Case Stipulation: Deposition Index: Glen S. Hess, Defendant

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Deposition Index: Glen S. Hess, Defendant Stipulation: Deposition of Glen Hess was taken before Cindy Fields at this time and place. All irregularities regarding time and place and manner of taking deposition are waived and can only be objected to during trial. Reading and signing of the deposition is waived. Mr. Hess was sworn in before testifying. Pages 2-5 Mr. Gig Wyatt will be appearing on behalf of Mr. Burt, representing Antonia Garcia. Glen Steven Hess DOB: 11/03/1963, SSN: 105-48-1130. Place of residence/ incident: 3190 Willamette Drive North. No criminal convictions Mechanic at Japanese Connection since 1989 Family: Wife, Jodi Hess (present during Deposition) and 6 month old child…show more content…
Garcia’s asthma. She wears a paper throw away mask to help with the prevention of breathing in fumes, which seems to work. Cigarette smoke also aggravates the asthma. Mrs. Garcia started seeing a psychiatrist for depression related to her marital problems this last year. She is 25% Blackfeet Indian from her mother’s side, which entitles her to Indian benefits. Mrs. Garcia is bothered by the fact that she has $4,000 in medical bills that she cannot pay. The doctors told her to get into contact with the Credit Consumer Bureau, but she never got around to it. She has been paying $50 out of the $370 that she receives for pay every two weeks for five months. Most of her reason for depression is marital problems and are not related to this incident. Mrs. Garcia is trying to get off of the depression medication because of its side effects, including dry mouth. She uses inhalers when she has an asthma attack; she uses it about 10 times a day. She used her inhaler during a break from the depositions. The inhalers are used when she starts to feel tightening in her breathing, and they lessen the tightening making it easier for her to breathe. The medicine is named Albuterol. Her doctor told her that being in contact with the fumes made her asthma act up. Normally Mrs. Garcia would try to avoid things that would make her asthma act up. Her asthma acts up with dust, cut grass, but unsure about mold or pollen. She had painted over ten years ago, but did not have…show more content…
The kids were watching cartoons while she was folding blankets in her bedroom. She doesn’t remember Carlos being there in the morning, but he was there in the afternoon. Mrs. Garcia was aware that there were more repairs that needed to be made on the house, but was only aware of the roof. She spoke with the defendants at about 5:00 pm, but never asked if Carlos had talked to them before then, nor did he tell her that he had talked with them. She first spoke with Jodi Hess and there was no hostility, it was a friendly conversation. Mrs. Garcia had laid down for a nap at around 4:00 pm and woke up at 5:00 pm, then left her room to go talk to Mrs. Hess. She opened her front door and asked Jodi what the smell was. The smell was in the bedroom and hallway, not so much in the living room. She does not recall if she had any windows open that day. Mrs. Garcia said that the smell was similar to Raid bug spray. Using Raid in the past had not given her any trouble breathing. When she spoke to Jodi, there was something like a brush in Jodi’s hand. She asked what they were doing and told them to come in and smell the house. Mrs. Garcia told the Hesses that she had asthma and that they needed to stop spraying whatever it was that they were spraying. Carlos had been awake while Mrs. Garcia was napping and the kids were in the house. No one had complained about smelling anything

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