Joyce Doty Deposition

JOYCE A.
DOTY 10/24/2014
Page 1
1
IN THE CIRCUIT COURT OF PETTIS COUNTY

STATE OF MISSOURI
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 3
IN THE CIRCUIT COURT OF PETTIS COUNTY
STATE OF MISSOURI
2
ROBERT J. DOTY and )
JOYCE DOTY,
)
)
Plaintiffs, )
)
vs.
) Case No. 13CO-CC00004-01
)
JOHN J. LUSCOMBE and )
MARTHA SMITH,
)
)
Defendants. )
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
VIDEOTAPED DEPOSITION OF JOYCE A. DOTY

OCTOBER 24, 2014
(Deposition Starting Time: 2:33 p.m.)
ROBERT J. DOTY and )

JOYCE DOTY,
)
)
Plaintiffs, )
)
vs.
) Case No. 13CO-CC00004-01
)
JOHN J. LUSCOMBE and )
MARTHA SMITH,
)
)
Defendants. )
VIDEOTAPED DEPOSITION OF JOYCE A. DOTY,
produced, sworn and examined on October 24,
2014, between the hours of 2:33 p.m. and
3:23 p.m. of that day, at the law offices of
Kempton and Russell, 114 East Fifth Street,
Sedalia, Missouri, before J. D. Martin,
Registered Professional Reporter, Certified
Court Reporter within and for the State of
Missouri, in a certain cause now pending in the
Circuit Court of Pettis County, State of
Missouri, in re: ROBERT J. DOTY and JOYCE DOTY
vs. JOHN J. LUSCOMBE and MARTHA SMITH; on behalf
of the Defendants.
Page 2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
INDEX
1
2
3
PAGE
JOYCE A. DOTY
Examination by Mr. Blaylock
Page 4
4
5
EXHIBITS
MARKED
No Exhibits Marked.
6
7
8
9
10
11
12
13
14
15
APPEARANCES:
For the Plaintiffs:
T. BRODY KEMPTON
Kempton & Russell
114 East Fifth Street
Sedalia, Missouri 65301
660-827-0314
660-827-1200 (FAX)
brody@kemptonrussell.com
For the Defendants:
JEFFREY H. BLAYLOCK
Ford, Parshall & Baker
3210 Bluff Creek Drive
Columbia, Missouri 65201
573-449-2613
573-875-8154 (FAX)
jblaylock@fpb-law.com
VIDEOGRAPHER:
KENNY GAMBLE
MI DWEST LITIGATION SERVICES
REPORTED BY:
16
17
18
19
J. D. MARTIN, RPR, CCR

MIDWEST LITIGATION SERVICES
401 Locust Street, Suite 204
573-449-0561
573-499-0811 (FAX)
jmartin@midwestlitigation.com
20
21
22
23
24
25
1 (Pages 1 to 4)
www.midwestlitigation.com
MIDWEST LITIGA TION SERVICES

Phone: 1.800.280.3376
Fax: 314.644.1334
JOYCE A. DOTY 10/24/2014

Page 5
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
It is hereby stipulated and agreed

by and between counsel for Plaintiffs and
counsel for the Defendants that this deposition
may be taken in shorthand by J. D. Martin, RPR,
CCR and Notary Public, and afterwards
transcribed into printing, and signature by the
witness expressly reserved.
*****
JOYCE A. DOTY
of lawful age, produced, sworn, and examined on
behalf of the Defendants deposes and says:
EXAMINATION
QUESTIONS BY MR. BLAYLOCK:
Q. Could you please state your full
name for the record, ma'am?
A. Joyce Ann Doty.
Q. Ms. Doty, you were here during the
deposition of your husband, Robert Doty,
correct?
A. Yes.
Q. And so you know how this works, at
least to some extent having sat through his
deposition. Have you ever given a deposition
before?
A. No.
Page 7
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. And what are their names and ages?

A. Randall Kevin.
Q. Where does he live?
A. In St. Thomas in the Virgin
Islands.
Q. Okay. How old is he?
A. He was born in '63.
Q. Okay. And the other two?
A. Lisa Annette.
Q. And how old is she and where does
she live?
A. She lives in Lake Charles,
Louisiana. And she was born in '66.
Q. Okay. And the third child?
A. Julie Christine.
Q. Where does she live and what is her
age?
A. She lives in San -Q. San Antonio?
A. Yes.
Q. Okay. Go ahead.
A. She's in '69.
Q. Okay. To your knowledge do you
have any relatives that live in Pettis County?
A. No. None.
Page 6
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. Have you ever testified in court

before?
A. No.
Q. As with your husband, if at anytime
I ask you a question that you do not understand
or can't hear, please let me know and I will try
the rephrase it such that you can hear it or
understand it. If you need to take a break, let
us know. I just ask that you not do so if we
have a question pending.
Also if you could make sure to wait
to respond to a question until the question is
completely asked, that way the Court Reporter
isn't trying to take down both of us at the same
time. Okay?
You're married to Robert Doty,
correct?
A. Yes.
Q. And when were you the two of you
married?
A. June 24, 1962. You want to know
the date?
Q. Yes. How many children do you
have?
A. Three.
Page 8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. Where were you born and raised,

ma'am?
A. Napton, Missouri.
Q. Where is Napton?
A. A mile and a quarter -- I was born
a mile and a quarter north of Napton.
Q. Okay.
A. Okay.
Q. Where is Napton, Missouri located?
What county?
A. Saline.
Q. Oh, okay. Where is it in relation
to -- so you were what, 30 or 40 miles from
where Bob grew up?
A. No. Actually about 10 or 12.
Q. That close. Okay.
A. Right.
Q. You knew each other -A. We didn't know each other except
through 4-H.
Q. Okay.
A. Until we went to the University of
Missouri and started dating.
Q. Okay. And when did you get your
high school degree?
2 (Pages 5 to 8)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 9
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A.
In '60, I think it was.

MR. BLAYLOCK: Now, Bob, you can't
give her the answers.
THE WITNES S: I'm not good on
dates. He's good on dates. I am not good on
dates.
Q. (By Mr. Blaylock) You went to the
University of Missouri during what period of
time?
A. Yes. Two years.
Q. And did you obtain a degree?
A. No.
Q. Have you since then?
A. No.
Q. What was your major?
A. Home economics.
Q. Okay. And that's where you became
better acquainted with Bob.
A. Yes.
Q. Okay. Do you hold any licenses or
certifications?
A. None.
Q. Your husband mentioned that you
have a shop or a store in Blackwater, Missouri.
A. I do.
Page 11
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
raised cattle. And we showed cattle. I only

showed at the county fairs. I never did show at
the State Fair.
Q. What breed did you raise primarily?
A. Shorthorn. Registered Shorthorn.
Q. Not Milking Shorthorn?
A. No. Registered Shorthorn.
Q. Did the family -- did you have
bulls?
A. Sure.
Q. Okay. Did you ever work with the
bulls?
A. No.
Q. Would you generally -- would you
agree that, generally speaking, bulls are more
aggressive than cows?
A. I would assume. Most males are
more aggressive than females.
Q. That's fair. Did you ever have a
situation where you were threatened or attacked
by a bull?
A. None. No.
Q. Or any others on your family farm?
A. Bulls?
Q. Any one threatened by a bull?
Page 10
Page 12
Q.
What is the name of that?
A.
No.
A.
Blackwater Treasures.
Q.
Or attacked by a bull?
Q.
And how long have you operated
A.
Not that I know of.
Q.
Then after you and Bob married and
3
4
that?
A.
Ten years.
Bob continued farming, what was your exposure to
Q.
Do you have any employees?
the cattle operation after you were married?
A.
None full-time. I have one there
today.
9
10
Q.
Okay. Do you have any other
occupations outside of the home?
A.
Well, for the first few years we
had our own cattle. We had our own cattle at
first before it went into the partnership.
10
Q.
Okay.
A.
And then I was involved less when
11
A.
Not at this time.
11
12
Q.
Okay. Do you -- well, I assume you
12
it went into the partnership, because there was

enough men around to basically do the job.
13
have farming background experience. But can you
13
14
tell me what that is?
14
15
A.
Well, I was raised on a farm.
15
Q.
What was the -- what would your
involvement in the operation?
16
Q.
Okay.
16
17
A.
We farmed all of our married life.
17
Other than if they needed help moving cattle
Q.
You assisted Bob with his farming
18
from field to field --
18
19
operation after the two of you were married?
A.
I would say mostly recordkeeping.
19
Q.
Okay.
A.
-- or on highways or across
20
A.
Yes. To some extent. Not to --
20
21
Q.
Did you get actively involved in
21
highways or whatever like that.
22
Q.
23
A.
I raised cattle in 4-H.
23
A.
Right.
24
Q.
Okay.
24
Q.
-- that you would get involved
25
A.
I bought my first heifer and then
25
doing that.
22
the cattle production end of things?
That would be rather infrequent --
3 (Pages 9 to 12)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 13
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A. Yes.
Q. Again during the time that your
husband raised cattle after the two of you were
married, are you aware of any situation where
any of the bulls that they owned over the years
threatened or attacked anybody?
A. No.
Q. Do you have any experience working
with dairy cattle?
A. None. Daddy always milked cows.
You know. I probably know how to milk a cow, if
that's what you're asking.
Q. Well, did he have a dairy bull?
A. No. He had a Shorthorn bull.
Q. Do you remember what the
disposition of that Shorthorn bull was?
A. Not to this date I don't remember.
I'm sorry.
Q. That's okay. Have you ever been to
the milk barn where Bob was injured that he
testified about earlier?
A. No, I have never been in the barn.
I have picked up milk at the cooler.
Q. Right next to the barn?
A. Right.
Page 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
that Bob was going to the farm that morning

before he was headed to Kansas City to pick up
your son?
A. I was aware of that fact, right.
Q. Had he mentioned that to you the
day before?
A. No, he probably just told me that
morning before.
Q. What did he tell you he was going
to do?
A. To get milk, I think, is what he
told me he was going to do.
Q. So, he was going to get milk, bring
it back home, and then go get your son?
A. Right.
Q. Did he mention anything at all
about working cattle?
A. No.
Q. Would you have discouraged him from
working cattle if he had mentioned it to you?
MR. KEMPTON: Objection. Calls for
speculation. You can answer if you want.
THE WITNES S: Would I have objected
to him working cattle?
Q. (By Mr. Blaylock) Discouraged him
Page 14
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. Okay.
A. But I have never been in the barn.
Q. When you picked up milk, did you
ever see any of the cattle?
A. Up in the dairy milk area?
Q. Either in the milking area, or in
the holding pen, or nearby where you might have
walked?
A. I think they were always through.
I don't ever remember seeing any of that.
Q. Did you have any appreciation of
the fact that there was a bull on the farm?
A. Did I have an appreciation?
Q. Did you understand that there was a
bull on the farm?
A. Common knowledge would have told me
there was a bull on the farm.
Q. You made that assumption.
A. Yes, sir.
Q. But you didn't actually see the
bull to your knowledge.
A. No, sir. I have never seen the
bull in fact.
Q. What is your understanding of how
Bob -- well, let me ask this -- were you aware
Page 16
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
from doing that?

A. No.
Q. Okay.
A. He was highly capable.
Q. And I wasn't suggesting otherwise.
Do you remember what time it was that Bob left
that morning?
A. I don't. I'm sorry. When it comes
to times of that day -Q. Do you remember was it before or
after lunch, do you know, that he left?
A. I don't remember when Randy's
flight was in.
Q. Okay.
A. But I assume morning -- usually
morning he got milk. I will say that.
Q. And was he usually the person who
would pick the milk up?
A. Yes.
Q. How did you find out about the fact
Bob had been injured?
A. John came in. And I had quite a
few customers in the shop. And he said everyone
has to leave. Bob has been hurt bad. And I
went to get my purse and my keys to drive my
4 (Pages 13 to 16)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 17
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
car, and he wouldn't let me drive my car. He

wanted me to ride with him. So, I rode with him
to the emergency room in Boonville.
Q. Is that Cooper County Memorial
Hospital?
A. Yes. Right.
Q. On the way there did you have any
discussion or conversation with Bob -- I'm sorry
-- John, about how the accident occurred?
A. I can't remember him saying how it
occurred. I remember -- the only thing I
remember him telling me, he told me about four
times -- when I get very upset, I get very very
quiet. And he probably sensed that. And I
remember him saying four times, Joyce, I have
got good insurance. Don't worry.
Q. I'm sorry. Go ahead.
A. I never thought about insurance. I
wasn't even -- I was just wondering how Bob was
doing. You know, I was concerned about what
went on.
Q. Do you remember anything else that
John said?
A. No, I don't.
Q. Was there other conversation, and
Page 19
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A. Yes.
Q. Tell me as best you can what
conversation you have had with him about what
happened.
A. I just asked him what happened.
Q. Okay. Do you remember when this
conversation took place?
A. No. It would have probably been a
month -- it took over a month for us to get
through all the medical. So, it was probably at
least a month or so afterwards.
Q. And was there just the one
conversation with Fred about how it happened?
A. I assume so. I don't remember
asking him anymore.
Q. What is your recollection of what
Fred told you?
A. Just exactly what Bob told you this
morning.
Q. No variation whatsoever?
A. No.
Q. Where did that conversation take
place?
A. It was probably at my home.
Q. Would Fred have had a reason to be
Page 18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
you just don't remember it?

A. I'm not sure.
Q. Have you had any conversation with
John or Martha Smith since that date as to how
the accident occurred?
A. Martha took me on to Columbia to
the University after the helicopter left. I
don't remember her saying anything about the
accident. And at that point I wasn't -- I'm not
the inquisitive kind that I have to know every
single thing. I was more concerned about him.
Q. Okay. So, during that trip there
was no discussion between the two of you as to
how or why the accident occurred.
A. No, I don't remember if there was.
Q. Have you had any discussions with
anyone other than Bob as to how the accident
occurred? And we have talked about John and
Martha. But have you talked to anyone else
about how the accident occurred?
A. Afterwards?
Q. Yes, ma'am.
A. Probably I have said something to
Freddie.
Q. Okay. Fred Butler?
Page 20
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
there?
A. That would have been in -- I don't
remember when it was exactly. So -Q. Before December of two thousand -I'm sorry -- before March of 2013?
A. You know, I might have given him
something out of the garden. I might have given
him something that I had fixed or something.
But I don't know what the -- I don't know what
the reason would have been.
Q. During your conversation with Fred
did he mention anything to you about any prior
incidents? And by that I mean incidents that
occurred before August 30, 2012 at which the
bull acted aggressively?
A. To him? Yes.
Q. What did he tell you?
A. He just told me that the bull had
gotten him down before.
Q. Gotten him down? Were those the
words he used?
A. That's what I understood.
Q. Okay.
A. It may be a different description
than what you would call it. But when a bull
5 (Pages 17 to 20)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 21
1
attacks someone, that would be my assumption of
the word I would use.
3
4
Q.
Did he tell you that the bull
attack him?
A.
Q.
Did he tell you when that happened?
A.
No, I don't know a date. But I
8
9
10
Yes.
know it happened prior to Bob's accident.

Q.
Did he tell you the circumstances
of that?
11
A.
No, he didn't.
12
Q.
Did he tell you whether or not he
13
14
was injured?
A.
He was hurt. I don't know how bad.
15
Because I did not see him or know of it at the
16
time.
17
Q.
Do you know if John Luscombe or
18
Martha Smith were aware of this incident between
19
Fred Butler and the bull?
20
A.
I do not know.
21
Q.
Did Fred tell you whether or not he
22
told John Luscombe or Martha Smith about that
23
incident?
24
A.
I don't know that.
25
Q.
Well, I'm not asking if you know
Page 23
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
incident involving the bull -- by prior I mean

before had August 30 of 2012 in which the bull
was alleged to have acted aggressively?
A. No, sir.
Q. You have no personal knowledge of
the disposition of the bull I take it.
A. No, sir. I have never seen the
bull.
Q. Have you ever heard a tape
recording of a statement of my clients taken by
Aaron Smith?
A. Have I heard a recording?
Q. A recording of a statement that
Aaron Smith made of my clients?
A. I have not heard that. I know
there was a recording. But I have not heard of
the recording.
Q. You haven't actually heard the
recording itself.
A. No, sir.
Q. Do you have any knowledge of what
happened to that recording?
A. No, sir, I don't.
Q. Have you listened to the recording
of the statement taken of Bob while he was at
Page 22
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
whether or not he did. Did he tell you that he

did?
A. No.
Q. Okay. Have you had any discussions
with anyone else about any incidents involving
the bull which you understand to have occurred
before August 30 of 2012 in which the bull acted
in an aggressive manner?
A. I know what Bob told me about
meeting Judy on the sidewalk in Blackwater.
Q. Okay.
A. I know that.
Q. And what did Bob tell you that Judy
said?
A. Basically that she was in a skirt
in a pasture -- which they just live across from
them -- and said that the bull had chased her
out of the pasture, and she had to get over the
fence. And was very concerned because they have
little children.
Q. Judy and her husband, John's son,
have young children?
A. Yes.
Q. Right. Any other conversations
with anyone else about any alleged prior
Page 24
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Rusk Rehab?
A. I heard it today for the first
time.
Q. When we played it during Bob's
deposition?
A. Yes, sir.
Q. And to be fair, we didn't play the
entire statement. But you heard that portion of
the -A. I heard enough to realize how tired
his voice sounded. That was not his normal
voice.
Q. Do you have any knowledge of what
pain medications Bob might have been taken
within the 24 hour period before he gave his
statement?
A. I know they were always giving him
pain medication before he did therapy. Because
it was so hard for him to do therapy. And he
was in so much pain, that they always gave him
pain medicine ahead of it.
Q. Do you have any specific knowledge
of what pain medications he took -A. I do not.
Q. -- during that 24 hour period?
6 (Pages 21 to 24)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 25
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A. No. I knew what he was on. You

know, they told me in the hospital of what he
was on. I didn't ask when he got to Rusk what
medication he was on. We were trying to get his
hand to work.
Q. Was Bob reluctant to take pain
medications?
A. Not at that point. He was hurting
bad enough that he would have taken them.
Q. Bob testified at some length this
morning about his physical limitations and pain
and discomfort that he continues to experience.
Can you add anything to what Bob testified to
this morning from your observations?
A. Bob has always -- ever since he
lost his arm -- like everything he did was a
challenge, to see it through and to get it
accomplished. I have seen a complete change in
attitude of giving up, and not having the
strength to accomplish what he wants to
accomplish.
As far as little nails or little
screws or anything very delicate, he can no
longer handle. I mean his fingers just will not
let him do anything. And where I have the
Page 27
1
A.
I don't have idea at this point.
Q.
Did you read anything to prepare
3
4
for your deposition today?

A.
Aaron gave me a packet.

MR. KEMPTON: No. I'm Brody.
THE WITNESS: Oh, I'm sorry. Gave
me a packet to look over. And I signed, I
think.
Q.
(By Mr. Blaylock) You looked at
10
some answers to the written discovery that we
11
sent you earlier on in the case --
12
A.
Right.
13
Q.
Interrogatories and Requests for
14
Production.
15
A.
Yes.
16
Q.
Okay. Having looked at those, are
17
there any responses to those interrogatories
18
that you believe at this time need to be
19
supplemented that you can supplement or answers
20
that need to be changed?
21
A.
I didn't see anything. It does say
22
that I got in John's car. Well, John had a
23
pickup. I got into John's pickup.
24
Q.
Okay.
25
A.
That was the only thing that I saw
Page 26
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
antique shop and he repaired things in the past

-- done electrical wiring and things like
that -- those things are -- you know, it's just
almost impossible.
I have seen him hire help. I have
seen him go get help when he needs to do things
with machinery that he's using -- that he never
had to do before.
I think one of the biggest things
is around the grandkids and things like that,
they are all very sports -- all in sports. You
know, things like that. That he was a pole
vaulter. He was involved in sports, too. You
know. That was a biggie for him.
There is just, you know, a
completely different overall attitude about
everything.
From the time that he was in the
hospital, I have financially taken care of
paying things and taking care of the majority of
what needs to be taken care of.
Q. Do you have a figure, if you know,
the amount that you all have spent out-of-pocket
for medical expenses, prescription drugs,
arising out of the August 30 incident?
Page 28
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
that I think might be different.

Q. That was the day that he drove you
to the hospital?
A. Yes.
Q. Okay. Did you consider John and/or
Martha to be friends -A. Yes.
Q. -- before -A. Definitely.
Q. -- Bob was hurt? Okay. Did you
socialize with either one of them?
A. No, not necessarily.
Q. What was the nature of your
relationship? In other words, what did you do
with them or for each other, that sort of thing?
A. I made pies. Homemade pies. And
we traded milk for pies.
Q. Okay.
A. And that was the agreement that we
started out with. And then Bob saw things that
he could help with. And so -Q. I'm sorry. Go ahead.
A. I think we went to his mother's
funeral.
Q. Okay.
7 (Pages 25 to 28)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 29
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A. I did not personally know his

mother. But we went to her funeral in respect
for them.
Q. Did Bob ever mention the bull
before August 30, 2012?
A. No.
Q. And had you ever heard anyone talk
about the bull before August 30, 2012?
A. No, sir.
Q. I take it that it's not your
intention to offer any opinions about this
bull's disposition at trial.
MR. KEMPTON: No, it's not.
Q. (By Mr. Blaylock) You have some
general ideas about bull's behavior.
A. I would say this -- if we had had a
bull on our farm that had acted like this bull,
it would not have been on our farm very long.
Q. Okay. Do you know what knowledge
John and Martha had of these prior behaviors?
A. I don't.
Q. Do you have any knowledge that this
bull, when compared to other dairy bulls of the
same breed, was any more or less aggressive?
A. I have no idea.
Page 31
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
you had to provide some assistance to Bob, and

still might, as a result of any condition that
he continues to suffer from as a result of the
accident. Can you tell me what sort of care you
have had to provide for Bob since he came home
from Rusk, and how that might have changed or
progressed over time?
A. You want to go back to when he was
in the University?
Q. That's fine.
A. Okay.
Q. If that would apply to that time.
A. Because his hand was tied to a
board because all the central lines were going
into his arm, he could not feed himself
whatsoever. He was supposed to drink -- I don't
know if he was six or eight Ensures because he
couldn't eat. So, he had to sip on those. So,
we had to be there -- I had to be there -either my daughter or I had to be there.
My daughter was in Moberly at the
time. And we tried to do a little bit of
trading off. I did most of it when he was in
the hospital.
So, the doctor said he had to sip
Page 30
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. Are you critical of the decision

that was made for Martha to drive Bob to the
hospital?
A. No, sir.
Q. Has Bob ever told you that he
believed that it was John or Martha's fault that
the accident happened?
A. Bob is not that kind of person.
Q. Do you believe that your husband
ever takes unnecessary risks?
A. No.
Q. Do you believe he did so on the day
that he was hurt?
A. No. I would have done the same
thing.
Q. Do you believe he would have gone
into that holding pen even if he had known that
the bull was in there?
MR. KEMPTON: Calls for
speculation. You can answer.
THE WITNES S: If he knew it was a
mean bull, I know he wouldn't have gone in
there. If you're talking about an ordinary
bull, yes.
Q. (By Mr. Blaylock) I assume that
Page 32
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
on that enough to get enough nutrition so his

body would heal. So, that was however many days
he was in the University.
Q. What hours would you be there each
day?
A. It was all during daytime hours.
Q. Okay.
A. You know, it was after dark when I
left.
Q. Okay. More into night.
A. Right.
Q. Okay. Okay and then -A. Then we went to Rusk -Q. Okay.
A. -- after that. Basically we fed
him because his hand would not even work enough
that he could hold a fork. I kept telling them
at the University that he couldn't even squeeze
my hand or squeeze my fingers. And I kept
saying at the University when he was there, that
something was wrong with his hand. Of course,
they were more worried about saving his life.
And I fully realized that they were doing
everything that they could to progress his
living. And I was worried about his hand.
8 (Pages 29 to 32)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 33
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Because I knew if his hand didn't work, he

wasn't going to be a happy camper.
And anyway, until he could get
strength enough in that hand, we fed him every
meal.
Q. How long did you have to feed him
while he was at Rusk?
A. And I can't tell you that. I'm
sorry. I didn't write down anything.
Q. Well, did either one of you keep a
calendar -A. No.
Q. -- of significant event?
A. No. There was too much going on.
Q. Was he able to feed himself by the
time he was discharged from Rusk?
A. Yes. Basically, barely.
Q. Okay.
A. He could sit up.
Q. Does he require any assistance in
that regard today?
A. Not eating. He has wounds that had
to be -- we had to use a special honey -- I
think it was surgical honey or something like
that, where they had taken the tubes out. So,
Page 35
1
that.
Q.
And where were the wounds located?
A.
Basically in his side is where they
put the tubes in for the lungs to drain the
blood out and everything.
Q.
What about the scars from the
wounds from the surgical procedure? Did those
require dressing changes after he was discharged
to home or were those pretty well healed by the
10
11
time he got home?

A.
I think there were some that
12
required. But not many. I think they were
13
pretty well healed.
14
15
Q.
You mentioned you had to help him
get in and out of the braces.
16
A.
Uh-huh.
17
Q.
He was wearing the neck brace and
18
the upper body brace, is that right?
19
A.
Right.
20
Q.
Was Bob eventually able to get in
21
22
and out of the braces himself?

A.
He's not able to get in and out of
23
the back brace -- the front and back brace
24
himself. It has several different --
25
Q.
Are you referring to the brace that
Page 34
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
those dressings had to be changed.

Q. Was that after he was discharged to
home?
A. Right.
Q. How long did you have to change
those dressings?
A. I don't remember how long. It was
just whatever it took.
Q. Are we talking months or weeks?
A. It was probably at least a month.
Q. Okay.
A. And there was one suture left even
after that that they didn't take out before he
left the hospital. And the home health nurse
took that out.
Q. How else did you have to assist Bob
-- well, have we covered the things that you had
to do to assist Bob while he was at UMC and
Rusk?
A. Right. They pretty well got him
in and out of the braces. When we were back
home then I had to get him out of braces. And
the showering -- you had to wrap everything.
Wrap all the wounds basically in Saran Wrap and
tape so he could take a shower or anything like
Page 36
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Bob testified about earlier that he got within

the last year or so.
A. No, that was the one that the
University sent him home with.
Q. Okay. Does he still use that brace
from time to time?
A. I have seen him put it on from time
to time.
Q. Okay. When is the last time that
he wore that brace?
A. I can't give you a date on that.
I'm sorry. When the pain gets bad, then he will
put it on. Or when he becomes so uncomfortable
that he can't -Q. Is that something that happens,
say, once a month?
A. I'd say on that regular basis.
Q. As far as the other brace that I
was asking about that Bob said he has gotten in
the last year, is he able to put that on
himself?
A. I can't remember. I'm sorry.
Q. Do you remember helping him put it
on?
A. Yes.
9 (Pages 33 to 36)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 37
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. And when was the last time that you

helped him do that?
A. Again, I can't give that date.
Q. What other activities or -activities of daily living or other activities
have you had to assist Bob with since he's been
back home?
A. Sometimes just getting clothes on
sometimes. Before, you know, he could always
button all of his own buttons, tie his own shoes
and do all of that himself. And there is not
every day I have to do that. It's just on
occasion that it doesn't seem like his hand is
working or whatever.
Q. Since Bob has gotten home, has the
use of his hand improved?
A. I can't see that it has.
Q. Does Bob still do any type of home
exercise program?
A. From time to time he does back -well, I don't know -- there are back and leg
exercises I guess. They didn't give him any
exercises necessarily on his hand to do.
Q. Does he do some hand exercises,
even if it's like isometric stretching?
Page 39
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. Bob is able to -- basically he can

bathe himself now.
A. Sure.
Q. And for the most part he can dress
himself. Sometimes he requires assistance.
A. Yes.
Q. Is there any other specific thing
that you haven't already mentioned where you
have to provide Bob with physical assistance?
A. Carrying anything heavy.
Q. Okay. Does Bob do most of the
driving?
A. Not anymore. I usually drive.
Q. You do it more than he does?
A. Yeah.
Q. Is it uncomfortable for Bob to
drive any distance?
A. Seems like it. I drove most of the
trips to Lake Charles and San Antonio.
Q. Is there anything else that you do
now or do more of that Bob used to do?
A. He used to -- he used to
financially pay the bills and stuff. Now I do
that.
Q. And by that, you're the one that
Page 38
1
2
3
4
A.
I have seen him do things like
that. But I don't see him doing anything else.

Q.
Bob's sleep habits -- have you
noticed a change in those?
A.
He doesn't sleep well.
Q.
And did Bob sleep well before the
accident?
A.
Yeah.
Q.
Does he get up in the night and
10
move around?
11
A.
12
once a night.
13
14
Q.
He does get up usually at least

Have you ever had anyone live in
the home to provide assistance for Bob?
15
A.
No, we haven't.
16
Q.
Have you hired anyone to assist Bob
17
-- and we talked about some things that you
18
hired people to do, for instance, at the store
19
or around the house. But have you hired anybody
20
to assist Bob with any activities of daily
21
living? Dressing, changing --
22
A.
No.
23
Q.
-- feeding himself, that sort of
24
25
thing? Bathing?
A.
No.
Page 40
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
sits down and balances the checkbook, and pays

the monthly bills and that sort of thing?
A. Right.
Q. What do you attribute that to?
A. I don't know. I don't know whether
it's concentration or whether it's -- I don't
know the answer to that.
Q. Okay. And I don't ask this
question just to pry. But because this is the
basis of your claim in this case, I need to ask
about how your relationship with Bob has
changed, if at all, since the accident in terms
of your married life.
A. Stress.
Q. Okay.
A. That's one big thing. Maybe not as
compatible. Because his body is different. But
that's the only two things that I can think of
right now.
Q. And when you say compatible, you're
referring to marital relations?
A. Right. Our husband and wife
relationship or whatever.
Q. It's less frequent and less
enjoyable? Is that a fair -- I don't want to
10 (Pages 37 to 40)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 41
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
put words in your mouth.

A. Well, let's just say you have got
metal against -- it's a whole different feeling.
Okay?
Q. Other than your attorney, have you
spoken with anyone who has told you that this
bull was more dangerous than other bulls of the
same breed?
MR. KEMPTON: Other than what she
has already talked about?
MR. BLAYLOCK: Yeah.
THE WITNES S: What do you mean by
that?
Q. (By Mr. Blaylock) Well, have you
spoken with anyone who has told you that the
bull that injured Bob was more dangerous than
other bulls of the same breed?
A. I haven't spoken to anyone about
that.
MR. BLAYLOCK: Okay. I think I'm
about done, Brody. I'm just going to take a
short break and step out real quick. I'll be
right back.
(OFF THE RECORD. )
Q. (By Mr. Blaylock) Ms. Doty, we're
Page 43
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A. No, I haven't. I have talked to

Dan.
Q. I'm sorry?
A. I have talked to Dan, her husband.
Q. Okay.
A. But not about that situation.
Q. Have you had any discussion with
Dan about the bull?
A. About the bull?
Q. Yes, ma'am.
A. No, not about the bull.
Q. Okay. Anything regarding this
lawsuit or any claim that is being made?
A. Yes.
Q. And what would that be?
A. I explained to him that how many
dollars worth of medical expenses that we had.
And the only thing that we could do was to go
through this process.
Q. Do you know what your medical
expenses have been up to this point?
A. I have seen a list of them. Do you
want me to know the exact amount to the penny?
Q. If you know in general.
A. I know it's close to 300,000.
Page 42
1
back on the record after a sort break. I just
have a couple of questions. But before I go on,
is there anything about your testimony up to
this point as you sit here right now that you
can think of that you want to change, or add to,
or amend in any way?
A.
No.
Q.
Going back to the situation that
you were telling me about -- I believe Bob told
10
you that Judy Luscombe had mentioned an incident
11
when she was in the pasture with the bull.
12
A.
Right.
13
Q.
And I may have misunderstood you.
14
Did you say that you were concerned about the
15
situation because she and her husband have young
16
children? Or was it Judy told Bob that she was
17
concerned because she had --
18
A.
No. I was concerned.
19
Q.
Okay. Did Bob at anytime tell you
20
that Judy was concerned because she had small
21
children?
22
A.
No.
23
Q.
And I take it you haven't had any
24
personal conversation with Judy about that
25
situation.
Page 44
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. And are you personally responsible

for any portion of those expenses?
A. Not of those expenses. Those are
all from the bull.
Q. What other medical expenses -well, are there other medical expenses relating
to this incident that -A. Are not included?
Q. Yeah, that are not included?
A. I noticed that when he had a colon
scan because he had had diarrhea for three
months afterwards -- we thought maybe he had
picked up a bug in the hospital or something -those expenses aren't added in.
And also he was choking -- just
drinking water sometimes he would choke. So,
they did a throat scope in Marshall. Both of
those were done in Marshall with local
physicians. And those bills were not added to
the claim.
Q. Okay. Now, did you have to pay
those expenses, or were those covered by
Medicare, or do you know?
A. Those were covered by our insurance
and Medicare I'm sure. Because we have not
11 (Pages 41 to 44)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 45
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
received billing on them.

Q. And at this time I believe you
indicated earlier you didn't know that a general
or an estimate of the amount that you have been
out-of-pocket for medical and related expenses
as a result of the accident, is that correct?
A. I don't know.
Q. Do you believe it's in the
thousands of dollars?
A. No, not really. I don't know.
Q. Okay.
A. I just don't know.
Q. Okay. You don't even feel
comfortable making -A. No, I don't. And I don't know what
you expect. Whether it be prescriptions or
whether it would have been like the procedures
that he had done -Q. Right.
A. -- because of the -- I don't know
what you mean.
Q. Well, I'm asking if you know what
you're out-of-pocket expenses have been for any
medical or prescription costs incurred by Bob as
a result of the accident. And if you don't know
Page 47
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A. No. They couldn't find anything.

They assumed it was the tube going down his
throat did something. But, anyway -MR. BLAYLOCK: I don't think I have
anything further, Brody. And whatever you all
want to do on signature is fine.
MR. KEMPTON: I want her to read
and sign. I have no questions.
(OFF THE RECORD.)
(Deposition Ending Time: 3:23 p.m.)
Page 46
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
I understand.
A. I don't know.
Q. Okay. Has any physician told you
that that diarrhea condition was as result of
the hospitalization?
A. No. They sent the results off.
And it didn't have whatever they were looking
for. Whether it was some kind of a bug that you
can get in the hospital.
He wasn't eating for so many days,
and it gets your system all out of whack. And
so -- but he had diarrhea for three months after
this.
Q. Did any physician explain to you
the cause of that condition?
A. No.
Q. And then you mentioned the
difficulty swallowing.
A. Yes.
Q. Has that resolved?
A. Not to a certain extent. There are
still times he gets choked. The diarrhea has
stopped.
Q. Has any physician told you what the
cause of the difficulty swallowing that Bob has?
Page 48
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
CERTIFICATE
I, J. D. Martin, Registered Professional
Reporter, Certified Court Reporter for the State
of Missouri, do hereby certify that the witness
whose testimony appears in the foregoing
deposition was duly sworn by me; that the
testimony of said witness was taken by me to the
best of my ability and thereafter reduced to
typewriting under my direction; that I am
neither counsel for, related to, nor employed by
any of the parties to the action in which this
deposition was taken, and further that I am not
a relative or employee of any attorney or
counsel employed by the parties thereto, nor
financially or otherwise interested in the
outcome of the action.
____________________________
J. D. Martin, RPR, CCR
12 (Pages 45 to 48)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 49
1
COURT MEMO
IN THE CIRCUIT COURT OF PETTIS COUNTY, MISSOURI
2
3
4
5
6
ROBERT J. DOTY and JOYCE DOTY )

vs.
) Case No. 13CO-CC00004-01
JOHN J. LUSCOMBE and MARTHA )
SMITH
)
CERTIFICATE OF OFFICER AND STATEMENT OF DEPOSITION CHARGES

(Rule 57.03(g)(2)(a) & Sec. 492.590 RSMO 1985.)
DEPOSITION OF JOYCE A. DOTY
OCTOBER 24, 2014
7
8
9
Name and address of person or firm having custody of the

original transcript: JEFFREY H. BLAYLOCK
Ford, Parshall & Baker
3210 Bluff Creek Drive
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 51
TAXED IN FAVOR OF: JEFFREY H. BLAYLOCK

TOTAL: $
TAXED IN FAVOR OF: T. BRODY KEMPTON
TOTAL: $
Upon delivery of transcript, the above charges had not yet
been paid. It is required that all charges will be paid
in the normal course of business.
711 N. 11th Street
St. Louis, Missouri 63101
__________________________
NOTARY PUBLIC
My Commission Expires:
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
ERRATA SHEET
Witness Name: JOYCE A. DOTY
Case Name: ROBERT J. DOTY and JOYCE DOTY vs. JOHN J.
LUSCOMBE and MARTHA SMITH
Date Taken: OCTOBER 24, 2014
Page #_____ Line #_____
Should read: ____________________________________
Reason for change: ______________________________
Page #_____ Line #_____
Should read: ____________________________________
Page #_____ Line #_____
Should read: ____________________________________
Page #_____ Line #_____
Should read: ____________________________________
Page #_____ Line #_____
Should read: ____________________________________
Witness Signature: ______________________________
Page 50
1
November 6, 2014
T. BRODY KEMPTON
Kempton & Russell
114 East Fifth Street
Sedalia, Missouri 65301
4
5
6
IN RE: ROBERT J. DOTY and JOYCE DOTY vs. JOHN J.

LUSCOMBE and MARTHA SMITH
Dear Mr. Kempton:
Please find enclosed your copies of the deposition of

JOYCE A. DOTY taken on October 24, 2014 in the
above-referenced case. Also enclosed is the original
signature page and errata sheets.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Please have the witness read your copy of the

transcript, indicate any changes and/or corrections
desired on the errata sheets, and sign the signature
page before a notary public.
Please return the errata sheets and notarized
signature page to Jeffrey Blaylock for filing prior to
trial date.
Sincerely,
J. D. MARTIN, RPR, CCR
Enclosures
Page 52
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
STATE OF _______________)
COUNTY OF ______________)
I, JOYCE A. DOTY, do hereby certify:
That I have read the foregoing deposition;
That I have made such changes in form
and/or substance to the within deposition as might
be necessary to render the same true and correct;
That having made such changes thereon, I
hereby subscribe my name to the deposition.
I declare under penalty of perjury that the
foregoing is true and correct.
Executed this _____ day of _______________,
20___, at ___________________________.
__________________________
JOYCE A. DOTY
__________________________
NOTARY PUBLIC
My Commission Expires:
13 (Pages 49 to 52)

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 53
A
Aaron 23:11,14
27:4
ability 48:9
able 33:15 35:20
35:22 36:20
39:1
above-referenc...
50:9
accident 17:9
18:5,9,14,17,20
21:8 30:7 31:4
38:7 40:12 45:6
45:25
accomplish 25:20
25:21
accomplished
25:18
acquainted 9:18
acted 20:15 22:7
23:3 29:17
action 48:12,17
actively 10:21
activities 37:4,5
37:5 38:20
add 25:13 42:5
added 44:14,19
address 49:7
age 5:10 7:17
ages 7:1
aggressive 11:16
11:18 22:8
29:24
aggressively
20:15 23:3
agree 11:15
agreed 5:1
agreement 28:19
ahead 7:21 17:17
24:21 28:22
alleged 22:25
23:3
amend 42:6
amount 26:23
43:23 45:4
and/or 28:5
50:11 52:8
Ann 5:16
Annette 7:9
answer 15:22
30:20 40:7
answers 9:3
27:10,19
antique 26:1
Antonio 7:19
39:19
anybody 13:6
38:19
anymore 19:15
39:13
anytime 6:4
42:19
anyway 33:3
47:3
APPEARANC...
4:1
appears 48:6
apply 31:12
appreciation
14:11,13
area 14:5,6
arising 26:25
arm 25:16 31:15
asked 6:13 19:5
asking 13:12
19:15 21:25
36:19 45:22
assist 34:16,18
37:6 38:16,20
assistance 31:1
33:20 38:14
39:5,9
assisted 10:18
assume 10:12
11:17 16:15
19:14 30:25
assumed 47:2
assumption
14:18 21:1
attack 21:4
attacked 11:20
12:2 13:6
attacks 21:1
attitude 25:19
26:16
attorney 41:5
48:14
attribute 40:4
August 20:14
22:7 23:2 26:25
29:5,8
aware 13:4 14:25
15:4 21:18
billing 45:1
bills 39:23 40:2
44:19
bit 31:22
Blackwater 9:24
10:2 22:10
Blaylock 2:4 4:9
5:13 9:2,7
15:25 27:9
29:14 30:25
41:11,14,20,25
47:4 49:8,10
B
50:16
B 2:8
blood 35:5
back 15:14 31:8 Bluff 4:10 49:9
34:21 35:23,23 board 31:14
37:7,20,21
Bob 8:14 9:2,18
41:23 42:1,8
10:18 12:4,5
background
13:20 14:25
10:13
15:1 16:6,21,24
bad 16:24 21:14
17:8,19 18:17
25:9 36:12
19:18 22:9,13
Baker 4:9 49:8
23:25 24:14
balances 40:1
25:6,10,13,15
barely 33:17
28:10,20 29:4
barn 13:20,22,24
30:2,5,8 31:1,5
14:2
34:16,18 35:20
basically 12:13
36:1,19 37:6,15
22:15 32:15
37:18 38:6,14
33:17 34:24
38:16,20 39:1,9
35:3 39:1
39:11,16,21
basis 36:17 40:10
40:11 41:16
bathe 39:2
42:9,16,19
Bathing 38:24
45:24 46:25
behalf 3:21 5:11 Bob's 21:8 24:4
behavior 29:15
38:3
behaviors 29:20 body 32:2 35:18
believe 27:18
40:17
30:9,12,16 42:9 Boonville 17:3
45:2,8
born 7:7,13 8:1,5
believed 30:6
bought 10:25
best 19:2 48:9
brace 35:17,18
better 9:18
35:23,23,25
big 40:16
36:5,10,18
biggest 26:9
braces 34:21,22
biggie 26:14
35:15,21

Phone: 1.800.280.3376
break 6:8 41:22

42:1
breed 11:4 29:24
41:8,17
bring 15:13
Brody 4:3 27:5
41:21 47:5
49:11 50:3
brody@kempt...
4:6
bug 44:13 46:8
bull 11:21,25
12:2 13:13,14
13:16 14:12,15
14:17,21,23
20:15,18,25
21:3,19 22:6,7
22:17 23:1,2,6
23:8 29:4,8,17
29:17,23 30:18
30:22,24 41:7
41:16 42:11
43:8,9,11 44:4
bulls 11:9,12,15
11:24 13:5
29:23 41:7,17
bull's 29:12,15
business 49:15
Butler 18:25
21:19
button 37:10
buttons 37:10
C
calendar 33:11
call 20:25
Calls 15:21 30:19
camper 33:2
capable 16:4
car 17:1,1 27:22
care 26:19,20,21
31:4
Carrying 39:10
case 1:5 3:5
27:11 40:10
49:3 50:9 51:2
Fax: 314.644.1334

Page 54
cattle 10:22,23
11:1,1 12:6,8,8
12:17 13:3,9
14:4 15:17,20
15:24
cause 3:18 46:15
46:25
CCR 4:16 5:5
48:22 50:22
central 31:14
certain 3:18
46:21
CERTIFICATE
48:1 49:5
certifications
9:21
Certified 3:16
48:4
certify 48:5 52:5
challenge 25:17
change 25:18
34:5 38:4 42:5
51:6,10,14,18
51:22
changed 27:20
31:6 34:1 40:12
changes 35:8
50:11 52:7,10
changing 38:21
charges 49:5,13
49:14
Charles 7:12
39:19
chased 22:17
checkbook 40:1
child 7:14
children 6:23
22:20,22 42:16
42:21
choke 44:16
choked 46:22
choking 44:15
Christine 7:15
Circuit 1:1 3:1
3:19 49:1
circumstances
21:9
City 15:2
claim 40:10
43:13 44:20
clients 23:10,14
close 8:16 43:25
clothes 37:8
colon 44:10
Columbia 4:10
4:18 18:6 49:9
comes 16:8
comfortable
45:14
Commission
49:24 52:24
Common 14:16
compared 29:23
compatible 40:17
40:20
complete 25:18
completely 6:13
26:16
concentration
40:6
concerned 17:20
18:11 22:19
42:14,17,18,20
condition 31:2
46:4,15
consider 28:5
continued 12:5
continues 25:12
31:3
conversation
17:8,25 18:3
19:3,7,13,22
20:11 42:24
conversations
22:24
cooler 13:23
Cooper 17:4
copies 50:8
copy 50:10
correct 5:19 6:17
45:6 52:9,13
corrections 50:11
costs 45:24
counsel 5:2,3
48:11,15
county 1:1 3:1,19
7:24 8:10 11:2
17:4 49:1 52:3
couple 42:2
course 32:21
49:15
court 1:1 3:1,17
3:19 6:1,13
48:4 49:1,1
covered 34:17
44:22,24
cow 13:11
cows 11:16 13:10
Creek 4:10 49:9
critical 30:1
custody 49:7
customers 16:23
Dear 50:7
December 20:4
decision 30:1
declare 52:12
Defendants 1:7
3:7,22 4:8 5:3
5:11
Definitely 28:9
degree 8:25 9:11
delicate 25:23
delivery 49:13
deposes 5:11
deposition 1:17
1:20 3:10 5:3
5:18,23,23 24:5
27:3 47:11 48:7
48:13 49:5,6
50:8 52:6,8,11
description 20:24
desired 50:12
diarrhea 44:11
D
46:4,12,22
D 2:1 3:15 4:16
different 20:24
5:4 48:3,22
26:16 28:1
50:22
35:24 40:17
Daddy 13:10
41:3
daily 37:5 38:20 difficulty 46:18
dairy 13:9,13
46:25
14:5 29:23
direction 48:10
Dan 43:2,4,8
discharged 33:16
dangerous 41:7
34:2 35:8
41:16
discomfort 25:12
dark 32:8
discouraged
date 6:22 13:17
15:19,25
18:4 21:7 36:11 discovery 27:10
37:3 50:17 51:3 discussion 17:8
dates 9:5,5,6
18:13 43:7
dating 8:23
discussions 18:16
daughter 31:20
22:4
31:21
disposition 13:16
day 3:13 15:6
23:6 29:12
16:9 28:2 30:12 distance 39:17
32:5 37:12
doctor 31:25
52:14
doing 12:25 16:1
days 32:2 46:10
17:20 32:23
daytime 32:6
38:2

Phone: 1.800.280.3376
dollars 43:17
45:9
Doty 1:2,3,17 2:3
3:2,3,10,20,20
5:9,16,17,18
6:16 41:25 49:2
49:2,6 50:5,5,8
51:1,2,2 52:5
52:20
drain 35:4
dress 39:4
dressing 35:8
38:21
dressings 34:1,6
drink 31:16
drinking 44:16
drive 4:10 16:25
17:1 30:2 39:13
39:17 49:9
driving 39:12
drove 28:2 39:18
drugs 26:24
duly 48:7
E
E 2:1,8
earlier 13:21
27:11 36:1 45:3
East 3:14 4:4
50:4
eat 31:18
eating 33:22
46:10
economics 9:16
eight 31:17
either 14:6 28:11
31:20 33:10
electrical 26:2
emergency 17:3
employed 48:11
48:15
employee 48:14
employees 10:6
enclosed 50:8,9
Enclosures 50:24
enjoyable 40:25
Fax: 314.644.1334

Page 55
Ensures 31:17
entire 24:8
errata 50:9,12,15
51:1
estimate 45:4
event 33:13
eventually 35:20
exact 43:23
exactly 19:18
20:3
Examination 2:4
5:12
examined 3:11
5:10
Executed 52:14
exercise 37:19
exercises 37:22
37:23,24
Exhibits 2:10
expect 45:16
expenses 26:24
43:17,21 44:2,3
44:5,6,14,22
45:5,23
experience 10:13
13:8 25:12
Expires 49:24
52:24
explain 46:14
explained 43:16
exposure 12:5
expressly 5:7
extent 5:22 10:20
46:21
farmed 10:17
farming 10:13,18
12:5
fault 30:6
FAVOR 49:10
49:11
FAX 4:5,11,19
fed 32:15 33:4
feed 31:15 33:6
33:15
feeding 38:23
feel 45:13
feeling 41:3
females 11:18
fence 22:19
field 12:18,18
Fifth 3:14 4:4
50:4
figure 26:22
filing 50:16
financially 26:19
39:23 48:16
find 16:20 47:1
50:8
fine 31:10 47:6
fingers 25:24
32:19
firm 49:7
first 10:25 12:7,9
24:2
fixed 20:8
flight 16:13
Ford 4:9 49:8
foregoing 48:6
52:6,13
F
fork 32:17
fact 14:12,23
form 52:7
15:4 16:20
four 17:12,15
fair 11:3,19 24:7 Fred 18:25 19:13
40:25
19:17,25 20:11
fairs 11:2
21:19,21
family 11:8,23
Freddie 18:24
far 25:22 36:18
frequent 40:24
farm 10:15 11:23 friends 28:6
14:12,15,17
front 35:23
15:1 29:17,18
full 5:14
fully 32:23
full-time 10:7
funeral 28:24
29:2
further 47:5
48:13
G
GAMBLE 4:13
garden 20:7
general 29:15
43:24 45:3
generally 11:14
11:15
getting 37:8
give 9:3 36:11
37:3,22
given 5:23 20:6,7
giving 24:17
25:19
go 7:21 15:14
17:17 26:6
28:22 31:8 42:2
43:18
going 15:1,9,12
15:13 31:14
33:2,14 41:21
42:8 47:2
good 9:4,5,5
17:16
gotten 20:19,20
36:19 37:15
grandkids 26:10
grew 8:14
guess 37:22
H
H 2:8 4:9 49:8,10
habits 38:3
hand 25:5 31:13
32:16,19,21,25
33:1,4 37:13,16
37:23,24
handle 25:24
happened 19:4,5
19:13 21:6,8
23:22 30:7
happens 36:15
happy 33:2
hard 24:19
headed 15:2
heal 32:2
healed 35:9,13
health 34:14
hear 6:6,7
heard 23:9,12,15
23:16,18 24:2,8
24:10 29:7
heavy 39:10
heifer 10:25
helicopter 18:7
help 12:17 26:5,6
28:21 35:14
helped 37:2
helping 36:23
high 8:25
highly 16:4
highways 12:20
12:21
hire 26:5
hired 38:16,18
38:19
hold 9:20 32:17
holding 14:7
30:17
home 9:16 10:10
15:14 19:24
31:5 34:3,14,22
35:9,10 36:4
37:7,15,18
38:14
Homemade
28:16
honey 33:23,24
hospital 17:5
25:2 26:19 28:3
30:3 31:24
34:14 44:13
46:9
hospitalization
46:5
hour 24:15,25

Phone: 1.800.280.3376
hours 3:12 32:4,6

house 38:19
hurt 16:24 21:14
28:10 30:13
hurting 25:8
husband 5:18 6:4
9:23 13:3 22:21
30:9 40:22
42:15 43:4
I
idea 27:1 29:25
ideas 29:15
impossible 26:4
improved 37:16
incident 21:18,23
23:1 26:25
42:10 44:7
incidents 20:13
20:13 22:5
included 44:8,9
incurred 45:24
indicate 50:11
indicated 45:3
infrequent 12:22
injured 13:20
16:21 21:13
41:16
inquisitive 18:10
instance 38:18
insurance 17:16
17:18 44:24
intention 29:11
interested 48:16
interrogatories
27:13,17
involved 10:21
12:11,24 26:13
involvement
12:15
involving 22:5
23:1
Islands 7:5
isometric 37:25
J
Fax: 314.644.1334

Page 56
J 1:2,6 3:2,6,15
3:20,21 4:16
5:4 48:3,22
49:2,3 50:5,5
50:22 51:2,2
jblaylock@fpb...
4:12
Jeffrey 4:9 49:8
49:10 50:16
jmartin@mid...
4:19
job 12:13
John 1:6 3:6,21
16:22 17:9,23
18:4,18 21:17
21:22 27:22
28:5 29:20 30:6
49:3 50:5 51:2
John's 22:21
27:22,23
Joyce 1:3,17 2:3
3:3,10,20 5:9
5:16 17:15 49:2
49:6 50:5,8
51:1,2 52:5,20
Judy 22:10,13,21
42:10,16,20,24
Julie 7:15
June 6:21
know 5:21 6:6,9

6:21 8:19 12:3
13:11,11 16:11
17:20 18:10
20:6,9,9 21:7,8
21:14,15,17,20
21:24,25 22:9
22:12 23:15
24:17 25:2 26:3
26:12,14,15,22
29:1,19 30:22
31:17 32:8 37:9
37:21 40:5,5,7
43:20,23,24,25
44:23 45:3,7,10
45:12,15,20,22
45:25 46:2
knowledge 7:23
14:16,21 23:5
23:21 24:13,22
29:19,22
known 30:17
50:6 51:2
Martha's 30:6
Martin 3:15 4:16
5:4 48:3,22
50:22
ma'am 5:15 8:2
18:22 43:10
meal 33:5
mean 20:13 23:1
25:24 30:22
41:12 45:21
medical 19:10
26:24 43:17,20
44:5,6 45:5,24
Medicare 44:23
44:25
medication 24:18
25:4
medications
24:14,23 25:7
medicine 24:21
meeting 22:10
MEMO 49:1
L
Memorial 17:4
Lake 7:12 39:19
men 12:13
law 3:13
mention 15:16
lawful 5:10
20:12 29:4
M
lawsuit 43:13
mentioned 9:23
leave 16:24
machinery 26:7
15:5,20 35:14
left 16:6,11 18:7 major 9:15
39:8 42:10
K
32:9 34:12,14
majority 26:20
46:17
Kansas 15:2
leg 37:21
making 45:14
metal 41:3
keep 33:10
length 25:10
males 11:17
MIDWEST 4:14
Kempton 3:14
let's 41:2
manner 22:8
4:17 49:17 50:1
4:3,3 15:21
licenses 9:20
March 20:5
mile 8:5,6
27:5 29:13
life 10:17 32:22
marital 40:21
miles 8:13
30:19 41:9 47:7
40:13
Marked 2:9,10
milk 13:11,20,23
49:11 50:3,3,7 limitations 25:11 married 6:16,20
14:3,5 15:11,13
KENNY 4:13
Line 51:4,8,12,16
10:17,19 12:4,6
16:16,18 28:17
kept 32:17,19
51:20
13:4 40:13
milked 13:10
Kevin 7:2
lines 31:14
Marshall 44:17
milking 11:6
keys 16:25
Lisa 7:9
44:18
14:6
kind 18:10 30:8
list 43:22
Martha 1:6 3:6
Missouri 1:1 3:1
46:8
listened 23:24
3:21 18:4,6,19
3:15,18,20 4:4
knew 8:18 25:1
LITIGATION
21:18,22 28:6
4:10,18 8:3,9
30:21 33:1
4:14,17 49:17
29:20 30:2 49:3
8:23 9:8,24
50:1
little 22:20 25:22
25:22 31:22
live 7:3,11,16,24
22:16 38:13
lives 7:12,18
living 32:25 37:5
38:21
local 44:18
located 8:9 35:2
Locust 4:17
long 10:3 29:18
33:6 34:5,7
longer 25:24
look 27:7
looked 27:9,16
looking 46:7
lost 25:16
Louis 49:19
Louisiana 7:13
lunch 16:11
lungs 35:4
Luscombe 1:6
3:6,21 21:17,22
42:10 49:3 50:6
51:2

Phone: 1.800.280.3376
48:5 49:1,9,19
50:4
misunderstood
42:13
Moberly 31:21
month 19:9,9,11
34:10 36:16
monthly 40:2
months 34:9
44:12 46:12
morning 15:1,8
16:7,15,16
19:19 25:11,14
mother 29:2
mother's 28:23
mouth 41:1
move 38:10
moving 12:17
N
N 2:1 49:18
nails 25:22
name 5:15 10:1
49:7 51:1,2
52:11
names 7:1
Napton 8:3,4,6,9
nature 28:13
nearby 14:7
necessarily 28:12
37:23
necessary 52:9
neck 35:17
need 6:8 27:18
27:20 40:10
needed 12:17
needs 26:6,21
neither 48:11
never 11:2 13:22
14:2,22 17:18
23:7 26:7
night 32:10 38:9
38:12
normal 24:11
49:15
north 8:6
Fax: 314.644.1334

Page 57
notarized 50:15
notary 5:5 49:23
50:13 52:23
noticed 38:4
44:10
November 50:2
nurse 34:14
nutrition 32:1
45:11,13 46:3
old 7:6,10
once 36:16 38:12
operated 10:3
operation 10:19
12:6,15
opinions 29:11
ordinary 30:23
original 49:8
50:9
outcome 48:17
outside 10:10
out-of-pocket
26:23 45:5,23
overall 26:16
owned 13:5
30:8 49:7
personal 23:5
42:24
personally 29:1
44:1
Pettis 1:1 3:1,19
7:24 49:1
physical 25:11
39:9
O
physician 46:3
objected 15:23
46:14,24
Objection 15:21
physicians 44:19
observations
pick 15:2 16:18
25:14
picked 13:23
obtain 9:11
14:3 44:13
occasion 37:13
pickup 27:23,23
occupations
pies 28:16,16,17
P
10:10
place 19:7,23
occurred 17:9,11 packet 27:4,7
Plaintiffs 1:4 3:4
18:5,14,18,20
page 2:2 50:9,13
4:2 5:2
20:14 22:6
50:16 51:4,8,12 play 24:7
October 1:18
51:16,20
played 24:4
3:11 49:6 50:8 paid 49:14,14
please 5:14 6:6
51:3
pain 24:14,18,20
50:8,10,15
offer 29:11
24:21,23 25:6
point 18:9 25:8
OFFICER 49:5
25:11 36:12
27:1 42:4 43:21
offices 3:13
Parshall 4:9 49:8 pole 26:12
Oh 8:12 27:6
part 39:4
portion 24:8 44:2
okay 6:15 7:6,8
parties 48:12,15 prepare 27:2
7:14,21,23 8:7 partnership 12:9 prescription
8:8,12,16,21,24
12:12
26:24 45:24
9:17,20 10:9,12 pasture 22:16,18 prescriptions
10:16,24 11:11
42:11
45:16
12:10,19 13:19 pay 39:23 44:21 pretty 34:20 35:9
14:1 16:3,14
paying 26:20
35:13
18:12,25 19:6
pays 40:1
primarily 11:4
20:23 22:4,11
pen 14:7 30:17
printing 5:6
27:16,24 28:5
penalty 52:12
prior 20:12 21:8
28:10,18,25
pending 3:18
22:25 23:1
29:19 31:11
6:10
29:20 50:16
32:7,10,12,12
penny 43:23
probably 13:11
32:14 33:18
people 38:18
15:7 17:14
34:11 36:5,9
period 9:8 24:15
18:23 19:8,10
39:11 40:8,15
24:25
19:24 34:10
41:4,20 42:19
perjury 52:12
procedure 35:7
43:5,12 44:21
person 16:17
procedures 45:17
process 43:19
produced 3:11
5:10
production 10:22
27:14
Professional 3:16
48:3
program 37:19
progress 32:24
progressed 31:7
provide 31:1,5
38:14 39:9
pry 40:9
public 5:5 49:23
50:13 52:23
purse 16:25
put 35:4 36:7,13
36:20,23 41:1
p.m 1:20 3:12,13
47:11
51:14,18,22
received 45:1
recollection
19:16
record 5:15
41:24 42:1 47:9
recording 23:10
23:12,13,16,17
23:19,22,24
recordkeeping
12:16
reduced 48:9
referring 35:25
40:21
regard 33:21
regarding 43:12
Registered 3:16
11:5,7 48:3
regular 36:17
Rehab 24:1
related 45:5
Q
48:11
quarter 8:5,6
relating 44:6
question 6:5,10
relation 8:12
6:12,12 40:9
relations 40:21
questions 5:13
relationship
42:2 47:8
28:14 40:11,23
quick 41:22
relative 48:14
quiet 17:14
relatives 7:24
quite 16:22
reluctant 25:6
remember 13:15
R
13:17 14:10
raise 11:4
16:6,10,12
raised 8:1 10:15
17:10,11,12,15
10:23 11:1 13:3
17:22 18:1,8,15
Randall 7:2
19:6,14 20:3
Randy's 16:12
34:7 36:22,23
read 27:2 47:7
render 52:9
50:10 51:5,9,13 repaired 26:1
51:17,21 52:6
rephrase 6:7
real 41:22
REPORTED
realize 24:10
4:15
realized 32:23
Reporter 3:16,17
really 45:10
6:13 48:4,4
reason 19:25
Requests 27:13
20:10 51:6,10
require 33:20

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 58
35:8
required 35:12
49:14
requires 39:5
reserved 5:7
resolved 46:20
respect 29:2
respond 6:12
responses 27:17
responsible 44:1
result 31:2,3 45:6
45:25 46:4
results 46:6
return 50:15
ride 17:2
right 8:17 12:23
13:24,25 15:4
15:15 17:6
22:24 27:12
32:11 34:4,20
35:18,19 40:3
40:19,22 41:23
42:4,12 45:19
risks 30:10
Robert 1:2 3:2
3:20 5:18 6:16
49:2 50:5 51:2
rode 17:2
room 17:3
RPR 4:16 5:4
48:22 50:22
RSMO 49:5
Rule 49:5
Rusk 24:1 25:3
31:6 32:13 33:7
33:16 34:19
Russell 3:14 4:3
50:3
S
S 2:8
Saline 8:11
San 7:18,19
39:19
Saran 34:24
sat 5:22
saving 32:22
saw 27:25 28:20
saying 17:10,15
18:8 32:20
says 5:11
scan 44:11
scars 35:6
school 8:25
scope 44:17
screws 25:23
Sec 49:5
Sedalia 3:15 4:4
50:4
see 14:4,20 21:15
25:17 27:21
37:17 38:2
seeing 14:10
seen 14:22 23:7
25:18 26:5,6
36:7 38:1 43:22
sensed 17:14
sent 27:11 36:4
46:6
SERVICES 4:14
4:17 49:17 50:1
SHEET 51:1
sheets 50:9,12,15
shoes 37:10
shop 9:24 16:23
26:1
short 41:22
shorthand 5:4
Shorthorn 11:5,5
11:6,7 13:14,16
show 11:2
showed 11:1,2
shower 34:25
showering 34:23
side 35:3
sidewalk 22:10
sign 47:8 50:12
signature 5:6
47:6 50:9,12,16
51:24
signed 27:7
significant 33:13
Sincerely 50:19
single 18:11
sip 31:18,25
sir 14:19,22 23:4
23:7,20,23 24:6
29:9 30:4
sit 33:19 42:4
sits 40:1
situation 11:20
13:4 42:8,15,25
43:6
six 31:17
skirt 22:15
sleep 38:3,5,6
small 42:20
Smith 1:6 3:6,21
18:4 21:18,22
23:11,14 49:4
50:6 51:2
socialize 28:11
son 15:3,14 22:21
sorry 13:18 16:8
17:8,17 20:5
27:6 28:22 33:9
36:12,22 43:3
sort 28:15 31:4
38:23 40:2 42:1
sounded 24:11
speaking 11:15
special 33:23
specific 24:22
39:7
speculation
15:22 30:20
spent 26:23
spoken 41:6,15
41:18
sports 26:11,11
26:13
squeeze 32:18,19
St 7:4 49:19
started 8:23
28:20
Starting 1:20
state 1:1 3:1,17
3:19 5:14 11:3
48:4 52:1
statement 23:10
23:13,25 24:8
24:16 49:5
step 41:22
stipulated 5:1
stopped 46:23
store 9:24 38:18
Street 3:14 4:4
4:17 49:18 50:4
strength 25:20
33:4
Stress 40:14
stretching 37:25
stuff 39:23
subscribe 52:11
substance 52:8
suffer 31:3
suggesting 16:5
Suite 4:17
supplement
27:19
supplemented
27:19
supposed 31:16
sure 6:11 11:10
18:2 39:3 44:25
surgical 33:24
35:7
suture 34:12
swallowing 46:18
46:25
sworn 3:11 5:10
48:7
system 46:11
33:25 48:8,13
50:8 51:3
takes 30:10
talk 29:7
talked 18:18,19
38:17 41:10
43:1,4
talking 30:23
34:9
tape 23:9 34:25
TAXED 49:10,11
tell 10:14 15:9
19:2 20:17 21:3
21:6,9,12,21
22:1,13 31:4
33:8 42:19
telling 17:12
32:17 42:9
Ten 10:5
terms 40:12
testified 6:1
13:21 25:10,13
36:1
testimony 42:3
48:6,8
therapy 24:18,19
thereon 52:10
thereto 48:15
thing 17:11
18:11 27:25
28:15 30:15
38:24 39:7 40:2
40:16 43:18
things 10:22 26:1
26:2,3,6,9,10
26:12,20 28:20
T
34:17 38:1,17
T 2:8 4:3 49:11
40:18
50:3
think 9:1 14:9
take 6:8,14 19:22
15:11 26:9 27:8
23:6 25:6 29:10
28:1,23 33:24
34:13,25 41:21
35:11,12 40:18
42:23
41:20 42:5 47:4
taken 5:4 23:10
third 7:14
23:25 24:14
Thomas 7:4
25:9 26:19,21
thought 17:18

Phone: 1.800.280.3376
Fax: 314.644.1334

Page 59
44:12
thousand 20:4
thousands 45:9
threatened 11:20
11:25 13:6
three 6:25 44:11
46:12
throat 44:17 47:3
tie 37:10
tied 31:13
time 1:20 6:15
9:9 10:11 13:2
16:6 21:16 24:3
26:18 27:18
31:7,12,22
33:16 35:10
36:6,6,7,8,9
37:1,20,20 45:2
47:11
times 16:9 17:13
17:15 46:22
tired 24:10
today 10:8 24:2
27:3 33:21
told 14:16 15:7
15:12 17:12
19:17,18 20:18
21:22 22:9 25:2
30:5 41:6,15
42:9,16 46:3,24
TOTAL 49:11,12
traded 28:17
trading 31:23
transcribed 5:6
transcript 49:8
49:13 50:11
Treasures 10:2
trial 29:12 50:17
tried 31:22
trip 18:12
trips 39:19
true 52:9,13
try 6:6
trying 6:14 25:4
tube 47:2
tubes 33:25 35:4
two 6:19 7:8 9:10

10:19 13:3
18:13 20:4
40:18
type 37:18
typewriting
48:10
U
Uh-huh 35:16
UMC 34:18
uncomfortable
36:13 39:16
understand 6:5,8
14:14 22:6 46:1
understanding
14:24
understood
20:22
University 8:22
9:8 18:7 31:9
32:3,18,20 36:4
unnecessary
30:10
upper 35:18
upset 17:13
use 21:2 33:23
36:5 37:16
usually 16:15,17
38:11 39:13
V
variation 19:20
vaulter 26:13
VIDEOGRAP...
4:13
VIDEOTAPED
1:17 3:10
Virgin 7:4
voice 24:11,12
vs 1:5 3:5,21 49:3
50:5 51:2
W
wait 6:11
walked 14:8
want 6:21 15:22

31:8 40:25 42:5
43:23 47:6,7
wanted 17:2
wants 25:20
wasn't 16:5
17:19 18:9 33:2
46:10
water 44:16
way 6:13 17:7
42:6
wearing 35:17
weeks 34:9
went 8:22 9:7
12:9,12 16:25
17:21 28:23
29:2 32:13
we're 41:25
whack 46:11
whatsoever
19:20 31:16
wife 40:22
wiring 26:2
witness 5:7 9:4
15:23 27:6
30:21 41:12
48:5,8 50:10
51:1,24
wondering 17:19
word 21:2
words 20:21
28:14 41:1
wore 36:10
work 11:11 25:5
32:16 33:1
working 13:8
15:17,20,24
37:14
works 5:21
worried 32:22,25
worry 17:16
worth 43:17
wouldn't 17:1
30:22
wounds 33:22
34:24 35:2,7
wrap 34:23,24,24 3210 4:10 49:9

write 33:9
4
written 27:10
4-H 8:20 10:23
wrong 32:21
40 8:13
X
401 4:17
X 2:1,8
492.590 49:5
Y
Yeah 38:8 39:15
41:11 44:9
year 36:2,20
years 9:10 10:5
12:7 13:5
young 22:22
42:15
1
10 8:15
11th 49:18
114 3:14 4:4 50:4
12 8:15
13CO-CC0000...
1:5 3:5 49:3
1962 6:21
1985 49:5
5
5 2:4
57.03(g)(2)(a)
49:5
573-449-0561
4:18
573-449-2613
4:11
573-499-0811
4:19
573-875-8154
4:11
6
6 50:2
60 9:1
63 7:7
63101 49:19
65201 4:10,18
49:9
65301 4:4 50:4
66 7:13
660-827-0314 4:5
660-827-1200 4:5
69 7:22
2
2:33 1:20 3:12
20 52:15
2012 20:14 22:7
23:2 29:5,8
2013 20:5
2014 1:18 3:12
7
49:6 50:2,8
51:3
711 49:18
204 4:17
24 1:18 3:11 6:21
24:15,25 49:6
50:8 51:3
3
3:23 3:13 47:11
30 8:13 20:14
22:7 23:2 26:25
29:5,8
300,000 43:25

Phone: 1.800.280.3376
Fax: 314.644.1334

Joyce Doty Deposition

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Joyce Doty Deposition

Uploaded by

Copyright:

Available Formats

JOYCE A.

IN THE CIRCUIT COURT OF PETTIS COUNTY

VIDEOTAPED DEPOSITION OF JOYCE A. DOTY

ROBERT J. DOTY and )

J. D. MARTIN, RPR, CCR

MIDWEST LITIGA TION SERVICES

JOYCE A. DOTY 10/24/2014

It is hereby stipulated and agreed

Q. And what are their names and ages?

Q. Have you ever testified in court

Q. Where were you born and raised,

MIDWEST LITIGA TION SERVICES

JOYCE A. DOTY 10/24/2014

In '60, I think it was.

raised cattle. And we showed cattle. I only

What is the name of that?

And how long have you operated

Not that I know of.

Then after you and Bob married and

Bob continued farming, what was your exposure to

Do you have any employees?

the cattle operation after you were married?

None full-time. I have one there

Okay. Do you have any other

occupations outside of the home?

Well, for the first few years we

had our own cattle. We had our own cattle at

first before it went into the partnership.

And then I was involved less when

Not at this time.

Okay. Do you -- well, I assume you

it went into the partnership, because there was

have farming background experience. But can you

tell me what that is?

Well, I was raised on a farm.

What was the -- what would your

involvement in the operation?

We farmed all of our married life.

Other than if they needed help moving cattle

You assisted Bob with his farming

from field to field --

operation after the two of you were married?

I would say mostly recordkeeping.

Yes. To some extent. Not to --

Did you get actively involved in

highways or whatever like that.

I raised cattle in 4-H.

-- that you would get involved

I bought my first heifer and then

the cattle production end of things?

That would be rather infrequent --

MIDWEST LITIGA TION SERVICES

JOYCE A. DOTY 10/24/2014

that Bob was going to the farm that morning

from doing that?

MIDWEST LITIGA TION SERVICES

JOYCE A. DOTY 10/24/2014

car, and he wouldn't let me drive my car. He

you just don't remember it?

MIDWEST LITIGA TION SERVICES

JOYCE A. DOTY 10/24/2014

attacks someone, that would be my assumption of

the word I would use.

Did he tell you that the bull