Robert Stone Deposition Summary ( Prior Lawsuit )

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Robert Stone Deposition Summary (Prior Lawsuit) On April 2, 2014, Robert Stone took a deposition for a previous lawsuit. Robert Stone has served a supervisor for Elliott Construction for approximately 27-28 years. Scott Elliott is his direct boss. Prior to working at Elliott Construction, he worked for CG and Company for about four years as a backhoe operator. He has a 9th grade education and never received his high-school diploma. He got arrested a couple years back for a DWI. Mr. Stone took an eight-hour TEEX safety course on excavating and shoring. He cannot recall when he took the course, but he guesses it was more than five years, but less than 10 years before the accident. Robert Stone was responsible for overseeing Jesus Garcia, Baudelio Garcia, Luis Prado, and Armando Gonzalez. Ben Elliott and Jesus Garcia served as the other supervisors for the project. Ben, Jesus and Robert all serve as competent persons on site. Prior to this job, Mr. Stone had no experience with the slide rail system and the deepest excavation that Mr. Stone worked on was 25 feet. Mr. Elliott visited the worksite on and off throughout the project. He was present when the excavation occurred, the installation of the system, and removal of the system after the accident. Mr. Stone saw Bob Jewell and Robert Stevenson present on the job site before the accident. He saw Mr. Jewell when the system was being delivered and installed, and he saw Mr. Stevenson when the system was being

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