Industry-Provided Depositions
Deposition of Lois Hicks. 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, Vs R.J. Reynolds Industries Inc., Et Al.
Fields
- Named Person
- B&W
- Ti
- Rjr Nabisco
- Campbell, R.R.
- Colville, S.
- Coleman, N.R. Jr
- Moseley, R.H.
- Davidson, M.S.
- Ciraldo, J.A.
- Carruth, M.W.
- Rogers, P.
- Rogers, G.
- Hicks, C.H.
- Riggs, M.R.
- Riggs, J.
- F Bob
- F Mary
- F Charles
- Williams, O.
- Williams, E.
- Boruff, S.J.
- Boruff, B.
- Lafollette Community Hospital
- Woods
- Crutchfield
- Baptist Hospital
- Sargent, L.J.
- Mcfarland
- Gibson, C.
- Gibson, B.W.
- Williams, B.A.
- F Larry
- Gibson, I.
- Gibson, G.
- Burrell, J.
- F Betty
- F Linda Sue
- Jellico Hospital
- Terwilliger, R.
- Acuff
- Woods, B.
- Shouse
- Bradsher
- Hart
- Dorsey
- Davis, M.L.
- F Maria
- Gibson
- Lee, J.D.
- Dalton Townsend
- Beder, E.J. Jr
- Hicks, L.
- F Jess
- Army
- Mars
- F George
- F Wynn
- Sparks, E.G.
- Type
- DEPOSITION
- Site
- Law
- Record Center
- Box
- Rjr1175
- Request
- 1rfp2
- 1rfp41
- 1rfp5
- 1rfp37
- 1rfp45
- 1rfp46
- 1rfp73
- 1rfp74
- 1rfp88
- 1rfp92
- 1rfp9
- 3
- 4rfp6
- Minnesota
- 1rfp71
- Texas
- Initial
- Disclosure
- Castano
- 1rfp1
- Burton
- 2rfp16
- Rogers
- Author
- Gibson Sherrod Carruth
- Natl Shorthand Reporters Assn
- Coleman, N.R. Jr
- Moseley, R.H.
- Hicks, L.
- Rogers, P.
- Carruth, M.W.
- Campbell, R.R.
- B&W
- Rjr Nabisco
- Date Loaded
- 27 Feb 1998
- Brand
- Camel
- Winston
- Vantage
- Kool
Document Images
' DEPOSITION OF LOIS HICKS
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,
vs.
R. J. REYNOLDS INDUSTRIES,
INC., ET AL,
II
APPEARANCES:
~_~
A'/ SSO ~~tS
Plaj.ntiff,
Defendants.
. Civil Action
No. 3-84-309
FOR THE PLAINTIFF:
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
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Hicks
(Appearances continued)
FOR THE DEFENDANT
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
P. 0. Box 1060
Greeneville, Tennessee 37744
Edward J. Beder, Jr.
Attorney at Law
P. 0. Box 7566
Washington, D.C. 20044
FOR THE DEFENDANT R. J.
REYNOLDS INDUSTRIES, INC.:
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
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v -
GIBSON - SHERROD CARRUTH COURT REPORTING
COURT REPORTING AND VIDEO SERViCES602 GAY STREET. SUITE 1005
r<NOxVILLE. TENNESSEE 37902
Hicks
(Appearances continued)
John A. Ciraldo
Attorney at Law
1270 Sixth Avenue
New York, New York 10020
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GIBSbN - SHERROD - CARRUTH COURT REPORTING
COURT REPORTING AND VIDEO SERVICES
602 GAY STREET. SUITE 1005
KNOxVILLE. TENNESSEE 37902
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Hicks 4
I N D E X
Page No.
Examination,
by Mr. Campbell----------------------- 6
.
GIBSON - SHERROD - CARRUTH COURT REPORTING
COURT REPORTING AND VIDEO SERVICES
602 GAY STREET. SUITE 1005
KNOXVILLE. TENNESSEE 37902
Hicks
The deposition of LOIS HICKS, called as a
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ti
cedure, taken by agreement on the 14th day of September,
1984, at the Sequoyah Room, Downtown Hilton, Knoxville,
Tennessee, before Melton W. Carruth, Registered Profes-
witness at the instance of the defendants, for use in
evidence, pursuant to the Federal Rules of Civil Pro-
sional Reporter and Notary Public, pursuant to the.:,,
stipulation of counse 1.
S T g P U L i. T I 0 N
It being agreed tha: Melton W. Carruth,
Registered Professional Reporer and Notary Public,
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may swear the witness, report her deposition in ma=,
chine shorthand, afterva;°ds r, 3ucing the same to type-
writ ing.
All objectior..s ::cE t as to the form of the
questions are reserved ~-n » before the hearing.
It being furt r a: : eed that all formalities
as to notice, caption, _ i;ate, transmission,
etc., including the rez the completed deposi-
tion by the witness anc.- ;nature of the witness,
are expressly waived.
MR.
:F ':,L: For the record, and
before we be[ t defendant Brown and
Williamson, C . :. :)ne at the time of Mr.
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GIBSbN - SHEF 4 -I COURT REPORTING
COUR'~, DEO SERVICES _
. srtE 1005
~ ' SEE 37902
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.
Hicks 6
Paul Rogers' deposition, would object to any
use of the video recording of the deposition
and would point out that by agreeing or allow-
ing it to be done, we are making no waiver
of any objections to the admissibility of the
video deposition at any future proceeding.
I assume other defendants join in
that objection.
MR. MOSELEY: On behalf of Reynolds,
we join in that position.
MR. COLEMAN: We ,join in the same
position on behalf of The Tobacco Industry.
LOIS HICKS,
called as a witness at the instance of the defendants,
for use in evidence, having been first duly sworn, was
examined and deposed as follows:
EXAMINATION
BY MR. CAMPBELL:
q, Would you state your name, please?
A. Lois Hicks.
g Mrs. Hicks, my name is Bob Campbell,
and I represent Brown and Williamson Tobacco Corporation.
You know the general reason that you're here. Specifi-
cally you'll be asked a lot of questions as they relate
GIBeON - SHERROD - CARRUTH COURT REPORTING
COURT REPORTING AND VIDEO SERVICES
602 GAr STREET. SUITE +005
KNO%viLLE. TENNESSEE 37902
Hicks
to your sister, Georgia Rogers, and your family. If at
any time you don't understand my question, ask me to
repeat it. If at any time you want a recess, you're
tired of hearing me talk, just say that you'd like a
recess because this will take a little time and we'll
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e patient with you if you'll be patient with me.
A. Okay.
Q Where do you-live, Mrs. Hicks?
A. LaFollette.
Q And what's your address there in
LaFollette?
A. Rout e 2.
MR. COLEMAN: I'm sorry. You've
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broken your first promise already. You're
supposed to speak up and I can't hear you.
THE WITNESS: Route 2.
MR. CAMPBELL: Pretend that you're
speaking to the lawyers at the end of the table
there, and I think everybody can hear.
MR. COLEMAN: Route 2, LaFollette?
THE WITNESS: Uh-huh.
MR. COLEMAN: It will sound loud to
you, but don't worry about it.
THE WITNESS: Okay.
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GIBSUN - SHERROD - CARRUTH COURT REPORTING
COURT REPORTING AND VIDEO SERVICES
602 GAY STREET. SUITE 1005
KNOxVILIE. TENNESSEE 37902
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Hicks
BY MR. CAMPBELL:
g What road do you live on?
A Long Hollow Road.
4 As I understand, Mrs. Hicks, Long
Hollow Road is in a rural area about two or three miles
from LaFollette, is that right?
A.
on?
Yes, that's right.
And what side of LaFollette is it
MR. ROGERS: It's on the east side,
if I can help her on some of them she might
not understand.
MR. CAMPBELL: Well, I guess we bette
let her answer, Mr. Rogers.
MR. ROGERS: Okay.
BY MR. CAMPBELL:
4 Now, Mrs. Hicks, are you married?
A. No. I'm a widow.
4 And what was your husband's name?
A. Clarence Homer Hicks.
4 Clarence Homer Hicks?
A. Uh-huh.
8 And how long has he been deceased?
A. Since '71.
GIBS6N - SHERROO - CARRUTH COURT REPORTING
COURT REPORTING AND VIDEO SERVICES.
602 GAY STREET. SUITE 1005 KNOZVIILE. TENNESSEE 37902
Hicks
g Do you have any children?
A One.
a And what's -- is it a boy or a girl?
A. Boy.
,
(~ And what's his name and age?
A. Michael Ray Riggs. I've been married
twice, and he's 27 year old.
g All right. And he's 27 and his name
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is?
A. Michael Ray.
4 Michael Ray Riggs?
A. Uh-huh.
4 And Michael Ray was born to the
marriage of you and a Mr. Riggs?
A. Yeah.
4 What was Mr. Riggs' first name?
A. Jess.
A-
A.
Q,
Jess?
Uh-huh.
Did.that marriage end in divorce?
Yes.
All right. Over what period of time,
Mrs. Hicks, were you and Mr. Riggs married; when were
you married and when were you divorced?
~ GIBSbN - SHERROD - CARRUTH COURT REPORTING
COURT REPORTING AND VIDEO SERVICES
_ . 602 GAY STREET. SUITE 1005 '
rcNOZViLLE. TENNESSEE 37902
Hicks
Well, approximately about 10 year.
Q What years were those?
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A. I think we divorced in about '55.
4 Which means you would have been
married about 1945, is that right?
A. Yeah.
~ Is Mr. Riggs still living?
A. Uh-huh.
Q; Where does he live?
A. He lives out in the same place we do.
Q You mean on Long Hollow Road?
A. Yeah, on Long Hollow Road.
Q, How far from where you live?
A. Just right across the road.
Q Do you go by Lois, or do you have any
nicknames?
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A. Just plain Lois.
Q Just plain Lois?
A. Don't have no middle name.
Q Your maiden name, of course, was
Gibson, I believe?
A. Yeah.
4 Did you have a-- before you were
married, when you were Lois Gibson, did you have a middle
GIBS'bN - SHERROD - CARRUTH COURT REPORTING
COURT REPORTING AND VIDEO SERVICES
602-GAr STREET. SUiTE 1005
KNOXVILLE. TENNESSEE 37902
