Laura L. Krueger - Baum Hedlund...Case: 1:12-cv-06403 Document #: 555-12 Filed: 04/14/17 Page 1 of 51 PageID #:40946 Confidential - Subject to Protective Order Golkow Technologies,

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

Case: 1:12-cv-06403 Document #: 555-12 Filed: 04/14/17 Page 1 of 51 PageID #:40946

Confidential - Subject to Protective Order

Golkow Technologies, Inc. Page 1

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.




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.)




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.




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?


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?


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.




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.




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?


25 Q. Any of the e-mail communication that you




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.




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


3 A. I was legal secretary to three

4 individuals.




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




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




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




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


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


21 A. He never talked to me about it.




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





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




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.


SUSTAINED as to 35:11-19; OVERRULED as to 35:23-37:10




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

SUSTAINED as to 35:11-19; OVERRULED as to 35:23-37:10




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




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




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.




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.




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...




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




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





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




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.




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




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?




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.




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.




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




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?


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?





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





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.




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?


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?


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?




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?


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?


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.




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.





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?


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?


24 Q. So, he was traveling more when he was

25 solely the practice group leader?





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.




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.




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.




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




1 Mr. Dolin's career where he faced the possibility

2 that he would lose a major client?


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?


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




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.





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.




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




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.





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?


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




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?


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.




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?


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




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.


Documents

Laura L. Krueger - Baum Hedlund...Case: 1:12-cv-06403 Document #: 555-12 Filed: 04/14/17 Page 1 of 51 PageID #:40946 Confidential - Subject to Protective Order Golkow Technologies,