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'f Z 4_e THE DISCOVERY DEPOSITION OF CHARLES GIBSON September 14,1984 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TENNESSEE NORTHERN DIVISION PAUL ROGERS, INDIVIDUALLY AND AS NEXT OF KIN OF GEORGIA ROGERS, DECEASED, Plaintiff, vs. R. J. REYNOLDS INDUSTRIES,. INC., ET AL, Defendants. APPEARANCES: FOR THE PLAINTIFF: : CIVIL ACTION NUMBER . 3-84-309 J. D. Lee Attorney at Law 14th Floor Andrew Johnson Plaza Knoxville, Tennessee GIBSON - SHERROD - CARRUTH 602 GAY STREET, SUITE 1005 KNOXVILLE. TENNESSEE 37902 (615) 546-7477 1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Gibson APPEARANCES: FOR THE DEFENDANTS BROWN AND WILLIAMSON: Robert R. Campbell Dalton Townsend Attorneys at Law 407 Main Avenue Knoxville, Tennessee Sam Colville Attorney at Law 1101 Walnut 20th Floor Kansas City, Missouri 64106 FOR THE DEFENDANT THE TOBACCO INSTITUTE: N. R. Coleman, Jr. Attorney at Law Post Office Box 1060 Greeneville, Tennessee 37744 Edward J. Beder, Jr. Att t L orney a Post Office aw Box 7566 Washington, D. C. 20044 FOR THE DEFENDANT R. J. REYNOLDS INDUSTRIES: Ray H. Moseley Attorney at Law Suite 201, Johnson Building Second and Walnut Streets Chattanooga, Tennessee 37403 Michael S. Davidson Attorney at Law 1270 Avenue of the Americas Rockefeller Center New York, New York 10020 2 1 I GIBSON - SHERROD - CARRUTH COURT REPORTING COURT REPORTING AND VIDEO SERVICES 602 GAY STREET. SUITE 1005 KNOXVILLE.TENNE55EE379O2

c 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . Gibson APPEARANCES: John A. Ciraldo Attorney at Law 1270 Sixth Avenue New York, New York 10020 0 - GIBSON-SHERROD-CArR TF+ CCLG' :'E7 P`.?' .~s COVRT REpQw-.•~,_ :--c _- -- ' _ . 602 G- KNOY" ._~ _•-_~___ ._-~ . 3

t• 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Gibson I N D E X 4 Page Number by Mr. Campbell ------------------ 6 GIBSON - SHERROD - CARRUTH COURT REPORTING COURT REPORTING AND VIDEO SERVICES 602 GAY STREET. SUITE 1005 KNOXV/l{.E. TENNESSEE 37902

t 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 Gibson 5 The discovery deposition of CHARLES GIBSON, 1) S ~+ ~ .~.. T S : g; _c--cklled at the instance of the defendants, for purposes of'discovery, pursuant to the Federal Rules of Civil Procedure, taken by agreement on the 14th day of September, 1984, at the Sequoyah Room of the Downtown Hilton, Knoxville, Tennessee, before Melton W. Carruth, Registered Professional Reporter and Notary Public, pursuant to the stipulation of counsel. S T I P U L A T I O N It being agreed that Melton W. Carrntb~ r,.> orter and Notary Publi~-t ; i nal Re fes d P t i p ro s o ere Reg s swear the witness, report his deposition in machine shorthand, afterwards reducing the same to typewriting. All objections except as to the form of the questions are reserved to on or before the hearing. It being further agreed that all formali- ties as to notice, caption, certificate, transmission., etc., including the reading of the completed deposition .::. . by:'th~r1;witness and the signature of the witness, are ~ .,:- ~~.: . . . . express,ly waived. CHARLES GIBSON, a witness called at the instance of the defendants, for purposes of discovery, having been first duly examined and deposed as follows: GIBSON - SHERROD - CARRUTH COURT REPORTING COURT REPORTING AND VIDEO SERVICES 602 GAY STREET. SUITE 1005 KNOXVILLE. TENNESSEE 37902 sworn, was,

S . c ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I Gibson BY _M*t--CAMPBELL: A. 4. EXAMINATION State your name, please, sir. Charles Gibson. Mr. Gibson, as you know, my name is Bob Campbell and I'm one of the lawyers that is in- volved in this lawsuit which has been filed by Paul Rogers and we have brought you here to ask you some questions that will relate to your family, your sister, Georgia, and things that might be relevant to this.,,,{+.~t ~ lawsuit. A. down.) (Witness moves head up and- t-~nr,ri I;nraiat yLU t_ r_lax= -We-Ire going to ask you questions and if you don't know the answer, just say you don't know. If you don't under- stand the question, tell me you don't understand the question, and if at any time you want to take a little break; -'just say so. .... • . YtG "` . . .. A. 4. A. 2. All right. Okay. Yeah. What is your age, Mr. Gibson? A. 52. co a a- G1BSdN - SHERROD - CARRUTH COURT REPORTING COURT REPORTING AND VIDEO SERVICES 602 GAY STREET. SUITE 1005 KNOXVILLE. TENNESSEE 37902

1 , 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Gibson Q. A. I was born in LaFollette, Campbell County. Q. When you were born, Mr. Gibson, I know you can't remember the day when you were born, but from what you have learned since, where were your folks living in Campbell County? A. Well, as long as I can rem~mb~~~; .r, we've lived at Long Hollow in Campbell County. Q. - A. that we've gotten that indicates that when Georgia was born, the family was living in a mining camp somewhere, but during your entire life, the family lived in Long Hollow, is that pight? A. me ask you, Q. September 29th, 1931. 7 And where were you born? Okay. There's some information Yeah. And where do you live now? I live in Long Hollow. Do you live -- well, first, let are you married? A. Yes. Q. Do you have any children, Mr. GIBSON - SHERROD - CARRUTH COURT REPORTING COURT REPORTING AND VIDEO SERVICES 602 GAY STREET. SUITE 1005 KNOXVILLE. TENNE55EE 3790Z 1

` 1 II Gibson 8 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Gibson? 4 4~ A. • Q Three. Are any of those children still living with you or are they grown and gone? A. They're grown and all married. Q. Okay. And what's your wife's name? A. Lois. Lois Gibson. Q. Lois? A. down.) Q. A. Q. A. S2 . Lois married? . A. I don't remember. We've been .. ;, . - _,.,. marri.e•d~ 3j"'year. Q. (Witness moves head up and-, .~. What was her maiden name? Stanford. Stanford. Stanford or Stannifer? Stanford, S-t-a-n-f-o-r-d. Okay. And when were you and Okay. So, at the present time, it's just you and Lois where you all live, is that right? A. Yeah. 4. You don't live with any other G19SON - SHERROD - CARRUTH COURT REPORTING COURT REPORTING AND VIDEO SERVICES . 602 GAY STREET. SUITE 1005 KNOXVILLE. T€NNESSEE 37902

, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . S Gibson family? No. 7 Where do you live, you 9 and Lois, relative to where Paul and Georgia Rogers live? A, It's across the street. Q, How long have you lived in the house just across the street from Paul? A. I've not lived there long. Q. that. A. 4. did you live in another house on Long Hollow Road? A. Well, no. It wasn't on Long Hollow Road. it was on High Knob Road. Q- A. S2 . About how long? High Knob Road? Yeah. Where is High Knob Road; where ou lived on High Knob relative to where A. A. Q. it' s about f ive mile. Which direction? I don't know. Well, in order to get to High GIHS6N - SHERROD - CARRUTH COURT REPORTING COURT REPORTING AND VIDEO SERVICES 602 GAY STREET. SUITE 1005 uNOxVILLE. TENNESSEE 37902 .

' 1 11 Gibson 10 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 LaFollette and then turn lefthanded and go about three mile. Q. Is that back down toward Jacks- boro? A. No. You turn left right there at the First National Bank, you turn left, go out on the lake back in there. Q. Oh, on the lake? A. Yeah. Q. I see. How long did you live on High Knob Road? A. Five year. Q. Before then, where did you live? A. I lived in Long Hollow. Q. Okay. And did you live -- have you l'ived:any`other places in Campbell County other . . _ - y: .r . .. . . . than LoAg Hollow Road and High Knob Road? A. That's all. I lived in Long Hollow about all my life. I lived about five year out there on High Knob. Q. How did you happen to move to GIBSON '- SHERROD - CARRUTH COURT REPORTING COURT REPORTING AND VIDEO SERVICES 602 GAY STREET. SUITE 1005 KNOxViLLE_ TENNESSEE 37902