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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
WENDY B. DOLIN, Individually and as Independent Executor of the ESTATE OF STEWART DOLIN, Deceased,
))))
Plaintiff, ))
v. ) Case No. 1:12-cv-06403 )
SMITHKLINEBEECHAM CORPORATION D/B/A GLAXOSMITHKLINE, a Pennsylvania Corporation
)))))
Defendant. )
Exhibit 12
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1 IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS 2 EASTERN DIVISION 3
WENDY B. DOLIN, Individually ) 4 and as Independent Executor )
of the ESTATE OF STEWART DOLIN, ) 5 Deceased, )
) 6 Plaintiff, )
) Case No. 7 -vs- ) 1:12-cv-06403
) 8 SMITHKLINE BEECHAM CORPORATION )
D/B/A GLAXOSMITHKLINE, ) 9 a Pennsylvania Corporation; )
MYLAN, INC., a Pennsylvania ) 10 Corporation; and H.D. SMITH )
WHOLESALE DRUG CO., a ) 11 Delaware Corporation with its )
principal place of business ) 12 in Illinois, )
) 13 Defendants. ) 14 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER 15 The videotaped deposition of LAURA L. KRUEGER 16 called by the Defendant GlaxoSmithKline for 17 examination, taken pursuant to the Federal Rules of 18 Civil Procedure of the United States District 19 Courts pertaining to the taking of depositions, 20 taken before CORINNE T. MARUT, C.S.R. No. 84-1968, 21 Registered Professional Reporter and a Certified 22 Shorthand Reporter of the State of Illinois, at the 23 offices of Schopf & Weiss LLP, Suite 2800, One 24 South Wacker Drive, Chicago, Illinois, on 25 December 9, 2014, at 9:11 a.m.
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1 (WHEREUPON, a certain document was
2 marked for identification as
3 Krueger Deposition Exhibit No. 1:
4 Notice of Deposition and subpoena.)
5 THE VIDEOGRAPHER: We are now on the record.
6 My name is Milo Savich and I am a
7 videographer for Golkow Technologies. Today's date
8 is December 9, 2014 and the time is 9:11 a.m.
9 This video deposition is being held in
10 Chicago, Illinois, in the matter of Wendy B. Dolin
11 vs. SmithKline Beecham Corporation, et al., for the
12 United States District Court for the Northern
13 District of Illinois.
14 The deponent is Laura Krueger.
15 Will counsel please identify themselves
16 for the record.
17 MR. BAUGHER: Peter Baugher and Nick Gowen for
18 the witness and Reed Smith.
19 MR. WISNER: Brent Wisner on behalf of the
20 Plaintiff Wendy Dolin.
21 MR. DAVIS: Todd Davis on behalf of
22 GlaxoSmithKline.
23 THE VIDEOGRAPHER: The Court Reporter is Corey
24 Marut who will now swear in the witness.
25 (The witness was duly sworn.)25 (The witness was duly sworn.)
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1 MR. DAVIS: This will be the deposition of
2 Laura Krueger that's taken in Dolin vs.
3 GlaxoSmithKline.
4 This deposition is being taken pursuant
5 to subpoena as well as Notice and agreement of
6 counsel and it's being taken pursuant to the
7 Federal Rules of Civil Procedure.
8 All objections except as to the form of
9 the question and responsiveness of the answer are
10 reserved until such further use of the deposition
11 or until time of trial.
12 LAURA L. KRUEGER,
13 called as a witness herein, having been first duly
14 sworn, was examined and testified as follows:
15 EXAMINATION
16 BY MR. DAVIS:
17 Q. Will you please tell us your full name,
18 ma'am.
19 A. Laura L. Krueger.
20 Q. Ms. Krueger, my name is Todd Davis. I
21 represent GlaxoSmithKline in the lawsuit that Wendy
22 Dolin has brought against my client that's pending
23 here in Federal Court in Chicago.
24 I'm here today to ask you some questions
25 because you've been identified as a witness that
17 Q. Will you please tell us your full name,
18 ma'am.
19 A. Laura L. Krueger.
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1 Q. That was the address that you lived at
2 in 2010?
3 A. That is correct.
4 Q. And can you give me just an overview of
5 your educational background?
6 A. Through high school.
7 Q. Through high school. And what high
8 school did you attend?
9 A. Oak Lawn Community High School.
10 Q. Is that here in Chicago?
11 A. It's in a suburb of Chicago.
12 Q. And you're employed at Reed Smith as an
13 administrative assistant?
14 A. That is correct.
15 Q. Is that your title, administrative
16 assistant, or do they go by legal secretary?
17 A. It varies. I believe it's legal
18 secretary.
19 Q. And how long have you been a legal
20 secretary?
21 A. About -- about 20, 20 some years.
22 Q. And is that how you met Mr. Dolin?
23 A. Yes.
24 Q. Did he hire you as a legal secretary?
25 A. The firm hired me.
12 Q. And you're employed at Reed Smith as an
13 administrative assistant?
14 A. That is correct.
19 Q. And how long have you been a legal
20 secretary?
21 A. About -- about 20, 20 some years.
22 Q. And is that how you met Mr. Dolin?
23 A. Yes.
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1 Q. Yes?
2 A. Yes. Sorry.
3 Q. What month did you start there?
4 A. February.
5 Q. And how long were you at the
6 Sachnoff & Weaver before you started working as
7 Mr. Dolin's secretary?
8 A. 1993.
9 Q. Do you remember what month?
10 A. I don't.
11 Q. Was it early 1993, mid, late?
12 A. I think it was -- I really don't know.
13 Q. And once you started working for
14 Mr. Dolin as his secretary in 1993, did that
15 continue on through the time that he passed away in
16 July of 2010?
17 A. Yes.
18 Q. Was there ever a period of time that you
19 weren't working for him as his secretary?
20 A. No.
21 Q. Do you remember the secretaries that
22 Mr. Dolin had before you started working for him at
23 Sachnoff Weaver in 1993?
24 A. I remember her first name. Sue.
25 Q. But not her last?
13 Q. And once you started working for
14 Mr. Dolin as his secretary in 1993, did that
15 continue on through the time that he passed away in
16 July of 2010?
17 A. Yes.
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1 A. (Shaking head.)
2 Q. Okay. Is she still at --
3 A. No.
4 Q. Employed by Reed Smith?
5 A. No.
6 Q. Do you know where she is working now?
7 A. I do not.
8 Q. When was the first time that you met
9 Wendy Dolin?
10 A. I couldn't tell you. I don't know.
11 Q. Was it shortly after the time that you
12 started working for Mr. Dolin in 1993?
13 A. No.
14 Q. Much later or earlier?
15 A. It would have been later, but I couldn't
16 tell you what year.
17 Q. Did you ever have any e-mail
18 communications with Wendy Dolin over the years
19 before Stewart Dolin passed away?
20 A. Yes.
21 Q. Did any of those e-mail communications
22 concern any doctor visits that Mr. Dolin had or
23 were scheduled to have?
24 A. Not that I remember.
25 Q. Any of the e-mail communication that you
SUSTAINED
17 Q. Did you ever have any e-mail
18 communications with Wendy Dolin over the years
19 before Stewart Dolin passed away?
20 A. Yes.
21 Q. Did any of those e-mail communications
22 concern any doctor visits that Mr. Dolin had or
23 were scheduled to have?
24 A. Not that I remember.
25 Q. Any of the e-mail communication that you
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1 had with Wendy Dolin where you recall that she
2 expressed some concern about stresses that were
3 going on with Mr. Dolin at work or someplace else?
4 A. No.
5 Q. Did you have a close personal
6 relationship with Wendy Dolin?
7 A. I had a close relationship with Wendy.
8 Q. Were you and she friends?
9 A. Yes.
10 Q. Did you do anything outside of work
11 where you interacted with each other?
12 Let me ask a better question.
13 Outside of your communications with her
14 as Mr. Dolin's secretary, did you have any
15 interactions with Mrs. Dolin?
16 A. Outside of company picnics, I did not
17 have any interactions with her.
18 Q. And outside of your work with -- for
19 Mr. Dolin as his secretary, did you have any
20 interactions with him other than seeing him at
21 firm-sponsored events?
22 A. No.
23 Q. Do you have any type of medical
24 training?
25 A. No.
SUSTAINED
SUSTAINED
1 had with Wendy Dolin where you recall that she
2 expressed some concern about stresses that were
3 going on with Mr. Dolin at work or someplace else?
4 A. No.
5 Q. Did you have a close personal
6 relationship with Wendy Dolin?
7 A. I had a close relationship with Wendy.
8 Q. Were you and she friends?
9 A. Yes.
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1 Q. In 2010 what were your job
2 responsibilities at Reed Smith?
3 A. I was legal secretary to three
4 individuals.
5 Q. Besides Mr. Dolin who else were you a
6 legal secretary for?
7 A. Nina Borders, Mary Lou Zwick.
8 Q. Is that Z-w-i-c-k?
9 A. It is.
10 Q. And how long had you been a legal
11 secretary for Ms. Borders and Ms. Zwick?
12 A. At that time?
13 Q. Yes.
14 A. A couple years. I couldn't say exactly
15 how long.
16 Q. Are Ms. Zwick and Ms. Borders lawyers
17 who worked in Mr. Dolin's practice group,
18 Corporate -- U.S. Corporate & Securities?
19 A. No.
20 Q. What practice groups did each of them
21 work in?
22 A. Nina Borders worked in Intellectual
23 Property and Mary Lou Zwick worked in Benefits.
24 Q. Employee benefits?
25 A. Um-hmm.
1 Q. In 2010 what were your job
2 responsibilities at Reed Smith?
3 A. I was legal secretary to three
4 individuals.
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1 on the merger, investigating the merger with
2 Reed Smith or other law firms?
3 A. I don't have names of individuals.
4 Q. At the time of the merger between
5 Sachnoff & Weaver and Reed Smith, was Mike LoVallo
6 the managing partner of the Sachnoff & Weaver firm?
7 A. I don't know if Mike was the managing
8 partner. It may have been another attorney.
9 Q. Who else are you thinking of besides
10 Mr. LoVallo who may have been the managing partner?
11 A. Austin Hirsch.
12 Q. Okay. Did you ever have any discussions
13 with Mr. Dolin about his reaction to a merger
14 between Reed Smith and the Sachnoff & Weaver firm?
15 A. Specifically related to the merger?
16 Q. Yes, ma'am.
17 A. I never had any personal -- no.
18 Q. Do you have any sense of what his --
19 what his reaction, what Mr. Dolin's reaction was to
20 the fact that Reed Smith and Sachnoff & Weaver may
21 merge? Was it positive? Was it negative? Do you
22 remember anything about his reaction to that?
23 A. I believe it was both.
24 Q. What was -- what were the positive
25 reactions that Mr. Dolin had to the merger?
18 Q. Do you have any sense of what his --
19 what his reaction, what Mr. Dolin's reaction was to
20 the fact that Reed Smith and Sachnoff & Weaver may
21 merge? Was it positive? Was it negative? Do you
22 remember anything about his reaction to that?
23 A. I believe it was both.
24 Q. What was -- what were the positive
25 reactions that Mr. Dolin had to the merger?
22:18-23:5No objection from Plaintiff; Court struck testimony from record pursuant to Fed. R. Evid. 403
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1 A. He was very excited about it, thought it
2 was a good fit.
3 Q. Anything else on the positive side?
4 A. Just that he, you know, for the future
5 of the firm it was a -- it was a good fit.
6 Q. Did he ever give anything -- did he ever
7 give you an explanation of -- let me back up.
8 When you say that he was excited and
9 thought it was a good fit for the future of the
10 firm, did he elaborate at all on his view about
11 those issues?
12 A. No.
13 Q. And what were his negative reactions to
14 the merger?
15 A. I think the only negative in my view
16 would have been his concern that everybody was
17 happy about the decision.
18 Q. And what do you mean by that?
19 A. He didn't want to see anybody feel bad
20 about it, you know. He didn't want to -- I don't
21 know how to explain it. He wanted to make sure
22 that everybody was happy.
23 Q. Did he express to you that there are
24 some people who may not have been happy with a
25 merger between Sachnoff & Weaver and Reed Smith?
1 A. He was very excited about it, thought it
2 was a good fit.
3 Q. Anything else on the positive side?
4 A. Just that he, you know, for the future
5 of the firm it was a -- it was a good fit.
13 Q. And what were his negative reactions to
14 the merger?
15 A. I think the only negative in my view
16 would have been his concern that everybody was
17 happy about the decision.
18 Q. And what do you mean by that?
19 A. He didn't want to see anybody feel bad
20 about it, you know. He didn't want to -- I don't
21 know how to explain it. He wanted to make sure
22 that everybody was happy.
23:13-22No objection from Plaintiff; Court struck testimony from record pursuant to Fed. R. Evid. 403
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1 knowledge, did he ever express concerns about
2 the -- that the size of Reed Smith compared to the
3 size of the Sachnoff & Weaver firm and how that
4 would affect his practice?
5 A. No.
6 Q. At the time of the merger between the
7 Sachnoff & Weaver firm and Reed Smith, it was your
8 understanding that Reed Smith was a much larger law
9 firm?
10 A. Yes.
11 Q. Was it your understanding at the time as
12 well that Reed Smith had multiple offices across
13 the world and was also considered a global law firm
14 compared to the Sachnoff & Weaver firm?
15 A. Did I know that they were a larger firm,
16 worldwide?
17 Q. Yes.
18 A. Yes, I did.
19 Q. And at the time that the
20 Sachnoff & Weaver firm merged with Reed Smith, was
21 Mr. Dolin the head of a practice group at
22 Sachnoff & Weaver?
23 A. Yes, he was.
24 Q. How many lawyers and staff was he managing
25 at the time of the merger?
19 Q. And at the time that the
20 Sachnoff & Weaver firm merged with Reed Smith, was
21 Mr. Dolin the head of a practice group at
22 Sachnoff & Weaver?
23 A. Yes, he was.
25:19-23No objection from GSK; Court struck testimony from record pursuant to Fed. R. Evid. 403
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1 A. I don't know. I don't.
2 Q. After the merger between Reed Smith and
3 the Sachnoff Weaver firm, did Mr. Dolin serve as a
4 deputy team leader for the U.S. Corporate &
5 Securities group --
6 A. Yes.
7 Q. -- for Reed Smith? He did.
8 And was the group of lawyers and staff
9 that he had to manage as part of his job larger
10 than what he had to manage when he was at the
11 Sachnoff & Weaver firm?
12 A. Yes, it was much larger.
13 Q. Much larger. Was it -- are we talking
14 about a two or three times difference in terms of
15 the number of people whom he had to manage?
16 A. I would say at least two or three times.
17 Q. Did he ever talk to you about any
18 concerns or anxieties that he had about managing
19 that large group of people as part of his job
20 responsibilities at Reed Smith?
21 A. He never talked to me about it.
22 Q. Did Mr. Dolin and you have the
23 relationship where he confided in you about
24 personal family matters?
25 A. No.
2 Q. After the merger between Reed Smith and
3 the Sachnoff Weaver firm, did Mr. Dolin serve as a
4 deputy team leader for the U.S. Corporate &
5 Securities group --
6 A. Yes.
7 Q. -- for Reed Smith? He did.
8 And was the group of lawyers and staff
9 that he had to manage as part of his job larger
10 than what he had to manage when he was at the
11 Sachnoff & Weaver firm?
12 A. Yes, it was much larger.
13 Q. Much larger. Was it -- are we talking
14 about a two or three times difference in terms of
15 the number of people whom he had to manage?
16 A. I would say at least two or three times.
17 Q. Did he ever talk to you about any
18 concerns or anxieties that he had about managing
19 that large group of people as part of his job
20 responsibilities at Reed Smith?
21 A. He never talked to me about it.
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1 office?
2 A. No.
3 Q. Or anywhere else?
4 A. No.
5 Q. After Mr. Dolin passed away did you
6 learn that he was seeing a therapist or mental
7 health counselor before he passed away?
8 A. No.
9 Q. After the Sachnoff & Weaver firm merged
10 with Reed Smith there is a period of I believe two
11 years where Mr. Dolin was the deputy leader of the
12 U.S. Corporate & Securities team?
13 A. Okay.
14 Q. Is that your recollection as well?
15 A. The deputy?
16 Q. Or the co-practice leader.
17 A. Yes.
18 Q. Okay. And then in 2009 did his
19 responsibilities change where he was the leader,
20 the practice group leader, for the U.S. Corporate &
21 Securities team?
22 A. Yes, that is correct.
23 Q. And in terms of your working with him
24 did you notice as a result of that transition where
25 he had -- he was working more on administrative
9 Q. After the Sachnoff & Weaver firm merged
10 with Reed Smith there is a period of I believe two
11 years where Mr. Dolin was the deputy leader of the
12 U.S. Corporate & Securities team?
13 A. Okay.
14 Q. Is that your recollection as well?
15 A. The deputy?
16 Q. Or the co-practice leader.
17 A. Yes.
18 Q. Okay. And then in 2009 did his
19 responsibilities change where he was the leader,
20 the practice group leader, for the U.S. Corporate &
21 Securities team?
22 A. Yes, that is correct.
23 Q. And in terms of your working with him
24 did you notice as a result of that transition where
25 he had -- he was working more on administrative
33:9-34:16No objection from Plaintiff; Court struck testimony from record pursuant to Fed. R. Evid. 403
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1 responsibilities for the firm?
2 A. Yes.
3 Q. And were the administrative
4 responsibilities that he was taking on as a
5 practice group leader more demanding than what he
6 had experienced when he had someone else to share
7 the responsibility with?
8 A. Yes, yeah.
9 Q. More demanding in what way?
10 A. Travel. Just, you know, people coming
11 to his door more. More conference calls.
12 Q. More meetings?
13 A. More meetings. Lots more meetings.
14 Q. And were these meetings having to deal
15 with firm management?
16 A. Yes, I believe so.
17 Q. Did Mr. Dolin ever express to you any
18 concerns, worries or anxieties about him having to
19 serve as a practice group leader on his own with no
20 other person to give him support as he had in the
21 years prior when he had shared responsibility in
22 that role?
23 A. No.
24 Q. With Mr. Dolin's additional
25 responsibilities in 2009 as a practice group
ed.
SUSTAINED
1 responsibilities for the firm?
2 A. Yes.
3 Q. And were the administrative
4 responsibilities that he was taking on as a
5 practice group leader more demanding than what he
6 had experienced when he had someone else to share
7 the responsibility with?
8 A. Yes, yeah.
9 Q. More demanding in what way?
10 A. Travel. Just, you know, people coming
11 to his door more. More conference calls.
12 Q. More meetings?
13 A. More meetings. Lots more meetings.
14 Q. And were these meetings having to deal
15 with firm management?
16 A. Yes, I believe so.
17 Q. Did Mr. Dolin ever express to you any
18 concerns, worries or anxieties about him having to
19 serve as a practice group leader on his own with no
20 other person to give him support as he had in the
21 years prior when he had shared responsibility in
22 that role?
23 A. No.
24 Q. With Mr. Dolin's additional
25 responsibilities in 2009 as a practice group
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1 leader, did you see that those responsibilities
2 caused him either anxiety, worries or stresses?
3 A. Yes, yes.
4 Q. And can you give examples of how his
5 responsibilities as a practice group leader in 2009
6 caused him worries, anxieties or stresses?
7 A. I'm sorry. You said 2009?
8 Q. Yes.
9 A. Then I would have to say no, not in
10 2009.
11 Q. What period of time were you thinking
12 of?
13 A. In 2010 I had asked him -- he had lost
14 weight.
15 Q. When did you notice that he had lost
16 weight?
17 A. I couldn't tell you the month. All I
18 know is that -- I would think it would be in
19 June or July, yeah.
20 Q. Did you raise that with Mr. Dolin that
21 he -- that you -- let me back up. Sorry. Bad
22 question.
23 When you noticed that Mr. Dolin had lost
24 weight, did you raise that issue with him?
25 A. I did.
1 leader, did you see that those responsibilities
2 caused him either anxiety, worries or stresses?
3 A. Yes, yes.
4 Q. And can you give examples of how his
5 responsibilities as a practice group leader in 2009
6 caused him worries, anxieties or stresses?
7 A. I'm sorry. You said 2009?
8 Q. Yes.
9 A. Then I would have to say no, not in
10 2009.
11 Q. What period of time were you thinking
12 of?
13 A. In 2010 I had asked him -- he had lost
14 weight.
15 Q. When did you notice that he had lost
16 weight?
17 A. I couldn't tell you the month. All I
18 know is that -- I would think it would be in
19 June or July, yeah.
23 When you noticed that Mr. Dolin had lost
24 weight, did you raise that issue with him?
25 A. I did.
34:24-35:10No objection from Plaintiff; Court struck testimony from record pursuant to Fed. R. Evid. 403
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1 Q. And what did you say to him?
2 A. I asked him if everything was okay
3 because he had lost weight.
4 Q. And to you, can you describe how marked
5 or significant was the weight loss to you?
6 A. Because of his build, I would say maybe
7 seven to ten pounds and it would show because of
8 his build. He wasn't an extremely large man.
9 Q. And when you say "his build," are you
10 talking about there were certain parts of him that
11 looked thinner than normal?
12 A. He just looked thinner generally.
13 Q. And was that not only with his body but
14 also his face?
15 A. Yes, I would say so.
16 Q. And can you give any more precision
17 about when you noticed this in June or July of
18 2010?
19 A. I can't. It was just something that I
20 had noticed.
21 Q. And can you give us an estimate of how
22 many weeks before he passed away that you noticed
23 this and said something to him?
24 A. It was something I noticed. I couldn't
25 tell you exactly when. It was just something I
1 Q. And what did you say to him?
2 A. I asked him if everything was okay
3 because he had lost weight.
4 Q. And to you, can you describe how marked
5 or significant was the weight loss to you?
6 A. Because of his build, I would say maybe
7 seven to ten pounds and it would show because of
8 his build. He wasn't an extremely large man.
9 Q. And when you say "his build," are you
10 talking about there were certain parts of him that
11 looked thinner than normal?
12 A. He just looked thinner generally.
13 Q. And was that not only with his body but
14 also his face?
15 A. Yes, I would say so.
16 Q. And can you give any more precision
17 about when you noticed this in June or July of
18 2010?
19 A. I can't. It was just something that I
20 had noticed.
21 Q. And can you give us an estimate of how
22 many weeks before he passed away that you noticed
23 this and said something to him?
24 A. It was something I noticed. I couldn't
25 tell you exactly when. It was just something I
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1 noticed and I can't tell you when. I'm sorry.
2 Q. Let me just see if I can nail this --
3 A. Yeah.
4 Q. -- down a little bit more.
5 A. Yeah.
6 Q. Are you able to say that it was within
7 the last week of his death, two weeks before his
8 death?
9 A. I cannot say whether it was within that
10 time frame, no.
11 Q. Okay. And, so, you mentioned to him
12 that you had noticed that he had lost weight?
13 A. Um-hmm.
14 Q. Yes?
15 A. Yes.
16 Q. And what did he say in response? I
17 think you asked him -- you said to him, "Is
18 everything okay"?
19 A. Correct.
20 Q. What was his response?
21 A. Initially he said he was fine and we
22 left it at that.
23 Q. Did you --
24 A. And then.
25 Q. Did you come back -- did that issue
1 noticed and I can't tell you when. I'm sorry.
6 Q. Are you able to say that it was within
7 the last week of his death, two weeks before his
8 death?
9 A. I cannot say whether it was within that
10 time frame, no.
16 Q. And what did he say in response? I
17 think you asked him -- you said to him, "Is
18 everything okay"?
19 A. Correct.
20 Q. What was his response?
21 A. Initially he said he was fine and we
22 left it at that.
23 Q. Did you --
24 A. And then.
25 Q. Did you come back -- did that issue
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1 again -- did you re-raise the issue with him later?
2 A. I did not re-raise it with him, no.
3 Q. Did he re-raise it with you?
4 A. He did.
5 Q. When did that occur?
6 A. The same day, whenever that was. I had
7 gone into his office to either give him something
8 and he had just made mention of it again.
9 Q. What did he say to you?
10 A. He said that there was a lot going on in
11 his life and that he was not able to devote the
12 type of time any one of the matters that he was
13 concerned about. Does that make sense?
14 Q. He was not able to devote?
15 A. The type of time, the amount of time to
16 any one of them.
17 Q. When you had this discussion with him,
18 how did he appear to you?
19 A. He wanted to set me at ease.
20 Q. Why do you say that he -- why do you say
21 that?
22 A. Because that's the type of person he
23 was.
24 Q. Did he say anything more to you other
25 than he was not able to devote his time to any one
1 again -- did you re-raise the issue with him later?
2 A. I did not re-raise it with him, no.
3 Q. Did he re-raise it with you?
4 A. He did.
5 Q. When did that occur?
6 A. The same day, whenever that was. I had
7 gone into his office to either give him something
8 and he had just made mention of it again.
9 Q. What did he say to you?
10 A. He said that there was a lot going on in
11 his life and that he was not able to devote the
12 type of time any one of the matters that he was
13 concerned about. Does that make sense?
14 Q. He was not able to devote?
15 A. The type of time, the amount of time to
16 any one of them.
17 Q. When you had this discussion with him,
18 how did he appear to you?
19 A. He wanted to set me at ease.
20 Q. Why do you say that he -- why do you say
21 that?
22 A. Because that's the type of person he
23 was.
24 Q. Did he say anything more to you other
25 than he was not able to devote his time to any one
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1 of the matters or however he phrased it? Did he
2 say anything more to you other than what you
3 previously told us in that second conversation?
4 A. Specifically he made mention of his
5 father-in-law.
6 Q. What did he mention about his
7 father-in-law?
8 A. That his father-in-law was passing. He
9 was ill, very ill.
10 Q. What else did he mention during that
11 second conversation?
12 A. That his clients and his -- the
13 administrative side of his work. Those were the
14 three issues that he wanted to be able to devote
15 more time to.
16 Q. So, his three issues that he wanted to
17 devote more time to were his clients, the
18 administrative work and this issue with his
19 father-in-law being very ill?
20 A. Yes.
21 Q. All right. Did he mention to you that
22 day, either during the first conversation or the
23 second conversation, anything about any problems or
24 issues that he was having with a particular client?
25 A. No.
1 of the matters or however he phrased it? Did he
2 say anything more to you other than what you
3 previously told us in that second conversation?
4 A. Specifically he made mention of his
5 father-in-law.
6 Q. What did he mention about his
7 father-in-law?
8 A. That his father-in-law was passing. He
9 was ill, very ill.
10 Q. What else did he mention during that
11 second conversation?
12 A. That his clients and his -- the
13 administrative side of his work. Those were the
14 three issues that he wanted to be able to devote
15 more time to.
16 Q. So, his three issues that he wanted to
17 devote more time to were his clients, the
18 administrative work and this issue with his
19 father-in-law being very ill?
20 A. Yes.
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1 Q. How long did the first conversation
2 last?
3 A. My first conversation when I asked him?
4 Q. Yes.
5 A. That was the extent of it.
6 Q. And then -- so, a few seconds?
7 A. Oh, sure. A couple of seconds.
8 Q. And for the second conversation that you
9 had with him, how long did that last?
10 A. Enough time -- three minutes, five
11 minutes.
12 Q. And when you had the conversation with
13 him the second time, did he shut the door to his
14 office before having this conversation with you?
15 A. I don't remember. I don't remember. He
16 may have. I may have.
17 Q. And do you remember him saying anything
18 else during the second conversation other than what
19 you've already told us?
20 A. No.
21 Q. And do you remember anything else that
22 you said to him during that second conversation?
23 A. If there was anything I can do to help,
24 let me know.
25 Q. Did he mention at all about whether he
1 Q. How long did the first conversation
2 last?
3 A. My first conversation when I asked him?
4 Q. Yes.
5 A. That was the extent of it.
6 Q. And then -- so, a few seconds?
7 A. Oh, sure. A couple of seconds.
8 Q. And for the second conversation that you
9 had with him, how long did that last?
10 A. Enough time -- three minutes, five
11 minutes.
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1 was seeking any kind of help from a doctor,
2 counselor or therapist?
3 A. Not at all.
4 Q. Did he mention at all that he was taking
5 or thinking about taking any type of medication to
6 help him?
7 A. Not at all.
8 Q. And in terms of his physical appearance
9 during that -- those conversations, how did he
10 look?
11 A. He looked good. He looked good.
12 Oh, I'm sorry. He did mention that he
13 wanted to start getting prepared for skiing season
14 as well, which was another reason that he was...
15 Q. Did you notice -- after you had this
16 conversation with him about his weight and the fact
17 that he lost weight and then what he told you about
18 what was going on with him, did you notice any
19 change in his weight after that time, whether it
20 went up or down or stayed the same?
21 A. It would have stayed the same. I didn't
22 notice an increase or a decrease in weight.
23 Q. Did he mention anything to you during
24 his conversations with you about whether he was
25 losing sleep?
8 Q. And in terms of his physical appearance
9 during that -- those conversations, how did he
10 look?
11 A. He looked good. He looked good.
12 Oh, I'm sorry. He did mention that he
13 wanted to start getting prepared for skiing season
14 as well, which was another reason that he was...
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1 added job responsibilities that he had as a
2 practice group leader, did you ever see any effect
3 on his ability to maintain his composure and his
4 ability to interact with other people?
5 A. No, it never changed his personality,
6 no.
7 Q. Did he ever -- during -- there was a
8 time when Mr. Dolin -- there was an announcement
9 made that Mr. Dolin -- let me see if I can show
10 this to you. Hold on.
11 There was an announcement by Reed Smith
12 where it was announced that Paul Jaskot was going
13 to share practice group leader responsibility with
14 Mr. Dolin and that announcement came out a few
15 weeks before Mr. Dolin's death. Do you remember
16 that?
17 A. I remember Paul, yes. Okay.
18 Q. Do you --
19 A. The announcement I don't remember
20 specifically.
21 Q. Do you remember how long that there had
22 been discussions with Mr. -- where Mr. Dolin had
23 advised the firm management about that he --
24 that -- let me back up.
25 Do you know the circumstances by which25 Do you know the circumstances by which
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1 that decision was made for Mr. Jaskot to come in
2 and be a co-practice group leader with Mr. Dolin?
3 A. I did not know that a co-leader was
4 being named.
5 Q. Did that come as a surprise to you?
6 A. When the announcement came out?
7 Q. Yes.
8 A. I believe -- yeah. I'm trying to
9 remember if -- I believe that's when I found out is
10 when -- I believe that's when I found out is when
11 the announcement came out.
12 Q. Mr. Dolin hadn't shared with you in
13 advance that he -- that Mr. Jaskot would be coming
14 in to serve as a co-practice group leader with him
15 before the announcement was made?
16 A. He may have. I can't -- I know that we
17 spoke about it, but I can't remember if it was
18 before or after the announcement came out.
19 Q. And --
20 A. Because I was surprised.
21 Q. Why were you surprised?
22 A. Because I didn't know anything about it
23 and I was just, you know. It caught me off guard.
24 Q. Was this -- was the announcement made
25 before or after you had the conversation with him
1 that decision was made for Mr. Jaskot to come in
2 and be a co-practice group leader with Mr. Dolin?
3 A. I did not know that a co-leader was
4 being named.
5 Q. Did that come as a surprise to you?
6 A. When the announcement came out?
7 Q. Yes.
8 A. I believe -- yeah. I'm trying to
9 remember if -- I believe that's when I found out is
10 when -- I believe that's when I found out is when
11 the announcement came out.
12 Q. Mr. Dolin hadn't shared with you in
13 advance that he -- that Mr. Jaskot would be coming
14 in to serve as a co-practice group leader with him
15 before the announcement was made?
16 A. He may have. I can't -- I know that we
17 spoke about it, but I can't remember if it was
18 before or after the announcement came out.
19 Q. And --
20 A. Because I was surprised.
21 Q. Why were you surprised?
22 A. Because I didn't know anything about it
23 and I was just, you know. It caught me off guard.
24 Q. Was this -- was the announcement made
25 before or after you had the conversation with him
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1 that day where you mentioned something about him
2 losing weight and asking if he was okay?
3 A. I -- that wasn't even on the same day.
4 Q. I know. I was just trying to get a
5 sense of whether your conversations you had with
6 him, that you had two conversations with him on a
7 day where you --
8 A. Um-hmm.
9 Q. -- talked to him about how he was doing.
10 A. Um-hmm.
11 Q. And I was trying to get a sense of
12 whether the conversations you had with him took
13 place before or after the announcement that
14 Mr. Jaskot was coming in.
15 A. Oh. It would have been before.
16 Q. Before the announcement about
17 Mr. Jaskot?
18 A. About -- yes.
19 Q. Did Mr. Dolin ever tell you or say in
20 your presence why he was -- Mr. Jaskot had come in
21 to serve as a co-practice group leader?
22 A. Yes.
23 Q. What do you remember Mr. Dolin saying
24 about that?
25 A. That the amount of -- he was not going
1 that day where you mentioned something about him
2 losing weight and asking if he was okay?
3 A. I -- that wasn't even on the same day.
11 Q. And I was trying to get a sense of
12 whether the conversations you had with him took
13 place before or after the announcement that
14 Mr. Jaskot was coming in.
15 A. Oh. It would have been before.
16 Q. Before the announcement about
17 Mr. Jaskot?
18 A. About -- yes.
19 Q. Did Mr. Dolin ever tell you or say in
20 your presence why he was -- Mr. Jaskot had come in
21 to serve as a co-practice group leader?
22 A. Yes.
23 Q. What do you remember Mr. Dolin saying
24 about that?
25 A. That the amount of -- he was not going
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1 to be able to handle the amount of administration
2 matters because the group was so large.
3 Q. Do you remember him saying anything
4 else?
5 A. No, not really.
6 Q. Do you remember anything -- Mr. Dolin
7 saying anything along the lines that this would
8 allow him to spend more time with his clients as
9 opposed to doing administrative work?
10 A. No.
11 Q. Did you ever hear anybody make any
12 criticisms or complaints about Mr. Dolin's work as
13 a practice group leader?
14 A. No.
15 Q. Did Mr. Dolin ever discuss with you any
16 of his compensation reviews?
17 A. Never.
18 Q. I would not think so, but I needed to
19 ask.
20 When -- do you remember what time of the
21 year that the compensation process, evaluation
22 process takes place for Reed Smith equity partners?
23 A. I don't remember. I believe October. I
24 don't remember.
25 Q. And did you ever assist Mr. Dolin in
OVERRULED
1 to be able to handle the amount of administration
2 matters because the group was so large.
11 Q. Did you ever hear anybody make any
12 criticisms or complaints about Mr. Dolin's work as
13 a practice group leader?
14 A. No.
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1 preparing any of his paperwork such as a
2 self-evaluation for purposes of his evaluation as
3 an equity partner?
4 A. No.
5 Q. Did he do those always on his own?
6 A. I believe so, yes.
7 Q. Did you have access to them on the
8 computer?
9 A. No.
10 Q. When he created a document for purposes
11 of his self-evaluation, would he -- like you have
12 to create the document -- I would assume you have
13 to create the document on the system. Did he ask
14 your assistance in setting it up or did he do all
15 that by himself?
16 A. I believe he did all that by himself.
17 It was I believe a system run -- I don't know if
18 there was a document creation.
19 Q. There may have been a link where he
20 could go online and type in his evaluation?
21 A. I assume there is.
22 Q. After the announcement came out that
23 Mr. Jaskot was going to be sharing co-practice
24 group leader responsibilities with Mr. Dolin, did
25 Mr. Dolin appear more relieved or less stressed in
22 Q. After the announcement came out that
23 Mr. Jaskot was going to be sharing co-practice
24 group leader responsibilities with Mr. Dolin, did
25 Mr. Dolin appear more relieved or less stressed in
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1 any way to you?
2 A. Yes.
3 Q. In what way?
4 A. Exactly what you stated, less --
5 relieved, less stressed.
6 Q. More relieved, less stressed?
7 A. More relieved, less stressed.
8 Q. Okay. In May of 2010 -- let me back up.
9 In the first part of the year of 2010
10 was Mr. Dolin relatively busy during that time
11 period?
12 A. I cannot remember.
13 Q. Was there a period of time where he was
14 busy in 2010 and then there was a period where he
15 was not as busy in terms of his billable hours?
16 A. I cannot remember.
17 Q. Was there a period of time where any of
18 the months in 2010 that you can recall where he was
19 not billing as many hours as another month?
20 A. I -- that would not -- I don't remember.
21 Q. Did you enter Mr. Dolin's time in 2010?
22 A. I did.
23 Q. Did he have time sheets?
24 A. He did.
25 Q. Did he handwrite out the time sheets?
1 any way to you?
2 A. Yes.
3 Q. In what way?
4 A. Exactly what you stated, less --
5 relieved, less stressed.
6 Q. More relieved, less stressed?
7 A. More relieved, less stressed.
21 Q. Did you enter Mr. Dolin's time in 2010?
22 A. I did.
23 Q. Did he have time sheets?
24 A. He did.
25 Q. Did he handwrite out the time sheets?
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1 A. Yes, he did.
2 Q. And were the time sheets due at the end
3 of every week?
4 A. Well, Stu handed them in every day.
5 Q. He did. All right. And did -- during
6 the week of his death, the week he passed away, did
7 he complete a time sheet for every day?
8 A. I believe so.
9 Q. Except I assume for the Thursday, the
10 day he passed away, that's one day of that week
11 where he would not have put in a time sheet?
12 A. That would be correct because he would
13 have given it to me the following day.
14 Q. So, he had a routine of at the end of
15 every day he would give you his time sheet for that
16 day?
17 A. I would pick it up in the morning. I
18 don't know when he would finish it.
19 Q. Yes. And so the last week of his death,
20 he continued to follow that practice?
21 A. Yes, to my knowledge.
22 Q. Do you remember any physician, therapist
23 or counselor making contact or a phone call with
24 Mr. Dolin in the month before he passed away?
25 A. A doctor for his health?
1 A. Yes, he did.
2 Q. And were the time sheets due at the end
3 of every week?
4 A. Well, Stu handed them in every day.
5 Q. He did. All right. And did -- during
6 the week of his death, the week he passed away, did
7 he complete a time sheet for every day?
8 A. I believe so.
19 Q. Yes. And so the last week of his death,
20 he continued to follow that practice?
21 A. Yes, to my knowledge.
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1 more focused on my vacation. Sorry.
2 Q. Did you notice anything different with
3 Mr. Dolin in terms of his routine that week?
4 A. No.
5 Q. Did you notice anything where -- during
6 that last week of his life where he was having more
7 phone calls than typical?
8 A. No.
9 Q. Was that something that you were paying
10 attention to at the time?
11 A. Not at all.
12 Q. Are you aware of any client complaints
13 that came in to Mr. Dolin the last week of his
14 life?
15 A. No.
16 Q. Did Mr. Dolin ever ask you to do any
17 type of non-business personal tasks for him over
18 the course of the time that you worked for him?
19 A. Yes.
20 Q. What kind of non-personal things would
21 he ask you to do?
22 A. Type up his children's college
23 applications.
24 Q. Okay. Those are always fun.
25 Any others?
OVERRULED
12 Q. Are you aware of any client complaints
13 that came in to Mr. Dolin the last week of his
14 life?
15 A. No.
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1 Q. Nothing jumps out?
2 A. Nothing jumps out.
3 Q. As some different routine or some where
4 he went out of the office to someplace that -- and
5 left before you did that week?
6 A. The only day that he left and didn't
7 return was the Thursday.
8 Q. And I'm sorry if I already asked this.
9 But for each of the evenings of that week you don't
10 know what -- how late he stayed at the office?
11 A. I don't remember, no.
12 Q. During that entire week did you notice
13 anything different, unusual or odd about Mr. Dolin?
14 A. No.
15 Q. When you spoke with him that week, was
16 Mr. Dolin acting coherently to you?
17 A. Yes.
18 Q. When you spoke to him that week, was he
19 thinking -- strike that.
20 When he spoke to you that week, did he
21 sound rational and -- let me back up.
22 When you spoke to him that week, did he
23 sound rational to you?
24 A. Yes.
25 Q. Did you notice any anxious behavior on
12 Q. During that entire week did you notice
13 anything different, unusual or odd about Mr. Dolin?
14 A. No.
15 Q. When you spoke with him that week, was
16 Mr. Dolin acting coherently to you?
17 A. Yes.
22 When you spoke to him that week, did he
23 sound rational to you?
24 A. Yes.
25 Q. Did you notice any anxious behavior on
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1 his part that week, whether that be pacing or
2 jitteriness of his hands or legs or hand wringing,
3 anything of that nature?
4 A. Not that I can remember.
5 Q. And did you have multiple interactions
6 with Stewart Dolin the week before his death?
7 A. He was in the office, so I saw him as he
8 would walk into his office and walk out of his
9 office, but...
10 Q. Were you working on any particular
11 project for Mr. Dolin like a document or
12 something -- something legal-related that week?
13 A. That week?
14 Q. Yes.
15 A. I don't know if I was working on
16 documents. I mean, I worked for two other
17 attorneys as well. So, I can't say specifically
18 yes, I was working on a document for Stu. I may
19 have been. I don't remember.
20 Q. Are you aware that the morning that
21 Mr. Dolin passed away that he had about a 45-minute
22 meeting with Mike LoVallo at Mike LoVallo's office?
23 A. Not that I can remember.
24 Q. And were Mr. LoVallo and Mr. Dolin, they
25 were on different floors?
1 his part that week, whether that be pacing or
2 jitteriness of his hands or legs or hand wringing,
3 anything of that nature?
4 A. Not that I can remember.
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1 a conversation with Mrs. Dolin where she asked you
2 whether Mr. Dolin was acting differently in any way
3 during his last week?
4 A. No.
5 Q. When you met with the lawyer for
6 Mrs. Dolin, did you tell her what you've told us
7 her today, that Mr. Dolin -- that you didn't
8 observe anything in terms of Mr. Dolin acting
9 differently or unusual the last week of his life?
10 A. I believe so with the exception of the
11 weight loss. I made mention of that to her.
12 Q. Has Mrs. Dolin ever asked you what
13 Mr. Dolin was doing the last week of his life?
14 A. I don't remember her asking that.
15 Q. Did you ever hear Mrs. Dolin say that
16 Mr. Dolin was acting differently or unusual or odd
17 in any way in the week before he passed away?
18 A. In the week before he passed away? She
19 had e-mailed me and said that the nurse on the
20 platform of the el track had noticed his behavior.
21 That would be the only thing.
22 Q. All right. And, so, she -- do you
23 remember when Mrs. Dolin e-mailed you about that?
24 A. I don't. But, again, it would have
25 been -- I was gone for two weeks afterwards so it
15 Q. Did you ever hear Mrs. Dolin say that
16 Mr. Dolin was acting differently or unusual or odd
17 in any way in the week before he passed away?
18 A. In the week before he passed away? She
19 had e-mailed me and said that the nurse on the
20 platform of the el track had noticed his behavior.
21 That would be the only thing.
22 Q. All right. And, so, she -- do you
23 remember when Mrs. Dolin e-mailed you about that?
24 A. I don't. But, again, it would have
25 been -- I was gone for two weeks afterwards so it
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1 would have been after that.
2 Q. And other than Mrs. Dolin recounting in
3 this e-mail that a nurse had seen Mr. Dolin on the
4 platform before his death, did she mention anything
5 else in the e-mail about Mr. Dolin acting unusual
6 or differently during the week of his death?
7 A. No.
8 Q. During the e-mail that Mrs. Dolin sent
9 to you a short time after Mr. Dolin passed away,
10 did she mention anything about a medication that
11 Mr. Dolin was taking and whether that was causing
12 him to act in any way?
13 A. I don't know if it was Wendy, but that
14 would be the only one I would assume. Was taking
15 either Paxil or a generic form of it.
16 Q. I'm sorry. Who was taking that
17 medication?
18 A. That Stu was taking either -- it was
19 either Paxil or a generic form of it.
20 Q. And was that information in the e-mail
21 that Mrs. Dolin sent you shortly after Mr. Dolin
22 passed away?
23 A. I think so, yeah. Yeah.
24 Q. And did Mrs. Dolin attribute the Paxil
25 or the generic version of it to Mr. Dolin's
1 would have been after that.
2 Q. And other than Mrs. Dolin recounting in
3 this e-mail that a nurse had seen Mr. Dolin on the
4 platform before his death, did she mention anything
5 else in the e-mail about Mr. Dolin acting unusual
6 or differently during the week of his death?
7 A. No.
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1 Q. What time did you leave for your lunch
2 that day?
3 A. I don't remember. I remember I was away
4 from my desk. Probably around -- I typically would
5 take lunch around 12:00. So, it was either 12:00
6 or 12:30 that I went to lunch.
7 Q. When was the last time that you saw him
8 on the -- on July 15, 2010?
9 A. In the morning. I don't know what time.
10 Q. And you -- I think you told us you
11 typically got in around 8:00 that morning?
12 A. Right.
13 Q. Okay. And any behavior of his that you
14 observed -- let me back up.
15 Did you see him the morning of July 15,
16 2010?
17 A. I believe so, yes.
18 Q. Anything about Mr. Dolin's behavior that
19 day that was odd, unusual or out of the ordinary in
20 any way?
21 A. I did not notice anything.
22 Q. Did you speak with him that day?
23 A. I'm sure I did.
24 Q. Was he -- did he sound as if he was
25 speaking clearly and coherently?
15 Did you see him the morning of July 15,
16 2010?
17 A. I believe so, yes.
18 Q. Anything about Mr. Dolin's behavior that
19 day that was odd, unusual or out of the ordinary in
20 any way?
21 A. I did not notice anything.
22 Q. Did you speak with him that day?
23 A. I'm sure I did.
24 Q. Was he -- did he sound as if he was
25 speaking clearly and coherently?
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1 A. Yes.
2 Q. Anything about his speech or his pattern
3 of speech that was unusual or out of the ordinary
4 in any way?
5 A. Not that I can remember.
6 Q. Your last interaction with him on
7 July 15, 2010 was sometime before he left for his
8 lunch?
9 A. Sometime before I left for my lunch,
10 yes.
11 Q. Okay. And do you know anything about
12 what happened during his lunch date that day?
13 A. No.
14 Q. Have you spoken with the gentleman who
15 he had lunch with that day?
16 A. No.
17 Q. Do you know of anyone who saw him after
18 lunch on that day?
19 A. No.
20 Q. Do you know of anyone who saw him leave
21 the building that day?
22 A. The secretary that sat next to me said
23 that she had, you know -- he said he was leaving
24 and -- because I was away from my desk.
25 Q. Who was the secretary who sat next to
1 A. Yes.
2 Q. Anything about his speech or his pattern
3 of speech that was unusual or out of the ordinary
4 in any way?
5 A. Not that I can remember.
6 Q. Your last interaction with him on
7 July 15, 2010 was sometime before he left for his
8 lunch?
9 A. Sometime before I left for my lunch,
10 yes.
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1 deputy.
2 Q. And where was John Iino located, what
3 office?
4 A. California.
5 Q. Was he in the Los Angeles office?
6 A. I think he shared two offices. I can't
7 remember if it was Silicon Valley. Silicon Valley
8 and another office. I can't remember which one he
9 was in.
10 Q. Based upon your observations and
11 interactions with Mr. Dolin during the time period
12 that he was serving, as you describe it, as a
13 deputy practice group leader, was Mr. Iino
14 principally responsible for doing the practice
15 group leader responsibilities?
16 A. Yes.
17 Q. And in terms of the volume of work that
18 Mr. Dolin had to do as a practice group leader when
19 he was the sole practice group leader versus when
20 he was working underneath Mr. Iino, did his work
21 substantially increase once he was doing it all by
22 himself?
23 A. His administrative work?
24 Q. Yes.
25 A. Yes.
10 Q. Based upon your observations and
11 interactions with Mr. Dolin during the time period
12 that he was serving, as you describe it, as a
13 deputy practice group leader, was Mr. Iino
14 principally responsible for doing the practice
15 group leader responsibilities?
16 A. Yes.
17 Q. And in terms of the volume of work that
18 Mr. Dolin had to do as a practice group leader when
19 he was the sole practice group leader versus when
20 he was working underneath Mr. Iino, did his work
21 substantially increase once he was doing it all by
22 himself?
23 A. His administrative work?
24 Q. Yes.
25 A. Yes.
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1 Q. And when he had -- when he was working
2 with Mr. Iino as a -- as what you describe as a
3 deputy practice group leader, how many hours per
4 month was he devoting to that administrative role?
5 A. I have never calculated them. I don't
6 know.
7 Q. Was it minimal compared to what he was
8 doing when he was the sole practice group leader?
9 A. I don't know how many hours he put forth
10 doing administrative work prior to. I know it was
11 a lot. But I don't know how many. And then, yes,
12 the administrative side did increase because he was
13 the sole person in charge then.
14 Q. And when Mr. Iino was the practice group
15 leader and Mr. Dolin was the deputy practice group
16 leader, as you described it, did Mr. Iino take the
17 lion's share of the work on the administrative
18 side?
19 A. I don't know.
20 Q. Did Mr. Dolin travel as much when he
21 was a deputy practice group leader before he was a
22 sole practice group leader?
23 A. Not that I remember.
24 Q. So, he was traveling more when he was
25 solely the practice group leader?
1 Q. And when he had -- when he was working
2 with Mr. Iino as a -- as what you describe as a
3 deputy practice group leader, how many hours per
4 month was he devoting to that administrative role?
5 A. I have never calculated them. I don't
6 know.
7 Q. Was it minimal compared to what he was
8 doing when he was the sole practice group leader?
9 A. I don't know how many hours he put forth
10 doing administrative work prior to. I know it was
11 a lot. But I don't know how many. And then, yes,
12 the administrative side did increase because he was
13 the sole person in charge then.
20 Q. Did Mr. Dolin travel as much when he
21 was a deputy practice group leader before he was a
22 sole practice group leader?
23 A. Not that I remember.
24 Q. So, he was traveling more when he was
25 solely the practice group leader?
78:20-79:12No objection from Plaintiff; Court struck testimony from record pursuant to Fed. R. Evid. 403
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1 A. Yes.
2 Q. And was he having as many administrative
3 meetings when he was a deputy practice group leader
4 as opposed to the sole practice group leader?
5 A. I don't know, but the meetings changed.
6 He became -- it may have been more conference calls
7 when he was a deputy and not so many face-to-face
8 meetings as he was when he was practice group.
9 Q. So, he had more face-to-face meetings as
10 a sole practice group leader than when he had in
11 his previous administrative responsibilities?
12 A. If my memory serves me correct, yes.
13 Q. Was there anything that you can recall
14 from around late 2007 where Mr. Dolin was under
15 stress because of work or family issues?
16 A. Not that I can remember because I think
17 the merger had already taken place by that time.
18 Q. Did you get the impression from your
19 interactions with Mr. Dolin that he was anxious or
20 stressed in any way about the merger between
21 Sachnoff & Weaver and Reed Smith?
22 A. Yes, he was anxious because of change.
23 Q. And when you say "he was anxious because
24 of change," what do you mean by that?
25 A. Well, he was concerned for all aspects
1 A. Yes.
2 Q. And was he having as many administrative
3 meetings when he was a deputy practice group leader
4 as opposed to the sole practice group leader?
5 A. I don't know, but the meetings changed.
6 He became -- it may have been more conference calls
7 when he was a deputy and not so many face-to-face
8 meetings as he was when he was practice group.
9 Q. So, he had more face-to-face meetings as
10 a sole practice group leader than when he had in
11 his previous administrative responsibilities?
12 A. If my memory serves me correct, yes.
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1 The objection goes to whether you know the answer
2 to the question.
3 THE WITNESS: Okay.
4 BY THE WITNESS:
5 A. Could you repeat the question for me
6 now, please.
7 BY MR. DAVIS:
8 Q. Sure. Based upon your observations and
9 interactions, how did the economic downturn in 2009
10 affect Mr. Dolin?
11 A. I don't know how it affected him
12 personally. Professionally I can say that he tried
13 to keep everybody upbeat about it.
14 Q. Was there -- were there occasions where
15 he expressed to you during the 2008-2009 time frame
16 that there was a difficult financial market for his
17 practice group?
18 A. In general conversation we would talk
19 about -- I would talk with anybody -- about, you
20 know, transactions had slowed down based upon, you
21 know, the economy.
22 Q. And based upon your interactions and
23 observations of Mr. Dolin, did it appear to you
24 that his practice in 2009 had been affected by the
25 economic downturn?
Based upon your observations and
9 interactions, how did the economic downturn in 2009
10 affect Mr. Dolin?
11 A. I don't know how it affected him
12 personally. Professionally I can say that he tried
13 to keep everybody upbeat about it.
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1 A. I don't remember.
2 Q. When you interacted with Mr. Dolin
3 during the week of July 12, did he -- was he his
4 normal friendly self?
5 A. Yes.
6 Q. Are you aware of any instances where
7 Mr. Dolin reported to somebody else that he didn't
8 believe that he had the abilities or the experience
9 to work at a law firm like Reed Smith?
10 A. Can you rephrase that?
11 Q. Sure. Was there ever an occasion where
12 you learned that Mr. Dolin had reported to somebody
13 else that he didn't feel qualified or didn't feel
14 like he had the expertise to work at a law firm
15 such as like Reed Smith?
16 A. That Stu didn't feel he had the
17 expertise or that Stu felt that the person he was
18 reporting to didn't have the expertise?
19 Q. That Stu felt like he didn't have the
20 experience or expertise to work at a law firm like
21 Reed Smith.
22 A. No.
23 Q. If Mr. Dolin had reported that to
24 somebody else, would that be the Stewart Dolin that
25 you knew of?
OVERRULED
2 Q. When you interacted with Mr. Dolin
3 during the week of July 12, did he -- was he his
4 normal friendly self?
5 A. Yes.
6 Q. Are you aware of any instances where
7 Mr. Dolin reported to somebody else that he didn't
8 believe that he had the abilities or the experience
9 to work at a law firm like Reed Smith?
10 A. Can you rephrase that?
11 Q. Sure. Was there ever an occasion where
12 you learned that Mr. Dolin had reported to somebody
13 else that he didn't feel qualified or didn't feel
14 like he had the expertise to work at a law firm
15 such as like Reed Smith?
16 A. That Stu didn't feel he had the
17 expertise or that Stu felt that the person he was
18 reporting to didn't have the expertise?
19 Q. That Stu felt like he didn't have the
20 experience or expertise to work at a law firm like
21 Reed Smith.
22 A. No.
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1 A. 2011? I'm not sure. I'm not sure.
2 Q. Was it early 2011?
3 A. It could have been. I can't remember,
4 to tell you the truth.
5 Q. And when that one client to your
6 recollection left working with Mr. Dolin because of
7 the rate issue, was that an amicable resolution to
8 your knowledge in terms of --
9 A. As far as I understood it, yes.
10 Q. And to your knowledge was -- did
11 Mr. Dolin ever have to over the course of his
12 career ever deal with -- let me back up.
13 Do you remember what the billings were
14 for that particular client?
15 A. I do not.
16 Q. Was it large, medium, small?
17 A. Probably medium.
18 Q. Do you know how many people worked on
19 Standard Parking matters at Reed Smith before
20 Mr. Dolin's passing?
21 A. I do not know.
22 Q. Was that -- was Standard Parking a major
23 firm for the Chicago office?
24 A. It was a major client for Stu.
25 Q. And do you know of any situation over
22 Q. Was that -- was Standard Parking a major
23 firm for the Chicago office?
24 A. It was a major client for Stu.
25 Q. And do you know of any situation over
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1 Mr. Dolin's career where he faced the possibility
2 that he would lose a major client?
3 A. Not that I can remember.
4 MR. DAVIS: I'm going to look -- I'm going to
5 turn the questioning over to Mr. Wisner. I'm going
6 to look back through my notes to see if I have any
7 follow-up questions, but I really appreciate your
8 patience and time.
9 THE WITNESS: Thank you.
10 MR. DAVIS: Thank you.
11 EXAMINATION
12 BY MR. WISNER:
13 Q. Good morning/early afternoon.
14 A. Hi.
15 Q. My name is Brent Wisner. I represent
16 Wendy Dolin in this litigation. I want to ask you
17 a couple follow-up questions on different topics
18 that were covered this morning.
19 A. Okay.
20 Q. Shouldn't be too long.
21 The first question I want to ask you is:
22 What is your understanding of Mr. Dolin's
23 responsibilities as the practice group leader in
24 2010?
25 A. He was -- I don't know what he was in
SUSTAINED
1 Mr. Dolin's career where he faced the possibility
2 that he would lose a major client?
3 A. Not that I can remember.
20 Q. Shouldn't be too long.
21 The first question I want to ask you is:
22 What is your understanding of Mr. Dolin's
23 responsibilities as the practice group leader in
24 2010?
25 A. He was -- I don't know what he was in
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1 charge of. I don't know what they do exactly. But
2 he was there to make sure the group ran well,
3 produced.
4 Q. Was he viewed as one of the more senior
5 people at the firm?
6 A. Yes.
7 Q. And how was -- what was his reputation
8 amongst the staff or the attorneys, to the best of
9 your knowledge?
10 A. Well liked.
11 Q. Anything else?
12 A. Smart, compassionate.
13 Q. What was his general demeanor while he
14 was at work?
15 A. Business, very business.
16 Q. What do you mean by "business"?
17 A. He wasn't someone to walk around the
18 halls and chitchat.
19 Q. What kind of hours did he work? This is
20 also within 2010, just to be clear.
21 A. I can only tell you about the hours that
22 I worked that he was there. So, he was there
23 before I came in and he was typically there after I
24 left.
25 Q. Did you ever have any busy periods
1 charge of. I don't know what they do exactly. But
2 he was there to make sure the group ran well,
3 produced.
4 Q. Was he viewed as one of the more senior
5 people at the firm?
6 A. Yes.
7 Q. And how was -- what was his reputation
8 amongst the staff or the attorneys, to the best of
9 your knowledge?
10 A. Well liked.
11 Q. Anything else?
12 A. Smart, compassionate.
13 Q. What was his general demeanor while he
14 was at work?
15 A. Business, very business.
16 Q. What do you mean by "business"?
17 A. He wasn't someone to walk around the
18 halls and chitchat.
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1 his children?
2 A. No. Not out of just a generalization.
3 Q. Did Wendy frequently call him at his
4 office?
5 A. She did.
6 Q. About how many times a day do you think
7 she'd call him?
8 A. Once a day.
9 Q. And what about his children, did they
10 frequently call him as well?
11 A. They would call. As they grew older
12 they called less but they would call.
13 Q. Okay. Mr. Dolin like to take vacations?
14 A. Yes.
15 Q. Compared to other partners that you've
16 seen at the firm, did he take less -- more frequent
17 or more infrequent vacations?
18 A. I don't know about other partners at the
19 firms -- or at the firm. But Stu was -- would take
20 vacation at the same time of the year.
21 Q. Were you at all responsible for helping
22 him arrange for his travel for vacations?
23 A. No.
24 Q. Do you remember if he took any vacations
25 in 2010 that you're aware of?
3 Q. Did Wendy frequently call him at his
4 office?
5 A. She did.
6 Q. About how many times a day do you think
7 she'd call him?
8 A. Once a day.
9 Q. And what about his children, did they
10 frequently call him as well?
11 A. They would call. As they grew older
12 they called less but they would call.
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1 A. I think he was planning on taking
2 vacation. I don't believe that he had gone.
3 Q. What makes you think that he was
4 planning on taking a vacation?
5 A. Because he would take vacations toward
6 the end of the year every year.
7 Q. And by the end of the year do you mean
8 the fiscal year or the actual like December time
9 period?
10 A. December time period.
11 Q. Okay. You mentioned that you had a
12 conversation with Mr. Dolin at some point regarding
13 his loss of weight? Do you remember that?
14 A. Um-hmm.
15 Q. And there was two parts to that
16 conversation, the first one and a longer second
17 one, is that correct?
18 A. Yes.
19 Q. He mentioned -- you said earlier that he
20 mentioned he was getting ready for skiing?
21 A. Yes.
22 Q. What do you mean by that?
23 A. He would take -- he would exercise to
24 get his lungs and his legs ready for skiing. So...
25 Q. And when you said he looked like he had
11 Q. Okay. You mentioned that you had a
12 conversation with Mr. Dolin at some point regarding
13 his loss of weight? Do you remember that?
14 A. Um-hmm.
15 Q. And there was two parts to that
16 conversation, the first one and a longer second
17 one, is that correct?
18 A. Yes.
19 Q. He mentioned -- you said earlier that he
20 mentioned he was getting ready for skiing?
21 A. Yes.
22 Q. What do you mean by that?
23 A. He would take -- he would exercise to
24 get his lungs and his legs ready for skiing. So...
25 Q. And when you said he looked like he had
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1 lost weight, did he look malnourished?
2 A. No.
3 Q. Did he look more fit?
4 A. Yes.
5 Q. Okay. So, the loss of weight didn't
6 suggest to you bad health. It suggested of good
7 health?
8 MR. DAVIS: Object to form.
9 BY THE WITNESS:
10 A. It was something I noticed.
11 BY MR. WISNER:
12 Q. I guess what I'm trying to get at is
13 were you concerned that he was not eating or did he
14 look like he was getting more in shape? I'm just
15 trying to get an idea of your viewpoint of it.
16 A. My viewpoint would have been that I was
17 more concerned.
18 Q. But he stated -- did he suggest that the
19 loss of weight was due to stress or because he was
20 actively trying to get in shape?
21 A. He stated his loss of weight was getting
22 in shape and that he had a lot on his mind because
23 of the three matters that he couldn't...
24 Q. Okay. Do you know where he liked to go
25 for lunch?
1 lost weight, did he look malnourished?
2 A. No.
3 Q. Did he look more fit?
4 A. Yes.
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1 A. I don't remember.
2 BY MR. WISNER:
3 Q. Okay. That's fine.
4 Did Mr. Dolin typically attend
5 shareholder or board meetings?
6 A. Yes.
7 Q. Was that a common part of his practice?
8 A. Yes.
9 Q. Was the -- to the best of your
10 knowledge, was the board meeting or shareholder
11 meeting that potentially was scheduled for the day
12 after his passing, did you know anything about that
13 meeting specifically?
14 A. The contents of the meeting? No.
15 Q. Did Mr. Dolin express any concern to you
16 about that meeting?
17 A. Not to my knowledge. I don't remember.
18 Q. Did you overhear Mr. Dolin speaking with
19 anybody about that meeting?
20 A. I don't remember.
21 Q. Okay. When things were busy at the
22 office, throughout the career, not just in 2010,
23 but when things were busy in the office, how did
24 Mr. Dolin generally cope?
25 A. Calmly. When -- I had already
When things were busy at the
22 office, throughout the career, not just in 2010,
23 but when things were busy in the office, how did
24 Mr. Dolin generally cope?
25 A. Calmly. When -- I had already
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1 started -- I had worked for him when he had already
2 made -- he was already partner and so I'm trying to
3 remember specifically.
4 He was always calm to me.
5 Q. Did he ever seem emotionally distraught
6 in front of you?
7 A. No.
8 Q. And to the best of your knowledge how
9 did other attorneys or staff members look upon him?
10 MR. DAVIS: Object to form.
11 BY THE WITNESS:
12 A. I always thought that they looked
13 favorably upon him. That he was a leader.
14 BY MR. WISNER:
15 Q. Do you ever remember hearing any bad or
16 critical comments about Mr. Dolin, in 2010
17 specifically?
18 A. No one would ever tell me bad things
19 about Stu.
20 Q. On the day of his passing you stated
21 that Mr. Dolin said something to the individual who
22 sits next to you. Ms.?
23 A. Gareis.
24 Q. Gareis? I just want to get an
25 understanding.
OVERRULED
1 started -- I had worked for him when he had already
2 made -- he was already partner and so I'm trying to
3 remember specifically.
4 He was always calm to me.
5 Q. Did he ever seem emotionally distraught
6 in front of you?
7 A. No.
8 Q. And to the best of your knowledge how
9 did other attorneys or staff members look upon him?
12 A. I always thought that they looked
13 favorably upon him. That he was a leader.
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1 the train to the person in HR who had called my
2 home in the morning but I had already left for the
3 day.
4 Q. And did -- on the message did they tell
5 you what had happened or they just said to call me
6 back?
7 A. My husband called me on the train and
8 said that the HR person called and he said, "It
9 sounded like she wanted to talk to you urgently."
10 So, I called her back.
11 Q. How did the office -- how did the people
12 seem to feel or react to Mr. Dolin's passing on
13 Friday?
14 MR. DAVIS: Object to form.
15 BY THE WITNESS:
16 A. Shocked. I think that's -- shocked,
17 dismayed.
18 BY MR. WISNER:
19 Q. Were you personally surprised by what
20 had happened?
21 A. Yes.
22 THE WITNESS: Thank you. How did you know?
23 BY MR. WISNER:
24 Q. During the many hours -- the many years
25 that you've worked with Mr. Dolin, had you ever
24 Q. During the many hours -- the many years
25 that you've worked with Mr. Dolin, had you ever
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1 seen him nervously pacing back and forth?
2 A. No.
3 Q. Had you ever seen him be jittery or tap
4 his leg nervously?
5 A. No.
6 Q. Had he ever repeated statements over and
7 over again?
8 A. No.
9 Q. In the years that you worked with him
10 had you ever known Mr. Dolin to have a hard time
11 processing information?
12 A. No.
13 Q. If you were to learn that all of these
14 things manifested in the week prior to his death,
15 would that be something that would have surprised
16 you?
17 MR. DAVIS: Object to the form.
18 MR. BAUGHER: Objection; form.
19 MR. DAVIS: And foundation.
20 BY THE WITNESS:
21 A. In my -- I would find it surprising in
22 my relationship with him, yes.
23 MR. WISNER: Thank you. I have no further
24 questions. Thank you for your time.
25 THE WITNESS: Thank you.
SUSTAINED
1 seen him nervously pacing back and forth?
2 A. No.
3 Q. Had you ever seen him be jittery or tap
4 his leg nervously?
5 A. No.
6 Q. Had he ever repeated statements over and
7 over again?
8 A. No.
9 Q. In the years that you worked with him
10 had you ever known Mr. Dolin to have a hard time
11 processing information?
12 A. No.
13 Q. If you were to learn that all of these
14 things manifested in the week prior to his death,
15 would that be something that would have surprised
16 you?
21 A. In my -- I would find it surprising in
22 my relationship with him, yes.
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