2001-01-26 Harley-Davidson Response - Minnesota Judicial Branch

Q. SO a good
A. Right.
IS ycnrs?
3 Q, Did you graduate from high school?
4 A. No. I did not.
5 Q. How far did you tnakc it in school’!
h A. I went to nay -- I started my senior year and
7 went and got a (il!D.
x Q. When did you get your (i13?
9 A. A couple of years later. I’m not sure of the
o date.
I Q. Any formal education beyond your ND?
2 A. No.
Condo
Page 5
3 Q. Have you ever served in the military?
4 A. No.
5 Q. Do you have a criminal record of any type?
6 A. None other than driving.
7 Q. What type of driving offenses have you had ?
8 A. Alcohol-related DWI.
9 Q. How many DWIs have you had?
0 A. Three.
I Q. What years were those in?
i2 A. I’d be guessing ‘78, ‘83, and ‘9 1.
:3
I4
5
Q. Do you remember what counties those were in?
A. Hennepin and Dakota.
0. Consecutivelv?
Page C
i A. Right.
2 Q. Have you ever gone through any chemical
3 dependency treatment?
4 A. No..
5 Q. Or alcohol abuse treatment programs?
6 A. N&
7 Q. Are you ‘presently employed?
8 A. No. I wasjust Iaidoff.
9 Q. Who did you work for?
0 A. PaceCQnueteconstructiion.
11 MR. fSwCSQN: Excuse me, 1 didn’t hear
‘2 thai Wl&hatPace? ., _.. ,
I3 t THE WITNESS: ct’aa c0peret.e
.
14 constructHla
IS BY MR. LAF’EBER:
J
, : I! ,L? ,. .
16 Q. vt’hewmtheylooated?.
17 A. Inwzr Grove Heights. I
18 Q. What did you & for them?
19 A. cement finisher.
to Q. How iong did you work for them?
II A. Tht’e0,yetu-s.
u Q. Was this, a f$ll-t&e position?
u A. Yes.
14 Q. was it seasonal?
ls A. Yes.
‘age S,‘- Page 8
sdt Ihi James D. Kinnky
I q. What did you do in rhc ofl-sc;cason during those
2 three years’?
3 A. Lxt .~ason I coultln’~ I’ind work. hut I hook4
Page 7
4 up with other cornpanics and (r~tvclcd. work4 in Floritlu one
5 year, work4 in Kansas City it littlc hit. They send mc: oul
h on JilTcrcnr rclck jobs, arlil’icial rcxk work.
7 Q. I neglec~ccl to ask you, xc you Inarriccl’!
x A. No.
9 Q. I-law you ever be431 married?
0 A. No.
I Q. Do you have any kids?
2 A. No.
3 Q. And where did you work prior to Paw: Cancrett:
4 Construction?
5 A. Custoln Rock International in St. Paul.
6 Q. And how long did you work for Custoln Rock
7 International?
18 A. I believe that was nine-&.
I9
!O
Q. What did you do for them?
A. Iwasacementmason. I
!I ,Q. Was that a full-time position?
!2 A. Yes, it was.
!3 Q. Was that seasonal?
!4 A. Yes and no. Some seasons, yes. Otlwr seasons
15 they would send me. on the road.
1 Q. Tell me, how long is the cement season that
Page 8
2 you can do cement work?
3 A. It varies. ‘Ihe last couple of winters have
4 been warm, so it goes eight, nine months. If it’s real
5 cold,itcanbeassbortasxvenmontbs.
6 Q. You indicated you worked for Pace Concrete
7 Construction for roughly three years?
8 A. Comxt. IsbeuldmentienIbadmyown
9 businessinbetweentbosetwo.
IO Q. Whatpaiodoftimedidyoubaveyourown
II business?
12 A. FortwoyearspriortoPaee. .I
13 Q. Wbatwastbenameofyourbusiness?
14 A. FirstImpmssionsComxete. -
15 Q. Did FirstImp+si&ns tbesame
16 t.ypeoftbiqsasPaeeCanc&e?
17 A. Yes.
T
18 Q. AndCustomRock?
19 A. No, not Custom Rock.
20 Q. WbattypeofworkdidCustomRo&do?
21 A. TbeydidartiCcialro&worlcsuebasan
22 example would be Camp Snoopy at the Mall of America.
23 Q. You idbated while you wm at Pace Concrete
24 Constructionthxwemsomeseasons$atyougotworkin
25 otberpartsoftllecoun~solneoff-sea%ms andsome.
Kirby A. Kemedy st~ktzsda~~(~~2) 922-195