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Richafd Fredericl CoBdenif.itPage 65BY MR. GREENE;Q. Then just write â– Wood."Are you indicating where the property is or where the house is?A. 1 are indicating where the property is.(Marking.)Q. Why don't you put under "Wood." the word <br />"property"? <br />A. (Marking.) <br />Q. Now, let's return a moment to the maintenance <br />shed. Are there machines in operation at the maintenance <br />shed from time to time? <br />A. Yes. <br />Q. What kind of machinery is housed in the <br />maintenance shed? <br />A. All of our mowers and most of our tractors. <br />Q. Are the mowers and tractors serviced at the <br />maintenance shed? <br />A. Yes, they are. <br />Q. So. the mowtrs and the tractors are brought to <br />the maintenance shed over the roadways within the club's <br />property? <br />A. That's correct. <br />Q. Can you describe in any greater detail the type <br />2S of servicing you do to this equipment at the maintenance <br />Page 67in any discussiom at the club or elsewhere during which the subject of opening access from Woodhill Avenue to the club was discussed?MR. MCCARTHY: YOU mean not for tractors going back and forth, l.ut on a regular basis for cars and trucks? Is that what you mean?MR. GREENE: Right. <br />BY MR. GREENE: <br />Q. Other than the two occasions in '90 and '97 <br />when you took the chains down so tractors could get <br />serviced, were there any other occasions where you had <br />HisruMBd removing the bamers anu making access from <br />Woodhill Avenue permissible? <br />A. I had limited discussion with Mark Albrecht <br />previously to that, but it was more in passing. Be it <br />lunchtime, we would have discussions discussing the <br />condition of the golf course, and I ioiow the issue had <br />come up, but nothing in the ofTicial capacity. <br />Q. From your standpoint, as the greens <br />superintendent of the golf course, was it your preference <br />to sec that barrier stay in place to prevent vandalism <br />to the golf course? <br />A. I didn't have a preference one way or the <br />other. <br />Q. From 1989 until May 5. 1998, did the club <br />Page 66 <br />shed? <br />A. They are gassed up, refueled, oil changes, <br />movrers are adjusted. Any type of maintenance work, repairs <br />(lone on them arc done there. <br />MR. MCCARTHY: I have given you wide range <br />of discovery in this case, but how lawn mowers are serviced <br />in the maintenance shed do not appear relevant to the issues <br />in the lawsuit. <br />BY MR. GREENE <br />Q. Do you service golf carts there, aiso? <br />A. No, we don't <br />Q. What other types of services are performed at <br />the maintenance shed in addition to servicing the vehicles <br />that you described? <br />A. We do our staff training there, orienution. <br />It is where our lunches are. All of our personnel services <br />are done there. <br />Q. Do you know what was at the maintenance shed <br />previously? <br />A. In the new oik ? <br />Q. Yes, the new maintenance shed, what was there <br />before it was built? <br />A. It is my understanding that there was a house <br />in the area. Beyond that, I don't. <br />Q. Prior to May 4, 1998. had you ever participated <br />Kii'by A. Kennedy and Associates (612) 922-1955 <br />Page 68 <br />perform any maintenance in the vicinity of the gravel <br />roadway to the west of the chain barrier all of the way <br />to the pavement of Woodhill Avenue? <br />A. We performed some tree trimming along <br />the edges, along the road coming up from the asphalt <br />pcnodically, so you could entet and access that on bike; <br />otherwise, no. <br />Q. So. let me sec if 1 understand Other than <br />tree trimming to facilitate bike access, the club did no <br />maintenance on the gravel roadway in the area that you have <br />shaded in in pink on deposition Exhibit 88? <br />A. That is correct. <br />Q. During this period of time, did vegetation, <br />underbrush, saplings, trees, whatever, grow within U k area <br />that had formerly been a gravel roadway? <br />MR. MCCARTHY: I object 8s Compound. You <br />have about 12 questions there. <br />MR. GREENE: I will let him describe it. <br />1 am trying to give him the universe of what I am looking <br />for here. <br />A. Your question is? <br />BY .MR GREENE: <br />Q. Can you describe what had grown up in the <br />vicinity of this pink shaded area on Exhibit 88, what type <br />of vegetation during the period from 1989 to May of 1998, <br />Page 65 - Page 6