245:9 165:14 264:9 tall 156:22 144:2, 5, 10, 19, 25
sworn 9:20 12:7 talk 49:10, 12 Tammy 121:15 145:16 146:2, 11
263:6 264:18 87:10, 19 88:4 251:24 151:14 176:23, 25
sympathetic 93:5 98:8 112:17 tanks 121:17 tested 130:21
207:10 211:11 137:6, 7 141:22 target 69:6 139:22
symposiums 38:1 146:23 154:8, 9 taste 145:23, 24 testified 9:20
System 53:12 159:7, 9 176:15 tax 57:18 127:16, 11:18 12:2, 4, 5
56:3, 5, 10 57:5, 8, 192:8 206:14 18 128:8 68:17, 17 115:9,
10, 21 58:24 59:3, 208:11, 17 210:6, taxes 127:10, 14 13 130:24 134:20
24 60:11, 11, 17, 7 216:19 226:16 team 171:13 135:5 155:1
20 61:1 95:21, 23 228:3 242:7 215:1, 4 226:6 163:21 240:4
96:20 176:23, 25 243:14 technically 99:9 testify 11:7
186:12 talked 147:2 tecum 10:10, 10 134:24
Systems 45:11, 12, 201:24 205:16 telephone 5:4 testifying 134:16
15, 22, 23 46:2, 4, 206:25 219:24 tell 11:17 36:22 testimony 11:14
5, 7, 14, 16 47:1, 5, 37:2 66:3 69:20 68:12, 22 75:4

39
133:5 135:14, 15, think 20:24 24:1 thousandth 131:24 20 242:15 247:19
15 154:23 229:24 30:14 61:21 threat 27:7 28:25 248:13 252:20
258:14 263:9 70:21 72:4, 7 threaten 30:5 254:13 257:8
testing 132:2, 4 74:1 79:9 92:23, 211:16 258:1, 12 261:24
139:5, 8, 10, 14 25 94:1 101:21 threatened 29:1, 5, timeline 204:15
141:8 142:2 108:11 119:24 7 30:15, 16, 21 times 13:18 83:23
144:22 176:21 151:6, 16 156:22 threatening 29:9 86:16 185:5
tests 131:5, 25 160:4 161:8, 9 threats 29:19, 20 227:2 228:17
139:1 140:21 164:7, 14 165:6, 7 three 44:6 92:24 238:14 247:16
142:23 143:16, 21 170:18 171:14 110:3, 7, 14, 14 timing 255:25
145:21 178:12 181:4 160:11 178:13 Tire 99:15
text 33:9, 10 183:20 184:23 182:14 213:23 Title 1:25 2:1
Thank 153:13 186:20 187:23 226:10 227:5 199:9
169:23 212:17 196:20, 25 197:22 247:16 to: 265:4, 7, 10, 13,
252:13 199:20, 22 200:25 tickets 188:18, 19 16, 19 266:4, 7, 10,
thanks 259:5 201:10 204:11 196:4 13, 16, 19
theirs 243:25 205:5, 10 207:15 Tier 199:12 today 8:22 10:2
thereof 263:13 209:6 210:5 ties 151:8 11:6, 8 12:16
they, 135:25 213:21 215:9 tightened 158:24, 16:2 18:2, 13, 16
THIES 5:13 9:8 217:1 218:4 24 19:21 20:1, 4, 10,
thing 13:3, 15 221:12 227:8 time 13:2, 9 16 23:15 24:8, 19
57:25 70:4, 9 229:10, 18 232:21, 15:20 20:12, 20, 29:11, 21 31:17
89:6 107:24 23 234:25 255:12 21 21:3, 5 35:23 65:20 71:2
113:19 123:16 thinking 58:3 49:11 68:3, 6 129:11 137:13
151:2 169:10 208:22 209:5, 6 69:25 70:6, 10 147:7 212:24
171:20 176:19 third 10:22 33:19 72:19, 23 74:3, 7, 214:7 216:16
177:20 184:8 34:9 40:7, 17 11, 15, 17 78:4, 17 today's 16:10
190:15 235:20 176:6 181:18 106:18, 24 110:8 19:1, 9 24:13
238:1 246:9 226:8 114:15, 16 120:1 told 26:5 28:5
260:10, 12, 25 thought 18:25 122:1 150:14 69:24 73:10, 17
things 12:19 13:8 45:3 50:1 88:7 152:6 153:6, 11 85:21 113:24
25:19 26:8 42:8 102:16 103:10 154:7 156:21 123:13 137:15
47:17 48:22 49:1, 135:1 137:5 159:18 171:25 142:8, 17, 22
2 75:2 77:19 169:17 170:19 172:14 173:9, 16 150:18 159:16
78:16, 18 89:11, 171:1 198:25 175:5 176:10, 14 205:25 211:7
24 96:21 110:18 200:19 201:17 178:14 179:19 232:5 241:3
112:2, 17 113:11 214:7 241:23 184:23 186:11, 19 259:21, 24
118:4, 21 119:8 245:11 246:4 188:1 191:22, 25 toluene 79:5, 7, 8,
123:2 140:15 thousand 55:20, 196:16, 17 199:20 15, 19 80:2, 9
171:3 179:11 23 116:24 203:25 210:18, 25 130:11 131:11, 16
185:5 188:18 thousands 55:23 211:6 214:21 137:21
192:22 193:21, 24 56:2 131:4 225:2, 217:15 218:13 ton 184:6
198:2 199:1 23 230:7 232:24 223:21 225:21 tons 143:20
207:20 212:24 236:11, 25 258:16 230:2 236:8 top 141:24
225:12 237:16 238:3, 5, 194:21 223:3

40
total 26:2, 4 treatment 45:15 23 92:23 101:10 24 52:18 54:3, 20

217:2 229:8 46:4 60:16, 20 108:11 111:22 56:5, 9 57:23, 25,
242:6 244:1 134:11 183:14 112:2 151:17, 18 25 58:7, 8 60:7
totally 50:25, 25 trial 214:14, 14 152:13, 15, 18, 21 70:4 81:12 106:9
104:20 117:9 tried 90:11 153:1 154:24 115:7 163:5, 12
131:19 150:4 trip 188:4, 8, 11 155:1 193:7, 10 176:11 182:4
153:2 158:25 204:13 210:21 196:19 197:6 183:18, 23 184:10
tour 199:16 222:14, 21 198:14 200:17 211:16 221:13
Towing 99:15 trouble 169:20 203:18 204:1 237:24 246:21
town 80:12 truck 89:15, 20, 205:7 217:10, 17, typed 14:9, 10
114:10 154:19 23, 25 90:2, 4, 13 20, 25 218:1, 1 typically 175:8
township 67:17 99:1, 2, 4, 6, 8, 17 220:17 229:5 typing 168:8
159:25 198:23 100:3 109:20, 20 230:25 235:16
track 56:13 110:1, 4, 5, 6, 11, Tuesday 188:14 <U>
254:23, 24 12 111:8 113:2, 4 turn 15:4 26:13 U.N 189:14
Tracker 190:9 114:18 115:10, 14, 31:10, 11 145:16 U.N. 189:13
trade 60:2, 3, 6, 8, 17, 17, 19 116:4, 153:18 237:8 U.S 135:2
11 186:14 11 117:20 119:10, turned 145:10 unaware 35:21
trail 242:25 24 121:8, 9 122:5, Tustin 175:16, 17 258:15, 22
training 176:12 10 123:24, 24 twice 29:6 91:6 uncle 182:15
transcript 25:15, 124:13, 15 125:4 196:11, 12 197:22, unclear 10:17
17 263:8 264:8 126:2, 3, 17 24 undercover 109:15
transcription 179:10 200:14, 14, Twitter 69:12, 15, undergone 63:13
12:24 15, 16, 17 201:10, 21 understand 13:10,
transfer 89:2 12 205:4, 5 two 10:12 21:5 12 18:11 19:5
249:14 257:24 229:14 238:22 22:4 27:18 34:18 20:5 22:15 43:17
transferred 89:8 252:21, 25 253:2, 70:9 92:24 44:21, 25 45:2
163:22 4 255:6 258:20 102:25 103:1 46:8 48:21 50:9,
transition 74:7 trucks 116:10 104:14 117:11 25 54:24, 25 57:6
230:16 235:2 true 39:3 154:25 121:23 129:10 58:23 73:6 75:4
240:7 263:8 264:10 146:12 169:7 81:24 87:8, 16
transitionary truth 26:7 100:24 175:15, 25 176:22 95:5 96:19 97:19
74:14 133:7 142:24 179:22, 23, 25 100:20, 23 114:4
travel 94:25 95:6 truthful 26:15, 17 180:12 181:13 117:15 130:6, 9
98:14 161:14 78:21 101:9 188:10 189:21 131:9 133:4
188:15 191:12, 22 147:5 196:7, 13 199:2 134:15 137:14
196:23 198:7 truthfully 101:24 202:9 219:13 139:7 143:1
229:21, 23 236:2, 3 try 13:11 26:15, 227:4, 6 238:13, 147:8 152:25
traveled 191:24, 17 28:13 63:14, 14 239:4 250:14 166:7, 9 170:10
25 192:4 196:10 17 109:16 140:18 258:2 186:1 191:7
197:24 155:4 216:17 two-year 176:9 193:7 198:19, 21
traveling 39:4 221:2 type 30:5 38:20 207:22 208:15
106:18 191:18 trying 21:24 22:3 42:18 43:4, 9 213:8 214:6
192:2, 6 41:23 43:16 46:20 47:22 48:2 222:19 225:21
44:16, 21 71:13, 50:15 51:15, 21, 231:16 233:23

41
understanding 160:17 161:17 videotape 82:19 118:20 122:21

41:23 69:5 70:21 186:14 232:12 violates 24:2 123:4, 10 128:22
79:14 93:24 95:4 261:3 violating 29:15 145:6 146:24
109:9 112:22 87:5 147:3, 16 149:6, 8
123:17 125:25 <V> Virginia 1:15 2:9, 159:9 166:12
139:11 163:20 vacation 15:8 12 8:13 27:17 167:6, 23 175:7
167:13 169:9 16:15 27:18 28:21 35:22 176:15 193:4, 15,
170:3, 9 175:18 valve 113:3 148:11 183:2 16 194:1 206:24
182:17 206:10, 20 vehicle 42:16 196:24 197:4, 9 214:21 221:20
209:11 246:1 115:8 196:16 206:1 263:1, 4, 20 239:22 242:17
256:8 264:13 205:6, 7 visit 188:8 195:15 244:9 258:11
understood 20:15 vehicles 42:8 visited 195:14 259:1
141:3 243:22 111:17 161:10 visiting 187:25 wanted 57:8
undue 10:20 164:11 visual 145:22 78:10 90:15
unhappy 219:13 Vera 16:24 voice 169:22 109:2, 8 125:22
220:15 221:21, 23 verbal 13:19 253:21 159:7 168:11
unintelligible 105:20 volatile 79:13 176:6 216:16
227:5 245:15 verbally 13:17 Voloara 46:12 220:19 241:3
unit 249:19, 23 105:21 59:1, 4, 9 wants 219:9
258:2 Verbatim 2:10 V-O-L-O-A-R-A Washington 4:18
United 156:9 versus 8:6 46:12 Watch 24:18
157:8 vice 77:18 volunteering 94:8, 18, 19, 24
units 249:17 Video 2:4 8:3 116:12 95:5, 6, 12 96:7,
University 175:15 83:5, 10 130:18 16 97:17 98:5, 11,
176:7 135:11, 14 136:1, <W> 12 102:10 103:14
unredacted 143:2 7, 25 138:11 wait 12:22 45:19 104:7, 12 105:3, 8,
unrelated 67:23 140:25 141:14 89:22 10, 16, 21 125:5,
68:4 147:14, 15 148:2 waived 262:16 10 151:21 187:15
unsubstantiated 149:9 156:9 walk 12:13 47:25 199:15, 18 221:22
156:1 157:6, 10, 14, 21 Walsh 125:18, 19, 229:3, 11, 21
up, 126:14 158:8, 14, 18 24 200:1, 4 229:2 230:6, 24 233:12,
UPS 179:9, 20, 21 160:1, 5, 7, 9, 13 247:18 249:15, 16, 18 234:7, 10, 15,
upset 207:20 222:7 259:15 18, 24 255:20 19, 24 235:6, 10,
209:5 211:5, 8, 22 260:16 257:25 24 236:10 237:1,
Upstairs 247:9 VIDEOGRAPHER Walsh's 252:16 10, 12 238:10, 16
Upstate 93:1 5:12 8:3, 14 9:14 want 9:7 16:9 239:25 240:10, 19,
124:11 100:7, 10, 13, 16 28:13 37:11 44:1, 22 241:2, 8, 18
upwards 201:25 149:2, 4, 8, 11 13 48:19 49:17, 243:6, 23 244:22
use 13:6 56:6, 16 165:11 166:3 17, 18 50:4, 7, 22, 245:7, 18, 24
57:4, 4 91:10 169:21 216:10, 12 23, 23 63:2 64:2, 246:3, 11, 24
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139:4 210:4, 9, 11 8 262:14 78:18, 19, 20 252:5
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Craig Stevens Transcript

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1

Craig Stevens 1/31/2019

1 IN THE COURT OF COMMON PLEAS OF SUSQUEHANNA COUNTY

25 (Title continued on the following page.)

Casamo & Associates 703 837 0076 www.casamo.com

4 Video Deposition of:

Casamo & Associates 703 837 0076 www.casamo.com

3 ON BEHALF OF THE PLAINTIFFS:

12 COLE DELANCEY, ESQUIRE

25 (Appearances continued on the next page.)

Casamo & Associates 703 837 0076 www.casamo.com

4 ON BEHALF OF THE DEFENDANTS CHARLES F. SPEER, EDWARD

14 ON BEHALF OF THE WITNESS:

25 (Appearances continued on the next page.)

Casamo & Associates 703 837 0076 www.casamo.com

3 ON BEHALF OF THE DEFENDANT RAYMOND KEMBLE (via

Casamo & Associates 703 837 0076 www.casamo.com

7 DEPOSITION EXHIBITS: PAGE

25 (Contents continued on the next page.)

Casamo & Associates 703 837 0076 www.casamo.com

3 DEPOSITION EXHIBITS: PAGE

Casamo & Associates 703 837 0076 www.casamo.com

Casamo & Associates 703 837 0076 www.casamo.com

1 Ciarimboli, Clancy Boylan, Fellerman and Ciarimboli.

Casamo & Associates 703 837 0076 www.casamo.com

1 Before we get started, do you happen to

Casamo & Associates 703 837 0076 www.casamo.com

1 not related to the claims asserted against the

Casamo & Associates 703 837 0076 www.casamo.com

1 Q. Any other Susquehanna County places you

Casamo & Associates 703 837 0076 www.casamo.com

1 difficult for her to get everything accurately. If

Casamo & Associates 703 837 0076 www.casamo.com

1 Q. I'm handing you what's been marked for

Casamo & Associates 703 837 0076 www.casamo.com

1 Q. Okay. Now, you said you drafted this in

Casamo & Associates 703 837 0076 www.casamo.com

1 MS. BARRETTE: Well, we'd like to get done

Casamo & Associates 703 837 0076 www.casamo.com

1 Q. Oh, Eric Roos. So Mr. Kemble, Mr. Ely --

Casamo & Associates 703 837 0076 www.casamo.com

1 A. I didn't know who was going to depose me

Casamo & Associates 703 837 0076 www.casamo.com

1 today's date on the one that I'm responding to.

Casamo & Associates 703 837 0076 www.casamo.com

1 A. I'm saying I came here today because of the

Casamo & Associates 703 837 0076 www.casamo.com

Casamo & Associates 703 837 0076 www.casamo.com

1 not able to find one until just this week.

Casamo & Associates 703 837 0076 www.casamo.com

1 MS. BARRETTE: You raised the objection at

Casamo & Associates 703 837 0076 www.casamo.com

1 receiving legal advice. So I don't think asking him

Casamo & Associates 703 837 0076 www.casamo.com

Casamo & Associates 703 837 0076 www.casamo.com

1 Q. So there was more you were going to say?

Casamo & Associates 703 837 0076 www.casamo.com

1 MS. BARRETTE: As a matter of fact, I have

Casamo & Associates 703 837 0076 www.casamo.com

Casamo & Associates 703 837 0076 www.casamo.com

1 threatened financial sanctions against you?

Casamo & Associates 703 837 0076 www.casamo.com

1 come and serve me were directed by your company that

Casamo & Associates 703 837 0076 www.casamo.com

1 instruct you not to answer.

Casamo & Associates 703 837 0076 www.casamo.com

1 Q. Okay. And where did you look?