PART
8
PRACTICE
ORAL EXAMINATION ATTACHMENT
PART
4
FCICE - Practice Simultaneous Q&A
– Marked Copy
Q. Would
you state your full name, Ma'am?
A. Margaret
Pierce
Anderson
.
Q. And would you tell us1A what you do for a living,2E ma'am?
A. I'm
Assistant Director of Nurses at IHS, which is an affiliate of St. Paul's Hospital3G of
Dallas
.
Q. Where
do you live, Ms. Anderson?
A. I
live on
County Road
in
Copeville
,
Texas
.
Q. In
relation to the intersection4C of
Power Plant Road
and the
Kansas City
Southern
railroad line there where Mr. Garcia was killed, how far5A from it do you live?
A. Less
than a fourth of a mile.
Q. Okay. Now, have you had some personal
experiences with
Kansas City
Southern and the dangers at that intersection?
A. Yes,
sir, I have.
Q. Would
you tell the court6D about it?
A. Numerous
times my family and I have gone to the railroad
tracks,7C and you can't see the trains. So I called a number of times to have
someone come out8A to do an assessment of
it.
Q. Now,
was this before July 7th that you made these calls?
A. Yes,
sir, it was.
Q. And
when you complained that the view of traffic traveling on
Power Plant Road
was blocked, what was it9A that was blocking the
view of the trains going north or south?
A. A
lot of trees and shrubbery.10C
Q. How
many times prior to July 7th do you suppose you called11A to complain about this hazard?12C
A. I'd
say just about every month. Sometimes in the summer months I know I did at least twice a month,
because that's when the shrubs and greenery are really thick.13B
Q. And
where did you call the railroad company to
lodge14F these
complaints?
A. I
had a number, and then I got another number from information and that was
when I spoke with Mr. Peterson.
Q. All
right. First of all,15I how did you get his
number? And, secondly, how did he
respond to you?
A. Well,
I called
Garland
,
because that's where the trains used to come out of. And then that's when they told me they
no longer did and they gave me this other phone number to call.
Q. I
see. And when you got Mr.
Peterson on the phone, how did the conversation go?
A. I
didn't get to talk to him that Monday. I called and he was out of
town16B until
Wednesday, so I left a message on his answering
machine17C to
return my call18B as soon as he came in his office.
Q. Now
was this the very19H day of Mr.
Garcia’s demise?20D
A. It might
have been the day after. No, on second thought,21E it was the same day.
Q. So
you actually22B called
Kansas City
Southern on the date of his
death?
A. Yes,
sir, I did.
Q. Did
you call them before Mr. Garcia was
killed23B or
after?
A. It
was just before, about 10 o'clock24G in the morning.
Q. Why
did you call them?
A. My
husband had left to go to work that morning, and he had called me from work
and said, "I nearly got wiped
out25E this
morning." And I said,
"What happened?" And he
said, "I barely26H stopped in
time." So that really shook me up,27J and that's when I got on
the phone and made some phone calls, and that's when they gave me the number
that I called when I got hold of Mr. Peterson.
Q. Thank
you, Mrs. Anderson, I have no further questions at this time.
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