Document 37m9ykr2B8Ma7wrk39j22nYgn

FILE NAME: Chevron (CHV) DATE: 1998 Sept 16 DOC#: CHV006 DOCUMENT DESCRIPTION: Legal - Testimony of Ron Corbal - BC Notes "exposure" on pg 23 In The Matter O f: RonaldJ Corbal, et al. v. Chevron Corporation, et al RonaldJ. Corbal September 16, 1998 Trial Testimony Behmke Reporting & Video Services Serving San Francisco and the Bay Area 1320Adobe Drive Pacifica, CA 94044 (650) 359-3201 FAX: (650) 359-3293 Original File corb a lttvl, 51 Pages Min-U-Script File ID :3563881322 Word Index included w ith th is Min-U-Script Ronald J. Corbal, et aL v. Chevron C orporation, et aL T rial Testim ony R onald J. Corbal Septem ber 16,1998 THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF LOS ANGELES RONALD J. CORBAL and KATHLEEN) ANN CORBAL, ) Plaintiffs, ) ) CASE NO. V. ) BC 19289S CHEVRON CORPORATION, a ) corporation; et al., ) Defendants. ) TRIAL TESTIMONY OF RONALD J. CORBAL WEDNESDAY, SEPTEMBER 16,1998 PAGES 1 - 50; VOLUME 1 BEHMKE REPORTING a VIDEO SERVICES BY: VICKI A. CARR, CSR No. 6280 1320 ADOBE DRIVE PACIFICA, CALIFORNIA 94044 (650) 359-3201 Page 1 Trial Testimony of RONALD J. CORBAL, taken on behalf of PLAINTIFFS, at 3262 Trebol Lane, San Jose, California, commencing at 10:01 a.m., W EDNESDAY, SEPTEMBER 16, 1998, before VICKI A. CARR, Certified Shorthand Reporter No. 6280, pursuant to Notice. Page 2 APPEARANCES OF COUNSEL: FOR PLAINTIFFS: DAVIS & THOMAS BY: THOMAS D. THOMAS, ESQUIRE 1999 Avenue of the Stars, Suite 2310 Los Angeles, California 90067 Telephone: (310)552-2121 FOR CENTER FOR CLAIMS RESOLUTION: HAIGHT, BROWN a BONESTEEL JOANNE LEMBERT ROSEN, ESQUIRE 1620 26th Street Suite 4000 North Santa Monica, California 90406 Telephone: (310)449-6000 FOR CHEVRON CORPORATION: STEPTOE a JOHNSON BY: LAWRENCE P. RIFF, ESQUIRE 633 West Fifth Street, Suite 700 Los Angeles, California 90071 Telephone: (213)439-9494 Page 3 APPEARANCES OF COUNSEL - CONTINUED: FOR THORPE INSULATION COMPANY: FOX, SHJEFLD, WOHL & NEWKOLD BY: SH AR DN W . GREY, ESQUIRE Sixth Floor, Home Savings Building 1730 South El Camino Real San Mateo, California 94402 Telephone: (650)341-2900 FOR RAPID AMERICAN CORPORATION: GORDON a REES BY: KELLY W. BHIRDO, ESQUIRE 275 Battery Street, Suite 2000 San Francisco, California 94111 Telephone: (415)986-5900 Page 4 INDEX W EDNESDAY, SEPTEMBER 16, 1998 RONALD J. CORBAL, VOLUME 1 Pago Examination by MR. THOMAS 7 QUESTIONS WITNESS INSTRUCTED NOT TO ANSWER: PAGE LINE None. Page 5 EXHIBITS RONALD J. CORBAL VOLUME 1 Number Description Page None. Page 6 [i] WEDNESDAY, SEPTEMBER 16, 1998; 10:01 A.M. 13] MR.THOMAS: W e're going to go through the [4] obligatory introductions and statements before [5] we go on the video record, so let me begin. [6i My name is Tom Thomas. I'm m representing Mr. and Mrs. Corbal in an action [8]pending in Los Angeles County. I am w ith the |9) firm of Davis &Thomas, 1999 Avenue of the |io] Stars, Suite 2310, Los Angeles, California |ii] 90067. [12] I am operating the video camera U3] today.We are videotaping the testimony of [hi Mr.Corbal for perpetuation fortrial [15] purposes. And counsel present, w e'll go around [i6] and state your appear ances and then we will mi begin. [is] MR. RIFF: My name is Larry Rifffrom [191 Steptoe &Johnson. I represent Chev ron. [20] MS. BHIRDO: Kelly Bhirdo from Gor don & [2i] Rees, for Rapid American Corporation. [22] MS. ROSEN:Joanne Rosen from Haight, Brown [23] & Bonesteel re presenting a number of other [24] defe ndants in this case. [25] MR.THOMAS: This is the com mencement of Page 7 Hi tape 1 at approxim ately 10:02 a.m., [2] September 16, 1998. And, madam re porter, if [3] you'll swear the witness, please. [4] RONALD J. CORBAL, [5] having been first duly sworn, testified as [6] follows: [8] EXAMINATION [9] BY MR.THOMAS: [10] Q: Sir, could you state your name for the [in record,please? [12] A: Ronald J. Corbal. [13] Q: Mr. Corbal, we are here today in your [i4j home videotaping your trial testimony to be us] played before a jury in your lawsuit pending in [16] Los Angeles. [17] The oath that you have just been given [is] isthe same oath thatyou would receive were [19] you in a court of law, carries with it the same [20] penalty of perjury. Do you understand that, [21] sir? [22] A: Yes, I do. [23] Q: Would you tell us your date of birth? [24] A: I was born September 10th, 1946. [25] Q: That w ould make you age 52? Page 8 [1] A: Fifty-two. [2] Q: In fact that would have been then your [3] 52nd birthday was just last week. [4] A: Last week, yes. [5] Q: Also, if you'll rem em ber to allow me [6] to complete my question before you begin your m answer, it will make it a lot easier to [8] understand both on the video as well as for the [9]court reporter, [io] Sir, are you married? mi A: Yes. [12] Q: And what is your wife's name? [13] A: My wife's name is Kathleen Ann. Behmke Reporting & Video (650) 359-3201Min-U-Script 114] Q: And w hen were you married? 115] A: Do you need her maiden name? [16] Q: No.That'sfine.She goes by Kathy? [17] A: Yes. [is] Q: And w hen were you married to Kathy? [19] A: We were married July 9th, 1972. [20] Q: So then you've been married a little [2i] bit over 26 years now? [22] A: Twenty-six years, correct. [23] Q: How did you m eet Kathy? [24] A: I was playing adult softball, and a [25] friend of mine on the team men tioned that he. Page 9 [i] had a cousin that he would like me to m eet. So [2j he basically set this up, and my wife came to [3]one ofthe games and w e became acquainted and [4] started dating at an adult softball game. [5] Q: And this has been your one and only [6] marriage, correct? [7] A: That's correct. [8] Q: Do you have any children? [9] A: Yes. [10] Q: Would you tell us their names and [ii] ages, please? [12] A: We have three children. The old est, [13] Robert Allen, just turned 24 on Sunday. His [14] birthday is the 13th of September. 115]My second son is RichardJames.He is [16] 21. His birthday is in March, March 26th. And [17] my daughter is 17. Her birthday is in June, [is] June 15th. [19] Q: Are th e children still living at home? [20] A: My middle son is currently attend ing [2i] UC Santa Cruz and basically lives off campus at [22] the college, works in Santa Cruz and goes to [23] school there. So he goes not really spend a [24] great deal of time here. [25] My older son graduated from UC Santa Page 10 [i] Cruz and has returned home. He's doing [2]substitute teaching.And until he can really [3]establish himself in order to become [4] independent, more in dependent, he is living at [5] home here with us. My daughter obviously, yes, [6]is home with us. [7] Q: What is she, a senior in high school [8] now? [9] A: She's a senior in high school. [10] Q: You provide financial support to both [in your wife and your children? [12] A: Yes. [i3l Q: Could you describe, please, for us [i4] your educational background? (3) Page 1 - Page 10 R onald J. C orbal Septem ber 16,1998 T ria l Testim ony Ronald J. Corbal, et aL v. C hevron C orporation, et al* [1 US] A: My educational background, I ntative 120] assisting vets to find me as a person but I was entitled 121] to have a U6] bachelor's degree in business employment. some payments from Uncle Sam also. administration [17] and industrial man [2i] MR.THOMAS: All right. Let's take a 122] So I did return. And while starting a fi agement from San Jose State [is] Uni short [22] break on tape num ber 1 at [23] new family, working full time, trying versity which I obtained in 1969.1 also approximately 10:08. [23] We have an to keep a [24] new house, you know, i[is9t]rathioanve[20a] wmhasictehr'Is oinbtabiunseindefsrsomadSmainn o th er guest here.This will be a [24] break maintained and whatoot.it 125]was quite hectic, but in about two and a half 0 Jose State University [2i] in 1976. on tape 1. Page 15 [22] Q: Now, it's my understanding bet [25] (Recess.) w een the [23]bachelor's and the master's Page 13 H I years I completed the MBA program. you got a polite [24] little notice from a ID MR.THOMAS: This is the con And in '76 [2] ultimately received the very rich uncle, Uncle [25] Sam, drafting tinuation of [2] tape 1 at approximately degree. you into the service; is that 10:11 a.m. [3] Q: W hat exactly is your position with Page 11 13] BY MR. THOMAS: EDD [4] presently? i.. -1 ID correct? [4] Q: Mr. Corbal, not to slight your [5] g[5r]amA: C[6]urmreanntalgyeIr'.mAanndemwpitlhoiynmaenftieplrdo [2] A: That's correct. daughter, I don't believe w e've actually office - field [7] office I'm assigned to is [3] Q: Would you tell us aboutthat? When heard [6]her name on the record.W hat is the Campbell [8] office - I manage a [4] did you serve in the military? her name? group of individuals who [9] are re [5] A: In 1969, when I graduatedwith a [6] [7] A: My daughter's name is Kristin Mar sponsible for assisting the public, the [ioj bachelor's degree from San Jose State, I ie. public being job seekers, employers, n was [7] informed that I no longer had [8] Q: Now, you were telling us about those [ii] people lookingforinformation deferment, [8] college deferment, and your [9] employment and the company on training. [12] Anyone who needs that my presence was [9] requested at EDD.What is EDD? assistance with employment and 113] Fort Lewis, Washington. I spent [io] training issues our staff is there to assist n approximately th e next two years in th e [io] A: EDD stands for th e Employment [i4] them, providing workshops, pro s ; army ni] infantry and served a tour of [ill Development Department, which is viding direct [15] placement assistance, duty in Vietnam. th e state [12] component of the national providing referrals to [16]other services. [i2] Q: The tour of duty in Vietnam, that job service system [13] under the Dep Again, just a whole myriad of [17] activ l1 `.i was [i3] approximately April 1970 artment of Labor. ities. through middle of [i4]March 1971 ;isthat [14] And it is charged with providing [15] [18] Q: It is my understanding your curr correct? assistance to employers and job seekers. ent [i9] rate o f pay is approximately [15] A: Correct. Also [16] it provides unemployment in $4,170 per month [20] plus benefits; is surance. And there [17] is just so many that correct? [161 Q: Following your discharge from the [17] military, the active duty military programs now that w e're us] involved in. [21] A: That's correct. portion, [is] there was a period of time [19] Q: Now, you still work for EDD, [22] Q: There was a recent opportunity w here you also [19] served as a reserved correct? for 123] promotion that was presented to enlisted individual, 120] correct? [20] A: Correct. you; is that [24] correct? K [21] A: Um-hum. [21] Q: This has been your one and only [25] A: That's correct. [22] Q: Ultimately some six years after job [22] since getting out of the service for, what, the [23] last 27 years? ___________________________ Page 16 your [23] initial drafting you had com pleted your [24] military service with the [24] A: Correct. ID Q: Would you describe that for us, [2] please, and what happened? U.S.Army? [25] Q: Let me see if I can put this [3] A: As we had talked before, within [4] M [25] A: Yes. Page 14 government civil service, especially H1 , Page 12 ID chronology into perspective. You get with an [5] EDD, there have not been Li ID Q: What did you do after you got out out of [2] the service in March of 1971, spend a period of 13] time seeking many opportunities for [6] advancement over the years.And just recently u\ it was of [2] the army in 1971? employment, ultimately work with [4] like all of a sudden the door opened [8] 13] A: I started looking for employment. EDD.andobtainfiill-time employment in with a few promotional opportunities. And [4] while I was a veteran and had a degree, I [5] believed it would be fairly October [5] of 1971. [9] I currently am on two promotional [10] [6] You have met your wife, have been [7] lists for classifications higherthanm y [in easy to get a job. [6] Unfortunately most employers told me that [7] without dating her, ultimately married July 9, 1972, [8] but you're not getting your current classification and would be con sidered [12] for openings at that level, experience they would like to talk to [8] master's until [9] 1976; is that correct? those advanced [13]levels, and hopefully me later, once I did have some experi ence. So [9] I spent approximately six [io] A: Correct. would be selected. In [i4] one case I months looking for no] employment. actually have a letter where I would [15] Hi] Q: Could you tell us how you came have been selected had it not been for [u] During that time I contacted the State about ii2] going back to school and the my [16] health. [12] of California Employment Deve circumstances 113] involved there? [17] Q: You've had to withdraw your j lopment U3] Department, the state job [14] A: W hen I came out of the service name from [is] consideration for this service and through [i4] their assistance was referred to a number of us] positions one of [is] the things that I learned was that under the GI [16] bill there were promotion due to your [19] health? but also was given information about [i6] some benefits that I was [17] entitled to [20] A: That's correct. a position internal to EDD helping vete that I would be foolish not to take [is] [21] Q: Sir, can you give us an approx rans U7i find employment. advantage of. And if I was to return to imation [22] as to what the pay increase [is] So in October of 1971 Iwas hired by school [19] and pursue an advanced would have been [23] under this new [19] EDD to work as a veteran's represe degree, not only would [20] that benefit promotion compared to your 1241 curr- Page 11 - Page l 6 (4) M in-U-ScriptsBehm ke Reporting & Video (650) 359-3201 Ronald J. Corbal, et al. v. C hevron C orporation, et al. T ria l T estim ony R onald J. Corbal Septem ber 16,1998 ent? [25] A: Most of our classifications have Page 17 m ranges, but it's like a 5 percent increase [2] classification to classif ication. You know, I [3] couldn't give you details without looking at hi the chart but approximately 5 percent. [5] Q: Over your 27 some years with EDD, you [6] have worked your way up through the ranks from [7] a low level trainee u p to your current [8] position; is that correct? [9] A: Correct. no] Q: Do you have any plans to retire? [11] A: Actually I haven't given it a great [12] deal of thought. I do, sure,I mean off into [i3] the future. We have a fairly decent retirement [i4] package, and I am lookingforward somedayto [15]enjoying not having to get up in die morning [16] and clean up and go to work and all that kind [i7] of stuff. us] But I really haven't given it a great [19] deal of thought.I kind oflike what I'm [20] doing. And, you know, ifyou enjoy what you're [21] doing, if you enjoy the people you're working [22]with, if you feel that what you're doing makes [23]some sense and has some importance, that'swhat [24] I focus on. So I really haven't given [25] retirement per se a great deal of thought. Page 18 ID Q: With a young daughter still in high [2] school and college yet to come and perhaps even [3) advanced degrees, w ould it be fair to say that [4] you would continue working as long as you were [5] physically able even up through age 65 to age [6] 70? [7] MR. RIFF: Objection. Leading. [8] THE WITNESS: Pardon me? [9] MR. RIFF: I have made an objection, and [10] you can answer. [11] MR.THOMAS: Let me rephrase it. [12] BY MR.THOMAS: [13] Q: Sir, given the situation with a young [14] daughter still at home yet to go to college and ns) perhaps even a n y ' other advanced degrees, could [i6] you give us an estimate as to how long you [171 would have anticipated continuing to work given [is] your health allowing you to continue working? [19] A: I really wouldn't be able to answer [20] how long. I mean it would be guess work on my [21] part. [22]You're right. My daughter right now [23] is a senior in high school and is looking at [24] various universities as possibilities. One of [25) the universities she is looking at is Gonzaga, Page 19 luand I said,"Fine,great, woqderful.And you [2] better be looking at the schol arship money [3] you're going to get to pay for it too." The [4] point being that, yes, college is extremely [5] expensive. [6] I have a disabled veteran tuition [7] waiver that can be applied within the [8] University of California system that has meant [9] that for my two sons going to UC Santa Cruz [io]theyhave had some of their fees waived which [in saved us some money, not having to pay those [12] fees. (13) We still had to pay other fees and the [14]living expenses.And there have been times [is] where writing out that check for the fall [16] semester kind o f cut into some o f the checks we [i7] w ere writing for other things. [is] So college is definitely something [19] that has to be considered when I look at can I [20]survive on retirement income or do I need to [21] continue working in order to have a full [22) income. [23] Q: If your health were to allow your [24] continued work at EDD, there is no mandatory [25] retirement age there, is there? Page 20 [1] A: No. [2] Q: And you would be able to work up to [3] age 70 is you so desired? [4] A: Correct. [5] Q: What I want to do now is focus your [6] attention many, many years in your past to a [7]period while you were in college and talk to [8] you about your summer jobs during college. [9] Would you tell us, please, where did [10] you work during your summers while going to [ii] college? [12] A: The first summer - I believe this was [13] betweenhigh school and college - 1worked for [i4] a company, Grosken, Incorporated, which was an [15] in dustrial or commercial landscape firm that [i6] contracted to take care of plantingplantsand [17] sterilizing soil and doing various things [is] around cor porate headquarters, things of that [i9] nature. I did that for one summer. [20] The following summer I was for tunate [2i] enough to get a job with Southern Pipe & [22] Casing. And I say fortunate because this was a [23) union type of position, meaning it paid a [24] little more than the average summer position. [25) And w hen you are just working three or four Page 21 [i] months to try to pay for your entire school [2] year, that's very important. [3] Q: Let me interrupt you here for a [4] se cond,just ask you briefly,this period of [5]time between your senioryear in high school [6] and your freshman year in Behmke Reporting & Video (650) 359-3201Min-U-Sciipt working for Grosken, [7] there is no reason to your knowledge to believe [8] that you had any asbestos exposure during that [9] summer, correct? [10] MR. RIFF:Objection. Leading. [11] Go ahead and answer. [12]THE WITNESS: None whatsoever. We [13] basically were planting ivy,prun ing bushes, [14] watering plants, doing th in g s th at to my [15] knowledge didn't expose me to any asbestos. lie] BY MR.THOMAS: [i7] Q: Let me rephrase the question in [i8j response to the objection to make sure that we [19] have it clear on the record. [20]What didyou do?W hat were your job [21] duties while working for Grosken during that [22] summer betw een your senior year in high school [23] and your freshman year in college? [24] A: I was a laborer. And basically, [25] again, I spent time planting mostly ivyon side Page 22 ID hills, watering plants, priming and shaping [2] plants. That was predom inantly what I did. [3] Q: N ow let's take you to your work at [4] Southern Pipe.First let's get a general [5] picture. [6] You w ent back and worked at Sou thern (7) Pipe for each o f the summers during your [8] college years, correct? [9] A: That's correct. [10] Q: So the time frame w e're talking about [ii] is the summer o f 1965, '66, '67, and '68, [12) correct? [13] A: T hat's correct. [14] Q: Tell us, w hat did you do while working [15] during those summers for Southern Pipe? [16] A: Each of those four years, and it [17] didn't change appreciably from summer to [is] summer, I was a laborer. I'm not even sure now [19] b ut I think the union classification probably [20] was laborer. [21]I was asked and did anything basically [22] that they told me to do, which included helping [23] the forklift drivers move steel pipe around the [24]yard,take it off o f trucks, p u t it on trucks, [25]move pipe into the area where it would go Page 23 [1]through the machines that would coat - p u t a [2] coating on the outside of the pipe, yard [3] cleanup around the yard itself, just so many [4] very basic labor types of activities. [5] Q: W hat was this coating that went on the [6] pipe called? W hat was its name? [7] A: Somastic. [8] Q: Somastic. S-o-m-a-s-t-i-c? ( 5) Page 17 - Page 23 Ronald J. Corbal Septem ber 16,1998 T ria l T estim ony R onald J. Corbal, et aL v. C hevron C orporation, et al. [9] A: I believe so.yes.iiojThatwasoneof the coatings. This [in plant coated pipe basedon w here the pipe was [12]going to be laid,underthe bay,in adobe soil, [131in loam.So the coating dependedon where the [i4] pipe was going to be. [15] I would say the majority - gosh, I [16] w ouldn't begin to - a very high per centage of [i7] the pipe that we ran through ran through [is] Somastic. So w hat I'm saying is there were H9) other coatings that were put on the pipe but [20] Somastic was without a doubt the foremost [2ij coating that we put on. 122] Q: Describe for us, what was this process [231 o f coating these steel pipes with Somastic? [24] How did that occur? [25] A: Most of the tim e it was a matter of Page 24 in placing steel pipe - and this steel pipe was [2] betw een two inches and I think the largest we 131dealt with was 3 6 - steel pipe, 40 foot [4] lengths.These pipe were placed in a machine, [5] an extrusion machine. Were run through, and [6j through a process of - 1don't know how to [7] describe it exactly.I wasn't privy to the [8] technical aspect of the process b u t [9]basically tar or asphalt, the various materials [io] that made up Somastic, for example, came [11]together in this mach ine and w ere spread - 112] for lack o f a b etter word - were spread on [131 the pipe as the pipe w ent through the machine. [14] Q: Were the ends of these pipes coated [15] with Somastic during the application process? [16] A: No. [17] Q: And why not? [18] A: Obviously you have 40 foot lengths. [i9] They have to be trucked to a job site and 120] connected at the job site. So the Somastic, or [21] whatever the coating we were using, normally [22] stopped a good foot, foot and a half, tw o feet [23] short of the end. So that when th ey w ere sent [24] to the field this pipe could then be welded, [25] could be coated, the ends could go coated in Page 25 [1] the field to finish the job. [2] Q: Now, during your summer jobs at [3] Southern Pipe, did you know at that time that [4] Somastic contained as bestos? [5] A: Absolutely not. 6] Q: Let me talk to you about the bag days, [7] the process o f filling bags with dry Somastic [8] mix. Could you describe that process for us, [9] please? no] A: Yes. As I mentioned, the ends o f the [u] pipe were free ofthecoating. And w hen it [12] w ent to the field a mixture had to be made and [13] the job finished Page 24 - Page 29 (6) so that this was a continuous [i4j pipe run. [15] The only way we could do this is to [16] have like a dry mix of the Somastic material [ 17] that could be combined w ith asphalt, I guess, [i8] in the field to complete that job.In order to [19] get this dry mix, we had to tun the machine [20] that normally coated the pipe basically the [2i] same way it always ran with the exception that [22] the asphalt wasn't included in the mixture as 1231 it came through the machine. [24] Now, w hat this meant was that from th e [25] machine there was a "Y" appar atus, a duct work Page 26 [i] "Y" apparatus, coming down to the "Y" being [2] upside down, two spigots with control handles [3]that could shut off or open that particular [4] side. [5]And we four individuals usuallywould [6] stand there with gunnysacks.And one person [7] would have a sack over the end of that spigot, [8] if you will. His would be open, the sack would [9] be filling. Once that sack was full he [io] basically would shut his off and it [in automatically opened the other side. The other [12] side, the guy better be standing there with a U3] sack covering his spigot.Andthis justwent [14]back and forth, back and forth, back and [151forth. [16] The other two individuals in the [17] process were there to very quickly tie the top [is] of the gunnysack and throw the sacks onto a [19] pallet, stack them onto a pallet. It could be [20] set at different speeds. And sometimes it was [21] set pretty fast. [22] And we did this quite often. We did [23] quite a bit of this because, again, it was [24] needed for the ends of the pipe in the field. [25] Q: So every single load of pipe that went Page 27 [i] out in the field had to have their own batch o f [2] dry mix Somastic that could then be applied on [3] the ends of the pipe that's in the field? [4] A: That's correct. [5] Q: Yourjob duringthese bag days was [6] simply to, as quickly as able, you and three m other fellows fill these gun nysacks with this [8] dry material on a continuing basis, correct? [9] A: That's correct. [10] Q: Were these bag filling days - was [in that a dusty process? [12] A: Yes.Very, very, very dusty. [i3l Q: How would you describe it? What was [i4] it like? [15] A: I have been on baseball fields where [16] the dirt was so finely ground that it was like [i7] powder, I mean just like talcum pow der or [i8j something. And I have kicked that dirt. And [19] that dust cloud is the best dust cloud you ever [20] saw. I mean it beats, let's say, a sand storm, [2i] anything.It'sjust ultimate dust. I would [22] equate this with that. Very, very dusty. [23] Q: Now, this was a material that you w ere [24]putting in the bags from spigots that w ere base [25] high, shoulder high? Could you describe what Page 28 [1] level it was? [2] A: More or less shoulder height, yes. 13] Q: W ould this dust also get all over your [4] clothes? 15] A: Oh, definitely. [6] Q: Was this dust that you and the other [7] fellows breathed? [8] A: Yes. 19] Q: Was there any way for you to avoid no] breathing this dust during the bagg ing process? [ii] A: There was no way to avoid breath ing in [12] the dust, no. [13] Q: W ere any respirators provided for your [14] use? [15] A: No. [16] Q: W ere any uniforms provided that would [i7] allow you to then take off these dusty clothes [is] and not transport the dust home in either your [19]car orto the home? [20] A: No. [21] Q: Did you in fact bring hom e [22] contaminated dusty clothes as a result of this [23] bagging process? [24] A: I 'm sure I had to have because, again, [25] we just - the Levi's and sweatshirt or Page 29 [i] whatever we w ere wearing that particular day, [21 w hen the day ended you jum p in die car and you [31 go home. And so basically whatever I had on [4]me - now, sure, we might try to, you know, [5] brush it off. But I'm sure that I was bringing [6] this material wherever my clothes went. [7] Q: D idyoudrivebackandforthtothis [8] job during the summers in your own car? 19] A: Yes. [io] Q: And so whatever was in that dust that [ii] was on your clothes also ended up in your car [12] and in your home? [13] A: I would say yes. [14] Q: D uringthese summers working at [15] Southern Pipe did you expect you could work [16]with or around Somastic without it causing you 117] any harm? Min-U-ScriptBehxnke Reporting & Video (650) 359-3201 Ronald J. Corbal, et aL v. Chevron C orporation, et aL T rlal T estim ony R onaldj. coroai Septem ber 16,1998 [ 18] A: I didn't give it any thought. In my 119] mind there was no reason to believe th ere was 120] any harmful effect o r any danger. [2i] Q: In essence you expected you could work [22] with and around this material without any [23]personal injury? [24] A: Yes, absolutely. [25] Q: No one ever told you Somastic could be Page 30 [1]harmful to your health in any respect, did [2] they? [3] A: No. [4] Q: You saw no warnings on the bags? [5] A: No. [6] Q: Didanybodyevermakeanystatement to [7] you in any fashion that breath ing the asbestos [8] dust from Somastic would cause you any physical [9] harm? [io] A: No. HU Q: Were you ever instructed by any body, [i2] during these summer jobs while at Southern Pipe [13] breathing asbestos dust from Somastic, that [i4] precaution should be taken to avoid breathing [151 this asbestos? [16] A: Not per se. In other words, not as [17] far as asbestos or Somastic or any thing of that [is] nature. But rather just because it was a very 119] dusty area, we all would say to each other (201 some thing about wearing these little masks. [2i] And the masks that we had were - 1 would call [22] them these inexpensive garden type of mask. [23] Wear long sleeve shirts. [24] I mean we took those kinds o f [25] precautions just because it was so dusty. But Page 31 Hi no one ever instructed us or gave us any [2]informationthat w ouldhelp us go beyond that. 13] Q: These little masks that you're [4] describing, are these little paper masks [5] that - [6] A: Right. [7] Q: Is it basically because it was so [8] darned dusty you would be choking on the dust [9] if you didn't wear it? [io] A: Absolutely. [in Q: Other than your work at Southern Pipe [i2] during the summer jobs from 1965 through 1968,[13] are you aware of any other potential exposures [i4] to asbestos in your entire life? [is] A: I am not. [16] Q: No other jobs w here you could in your [17] understanding have any as bestos exposure? [is] A: I cannot think of any exposure. [19] Q: After graduating college, after go- ing [20]to the army and coming to work for EDD, from [21] that point on your entire employment career has [22] been involved with office jobs, correct? [23] A: That's correct. [24] Q: Wearing a coat and tie and no exposure [25] to any dust as you know? Page 32 [1] A: That's correct. [2] Q: Sir, let me turn your attention to [31 your medical condition and the disease [4] mesothelioma. What I would like you to do is [5] describe for us, please, the symptoms you were [6] experiencing up to the diagnosis of [7] mesothelioma in March of 1998. [8] A: Approximately November or December of [9] 1997 I started exper iencing some chest pain, (101 shortness of breath,but a great deal of uu heartburn and acid indigestion. I went to my [12] doctor and we pursued a belief that perhaps I [13]was suffering from like an esophagal reflux or [14] something that was more esophagal in nature. 115]I was given some medication that did [16] help as far as the heartburn and the acid [i7] condition.But I still continued to have pain, [18]and it started getting worse probably about [19] beginning of this year. Sometime beginning of (201January, the pain started getting worse.And [21]it was focused in the front left rib area and [22] left back. And this could at times be very [23] excruciating. [24] Later I was told that the cause o f the [25] pain was that the disease was pre ssing against Page 33 in or had grown into a rib and obviously the [2] effect on the nerves that was causing the 131 pain. [4] I spent a great deal o f time during [51 that period, December, January, Feb ruary, [6] March, working with a pain management nurse at [7] Kaiser, here in SanJose, trying to come up [8]with ways to control the pain. [9] I'd say for about four months I spent [10] my life trying to find a comfortable po sition [ii] that I couldn't find. The pain was just too [12] excruciating. And no matter how I climbed all 113] over the furniture, no matter what I did, I had [14] the pain. [15]Finally about April, I think, we hit [16] on the best combination of medications that is [17] now fairly well controlling the pain. [is] Q: Describe those pain medications that [19] you've utilized to control the pain at [20] present. [21] A: The two primary medications, one is [22] Oramorph MSCONTIN, a morphine tablet. I take [231 300 millig Behmke Reporting & Video (650) 359^3201Min-U-Script rams twice a day, so 600 milligrams [24]of MSCONTIN. [25] I also take Mexiletine, which is a Page 34 Hi morphine product, and I take 900 milligrams of [2]that a day in tablet form. [3] Q: Have your pain medication dos ages [4] increased over time? [5] A: It did increase up to the present [6] level, w hich seems to be the level that is for [7] the most part controlling the pain. And I have [8] to tell you, everything is relative. It's not [9] that I'm w ithout pain but it's controlled, no] Q: You are in pain right now? [in A: Minor. [12] Q: Is virtually every waking moment o f U3] your life dealing in trying to control the pain [14] you're exper iencing? [15] A: Um-hum. [16] Q: Let's take you back before March, and [i7] if you'll describe for us, please, the [is] chronology of the diagnosis until the point [19] w hen a doctor told youyou had mesothelioma, if [201 you would, please. [2i] A: Again, my doctor was having tests run, [22] x-rays, and w e felt that it had something to do [23]with the esophagus. But she is a specialist [24]who I guess has had some background with chest [25] xrays and how they depict certain cloudy Page 35 [i] areas. And this apparently is what occu rred in [2] this case. [3] An x-ray showed a very suspicious [4] cloudy area that caused her to ask for a CT [5] scan. The scan basically told her that [6]mesothelioma was a possibility or something [7] serious was a possibility. She ordered a [8] biopsy, and the biopsy confirmed w hat she had [9] felt, that it was mesothelioma. [io] Q: After confirming the diagnosis that [ii] indeed you had mesothelioma, w hat did you do [12] regarding a search for effective treatm ent if [13] anything? [14] A: I have to say th at my wife and I [i5] especially spent many,many, many hours o n the [i6] Internet, making phone calls, making copies o f [17] materials. In ad dition, friends and relatives [is] have just been unbelievable helping us to get [19] information. [20] And w hat w e were looking for was [21] something that w ould be the most how should [22] I say it - the most beneficial treatment. [23] Mesothelioma does not have a standard treatment [24] procedure that works. And because of that we [25]were looking at clinical trials, we were Page 36 (7) Page 30 - Page 36 R onald J. C orbal Septem ber 16,1998 T rial T estim ony R onald J. Corbal, et aL v. Chevron Corporation, et a l m looking at photo dynamics, gene therapy. You [21 name it, we looked at it. [31We made phone calls to Pennsylvania, [41 to Louisiana, to specialists at uni versities [51all over the country trying to find out about [6]their particular clinical trials or do we [7i qualify, do I qualify for what they're looking [8i into. [9i End result being that unfortunately I [ioi do not qualify for most of the studies because uu the pleural area had been too m uch invaded, if [121 you will. There was not enough room or space [131 to continue a study of that nature, so I wasn't [Hi eligible. [151We were referred to an oncologist, a [161 specialist at Kaiser here in San Jose, w ho is [i7i the head of the department and very well [i8i respected, who along with a private doctor in [19] Aptos assisted in coming up with what is now [201the only course ofaction Ihave really. [211 Q: And what is that? [22i A: Chemotherapy. [231 Q: Describe thatforus,please,the [24i process and the chronology of your chemo [251 treatments. Page 37 [UA: Again, mesothelioma does not re spond [21 to standard treatments well. So chem otherapy [31 even was not ever considered die answer. But [4i w hen we got to the point w here there wasn't any [51 other answers then we had to con sider it as [61 something that we might at least try to buy [7i some time. [8i So alongabout - I 'm going to say [9] it's been two months since we started the [ioi chemotherapy. Along about July I was started [111 on a regimen with two chem otherapy drugs. The [121 regimen is four w eeks-excuse me.It'sone [131 day a w eek, a Friday, for four weeks, and then [Hi with two weeks off the chemo therapy. And then [151 a repeat of that cycle. [1611 have completed one cycle. Iam next [i7i week due to complete the second cycle. I think [isi it's too early to say w hether it's had any [19]beneficial - you know, w hether it's been [201beneficial or not. [2i] Q: You receive the chemotherapy treatment [221 on Fridays? [23i A: Correct. [24i Q: Do you have to do anything on Thursday [251 in anticipation of the treatment on Friday? Page 38*I Hi A: Yes. Thursdays I have a blood test so [21 that they can determine the blood counts, so [31that if the blood counts are too lo w - and it hi happened once where I was denied treatment, if[5]you will.And w hen I say denied, it was felt [6]that it was better that I not receive the m chem otherapy that particular week because my [8] white blood count was so low that I was just a [9] target for infection. [ioi And I guess - you know, this is - [in I've never been through thisbefore.This is [12] all new to me. I guess that's the thing you [13]have to really watch out for is infections. [hi Q: We'll get to this in a moment. You've [isi had some infections and you've had three [161 emergency room visits recendy. ini A: Correct. [isi Q: Let me just focus at this stage on the [191 chemotherapy. The therapy it self, how long [2oi does that take on Fridays? [211 A: It's an infusion process. And [22] normally I'm there between three and four [23] hours. There are some pre liminary drugs that [24] are infused that have to do with nausea, to try [251 to prevent nausea. And then the two drugs are Page 39 HI given. [2i Q: Have you experienced nausea as a side [31effect of your chemotherapy? [4] A: I have experienced side effects, yes. [51Q: Describe those for us. [6] A: Well, I have had some hair loss. I [7] guess I'm very fortunate in that it has been a [8ithinning rather than a total loss o f my hair. [91 The primary and more serious side effects are [101 nausea, con stipation. Sometimes the mi con stipation changes and it's diarrhea. [121 Light-headedness and anxiety, tingling and [131 numbness in my feet, swelling. Every day is [14] different. [isi Q: Following the chemotherapy, can you [16] predict how you are going to feel? ini A: No. [isi Q: Your last chemotherapy treatm ent was [i9i last Friday. Today is Wed nesday. Your next [20] treatment - you'll have blood tests tomorrow [211 and another treatment two days from now, [221 correct? [231 A: Correct. [24i Q: Let me talk to you about your sleep [251 patterns. Could you describe those for us, Page 40 in please? What isyour sleeping situation these [21 days? [31 A: Because of the pain, the pressure on [4ithe rib,I have not been able to sleep in a bed [51forages. In fact, stomach is out of the [6] question since like last - since the first of m the year. Right and left side I've trieda few [8itimes but they're iffyat best. [91So basically it's a lay on your back [101 situation, and my bed is too firm, so for quite [111 sometime I have been sleeping on an air [121 mattress on th e floor of my bedroom. [131 Q: Are youableto get a full night's [i4i sleep? [151A: It's the best I can get. I mean I [161 wake up two or three times. But I do get some ini sleep. [18] Q: Now, you've had some infections, and [19]you've been to the ERthree times recently, [20] correct? [211 A: Correct. [22i Q: Just describe those for us, please. [23] A: The first time was a couple of months [24] ago. One evening I was very, very anxious and [251 experiencing naus ea, light-headedness and Pago 41 HI whatnot. My wife became very con cerned and [2] called 911. [31 The paramedics determined that while [4i there probably w asn't anything serious, I [5] should b e checked out and took me over to [61 emergency. It was determined that I did have m an in fection at that time, and they prescribed [8] some other medications to help me overcome, for [9] example, th e nausea, [ioi I had lost approximately 15 pounds.I [in was very weak. And so w hat they w ere going to [121 do basically was try to build me back up. I [131 was very, very down at that point. [14] The second time hadto do more with [isi the nausea, the fact that I didn't know w here [16] this was going. I mean it was something I had [i7i never experienced before and didn't know how to [isi deal with .And it ended up that they had to [191 increase the medication for the nausea. [201This lasttime I came home on aFriday [211 afternoon from work, in fact it was th e last [221 day that I worked, and felt a litde feverish. [231 My daughter took my temperature, and it was [241101. 125] My wife got home minutes later, and as Page 42[i] [i] soon as she heard that we were onour way to [21 emergency, because one of the things they say [31 w hen you're on chemotherapy is if your [4] tem perature reaches 101, get in here. I don't [51know the reason but there must be a reason. [61W hen we w ent into emergency a lot of [7i tests, a lot of x-rays and w hatnot, and they [8i determined that I had pneu monia. Very [9] concerned because, again, on chemotherapy, [10] these pois ons are put in your system to kill [111 the cancer cells but they also kill good cells Page 37 - Page 42 (8) M in-U-ScriptsBehmke Reporting & Video (650) 359-3201 Ronald J. Corbal, et al. v. Chevron Corporation, et al. T rial Testim ony Ronald j. to rn a i Septem ber 16,1998 [12] and take your ability to fight off infections [13) way down. [14]And so without the ability to fight [15] off infections and having pneumonia, I was - [16] they were very concerned at that point in 117] time. Gave me anti biotics and sent me home, [is] So I'm basically over that pneumonia. [19] Q: You've also been prescribed [20] supplemental oxygen; is that true? [21] A: That's true. [22] Q: In fact we have the oxygen tank, the [23] portable tank, right next to you. You've not [24]needed it so far during this session. But [25] could you describe for us, please, what you Page 43 HI need the oxygen for and w hen do you use it? [2] A: Increasingly, especially over the last [3] month, I've noticed decreased lung capacity, a [4] much harder time breathing.And I noticed also [5]inthe hot w eather the heat just - if there [6]was no breeze, if there was no air circulating, p] it was just very,very difficult for me to [8] breathe. 19]And part of it,I think, is that it [ioj tends to make you anxious. And that plays on [11]itselftoo, so that-1 mean it's a vicious [12] cycle. And the more you think you needit,the [13] m oreyouneedit.A ndthe more you use it - I (i4) mean I haven't needed it a great deal, but I usi have at times needed it and I'm glad I had it. [16] Q: In addition to the portable unit that ini youhave here in the living room you also have [is] a much larger unit, a recirculator, correct? [19] A: Correct. [2q Q: W hen you are using the oxygen, would[2i]you tell usw hatisthe flowrate that you [22] are - [23] A: Two millimeters. [24] Q: And that is per minute? [25] A: Yes, I believe so. Page 44 [i] Q: And the capacity of the one tank that [2]you have next to you, that's rated betw een [3] three and four hours; is that true? [4] A: I believe so. [5] Q: Now, you mentioned you've been unable [6] to work? 17] A: Um-hum. [8] Q: Tell us what has happened re cently [9] w ith respect to your work. [ioj A: Well,I tried as long as I could to [ii) continue a normal life-style. And part of that [i2] is going to work. Done it for 27 years, why [i3] stop now. But I found it more and more [i4] difficult to - from an energy standpoint, just us] found it difficult to spend an .entire day at [16] work.So for about a three-week periodl cut [17] back, and I w ould work - one of the weeks I [is] think I worked two days, another week three [i9] days, and a final week two or three days. [20] And that's when I had the pneu monia. [2i] And the doctor said two things;You can't even [22]handle two or three days; and, secondly, this [23] is putting you in an environment where you're [24] more susceptible to be around viruses, the [25] various things that I'm trying to avoid from Page 45 HI the standpoint of infection. [2] So fortunately I have the ability - 1 [3] have accum ulated sick leave, and I have the [4] ability to take some time, right now at least, [5] at full pay. [6] Q: Prior to your disease meso thelioma, [7] would you describe for us what was your general [8] health like? [9] A; I was always on the go. And typical [10] aches and pains, typical 50 year-old complaints (ii) about various things. But generally pretty [121 good health. [13] Q: Trips to the doctors over the 10 years [ 14] prior to this mesothelioma, did you have to go [is] to the doctor? [16] A; I practically live at Kaiser right [17] now. And there were years probably prior to (is) this where I didn't go to Kaiseronce in the (i9)whole year.I didn't need to. [20] Q: O ther than a short bout with malaria [21) back in the army in Vietnam, have you ever been [22] hospitalized in th e 20 years prior to this [23) meso thelioma? [24] A: No. (25) Q: Your m other and father are still Page 4612345*79 [1] living, correct? [2] A; Correct. [3] Q: How old are they? [4] A: My m other is eighty- - 1want to say [5] three but it might be four, and my father is [6] 82. He will be 82 in October. [7] Q: H ow about your grandfather, how long [8] did he live? [9] A: M ypaternalgrandfatherlivedtobe [ioj 99. [in Q: Let me talk to you about your [12] activities and hobbies and family affairs prior (13) to the diagnosis. Could you describe for the (i4) ladies and gentlemen of the jury, just what [isi generally were the things that you and your [16] family enjoyed doing prior to this disease? [17] A: We had kind of a "Leave It To Beaver'1[is] family in that it's rare, I think, but w e did a [191 lot of things together. And we enjoyed doing [20] things toge Behmke Reporting & Video (650) 359-3201Mln-U-Script ther.We have a home up in the 1211Sierras that my father built in 1980 that we [22] use year round. In the w inter w e're up there [23] skiing; in the summer w e're up there fishing, [24] boating, whatnot. [25] My kids have been involved in lots and Page 47 [1] lots and lots of sports and school activities. [2] And over the years we just have - w e've done [3] an awful lot of things together and enjoyed [4] being together. [5] Personally, I enjoy playing golf. I [6] played softball, fished, skied, did a lot of 17] work around my home here. I took a great deal [8]ofpride in the way myhome looked and so as [9] far as maintenance and yard work and that type [ioj of thing, you know, spent a lot of time doing [ii] that. [12] But busy in the sense of good clean [13)activities. I mean lots ofthings we did. [14] Q: W hat were your dreams for the future? [is] A: Well, obviously I have three [16] children. And making sure that they're okay, [17] that - I mean, like anyone, I w anted to see my [i8]daughter go down the aisle. You know, see U9] graduations, those type of things. [20]But it goes beyond that. I am very [21] close to my kids. And I'm very con cerned about [22] them. I'm very con cerned about what this [23] means. (24) MR. THOMAS: Thank you. That's all I have, [25] sir. Page 48 ID THE WITNESS: Pardon? [2] MR.THOMAS: That's all I have. [3] This will conclude the videotape [4] testimony of Mr. Corbal. At tape 1, [5] approximately 11 a.m., w e'll go off the tape. [6] MR. RIFF:W hy don't we go off the record a [7] couple minutes and re organize ourselves. [8] MR. THOMAS: This concludes the vid eotape [9] trial testimony of Ron Coibal and end of tape [ioj 1. [ii] (At 11:01 a.m., the deposition [12] proceedings concluded.) [15] RONALD J. CORBAL Page 49 STATE OF CALIFORNIA COUNTY OF SAN MATEO ) ) ss ) i hereby certify that the witness in the foregoing deposition, RONALD J. CORBAL, was by me duly sworn to testify to the truth, the whole truth and nothing but the truth, in the within-entitled cause; that said deposition was taken at the time and place herein named; that the deposition is a true record of the witness' testimony as reported by me, a duly certified shorthand reporter and a disinterested person, and was thereafter transcribed into typewriting by computer. I further certify that I am not interested in the outcome of the said action, (9) Page 43 - Page 49 Ronald J. Corbai Septem ber 16,1998 nor connected with, nor related to any of the parties in said action, nor to their respective counsel IN WITNESS WHEREOF, I have hereunto set my hand this 29th day of September, 1998. VICKi A. CARR, CSR No. 6260 STATE OF CALIFORNIA Page 50 T ria l Testim ony Ronald J. Corba! et a l v. Chevron Corporation, et a l Page 50 - Page 50 (10) Min-U'ScriptBehmke R eporting & Video (650) 359-3201 Lawyer's Notes R onald J. Corbal, et al. v. C hevron Corporation, et aL T rial Testim ony KOnaia J. eu n n u September 16,1998 $ $4,170 16:19 1 I 8:1; 13:22, 24; 14:2; 49:4,10 10 46:13 101 42:24; 43:4 10:01 7:1 10:02 8:1 10:0813:22 10:11 14:2 10th 8:24 I I 49:5 11:01 49:11 13th 10:14 15 42:10 15th 10:18 16 7:1; 8:2 1710:17 1946 8:24 1965 23:11; 32:12 1968 32:12 1969 11:18; 12:5 197012:13 1971 12:14; 13:2,18; 15:2, 5 1972 9:19; 15:7 1976 11:21; 15:9 1980 47:21 1997 33:9 1998 7:1; 8:2; 33:7 1999 7:9 2 20 46:22 21 10:16 2310 7:10 24 10:13 26 9:21 26th 10:16 2714:23; 18:5; 45:12 3 300 34:23 36 25:3 4 40 25:3,18 5 5 18:1,4 50 46:10 52 8:25 52nd 9:3 6 600 34:23 65 19:5 66 23:11 67 23:11 68 23:11 7 70 19:6; 21:3 7616:1 8 82 47:6,6 9 9 15:7 900 35:1 90067 7:11 911 42:2 99 47:10 9th 9:19 A A.M 7:1; 8:1; 14:2; 49:5, 11 ability 43:12,14; 46:2,4 able 19:5,19; 21:2; 28:6; 41:4,13 Absolutely 26:5; 30:24; 32:10 accumulated 46:3 aches 46:10 acid 33:11,16 acquainted 10:3 action 7:7; 37:20 active 12:17 activities 16:17; 24:4; 47:12; 48:1,13 actually 14:5; 17:14; 18:11 addition 36:17; 44:16 administration 11:16,19 adobe 24:12 adult 9:24; 10:4 advanced 15:19; 17:12; 19:3,15 advancement 17:6 advantage 15:18 affairs 47:12 afternoon 42:21 Again 16:16; 22:25; 27:23; 29:24; 35:21; 38:1; 43:9 ' against 33:25 age 8:25; 19:5,5; 20:25; 21:3 ages 10:ll;41:5 ago 41:24 ahead 22-.il air 41:1 1 ; 44:6 aisle 48:18 Allen 10:13 allow 9:5; 20:23; 29:17 allowing 19:18 along 37:18; 38:8,10 always 26:21; 46:9 American 7:21 Angeles 7:8,10; 8:16 Ann 9:13 antibiotics 43:17 anticipated 19:17 anticipation 38:25 anxiety 40:12 anxious 41:24; 44:10 apparatus 26:25; 27:1 apparently 36:1 appearances 7:16 application 25:15 applied 20:7; 28:2 appreciably 23:17 approximately 8:1; 12:10,13; 13:9,22; 14:2; 16:19; 18:4; 33:8; 42:10; 49:5 approximation 17:21 April 12:13; 34:15 Aptos 37:19 area 23:25; 31:19; 33:21; 36:4; 37:11 areas 36:1 army 12:10,24; 13:2; 32:20; 46:21 around 7:15; 21:18; 23:23; 24:3; 30:16,22; 45:24; 48:7 asbestos 22:8,15; 26:4; 31:7,13,15,17; 32:14,17 aspect 25:8 asphalt 25:9; 26:17,22 assigned 16:7 assist 16:13 assistance 13:14; 14:15; 16:12,15 assisted 37:19 assisting 13:20; 16:9 attending 10:20 attention 21:6; 33:2 automatically 27:11 Avenue 7:9 average 21:24 avoid 29:9,11; 31:14; 45:25 aware 32:13 Behmke Reporting & Video (650) 359-3201 Min-U-Script awful 48:3 B bachelor's 11:16,23; 12:6 back 15:12; 23:6; 27:14, 14,14; 30:7; 33:22; 35:16; 41:9; 42:12; 45:17; 46:21 background 11:14,15; 35:24 bag 26:6; 28:5,10 bagging 29:10,23 bags 26:7; 28:24; 31:4 base 28:24 baseball 28:15 based 24:11 basic 24:4 basically 10:2,21; 22:13, 24; 23:21; 25:9; 26:20; 27:10; 30:3; 32:7; 36:5; 41:9; 42:12; 43:18 basis 28:8 batch 28:1 bay 24:12 beats 28:20 Beaver 47:17 became lO:3;42-.l become 11:3 bed 41:4,10 bedroom 41:12 begin 7:5,17; 9:6; 24:16 beginning 33:19,19 belief 33:12 beneficial 36:22; 38:19, 20 benefit 15:20 benefits 15:16; 16:20 best 28:19; 34:16; 41:8, 15 better 20:2; 25:12; 27:12; 39:6 beyond 32:2; 48:20 BHIRDO 7:20,20 bill 15:16 biopsy 36:8,8 birth 8:23 birthday 9:3; 10:14,16, 17 bit 9:21; 27:23 blood 39:1,2,3,8; 40:20 boating 47:24 Bonesteel7:23 born 8:24 both 9:8; 11:10 bout 46:20 break 13:22,24 breath 33:10 breathe 44:8 breathed 29:7 breathing 29:10, 1 1 ; 31:7,13,14; 44:4 breeze 44:6 briefly 22:4 bring 29:21 bringing 30:5 Brown 7:22 brush 30:5 build 42:12 built 47:21 bushes 22:13 business 11:16,19 busy 48:12 buy 38:6 c California 7:10; 13:12; 20:8 call 31:21 called 24:6; 42:2 calls 36:16; 37:3 came 10:2; 15:11,14; 25:10; 26:23; 42:20 camera 7:12 Campbell 16:7 campus 10:21 can 11:2; 14:25; 17:21; 19:10; 20:7,19; 39:2; 40:15; 41:15 cancer 43:11 capacity 44:3; 45:1 car 29:19; 30:2,8,11 care 21:16 career 32:21 carries 8:19 case 7:24,17:14; 36:2 Casing 21:22 cause 31:8; 33:24 caused 36:4 causing 30:16; 34:2 cells 43:11,11 certain 35:25 change 23:17 changes 40:11 charged 14:14 chart 18:4 check 20:15 checked 42:5 checks 20:16 chemo 37:24 Chemotherapy 37:22; 38:2,10,11,14,21;39:7, 19:40:3,15,18; 43:3,9 chest 33:9; 35:24 Chevron 7:19 children 10:8,12,19; 11:11; 48:16 choking 32:8 chronology 15:1; 35:18; 37:24 circulating 44:6 circumstances 15:12 (1 ) $4,170 - circum stances R onald J. C orbal Septem ber 16,1998 T ria l Testim ony R onald J. Corbal, et aL v. C hevron C orporation, e t aL civil 17:4 classification 17:11; 18:2,2; 23:19 classifications 17:10,25 clean 18:16; 48:12 cleanup 24:3 clear 22:19 climbed 34:12 clinical 36:25; 37:6 close 48:21 clothes 29:4,17,22; 30:6 ,11 cloud 28:19,19 cloudy 35:25; 36:4 coat 24:1; 32:24 coated 24:11; 25:14,25, 25; 26:20 coating 24:2,5,13,21, 23; 25:21; 26:11 coatings 24:10,19 college 10:22,12:8; 19:2, 14; 20:4,18; 21:7,8,11, 13; 22:23; 23:8; 32:19 combination 34:16 combined 26:17 comfortable 34:10 coming 27:1; 32:20; 37:19 commencement 7:25 commercial 21:15 company 14:9;2i:l4 compared 17:23 complaints 46:10 complete 9:6; 26:18; 38:17 completed 12:23; 16:1; 38:16 component 14:12 concerned 42:1; 43:9, 16; 48:21,22 conclude 49:3 concluded 49:12 concludes 49:8 condition 33:3,17 confirmed 36:8 confirming 36:10 connected 25:20 consider 38:5 consideration 17:18 considered 17:11; 20:19; 38:3 constipation 40:10,11 contacted 13:11 contained 26:4 contaminated 29:22 continuation 14:1 continue 19:4,18; 20:21; 37:13:45:11 continued 20:24; 33:17 continuing 19:17; 28:8 continuous 26.-13 contracted 21:16 civil - forth (2) control 27:2; 34:8,19; 35:13 controlled 35:9 controlling 34:17; 35:7 copies 36:16 Corbal 7:7,14,8:4,12, 13; 14:4; 49:4,9,15 corporate 21:18 Corporation 7:21 counsel 7:15 count 39:8 country 37:5 counts 39:2,3 County 7:8 couple 41:23; 49:7 course 37:20 court 8:19; 9:9 cousin 10:1 covering 27:13 Cruz 10:21,22; 11:1; 20:9 CT 36:4 current 16:18; 17:11,24; 18:7 currently 10:20; 16:5; 17:9 cut 20:16; 45:16 cycle 38:15,16,17; 44:12 D danger 30:20 darned 32:8 date 8:23 dating 10:4; 15:7 daughter 10:17; 11:5; 14:5; 19:1,14,22; 42:23; 48:18 daughter's 14:7 Davis 7:9 day 30:1,2; 34:23; 35:2; 38:13; 40:13; 42:22; 45:15 days 26:6; 28:5,10; 40:21; 41:2; 45:18,19,19, 22 deal 10:24; 18:12,19,25; 33:10; 34:4; 42:18; 44:14; 48:7 dealing 35:13 dealt 25:3 December 33:8; 34:5 decent 18:13 decreased 44:3 defendants 7:24 deferment 12:7,8 definitely 20:18; 29:5 degree 11:16; 12:6; 13:4; 15:19; 16:2 degrees 19:3,15 denied 39:4, 5 Department 13:13; 14:11,13; 37:17 depended 24:13 depict 35:25 ' deposition 49:11 describe 11:13; 17:1; 24:22; 25:7; 26:8; 28:13, 25; 33:5; 34:18; 35:17; 37:23; 40:5,25; 41:22; 43:25; 46:7; 47:13 describing 32:4 desired 21:3 details 18:3 determine 39:2 determined 42:3,6; 43:8 Development 13:12; 14:11 diagnosis 33:6; 35:18; 36:10; 47:13 diarrhea 40:11 different 27:20; 40:14 difficult 44:7; 45:14,15 direct 16:14 dirt 28:16,18 disabled 20:6 discharge 12:16 disease 33:3,25; 46:6; 47:16 doctor 33:12; 35:19,21; 37:18; 45:21; 46:15 doctors 46:13 Done 45:12; 48:2 door 17:7 dosages 35:3 doubt 24:20 down 27:1,2; 42:13; 43:13; 48:18 drafting 11:25; 12:23 dreams 48:14 drive 30.7 drivers 23:23 drugs 38:11; 39.23,25 dry 26:7,16,19; 28:2,8 duct 26:25 due 17:18; 38:17 duly 8:5 During 13:11; 21:8,10; 22:8,21; 237,15; 25:15; 26:2; 28:5; 29:10; 30:8,14; 31:12; 32:12; 34:4; 43:24 dust 28:19,19,21; 29:3, 6,10,12,18; 30:10; 31:8, 13:32:8,25 dusty 28:11,12,22; 29:17,22; 31:19,25; 32:8 duties 22:21 duty 12:11,12,17 dynamics 37:1 E early 38:18 easier 97 easy 13:5 EDD 13:16,19; 14:9,9, 10,19; 15:4; 16:3; 17:5; 18:5; 20:24; 32:20 educational 11:14,15 effect 30:20; 34:2; 40:3 effective 36.12 effects 40:4,9 eighty 47:4 either 29:18 eligible 37:14 emergency 39:16; 42:6; 43:2,6 employers 13:6; 14:15; 16:10 employment 13:3,10, 12,17,20; 14:9,10; 15:3, 4; 16:5,12; 32:21 end 25:23; 27:7; 37:9; 49:9 ended 30:2,11; 42:18 ends 25:14,25; 26:10; 27:24; 28:3 energy 45:14 enjoy 18:20,21; 48:5 enjoyed 47:16,19; 48:3 enjoying 18:15 enlisted 12:19 enough 21:21; 37:12 entire 22:1; 32:14,21; 45:15 entitled 15:17,20 environment 45:23 equate 28:22 ER 41:19 esophagal 33:13,14 esophagus 35:23 especially 17:4; 36:15; 44:2 essence 30:21 establish 11:3 estimate 19:16 even 19:2, 5,15; 23:18; 38:3; 45:21 evening 41:24 exactly 16:3; 257 EXAMINATION 8:8 example 25:10; 42:9 exception 26:21 excruciating 33:23; 34:12 excuse 38:12 expect 30:15 expected 30:21 expenses 20:14 expensive 20:5 experience 13 7 ,8 experienced 40:2,4; 42:17 experiencing 33:6,9; 35:14; 41:25 expose 22:15 exposure 22:8; 32:17, 18,24 exposures 32:13 extremely 20:4 extrusion 25:5 F fact 9:2; 29:21; 41.5; 42:15,21; 43:22 fair 19:3 fairly 13:5; 18:13; 34:17 fall 20:15 family 15:23; 47:12,16, 18 far 31.17; 33:16; 43:24; 48:9 fashion 31:7 fast 27:21 father 46:25:47:5,21 February 34:5 feel 18:22; 40:16 fees 20:10,12,13 feet 25.22; 40:13 fellows 28:7; 297 felt 35:22; 36:9; 395; 42:22 feverish 42:22 few 17:8; 41.7 field 16:6,6; 25:24; 26:1, 12,18; 27:24; 28:1,3 fields 28:15 Fifty-two 9:1 fight 43:12,14 fill 287 filling 26:7; 27:9; 28:10 final 45:19 Finally 34:15 financial 11:10 find 13:17,20; 34:10,11; 37:5 fine 9:16; 20:1 finely 28:16 finish 26:1 finished 26:13 firm 7:9; 21:15; 41:10 first 8:5; 21:12; 23:4; 41:6,23 fished 48:6 fishing 47:23 floor 41:12 flow 44:21 focus 18:24; 21:5; 39:18 focused 33:21 Following 12:16; 21:20; 40:15 follows 8:6 foolish 15:17 foot 25:3,18,22,22 foremost 24:20 forklift 23:23 form 35:2 Fort 12.9 forth 27:14,14,15; 30:7 Min-U-Script Behmke Reporting & Video (650) 359-3201 Ronald J. Corbal, et aL v. C hevron C orporation, et al. T ria l Testim ony fortunate 21:20,22; 40:7 fortunately 46:2 forward 18:14 found 45:13,15 four 21:25; 23:16; 27:5; 34:9; 38:12,13:39:22; 45:3; 47:5 frame 23:10 free 26:11 freshman 22:6,23 Friday 38:13,25; 40:19; 42:20 Fridays 38:22; 39:20 friend 9:25 friends 36:17 front 33:21 full 15:23; 20:21; 27:9; 41:13; 46:5 full-time 15:4 furniture 34:13 future 18:13; 48:14 G game 10:4 games 10:3 garden 31:22 gave 32:1; 43:17 gene 37:1 general 23:4; 46:7 generally 46:11; 47:15 gentlemen 47:14 Gl 15:15 given 8:17; 13:15; 18:11, 18,24; 19:13,17; 33:15; 40:1 glad 44:15 goes 9:16; 10:22,23; 48:20 golf 48:5 Gonzaga 19:25 good 25:22; 43:11; 46:12; 48:12 Gordon 7:20 gosh 24:15 government 17:4 graduated 10:25; 12:5 graduating 32:19 graduations 48:19 grandfather 47:7,9 great 10:24; 18:11,18, 25; 20:1; 33:10; 34:4; 44:14; 48:7 Grosken 21:14; 22:6,21 ground 28:16 group 16:8 grown 34:1 guess 19:20; 26:17; 35:24;39:10,12; 40:7 guest 13:23 gunnysack 27:18 gunnysacks 27:6; 28:7 guy 27:12 H Haight 7:22 hair 40:6,8 half 15:25; 25:22 handle 45:22 handles 27:2 happened 17:2; 39:4; 45:8 harder 44:4 harm 30:17; 31:9 harmful 30:20; 31:1 head 37:17 headquarters 21:18 health 17:16,19; 19:18; 20:23; 31:1; 46:8,12 heard 14:5; 43:1 heartburn 33:11,16 heat 44:5 hectic 15:25 height 29:2 help 32:2; 33:16; 42:8 helping 13:16; 23:22; 36:18 high 11:7,9; 19:1,23; 21:13; 22:5,22; 24:16; 28:25,25 higher 17:10 hills 23:1 himself 11:3 hired 13:18 hit 34:15 hobbies 47:12 home 8:14; 10:19; 11:1, 5,6; 19:14; 29:18,19,21; 30:3,12; 42:20,25; 43:17; 47:20; 48:7,8 hopefully 17:13 hospitalized 46:22 hot 44:5 hours 36:15; 39:23; 45:3 house 15:24 I iffy 41:8 importance 18:23 important 22:2 inches 25:2 included 23:22; 26:22 income 20:20,22 Incorporated 2 1 :14 increase 17:22; 18:1; 35:5; 42:19 increased 35:4 Increasingly 44:2 indeed 36:11 independent 11:4,4 indigestion 33:11 individual 12:19 individuals 16:8; 27:5, 16 industrial 11:17;21:15 inexpensive 31:22 infantry 12:11 infection 39:9; 42:7; 46:1 infections 39:13,15; 41:18; 43:12,15 information 13:15; 16:11; 32:2; 36:19 informed 12:7 infused 39:24 infusion 39:21 initial 12:23 injury 30:23 instructed 31:11; 32:1 insurance 14:16 internal 13:16 Internet 36:16 interrupt 22:3 into 11:25; 15:1; 18:12; 20:16; 23:25; 34:1; 37:8; 43:6 introductions 7:4 invaded 37:11 involved 14:18; 15:13; 32:22; 47:25 issues 16:13 ivy 22:13,25 J J 8:4,12; 49:15 James 10:15 January 33:20; 34:5 Joanne 7:22 job 13:5,13; 14:12,15, 21; 16:10; 21:21; 22:20; 25:19,20; 26:1,13,18; 28:5; 30:8 jobs 21:8; 26:2; 31:12; 32:12,16,22 Johnson 7:19 Jose 11:17, 20; 12:6; 34:7; 37:16 July 9:19; 15:7; 38:10 jump 30:2 June 10:17,18 jury 8:15; 47:14 K Kaiser 34:7; 37:16; 46:16,18 Kathleen 9:13 Kathy 9:16,18,23 keep 15:23 Kelly 7:20 kicked 28:18 kids 47:25; 48:21 kill 43:10,11 Behmke Reporting & Video (650) 359-3201 Min-U-Script Ronald J. Corbal Septem ber 16,1998 kind 18:16,19; 20:16; 47:17 kinds 31:24 knowledge 22:7,15 Kristin 14:7 L Labor 14:13; 24:4 laborer 22:24; 23:18,20 lack 25:12 ladies 47:14 laid 24:12 landscape 21:15 larger 44:18 largest 25:2 Larry 7:18 last 9:3,4; 14:23; 40:18, 19; 41:6; 42:20,21; 44:2 later 13:8; 33:24; 42:25 law 8:19 lawsuit 8:15 lay 41:9 Leading 19:7; 22:10 learned 15:15 least 38:6; 46:4 leave 46:3; 47:17 left 33:21,22; 41:7 lengths 25:4,18 less 29:2 letter 17:14 level 17:12; 18:7; 29:1; 35:6,6 levels 17:13 Levi's 29:25 Lewis 12:9 life 32:14; 34:10; 35:13 life-style 45:11 Light-headedness 40:12;41:25 lists 17:10 little 9:20; 11:24; 21:24; 31:20; 32:3,4; 42:22 live 46:16; 47:8 lived 47:9 lives 10:21 living 10:19; 11:4; 20:14; 44:17; 47:1 load 27:25 loam 24:13 long 19:4,16,20; 31:23; 39:19; 45:10; 47:7 longer 12:7 look 20:19 looked 37:2; 48:8 looking 13:3, 9; 16:1 1 ; 18:3,14; 19:23,25; 20:2; 36:20,25:37:1,7 Los 7:8,10; 8:16 loss 40:6,8 lost 42:10 lot 9:7; 43:6,7; 47:19; 48:3,6,10 lots 47:25; 48:1,1,13 Louisiana 37:4 low 18:7; 39:3,8 lung 44:3 M machine 25:4,5,11,13; 26:19,23,25 machines 24:1 madam 8:2 maiden 9:15 maintained 15:24 maintenance 48:9 majority 24:15 makes 18:22 making 36:16,16; 48:16 malaria 46:20 manage 16:8 management 11:17; 34:6 manager 16:6 mandatory 20:24 many 14:17; 17:5; 21:6, 6; 24:3:36:15,15,15 March 10:16,16; 12:14; 15:2; 33:7; 34:6; 35:16 Marie 14:7 marriage 10:6 married 9:10,14,18,19, 20; 15:7 mask 31:22 masks 31:20,21;32:3,4 master's 11:19,23:15:8 material 26:16; 28:8,23; 30:6,22 materials 25:9; 36:17 matter 24:25; 34:12,13 mattress 41:12 MBA 16:1 mean 18:12; 19:20; 28:17, 20; 31:24; 41:15; 42:16; 44:11,14; 48:13,17 meaning 21:23 means 48:23 meant 20:8; 26:24 medical 33:3 medication 33:15; 35:3; 42:19 medications 34:16,18, 21; 42:8 meet 9:23; 10:1 mentioned 9:25; 26:10; 45:5 mesothelioma 33:4,7; 35:19; 36:6,9,11,23; 38:1 46:6,14,23 met 15:6 Mexiletine 34:25 middle 10:20; 12:13 (3) fortunate - m iddle Ronald J. C orbal Septem ber 16,1998 might 30:4; 38:6; 47:5 military 12:4,17,17,24 milligrams 34:23,23; 35:1 millimeters 44:23 mind 30:19 mine 9:25 Minor 35:11 minute 44:24 minutes 42:25; 49:7 mix 26:8,16,19; 28:2 mixture 26:12,22 moment 35:12; 39:14 money 20:2, l l month 16:19; 44:3 months 13:9; 22:1; 34:9; 38:9;41:23 more 11:4; 21:24; 29:2; 33:14; 40:9; 42:14; 44:12, 13,13;45:13,13,24 morning 18:15 morphine 34:22; 35:1 most 13:6; 17:25; 24:25; 35:7; 36:21,22; 37:10 mostly 22:25 mother 46:25; 47:4 move 23:23,25 Mrs 7:7 MSCONTIN 34:22,24 much 37:11;44:4,18 must 43:5 myriad 16:16 N name 7:6,18;8:10; 9:12, 13,15; 14:6,6,7; 17:17; 24:6; 37:2 names 10:10 rational 14:12 nature 21:19; 31:18; 33:14;37:13 nausea 39:24,25; 40:2, 10; 41:25; 42:9,15,19 need 9:15; 20:20; 44:1, 12,13; 46:19 needed 27:24; 43:24; 44:14,15 reeds 16:12 verves 34:2 aw 15:23,24; 17:23; ; *12 next 12:10; 38:16; 40:19; 43:23; 45:2 right's 41:13 Fione 22:12 normal 45:11 normally 25:2 1; 26:20; 39:22 notice 11:24 noticed 44:3,4 November 33:8 number 7:23; 13:14,22 numbness 40:13 nurse 34:6 o oath 8:17,18 Objection 19:7,9; 22:10, 18 obligatory 7:4 obtain 15:4 obtained 11:18,20 obviously 11:5; 25:18; 34:1; 48:15 occur 24:24 occurred 36:1 October 13:18; 15:4; 47:6 Off 10:21; 18:12; 23:24; 27:3,10; 29:17; 30:5; 38:14; 43:12,15; 49:5,6 office 16:6,7,8; 32:22 often 27:22 old 47:3 older 10:25 oldest 10:12 once 13:8; 27:9; 39:4; 46:18 oncologist 37:15 one 10:3,5; 14:21; 15:14; 17:14; 19:24; 21:19; 24:10; 27:6; 30:25; 32:1; 34:21; 38:12,16; 41:24; 43:2; 45:1,17 only 10:5; 14:21; 15:19; 26:15; 37:20 onto 27:18,19 open 27:3,8 opened 17:7; 27:11 openings 17:12 operating 7:12 opportunities 17:5,8 opportunity 16:22 Oramorph 34:22 order 11:3; 20:2 1; 26:18 ordered 36:7 ourselves 49:7 out 13:1; 14:22; 15:1,14; 20:15; 28:1; 37:5; 39:13; 41:5; 42:5 outside 24:2 over 9:21; 17:6; 18:5; 27:7; 29:3; 34:13; 35:4; 37:5; 42:5; 43:18; 44:2; 46:13; 48:2 overcome 42:8 own 28:1; 30:8 oxygen 43:20,22; 44:1, 20 m ight - respirators (4) T rial Testim ony R onald J. Corbal, et al. v. C hevron C orporation, et'al. P package 18:14 paid 21:23 pain 33:9,17,20,25; 34:3,6,8,11,14,17,18, 19; 35:3,7,9,10,13; 41:3 pains 46:10 pallet 27:19,19 paper 32:4 paramedics 42:3 Pardon 19:8; 49:1 part 19:21; 35:7; 44:9; 45:11 particular 27:3; 30:1; 37:6; 39:7 past 21:6 paternal 47:9 patterns 40:25 pay 16:19; 17:22; 20:3, 11,13; 22:1; 46:5 payments 15:21 penalty 8:20 pending 7:8; 8:15 Pennsylvania 37:3 people 16:11; 18:21 per 16:19; 18:25; 31:16; 44:24 percent 18:1,4 percentage 24:16 perhaps 19:2,15; 33:12 period 12:18; 15:2; 21:7; 22:4; 34:5; 45:16 perjury 8:20 perpetuation 7:14 person 15:20; 27:6 personal 30:23 Personally 48:5 perspective 15:1 phone 36:16; 37:3 photo 37:1 physical 31:8 physically 19:5 picture 23:5 Pipe 21:21; 23:4,7,15, 23,25; 24:2,6,11,11,14, 17,19; 25:1,1,3,4,13,13, 24; 26:3,11,14, 20; 27:24, 25; 28:3; 30:15; 31:12; 32:11 pipes 24:23; 25:14 placed 25:4 placement 16:15 placing 25:1 plans 18:10 plant 24:11 planting 21:16; 22:13,25 plants 21:16; 22.14; 23.1, 2 played 8:15; 48:6 playing 9:24; 48:5 plays 44:10 please 8:3,11; 10:1 1 ; 11:13; 17:2; 21:9; 26:9; 33:5; 35:17,20; 37:23; 41:1,22; 43:25 pleural 3 7:ll . plus 16:20 pneumonia 43:8,15,18; 45:20 point 20:4; 32:21; 35:18; 38:4; 42:13; 43:16 poisons 43:10 polite 11:23 portable 43:23; 44:16 portion 12:17 position 13:16; 16:3; 18:8; 21:23,24; 34:10 positions 13:15 possibilities 19:24 possibility 36:6,7 potential 32:13 pounds 42:10 powder 28:17,17 practically 46:16 precaution 31:14 precautions 31:25 predict 40:16 predominantly 23:2 preliminary 39:23 prescribed 42:7; 43:19 presence 12:8 present 7:15; 34:20; 35:5 presented 16:23 presently 16:4 pressing 33:25 pressure 41:3 pretty 27:21; 46:11 prevent 39:25 pride 48:8 primary 34:21; 40:9 Prior 46:6,14,17,22; 47:12,16 private 37:18 privy 25:7 probably 23:19; 33:18; 42:4; 46:17 procedure 36:24 proceedings 49:12 process 24:22; 25:6,8, 15; 26:7,8; 27:17; 28:11; 29:10,23; 37:24; 39:21 product 35:1 program 16:1,5 programs 14:17 promotion 16:23; 17:18, 23 promotional 17:8,9 provide 11:10 provided 29:13,16 provides 14:16 providing 14:14; 16:14, 14,15 pruning 22:13; 23:1 public 16:9,10 purposes 7:15 pursue 15:19 pursued 33:12 put 14:25; 23:24; 24:1, 19,21; 43:10 putting 28:24; 45:23 Q qualify 37:7,7,10 quickly 27:17; 28:6 quite 15:25; 27:22,23; 41:10 R ran 24:17,17; 26:21 ranges 18:1 ranks 18:6 Rapid 7:21 rare 47:18 . rate 16:19; 44:21 rated 45.2 rather 31:18; 40:8 reaches 43:4 really 10:23; 11:2; 18:18, 24; 19:19; 37:20; 39:13 reason 22:7; 30:19; 43:5, 5 receive 8:18; 38:21; 39:6 received 16:2 recent 16:22 recently 17:6; 39:16; 41:19; 45:8 Recess 13:25 recirculator 44:18 record 7:5; 8:11; 14:6; 22:19; 49:6 Rees 7:21 referrals 16:15 referred 13:14; 37:15 reflux 33:13 regarding 36:12 regimen 38:1 1 ,1 2 relative 35:8 relatives 36:17 remember 9:5 reorganize 49:7 repeat 38:15 rephrase 19:11; 22:17 reporter 8:2; 9:9 represent 7:19 representative 13:19 representing 7:7,23 requested 12:9 reserved 12.19 respect 31:1; 45:9 respected 37:18 respirators 29:13 Min-U-Script Behmke Reporting & Video (650) 359-3201 Konaki J. Corbal, et al. v. Chevron Corporation, et a l T rial Testim ony respond 38:1 response 22:18 responsible 16:9 result 29:22; 37:9 retire 18:10 retirement 18:13,25; 20:20,25 return 15:18,22 returned 11:1 rib 33:21; 34:1; 41:4 rich 11:24 Richard 10:15 RIFF 7:18,18; 19:7,9; 22:10; 49:6 right 13:21; 19:22,22; 32:6; 35:10; 41:7; 43:23; 46:4,16 Robert 10:13 Ron 49:9 RONALD 8.4,12; 49.15 room 37:12; 39:16; 44:17 ROSEN 7:22,22 round 47:22 run 25:5; 26:14,19:35:21 s S-o-m-a-s-t-i-c 24:8 sack 27:7,8,9,13 sacks 27:18 Sam 11:25; 15:21 same 8:18,19; 26:21 San 11:17,20; 12:6; 34:7; 37:16 sand 28:20 Santa 10:21,22,25; 20:9 saved 20:l l saw 28:20; 31:4 saying 24:18 scan 36:5,5 scholarship 20:2 school 10:23; 11:7,9; 15:12,18; 19:2,23; 21:13; 22:1,5,22; 48:1 se 18:25:31:16 search 36:12 second 10:15; 22:4; 38:17; 42:14 secondly 45:22 seekers 14:15;16:10 seeking 15:3 seems 35:6 selected 17:13,15 semester 20:16 senior 11:7,9; 19:23; 22:5,22 sense 18:23; 48:12 sent 25:23; 43:17 SEPTEMBER 7:1; 8:2, 24; 10:14 serious 36:7; 40:9; 42:4 serve 12:4 served 12:11,19 service 11:25; 12:24; 13:13; 14:12, 22; 15:2,14; 17:4 services 16:16 session 43:24 set 10:2; 27:20,21 shaping 23:1 shirts 31:23 short 13:21; 25:23; 46:20 shortness 33:10 shoulder 28:2 5; 29:2 showed 36:3 shut 27:3,10 sick 46:3 side 22:25; 27:4,11,12; 40:2,4,9:41:7 Sierras 47:21 simply 28:6 single 27:25 site 25:19,20 situation 19:13;41:1,10 six 12:22; 13:9 skied 48:6 skiing 47:23 sleep 40:24;4l:4,14,17 sleeping 41:1,1 1 sleeve 31:23 slight 14:4 softball 9:24; 10:4; 48:6 soil 21:17; 24:12 Somastic 24:7,8,18,20, 23; 25:10,15,20; 26:4,7, 16; 28:2; 30:16,25; 31:8, 13,17 someday 18:14 Sometime 33:19; 41:11 sometimes 27:20; 40:10 son 10:15,20,25 sons 20:9 soon 43:1 Southern 21:21; 23:4,6, 15; 26:3; 30:15; 31:12; 32:11 space 37:12 specialist 35:23; 37:16 specialists 37:4 speeds 27:20 spend 10:23; 15:2; 45:15 spent 12:9; 139; 22:25; 34:4,9; 36:15; 48:10 spigot 27:7,13 spigots 27:2; 28:24 sports 48:1 spread 25:11,12 stack 27:19 staff 16:13 stage 39-18 stand 27:6 standard 36:23; 38:2 standing 27:12 standpoint 45:14; 46: l stands 14:10 Stars 7:10 started 10:4; 13:3; 33:9, 18,20; 38:9,10 starting 15:22 state 7:16; 8:10; 11:17, 20; 12:6; 13:11,13; 14:11 statement 31:6 statements 7:4 steel 23:23; 24:23; 25:1, 1,3 Steptoe 7:19 sterilizing 21:17 Still 10:19; 14:19; 19:1, 14; 20:13; 33:17; 46:25 stomach 41:5 stop 45:13 stopped 25:22 Storm 28:20 studies 37:10 study 37:13 stuff 18:17 substitute 11:2 sudden 17:7 suffering 33:13 Suite 7:10 summer 21:8,12,19,20, 24; 22:9,22; 23:11,17,18; 26:2; 31:12; 32:12; 47:23 summers 21:10; 23:7, 15; 30:8,14 Sunday 10:13 supplemental 43:20 support 11:10 sure 18:12; 22:18; 23:18; 29:24; 30:4,5; 48:16 survive 20:20 susceptible 45:24 suspicious 36:3 swear 8:3 sweatshirt 29:25 swelling 40:13 sworn 8:5 symptoms 33:5 system 14:12; 20:8; 43:10 T tablet 34:22,35:2 talcum 28:17 talk 13:7; 21:7; 26:6; 40:24;47:11 talked 17:3 talking 23:10 tank 43:22,23; 45:1 tape 8:1; 13:22,24; 14:2; 49:4,5,9 tar 25:9 target 39:9 teaching 11:2 team 9:25 Behmke Reporting & Video (650) 359-3201 Min-U-Script Ronald J. Corbal Septem ber 16,1998 technical 25:8 telling 14:8 temperature 42:23; 43:4 tends 44:10 test 39:1 testified 8:5 testimony 7:13; 8:14; 49:4,9 tests 35:21; 40:20; 43:7 therapy 37:1; 39:19 thinning 40:8 THOMAS 7:3,6,9,25; 8:9; 13:21; 14:1,3; 19:11, 12; 22:16; 48:24; 49:2,8 thought 18:12,19,25; 30:18 three 10:12; 21:25; 28:6; 39:15, 22; 41:16,19; 45:3, 18,19,22; 47:5; 48:15 three-week 45:16 throw 27:18 Thursday 38:24 Thursdays 39:1 tie 27:17; 32:24 times 20:14; 33:22; 41:8, 16,19; 44:15 tingling 40:12 today 7:13; 8:13; 40:19 together 25:11; 47:19, 20; 48:3,4 told 13:6; 23:22; 30:25; 33:24; 35:19; 36:5 Tom 7:6 tomorrow 40:20 took 31:24; 42:5,23; 48:7 top 27:17 total 40:8 tour 12 :1 1 ,1 2 trainee 18:7 training 16:11,13 transport 29:18 treatment 36:12,22,23; 38:21,25; 39:4; 40:18,20, 21 treatments 37:25; 38:2 trial 7:14; 8:14; 49:9 trials 36:25; 37:6 tried 41:7; 45:10 Trips 46:13 trucked 25:19 trucks 23:24,24 true 43:20,21; 45:3 try 22:1; 30:4; 38:6; 39:24; 42:12 trying 15:23:34:7,10; 35:13; 37:5; 45:25 tuition 20:6 turn 33:2 turned 10:13 Twenty-six 9:22 twice 34:23 two 12:10; 15:25; 17:9; 20:9; 25:2,22; 27:2,16; 34:21; 38:9,11,14; 39:25; 40:21; 41:16; 44:23; 45:18,19,21,22 type 21:23; 31:22; 48:9, 19 types 24:4 typical 46:9,10 u U.S 12:24 UC 10:21,25; 20:9 ultimate 28:21 Ultimately 12:22; 15:3,7; 16:2 Um-hum 12:21; 35:15; 45:7 unable 45:5 unbelievable 36:18 uncle 11:24,24; 15:21 under 14:13; 15:15; 17:23; 24:12 unemployment 14:16 Unfortunately 13:6; 37:9 uniforms 29:16 union 21:23;23:19 unit 44:16,18 universities 19:24,25; 37:4 University 11:18,20; 20:8 up 10:2; 18:6,7,15,16; 195; 21:2; 25:10; 30:11; 33:6; 34:7; 35:5; 37:19; 4 l:l6 ;4 2 :1 2 ,18; 47:20, 22,23 upside 27:2 use 29:14; 44:1,13:47:22 using 25:21; 44:20 usually 27:5 Utilized 34:19 V various 19:24; 21:17; 25:9:45:25; 46:11 veteran 13:4; 20:6 veteran's 13:19 veterans 13:16 vets 13:20 vicious 44:11 video 7:5,12; 9:8 videotape 49:3,8 videotaping 7:13;8:14 Vietnam 1 2 :1 1 ,12; 46:21 virtually 35:12 viruses 45:24 visits 39:16 (5) resp o n d - visits ko naia j. corba! Septem ber 16,1998 w waived 20:10 waiver 20:7 wake 41:16 waking 35:12 warnings 31:4 Washington 12:9 watch 39:13 watering 22:14; 23:1 way 18:6; 26:15,21; 29:9, 11;43:1,13;48:8 ways 34:8 weak 42:11 Wear 31:23; 32:9 wearing 30:1; 31:20; 32:24 weather 44:5 WEDNESDAY 7:1; 40:19 week 9:3,4; 38:13,17; 39:7; 45:18,19 weeks 38:12,13,14; 45:17 welded 25:24 whatnot 15:24; 42:1; 43:7; 47:24 whatsoever 22:12 wherever 30:6 white 39:8 whole 16:16; 46:19 wife 10:2; 11:11; 15:6; 36:14; 42:1,25 wife's 9:12,13 winter 47:22 withdraw 17:17 within 16:6; 17:3; 20:7 without 13:7; 18:3; 24:20; 30:16,22; 35:9; 43:14 witness 8:3; 19:8; 22:12; 49:1 wonderful 20:1 word 25:12 words 31:16 work 13:19; 14:19; 15:3; 18:16; 19:17, 20; 20:24; 21:2,10; 23:3; 26:25; 30:15,21; 32:11,20; 42:21; 45:6,9,12,16,17; 48:7,9 worked 18:6; 21:13; 23:6; 42:22;45:18 working 15:23; 18:21; 19:4,18; 20:21; 21:25; 22:6,21; 23:14; 30:14; 34:6 works 10:22; 36:24 workshops 16:14 worse 33:18,20 writing 20:15,17_______ w aived-young (6) T ria i Testim ony R onald J. Corbal, et aL v. C hevron C orporation, et aL Min-U-Script Behmke Reporting & Video (650) 359-3201