Excerpts from deposition of Mr. Cerrito

I work at the South Bend Tribune in the warehouse--I run a forklift to move pallets of paper and printed newspapers around. I've had this job since 1995.

My wife and I rented the house at 857 Forest back in 1996. We had been living with my parents and what with the baby and all we wanted a place of our own. We just loved it on first sight, plus it is close to the park and to Madison Elementary. It was in good shape, especially compared with some of the dumps we'd seen earlier. The rent was reasonable.

I don't really remember signing all the paperwork--it was three years ago. I might have signed a waiver or something about lead in the paint, but I really just wanted to sign the lease and get my family moved in. Whatever she (Ms Mount) gave me, I signed it. In retrospect that wasn't so smart, but at the time I just wanted to get moved in.

Of course I speak English--I was born in Finley, Ohio. We speak English at home. Yes, I can read perfectly well. Well, reading is not my strong suit, I am not what you'd call a pleasure reader.

Did I understand the EPA brochure? Frankly, I just glanced through it, it didn't seem relevant at the time since Johnny wasn't even walking then and he had no teeth to chew on the paintwork with. We put the thing away in a folder with the lease and I don't think I ever looked at it again until Dr. Hadley gave Maria another one. Science was never my strong subject in school. I mean, it's 16 pages long, and first it says lead paint is very dangerous, then it says you can look perfectly healthy and have lead poisoning, then it says taking the paint out is extremely dangerous.

We didn't realize anything was wrong with Johnny (John Jr.) until Dr. Hadley had him tested. He is our first child, you know how that goes--the kid does something wierd, like chewing on a table leg, and you're never sure if there is something really wrong with the kid, or if all kids do that.

The hospital was just a nightmare--they have to give the chelation with a really long needle, plus apparently the stuff stings like crazy. They have to mix it with local anaethetic. Johnny was scared, of course, how else should he have felt? They're waking him up at 4 in the morning to give him painful injections...my wife or I stayed in the room and slept in a chair. I lost two days of work. Well, we thought it was worth it because it got rid of the lead, but then 2 weeks later it was back again.

My hobbies? Well, I like to build model airplanes, I also do a little stained glass. I took a class in 1994 and sort of got hooked. I do my hobbies in the little greenhouse, and I have a baby gate to keep Johnny out. He likes to watch me, but he isn't allowed in there due to the glass splinters from cutting the glass and the delicacy of the models. If he got in, he would probably eat some little plastic parts or put epoxy in his hair, so he just has to hang on the gate and watch me.

No, I have never been tested for lead poisoning. Return to facts in the case