Dolores M. Cuddihy et al v. CBS Corporation et al, 812455/2015, 56 (N.Y. Sup. Ct., Erie County Jul. 19, 2016) (2024)

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`Page 1
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` SUPREME COURT OF THE STATE OF NEW YORK
` COUNTY OF NEW YORK
`
` DOLORES M. CUDDIHY,
` DIANE M. CUDDIHY,
` Plaintiffs,
` INDEX NO.:
` vs. 812455/2015
` CBS CORPORATION
` f/k/a VIACOM, INC.,
` successor by merger to
` CBS CORPORATION
` f/k/a WESTINGHOUSE ELECTRIC
` CORPORATION, et al.,
`
` Defendants.
` ________________________________/
`
` Marriott Courtyard
` 7780 SW 6th Street
` Plantation, Florida 33324
` Tuesday, December 1, 2015
` 9:45 a.m. - 12:35 p.m.
`
` DEPOSITION OF DOLORES M. CUDDIHY
` Pages 1-119
`
` Taken before Tambria Lee Dery, RPR, FPR,
` Registered Professional Reporter, Florida
` Professional Reporter and Notary Public in and for
` the State of Florida at Large, pursuant to Notice of
` Taking Deposition filed in the above cause.
` _ _ _ _ _ _
`
`JOB NO.: 2177801
`
`Priority-One Court Reporting Services Inc. – A Veritext Company
`718-983-1234
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`Page 2
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`1 I-N-D-E-X
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`Page 4
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` EXAMINATION PAGE
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`2 3
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`4 5
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` DIRECT EXAMINATION, BY MR. RAMSEY: 6
`6 CROSS-EXAMINATION, BY MR. SORRELS: 49
`7 CROSS-EXAMINATION, BY MR. DECICCO: 52
`8 CROSS-EXAMINATION, BY MS. BLACK: 77
`9 CROSS-EXAMINATION, BY MS. SQUITIERI: 88
`10 CROSS-EXAMINATION, BY MR. RICHMOND: 97
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`Page 5
`1 IT IS HEREBY STIPULATED AND AGREED by
`2 and between the attorneys for the respective parties
`3 hereto that filing, sealing and certification of the
`4 within Examination Before Trial be waived; that all
`5 objections, except as to form, are reserved to the
`6 time of trial.
`7 IT IS FURTHER STIPULATED AND AGREED
`8 that the transcript may be signed before any Notary
`9 Public with the same force and effect as if signed
`10 before a Clerk or Judge of the Court.
`11 IT IS FURTHER STIPULATED AND AGREED
`12 that the within examination may be utilized for all
`13 purposes as provided by the CPLR.
`14 IT IS FURTHER STIPULATED AND AGREED
`15 that all rights provided to all parties by the CPLR
`16 shall not be deemed waived and the appropriate
`17 sections of the CPLR shall be controlling with
`18 respect thereto.
`19 IT IS FURTHER STIPULATED AND AGREED
`20 by and between the attorneys for the respective
`21 parties hereto that a copy of this Examination shall
`22 be furnished, without charge, to the attorney
`23 representing the witness testifying herein.
`24
`25
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`2 (Pages 2 - 5)
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`1 APPEARANCES:
`
`23
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` JOHN RICHMOND, ESQUIRE
` Lipsitz & Ponterio, LLC
`4 135 Delaware Avenue
` Buffalo, NY 14202
`5 on behalf of the Plaintiffs
`6
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` COLIN RAMSEY, ESQUIRE
`7 Underberg & Kessler, LLP
` 50 Fountain Plaza, #320
`8 Buffalo, NY 14202
` on behalf of the Defendant, Hudson
`
`9
`10 STEPHEN SORRELS, ESQUIRE
` Feldman Kieffer, LLP
`11 110 Pearl Street, Suite 400
` Buffalo, NY 14202
`12 on behalf of the Defendant, Mader
`13
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` EDUARDO MEDINA, ESQUIRE
`14 Bice Cole Law Firm, PL on behalf of
` Lewis Brisbois Bisgaard & Smith, LLP
`15 77 Water Street, Suite 2100
` New York, NY 10005
`16 on behalf of the Defendant, Kaiser Gypsum
`17
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` CHANDLER BLACK, ESQUIRE
`18 Conroy Simberg, PA
` 3440 Hollywood Boulevard, #200
`19 Hollywood, Florida 33021
` on behalf of the Defendant, Georgia-
`20 Pacific
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`Page 3
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`1 APPEARANCES CONT.:
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`23
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` DANIEL DECICCO, ESQUIRE
` Darger, Errante, Yavitz & Blau, LLP
`4 116 E. 27th Street at Park Avenue
` New York, NY 10016
`5 on behalf of the Defendants, Certainteed,
` Union Carbide Corp.
`
`67
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` ERIC L. LUNDT, ESQUIRE
` Sedgwick, LLP
`8 2400 E. Commercial Blvd. #1100
` Ft. Lauderdale, Florida 33308
`9 appearing on behalf of the Defendants,
` GE, CBS
`
`10
`11 VIRGINIA SQUITIERI, ESQUIRE
` Wilson, Elser, Moskowitz, Edelman & Dicker, LLP
`12 150 East 42nd Street
` New York, NY 10017-5639
`13 appearing telephonically on behalf of the
` Defendant Conwed Corp.
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`1 THEREUPON,
`2 DOLORES CUDDIHY,
`3 having been first duly sworn, and answered, "I do,"
`4 testified upon her oath as follows:
`5 DIRECT EXAMINATION
`6 BY MR. RAMSEY:
`7 Q Good morning, Ms. Cuddihy.
`8 A Good morning.
`9 Q My name is Colin Ramsey, I represent one
`10 of the Defendants in the lawsuit that we're here to
`11 talk about this morning.
`12 A Okay.
`13 Q I'm sure your attorney has basically
`14 explained what's going to take place. I'm going to
`15 ask you a number of questions. Some of the other
`16 attorneys may have a few questions as well. I just
`17 ask that you do the best to answer my question. If
`18 you don't understand my question, if you don't hear
`19 it, I can repeat it.
`20 A Okay.
`21 Q So we're on the same page, everything we
`22 say is being taken down this morning, so let me
`23 finish my question before you start your answer.
`24 A Okay.
`25 Q You're probably going to know where I'm
`
`Page 7
`1 going with my question most of the time, but let me
`2 get it out so the court reporter can take down my
`3 full question before you start your answer and I
`4 will try and wait for you to finish your answer
`5 before I start another question, okay?
`6 A Okay.
`7 Q One more rule. Everything has to be
`8 verbal. We can't take down head nods, uh-huh,
`9 huh-uh's. So whatever the response calls for, it
`10 has to be verbal.
`11 A Okay.
`12 Q Any time you need a break, let us know and
`13 we can take a break, okay?
`14 A Okay.
`15 Q What is your date of birth?
`16 A
`33.
`17 Q And what is your current address?
`18 A 5541 Southwest 7th Street, Plantation,
`19 Florida.
`20 Q And how long have you lived at that
`21 address?
`22 A 22 years.
`23 Q Does anyone currently reside you at that
`24 address?
`25 A No.
`
`1 Q Okay. At any time in 22 years, has anyone
`2 resided with you?
`3 A Yes, two of my sons.
`4 Q And when did they reside with you there?
`5 A They moved in when I moved in in January
`6 of `94 and they moved out when they bought homes, I
`7 would say, I don't know the exact year, possibly 10
`8 to 12 years ago.
`9 Q So obviously, you have two sons. Do you
`10 have any other children?
`11 A Yes.
`12 Q Give me all of your children's names and
`13 ages.
`14 A I have my oldest daughter, Deborah. She's
`15 60. She lives in Buffalo.
`16 Q Okay.
`17 A The next was I had a son, Robert. He
`18 passed away when he was five.
`19 Q Okay.
`20 A I have a daughter, Diane. She's 56. She
`21 lives here in Florida.
`22 Q Okay.
`23 A I have a daughter, Madonna. She's 53.
`24 She's here in Florida. I have a son, Timothy, who's
`25 52 today here in Florida. And I have a son, Andrew,
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`1 who is 47. He also is here in Florida.
`2 Q And when you say here in Florida, in the
`3 general Plantation/Fort Lauderdale area?
`4 A Correct, yes.
`5 Q And it's my understanding that you were
`6 married until approximately 1993 when your husband
`7 passed away?
`8 A Yes.
`9 Q And no other marriages since that time?
`10 A No.
`11 Q Prior to the, prior to living at the 5541
`12 Southwest Seventh address, where did you live?
`13 A In Florida at 831 Northwest 80th Terrace.
`14 Also in Plantation.
`15 Q And what period of time did you reside at
`16 that address?
`17 A We moved here in 1978 and we were there
`18 until we moved in January of `74 -- I mean of '94.
`19 Sorry.
`20 Q And when you say we, are you referring to
`21 you and your husband?
`22 A Correct.
`23 Q Is it safe for me to assume that you moved
`24 to your current address after your husband passed
`25 away?
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`1 A That is correct.
`2 Q Okay. Did anyone else reside with you and
`3 your husband at any time during the 1978 to 1994
`4 period that you lived at that address?
`5 A Yes.
`6 Q Okay. Who resided with you?
`7 A My daughter, Diane.
`8 Q Was this before they reached --
`9 A They were all in school and before they
`10 were married, yeah.
`11 Q I'll leave that alone.
`12 A Okay.
`13 Q So at some point, one or more of your
`14 children lived with you off and on at that address?
`15 A Correct.
`16 Q Okay. Prior to living at the 831
`17 Northwest 80th Terrace address, it's my
`18 understanding you lived in the Buffalo area?
`19 A That's correct.
`20 Q What was the last address that you lived
`21 at in Buffalo?
`22 A 716 McKinley Parkway.
`23 Q And approximately what time period did you
`24 live in McKinley Parkway?
`25 A From 1970 til we moved in 1978.
`
`1 were married?
`2 A Well, when he came home from Korea.
`3 Q Okay. Was he in the Service then when you
`4 got married?
`5 A Yes.
`6 Q Where were you residing while he was
`7 overseas?
`8 A With my mom on McKinley Parkway. It was a
`9 family home.
`10 Q Okay. So the family home that you grew up
`11 in is the one you ended up in?
`12 A That is correct.
`13 Q After your husband came home from the
`14 Service, was he employed?
`15 A Yes, he worked at Republic Steel. Oh, no,
`16 wait a minute. When he came home? No, he became --
`17 he went right into plastering.
`18 Q Okay. That was his trade?
`19 A Correct.
`20 Q Do you recall any companies that he worked
`21 for over the course of his lifetime?
`22 A I remember he worked a lot for Hudson
`23 Plastering Corporation.
`24 Q Okay.
`25 A And Mader and then there was more, but I
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`Page 13
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`1 Q Just so we've got the full picture, prior
`2 to the McKinley address, where did you live in
`3 Buffalo?
`4 A 103 Tampa Drive, West Seneca.
`5 Q And approximate period of time at that
`6 address?
`7 A From October of `66 to May of `70 when we
`8 moved.
`9 Q And what about prior to the Tampa Drive
`10 address?
`11 A 86 Folger Street.
`12 Q And did you reside with your husband and
`13 at least some of your children at the addresses we
`14 talked about so far?
`15 A Yes.
`16 Q When were you and your husband married?
`17 A On December 27th, 1952.
`18 Q Prior to the 86 Folger Street address, it
`19 looks like you resided at another address on Folger
`20 Street?
`21 A At 51, but just for three or four months.
`22 Q And prior that to that, it looks like you
`23 resided at Cantwell Drive?
`24 A 106 Cantwell Drive.
`25 Q Did you reside on Cantwell Drive after you
`
`1 don't -- those are the two I remember.
`2 Q Okay. Do you know, would you know any of
`3 the job sites that he worked at on any of these?
`4 A I was never at a job site.
`5 Q Okay. Do you know with any of the
`6 products he worked with, did he ever come home and
`7 talk about the products that he worked?
`8 A Not really.
`9 Q Okay. But basically, for the entirety of
`10 his working life, he was a plasterer?
`11 A Correct.
`12 Q Back to your residences just for a minute.
`13 The 716 McKinley Parkway address that you grew up in
`14 it sounds like and lived in before you moved to
`15 Florida, what type of heat source was it?
`16 A It was a gas furnace.
`17 Q And do you recall growing up with any
`18 projects that were done, additions to the house,
`19 anything like that?
`20 A No, not really.
`21 Q What about after you and your husband
`22 moved in 1970, did you do any additions, any
`23 remodeling, any type of work like that?
`24 A Not on the inside, Bob did some stucco
`25 work on the outside, because we had stucco that was
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`1 falling off.
`2 Q And he did that work himself?
`3 A Correct.
`4 Q Other than the stucco work, any other
`5 remodeling renovations that were done to that house?
`6 A The only thing we did was paint.
`7 Q Okay.
`8 A And there was a lot of varnish on the wood
`9 and he redid the wood somehow.
`10 Q Okay. Sounds like mostly touch up work?
`11 A Correct.
`12 Q Aesthetic type work?
`13 A That's all he did.
`14 Q Did anyone help him with the stucco work
`15 that you can recall?
`16 A Probably his brother, Jim, he was also a
`17 plasterer.
`18 Q Any recollection of any of the products
`19 that your husband worked with doing the stucco?
`20 A I don't know the products.
`21 Q Pretty much the same questions for the
`22 Tampa Drive address and the Folger Street, two
`23 Folger Street addresses, do you recall any
`24 renovations or remodeling that you and your husband
`25 did at those addresses?
`
`1 Q And what period of time are we talking
`2 about when he would be doing this?
`3 A I think like from 1962, `63 maybe.
`4 Q So about a year period?
`5 A Yeah.
`6 Q Okay. How often would he be doing this, a
`7 couple weekends a month, every weekend of the year,
`8 how often?
`9 A No, not every weekend of the year,
`10 whenever they could get something, maybe, I don't
`11 know, maybe a couple weekends every two months or so
`12 if they could get something.
`13 Q Okay. And how would they hear about or
`14 get these jobs, just word of mouth from friends or
`15 did they post an advertisem*nt?
`16 A No, from word of mouth.
`17 Q Other than the time period when your
`18 husband and his brother were doing this work to
`19 support their father, did he do side jobs as well
`20 just for additional income?
`21 A Once in a while.
`22 MR. DECICCO: Objection.
`23 BY MR. RAMSEY:
`24 Q By once in a while, a couple times in a
`25 year, can you give me more context by what you mean
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`Page 15
`1 A When we were on Tampa, he and his brother
`2 built a garage apartment for his mother. It was
`3 done by a contractor, but they did do the plastering
`4 inside, but nothing in the home we were living in.
`5 Q Okay. So the apartment itself was built
`6 by a contractor, but your husband did the plastering
`7 work?
`8 A Correct.
`9 Q Okay. Any idea the product that he used
`10 in that plastering work?
`11 A I never knew what that was. I know it was
`12 big white buckets.
`13 Q Do you recall any of the writing on the
`14 big white buckets?
`15 A I don't, no.
`16 Q Other than his employment over the course
`17 of his work life, would your husband do any side
`18 jobs for friends and family?
`19 A Yes.
`20 Q How often would he do that?
`21 A When his father had a heart attack, he
`22 couldn't work anymore, Bob and his brother Jim used
`23 to do side work and gave all that money they made on
`24 the side to his parents, because they didn't have an
`25 income.
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`1 by once in a while?
`2 A I don't remember. Probably a couple times
`3 a year.
`4 Q Okay. And would this be the same thing,
`5 word of mouth, friends, that type of thing?
`6 A Uh-huh, yes.
`7 Q Other than his brother, do you recall
`8 anyone else going on the jobs or helping your
`9 husband out with these side jobs?
`10 A No, I don't.
`11 Q So after your husband returned from the
`12 Service, the first address that you lived in was --
`13 A Cantwell Drive.
`14 Q Did you own that address?
`15 A No.
`16 Q Okay. Rented?
`17 A Yes.
`18 Q Were there laundry facilities at that
`19 address?
`20 A Yes, in the basem*nt.
`21 Q What type of house, was it a duplex
`22 structure?
`23 A Double, it was a two-bedroom apartment
`24 upstairs is where we were.
`25 Q And there was laundry facilities in the
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`1 basem*nt?
`2 A Correct.
`3 Q Who in the family was responsible for
`4 doing the laundry? You were?
`5 A Me.
`6 Q Okay. And at that time when your
`7 husband's back from the Service, you're at the
`8 Cantwell address, he's begun his career as a
`9 plasterer?
`10 A Yes.
`11 Q Who else is living, if you recall, at the
`12 Cantwell address at that time?
`13 A I had a baby that was born there, but it
`14 was just us.
`15 Q Okay. Describe for me, if you could, what
`16 the laundry facility in the basem*nt was; was it
`17 just a washer and a dryer?
`18 A I had no dryer in those days. I had a
`19 wringer washer and then I hung everything out on a
`20 line in the basem*nt or on a line in the summertime
`21 outside.
`22 Q Do you recall at that time whether your
`23 husband had any type of work uniform or would he
`24 just wear whatever clothes to work?
`25 A He always wore white painters pants and
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`1 winter in the basem*nt and just shake them out
`2 really good and wash them.
`3 Q When you say he removed the work clothes,
`4 was there an area, a hamper or someone where he
`5 would remove them?
`6 A He would just take them off in the
`7 bathroom.
`8 Q Okay. And then as he was showering, it
`9 would be your practice to pick up the clothes and do
`10 something with them?
`11 A That's right, yes.
`12 Q Would you immediately take them to the
`13 basem*nt or would you put them off to the side
`14 somewhere and --
`15 A No, I took them to the basem*nt.
`16 Q And I think you said, if I heard you
`17 correctly, that it sounds like when the weather
`18 permitted, shake them outside; if it was too cold or
`19 raining, you would shake them out in the basem*nt?
`20 A Yes.
`21 Q Were your husband's clothes in basically
`22 the same condition every day that he came home from
`23 work or were there some days worse than the others?
`24 A It was always covered with white stuff. I
`25 don't know any that was worse, I don't remember.
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`Page 19
`1 long sleeve white shirts; old, old long sleeve white
`2 shirts.
`3 Q And when you say always, are you
`4 encompassing the entirety of his working career?
`5 A Yeah, he would always wear those.
`6 Q Okay. Would he get dressed in the morning
`7 at the house and then come home in the same clothes
`8 that he left the house in?
`9 A Yes.
`10 Q And what were the conditions of his
`11 clothes when he came home, were they dirty in any
`12 way?
`13 A It wasn't dirty, he was covered in white
`14 stuff. He was just covered in white stuff.
`15 Q Did you have an understanding or did he
`16 ever tell you what the white stuff was or how he got
`17 it on his clothes?
`18 A Well, I knew he got it while he was
`19 working, but I didn't know what it was. I just
`20 assumed it was plaster.
`21 Q Did he have a typical routine as far as
`22 what he would do with the work clothes?
`23 A Uh-huh. He would go in and remove his
`24 work clothes and take a shower and I would take the
`25 work clothes and in the summer outside or in the
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`Page 21
`1 Q By worse, you just mean more white stuff?
`2 A Yes, there was.
`3 Q I just want to make sure I'm hearing you
`4 correctly, there was always some amount of white
`5 stuff on his clothes, one day could be more than
`6 others?
`7 MR. DECICCO: Objection.
`8 MS. SQUITIERI: Objection to the form of
`9 the question.
`10 MR. DECICCO: Join.
`11 BY MR. RAMSEY:
`12 Q Would you launder your husband's work
`13 clothes every day or did he have a number of pairs
`14 of pants and work clothes?
`15 A I washed them every day.
`16 Q Did he have multiple pairs of painters
`17 pants and long sleeve shirts that he would use or
`18 was there just one?
`19 A He usually had probably two pair of pants.
`20 Q During the entirety of the time that you
`21 lived at the Cantwell Drive address, I guess about
`22 1956 to `56, anyone else have any responsibility for
`23 laundry in the house?
`24 A No.
`25 Q When you moved to the Folger Street, 51
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`1 Folger Street, was there a laundry facility at that
`2 address?
`3 A Yes.
`4 Q Okay. What type of house was that?
`5 A That also was a double home.
`6 Q Okay.
`7 A We were upstairs.
`8 Q And where were the laundry facilities
`9 there?
`10 A In the basem*nt.
`11 Q And was it the same setup, a wringer
`12 washer?
`13 A Yes.
`14 Q And no dryer?
`15 A Correct.
`16 Q And for the couple months that you were at
`17 the 51 Folger address, was your practice essentially
`18 the same as it was on Cantwell as far as how your
`19 husband's work clothes would be handled when he
`20 returned?
`21 A Yes.
`22 Q Any difference in what you did at 51
`23 Folger versus the Cantwell Drive address?
`24 A No.
`25 Q Then you moved to 86 Folger Street?
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`Page 23
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`1 A Yes.
`2 Q What type of house was that?
`3 A It was the same, a double, a two-bedroom
`4 double.
`5 Q And you were still renting at that point?
`6 A Yes.
`7 Q And I assume you were renting at 51 Folger
`8 as well?
`9 A Yes.
`10 Q And did you live on the second floor?
`11 A At 86, we lived on the first floor.
`12 Q And were there laundry facilities at 86?
`13 A In the basem*nt.
`14 Q And once again, was this a wringer washer?
`15 A Yes.
`16 Q And no dryer?
`17 A No dryer.
`18 Q Okay. Anything different about your
`19 practice with your husband's work clothes at the 86
`20 Folger Street than at the previous two addresses?
`21 A No.
`22 Q Looks like you were at Folger Street until
`23 about 1966?
`24 A Yes, we moved in October of '66.
`25 Q From the time that your husband returned
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`1 from the Service in 1954 until you moved from the
`2 second Folger Street address in 1966, was his work,
`3 as far as you saw anyway, essentially the same, that
`4 he'd leave in the morning, do plastering work, come
`5 home at night?
`6 A Yes.
`7 Q Any change in his work status, the type of
`8 work he did during that time period?
`9 A No.
`10 Q Then it looks like you lived at the 103
`11 Tampa Drive address for about four years after
`12 Folger Street?
`13 A 56 we moved. Yes, we moved in May of 1970
`14 to McKinley Parkway.
`15 Q Okay. But between 86 Folger and McKinley
`16 Parkway, you lived on Tampa Drive?
`17 A Yes.
`18 Q For four years. And I should have asked
`19 you, with respect to the two Folger Street
`20 addresses, did anyone else have any laundry
`21 responsibilities during that time; some of your
`22 children would have been born during that time
`23 period?
`24 A A lot of times the kids were in the
`25 basem*nt when I was shaking the clothes out and one
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`Page 25
`1 or two of the girls might have, I might have said
`2 throw dad's clothes in the machine for me while
`3 you're down there.
`4 Q Well, let me ask you this, do you have a
`5 specific --
`6 A Not --
`7 Q I know I'm taxing your memory going back a
`8 ways, do you have a specific memory of any of your
`9 children helping you with the laundry?
`10 MR. RICHMOND: Objection to form.
`11 THE WITNESS: Yes.
`12 BY MR. RAMSEY:
`13 Q Who do you recall?
`14 A I don't recall it on Folger as much as I
`15 think on Tampa Drive.
`16 Q Okay.
`17 A A couple of the girls might have helped
`18 out.
`19 Q Who do you recall helping out on Tampa
`20 Drive with the laundry?
`21 A My daughter, Diane. My daughter, Debbie,
`22 the oldest girl. That's about it. They were at
`23 that age where they could, you know, do something
`24 for me.
`25 Q And when you say helped, describe what you
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`1 mean when they helped you with the laundry.
`2 A It's so hard to remember. Perhaps one of
`3 them might have shook out the pants for me or if
`4 they were on the basem*nt floor, I would ask one of
`5 the girls to throw them in the machine.
`6 Q And just so we're on the same page, do you
`7 have a specific memory of them doing this or is it
`8 just something you assumed probably happened?
`9 MR. RICHMOND: Object to the form.
`10 THE WITNESS: I can remember the girls
`11 helping, yes.
`12 BY MR. RAMSEY:
`13 Q What type of, the 103 Tampa Drive, was
`14 that a house?
`15 A It was a single home, yes.
`16 Q And did you own or rent?
`17 A We rented.
`18 Q Okay. Was there a laundry facility at
`19 Tampa?
`20 A In the basem*nt, yes.
`21 Q Same set up as before, wringer washer?
`22 A Yeah, I still had that.
`23 Q Other than the fact that or your
`24 recollection that one or more of your children may
`25 have helped with the laundry, anything different
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`1 now had an automatic washer as well as the dryer,
`2 was it your practice before putting your husband's
`3 clothes in the washer any different than it had been
`4 at the previous addresses?
`5 A No.
`6 Q Was anyone else responsible at all for
`7 laundry at McKinley Parkway given the five children
`8 that resided with you at that point?
`9 A Well, I wouldn't say they were
`10 responsible, but they did help out more. They were
`11 older.
`12 Q And do you have a specific recollection of
`13 which of your children would help out or basically
`14 all of them would help out?
`15 MR. RICHMOND: Object to the form.
`16 THE WITNESS: I would just think it would
`17 be the oldest two girls, Debbie and Diane.
`18 BY MR. RAMSEY:
`19 Q And when you say they would help out,
`20 would this be a daily occurrence or depending on
`21 their schedule, they would help out?
`22 A It would not be daily. It would be
`23 depending on if they were home or what the
`24 circ*mstances were.
`25 Q Okay. At any of the addresses in Buffalo,
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`1 about your practice as far as your husband's work
`2 clothes when he returned home from work at the Tampa
`3 Drive address?
`4 A Not really. I just, you know --
`5 Q And at Tampa Drive, you're still doing
`6 your husband's laundry pretty much every day?
`7 MR. DECICCO: Objection.
`8 THE WITNESS: Yes.
`9 BY MR. RAMSEY:
`10 Q Do you recall what type of heat source at
`11 Tampa?
`12 A We had a gas furnace.
`13 Q The two Folger addresses, were those gas
`14 furnaces as well?
`15 A Yes, they were.
`16 Q So then in 1970 or thereabouts, you moved
`17 back to McKinley Parkway?
`18 A Yes.
`19 Q How many of your children were living with
`20 you in the home at that time when you were at
`21 McKinley?
`22 A Five of them.
`23 Q And laundry facilities at McKinley?
`24 A I had an automatic washer and dryer.
`25 Q All right. Other than the fact that you
`
`1 did your husband always, ever not take his clothes
`2 off in the bathroom, was there ever a hamper area or
`3 a mud room, for lack of a better word, where he
`4 dropped the work clothes?
`5 A I think a couple of times when he would
`6 get into the back hall, he would be so covered that
`7 I would bring him something and he would, you know,
`8 before he came up into the home. And the kids
`9 always were hugging him and he was covered with this
`10 whatever it was.
`11 MR. DECICCO: Move to strike as
`12 nonresponsive.
`13 BY MR. RAMSEY:
`14 Q Just so I'm clear, there wasn't a mud room
`15 other than the bathroom, but on occasion, he would
`16 do it --
`17 A When he would come in the lower hallway,
`18 if he was covered, I would say, oh, get that stuff
`19 off before you come up these stairs.
`20 Q Okay. And when you moved to Florida in
`21 1978, was your husband still working at that time?
`22 A Yes.
`23 Q Okay. And he worked in Florida as well?
`24 A Yes.
`25 Q Also as a plasterer?
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`1 A Yes.
`2 Q The 831 Northwest Terrace address, was
`3 that a home, single-family home?
`4 A It was a townhouse.
`5 Q And were there laundry facilities at the
`6 townhouse?
`7 A Yes.
`8 Q What type of laundry facilities?
`9 A We had an automatic washer and dryer.
`10 Q And was it still essentially the same
`11 practice for your husband's work clothes?
`12 A Well, we had a detached garage at that
`13 home and he would go in there, but his work was
`14 different there, it was like, it was mostly outside
`15 work, stucco work.
`16 Q When you say it was different, the
`17 condition of his work clothes when he came home was
`18 different?
`19 A He didn't appear to have that -- all that
`20 other stuff on him. And he would come home then and
`21 it would be so hot out, that he would have already
`22 removed the outer shirt, he would just come home
`23 with a t-shirt on when he would come through the
`24 garage.
`25 Q And when he came through the garage, would
`
`1 A Oh, no.
`2 Q Whatever laundry needs he had overseas,
`3 someone else had to deal with those?
`4 A Correct.
`5 Q Okay. When he would go on these work
`6 trips to the embassies, how long would he be gone?
`7 A He came home like every six months.
`8 Q So he would be gone for how long?
`9 A He would be gone for like a year.
`10 Q Okay. Other than the laundry process that
`11 you've told me about, was there anything else that
`12 you yourself did around the house that caused you to
`13 come in contact with any of the dust or white stuff
`14 that your husband brought home?
`15 A Just shaking his clothes out and just
`16 being around our car. We only had one car. The car
`17 was always filled with that white dust.
`18 Q And would that be something that you would
`19 be responsible for cleaning or would you make your
`20 husband go out and clean the car?
`21 A I would make him do it, but he didn't do
`22 it that often. And we had all the kids in the car.
`23 Q So sometimes he'd do it, sometimes you'd
`24 do it as far as cleaning the car?
`25 A He wouldn't do it that much. And his
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`1 he leave his work clothes in the garage or would he
`2 enter the house with them on?
`3