Q.   Good morning, Ms. Howell. 
                            A.   Good morning. 
                            Q.   My name is Paul Kramer and I represent the 
                    defendant in this case.  I'm going to ask you some 
                    questions today.  If at any point you don't understand 
                    what I ask, please ask me to clarify the question. 
                                 Also, the court reporter is going to take 
                    down my questions and your answers.  The court reporter 
                    can't take down nods or shrugs, so if the answer is yes, 
                    instead of nodding, if you can say "yes" or if the answer 
                    is "no," instead of shaking your head no, just say "no."  
                    Do you understand? 
                            A.   Yes. 
                            Q.   Ms. Howell, what is your present address? 
                            A.   232 Burnside Avenue, Portland, Oregon. 
                            Q.   And how long have you lived there? 
                            A.   60 years. 
                            Q.   And what's your current date of birth? 
                            A.   March 14, 1936. 
                            Q.   Are you presently married? 
                            A.   Yes. 
                            Q.   Do you have any children? 
                            A.   One. 
                            Q.   Who lives with you at your house? 
                            A.   My husband, my daughter, my son-in-law, my 
                    two grandchildren. 
                            Q.   Have you taken any medication within the last 
                    48 hours? 
                            A.   No. 
                            Q.   Have you consumed any alcohol in the last 24 
                    hours? 
                            A.   No. 
                            Q.   Is there anything that you're aware of that 
                    would affect your memory and your ability to answer 
                    questions today truthfully? 
                            A.   No. 
                            Q.   Other than speaking with your attorney, did 
                    you speak with anyone in preparation for today's 
                    deposition? 
                            A.   No. 


Q. Did you review any records in preparation for today's deposition? A. No. Q. Can you briefly give your educational background? A. Graduated from high school. A couple of courses at college, just minor courses. Q. Other than this lawsuit, have you ever brought any other lawsuits against anyone before? A. Yes. Q. When was that? A. Quite a few years ago. Q. What was the basis of that lawsuit? A. I had an accident, and had a lawsuit against a car company. I can't remember the name right now. Q. Are those two different lawsuits or just one lawsuit? A. Different ones. Q. The one with the accident, was that a car accident? A. Yes. Q. Did that take place more than ten years ago? A. About that time. Q. Were you deposed in that case? A. It was settled. Q. Did you give a deposition before it was settled? A. I don't believe so. Q. Do you have any long standing injuries as a result of that accident? A. Somewhat. Q. And what are they? A. My back. Q. And the other lawsuit, that was against a car? A. Yes. Q. What was the basis of that lawsuit? A. They didn't want to rent me the car. Q. And when did that lawsuit take place? A. About ten years ago. Q. Okay, and why didn't they want to rent you the car? A. I don't know. I had reservations for a Lincoln Town Car, and they refused to rent it to me.
Q. And what was the basis of that lawsuit? A. That I had a reservation and they refused to rent to me, to honor their contract. Q. And did that case settle? A. Yes. Q. Was that brought in Small Claims Court? A. No. Q. Do you know what court it was brought in? A. Federal Court, I believe. Q. It was brought in Federal Court? A. Yes. Q. Did you have an attorney in that case? A. Yes. Q. What was your attorney's name? A. Seymour. Q. Is Seymour the last name or the first name? A. Last name. Q. And how much did you get as part of that settlement? A. I'm not supposed to disclose that. Q. Do you remember the name of the case? A. No. Q. As a result of the back injury that you suffered in the earlier lawsuit, are you still receiving medical care from that? A. No. Q. When was the last time you received medical care regarding that back injury? A. Not from that one. That was a long time ago. I had another case since then. Q. You had another case since then? A. Yes. Q. What was that case about? A. When I tripped and fell in 1992. Q. And where did you trip and fall? A. On Dawson Street in Portland. Q. And did you bring a lawsuit based on that? A. Yes. Q. And did that case settle? A. No. Q. What happened to that case? A. It's still on.
Q. And who is representing you in that case? A. Rothman & Rothman. Q. Did you give a deposition in that case? A. Yes. Q. Do you remember when you gave a deposition? A. No. Q. And what were your injuries as a result of that trip and fall? A. I hurt my neck, my head, shoulders, back, and my legs. Q. And are you still seeking treatment from those injuries? A. Once in a while. Q. Do those injuries have any long-standing effect on you? A. Yes. Q. Do you currently feel pain? A. Yes. Sometimes. Q. And where do you feel pain? A. Sometimes in my shoulders, my back, and my neck. Q. So right now we have three lawsuits. We have the personal injury lawsuit, the car rental lawsuit and the trip and fall lawsuit. Have you ever been involved in any other lawsuits? A. Yes. Q. Okay, what other? A. In Publix, I slipped on a soap substance they had there. Q. And when did you bring that lawsuit? A. That was around '94. Q. And who represented you in that case? A. I can't think of his name right now. Q. Where was that case brought? A. In Eugene. Q. In Federal Court? A. County Court. Q. In the State of Oregon? A. Yes. Q. Did you get a settlement in that case? A. Yes. Q. How much did you get? A. 50,000. Q. What were the injuries you suffered as a result of that trip and fall? A. I fell. I hurt my knee, my back, my head.
Q. So the earlier case in which you were represented by Rothman & Rothman is still going on, so there's been no settlement? A. Right. Q. The personal injury case, was there a settlement in that case? A. The auto accident? Yes. Q. And how much did you get in that case? A. About $10,000. Q. Were you deposed in the Publix case? A. I believe so, yes. Q. Did you walk with a cane or any other device? A. No. Q. When were you hired by the Post Office? A. December, 1965. Q. So you were around thirty years old at the is that right? A. 29. Q. Did you have any employment before you were hired by the Post Office? A. Yes. Q. And where did you work before that? A. I used to work like in like factories. Q. What position were you hired for in 1965? A. Clerk. Q. And what were your responsibilities as clerk? A. Well, I worked there nights, so when I first was hired, I boxed mail. Q. In which Post Office did you work in at that time? A. Right down here on Grayson Street. Q. How long did you stay in the Grayson Street Post Office? A. About nine years. Nine or ten years. Q. Until around 1975, give or take? A. Yes, give or take, yes. Q. And where did you get assigned at that time? A. Where was I assigned? Q. Did you get transferred from the Grayson Street Post Office?