Document 2JBG0wy46R3ZnbLv9V2D2wqjb

John Katzbeck January 24, 2008 IN THE CIRCUIT COURT OF KANAWHA COUNTY, WEST VIRGINIA Page 1 LORRAINE JAMROM , an individual, Plaintiff, vs. CASE NO. 07-C-795 A.W. CHESTERTON COMPANY, et al., Defendant. TELEPHONIC DEPOSITION OF: DATE: TIME: LOCATION: TAKEN BY: REPORTED BY: JOHN KATZBECK January 24, 2008 10:19 p.m. Offices of A. William Roberts, Jr. 1201 Main Street Columbia, SC Counsel for the Plaintiff Susan M. Valsecchi, CRR Registered Professional Reporter Computer-Aided Transcription By: A. WILLIAM ROBERTS, JR., & ASSOCIATES Charleston, SC (843) 722-8414 Greenville, SC (864) 234-7030 Myrtle Beach, SC (843) 839-3376 Columbia, SC (803) 731-5224 Charlotte, NC (704) 573-3919 A. William Roberts, Jr. & Associates (800) 743-DEPO John Katzbeck January 24, 2008 1 APPEARANCES OF COUNSEL: 2 ATTORNEYS FOR THE PLAINTIFF LORRAINE JAMROM, an individual: 3 AARON J. DELUCA, PLLC 4 BY: AARON J. DELUCA 21021 Springbrook Plaza Drive, 5 Suite 150 Spring, Texas 77379 6 866-435-1831 aarondeluca@aarondeluca.com 7 8 9 ATTORNEYS FOR THE DEFENDANT SQUARE D COMPANY: 10 ORNDORFF & HATFIELD 11 BY: JON ORNDORFF 418 Eleventh Street, Suite 202 12 Huntington, WV 25701 304-781-5656 13 Jorndorff@oandhlaw.com - and - 14 KIRKPATRICK, LOCKHART, PRESTON, GATES, ELLIS, LLP 15 BY: MICHAEL J. ZUKOWSKI 535 Smithfield Street 16 Pittsburgh, PA 15222-2312 412-355-6397 17 Michael.zukowski@klgates.com 18 19 20 ATTORNEYS FOR THE DEFENDANT UNION BOILER: 21 MARKS, O'NEILL, O'BRIEN & COURTNEY 22 BY: DANIEL R. BENTZ (TELEPHONIC) Suite 2600 Gulf Tower 23 707 Grant Street Pittsburgh, PA 15219 24 (412) 391-6171, ext. 2021 dbentz@mooclaw.com 25 1 ATTORNEYS FOR THE DEFENDANT PNEUMO ABEX: 2 CAMPBELL WOODS, PLLC 3 BY: CHARLES F. BAGLEY III (TELEPHONIC) 517 Ninth Street, Suite 1000 4 Huntington, WV 25719-1835 304-529-2391 5 cbagley@campbellwoods.com - and - 6 CELBA, DES, ROCHERS BY: STEVEN CELBA 7 4493 N. Prospect Avenue Milwaukee, Wi 53211 8 scelba@celba.com 9 ATTORNEYS FOR THE DEFENDANT WEIR HAZLETON, INC., 10 HAZLETON PUMPS, INC: 11 SHUMAN, MCCUSKEY & SLICER, PLLC BY: JASON WANDLING (TELEPHONIC) 12 1411 Virginia Street East Suite 200 13 Charleston, WV 25301 304-345-1400 14 jwandling@shumanlaw.com 15 ATTORNEYS FOR THE DEFENDANT 16 GENERAL ELECTRIC: 17 FARMER CLINE & CAMPBELL, PLLC BY: KIMBERLY A. MARTIN (TELEPHONIC) 18 746 Myrtle Road Charleston, WV 25314 19 304-346-5990 kamartin@fcclaw.net 20 ATTORNEYS FOR THE DEFENDANT 21 MAGNETEK, INC.: 22 DINSMORE & SHOHL BY: DAVID J. SINGLEY (TELEPHONIC) 23 One Oxford Centre, Suite 2900 301 Grant Street 24 Pittsburgh, PA 15219 (412) 288-5868 25 david.singley@dinslaw.com 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 Page 3 24 25 1 2 3 4 5 6 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ATTORNEYS FOR THE DEFENDANT SHEPARD NILES: WILBRAHAM LAWLER & BUBA BY: WILLIAM D. HAGUE (TELEPHONIC) 603 Stanwix Street Two Gateway Center, 17N Pittsburgh, PA 15222 (412) 255-0568 whague@wlbdeflaw.com ATTORNEYS FOR THE DEFENDANT AMERICAN STANDARD, INC. AND VIMASCO CORPORATION: JENKINS FENSTERMAKER, PLLC BY: BRIAN S. LINDSAY (TELEPHONIC) 401 11th Street Suite 1100 Huntington, WV 25701 304-523-2100 BSL@JenkinsFenstermaker.com ATTORNEYS FOR THE DEFENDANT VALSPAR CORPORATION: STEPTOE & JOHNSON, PLLC BY: J. GREG GOODYKOONTZ (TELEPHONIC) Chase Tower - Sixth Floor 229 West Main Street Clarksburg, WV 26301 304-624-8000 greg.goodykoontz@steptoe-johnson.com ATTORNEYS FOR DEFENDANT: GOULDS PUMPS: WATERS, WARNER & HARRIS, PLLC BY: BRANDY BELL (TELEPHONIC) 321 W. Main St. 701 Goff Building Clarksburg, WV 26301 (304) 624-5571 bbell@wwhlaw.com (INDEX AT REAR OF TRANSCRIPT) Page 4 Page 5 (PLF. EXH. 1, Plaintiff's Notice of Deposition Duces Tecum, was marked for identification.) (PLF. EXH. 2, a letter to Cathy Gatson, Circuit Clerk, dated 1/22/2007 from J. Phillip Fraley with attachments, marked for identification.) JOHN KATZBECK being first duly sworn, testified as follows: EXAMINATION BY MR. DELUCA: Q. State your name, please. A. John W. Katzbeck. Q. Mr. Katzbeck, my name is Aaron DeLuca. I represent the Plaintiff in this action. Have you had a chance to review the Notice of Deposition that's been marked as Exhibit 1? A. Yes. Q. Are you prepared to speak to some of the issues set forth in that Notice of Deposition today? A. Yes. Q. And do you understand that you're here today as a corporate representative of Square D? 2 (Pages 2 to 5) A. William Roberts, Jr. & Associates (800) 743-DEPO John Katzbeck January 24, 2008 Page 10 Page 12 1 involving cases where Square D had been named as a 1 that it sold under its name; is that correct? 2 defendant in a lawsuit? 2 A. We made the brakes. Square D 3 A. Yes. 3 manufactured the brakes. 4 Q. Did any of those other depositions 4 Q. Okay. I guess maybe it's very 5 involve Square D's product line of crane controls, 5 important that I be sure that we're all using the 6 brakes, panel boards, anything like that? 6 same terms and terminology. 7 A. Not that I can recall. 7 The crane brakes were made by Square D 8 Q. Without getting into the details of 8 but the friction material was made by another 9 those cases, can you just tell me -- give me an 9 company; is that true? 10 overview of what types of cases they were? 10 A. That's correct. 11 A. Personal injury cases, property damage 11 Q. And when we talk about crane brakes, 12 cases, dealing with motor control products, push 12 what pieces of equipment comprise a, quote, crane 13 buttons, medium-voltage motor controllers, things 13 brake, end quote, as you use that term? 14 of that nature. 14 A. It's -- if I understand you correctly, 15 Q. Okay. Have all of those been within 15 it's an assembly of -- essentially consisting of an 16 the last ten, fifteen years? 16 electromagnet, a clapper arrangement with 17 A. I would say fifteen. Let me see. That 17 mechanical linkages that -- and springs -- that 18 would bring me back to 1992, '93, maybe the last 18 18 then function as essentially to clamp a brake wheel 19 years. 19 with the brake shoes. 20 Q. Okay. All right. Have you reviewed 20 Q. So if I were to use the term brake 21 any of the testimony of Lorraine Jamrom or Dimitri 21 assembly, that would consist of all the different 22 Novickoff taken in connection with the case that 22 parts that you identified, including the 23 we're here to talk to you about? 23 electromagnet, the clapper arrangement, the 24 A. Yes. 24 mechanical linkage, springs, and the actual brakes 25 Q. Have you reviewed both Mr. Novickoff's 25 which have a friction material component? Page 11 Page 13 1 testimony and Ms. Jamrom's? 1 A. The brake shoes and brake lining. 2 A. Yes. 2 Q. Am I correct that the only potential 3 Q. What do you understand the allegations 3 source of asbestos in all of those items would be 4 against Square D to be in this case? 4 in the brake lining? 5 A. My understanding is that the allegation 5 A. The brake. 6 is related to asbestos exposure on clothing due to 6 MR. CELBA: Objection, foundation. 7 crane brakes, exposure to crane brakes. 7 MR. DELUCA: Can I ask you who you are? 8 Q. Do you have an understanding as to the 8 MR. CELBA: Abex. 9 medical condition that the Plaintiff alleges that 9 MR. DELUCA: Okay, thank you. 10 she has? 10 THE WITNESS: As I understand it, the 11 A. Yes, mesothelioma. 11 brake linings could potentially have contained 12 Q. What do you know about mesothelioma? 12 asbestos. There's also some power wiring that is 13 MR. ORNDORFF: I'm going to object as 13 connected to the electromagnet that extends the 14 far as he's not a medical expert and not offered as 14 short distance, a matter of inches, outside the 15 such. 15 magnet case and where you would connect external 16 MR. DELUCA: I understand. 16 wiring to it. That wire that extends from the 17 THE WITNESS: It's a disease affecting 17 magnet case could possibly have an asbestos 18 the lungs or the areas surrounding the lungs. It's 18 insulation. I don't know. 19 very bad. 19 BY MR. DELUCA: 20 BY MR. DELUCA: 20 Q. Okay. That's fair enough. Any other 21 Q. Have you known anyone that's had 21 possible or potential components of the brake 22 mesothelioma? 22 assemblies that historically have had asbestos in 23 A. No. 23 them? 24 Q. Now, as I understand from your prior 24 A. Well, to the extent that they may have 25 testimony, Square D did not make the crane brakes 25 had, that's all I can -- I can say. 4 (Pages 10 to 13) A. William Roberts, Jr. & Associates (800) 743-DEPO John Katzbeck January 24, 2008 Page 14 Page 16 1 Q. What can you tell me about the history 1 correctly, please let me know. But there's a WB 2 of Square D? 2 style brake assembly? 3 A. Square D was founded in the early 1900s 3 A. Yes. 4 and existed under several names, in about 1917 4 Q. And an AT style brake assembly. 5 changed its name to Square D, and then has grown to 5 A. Correct. 6 this day. 6 Q. I understand the AT brake assembly 7 Q. All right. I understand in 7 stands for adjustable torque; is that right? 8 about -- was it 1955 -- that Square D entered the 8 A. Yes. 9 crane brake segment of industry? 9 Q. What does that mean? 10 A. Well, that -- that's when they 10 A. It means that the brake is capable of 11 purchased EC&M. 11 multiple holding forces, if you will. It can clamp 12 Q. Prior to Square D's purchase of EC&M, 12 at a certain pressure and then clamp at another 13 Square D was not in the business of selling crane 13 pressure on the brake wheel. 14 controls; is that fair? 14 Q. All right. And is the WB style brake 15 A. I think generally fair, yes. And to 15 assembly different than the AT? 16 just -- I do have some recollection of Square D 16 A. There are -- yes, it's -- it's -- it 17 attempting to do some crane control panels 17 shares a lot in common with the AT but the AT has 18 business, but it just was not -- 18 some extra features on it, yeah. 19 Q. Prior to the purchase of EC&M? 19 Q. Okay. Are there any other styles of 20 A. I believe I'm correct in that. 20 brake assemblies sold by Square D between 1955 and 21 Q. At the time Square D purchased EC&M, 21 2003 other than the WB style and the AT style? 22 was EC&M already in the business of manufacturing 22 A. Um, yes, yes. Very late in the Square 23 crane controls? 23 D history towards 2002, 2003, they were developing 24 A. Oh, yes. 24 a disk-type brake. 25 Q. Including brakes? 25 Q. That would have been years after any of Page 15 Page 17 1 A. Yes. 1 the friction material in the Square D brake 2 Q. And brake lines? 2 assemblies contained asbestos, correct? 3 A. Well, they didn't manufacture brake 3 A. That's correct. 4 lines, but... 4 Q. So for purposes of this case, we 5 Q. They, like Square D, bought them from 5 probably need not discuss that; is that right? 6 another company and incorporated them into their 6 A. That's correct. 7 finished product? 7 Q. During the 1960s and 1970s, did Square 8 A. Correct. 8 D sell any styles of brake assemblies other than 9 Q. And I understand that Square D sold off 9 the WB style and the AT style? 10 the EC&M portion of the business in 2003? 10 A. Right. I believe I'm correct in saying 11 A. Yes. 11 that the WB brake style and the AT brake style were 12 Q. And when that sale took place, Square D 12 the only two. 13 was no longer in the business of manufacturing 13 Q. Okay. You told me that you reviewed 14 crane controls for brakes, brake assemblies; is 14 Dimitri Novickoff's deposition testimony. 15 that right? 15 A. Yes. 16 A. That's correct. It was assembled by 16 Q. Having reviewed that, have you come to 17 EC&M Company, the new EC&M. 17 a conclusion as to what style of Square D brakes he 18 Q. So the time period that Square D was in 18 was describing? 19 the business of selling brake assemblies would have 19 A. Yes. 20 been 1955 to 2003? 20 Q. What style was he describing, in your 21 A. Yes. 21 judgment? 22 Q. I've seen references in your 22 A. I believe he alluded to both styles. 23 depositions and I've seen references in some 23 Q. Okay. Did Mr. Novickoff appear, from 24 product information that I have to two types of 24 your reading of his testimony, to be knowledgeable 25 crane brake assemblies. If I'm not using that term 25 about crane brakes and crane brake assemblies? 5 (Pages 14 to 17) A. William Roberts, Jr. & Associates (800) 743-DEPO John Katzbeck January 24, 2008 Page 18 Page 20 1 A. He seemed to be knowledgeable, yes, I 1 Q. This document which has been marked as 2 would say so. 2 Exhibit 3 in the third paragraph says the 3 Q. Have you ever -- I understand you're an 3 following: 4 engineer and that you work for Square D, but have 4 "The new non-asbestos lining is easily 5 you ever changed the brakes or brake assemblies on 5 distinguished from the old asbestos lining by 6 a crane? 6 color. The non-asbestos lining is green with 7 A. No. 7 brass-colored particles and asbestos lining is gray 8 Q. Have you ever seen that done in the 8 with silver-colored particles." 9 field? 9 Did I read that correctly? 10 A. No. 10 A. Yes. 11 Q. Have you ever changed brakes on your 11 Q. And does that accurately describe the 12 car? 12 appearance of the asbestos-containing and the 13 A. Yes. 13 non-asbestos-containing friction materials that 14 (PLF. EXH. 3, a Square D document, 14 were incorporated into the Square D brakes and 15 Non-Asbestos Brake Linings, was marked for 15 brake assemblies? 16 identification.) 16 A. To the best of my knowledge, that's a 17 BY MR. DELUCA: 17 good description. 18 Q. Mr. Katzbeck, I'm going to hand you 18 Q. Have you seen both asbestos-containing 19 what I've marked as Exhibit 3 and ask you to take a 19 and non-asbestos-containing brake linings that were 20 look at it. 20 incorporated into the Square D brake assemblies? 21 A. Okay. 21 A. Yes. 22 Q. Have you seen that before, sir? 22 Q. And is it true that their appearances 23 A. Yes. 23 are easily distinguished from one another? 24 Q. Do you recognize that as a document 24 MR. CELBA: I'm going to object, 25 generated by Square D? 25 indefinite, overbroad. Page 19 Page 21 1 A. Yes. 1 THE WITNESS: To the extent that one is 2 MR. DELUCA: John, I believe this is 2 gray and the other one is a greenish lighter -- a 3 substantially the same. 3 greenish hue, that's accurate. 4 MR. ORNDORFF: That's good. Thank you. 4 BY MR. DELUCA: 5 BY MR. DELUCA: 5 Q. And I don't mean to be flippant, but if 6 Q. Is this document dated 1982? 6 a person is capable of distinguishing gray from 7 A. Yes, that's the date that I see. 7 green, they could look at the Square D brake 8 Q. At that point was Square D advertising 8 linings and tell the difference between the 9 the fact that it was producing brake assemblies 9 asbestos-containing ones and the 10 that contained non-asbestos brake linings? 10 non-asbestos-containing ones. Is that fair? 11 A. Correct. 11 MR. CELBA: Again, I'm going to object. 12 Q. Is that about the time, to the best of 12 Indefinite as to time. 13 your knowledge, that Square D transitioned from 13 MR. ORNDORFF: Object as overbroad. 14 asbestos-containing friction products to 14 THE WITNESS: I will concede that you 15 non-asbestos-containing friction products? 15 could tell the difference between green and gray, 16 MR. CELBA: Object to the form. 16 assuming they don't change color over time, from 17 THE WITNESS: Yes. I would have to 17 usage, or just from aging, yeah, I think -- I'll 18 assume that some of the products contained asbestos 18 concede that somebody should be able to tell the 19 because we're now advertising non-asbestos. So 19 difference between green and gray. 20 that's about the time frame, yes. 20 BY MR. DELUCA: 21 BY MR. DELUCA: 21 Q. And you raised the issue of whether 22 Q. Do you know when Square D last sold a 22 they would change color over time. You're not 23 crane brake or crane brake assembly which contained 23 aware of any evidence that that happened, correct? 24 an asbestos-containing friction material? 24 A. No. I don't know one way or the other. 25 A. No. 25 Q. The fourth paragraph says that the new 6 (Pages 18 to 21) A. William Roberts, Jr. & Associates (800) 743-DEPO John Katzbeck January 24, 2008 Page 34 Page 36 1 A. It is -- to the extent that there are 1 Q. Let me give you an example. 2 electrically insulated -- that there are materials 2 A. Yeah, sure, please. 3 on the control panels that have to provide 3 Q. Let's say Mr. Novickoff said that the 4 electrical insulation, I could not rule that out. 4 Square D brakes were purple and had green polka 5 Q. Okay. Would the actual panel be made 5 dots. And you say, Aaron, I know from my 6 out of a material that contained asbestos fiber as 6 experience that they weren't purple, they didn't 7 a reinforcement or insulating material? 7 have green polka dots. 8 MR. ORNDORFF: Let me just object that 8 Or, you know, he said they were 42 9 there's no time period given here. 9 inches long and shaped like a -- you know, they 10 BY MR. DELUCA: 10 were triangular. And you said, well, our brakes 11 Q. Just historically. I'm just asking for 11 weren't triangular, they were circular, and we 12 an overview of your understanding. 12 never made any that were that big. Those are just 13 A. Well, the board itself onto which these 13 examples. 14 components were mounted was an electrically -- had 14 Do you have any issues in your mind 15 electrical insulation properties. It may or may 15 with respect to what Mr. Novickoff said about the 16 not have contained asbestos. 16 products he associated with Square D? 17 Q. Would that be something like a Bakelite 17 MR. ORNDORFF: Same objections. 18 or a mycarta or a row stone type board? 18 MR. CELBA: Join. 19 A. Well, something like that. I'm not 19 THE WITNESS: To the extent that he 20 sure if those were the ones that were used, but it 20 said this was a Square D product and how do you 21 would be yeah, Bakelite. 21 know it's a Square D product, it had a Square D 22 Q. Are those boards cementitious in 22 name on it, or it was a brake and it said Square D, 23 nature? Are they like a hard cement-type board 23 I have no problem with that, for the description. 24 or -- 24 In other words, I don't doubt that 25 A. The ones that I can recall seeing were 25 there were Square D products from his product Page 35 Page 37 1 a brown -- oh, like Benolex or something. It's not 1 descriptions. 2 cementy, it's a solid smooth surface type. 2 Q. Okay. Is there anything about his 3 Q. Is that like a phenolic-type material? 3 testimony that you disagree with or don't find 4 A. As far as I know, and I couldn't swear 4 credible or don't think is accurate? 5 to it. 5 MR. ORNDORFF: Same objection. 6 Q. Did Square D ever manufacture that type 6 MR. CELBA: Join. 7 of board or material? 7 THE WITNESS: I can't -- some of the 8 A. No, those materials were all purchased. 8 things that he testified that they did I would -- 9 Q. Did you have any specific criticisms or 9 may not be advisable to do, but I have no basis to 10 disagreement with the way Dimitri Novickoff 10 say that he didn't do what he said he did. 11 described the products he associated with Square D? 11 The same with the condition in which he 12 MR. CELBA: Object to the form. 12 found the equipment. I have no reason to -- to 13 MR. ORNDORFF: Object as overbroad. 13 say, oh, no, that couldn't have happened, that's 14 Are you talking about just describing the products 14 not possible. 15 or the use of the products? 16 MR. DELUCA: Anything. 15 BY MR. DELUCA: 16 Q. Okay. Do you understand that why I 17 BY MR. DELUCA; 17 came down here to meet you is I want to find out 18 Q. I mean, is there anything that you read 18 what you'd say if you come to Charleston and 19 with respect to Dimitri Novickoff's testimony about 19 testify. And the idea is no one wants to be 20 products he associated with Square D that you 20 surprised as to what you're going to say. 21 disagreed with or questioned or have any issues 21 A. Yeah, yeah. You know I -- fair enough, 22 with that you would discuss at the time of trial. 22 yeah. 23 MR. ORNDORFF: Overbroad, vague. 23 Q. Okay. So there's really nothing about 24 MR. CELBA: Join. 24 his testimony that you're prepared to say, look, 25 BY MR. DELUCA: 25 Aaron, that's just not the way it would have 10 (Pages 34 to 37) A. William Roberts, Jr. & Associates (800) 743-DEPO John Katzbeck January 24, 2008 Page 38 Page 40 1 happened or that's not accurate or that's not 1 more; but based on everything that you know, you're 2 credible or that's not an accurate description of 2 unable to identify any other companies, correct? 3 what the products we make look like or how they 3 MR. CELBA: Object, vague, ambiguous 4 were used; is that fair? 4 indefinite, overly broad, foundation, speculation. 5 MR. ORNDORFF: Same objection. 5 THE WITNESS: Correct. 6 MR. CELBA: Join. 6 BY MR. DELUCA: 7 THE WITNESS: I -- in reading the 7 Q. All right. And if I understood what 8 deposition of Mr. Novickoff, I -- nothing jumped 8 you said in the past, it's your understanding and 9 out at me as in that context. 9 your testimony, based on everything that you've 10 BY MR. DELUCA: 10 looked at and reviewed, that Square D did not 11 Q. Okay. Thank you. 11 obtain friction materials from Scan-Pac until about 12 A. Yeah. 12 19 -- let's see. 13 Q. Now, as I understand it from your prior 13 Let me strike that question. I've lost 14 testimony, there were, over time, various suppliers 14 the date. Just give me one moment, please. Let's 15 of the friction materials that were used on the 15 go off the record. 16 brake assemblies. 16 (A recess transpired.) 17 A. Yes. 17 BY MR. DELUCA: 18 Q. Can you identify, first, just the 18 Q. Okay. Let me ask you a question. 19 identity of those suppliers. And then we'll talk 19 Is it correct, Mr. Katzbeck, from 20 about time periods. 20 everything that you've reviewed, including the 21 MR. CELBA: Object. Foundation, 21 drawings, the instructional bulletins, the catalogs 22 speculation. 22 and other materials that you've reviewed in the 23 THE WITNESS: Concerning the brake 23 course of your employment with Square D, that to 24 linings there were two suppliers that I know of, 24 the best of your knowledge, Square D did not begin 25 Abex and Scan-Pac. 25 purchasing friction materials from Scan-Pac until Page 39 Page 41 1 BY MR. DELUCA: 1 the early 1980s? 2 Q. And just to lay a foundation for your 2 A. It is. I don't independently recall 3 knowledge concerning that, you have, as part of 3 the date; but if that's what I had said prior to 4 your work with Square D and consulting with Square 4 that, I would have no reason to doubt that. 5 D on litigation matters, looked at drawings for 5 Q. I appreciate that. Let me just show 6 crane brakes and crane brake assemblies, 6 you what you said. This is the Earner transcript 7 instruction bulletins and other catalogs, as well 7 from April 6th, 2006. 8 as other documents, in order to be able to tell me 8 A. Okay. 9 who supplied the friction materials to Square D, 9 Q. We talked about that transcript 10 correct? 10 earlier. 11 MR. CELBA: Object, indefinite, vague, 11 A. Okay. 12 ambiguous, overly broad. 12 Q. It was taken, I guess, here in 13 THE WITNESS: Yes. 13 Columbia. 14 BY MR. DELUCA: 14 A. Yes. 15 Q. And based upon your review of those 15 Q. And you were asked on Page 28 -- I'm 16 materials, it's your testimony that Square D 16 going to hand this to you. It says, "And do you 17 obtained friction materials from two companies over 17 know when the Square D Company first began 18 time, Abex and Scan-Pac, correct? 18 purchasing friction materials from Scan-Pac?" 19 MR. CELBA: Same objection, 19 And your answer on Line 24 was, "My 20 foundation -- 20 understanding is somewhere in the early 80s, I 21 THE WITNESS: Correct. There may have 21 would have to get a specific date." 22 been more, but those are the two that I was able 22 And the guy says okay. 23 to -- whose names I came across. 23 And then you said on Line 2 of Page 29, 24 BY MR. DELUCA: 24 "Or something to get that, like '81, 1981." 25 Q. Okay. And you said that there may be 25 Does that refresh your recollection? 11 (Pages 38 to 41) A. William Roberts, Jr. & Associates (800) 743-DEPO