A Civil Action (1998) Riley's deposition

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John Riley: I started working for my father sweeping the beam house floors for my father which he swept for his father when he was seven years old which my boys swept when they were seven years old ...

Jan Schlichtmann: Please answer the question I asked and not one I didn't. Silicon and trichloroethylene mixed together are used to waterproof leather, are they not Let the record show the witness has emptied a glass of water on the table. Mr. Riley, what do you intend to say by pouring a glass of water on my conference table?

John Riley: This is how silicon is applied to leather to waterproof it. I'm answering your question.

Jan Schlichtmann: It's poured on. Some of it must spill off on to the floor, like the water spilling off the conference table and on to my rug. That's the part I'm interested in. How was the silicon and trichlorethylene cleaned up?

John Riley: We never used TCE.

Jan Schlichtmann: "TCE"? I didn't say "TCE". I said "trichlorethylene". You said "TCE", as it commonly known to those who use it. Mr. Riley, do you mind if we check your purchase orders, receipts, etc.?

John Riley: Be my guest. We have those records going back three years. Everything else, we dumped.

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