IN THE COURT OF COMMON PLEAS INDEX OF EXHIBITS OF TIOGA COUNTY DEPOSITION JOHN R. KINGSLEY, CIVIL ACTION . LAW EXHIBITNUMBER DESCRIPTION MARKED Indiv¡dually and as 1 Photograph Adm lnistrator of the 2 Photograph. Estate of JASON A. 3 Photograph KINGSLEY. and DENISE 4 Photograph C. KINGSLEY, 5 Photograph Ind¡v¡dually and as 6 Photograph Adm¡nistrator of the 7 Photograph Estate ofJASON A. I Photograph KIN G S LEY, 9 Photograph 10 Photograph Pla¡ntlffs 11 Photograph LZ P hotog rap h -vs- 13 P hotog rap h L4 Photograph GOR-WOOD HOLSTEINS. 15 Photograph INc., d/b/a GOR-WoOD 16 Photog raph FARMS and RONALD L7 P hotog rap h CHRISTOPHER WOOD, 18 Photograph 19 Photograph D efend â nts No.198 CV 2016 20 Photog raph 2t P hotog ra p h 22 Photog ra ph 23 Photograph 24 Payroll Journal 25 Data Entry Worksheet. 93 DEPOSITION TESTIMONY OF 26 S ketch. 27 Photograph...., RONALD CHRISTOPHER WOOD 28 Photograph..... 29 Cell phone call log TUESDAY, FEBRUARY 28, ZOLT 30 Call log. 31 2009w-2...... TIOGA COUNTY COURTHOUSE 32 Handwr¡tten note. 116 MAIN STREET 33 Payroll Journal 3/22/ t6 WELLSBORO, PENNSYLVANIA 34 2015 w-2. 35 Real Estate note. .. TERESA A. CROSSIN, RMR 36 Employer's report of ¡njury NOTARY PUBLIC 37 Workmen's Com pensation worksheet. ...,180 38 Workmen's Compensat¡on audit Summary. ..,,.180 39 Workmen's Com pensation form 188 KEYSTONE COURT REPORTING AGENCY, ¡NC 40 Insurance document 4099 BIRNEY AVENUE, SUITE 9 4t Handwr¡tten letter., MOOS¡C, PA 18507 42 Copy ofcheck..... (s70) ss8-301r (800) 570-3773 t FAX 70 554-30 14 COUNSEL PREgENTT DOCUMENT REOUESTS On behalf of the Plaint¡ffs: HOURIGAN, KLUGER & QUINN 1. Partnership Agreement BY: DONALD C. LIGORIO¿ ESQ 600 Third Avenue 2. Minutes of dissolutlon Klngston. PA tA704 3. Copy of all minutes going back a year On behalf of the Defendantl THOMAS. THOMAS & HAFER 4. Document showing the State recognlz¡ng the BY: JOSHUA J. BOVENDER, ESQ. transfer of the Estatè 305 North Front Street - Sixth Floor P. O. Box 999 5. Document of a check written to Jason Kingsley purchase Harrisburg, PA 17108 lndlcating tlres Also presènt on behalf of Ronald Christopher wood perso n a lly! CHIP BLACKWELL, ESQ. STIPU LAT¡O NS It was furthêr agreed that all objecilons except as to the form of the question wlll be reserved until the time of trial. INDEX OF WITNESSES EXAMINATION PAGE NUMBER RONALD CHRISTOPHER WOOD By M r. Llgorio .7 By Mr, Bovender . zto By Mr, L¡gorio. 213 1 of 55 sheets Page 1 to 4 of 2L9 O3/O2/2O17 01:18:42 PM 5 7 1 VIDEO TECHNICIAN: Good day. My 1 EXAMINATXON BY MR. LXGORIO: 2 name is Dan Luvender, I am employee of 2 O. Good morning, still, Mr. Wood. My name 3 the Legal Scopes Support Services, 3 is Attorney Don Ligorio and I represent John and 4 located at 600 Third Avenue, Kingston, 4 Denise Kingsley in this lawsuit aris¡ng out of the 5 Pennsylvania, IB7O4. 5 death of Jason Kingsley. 6 Today is Tuesday, February 28, 6 I am going to be taking your deposit¡on 7 2QI7, and the time is 11:49 a.m. 7 today. I am going to ask you some questions about I We are located at Tioga County I your farm, about your background, and about this I Courthouse. This deposition is being I incident. t0 taken on behalf of the Plaintiff for use 10 Let me ask you this first: Have you 11 at playback at the time of trial and in 11 ever given a deposition before? 12 association wlth the rules of discovery 12 A. I have been to an arbiter but I don't 13 in the case of Kingsley versus Gor-Wood 13 believe I have ever g¡ven a deposition. 14 Holsteins, Incorporated, doing business 14 O. So, you have been before like an 15 as Gor-Wood Farms and Ronald Christopher 15 arbitration panel or something? l6 Wood. t6 A. Worker Comp. 17 Attorney for the Plaintiff is 17 O. Okay. I am going to give you an 18 Donald Ligorio. Attorney for the 18 instruction now, which is important and we all forget l9 Defendant is Joshua Bovender. The name 19 about. You need to answer all of my questions 20 of the witness is Ronald Wood. 20 verbally. You can't nod your head, shake your head, 21 Would the court reporter please 21 gesture, say uh-huh or uh-hum. you have to give us a 22 swear in the witness? 22 clear, verbal answer, That way, it will be recorded 23 RONALD CHRISTOPHER WOOD, 23 and the court reporter will take it down, 24 WAS CALLED, AND HAVING BEEN DULY SWORN, 24 Do you understand that? 25 WAS EXAMINED AND TESTIFIED AS FOLLOWS: 25 A. okay. 6 8 1 MR. LIGORIO: Counsel, as we 1 O, Okay. And yoLr saicl yor.r testified in a 2 discussed, this is a discovery 2 Workers' Comp proceeding. Was that the Workers' Comp 3 deposition. 3 proceeding regarding Mr. Eric Stone? 4 We also will state for the record 4 A. Yes. 5 that personal counsel, Mr. Chip, 5 a. Have you testif¡ed in any other matters 6 C-H-I-P, Blackwell is present as 6 such as a lawsuit, personal injury case, contract 7 personal counsel for Mr, Wood. 7 dispute where you were placed under oath and 8 And are you for Mr. Wood or I test¡fied? I Gor-Wood-D Holsteins or both? 9 A. I was brought in as an expert w¡tness 10 MR. BLACKWELL: Both. l0 once to court for a matter concerning sales and sale 11 MR. LIGORIO: I would note that 11 of cattle. 12 Mr. Blackwell has not entered his 12 A. okay. 13 appearance; so, it is my position that 13 A. And procedural matters that were normal 14 he shouldn't be directly involved in the 14 there. l5 deposition, But, obviously, if there is 15 O. So, somebody asked your opinion as a 16 something, he can discuss it with Mr. 16 dairy farmer about various matters involving farming. 17 Bovender, 17 Did you show r"rp in cor-¡rt and offer testimony? 18 This is a discovery deposit¡on in 18 A. yes. l9 accordance with the rules of civil 19 a. Okay. So, you know what testimony 20 procedure. I will ask you just, Mr. 20 under oath is? 21 Bovender, about read and sign. Does 21 A. Yes. 22 your client elect to read and s¡gn? 22 O. You are under oath today as if you were 23 MR. BOVENDER: Yes. 23 before a Judge or a jury in a courtroom; you 24 MR. LIGORIO: With that said, I 24 understand that? 25 will get started. 25 A. Yes. 03/02/2017 01:18:42 PM Page 5 to I of 219 2 of 55 sheets 9 11 1 A. Okay. Likewise, everything you say is I question is over; okay? 2 being recorded, so, anything that you do say will be 2 A. Okay. 3 recorded and can be used later in later proceedings 3 Q. Likewise, if Attorney Bovender and I 4 in this case, Do you understand that? 4 are having any type of discussions, just wait until 5 A. yes. 5 we are done discussing and you will be instructed 6 O. I am going to ask you some questions 6 whether to answer or not answer; fair enough? 7 and if you don't understand my question, tell me you 7 A. An right. I don't understand it, I will be happy to rephrase it. I O. Okay. State your full name, please. 9 A. okay. I A. Ronald Christopher Wood. 10 a. Is there any reason you would have 10 O. And what is your date of birth? 11 difficulty understanding my questions, hearing 11 A. 7l2elsz. 12 problems, medical issues, anything like that that 12 a. Where were you born? 13 would make it difficult for you to hear me and l3 A. Wellsboro. 14 understand me? 14 O, Were you born in the property you l5 A. No. l5 reside in now? 16 O. If there is, you will let me know. l6 A. Yeah. 17 Likewise, if you need a break or 17 O. And that is a farm, correct? l8 something, let me know; okay? l8 A. Yes. 19 A. Yes. t9 O. And who are your parents? 20 O. It is not appropriate to take a break 20 A. Gordon and Dorothy Wood. 21 to discuss my questions with counsel, but if you need 21 A. Are they both still alive? 22 a break for some other reason or need to stop, let me 22 A. My mother died; my father is still 23 know. But if I have a pending question, you will be 23 alive. 24 required to answer it. Do you understand that? 24 O. And Christopher Wood is your father? 25 A. Okay. 25 A. No. 10 12 1 MR. BOVENDER: And we can discuss 1 O. Gordon Wood is your father, correct? 2 his questions. What I think you mean is 2 A. Yes. 3 he has to give the answer before we 3 a. Do you still reside with Gordon Wood? 4 adjourn. 4 A. No. 5 MR. LIGORIO: Well, I don't know 5 A. Does he reside on the farm property, as 6 if he can discuss answering the 6 well? 7 questions with you while he is in the 7 A.