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FILE NAME: Reddaway Manufacturing REDD DATE: 2012 May 17 DOC#: REDDO12 DOCUMENT DESCRIPTION Legal - Deposition Raymond Raymond Lecki ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Page 1 IN THE UNITED FOR THE EASTERN STATES DISTRICT COURT DISTRICT OF PENNSYLVANIA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 IN RE ASBESTOS PRODUCTS LIABILITY LITIGATION NO VI = _ =- - -_ -_ - _ _ - - - - -_ - -_ - -_ This Document Relates to ERIK ROSS PHILLIPS and GINA PHILLIPS spouse Plaintiff Civil Action No. MDL 875 - : EDPA File No 60074 VS. ALBANY INTERNATIONAL et al CORPORATION Defendants DEPOSITION of RAYMOND J. LECKI taken at Hilton Garden Inn Lakewood 1885 Route 70 Lakewood New Jersey on Thursday May 17 2012 commencing at 10:17 a.m. before Jamie I. Moskowitz a Registered Profession Reporter and Notary Public Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL , ET AL Raymond J. Lecki on 05/17/2012 Pages 2..5 1 APPEARANCES Page 2 1 EXHIBIT NUMBER DESCRIPTION Page 4 PAGE 2 WALLACE and GRAHAM PA 3 BY JOHN S. HUGHES IV ESQUIRE 525 North Main Street 4 Salisbury North Carolina 28144 jhughes@wallacegraham.com 5 800.849.5291 Counsel for Plaintiff 6 2 Exhibit No. 15 Sample Order 3 Exhibit No. 16 Document entitled Product Information Sheet 4 5 6 63 106 7 7 COZEN O'CONNOR 8 BY DEXTER R. HAMILTON ESQUIRE 8 1900 Market Street 9 Philadelphia Pennsylvania 19103 9 215.665.2166 10 dhamilton@cozen.com 10 Counsel for Defendant Reddaway 11 Manufacturing 11 12 12 DEHAY ELLISTON 13 BY PATRICK C. SMITH ESQUIRE 13 36 South Charles Street 14 Baltimore Maryland 21201 14 jhughes@wallacegraham.com 15 800.849.5291 Counsel for Defendant Pneumo Abex LLC 15 16 16 17 DEAN & GIBSON PLLC BY AMY C. DRAYTON ESQUIRE 18 Cameron Brown Building Suite 900 301 South McDowell Street 19 Charlotte North Carolina 28204 704.372.2700 20 adrayton@deanandgibson.com adrayton@deanandgibson.com Counsel for Defendant Pemco Inc. 21 Telephonically 22 ALSO PRESENT 17 18 19 20 21 22 23 TODD WALKER 23 Representative of Reddaway 24 24 SCOTT LINDENBAUM 25 Legal Video Specialist 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX Testimony of RAYMOND J. LECKI By Mr. Mr. HughesHughes .8 .8 111 By Mr. Hamilton 96 By By MrMr.. SmiSmith thSmith .102 115 115 - - - EXHIBITS EXHIBITS EXHIBITS EXHIBITS EXHIBITS - - - EXHIBIT EXHIBIT NUMBER Exhibit No. 1 Exhibit No. 2 Exhibit No. 3 Exhibit No. 4 Exhibit No. 5 Exhibit No. 6 Exhibit No. 7 Exhibit No. 8 Exhibit No. 9 Exhibit No. 10 Exhibit No. 11 Exhibit No. 12 Exhibit No. 13 Exhibit No. 14 DESCRIPTION Letter to M. Wallace from A. Drayton dated 5/4/12 Handwritten Notes Photograph Sales Record Shipping & Receiving Sample Order Sample Order Document entitled Redco News Memo Document Material Sheet entitled Safety Data Sample Order Sample Order Shipping & Receiving Sales Record Page 3 1 2 3 4 5 6 7 8 PAGE 9 7 10 11 14 12 15 13 33 14 33 15 33 16 46 17 50 18 63 22222 63 22222 22222 63 22222 63 23 63 24 63 25 DEPOSITION SUPPORT INDEX INSTRUCTIONS NOT TO ANSWER Page Line None REQUEST FOR PRODUCTION OF DOCUMENTS Page Line Line Description Description Description None STIPULATIONS : Page Line Line None QUESTIONS MARKED Line Page Line None Page5 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 6..9 Page 6 1 THE VIDEOGRAPHER This is the 1 2 beginning of tape number one in the deposition 2 3 of Raymond J. Lecki in the matter of Eric Ross 3 4 Phillips versus Albany International 4 5 Corporation et al Civil Action number MDL875 5 6 Today's date is May 17th 2012 the 6 7 time is now 10:17 7 ~ 8 My name is Scott Lindenbaum I am the 8 9 videographer The court reporter is Jamie 9 10 Moskowitz We are here with Huseby Court 10 11 Reporting 11 12 Counsel please introduce yourselves 12 13 after which our court reporter will swear in 13 14 the witness 14 Page 8 going to agree to dismiss those four defendants without prejudice and reserving their claims against the remaining defendants And we understand that the defendants I've just listed deny liability And Amy is there anything you want to add to that MS DRAYTON Thank you John Just real quick I'll state for the record that the E.C.H. Will GmbH and Korber Paperlink GmbH were never actually served in this case and Korber Paperlink North America Inc. and Korber Paperlink North America LLC are no longer in existence 15 MR HUGHES John Hughes for the 16 plaintiffs 17 MR HAMILTON Dexter Hamilton Cozen 18 O'Connor for Reddaway Manufacturing defendant 19 MR SMITH Patrick C. Smith on behalf 222222 of Pneumo Abex LLC 222222 MR HUGHES Could the folks on the 222222 phone introduce themselves 15 And then finally as you know John 16 the May 4th letter we need to assert that that 17 letter in no way admits any successor liability 18 of Pemco or continues to accept any liability 19 of Aiken Matik or the Clark Aiken 20 Company I think that's it Thanks John 21 MR HUGHES Okay 22 EXAMINATION BY 222222 MS DRAYTON Amy Drayton for the 222222 defendant Pemco Inc. 222222 MR HUGHES Is there anybody else on 222 MR HUGHES 222 Q 25 record Sir can you state your name for the 1 the phone Page 7 1 A Raymond John Lecki Page 9 2 Okay And then who else do we have in 2 Q Can you spell your last name for the 3 the room here 3 court reporter 4 MR WALKER Todd Walker 4 A e 5 MR HUGHES Okay And he's here as a 6 corporate representative of Reddaway 7 MR HAMILTON Yes 8 * * * 9 RAYMOND J. LECKI after having been 5 Q Where do you live 6 A 53 Cherie h Drive Brick 7 New Jersey 08724 8 Q Okay And do you work 9 A Yes 10 first duly sworn was examined and testified as 11 follows 12 * * 13 Whereupon Lecki Exhibit 1 was 14 received and marked for Identification 15 MR HUGHES Mr. Lecki before I start 16 with you let me put something on the record 17 This is regarding some other defendants 18 I have marked as Exhibit 1 a letter 19 dated May 4th 2012 from Amy Drayton regarding 20 four entities E.C.H. Will GmbH is the first 21 Korber Paperlink GmbH is the second Korber 22 Paperlink North America Inc. is the third 23 Korber Paperlink LLLC is the fourth 10 Q Where do you work 11 A I work for buildings and grounds Toms 12 River for the Justice Complex 13 Q Okay And where's that located 14 A In Toms River New Jersey 15 Q Okay And how long have you been at 16 the Justice Complex 17 A Come in August it'll be ten years 18 this August 19 Q Okay And what's your position there 20 A I'm the night supervisor of jail 21 operations 22 Q Okay And are you married 23 A Yes 24 Based on the representations in her 25 letter and its attachments the plaintiffs are 24 Q What's your wife's name 25 A Erin C. Lecki c same last Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 10..13 1 name Page 10 Page 12 1 A -- said well send him down for an 2 Q Yes sir 2 application If they like him he's available 3 And does she work 4 A Yes 3 they'll hire him And they hired me 4 Q Okay And where was -- where did you 5 Q What's her job 5 go down there to -- 6 A She's in computer crimes in the Ocean | 6 A I went to the -- 7 County Prosecutor's Office 7 Q I should have also said you 8 Q Okay And how long have y'all been 8 understand you're under oath 9 married roughly 9 A Yes 10 A Twenty years 10 Q Okay If you need to take a break at 11 Q Congratulations 12 A Thank you 11 any time let me know 12 A Absolutely 13 Q Let me ask you just a little bit about | 13 Q And if you don't understand a 14 your background okay 14 question tell me and I'll try to rephrase it 15 A Yes 15 A Absolutely 16 Q Where did you grow up 16 Q All right So you went down to 17 A In Jersey City New Jersey 17 Reddaway Where was the office Was the office 18 Q Okay And how far did you go in 18 part of the plant 19 school 19 A Yes It was on 32 Euclid Avenue in 20 A Third year of college Jersey City 21 = State College 22 Q Okay And tell me about -- at 23 certain point in time you started working at 24 = Reddaway right 25 A In 1975 late 1975 20 Newark 22222 Q Is that where the plant and office 22222 together was all located | 22222 A Yes 22222 Q Okay Did Reddaway have any other 22222 locations besides that Page 11 1 Q Okay Just real quick walk me 1 A No. Page 13 2 through any work experience you had before Reddaway | 2 Q Okay And when you went there do you 3 A I worked in a paint factory I worked | 3 remember who you interviewed with 4 as school janitor prior to Pretty much that was | 4 A Yes 5 the only jobs when I started working class My 5 Q Who did you interview with 6 uncle got me the job through one of the factory 6 A He was one of the part owners Fred 7 workers which was a foreman Andy Alday back and 7 Grassel 8 said that this company in Newark was hiring So I 8 Q Okay Do you know how to spell that 9 went out there filled out an application and I got 9 last name 10 hired 10 A I'm going to wing it it's 11 Q Okay So you got the job through 11 G or possibly two Ls 12 your uncle 12 Q Okay Pronounced Grassel 13 A My uncle yes He was trucking I 13 A Grassel 14 worked for a company called New Penn which picked | 14 Q And he was a part owner to your 15 up at Reddaway 15 understanding 16 Q Okay And Reddaway is spelled 17 w 16 A Yes He was one of the part owners 17 Q Okay Did you meet with anyone else 18 A Correct . 18 A Yes Warren Conway 19 Q Okay So your uncle was a trucker 19 Q Okay 20 and he knew about Reddaway 20 A He was another part owner 21 A He met some of the workers down in 21 Q Anyone else 22 shipping and receiving and they explained that you | 22 A 23 know they were looking for men hiring And he 23 day That's all right -- right -- that 24 said my nephew needs a job you know -- 25 Q Okay 24 Q Okay And this was what you said 25 about 1975 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL , ET AL Raymond J. Lecki on 05/17/2012 Pages 14..17 Page 14 1 A July July of 1975. The date I'm j 1 A Grassel Page 16 2 too familiar I really can't remember I knew it 2 Q -- who you understood to be a part 3 was the month of July 3 owner Warren Conway who you understood to be a 4 Q Okay And you look -- you brought 4 part owner And what did they tell you what did 5 Some notes 5 you tell them as best you recall it was many years 6 A Yeah just to refresh my memory over 6 ago 7 the -- you know it's been a long time So I just 7 A Well they wanted to know where I 8 wrote down some notes on pretty much from start to {| 8 lived and you know what I was -- when I was 9 finish of the years of what went on and what I did 9 available which I was -- I said immediately 10 and how I worked through the years 10 whenever So they told me the type of work that 11 Q Can we ~~ can we mark those as an 11 was going to be done or what I was going to get 12 exhibit 12 involved in which they said you know this is an 13 MR HAMILTON Mark those as exhibits 13 asbestos plant so I said okay They go does that 14 BY MR HUGHES 14 matter to you I go no I'm looking for work you 15 Q Can we mark those as an exhibit 15 know I'll -- so they said you'll be an apprentice 16 A Absolutely 16 in the weaving shed under the guidance of Fred 17 Q Okay And then you can refer to them 17 Davies he was the lead foreman 18 whenever ever you need to 18 Eventually what they told me in the 19 A Yes 19 long run that he was going to be retiring in 20 Whereupon Lecki Exhibit 2 was 20 couple of years so if I worked out I was going to 22222 received and marked for Identification 21 take over his position which in turn I did 22222 BY MR HUGHES 22 Q Okay So they said it was an 22222 Q So Exhibit 2 is your notes -- 23 asbestos plant they used asbestos 22222 A huh 24 A Yes in brake lining applications 22222 Q I and feel free to refer to them 25 Q So they used asbestos in brake lining 1 anytime Page 15 1 applications right Page 17 2 A Okay 2 A Yes 3 Q And try to say yes or no instead of 4 huh so the court reporter can write it down 5 okay 3 Q Okay And they were -- they said you { ' 4 would be an apprentice in the weaving shed 5 A Yes 6 A Yes 6 Q And you would work under Fred Davies 7 Whereupon Lecki Exhibit 3 was 7 A Yes 8 received and marked for Identification 9 BY MR HUGHES 8 | Q And he was going to retire in a while :9 A Yes 10 Q And then let me hand you Exhibit 3 and j 10 Q 11 ask you is that a photo of part of the plant that 11 Reddaway 12 you're talking about 12 A And is that what you started doing at Yes 13 A Yes 13 Q Okay And so walk me through what 14 Q Okay Have you seen that sign before 14 happened from there What kind of duties did you -- 15 A Yes 15 what kind of things did you do in the weaving shed 16 Q How do you know that sign 16 A Basically everything as an apprentice 17 A I've recently painted it and done work 17 learned all the machines which were heavy 18 to it as well as the door that's the garbage 19 entrance Right next to it is shipping and | 18 looms which wove the brake lining So you had to 19 know the operations of the raw material that went 20 receiving and the entrance for the employees 20 into the machine as well as how it ran 21 Q So back when you worked at Reddaway 21 mechanically how to fix the machine how to make 22 you helped paint the sign 22 cuts meaning the size footage take them off learn 23 A Yes / 23 how to dry the rolls get them prepped for shipping 24 Q Okay So let's see So when you 24 you know the rest of the process throughout the 25 interviewed you interviewed with Fred Grassel -- 25 | factory Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 18..21 Page 18 Page 20 1 Q Okay And when you started how many 1 Norfab Ametex Ametex actually was the first 2 looms were there 2 company which supplied the asbestos then they 3 A Let me see it was the jumbo loom 3 changed to Norfab when they got into the 4 8ths inch quarter and 16ths and 4 asbestos 5 three quarters 6 Q Okay And when you talk about 7 quarter three quarters what does that mean 5 Q Okay And that would come -- that 6 would be yarn that would come in spools 7 A Yes bobbins 8 A That's what comes off the sizes of the | 8 Q Okay They all came in bobbins 9 brake lining on each machine Some did -- pretty 9 A Bobbins spools Yeah 10 much all of them did two sizes per loom except one | 10 Q Okay And then I've heard a term 11 the 8ths just ran 8ths Like the jumbo loom ran 11 creel e 12 an inch inch and an eighth three quarters ran 12 A That's what we load the looms which 13 three quarters and 8ths inch loom ran 14 inch and 8ths quarter loom ran 13 pulls the yarn into the front of the machine And 14 then a shuttle runs back and forth to bind 15 quarter and 16ths and the 16ths loom did | 15 everything together to make a piece of brake lining 16 16ths 32nds and 8th and two different sizes | 16 up in front on the different sizes widths and 17 You had the regular asbestos and you 17 thicknesses 18 had ebony which is a jute type of material with 19 rope and asbestos mixed in So it was like a -- 20 and they called it ebony 21 Q Okay Did the number of looms ever 2222 change over the years 18 Q You mentioned a weaving shed Was 19 that located somewhere in the overall plant 20 A It was the biggest major part of the 21 factory you know it started right with me on all 22 the raw materials -- 2222 A We added on another quarter loom | 23 Q Okay 2222 which was being built in the meantime oh couple of | 24 A -- to make a product 2222 years down the road Ed Pagano me and Fred Davies 25 Q And walk me through the first -- the 1 Q How do you spell that Page 19 1 Page 21 first years you worked there and working your way up 2 A n Pagano I'm winging 2 and what position you got to 3 that 4 Q So at some point a second loom was 5 added that could make the quarter 6 A And 16ths 7 Q Okay And do you know what decade 8 for example the second loom that could make the 9 quarter and 16ths was added 10 A From my notes around '85 11 Q Okay When the second loom was added 12 around 1985 do you remember if it made asbestos 13 brake lining or asbestos brake lining 14 A We had -- we were going to set it up 15 for asbestos but it actually turned into making 3 A Well I was apprentice under the 4 foreman of Fred Davies which I taught and was 5 learning the whole operation of the weaving shed 6 During the summers I worked summers learning pretty 7 much the rest of the factory on repairs on other 8 machinery as well as office I painted the office 9 a couple of times Down in shipping and receiving 10 did numerous repairs with Ed Pagano He was the 11 head machinist He oversaw all the machinery So 12 during the summer I used to work with him either 13 jobbed in the weaving shed if there was any 14 outstanding and throughout the rest of the factory 15 on all repairs 16 samples for the asbestos So it made samples of | 16 Q How many people worked with the looms 17 the asbestos but it was geared up at any 17 A At the beginning when it was busy oh 18 particular point for asbestos It could run 18 about eight or nine women plus me plus Fred until 19 either 20 Q Okay All right So when you 19 he retired So you're looking at ten in the weaving 20 shed 21 started there the raw material what would that be | 21 Q Okay And did you become a foreman or 22 Would that be spools 22 a supervisor 23 A It was yarns It was different types | 23 A I became foreman general foreman of 22 of yarns Each yarn was spun differently in 24 the weaving shed under supervision of eight women 25 thickness with brass and zinc mixed in it from 25 Q And when did you become the foreman Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL , ET AL Raymond J. Lecki on 05/17/2012 Pages 22..25 Page 22 1 roughly Was it still in the 70s was it in the 1 A Yes Yes Page 24 2 180 2 Q Okay Walk us through the 3 A 4 1831 '84 No it was the 80s I'm going to say | 3 4 manufacturing process for the asbestos brake lining For example you'd start with the yarn 5 Q Okay And so at that point were 5 A Yeah the ordering of the yarn 6 you -- tell me what kinds of things you would have 7 do What were your responsibilities 6 Depending on how many rolls were going to come off 7 each loom I would get that from Fred Grassel 8 A My responsibilities were now any 8 sometimes in the morning afternoon whatever day it 9 general breakdowns I had to report you know to the | 9 was and he would give me an order list on how 10 office or Ed Pagano fix and repair daily order 10 many -- what he needed per month or per week or for 11 yarn put in my yarn orders or got received orders 11 each individual loom And that I used to give him 12 from the office on what to make on the size on each 12 back what I had in stock in yarn saying well I 13 machine Basically it's like a general order on 13 can make so much but I need this 14 how many rolls to make off each loom So to fill | 14 He then would tell me how much you 15 production what they needed what they took out of 15 need and I said to him well I'm out of this size 16 stock down in shipping and receiving throughout the 16 certain sizes You need to call Ametex or Norfab 17 factory 18 Q Okay 17 and order some more And they used to buy by weight 18 and this is what I need to finish these orders or 19 A So I replaced any materials that was 20 needed It started with me 19 you know get it going and get it rolling So he 20 said okay I'll see when they're being delivered 21 Q And did you know how to actually work 21 He goes do you have enough to run now I says 22 on the looms themselves do what the women were 22 yeah but within a week or so I'm going to need more 23 doing -- 23 depending on if you don't change it meaning add 24 A I was taught how to run every machine 24 more or delete or switch things around which he did 25 There wasn't a machine in there I didn't know 25 randomly Page 23 1 Q Okay How old were these looms 1 Page 25 So instead of making maybe inch and 2 A Oh I think one of the dates was 1849 {| 2 an eighth we go down to eight to swing the yarn 3 from England They recently came from England 3 over to the quarter because the thinner size 4 Q Okay And how many bobbins or spools {| 4 sometimes were popular more popular than the big 5 would there be on the looms 5 It all depended on sales 6 A The largest loom was a jumbo The 6 Q Okay And when the yarn would -- that 7 jumbo loom that ran inch and inch and an eighth 7 would get woven on the loom and then what would 8 And that was a double decker it had like two tiers | 8 happen 9 It almost touched the ceiling That had over 1,500 | 9 A Each loom had different footages and 10 spools of yarn in it That had the most 10 widths The jumbo ran from 25 or 24 width to 28 and 11 Q That had the most 11 half wide by 30 in -- 30 feet 3/8 was 27 wide by 12 A Yeah 1,500 to possibly 2,000 ends 12 50 feet or 51 we made it for excess cut three 13 meaning each yarn spun into that machine to gather 14 up in front and then bound together with a shuttle 13 quarters was 27 by 30 feet inch was 27 by 14 51 feet Both quarter looms was 27 by 76 feet 15 that went across to bind the material woven 15 And the 16ths loom was 27 by 76 feet That's what 16 Q Was the jumbo loom like -- was it set 16 came off each loom every day never changed 17 up like that Did it exist when you started at the | 17 Q Once it came off the loom then what 18 company 18 would happen 19 A Oh yes Yes that was in place 19 A We would dry it 20 Q So as of say 1980 what kind of 21 products was the company making 22 A Asbestos brake lining 23 Q Okay So the main product was 20 MR HAMILTON I'm going to -- I'm 22222 going to just place a request that from here on 22222 out this portion of the deposition on the main 22222 factory process be marked confidential because 24 asbestos brake lining Was it called RBW Is that | 24 25 an abbreviation for it 25 I think it's going to be some proprietary information The judge will do whatever she'll Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONALINTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 26..29 1 do with it Page 26 1 A Yes it was all resins Page 28 2 But for purposes of this case 2 Q Okay And then after it came out of 3 obviously it's going to be used but I'm just 3 the dipping then what 4 thinking about he's going to give some 4 A It went into the drying racks which 5 detailed information about the manufacturing 5 was second level floor They rolled them out on to 6 process so I just note that request 6 racks I would say for a couple of weeks then 7 MR HUGHES Okay well we can -- we 7 whatever rolls were finished in that process they 8 can look at that after we get done 8 came down they went into drying coops for another 9 MR HAMILTON Sure 9 couple weeks and then they came out whatever was in 10 MR HUGHES All right 11 BY MR HUGHES 12 Q After it came off the looms would it 13 go -- would it get some sort of resin or something 10 process to go in They got rolled again to 11 thickness put in an oven for another eight hours of 12 cooking under gas temperatures and then they were 13 done rolled again cut to size 14 A It would dry first They had to be 15 totally dry 16 Q So was it wet 17 A Because it came off wet 18 Q Okay 19 A Asbestos had to be totally wet to a 14 They were cut down to foot lengths 15 or whatever lengths prescribed for an order Then 16 they were grinded and then they would finish cutting 17 even more on whatever special orders which went 18 through the finishing department or to specialty 19 departments meaning smaller sizes 20 point because it had a total friction It was like | 20 Q And how would they be shipped out 21 99.9 trying to make this -- because you're dealing 21 For example were burlap bags used 22 with rock So it was heavy friction for the 22 A On all rolled goods material yes 23 machine to run So the more we wet it the better 23 burlap was used on 100 percent of the product as 24 it ran So you couldn't give a dry roll to the 24 well as boxes per small parts or the oil fill which 25 processing end because compound wouldn't soak in 25 was the brake blocks And then some crates if 1 wet It had to be totally dry Page 27 Page 29 1 there was some left over from other products that 2 So in -- my department had a drying 2 came in we used to keep whatever so we didn't have 3 oven which ran off the boiler because it was dry 3 to buy because we were a small company 4 air So we dried about 15 to 16 rolls every other 4 Q Right 5 day and then shipping and receiving or finishing 6 department would come in take them out and then 7 that process just rolled over every other day in 8 drying rolls because I had numerous stock of all 5 A So one of the finishing departments 6 used to put some of their smaller brake pads in the 7 crate and then send it down to shipping and 8 receiving 9 different sizes 9 Q So if you know for a normal -- a 10 And that's the other thing after all 10 typical order for rolls of the woven lining would 11 the finished product on all the different sizes and | 11 they -- to your experience would they have normally 12 lengths come off Fred Grassel would then come and 12 been sent out in the bags burlap bags 13 say okay I need these dried these different sizes | 13 A Yes Burlap bags yes 14 dried and they would go in the -- what we call coop | 14 Q Okay And would those have some sort 15 and dry them up or the drying oven 15 of caution statement on them 16 Q Okay And was there -- the finishing | 16 A All -- every box bag or crate got 17 room what would they do if you know 17 tagged caution asbestos product It was a white 18 A They would then take my rolls roll 18 tag 19 them to size pretty close to the size that the 19 Q And were those tags did you see those 20 thickness that each size was They had these big 20 from when you first started at the company 21 rollers Then it went into the dipping department | 21 A Absolutely yes 22 on whatever size they needed dipped per process 23 per -- to finish or what they needed for orders 22 Q Okay Now was there something called 23 a material card or production card cards 22 Q And the dipping that was some sort of | 24 d 25 resin 25 A On each loom whatever material size Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 30..33 Page 30 Page 32 1 whether I started with the basic size let's take 1 A That's office That's all was left at 2 for example 8ths 8ths every -- whatever -- 2 the factory That never came home with me It 3 they usually made four rolls a day if the machine 3 stayed That was all factory stuff 4 ran well Each one had a number date and my 4 Q All right 5 signature on that card And then that number 5 A They hung by the tail end of each 6 followed through the process because if there was 6 machine in like a -- clear envelope where you can 7 any screw you can find out what was wrong with | 7 see your daily -- like any time any one of the 8 that particular material from start to finish 8 managers or any one of the -- in production come up 9 Q Would the cards say anything about 9 and see where I was at on how many I made or if I 10 whether the product had asbestos or not 10 was changing to a different size and everything was 11 A Yes yes 11 dated and if they want to reflect back on a number 12 Q Okay What would it say 12 because sometimes when a number rolled through the 13 A Well it would just -- the beginning 13 rollers and we got like messy so they came in to 14 of my card read asbestos I just put you know 14 get the number and my number had to coincide with 15 on the card asbestos until we changed 15 that roll So they would come and grab that number 16 Q Okay Describe for me the process of | 16 just to write it down on the roll again if it got 17 changing from the asbestos to the asbestos 17 messed up So my numbers always matched that size 18 A Well we had to liquidate all of the | 18 Q And did you ever have an occasion 19 asbestos and that ran about -- in the middle of '87 19 where in fact you'd have to go pull a production 20 we were finishing out all the asbestos That means | 20 card was there an incident with the tugboat once 21 some of the looms we were stripping because we 21 A Well that happened -- yeah there 22 didn't make any more heavy equipment which was |22 was -- back the early 80s we had a piece of 222 the inch inch and eighth because it had so much 23 finished brake lining come back and there was a 222 yarn in that we liquidated and stripped out of that | 24 barge incident accident that they said our brake 222 and pushed it to the other thinner sizes to finish 25 lining had failed And it was a inch -- Page 31 1 out the yarn instead of throwing it all away And 1 half or 8ths piece Page 33 2 that was command from the office on when we had to 2 And Vincent Lacarrubba was the R & D 3 change over And initially finish out that we're 3 and I just happened to be there and he showed me 4 not going to do asbestos anymore 4 He goes do you see anything wrong with this lining 5 Q Okay As of say 1983 was the company | 5 So I said no what happened He goes it failed 6 still making asbestos woven lining 6 Well low and behold they sent a coffee cup with 7 A Absolutely yes Yes 7 grounds in it saying that the brake pad had failed 8 Q Okay How about 1984 8 on the operation of the barge When they tested the 9 A Yes 9 grinds it was more metal fragments than asbestos 10 Q Okay For the quarter the 11 thinner widths okay 10 fragments and other particles from the brake lining 11 It ended up the lining didn't fail 12 A Yes . 12 their band had disintegrated which the lining had 13 Q Was the company still making asbestos 14 woven lining in 1985 13 nothing to grab on to So the barge went sailing 14 had the accident but they tried to claim that it 15 A Yes 15 was our fault the brake lining failed and it wasn't 16 Q In the thinner widths as well 16 Because we ended up seeing when I guess I don't 17 A Yes 17 know what lawyer went out and saw the barge and saw 18 Q Okay What about in 1986 19 A Yes 18 their equipment and it was like antiquated beyond 19 repair and that was their fault The winch failed 20 Q Okay And that would be noted on the | 20 21 production cards 21 22222 A Yes 22 23 Q Did you ever throw those away 23 24 A No. 22 22222 Q Did you keep them 25 Q Let me show you a sales document Whereupon Lecki Exhibit 4 was received and marked for Identification Whereupon Lecki Exhibit 5 was received and marked for Identification Whereupon Lecki Exhibit 6 was Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 34..37 Page 34 1 received and marked for Identification) 1 before Page 36 2 BY MR HUGHES 2 A Woven yes 3 Q Okay The first exhibit you have 4 there the sales record is it number 4 3 Q Does that appear to be Reddaway 4 shipping record 5 A Yes 5 A Yes 6 Q Have you ever seen documents like that | 6 Q What's the date on that 7 before 7 A 8-21-86 8 A I've seen these -- not so often but in 8 Q Okay Can you tell what kind of 9 shipping this is big in shipping but I do know 9 products are listed on there 10 what this is because it's throughout the factory 10 A Quarter quarter -- all 11 you see these hanging through the different 11 quarter 12 departments which was the finishing or shipping and | 12 Q Okay 13 receiving Because like I said it's not a big 13 A There's quarter ebony and then 14 factory I know what these are these are order 14 regular heavy woven which it's all asbestos 15 forms 15 Q Was the company still making and 16 Q Okay And what's the date on that 16 selling asbestos heavy woven in 1986 17 one Is that one 1984 17 A Yes 18 A 1-17-84 2222222 Q Okay Can you tell what kind of 20 products are being listed on there 2222222 A 5/16 8ths 16ths and 2222222 quarter Heavy woven asbestos lining 2222222 Q Okay Was the company making and 2222222 selling heavy woven asbestos lining in 1984 2222222 A Yes 18 Q How do you know that 19 A The date and plus whatever was still 20 left in stock was still in the factory finished 21 ~~ stock 22 Q Okay Explain for me the process 23 of -- when did the -- was there a time when you 24 first heard about the company thinking about making 25 asbestos 1 Q How do you know that Page 35 Page 37 1 A Yes In and around 1985 2 A Because HD is heavy woven If | 2 Q Okay What do you remember 3 it was anything else it would state it on the 3 A There was a letter or a document sent 4 billing if anything was changed 4 from OSHA to Ed Eggert He was the general manager 5 Q Okay And then the next document the | 5 then Eggert g I'm winging it Not 6 Exhibit 5 I think have you seen documents like that | 6 good with names He was the general manager and 7 before 7 also head of sales 8 A Yes this is shipping and receiving 8 Q Okay 9 which goes out with any finished product 9 A He would come out and give us reports 10 Q Okay 10 on up and coming things at the factory as well as 11 A The bales boxes or cartons 11 sales Anything to do with the NWPA laws which was 12 Q Is that one also dated '84 It's kind 12 an OSHA law We had put a humidification system in 13 of hard to read 13 which cost a lot of money figures I don't recall 14 A Yes 3-23-84 to be exact 14 but I knew it was close to probably a million 15 Q Okay And does it indicate that the 15 dollars to keep the dust levels down for OSHA 16 product -- whether the product was asbestos 17 A It says right on here 6 bales 16 because asbestos you know they were cracking down 17 on it And the more OSHA stepped in the more the 18 asbestos brake lining nonflex 18 dust levels went down meaning they wanted almost 19 Q Okay And what does that mean when it 19 zero tolerances of dust 20 talks about bales of brake lining do you know 21 A It's what they get wrapped in to be 22 shipped out to be covered So basically for 23 shipping purposes 24 Q Okay And then the next document 25 after that have you seen documents like that 20 So Ed Eggert told -- said -- he showed 21 us this document which was the thing from OSHA 22 saying it's going to be hard making asbestos for the 23 future think about another alternative 24 So at the point there was -- they 25 started to look into different types of yarns and Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 38..41 Page 38 Page 40 1 blends and getting into a different product And 1 A In times At the beginning very 2 that was in and around 1985 2 rarely saw him He was pretty much on the road 3 Q Okay And Ed Eggert do you remember | 3 sales He did a lot with the oil fields He had 4 when he -- was he at the company when you got there { 4 lot of good friends and that was pretty much one of 5 ... 5 our main productions was the oil fields So he 6 A No. : 6 pretty much stayed Texas out that way with some of 7 Q Okay Do you remember roughly when he | 7 his you know close I guess business friends that 8 came to the company 8 bought -- put a lot of orders in 9 A Well it had to be after Fred Grassel 9 Q And some of the oil field companies 10 passed away And that was pretty -- let me see 10 would buy the thicker sizes 11 Had to be after '85 that Grassel passed away and 11 A The inch and inch and an eighth 12 then Ed Eggert arrived He was brought in for a 12 Q And that could actually be submerged 13 general manager and sales because that's what 14 Grassel's position was He was pretty much plant 13 in oil or used in a clutch that sort of thing 14 A It's for drilling 15 operations general manager He was part owner 15 Q Okay 16 Q Okay And how long was Ed Eggert 16 A It's for slowing down the drill head 17 there 17 the drill shaft 18 A Till I'm going to say 1989 or 1990 2222222 winter winter of He was fired 2222222 Q Okay Tell me about that What 18 Q 19 A 20 too much Okay And so you met Mr. Barton Jr. Couple of times at the beginning not 21 happened 21 Q Did he take some folks out on the -- 2222222 A Between the changeover and the lack of 22 out on a boat at one point 2222222 sales and also Todd Walker started working in the 23 A Later on later in the late 80s He 2222222 factory as one of the head salesmen and he started | 24 brought the boat up because he wanted to get back in 2222222 in you know getting more involved in the factory | 25 touch with the factory and he wanted to see what was Page 39 Page 41 1 and saw that Ed Eggert wasn't doing his job 1 going on Because like I said the factory was in 2 basically 2 a big change 3 So eventually he just said he's not 3 Q Yup 4 going to you know deal with Ed Eggert anymore and | 4 A Sales was down trying to pick up 5 he fired Ed Eggert He -- because he wasn't 5 sales trying to pick up emotions So he brought 6 bringing in the sales lack of you know 6 the boat up a couple times and he took us out on the 7 production Things were really falling apart And | 7 boat for fishing 8 the asbestos changeover wasn't going well 8 Q What was the boat called 9 meaning sales were still lacking 9 A It was the Miss Redco 10 Q Okay Let me ask you about some of 11 these names William Barton Sr. and Junior 12 A He was the president and owner of 13 part owner of the factory 14 Q Bill -- so Bill Barton Jr. 15 A Bill Barton Jr. 16 Q Okay Was he the president when you 10 Q And Redco was another name for 11 Reddaway 12 A Right It was like our nickname if 13 you want to call it 14 Q And then Mr. Barton he had a spouse 15 named Pam is that right 16 A Yes 17 got there 18 A Yes 17 Q 18 the room Okay And then Todd Walker is he in 19 Q Okay Did you ever meet him 19 A Yes 20 A Yes 20 Q Okay Who was Todd Walker 22222 Q Okay Where did he live 21 A He was the son of Pam 22222 A In Stuart Florida 22 Q So he was the stepson of Mr. Barton 22222 Q So he lived away from the factory 23 A Yes 22222 A Yes 22222 Q Would he come up to visit 24 Q 25 Reddaway When did Todd Walker start working at Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 42..45 Page 42 Page 44 1 A Took over or actually in sales 1 was declined a raise So in turn Mr. Walker 2 Q 3 company Well when did he first show up at the | 2 3 brought in one of his friends to take over and help him He was I think plant operations and he took 4 A In and around 1985 4 over making a higher salary than me and I was to 5 Q Okay And what kinds of things did he | 5 train him His name was Joey Dipadavoa I'm going 6 do when he first started at Reddaway 6 wing this Dipadavoa a 7 A He was one of I would say head 7 Q Okay So in 1983 Todd Walker wasn't 8 salesmen involved in going out to the -- we got into | 8 at the company 9 some foreign business Germany I don't recall 9 A No. 10 anything other than Germany maybe some other 10 11 factories abroad But he went out to all our 11 12 pretty much all our distributors all our customers 12 13 met with them tried to get -- raise more orders and | 13 14 more business 14 15 Q Okay Could his start date have been 15 16 = 1987 16 17 A That could be more general manager 17 18 Q Okay What happened Did he move up / 18 2222222 or what happened 19 2222222 A Well when he fired Ed Eggert then he 20 2222222 took over general manager of the factory as well as 21 2222222 now head salesmen So he was involved in 22 2222222 everything 23 2222222 Q Okay Okay Did he become president | 24 2222222 of the company at some point 25 Q A had no -- Is that correct If he did it was for a visit but he Q - He wasn't working there A He wasn't -- no he wasn't involved with the factory as per se to make an order change something say that there's a special client or anything like that He wasn't involved Q Okay I want to show you a couple excerpts from Mr. Walker's deposition from April 13th 2012. First one is on page 15 in which I asked When was the date that Reddaway switched to asbestos And the answer was Basically they switched in 1983. Is that correct A No that's incorrect Q Why is that incorrect Page 43 1 A Probably now I don't know He 1 2 wasn't in charge -- or he was in charge then but I 2 3 don't know if you want to call it president 3 4 Q From your perspective in the 70s and | 4 5 80s who was the person at the very top of 5 6 Reddaway 6 7 A Bill Barton Jr. 7 8 Q Okay All right And how long did 8 9 you work for Reddaway When did you leave 9 10 A August of 1995 10 11 Q 12 retire Okay And were you fired Did you 11 12 13 A Retired 13 14 Q Okay And at the time you retired 14 15 what was your job position 15 16 A 17 __ shed 18 Q I was head foreman of the weaving 16 17 Why did you retire 18 19 A There was a little controversy on 19 222222 salaries pay scales and what I wanted to continue | 20 222222 making staying there being the you know one of the | 21 222222 lead persons of the factory because there was 22 222222 downsizing and you know plus I said business was | 23 222222 declining So in order to keep the factory 24 222222 running I put my -- my word in for a raise Well | 25 Page 45 A We only were making samples then for testing of the material to change over from asbestos to asbestos Q Tell me how you would make samples A We -- when we were switching out and downsizing the asbestos meaning moving the yarns to the other sizes to finish out the quarter the second quarter was the newer of the looms we had set up for a sample machine So they brought in different types of sample of the asbestos There was a synthetic it was more fiberglass it was a white texture which was very hairy itchy We ran samples of that Testing went accordingly which I found out it wasn't good because of the resins or the type of change that they needed because it was a different product Asbestos it was one patent one type of dipping process and it was all patent by Bill Barton Jr. and that worked well for asbestos With the asbestos we needed change It wasn't drying properly it wasn't setting up right and that meant a lot in the stopping of the new brake lining which was what we were trying to change into So there was many changes or samples that was run until we finally Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 46..49 | Page 46 Page 48 1 went to Norfab which now they switched from Ametex 1 the dipping was the different type of resin that had 2 to their name Norfab to find the right blend 2 to be formulated so it would set up and bake 3 Q Okay Now -- and were there occasions | 3 properly 4 where you would run part of a roll with asbestos | 4 Q 5 and part with asbestos 5 A Okay So that was a long trial basis So 6 A That was also on some machines I ran | 6 this was like the early workings of how the thinner 7 like a two or inch piece on the edge trim with 7 size to see what it did and then go from there with 8 asbestos and we ran a full roll that was dipped and | 8 the thicker sizes which took time 9 cut out separately because it was tighter and it 9 Q But once you ran a sample of the 10 held in so they can get a sample That ended up not 10 asbestos on a loom could you then still run 11 working well because it was a mixture and they 11 asbestos on the loom 12 weren't sure if that was the right type of blend 12 A If I was told to set back up yes 13 and that's when we went to the quarter to get a | 13 Q How would you do that 14 precise right blend of a product and start with a 14 A You would strip out all the ends out 15 smaller size instead of a thicker size Things 15 of the whole machine and then have a whole setup of 16 weren't working out And as well as the compounds 16 asbestos to put back in the machine 17 wasn't working properly 17 Q Okay Do you recall which loom was 18 Q Okay 18 the first loom that was used to run any 19 Whereupon Lecki Exhibit 7 was 19 asbestos 20 received and marked for Identification 20 A The newer quarter 21 BY MR HUGHES 21 Q Okay And so in Mr. Walker's 22 Q You mentioned running samples looking 22 deposition he testified that there was only one loom 23 at Exhibit 7 can you tell what that is 23 that ran a quarter is that correct 24 A This is one of the sample orders of 24 A No there was two 25 the asbestos quarter which came off that 25 Q Okay And -- Page 47 1 new quarter loom which was sent out for 1 A It also ran 16ths Page 49 2 samples to East Patterson Machine which I'm almost | 2 Q So the loom that ran a 3 positive in my memory it was a punch press operation | 3 quarter -- first of all there were two looms 4 in Clifton This is one of the ones I think Vincent | 4 that could run quarter inch 5 Lacarrubba knew 5 A Yes 6 Q Do you remember them as a customer 7 A Offhand yes and no There were so 8 many I just knew because this was a sample that 6 Q And the second loom came in in the 7 80s for the quarter 8 A Yes 9 was going out for testing in the first -- 10 Q Okay 9 Q And each loom that ran a quarter 10 could also run 16ths 11 A -- one of the first products that we / 11 A Yes 12 were trying to make and see how it worked on a 12 Q Okay And it was the new loom for the 13 smaller machine not big heavy duty Quarter 13 quarter that was used for asbestos 14 is very thin size light duty 14 A Yes in samples 15 Q Now to run a sample on a machine 15 Q Okay Was the new loom for the 16 wouldn't you have to change over the way the machine | 16 quarter ever used for asbestos or just for 17 works in order to run asbestos 17 asbestos | 18 A The workings of the machines it ran 18 A I'm not sure if we set it up to run 19 it depended on the variable of thickness The 19 some asbestos It could be yes we did but not 222222 asbestos would run thinner We had a hard time 20 for long period of time It was almost to run out 222222 getting tolerances And then when I finished my 21 the product 222222 tolerance it had like -- elasticity it like it 22 Q Okay When you worked there and 222222 would make it it'd be thinner and all of a sudden 23 Mr. Walker was also working there how much time did 222222 when it relaxed it got thicker And that's also the 24 he spend in the weaving shed 25 problems we had in rolling and in dipping And then | 25 A Not much Just periodically walk Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 50..53 Page 50 1 through either for how's everything going orders 1 A Yes Page 52 2 see how the operations if I needed anything in 3 inventory 4 Q How much time would you spend in the 5 weaving shed in your normal days 6 A Eight to 10 hours a day 7 Q Okay 8 A Five or six days 2 Q What was happening there 3 A We were trying to finish out and keep 4 up with business in the asbestos which we still had 5 in the factory but at a minimum meaning we weren't 6 ordering much more asbestos yarn which was almost 7 at nil meaning nothing and just by liquidating 8 our stock -- 9 Q Did the asbestos yarn have a 10 different color 9 Telephone interruption 10 BY MR HUGHES 11 A 12 orange 13 Q Nonasbestos was like a yellowish Was it Kevlar 11 Q And we can take a break if you need to 12 answer the phone 13 A No. 14 A It changed colors when it went in the (| 14 Q So in '86 what was happening with the 15 drying process 15 asbestos and asbestos 16 Q Okay And I interrupted you 17 Was it Kevlar 16 A We were liquidating our stock in yarn 17 meaning the raw material to finish out until we 18 A 19 the blend Kevlar was one of the main products of 18 19 couldn't use any more on the looms on finishing out roll good product Meaning before it went to 222222 MR HUGHES Okay Let me show you 20 process in my department before we ended up 222222 something else 21 liquidating and throwing it all away 222222 Whereupon Lecki Exhibit 8 was 22 So we didn't want to waste the yarn 222222 received and marked for Identification 23 where we could finish it in roll good put it into 222222 BY MR HUGHES 24 production because OSHA in the laws really weren't 222222 Q All right Let me hand you Exhibit 8 | 25 getting on us yet meaning it was in the works but Page 51 1 and ask you what's the date on that one Is that 1 it wasn't really serious yet Page 53 2 1986 2 Q Okay So am I understanding you 3 A August of 1986 yes 3 correctly that in 1986 the company was still 4 Q 5 bottom 01 A Does it have Mr. Eggert's name at the Yes it does |4 5 6 manufacturing woven lining with asbestos A Yes at a smaller scale meaning we were downsizing on the asbestos 7 Q Okay The part I highlighted towards 7 Q Okay And the company in that memo 8 the bottom can you tell me what that's talking 8 Mr. Eggert's talking about using up the rest of the 9 about 9 asbestos raw material That would be the yarn 10 A As of today August 18th 1986 we 10 A Yes 11 have 13 working weeks to process our remaining 11 Q Okay And then was there -- once all 12 asbestos yarn and roll goods inventory 12 the looms were converted over was there still 13 Consequently we must push on production as if we 13 asbestos woven lining that was in the finished 14 were up to our eyeballs in business Our goal is to | 14 product inventory 15 have all looms cleaned of asbestos yarns by 15 A Yes 16 November 18th I guess of 1986 and to have 17 completed all grinding and slitting by that date 16 Q 17 plant Okay Did OSHA ever come by the 18 also This is a tall order since we will also by | 18 A Yes on certain occasions they 19 trying to keep up with production of the RNAW " 19 announced that they were going to do air sampling 20 which is the asbestos 20 In the early beginning in the 70s or the early 21 Q 222225 company Okay Were you around in 1986 at the 21 80s we were tested a couple times by OSHA They 22 came in with their own equipment and each one of us 222225 A Yes 23 wore an apparatus for taking air samples and we had 222225 Q Okay Do you remember what he's 24 the humidification system in place and which was 222225 talking about there 25 working Evidently we passed and we went on But Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 54..57 | Page 54 1 randomly they would come in just to check make sure 1 2 the system was on or working properly 2 3 Q Did the company know in advance that 3 4 OSHA was going to come for an inspection 4 5 A On certain occasions yes because the | 5 6 testing had to be set up On any other like 6 7 surprise visits it was very rarely 7 8 Q Okay When the company knew in 8 9 advance would they do anything to get ready for the | 9 10 = inspection 10 11 A We do a massive cleanup We'd make 11 12 sure like soup to nuts it was clean like you can 12 13 walk through there and dine Because there was a 13 14 lot of dust a lot of cardboard empty boxes you 14 Q A Q mandatory A For the inspection Page 56 Yes But when OSHA wasn't there it wasn't No. That was laxed Q Okay A The only thing that was enforced was eye protection Q was coming Okay And when the company knew OSHA they would sweep up and clean that plant A Yes Q And clean up all the dust A Yes 15 know production garbage meaning it had to be clean | 15 Q Okay Was there asbestos dust 16 garbage cans clean everything bag it and tag it 16 A Yes | 17 All those cautioning tags were on everything when it 17 Q They would clean that up 18 went to the garbage area We'd do a massive cleanup | 18 A Yes 19 to make everything less dusty really Like when 19 Q Okay But when OSHA wasn't there the 20 they come in it was like wow this place is really 20 plant wasn't necessarily that clean 21 nice So we'd pass Make it easier on everybody . 21 A Through the production week we would 22 Q Would people wear new or clean 22 clean up either late Friday at the end of 23 uniforms for the visit 23 production we would like take more -- slow down 24 A Yes 24 machinery and end work a little early to clean up 25 Q Okay Would they normally wear new or 25 the whole mess of the week Normally if it was a | Page 55 1 clean uniforms every day Page 57 1 heavy week we'd end earlier clean up get the shop 2 A Yes we didn't have pigs They 2 ready for next week or if we worked Saturdays that 3 changed -- we had seven or eight or 10 uniforms per 3 was our cleanup Pretty much nothing ran in my shop 4 worker 4 on a Saturday but all cleanup -- Q Okay Would the workers wear dust 5 Q Okay I'm going to -- this is an 6 masks or respirators when OSHA showed up 6 exhibit from the deposition of Mr. Walker it's 7 A Yes and eye protection 7 Exhibit 34. It's the letter from Ralph Lanz at the 8 Q Okay Did the workers normally wear 8 end of it it has some pages of measurements of 9 dust masks or respirators when OSHA wasn't there 10 A No that was your option but eye 11 protection was the major thing 12 Q Okay 9 asbestos that lists employees It's my only copy 10 but I want to hand it to you and see if you can 11 recognize any of these names and what they did 12 okay Yes 13 A We had a couple of injuries so we 13 A 14 enforced the eye protection more than the mask The | 14 Q So I won't mark this for this one 15 mask were -- was up to your discretion At times we 15 but it's Exhibit 34 from the April deposition of 16 would enforce it more but when we got in to the 16 Mr. Walker 17 asbestos sampling we felt it was less because 18 it was a asbestos it wasn't asbestos So we 19 took away you know the authority on saying you 17 Actually on the first page I marked 18 where it talked about dry and wet Do you see that 19 A Yes 20 didn't have to wear a respirator 21 Q But when the company knew OSHA was 22 coming they would have everyone wearing a mask 23 A That was mandatory 24 Q When OSHA showed up 25 A Yes 20 Q Do you know what that's talking about 21 A Each asbestos roll came off soaking 22 wet because of the high friction levels of asbestos 23 Q Okay 24 A So each loom you know the jumbo 25 loom really got saturated because you're going to a Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 58..61 ; 1 big thickness of inch inch and an eighth to gePtageit58 1 that was her prime loom which was loom numberPa7ge 60 2 to work properly It had to be pretty much 2 Q Okay Who's the next person 3 saturated which also meant a lot of mess cleanup 3 A Roy Cleveland He worked in the 4 which involved you know more cleanup on a wetter 4 finishing department He did drill press he worked 5 production day or every production day but each 6 roll no matter which loom it ran off of was wet -- 5 _ with Andy Alday -- he worked down in the finishing 6 department He didn't work with me at all but I 7 Q Okay 7 knew who he was 8 A -- asbestos 8 Q Okay And then who's on the next 9 Q If you turn a couple of pages in 9 page | 10 you'll see -- go in one more page okay that page 11 Do you see where I highlighted an 10 A John SanRoman good man passed away 11 buried him He was one of the -- he was in the 12 employee name 12 finishing department He cut and slitted the 13 A Yes Gladys 13 finished product on some specialty roll good orders 14 Q Do you remember Gladys 14 He was the main guy He was pretty much partners 15 A Yes Gladys ran the bobbin machine 15 with Andy all day on a lot of the finished material 16 She ran the things that ran in the shuttle to bind 16 that went out for orders big orders | 17 the materials on the machines which ran -- it was 17 Q Okay Is there another page after 18 called the filler 18 that 19 Q Okay And does it say -- I think it 20 says something about bobbins on there 222225 A Yes she ran the bobbin machine 222225 Q Okay So was she one of the people 222225 that worked in the weaving department 222225 A She worked with me yes 222225 Q Was she one of the people that you 19 A Yes 20 Q Who's the next one 21 A Felicetta Barbieri She ran the 22 16ths loom She ran the thinnest loom with all 23 the thinner sizes Had numerous changeovers because 24 that loom also ran ebony and it had a lot of massive 25 changes meaning a lot of ends had to come out and 1 oversaw Page 59 1 2 A Well I oversaw at the beginning when 2 3 I was apprentice I worked with her to learn her 3 4 machine which I learned all the machines and hers | 4 5 pretty much I used to always give her help because 5 6 we were always low on bobbins because production was | 6 7 very heavy And in changing different sizes each 7 8 thickness that she ran on that had to be changed 8 9 quite frequently so she was always behind 9 10 So in my apprentice I used to always | 10 11 go over and give her a hand to make more bobbins 11 12 because the machines couldn't run without them 12 13 Q Okay 13 14 A Either in the back in the creel or up 15 in front you needed both but this mainly ran the 16 = front | 14 15 16 17 Q Okay Who's the name on the next 17 18 page 18 19 A Helen Ott 19 20 Q Do you remember her 20 21 A She ran the 8ths loom only She 21 22 knew all the looms but her main priority was the 22 23 8ths loom which was different from all the others | 23 24 it was an electric loom Ran very fast So she 24 25 was trained on that and pretty much she stayed on 25 Page 61 be restrung which I learned how to do that because I used to work with her I worked with all these women Q Okay Who's next A Florence Kowal she ran the half loom as well as the same loom ran 8ths She worked in the weaving shed with me Q Okay Is there another one A That's it Q Okay What about was there somebody named Vince Lacarruba u A He was -- he was head in charge of custom cutting meaning custom orders He did all custom fancy brake pads anything weird I would say Any special type He was also involved in & He tested the linings meaning anything that came back that they said failed or any of the new stuff like the asbestos that we were starting to get into he tested on a little brake machine Q cancer Okay Did he end up getting lung A From what I understand from his daughter he died yes of cancer Q Did his wife bring a claim of some sort against Reddaway Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 62..65 Page 62 A Through the daughter only from what I 1 recall yes And numerous other companies I think she ended up suing which I don't recall who But |2 3 through -- to the daughter who I met through she 4 works as an ray technician in Brick and I had to 5 go to a bone doctor then and low and behold that's | 6 how I met her Because she was the ray technician | 7 there and I just started talking to her about her 8 father and stuff and she told me he passed away 9 And I said oh and I says -- she 10 goes yes and my mother sued numerous customers or 11 what went on with Vince and pretty much that's all 12 she said And I said well it's sad you know 13 that things -- I hope everything goes along 14 Q When was that When did you talk to 15 her 16 A Oh that had to be about ten years 17 ago 18 Q About ten years ago 19 A Yeah 2000 20 Q And the daughter's name is Ann Marie 21 A Ann Marie Lacarruba She's married 22 now I don't recall her marriage name 23 Q Does she live around here 24 A Yes she still lives in Brick 25 Page 64 received and marked for Identification) BY MR HUGHES Q Mr. Lecki you brought a page of notes with you today A Some I jot down from memory Q Okay Can you walk us through what's in your notes and how it relates to what you remember A From start to finish I was at the age of 21 when I started at Reddaway in July of 1975 until August of 1995. It was a union factory Fred Grassel was one of the part owners Warren Conway part owner and Bill Barton Jr. he was the head owner Pam his wife that I knew later on when he -- you know I found out the whole information of the factory Then I found out Todd there was a -- her son was you know involved with you know the family member still until had '88 We did woven asbestos til around 1987 finished product in shipping and receiving or after Fred Davies was the foreman of the weaving shed worked with him until he retired and I took over as head foreman of the weaving shed Frank Davies Fred Davies nephew still works at Reddaway He worked with asbestos during the years Q A closes by River Okay Page 63 1 Or down the shore I know she's still | 2 If she's not in Brick it could be Toms 3 4 Q Okay Did Mr. Lacarruba do you 5 remember how long he worked there 6 A He was there before me in '75 so it 7 has to be a couple of years before '75 and when I 8 left in '95 he was still there 9 Q Okay Did he end up leaving the 10 company 11 A sure I guess I don't know I'm pretty 12 13 MR HUGHES We've been going for 14 about an hour let's go off and take a 15 minute break and then go a little bit 16 more 17 THE WITNESS Absolutely 18 THE VIDEOGRAPHER It is now 11:20 19 ' We are at the end of tape number 1 20 Whereupon a short break was taken THE VIDEOGRAPHER It is now 11:37 on May 17 2012. We will continue with tape 2 of the videotaped deposition of Raymond Lecki 21 | 22 23 24 Whereupon Lecki Exhibits 9-15 were 25 He works part time now at Reddaway Page 65 Todd was not at the Reddaway in any title in 1984 Fred Grassel was still alive and in charge of plant operations until '86 when he died Warren Conway was in charge of finance of the whole factory until he retired in 188 or around then Ed Eggert was hired by Bill Barton Jr. to take over sales and plant operations 1986 Mike Alape took over for Warren -- Alape e took over for Warren Conway when he retired 1989 with finance and sales Todd started at the factory late '87 '89 as head salesperson After a year or two Todd did not go out of the factory on the road for sales He convinced Bill and Pam the factory needed change ~ in the office Or -- at or around '89 or '90 he fired Ed Eggert in the winter and fired Mike Alape a week before Christmas In 1991 went to Germany with Todd and Joey Dipadavoa which also he hired in the factory as plant superintendent or plant operations manager I met my wife April 21st 1985 married October 4th 1986 and my daughter was born August 3rd '87 to bring some memory back on dates that's how I recalled most of the stuff because Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 66..69 || Page 66 Page 68 1 that's how when I came home my wife when I was still 1 During the regular workweek it wasn't mandatory 2 working with asbestos she said it was a bad smell 2 Q Okay 3 the asbestos smelled cleaner 3 A Again the only mandatory thing was 4 Q Okay 4 eye protection throughout the factory 5 A And that's all I have written 5 Q Okay Let me show you Exhibit 10 6 Q Okay Did she go to the plant 6 Have you seen a document like that before 7 sometime in the mid 7 A Material data sheets 8 A 9 lunch A couple times she stopped by for 8 Q Yeah An MSDS sheet have you ever 9 seen one of those 10 Q Okay Have you talked to her about 10 A Yes they came in on either the drums 11 your testimony today 11 the linseed oils to tell you what was in the 12 A Yes 12 product you know they covered you know when it 13 Q What can she recall about the use of 13 was shipped 14 asbestos if anything 14 Q Okay Now that MSDS sheet does it 15 A The smell was bad because it was 15 appear to be for the Reddaway woven lining 16 musty wet and normally the minute I come home she | 16 A Yes 50 percent asbestos 17 said take a shower don't go near the kids because | 17 Q Okay Is that correct from your 18 I worked with asbestos It's either was in my hair | 18 experience was the product about 50 percent 19 or pretty much on my skin From washup you couldn't 19 asbestos 20 really -- you know even though you changed 21 uniforms left your work shoes there it was still 22 you know you got home you washed up real good 20 A It was all asbestos weaving through 21 the dipping process when you dipped the rolls 22 total asbestos 23 Q Okay You mentioned a trip to 22 Germany what was that about 23 Q So the woven stuff was asbestos 24 A Yes 22 A We had -- it was one of our big 25 Q But was there also some wire in it Page 67 1 customers They bought asbestos lining at the 1 A Brass and zinc Page 69 2 beginning and then when we changed over to 2 Q Okay Was the brace and zinc -- first 3 asbestos they were putting in big orders which | 3 of all why was there brass and zinc 4 helped us out with the asbestos 4 A Brass held for strength zinc was for 5 We went over there because they were 5 lubrication throughout the wearing process as the 6 closing down one -- a part of their factory so we 6 lining was applied to the brake pad or the brake 7 went over and bought the remaining old looms which | 7 drum 8 looked like ours to get us extra parts and we 8 Q And for the heavy woven lining | 9 bought it for scrap metal meaning it was a deal you 9 how much brass or zinc would be in it if you know 10 couldn't pass up on The type of machinery it 10 A Per bobbin some had two strands of 11 almost coincided what we had Because the German 12 and English it looked the same For future you 11 brass and two strands of zinc Some had a single 12 strand of brass single strand of zinc Some were 13 know breakdowns and big major if anything really 13 plain nothing in them So some numbers were like 14 broke down we had extra stuff 14 630-0 then it was 6302B 6302BZ The six was the 15 Q Okay I'm going to show you a few 15 type of strand the three was the wrap wraps of 16 more documents That's Exhibit 9 and at the top it 16 yarn and the two meant two wires two wires of 17 talks about OSHA and talks about I think 17 brass two wires of zinc 18 respirators Do you see that 19 A Yes 18 Q Okay 19 A Or one brass one zinc | 20 Q Okay Do you know if the company ever 20 Q So when the woven heavy lining 21 got a citation from OSHA you may or may not know 21 was coming off of the looms okay say in 1984 22 I'm just asking 22 okay 23 A Not -- no that would be more office | 23 A Yes 24 because only when they arrived like for testing we | 24 Q What would be in that product before 25 more -- we wore the -- we wore the respirators 25 it went to the resin and the dip what would be in Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 70..73 Page 70 1 the product besides the asbestos yarn Would it be | 1 2 the brass or zinc 2 3 A It'd be both 3 4 Q Brass and zinc 4 5 A Brass and zinc yes 5 6 Q Anything else 6 7 A Oh on the edge so that -- for cutting 7 8 would be jute a trim on the edge which would be the | 8 9 rope type fiber just so -- because the trim always 10 = got thrown away |9 10 11 Q Okay And the jute was u 11 12 A u yes 12 13 Q So it was -- you'd have some strands 13 14 of the brass or wire or brass or zinc some of the 14 15 jute on the sides 15 16 A On the side for cutting purposes 16 17 because it was wasted it was thrown away 17 18 Q But the over -- is it fair to say the | 18 19 overwhelming majority of the stuff that would come 19 20 off the loom would be the asbestos yarn 20 21 A Yes With the -- 21 22 MR SMITH Objection to form 22 23 THE WITNESS -- with the brass and 23 24 zinc 24 25 25 didn't have asbestos in it right A No. Page 72 Q Okay So when it came out of there presumably now it has some of the resin in it too to go with what came off the loom A Yes that percentage I don't know That was in the dipping process Q Okay Let me show you another one That's number 11. what that is That's another -- can you tell me A These are order forms filled order forms for unbranded asbestos woven dated 1-27-88 and the other one is dated 2-16-88 Q Okay showing for that And what thicknesses is it A From the thin size 16ths quarter and 16ths Q Okay And is it your recollection that as of 1988 the company was able to make asbestos woven brake lining in those sizes A Yes Q Okay Let me show you Exhibit 12 Can you tell what that is A Another order dated 1-27-88 for 16ths asbestos woven 1 BY MR HUGHES Page 71 Page 73 1 Q Okay And is it your recollection 2 Q Okay 2 that the company was able to make asbestos in 3 A And in the filler It ran in the 3 that size in 1988 4 shuttle too that's what made the thickness on the 4 A Yes 5 sizes throughout the woven process to weave it 5 Q Okay I think you testified earlier 6 together There was also brass and zinc in there to | 6 that when the company was selling the asbestos 7 bind it and each -- each loom that ran always had | 7 product the sales documents would say 8 brass or a zinc wire in it for that thickness 8 asbestos on them is that correct 9 There was never a yarn without a wire in it and 9 A Yes 10 especially in the weaving up in front 11 Q Okay The yarn when the company was 10 Q And do those seem to say 11 asbestos on them 12 making the asbestos heavy woven lining was the | 12 A Yes 13 yarn to your understanding have anything in it 14 besides asbestos 13 Q Okay Let me show you Exhibit 13 14 Can you tell what that is 15 A No it was just asbestos 16 Q Okay All right So when the 17 product would come off the loom would it be more 18 than 50 percent asbestos 19 A Yes 20 Q Okay But then the product would go 21 to the dip right 15 A -- dated -- this is a -- one of the 16 shipping orders shipping release orders what's 17 going out of shipping and receiving dated 8-23-85 18 three bales of asbestos brake lining 19 Q And as of 1985 is it correct the 20 company was still making and selling asbestos 21 brake lining | 2222 A Yes 222 A Yes this is a finished product 2222 Q And it would be soaked in that resin 222 Q Okay And would that be woven rolls 2222 A Yes 222 there 25 Q Okay So presumably -- and the resin | 25 A Yes Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 74..77 Page 74 Page 76 1 Q Okay How do you know that 1 A On the outside of the finished 2 A It's three bales and in the bales 2 product 3 all bales had woven centrifugal brake lining which | 3 Q Okay Let me show you -~ 4 was the bales 4 A On the roll part 5 Q And that would be -- would that be the | 5 Q This is -- we don't need to bother to 6 burlap bags ' 6 mark this this is Exhibit 9 from Mr. Walker's 7 A Depending on the size -- burlap bag 7 deposition It's a -- it's like a Reddaway 8 yes roll -- roll good as it was called 8 promotional brochure but let me hand it to you 9 Q All right Let me show you one more | 9 okay You just mentioned a logo -- what did you 10 it's 14. Can you tell me what that is 10 say a logo on the outside 11 A Dated 8-16-85 this is an order form | ink 12 for the variable sizes from 16ths 8ths 11 A It was an pad type with a stencil 12 and they logo it on the outside if the customer 13 16ths a quarter woven lining that's 14 asbestos 13 wanted Redco which that's what it looked like right 14 there in the picture and that was branded on the 15 Q How do you know 16 A It just says HD it doesn't say 17 asbestos If it was asbestos it would 18 specify asbestos 15 outside as well as maybe on the inside If they 16 didn't they didn't get the logo They just got a 17 size and that was tagged on it to show what size the 18 roll was finished Whatever size it was 19 Q Okay Did you also see the 20 abbreviation RNAW for asbestos 19 Q Can you hold that up and show the jury 20 where the logo would be stamped on there when it was 21 A Yes that was another little logo or | 21 branded 22 abbreviation 22 A It's -- two brands would be on the 23 Q Would that stand for Reddaway 23 outside perimeter and on the inside diameter 24 asbestos woven 25 A Yes 24 Q So it'd be put on the outside and the 25 inside of the roll Page 75 1 Q Okay But that one the document 1 A Yes Page 77 2 you're looking at says -- what does it say heavy 3 duty 4 A Just heavy woven lining I 5 would say this is asbestos 6 Q Okay And then here's the last one 2 Q Okay And if you page through that 3 document do you see pictures of the heavy 4 woven rolls the way that they used to look 5 A Yes this is another one this is a 6 thicker size 7 I think that's 15. Can you tell me what that is 8 A This is another order form sizes 9 16ths quarter date 8-25-80 -- 8-28-85 10 sorry 11 Q Okay 12 A Unbranded heavy woven brake 13 lining That's asbestos 14 Q Where it says -- so that would be 7 Q Okay And would that -- if it was 8 branded Redco would it have had Redco stamped on 9 the outside and inside 10 A As well as same same as the thinner 11 sizes Any type of roll good in this form would 12 either get the logo here on the outside as well as 13 the inside and a tag stating the size of the -- of 14 each roll 15 asbestos right 16 A Yes 15 Q How would the logo be stamped on 16 there if you know | 17 Q Okay And where it says unbranded 18 do you know what that would mean 19 A There's not our logo on it It just 17 A With an ink stencil They had 18 stencils and an ink pad regular ink pad and they 19 just inked them on 20 goes out plain The company that it gets shipped 21 to they either put their logo or nothing on it 22 Q Okay Did you ever see the roll 20 Q Okay So it was possible then to 21 stencil graphics or words on the surface of the 22 rolls of lining 23 lining when it would have the Reddaway logo 24 A Yes it would say Redco 25 Q Where would it say that 23 A Yes 24 Q Okay Did you ever see where Reddaway 25 stenciled or put on the surface of the linings any Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 78..81 1 warning about asbestos Page 78 | |1 to Page 80 2 A No not on the linings only on the 2 A In the big oil field blocks they used 3 burlap bags when it was shipped out 3 to sell packet kits of brass bolts and nuts lock 4 Q Okay Did Reddaway while you were 4 washers and washers which is in that picture there 5 working there ever tell you that there was any risk | 5 Q Okay 6 that asbestos could cause cancer or mesothelioma 6 A That went in almost every box of the 7 A No just at -- just the warning labels | 7 oil field wells Or the thicker sizes depending on 8 that you worked with asbestos 8 what the customer wanted or needed 9 Q Okay But you never saw any warning 9 Q Did you have any understanding of 10 that was actually physically stenciled or put on the 10 other ways that the lining could be attached to 11 rolls themselves 11 brake bands for example could it be riveted 12 A Not to my knowledge no 12 A It could be riveted or also epoxy and 13 Q Okay Did you have any understanding 13 I think the epoxy went on lighter clutches or 14 of what the rolls would end up being used for out in | 14 brake applications 15 the market 15 Q Okay 16 A Yes 16 A We also sold the epoxy 17 Q What kind of things would they be used | 17 Q Did you ever actually see the roll 18 for 18 lining when it would be taken by an end user off the 19 A It was for all heavy equipment 19 roll and put on a brake Did you ever ever see an 20 So it went on heavy machinery Like I said 21 the oil field was a big product 20 end user or just hear about it or how do you know 21 about that 22 Q Cranes ; 22 A I would hear through you know some 23 A It went on cranes barges Then it 23 operations on what the other companies did I | 24 went -- the thinner sizes went to light holding 24 sometimes never saw how they applied just through 25 brakes parking brakes you know light 25 like when we used to counter -- countersink holes Page 79 1 Page 81 equipment So your thinner sizes went on lighter 1 that was I guess riveted The other company did 2 duty as well as you went up in sizes it went for 2 that 3 heavier duty or different applications Then it 4 went into custom cutting on different sizes 5 Q What about elevators could they be 6 used on elevators 7 A Elevators we tried getting into that 3 Q Okay 4 A What we used to ship to 5 Q So you understood that the lesser 6 widths like quarter could be used for brake 7 bands for industrial use 8 but it wasn't our field They were looking at the 8 A Yes 9 other variables 10 Q Okay Did you ever hear the phrase 9 MR SMITH Objection to form 10 BY MR HUGHES 11 brake bands 12 A Yes 13 Q B 14 What are brake bands 15 A Brake bands is what the lining gets 16 attached to 11 Q Okay Is that something that was 12 generally known around the company as far as you 13 could tell 14 MR SMITH Objection as to form 15 THE WITNESS Repeat that again 16 BY MR HUGHES 17 Q Okay 18 A So that's a surface that it gets 19 attached to as well as when it goes to on the -- it 20 would be on the other brake surface So there's 21 two surfaces one that it gets applied to and one 22 that gets put onto in the process of whatever 17 Q Well would other people at Reddaway 18 have known that as far as you could tell 19 MR SMITH Objection as to form 20 Speculation 21 THE WITNESS As to 22 BY MR HUGHES 23 equipment to hold or stop the equipment 23 Q What the brake lining would be used | 22 Q Did Reddaway sell products that would 24 for out in the market 25 help you to put the lining on the band if you wanted 25 A It was always for heavy Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 82..85 1 equipment 2 Q Page 82 Page 84 1 raw material to make our yarns And that was the Okay Was it marketed for that use 2 asbestos 3 A Yes 3 So he wanted to know how much -- how 4 Q Okay And would executives from 4 good our production was what was the outlook on 5 Reddaway go to your knowledge out in the field and | 5 production sales and how much you know we're 6 meet with potential accounts or existing accounts 6 going to order in the future 7 A Oh yes for promoting more sales or 7 Q Do you remember -- 8 trying to see if they were going to get any new 9 equipment Or buy new equipment or see if we can 10 put the pads on the new equipment Or we had a 8 A To gear up 9 Q Okay Roughly when was that meeting 10 if you know 11 change a design or different cutting which was 12 custom cutting 13 Q Okay 14 A And see if we got any orders 11 A That had to be '87 '88 12 Q Okay What about any meetings of the 13 company people at Reddaway to talk about trying to 14 change to asbestos | 15 Q When the company was making the change j 15 A Ed Eggert was telling us you know 16 from asbestos to asbestos did there come a time 16 periodically when we were changing over that we 17 when the company was having problems in terms of 18 revenues and being able to make payroll 17 started samples and this is going to be the new 18 product and when we find a good product because we 19 A Sure There was one time Warren came | 19 tried many samples And then when the Kevlar and | 20 out and he got us all together down in shipping and 20 the different blend came we said all right we're 21 receiving and he was a little taken aback that he 21 going to nail this down This is what we pretty | 22 had to tell us that one week we probably -- we used 22 much started ordering and started getting done But 23 to get paid every Wednesday that they might not 23 the problem started lacking in the dipping The | 24 meet payroll because of a customer late on payment 24 resin that was for asbestos didn't go with the 25 or not coming through with a payment because of , you 25 asbestos It had to be changed So that took | Page 83 1 know our lack of -- not lack of production it was 1 some time Page 85 2 lack of sales 3 And we were struggling to get out of 4 one which was the asbestos get into asbestos 5 and sales was dipping at the moment And things 2 So the dipping process started to 3 change because now we're getting out of asbestos it 4 wasn't the same The asbestos wouldn't set up 5 So Bill Barton Jr. had to get a chemist in one time | 6 you know we were spending -- trying to change over 7 which asbestos was three times the amount of 6 and help him and they started trying to figure out 7 what chemical or what process to now start with the 8 asbestos 9 Q 8 When you say the amount you mean the | 9 asbestos to get that geared up so we can start selling or make a product that would work out in the 10 price 10 field 11 A wise yes 12 Q Okay Were there ever any meetings 13 that you were involved in where people at Reddaway 11 Q Okay When the company had the 12 problem with payroll was that in the 80s do you 13 remember | 14 would talk about this changeover 15 A Well I visited with Norfab I went 16 to visit down in Pennsylvania Norristown 17 Pennsylvania 14 A Yes 15 Q Okay Now you said you got married 16 in 1986 is that right 17 A '87 18 Q Tell me about that who went 18 Q 187 okay | 19 A Me Ed Eggert Mike Alape Todd -- no 19 A Oh no '86 I'm sorry | 20 it wasn't Todd it was Bill Barton and we all went 20 Q '86 21 down for a big meeting on the pricing or getting 21 A October 4th 186 j 22 some more asbestos yarn when we finally figured 22 Q 86 okay | 23 out this is the blend we want and make some type of 23 As of that time was your recollection 24 business arrangement with John and he wanted to 24 that the company was still making or selling the 25 know how much that he had to buy because he gets the 25 asbestos heavy woven Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Pages 86..89 Page 86 1 A In finished product -- yes it still 1 A No. Page 88 | 2 had a lot of finished product To the amount I -- 2 Q End quote is that correct 3 offhand I don't know how much was in finished But | 3 A No we were only into samples 4 my end was -- we were finishing out of the woven all | 4 Q Okay How do you know that 5 the raw material because eventually you couldn't 5 A I ran it 6 weave anymore because we weren't buying any more 7 So what was ever in the shop was just being 8 liquidated through the machines 6 Q Okay Did anybody know what ran on 7 those machines better than you did during the time 8 you worked there 9 Q Did you have any understanding of why | 9 A 10 the company was switching to asbestos 10 Q 11 A The laws the laws have changed 11 A 12 Eventually everything came down that we had to get 12 Q 13 out and we had to get into different competition 13 best Yes Who knew better than you Nobody So you were the one that knew the 14 with the asbestos 15 Q Okay In term -- did you have any 14 A Pretty much it came down to when they 15 want a change of size they came to me on the sizes 16 sense of what was more popular with customers in the 16 the product and the yarn what ran in the machine 17 80s in terms of asbestos or asbestos 17 And pretty much they said this is what we want to 18 A The asbestos always ran the best I 18 go with a thin size first | 19 mean the customers always wanted that as well as 20 you know they looked if we didn't sell it or we 19 Q Okay Were there ever times where you 20 would put spools of asbestos yarn on a machine for 21 were changing there was other avenues that they 21 one job or run then you'd go back to asbestos 22 could buy it which that's where sales dropped 22 yarn and then go back to asbestos yarn 23 because Korea and Canada were selling asbestos brake | 23 A That was a sample We'd run a sample 24 pads or brake lining 24 on the edge of the asbestos and that would get cut 25 So customers went through them to get 25 in finishing 1 orders that we couldn't fill because we were Page 87 1 Q So were there time -- so is it Page 89 2 changing over then So they were still getting 3 finished product that we couldn't sell or we didn't 4 sell anymore where we were changing over and then 5 now that's where sales dipped also 2 correct that there were times where you would switch 3 over to asbestos yarn but then you would switch 4 back to asbestos yarn on a given machine 5 A Yes 6 Q Was the company using the sales of the | 6 Q Okay In Mr. Walker's deposition on 7 asbestos products to fund the change to the 7 page 25 he said you couldn't just go back and forth 8 asbestos | 8 with the asbestos and asbestos it would be 9 MR SMITH Objection to the form 9 impossible Once they were changed over that was 10 THE WITNESS Yes 10 it Is that correct 11 BY MR HUGHES 12 Q Okay How do you know that 11 A No. 12 Q Why not 13 A Well because we had a lot of finished | 13 A When you run a sample and you put it 14 product you had to finish out We just didn't 14 in the bobbins on the edge of the material which 15 throw it all away which was tons of you know 15 ran a three strip with the rest of the loom 16 finished product until we finally -- the customers | 16 asbestos up in front when everything got tied in 17 didn't buy it anymore or they were afraid to buy it 18 or they were buying it other routes sales dropped 17 you would run a asbestos fiber yarn through the 18 shuttle so that this product the sample gets the 19 Q Okay 19 asbestos the rest of the asbestos gets the 20 A And then they were -- the customers 20 asbestos which is a filler 22222 were changing over to asbestos or starting to 22222 gear up 22222 Q Okay In Mr. Walker's deposition on 22222 page 21 he said in early 1983 we were in full 22222 production of the asbestos 21 Then when it goes down and I 22 designated where the product was to be trimmed for 23 the finishing when it got dipped and the process of 24 rolled and finished and grinded they cut that then 25 it goes to sampling which Vince would get it in Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 90..93 Page 90 1 testing and then the rest of the lining would put 1 2 the side Whether they used it or not in 2 3 finished good that was up to finishing But it was | 3 4 all blended 4 5 But the edge was just the 5 6 asbestos meaning the yarn that came in from the | 6 7 creel as well as the yarn that ran just the front 7 8 for a sample Now that ran either a foot length | 8 9 or foot length and only ran for a specific length | 9 10 = for a sample 10 11 Q Okay 11 12 A When we were starting sampling 12 13 Q At page 40 of Mr. Walker's deposition | 13 14 I asked And they would have one loom for the 14 15 = quarter 15 16 Answer Yes 16 17 Question There would be one 17 18 particular loom that would make it 18 19 Answer Yes 19 20 Question And not two looms 20 21 Answer One loom 21 22 Is that correct that there was only 22 222 one loom for the quarter 23 222 A No there was two looms 24 222 Q How do you know that 25 Page 92 Q Okay All right I've asked you today about how the looms worked and I've asked you generally about the resin Have I asked you anything that you would think would be a trade secret that other companies shouldn't know about if Reddaway is trying to protect its secrets MR HAMILTON Objection to the form THE WITNESS When we've changed over the dipping room we changed over we situated different departments and made it more streamline When they changed the dipping room the dipping tank used to be in the ground So when they were going to fill that in and finish off that area and use it for a different department they had -- before the contractor came in and cemented the hole which was a tank which was left in ground we dumped in extra barrels or old barrels of resin and other parts of stuff or brake lining that was never going to be used or damaged in the hole to take up room So less cement and then that was finished And that's what's in the ground there now ; 1 A Page 91 Because I built the new one with Ed 1 BY MR HUGHES Page 93 23 Pagano and Fred Davies This is before Fred Davies | 2 Q 3 retired 3 there Are you saying they put asbestos in 4 Q Okay And was Mr. Walker working at 4 A Yes there should be some asbestos or 5 the plant when you all built the second loom 6 A No. 7 Q Okay Did Mr. Walker ever sit down 8 with you during the time that you worked together 9 to ask you all about how the looms worked how the 10 yarn worked all the details 11 A At times yes 12 Q Okay 5 resin dumped in that ground there that corner 6 Q Okay 7 A That was the old dipping department 8 the old dipping 9 Q Did the company get any approval from 10 any regulators before they -- are you saying they 11 put asbestos brake lining in the ground 12 A Yes 13 A Not much He was involved more sales | 13 Q Okay Did they -~ do you know if that 14 and then plant operations 14 was approved by any regulators 15 Q Okay Did he -- did Mr. Walker ever | 15 A Not to my knowledge 16 contact you say in the last year to ask any 17 questions about how these things worked 16 Q Okay Is that something that the 17 company hasn't publicly revealed 18 A Recently 18 A Yes 19 Q Yeah 19 Q Okay Is there anything about the you 20 A No. 20 general resin process I have asked you that 21 Q Okay When was the last time you ever 21 would consider a trade secret besides what you've 22 spoke to Mr. Walker 22 just said about putting things in the ground 23 A August of 1995 22222 MR HAMILTON Objection to the form 24 Q And that was when you resigned 22222 THE WITNESS The resins was a patent 25 A Yes retired 22222 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 94..97 1 BY MR HUGHES 2 Q Okay Page 94 1 corporation company manufacturing Page 96 2 Q Okay Have you ever heard of someone 3 A And whatever -- I don't recall what 3 named Sylvester White 4 company made the resins but the blend and 4 A He worked with Vincent Lacarruba in | 5 everything was a special percentage blend that was 5 the finishing department custom cutting 6 patent |6 Q Okay Is he still alive 7 Q Okay But I haven't asked you what 7 A To my knowledge I really don't know 8 the ingredients were in the resin 8 Q Okay Josephine Restano 9 A No no 9 A Deceased She worked with me at the 10 Q Except that it wasn't asbestos 10 beginning before she retired 11 A Yes 11 12 Q Do you know what the exact ingredients | 12 13 were in the resins 13 MR HUGHES Okay I think those are all my questions I'm going to look through my notes but I'm going to turn it over to the 14 A Linseed oils 15 Q Okay Was that a secret 14 other lawyers here to see if they have any 15 questions for you 16 A Depending on what type or how it was | 16 MR SMITH Go off the record 17 made yes 17 THE VIDEOGRAPHER It is now 12:11 18 Q Okay But I haven't asked you what 18 We're going off the video record 19 type of linseed oil right 20 A No. 19 Whereupon a short break was taken 20 THE VIDEOGRAPHER It is now 12:22 21 Q And I haven't asked you how it was 21 We'll go back on the video record 22 made 22 EXAMINATION BY 23 A No. 23 MR HAMILTON 24 Q Okay Do you know what process the 25 company uses nowadays to manufacture its lining 24 Q Hi Mr. Lecki my name is Dexter 25 Hamilton I'm an attorney for Reddaway I just have 1 A No. Page 95 1 a few questions for you Page 97 | 2 Q Okay Mr. Walker gave a deposition in 3 1993 where he was asked if Mr. Eggert resigned or 4 was fired and he said he resigned does that match LO your understanding 6 A No. 2 A Okay 3 Q You were shown a number of invoices 4 today where Reddaway's products were shipped to 5 various customers Do you remember seeing those 6 invoices 7 Q What's your understanding 7 A Not all the time I didn't work in | 8 A Ed Eggert when he came out he said he 8 shipping and receiving but I saw them in | passing 9 was just fired He said goodbye to everybody Todd 9 because I used to go down to shipping and receiving 10 had took his car away which was a Volkswagen Jetta 10 or in the areas saw them 11 And that was the last I saw of him Then shortly 11 Q Well I'm asking do you remember 12 after Mike Alape was fired a week before Christmas | 12 seeing those invoices today 13 Q How close was he to his retirement 13 A Yes yes 14 A Oh I don't know how many years he was | 14 Q That you were shown 15 going to put in or do 15 A Yes 16 Q At page 27 of his 1993 deposition 17 Mr. Walker said he was asked Why did Ed Eggert 16 Q Was your responsibility to prepare 17 those invoices 18 resign from the company and he said I don't 19 really have that knowledge to move out of New 18 A Through my department I only received 19 orders to make the roll good 20 Jersey because he didn't like it anymore basically | 20 Q So you didn't -- it wasn't your 21 Is that your understanding 21 responsibility or anyone who reported to you it 22 A No. 22 wasn't their responsibility to actually type those 23 Q What's your understanding 23 forms of what was being requested and what was being 24 A He was just fired and he -- from what 24 sent to the customer 25 I recall he went back to Raybestos company , 25 A No. Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 98..101 Page 98 1 Q You were asked some questions about Page 100 1 outside was the tanks on certain other chemicals 2 the content of the yarn the containing 2 that were put into the batch of the dip 3 yarn How did you know what materials comprised the ; 3 Q Now when the lining came off of the | 4 asbestos containing yarn when the factory was using 5 asbestos containing yard 4 looms and I think you said went into ovens 5 initially 6 A I was taught all that through Fred 6 A Drying ovens 7 Davies 7 Q Drying ovens 8 Q Okay 8 A My department to get the water out of 9 A He taught me all the yarns plus the 9 it 10 women Every woman that I was with on each machine | 10 Q So the drying ovens that would be in 11 how I learned each machine they taught me what was || 12 in the machine how it worked and I worked them as 11 your department also 12 A One I had one 13 well as repair them 13 Q One | 14 Q But the various shipments of asbestos 14 And then would it go into a dipping 15 containing yarn when the factory was using the 15 department correct 16 asbestos containing yarn would you necessarily see / 16 A Well there was a couple other 17 the packaging of the yarn and know specifically what 17 process but yes exactly finished To make the 18 was in each batch or each shipment 19 A I unloaded it 18 roll hard and get into a finished product it had to 19 be dipped 20 Q Okay So there would be paperwork 21 that would come with it 20 Q But you weren't in charge of that 21 department 22 A Yes 22 A No sir | 23 Q And what other department -- describe 23 Q And after the dipping department did 24 all of the departments that were at the factory 24 it go to another different department I know it 25 during the time period that you were there 25 went through other processes but I'm just trying to | Page 99 1 A You had a full working machine shop | 1 figure out what different stations Page 101 2 had lathes had cutting materials it had also -3 you know -- you know drill presses and the normal 4 pretty good sized machine shop to fix all repairs of | 5 the factory Ed Pagano ran that Then you had the || 6 stock room which partly was pretty much mine which 7 kept the inventory of asbestos at the time and as 8 well as the asbestos because that was the 2 A After it came out dipping it got like 3 vacuumed so it would squeeze out all the juice of 4 the compound they would weigh it because they went 5 by weight to see if the compound set up properly 6 Then it was taken to a drying rack second level 7 which was an upper level second floor on an 8 elevator They brought it up No man ever ran on 9 shipping area -- delivery area where I brought in 10 the yarns 11 The next area was Vincent Lacarruba 12 which was custom cutting And he did all of the 13 different custom work on I'm going to say the 14 thinner sizes or up to a certain size 9 it it was just for material They pulled the 10 chain -- it was an old belt driven elevator and it 11 went upstairs and they dried it on the rack 12 Q Was that a different dep 13 A Well it was pretty much involved the 14 finishing department It was all involved with 15 Then in the middle which was the 15 finishing 16 biggest department which was mine the weaving 17 shed which had all of the looms and a drying oven 16 Q And then after that there was the 17 shipping department 18 which you know was ran off of the boiler at the 18 A That was pretty much in the whole 19 time until we had a problem The material caught on 19 finishing area that section of the end of the 20 fire but it switched to gas So we put a new gas 20 company 21 drying oven in there Then it went to shipping and | 21 Q Okay And that's where the label 22 receiving and finish meaning everything -- big 22 were -- the warning labels and other labels were 23 cutting of the rolls bigger material all the rest 23 placed 24 of the material went there as well as the dipping 24 A Yes 25 department at the end of the factory And then 25 Q And you were never in charge of that Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 102..105 1 department correct 2 A No. Page 102 Page 104 1 told ten rolls then ten rolls possibly went out in 2 shipping That I wasn't involved in All I got was 3 MR HAMILTON That's all I have 4 EXAMINATION BY 5 MR SMITH 3 the initial orders to make the rolls I'm guessing 4 that was finished product that had to be replaced 5 Q And once the weaving shed made the 6 Q Mr. Lecki my name is Patrick Smith I 6 rolls and they went over to the finishing 7 have a few questions for you 8 In addition to the departments that 7 department you have no information as to where they 8 were sent what quantities they were sent to or what 9 you just spoke about there was -- was there also a 9 customers they were sent to correct 10 sales department 10 A No only if it went out in raw good 11 A Yes that was in the office 11 meaning roll good meaning out of my department 12 Q Did you ever have any responsibilities 12 which a couple times I had a couple orders that I 13 in the sales department 14 A No. 13 had to gather up dry rolls for an order but they 14 went out just like that white dry rolls 15 Q Okay Other than the trip to Germany / 15 If it was asbestos or when we changed 16 and the trip to Norfab in Norristown Pennsylvania 16 over to asbestos they went out of my department 17 were you ever responsible for making sales calls on 17 roll good finished meaning just off the loom 18 any of the Reddaway customers 18 Q But generally once the production was 19 A No. 19 done in your department it went over to finishing 20 Q Were you ever responsible in any of 20 and it went over to shipping and receiving and you 21 the years you spent at Reddaway to take orders from 21 had no further responsibility for determining who 22 any of those customers 22 got those rolls correct 23 A No. 23 A Yes 24 Q In the 1980s and let's -- say let's | 24 Q Okay Now you've told us that when 25 take from like 1983 to 1988 would it be correct 25 the company started to switch over to -- from | Page 103 1 that one of the largest customers of Reddaway would Page 105 1 asbestos containing yarn to a asbestos 2 have been oil fields in that time period 3 A Yes 2 containing yarn that it started first as samples 3 A Yes 4 Q Okay And in terms of the oil field 5 customers the products that they were buying from 6 Reddaway tended to be the larger size woven brake 7 linings correct 8 A Yes 4 Q Okay To your memory did there come 5 time where the production switched from samples to 6 the regular production of asbestos woven brake 7 linings 8 A Yes 9 Q Okay And when I say larger size 10 why don't you tell us what those larger size were 11 A Inch inch and an 1/8 inch and a 12 quarter 13 Q Okay 14 A Three quarters If it went on any 15 type of smaller oil field I wasn't -- I'm not sure 16 about that but three quarters is just right under 17 and 8ths under the inch product but mainly the 9 Q And when do you recall that 10 A It had to be late '86 to 187 11 Q Okay Do you recall any time in 1983 12 being informed by any member of the company either 13 folks you work with or folks in the front office 14 that Reddaway was advising its customers that it was 15 regular -- it was engaged to do regular production 16 of asbestos containing woven brake linings 17 A Yes 18 big jumbo product which was inch inch and a half 18 Q You were told that 19 inch and a quarter 20 Q In the time period and let's just 21 talk about '83 to '88 what percentage of the 19 A 20 Q 21 = from Yes Okay And who were you told that | 22 production of Reddaway was designed to go to the oil | 22 A Fred Grassel at the time he was still 23 field in those sizes 23 alive saying that we're going to be changing we're 24 A It varied It all depended on what I 24 going to be doing some samples while we were still 25 received to make the raw material product If I was | 25 into asbestos but they were getting scared because Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL , AL Raymond J. Lecki on 05/17/2012 Pages 106..109 | Page 106 Page 108 1 of the laws changing and we were going to get out of 1 number 16 the product information sheet would have 2 it 2 been to inform the Reddaway customers of the 3 So at the time we were still in 3 availability of the Reddaway asbestos woven 4 production but making samples and trying different {| 4 brake linings 5 variables of the asbestos 5 A Yes 6 Q Okay I guess my -- I guess my 7 question's a little bit different Do you -- to 6 Q 7 this memo Okay And what is the date you see on 8 your memory do you recall when the weaving shed 8 A April 1st 1983 9 went from simply making samples of the asbestos 10 woven brake lining to actually the regular 11 production of that product 9 Q Okay And for the material use 10 Exhibit 16 indicates that this Reddaway asbestos 11 woven brake lining was designed for use in band 12 A Late '86 into '87 fall into '87 full 12 brakes and band clutch service correct 13 bore Full bore meaning full production 13 A Yes 14 Q But other than full production do you | 14 Q Okay And these were the same band 15 recall a time in 1983 where there would have been 15 brakes that you were describing before for us 16 available to the Reddaway customer asbestos 16 A Yes 17 woven brake linings in various sizes such as a 18 quarter 16ths 8ths or one inch 19 A Only in samples 222222 MR SMITH Okay Let me -- what's 222222 our next exhibit 222222 Whereupon Lecki Exhibit 16 was 222222 received and marked for Identification 17 Q Okay And if you look there sir for 18 sizes available it indicates that as of April 1st 19 of 1983 Reddaway was making available to its 20 customers the asbestos woven brake linings in 21 widths to inches wide ground Now what does 22 that mean Does that mean the width of to 23 inches 222222 BY MR SMITH 24 A Yes 222222 Q Mr. Lecki we've handed you what we 25 Q Okay Page 107 1 marked as Exhibit number 16 which is an 1 A Well -- Page 109 2 April 1st 1983 memo of the Reddaway company Have | 2 Q So you would have made it from inch 3 you ever -- first of all let me give you a chance 3 to inches 4 to read that 5 A huh 4 A 5 wide yes On a sample size yes up to inches 6 Q Do you recognize the document as one 7 that you've ever seen before 8 A Not offhand no 9 Q Okay Why don't you just take a 10 second and just take a look at it 11 Have you ever seen that document 12 before 13 A No. 14 Q Okay What is a product information 15 sheet Mr. Lecki 6 Q Okay Now the sizes available 7 doesn't say anything about samples correct 8 A No no 9 Q Okay And in terms of again under 10 sizes available under thicknesses it indicates as 11 of April 1st of 1983 Reddaway's making available to 12 its customers the asbestos woven brake linings 13 in thicknesses of a quarter 16ths inch 14 8ths of an inch and one half of an inch correct 15 A Yes 16 A This is telling me about the 16 Q Now those particular thicknesses 17 asbestos woven brake lining which is made in my | 17 would have been what would have been gone to the 18 department 19 Q Right . 18 industrial customers other than the oil fields 19 correct 20 A All about it 20 A Yes 21 Q And would this have been a product 22 information sheet that would have been provided by 23 Reddaway to its customers 21 Q Okay Oil fields as we discussed 22 one of the bigger ones right 23 A Thicker sizes 24 A Yes 24 Q Okay So as of April 1st 1983 a 25 Q Okay And the purpose of this Exhibit 25 customer could have ordered from Reddaway a Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 110..113 Page 110 1 quarter inch or inch asbestos 1 poles about maybe head height Page 112 2 woven brake lining correct 2 Q Right 3 A Yes 3 A That said Caution asbestos product 4 Q Okay And if that order had come in | 4 in use 5 Reddaway would have produced it as of April 1st 5 Q Okay Did the signs ever come down 6 1983 correct 6 A I'm not -- I don't recall 7 A Yes 7 Q Okay Was there anyone there that had 8 Q Okay And if you'll see on page of | 8 a concern about carrying asbestos dust home with 9 that exhibit there's actually a price list for 9 them 10 those various brake linings correct 10 MR HAMILTON Objection to the form 11 A Yes 11 THE WITNESS No we changed uniforms 12 Q Okay Before Reddaway would sell to a / 12 We left our uniforms in the locker which 13 customer would Reddaway create an inventory of a 13 14 particular product before sales or announcements of | 14 15 the availability of product being available to the | 15 that's what we were supposed to do because they supplied uniform shoe work shoes everything stayed there 16 customer 16 BY MR HUGHES 17 A Yes 17 Q Okay Would Mr. Walker clean off the 18 Q So as of April 1st 1983 would it be 18 bottom of his shoes before he would leave 19 correct that Reddaway would have had in inventory 20 nonwoven -- asbestos woven brake linings in 21 thicknesses one quarter inch 16ths 19 A Yes 20 Q Okay Theresa Speights 21 p do you know who she was 22 8ths one inch 23 A Yes 22 A She worked in the weaving shed She 23 ran the thinner machine 16ths but she knew how 24 MR SMITH Okay Sir that's all the 24 to run all of them She pretty much was an all 25 questions I have thank you 25 purpose She knew a lot of the other looms Page 111 1 MS DRAYTON I have no questions 1 Q Okay Daisy Gonzales Page 113 2 thank you 2 A She works in the office if she's 3 MR HUGHES A couple cleanup 3 still there 4 questions sir 4 Q James Peero r 5 EXAMINATION BY 6 MR HUGHES 5 A He worked there in the finishing 6 department He hit the lottery and retired 7 Q It is it correct there were five looms | 7 Q Okay When you were working with 8 run off a belt drive pully system 8 Mr. Walker did he spend a good deal of time in 9 A Yes 10 Q And then two that were electric 11 A Yes 12 Q Okay When you worked at Reddaway 13 this was a full job 9 Florida or Texas to your understanding 10 A At the beginning when he did sales he 11 was on the road a lot and then yeah he stopped 12 Q Okay The Norfab facility that used 13 to be Ametex 14 A Yes 14 A Yes 15 Q Eight or nine hours a shift 16 A Yes 15 Q Is that right 16 A Yes 17 Q When were the shifts 18 A Day shift only 17 Q And that was in Norristown 18 Pennsylvania 19 Q Okay Were there actually signs in 19 A Yes 20 the plant that said asbestos on them back when the | 20 Q Was there a fellow named John 21 company was using asbestos 21 Weber Jr. 22 A Yes 22 A He was one of the owners 23 Q What were those signs Where were 23 Q Of what 24 they 24 A Of Ametex 25 A It said Caution They were up on 25 Q Okay And that's the place where you Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Pages 114..117 1 went on the trip that you mentioned Page 114 1 EXAMINATION BY Page 116 2 A Yes 3 Q When you worked at Reddaway did you 4 know that Abex was a customer 2 = MR.SMITH 3 Q In that time period the major 4 customers for that were the oil fields 5 A I've heard of variable customers I 6 wasn't really familiar of pretty much their 7 operation -- 8 Q Okay 9 A -- but you hear about some big 10 customers or some of the ones that were ordering 11 lot or were affiliated with the company in sales 12 Q Okay You were shown this exhibit 5 A Not at the beginning We couldn't 6 afford or we didn't supply the jumbo loom until 7 later They were waiting to see how the compound 8 set up because the big brake blocks that machine 9 like I said ran 2000 ends 2000 ends of the Kevlar 10 the asbestos was a lot of money So to fill 11 that machine I was pretty much the last one to get 12 involved in 13 the product information sheet for the asbestos / 13 Q Right So the -- so pretty much in 14 A huh 14 the -- that period of the 80s '84 185 186 187 15 Q Okay Is that a yes 15 the asbestos containing brake -- woven brake linings 16 A Yes 16 that were being made a lot of those were going to 17 Q Do you know whether this was sent to 17 the oil fields because that was the last loom to be 18 Abex or not 18 replaced correct 19 A I don't know That's part of sales or | 19 A Yes 20 office use only 20 21 Q Okay To your knowledge did Abex 21 22 assuming that they got that information did Abex 22 MR SMITH Thank you MR HAMILTON Nothing for me THE VIDEOGRAPHER It is now 12:44 23 ever make a request to switch to get the 23 24 asbestos instead of the asbestos do you know | 24 We are now done with the videotaped deposition of Raymond J. Lecki 25 A Not -- not to my -- 25 Whereupon the deposition concluded at Page 115 1 MR SMITH Objection to form 1 2 speculation lack of basis lack of foundation | 2 3 lack of knowledge 3 4 THE WITNESS Not to my knowledge 4 5 BY MR HUGHES 5 6 Q Okay Not withstanding this form is 6 7 it still your testimony that Reddaway was making 7 8 and selling asbestos heavy woven lining in 8 9 1984 9 10 A Yes 10 11 Q 1985 11 12 A Yes 12 13 Q 1986 13 14 A Yes getting out 14 15 Q Okay 1987 15 16 A Finished 16 17 Q Okay And then in 1988 would it be 17 18 asbestos 18 19 A Yes totally 19 20 Q And that's based on your personal 20 21 experience working in the weaving shed 21 22 A Yes 22 23 MR HUGHES Okay Thank you that's | 23 24 all 24 25 MR SMITH I just have one follow up | 25 12:44 p.m. Page 117 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 , ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL Raymond J. Lecki on 05/17/2012 ET AL Pages 118..120 CERTIFICATE Page 118 1 CERTIFICATE Page 120 STATE OF COUNTY OF 2 3 I Jamie I. Moskowitz a Shorthand 4 Stenotype Reporter and Notary Public of the State 5 Before me this day personally appeared 6 RAYMOND LECKI who being duly sworn states that 7 the foregoing transcript of his Deposition 8 taken in the matter on the date and at the time 9 and place set out on the title page hereof 10 constitutes a true and accurate transcript of said | 11 deposition 12 of New Jersey do hereby certify that the foregoing Deposition of the witness RAYMOND LECKI taken at the time and place aforesaid is a true and correct transcription of my shorthand notes I further certify that I am neither counsel for nor related to any party to said action nor in any way interested in the result or outcome thereof RAYMOND LECKI 13 IN WITNESS WHEREOF I have hereunto set my 14 hand this 17th day of May 2012 15 SUBSCRIBED and SWORN to before me this day of 2012 in the jurisdiction aforesaid 16 17 , 18 19 20 '' | Jamie Ilyse Moskowitz License No. XI01658 21 My Commission Expires 22 Notary Public 23 24 25 1 2 3 4 5 6 7 8 9 10 DEPOSITION ERRATA SHEET Page 119 RE FILE NO CASE CAPTION ERIK ROSS DEPONENT RAYMOND LECKI PHILLIPS DEPOSITION DATE May 17 2012 vs. ALBANY To the Reporter I have read the entire taken in the captioned transcript of matter or the my Deposition same has been read to entered me upon I request for the following changes be the record for the reasons indicated I have signed my name to the Errata Sheet and the appropriate Certificate and authorize you to attach both to the original transcript 11 12 13 14 15 16 17 18 19 20 21 22 SIGNATURE 23 RAYMOND LECKI 24 DATE 25 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 08724 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index 08724..3 0 7 1 73:13 13th 44:20 14 74:10 15 27 38 42 65:22 73:19 115 1986 31:18 2 2 14:20 63:23 110 1 13,18 63:20 1,500 12 23 1-17-84 34:18 1-27-88 13,24 16 27 106 1,: 10 17 63:23 17th 6 : 1849 23 : 18th 16 51:10 2,3,10 16,21 53 : 8,23 85:16 115 1987 42:16 64:19 64:19 115 2,000 23:12 2-16-88 72:13 inches 21,23 3,4 2000 62:20 116 1/8 103 8th 18:16 10 50 55 68 inch 25 100 28:23 10:17 10:17 7 : 11 72 11:20 63:19 11:37 63:22 12 72:22 12:11 96:17 12:22 96:20 12:44 116 111717 13 51:11 14 64:10 1980 23:20 1980s 102 1983 31 : 7,23 87:24 87:24 102 105 106 107 8,19 11,24 6,18 1984 31 17,24 65 69:21 115 1985 19:12 31:14 37 102 115 1989 38:18 65:10 1990 1991 1993 16 38:18 65:19 95 1995 43:10 64:11 91:23 91:23 1st 107 8,18 11,24 5,18 63:23 21 64:10 87:24 87:24 21st 65:22 24 25:10 25 25:10 89 25 foot 28:14 90 27 25:11 13,14,15 95:16 28 25:10 3 3 : 7,10 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index 3-23-84..9-15 3-23-84 35:14 35:14 inch wrap 46 69:15 40 90:13 4th 7:19 8:16 65:23 85:21 wraps 5 69:15 16ths 4,15,16 25:15 34:21 60:22 72:16 74:13 74:13 75 : 112 3/8 25:11 25:11 inch 110 8ths 18 11 30 21,23 74:12 106 109 inch 8ths 30 11,13 32 12:19 34 7,15 3rd 65:24 65:24 5 33:23 35 5/16 34:21 5 inch 110 : / 16ths 16ths 18:15 6,9 10 17,25 74:12 106 109 16ths 110 32nds 18:16 8ths 18:14 : : 50 25:12 68:16 71:18 foo foot t 90 51 12,14 4 53 6 4 33:21 34 6 6 33:25 35:17 630-0 69:14 6302B 69:14 69:14 6302BZ 69:14 49 53:21 85:12 85:12 116 83 22 103 84 22 35:12 116 7 7 19,23 60 8ths 18:13 103 70s 22 43 53:20 75 7,8 76 14,15 8 8 22,25 8-16-85 8-16-85 74:11 85 85 19:19:10 10 38:11 38:11 116 86 52:14 65 : 19,20 21,22 105 106 116 87 30:19 12,24 84:11 17,18 105 106 11: 6 8-21-86 36 8-23-85 73:17 | 8-25-80 75 65 84:11 103 89 13,16 8-28-85 75 80 22 : 80s 22 32:22 32:22 40:23 43 9 9 67:16 76 9-15 63:25 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index 90..asbestos 90 65:16 102 113 4,16 95 639 99.9 26:21 A A p admits 8:17 advance 3,9 advising 105 amount 83 9 86 Amy 6:23 7:19 6 and j 73:20 3,10 approval 93 approved 93:14 April abreviation ab reviation abbreviation 23:25 20,22 Abex Abex 6:20 4,18 21,22 abroad 42:11 AbsoAlbsuoltuteellyy 12,15 12,15 14:16 29:21 31 63:18 accept 8:18 accident 32:24 33:14 accounts 82 Action 5 add 7 24:23 added 18:23 5,: 9,11 aaddddi ittiioo nn 114 afford 116 afraid 87:17 afternoon 24 age 64 agree Aiken Aiken 1 8:19 air 27 19,23 Alape 65 17 83:19 95:12 Albany 4 : Alday 60 11 alive 65 96 : 105 alternative 37:23 America America 7:22 7:22 12,13 AmetAemxetex 20 : 24:16 46 Andy 11 5,15 Ann 62:21 62:21 announced 53:19 announcements 110 antiquated 33:18 anymore 39 86 87 17 95:20 anytime 15 apparatus 53:23 application 11 12 applications 16:24 17 79 80:14 applied 79:21 79:21 80:24 69 apprentice 16:15 57:15 107 : 8,18 11,24 5,18 area 54:18 54:18 92:16 9,11 10: 1 areas 97:10 arrangement 83:24 arrived 38:12 67:24 asbestos 25 13,182:137 19 19:12 15,18 20 22,24 24 26:19 29:17 10,14 15,17,19 20 4,6 13 13 33 : Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index containing..batch 22,24 4,5,14 86:21 79:25 16,18 36:14 16 99 104 11,12 B 14 16,22 1,25 bands 79:11 19 5, : 8 48:11 16,19 12,15 4,6,15 4,6,9 13 55:18 56:15 56:15 9,21,22 58 19,25 2,14,18 67 16,19 20,22,23 1,20 12,14 15,18 72 18,20 74:14 5,13,15 1,6,8 82:16 4,8 4,8 84:24 3,25 17,18 23 87 20: ,22 , 24 4,8 16,19 2,4,11 94:10 : 3,8 114 115 116 797:91:313 back 11 15:21 15:21 20:14 containing 98 11,22 assert 8:16 assuming 23 40:24 40:24 12,16 59:14 114 61:17 attached 65:24 16,19 80:10 21,22 4,7 atachments attachments 7:25 95:25 96:21 111 attorney 96:25 August 9:17 August43:10 3,10 64:11 64:11 background 10:14 bad 2,15 bag 54:16 74 65:24 91:23 authority 55:19 bags 28:21 12,13 : 12,13 74 : 78 : bake 48 availability 108 11: 0 Avenue 12:19 12:19 bales 35:11 17,20 73:18 2,3,4 avenues band 33:12 14,15 80:11 81 Barbieri Barbieri 60:21 60:21 barge 32:24 8,13,17 barges 78:23 barrels92:20 Barton 11,14 15 40:18 14,22 43 45:18 64:13 65 83:20 83:20 85 : 7:24 based 20 basic 30 basically 17:16 17:16 22:13 35:22 35:22 39 : 44:22 95:20 basis 48 : 115 : batch 98:18 100 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index beginning..bringing beginning 2 21:17 30:13 1,19 53:20 67 113 116 behalf 6:19 behold 62 belt 101 111 big 25 27:20 9,13 47:13 4581 60:417:613 66:25 3,13 78:21 83:21 99:22 80 1149 116 : billing 35 bind 20:14 23:15 58:16 71 bit 10:13 63:16 106 blend 46 12,14 12,14 12,14 50:19 83:23 84:20 4,5 blended 90 blends 38 boat 24 8 40:22 6,7 bobbin 15,21 69:10 born 65:23 bother 76 bottom 51 8 11: 2 bought 40 1,7,9 bound 23:14 box 29:16 80 boxes 28:24 35:11 54:14 brace 69 brake 16:24 25 17:18 18 19:13 20:15 22,24 24 28:25 29 23,24 7,10,15 18,20 6,16 106 107 4,11 20 109 2,10 20 116 15 brakes 78:25 78:25 108 branded 14,21 77 brands 76:22 brass 19:25 1,3,4 9,11,12 9,11,12 , 17,19 2,4,5 14,23 6,8 80 break 12:10 52:11 bigger bobbins 45:23 16,21 biggest 20:20 99:16 99:16 23 58:20 6,11 89:14 89:14 69 72:20 18,21 74 75:12 11,14 breakdowns 22 67:13 Brick 6 15 43 45:18 64:13 64:13 7,15 83:20 85 99:18 bolts 80 bone 62 bore 106 11,14 11,14 19 81 23,24 92:21 11 63 bring 65:24 bringing bringing 39 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index brochure..Christmas brochure 76 cartons C 35:11 59 67 66:20 84:25 broke 67:14 a case 8:11 26 86:11 9,10,13 38:12 40:24 41 44 45 99 : 101 : buildingbuildingss 9:11 9:11 built 18:24 1,5 buried 60:11 burlap 21,23 12,13 6,7 78 business 40 42 14 43:23 51:14 51:14 52 : 83:24 busy 21:17 buy 24:17 29 : 40:10 40:10 82 : 83:25 83:25 87:17 buying buying 86 87:18 103 h 6 e 20:11 call 24:16 27:14 41:13 43 called 11:14 18:20 23:24 29:22 41 58:18 74 calls 102 Canada 86:23 cancer : 21,23 21,23 78 cans 54:16 54:16 car 95:10 card 29:23 5,14,15 32:20 32:20 cardboard 54:14 cards 29:23 30 31:21 carrying 112 caught 99:19 caution caution 15,17 111 112 cautioning 54:17 ceiceillinig ng 23 : cement 92:23 cemented 92:1892:18 centrifugal 74 chain 101 chance 107 change 18:22 24:23 31 41 44:16 2,15 21,24 47:16 65:15 82:11 85 87 88:15 changed 25:16 30:15 50:14 20 35 55 112 changeover 38:22 39 83:14 changeovers 60:23 changing chcanhgainngg ing 30:17 32:10 59 84:16 86:21 2,4,21 105 106 charge 43 61:12 3,4 100 10: 1 check 54 chemical 85 chemicals 100 chemist 85 Cherie Cherie 6 Christmas 65:18 95:12 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index citation..cooking citation 67:21 close 27:19 37:14 40 3,7 3,8 comprised 98 City 20 10:17 Civil 5 95:13 closes 63 closing 67 55:21 56 63:11 67:20 71:11 computer 10 concern claim 33:14 clutch 40:13 72:19 112 61:24 108 2,6 concluded claims 2 Clark 8:19 Clark clutches . 80:13 coffee coffee 33 : 75:20 1,12 15,17 84:13 116 confidential 25:23 8:19 class 11 clean 54:12 15,16,22 55 10,13 17,20,22 24 57 11: 2 cleaned 51:15 51:15 cleaner 66 cleanup 11,18 3,4 3,4 3,4 111 clear 32 Cleveland 60 client client Clifton 44:16 coincide 32:14 32:14 coincided 67:11 coincided 67:11 college 20,21 color 50:10 col colors ors 50:50:14 14 command 31 companies companies 40 62 80:23 92 company 8:20 8,14 20 2318,21 18,21 3,20 5,13 34:23 34:23 15,24 4,8 4,8 3,25 11,24 86:10 87 9,17 4,25 18,25 96 101 104 105 107 111 114 competition 86:13 completed 51:17 Complex 12,16 compound 26:25 4,5 116 compounds Congratulations 10:11 contact 91:16 content 98 : continue 43:20 63:23 continues 8:18 contractor 92:17 controversy 43:19 converted 53:12 convinced 65:15 Conway 16 13:18 64:13 4,10 28:12 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONALINTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index coop..daughter's coop 27:14 County 10 61:13 11,12 coops 28 copy 57 : corner 93 couple 16:20 18:24 21 6,9 40:19 41 79 82:12 96 12,13 customer 96 99 12,23 D corporate 6 corporation 5 96 correct 11:18 44:10 44:18 53:21 55:13 58 66 100 104 111 47 76:12 80 97:24 106 109 13,16 114 customers D d 44 : daily 22:10 32 Daisy 113 damaged 48:23 688, :11 7 9 2,10 90:22 100 : 1,25 103 9,22 108 109 7,14 19 110 6,10,19 111 116 correctly 53 cost 37:13 Counsel 6:12 80:2580:25 countersink countersink 80:25 80:25 10,13 15 : 3 covered 35:22 68:12 68:12 Cozen 6:17 6:17 cracking 37:16 cranes 22,23 crate 16 29 crates 28:25 create 110 creel 20:11 59:5194:14 90 : crimes 10 cup 33 cucsutcusstoomtmomcustom 62:11 67 16,19 : 16,19 25 87:16 20 97 18,22 103 1,5 104 105 107 2,20 109 12,18 116 : cut 25:12 13,14 60:12 89:24 cuts 17:17:2 22 cutting 28:16 61:13 7,16 : 7,16 79 : data 68 date 6 14 30 34:16 6,19 6,19 42:15 44:21 1,17 75 108 dated 7:19 32:11 12,13 24 73:15 17 74:11 dates 23 65:24 65:24 daughter 61:23 1,4 65:23 daughter's 62:21 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index Davies..distributors Davies 16:17 17 18:25 21 21,24 21,24 91 98 Davies 64:24 delivered 24:20 delivery 99 deny 5 dep 101 80 94:16 deposition 2 25:22 44:19 48:22 48:22 6,15 63:24 76 differently 19:24 dine 54:13 dipdip 69:25 69:25 71:21 100 day 13:23 department 87:23 89 Dipadavoa 30 : 55 50 : 58 52:20 58:23 23,25 describe dipped 46 27:22 68:21 days 5,8 deal 39 67 113 dealing 26:21 decade 19 Deceased 96 decker 23 declined 44 declining 43:24 defendant 18,24 defendants 7:17 3,4 1 delete 24:24 96 97:18 98:23 98:23 16,25 8,11 15,21,23 24 101 17 102 10,13 7,11 16,19 11: 3 departments 28:19 29 34:12 92:11 98:24 102 depended 25 47:19 103 depending 6,23 describing 10: 8 design 82:11 designated 89:22 designed 10: 3 108 detailed 26 details 91:10 determining determining Dexter 6:17 diameter 76:23 died 61:23 65 didpipipnpging 21,24 28 45:17 47:25 48 68:21 72 83 85 : 84:23 10,13 14 7,8 99:24 14,23 101 : discretion 55:15 55:15 discussed : disintegrated 33:12 dismiss 1 distributors 42:12 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index doctor..end doctor 62 document 33:20 5,24 3,21 68 75 77 6,61,1 11 documents 6,25 67:16 73 dollars 37:15 86:22 87:18 drum 69 drums drums 68:10 dry 17:23 25:19 14,15 14,15 , 24 27 15 57:18 13,14 drying 8,15 27 28 8 45:21 E g 37 7:20 E.C.H. earlier earlier 73 : 57 : early 32:22 48 53:20 87:87:24 24 easier 54:21 42:20 7,17 83:19 84:15 84:15 3,8,17 Eggert's 51 53 eighth eighth 23 18:12 25 30:23 40:11 58 either 19:19 door 15:18 double 23 downsizing 43:23 53 Drayton 6:23 7:19 8 50:15 17,21 6,7,10 101 : duly 7:10 dumped 92:19 East 47 ebony 18:18 20 36:13 60:24 Ed 18:25 18:25 22:10 elasticity 47:22 electric 59:24 59:24 111 elevator : dried 27 131,31,414 101 drill 17 60 99 drilling 40:14 drive drive 6 111 dridvern iven 101 dropped dust 37:15 18,19 54:14 555,9 5,9 112 dusty 54:19 duties duties 17:14 duty 47:13 14 : 2,3 3,12,16 1,4,5 1,4,5 42:20 7,17 83:19 84:15 91 8,17 99 edge 7,8 88:24 89:14 90 Eggert 37 5,20 38 12,16 1,4,5 elevators 5,6,7 emotions 41 employee 58:12 employees 15:20 57 empty 54:14 end 26:25 26:25 32 : 22,24 1,8 61:20 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONALINTERATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index ended..failed 10,20 78:14 18,20 86 88 99:25 101 78:19 1,23 1,9,10 Eric 3 Erin 9:25 35 19,23 22,25 6,7,15 67:16 68 72:22 51:14 F facility facility 113 ended 33:11 16 46:10 52:20 62 ends 23:12 48:14 116 :60:25 enforce 55:16 enforced 55:14 56 engaged 105 England English English 67:12 23 entities 7:20 entrance 19,20 envelope 32 -- -- 80:12 et al 5 Euclid 12:19 eventually 16:18 39 5,12 Evidently 53:25 exact 35:14 94:12 EXAMINATION 96:22 102 111 116 examined examined 7:10 excerpts 44:19 excess 25:12 executives 82 exhibit 13,18 73:13 76 21,22 1,25 1,25 108 110 114 exhibits 14:13 63:25 exist 23:17 existence 8:14 existing existing existing 82 experience 11 29:11 68:18 115 Explain 36:22 explained 11:22 extra 67 14 92:19 fact 32:19 factories 42:11 42:11 factory 3,6 17:25 20:21 7,14 22:17 25:23 2,3 10,14 36:20 37:10 24,25 13,23 13,23 40:25 41 42:21 22,24 44:15 52 11,16 5,12 14,15,20 67 98 15,24 5,25 equipment 30:22 33:18 53:22 20,23 7,10 21,23 25 34 eye 56 10,14 :8 68 eyeballs fail 33:11 failed 32:25 5,7,15 19 61:17 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index fair..form fair 70:18 fall 106 falling 39 familiar 18,21 4,17 figure figure 85 : 101 figured finished 27:11 28 32:23 36:20 35 47:21 fishing 41 minute 63:16 63:16 fif x ix 17:21 17:21 family 64:18 fancy 61:14 fast 59:24 father 62 fault 19 33:15 feel 14:25 feet 25:11 12,13,14 15 Felicetta 60:21 60:21 fellow 113 felt 55:17 fiber 70 89:17 fiberglass 45:11 field 40 78:21 79 2,7 82 85:10 4,15 23 83:22 figures 37:13 37:13 fill 22:14 28:24 87 28:24 116 : 10 11 72:1172:1 filler filler 58:18 71 89:20 finally finally 45:25 83:22 87:16 8:15 8:15 finanf ce inance 5,11 5,11 find 30 46 84:18 finish 14 24:18 24:18 28:16 28:16 30 8,25 31 45 3,17,23 64 87:14 92:15 64:20 73:22 : 1,18 1,2 3,13,16 89:24 90 92:24 17,18 4,17 115 finishing 5,16 28:18 29 30:20 34:12 52:18 4,5,12 86 88:25 89:23 90 96 14,15 19 104 19 113 fire 99:20 fired 38:19 39 42:20 43:11 65:17 65:17 4,9,12 floor 28 101 Florence 61 Florida 39:22 113 folks 40:21 10: 5 follow 115 footage 17:22 17:22 footages 25 foreign 42 foreman 16:17 11 21 4,21 23,25 43:16 21,23 form 70:22 74:11 75 77:11 9,14,19 87 92 5 103 112 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index forms..grounds 115 4,7 85 77:11 forms 34:15 11,12 44 front 20:13 general 21:23 844,18 90 97:19 97:23 formulated 48 16 23:14 15,16 71:10 9,13 37 :4,6 13,15 13,15 104 10,11 10,11 , 17 113 found 45:14 15,16 15,16 15,16 foundation 115 fourth 7:23 fragments 89:16 90 10: 5 full 468 87:24 87:24 99 : 12,13 14 time time 17,21 93:20 93:20 generally 81:81:12 12 92 : 104 German 67:11 Germany goodbye 95 goods 28:22 51:12 grab 32:15 33:13 graphics graphics 77:21 Frank 64:24 Fred 13 15:25 16:16 18:25 17 4,18 24 27:12 38 12,21 24 91 98 fund 87 future 37:23 67:12 84 G 13:11 garbage 15:18 15,16 65:19 66:24 102 give 24 11 4,24 37 59 11 107 Gladys 13,14 15 Grassel 7,12,13 15:25 16 24 27:12 9,11 12 65 105 Grassel's 38:14 grinded grinded 28:16 28:16 free 14:25 frequently 59 : friction 26:20 gas 28:12 99:20 gather 104 gave 95 21 8:10 goal 51:14 Gonzales 113 good good 37 grinding 51:17 grinds 33 ground 14,19 Friday 56:22 friends gear 848 87:22 geared 19:17 19,23 10,13 66:22 74 11,22 108 grounds 9:11 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index grow..Hughes 33 hand 15:10 hear 79:10 hired 11:10 grow 10:16 guess 33:16 40 51:16 63:12 81 106 50:25 57:10 59:11 59:11 76 : handed 106 20,22 114 heard 20:10 36:24 96 114 12 20 65 hiring 23 11 hit 113 guessing 104 hanging 34:11 heavier 79 heavy 26:22 hold 76:19 79:23 guidance 16:16 happen 18 25 47:13 57 59 75 holding 78:24 guy 60:14 H happened 17:14 32:21 heavy 17:17 22,24 hole 22 92:18 hair 66:18 haihray iry 45:45:12 12 half 25:11 25:11 103 109 inch 4,13,14 25:13 32:25 32:25 33 : 61 106 110 Hamilton 6:17 7 14:13 25:20 26 92 23,25 102 112 116 38:21 18,19 happening 2,14 hard 35:13 47:20 47:20 100 : HD 35 74:16 74:16 WOVEN 74:13 74:13 head 21:11 37 38:24 40:16 : 7,22 43:16 61:12 14,23 14,23 65:13 112 14,16 8,20 71:12 71:12 4,12 77 19,20 85:25 115 height 112 home 32 1,16,22 112 . hope hour 62:14 63:15 hours 28:11 50 111 held 46:10 how's 50 69 Hughes 6:15 Helen 5959:1:9 19 59:19 helped 67 0 15:22 high 57:22 21,25 21,25 5 5 15 21,23 14,212 4,22 15 26 10,11 34 higher 44 highlighted 51 58:11 hire 12 46:21 46:21 20,24 52:10 63:14 71 64 10,16 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index humidification..judge 22 87:11 94 96:11 3,6 112 5,23 humidification 37:12 53:24 hung 32 Huseby 6:10 I individual 24:11 industrial 81 109 inform 108 information 25:25 26 64:16 1047 14,22 108 4 interrupted 50:16 interruption 52 interview 13 interviewed 13 15:25 introduce 12,22 jail 9:20 James 113 Jamie 9 janitor 11 Jersey 7 14 10:17 95:20 Jetta 95:10 job 10 6,11,24 39 43:15 Identification 7:14 14:21 15 22,24 34 46:20 50:23 64 106 immediately 16 13,22 informed 105 ingredients 8,12 initial 104 initially 31 100 inventory 50 51:12 53:14 99 13,19 invoices 3,6,12 17 involved 16:12 38:25 88:21 111 jobbed 21:13 jobs 11 Joey 44 65:20 John 6:15 8,15,20 1 60:10 impossible 89 injuries 55:13 8,22 14,17 83:24 113 inch 18:12 23 30:23 40:11 58 11,17 18,19 ink 76:11 17,18 inked 77:19 inside 58 61:15 64:17 13,14 104 116 Josephine 96 .jot 64 Jr 14,15 13,14 110 incident 20,24 incorrect 24,25 15,23 25 9,13 inspection 4,10 56 International itchy 45:12 J u 11,12 40:18 43 45:18 64:13 65 85 113 judge 25:25 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index juice..levels juice 101 55:21 56 lacking 39 leave 43 July 1,3 64:10 jumbo 18 11 6,7 16 25:10 25:10 57:24 103 116 Junior 59:22 60 64:14 10,12 23,25 knowledge 78:12 78:12 82 : 93:15 95:19 96 114 84:23 Lanz 57 larger 6,9,10 largest 103 . 23 late 10:25 40:23 112 leaving 63:10 63:10 Lecki 3 : 9,13,15 25 14:20 15 21,23 25 46:19 jury 76:19 Justice 12,16 jute 18:18 8,11,15 K Kevlar 13,17 18 84:19 116 : kids 66:17 kind 15 17:14 23:20 34:19 35:12 36 78:17 kinds 22 42 kits 80 knew 11:20 14 37:14 47 , 54 Korber 7:21 23 8:10 11,12 Korea 86:23 Kowal 61 65:12 82:24 105 106 lathes 99 law 37:12 24,25 64 96:24 102 : 10: 7 11: 6 L laws 37:11 u 61:11 52:24 86:11 106 k 4,25 label 101 lawyer lawyer 33:17 lawyers 96:14 labels 78 101 Lacarruba 61:11 62:22 62:22 63 : 96 99:11 laxed 56 lead 16:17 43:22 learn learn 17:17:2 22 59 left 36:20 63 36:20 :9 66:21 92:19 112 length 9 90 lengths 27:12 14,15 lesser 81 letter 7:18 25 16,17 Lacarrubba 33 47 lack 38:22 39 83 2,3 17:17 17:17 59 : 61 98:11 learning 5,6 5,6 level 28 6,7 levels 15,18 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index liability..looms 57:22 10,18 live 5 looked 67 liability 81:23 39:21 12 76:13 light light 47:14 light 24,25 lighter 79 lighter lighter 80:13 Lindenbaum 8 lining 24,25 17:18 18 19:13 20:15 20:15 22,24 24 29:10 6,14 23,25 4,10 11,12,15 22,24 18,20 45:23 4,13 67 68:15 6,8,20 71:12 72:20 18,21 3,13 4,13,23 77:22 15,25 92:21 93:11 93:11 94:25 100 106 107 10 8 110 : 115 linings 61:16 77:25 78 7,16 106 4,20 109 10,20 116 linseed 68:11 14,19 liquidate liquidate 30:18 liquidated liquidated 30:24 86 liquidating 7,16,21 list list 110 listed 4 34:20 36 lists 57 lived 16 39:23 lives 62:25 LLC 6:20 8:13 LLLC llooaad d 7:23 20:12 20:12 located 12:22 20:19 9:13 locations 12:25 lock 80 locker 112 logo 74:21 19,21 23 76 10,16,20 12,15 logo 76:12 76:12 long 8 9:15 16:19 38:16 43 48 49:20 63 longer 8:13 loom 18 , 10,11,13 14,15,23 4,8,11 22:14 6,7,16 7,11 7,9,15 16,17 29:25 47 10,11 17,18,22 2,6,9 12,15 24,25 58 21,23 24 60 22,24 61 70:20 7,17 72 89:15 14,18 21,23 91 104 6,17 looms 17:18 2,21 20:12 21:16 22:22 1,5 25:14 26:12 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index lot..mark 30:21 45 49 51:15 52:18 53:12 59:22 67 69:21 20,24 91 92 99:17 100 111 112 lot 37:13 3,4,8 45:22 45:22 54:14 58 15,24 25 86 87:13 112 114 10,16 lottery 113 low 62 Ls 13:11 lubrication 69 lunch 66 lung 61:20 13,24 25 23:13 26:23 30 32 45 2,13 15,16 15,16 15,21 59 61:19 16,20 89 10,11 12 1,4 112 8,11 machinery 8,11 56:24 67:10 78:20 machines 17:17 46 47:18 58:17 4,12 86 88 machinist 21:11 made 16 19:12 25:12 30 32 71 92:11 main 23:23 25:22 40 50:18 59:22 60:14 major 20:20 55:11 67:13 116 majority 70:19 make 17:21 5,8 15,24 12,14 24:13 26:21 30:22 44:15 45 12,23 , 19,21 19,21 59:11 72:19 73 82:18 83:23 84 85 90:18 97:19 100 103 104 114 37:22 43:21 44 45 71:12 73:20 82:15 85:24 102 4,9 108 109 115 man 10 101 manager 4,6 38 13,15 42:17 65:21 managers 32 mandatory 55:23 1,3 manufacture 94:25 manufacturing 6:18 24 26 53 96 Marie 22 62:21 M machine 20,21 18 104 4,17,22 107 109 116 making 19:15 : 6,13 34:23 15,24 mark 14:11 13,15 13,1557:14 76 : Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index marked..month marked 7:14 18 14:21 15 25:23 22,24 34 46:20 50:23 57:17 64 106 107 market 78:15 81:24 23,25 30 45 52:17 53 60:15 68 84 86 89:14 19,23 19,23 24 101 103 108 materials meant 45:22 58 69:16 meantime 18:24 measurements 57 mechanically 17:21 meet 13:17 39:19 mess 56:25 58 messed 32:17 messy 32:13 met 11:21 40:18 42:13 4,7 65:22 metal 67 marketed 82 marriage 62:23 married 9:22 10 62:22 65:23 85:15 mask 55:14 15,22 masks 6,9 massive 11,18 60:24 60:24 22:19 22:19 58:17 98 99 Matik 8:19 3 matter 16:14 58 16:14 : MDL875 5 meaning 23:13 23:13 24:23 24:23 28:19 37:18 37:18 39 : 45 52 6,24 meeting 83:21 84 meetings 84:12 84:12 member 64:18 105 memo 53 107 108 memory 47 14 64 65:24 105 106 mid 66 86:17 middle 30:19 99:15 Mike 17 ; 65 83:19 95:12 million 37:14 mine 16 99 minimum 52 minute minute 66:16 mixed 18:19 matched 32:17 material 17:19 18:18 19:21 23:15 28:22 53 54:15 60:25 13,16 67 90 99:22 11,17 106 means 30:20 30:20 men 11:23 mentioned 20:18 46:22 66:23 76 114 mesothmesoethellioima oma 78 19:25 mixture mixture 46:11 moment 83 money 37:13 37:13 116 month 14 24:10 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index morning..O'connor morning 24 12:20 88:21 North 7:22 Moskowitz 6:10 mother 62:11 newer 45 48:20 nice 54:21 3,8,17 19,20 90 99 104 12,13 note 26 noted 31:20 move 42:18 95:19 moving 45 MR.SMITH 116 : MSDS 14 68 musty 66:16 N nail 84:21 named 41:15 61:11 : names 37 57:11 necessarily 98:16 98:16 nickname 41:12 night 9:20 nil 52 asbestos 13,16 17 20 30:17 30:17 36:25 39 44:22 3,10,20 4,25 17,20 10,19 13,17 50 51:20 52:15 55:17 61:18 61:18 3,4 12,20 25 2,6 1,6,16 5,9,16 107 3,10 20 109 1,20 13,24 115 116 union 64:11 Nonasbestos 50:11 nonflex 35:18 nonwoven 110 Norfab 20 3 24:16 24:16 : 1,2 83:15 notes 14 8,23 19:10 3,7 96:13 November 51:16 nowadays 94:25 number 2,5 18:21 4,5 11,12 14,15 34 60 63:20 72 97 108 numbers 32:17 32:17 69:13 numerous 21:10 27 15,20 24:10 22,23 15,20 50 : 65:15 65:15 80 : nephew Newark 64:24 11 17,18 20,24 82:16 4,: 7,22 2,14,25 4,8 10,14 17 : 87 21,25 113 ametex 113 normal 50 : 29 99 : Norristown 102 113 2,11 nuts 54:12 80 NWPA 37:11 O'connor 6:18 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index oath..paid oath 12 2,4 84:22 overwhelming Objection 15,22 114 70:19 70:22 9,14,19 87 92 18,21 4,17 oils 68:11 orders 22:11 24:18 27:23 owner 13:14 20 3,4 38:15 93:23 112 115 occasion 32:18 94:14 operation operation 21 33 47 114 operations 28:17 40 42:13 46:24 50 61:13 13,16 3 73:16 39:12 13,14 owners 13 16 64:12 113 54 Ocean 10 October 65:23 85:21 offhand 47 86 107 office 10 17,21 21 10,12 31 32 65:16 65:16 67:23 102 10: 5 113 114 oil 28:24 3,5,9 13 78:21 2,7 94:19 50 8,21 8,21 65 80:23 80:23 91:14 option 55:10 orange 50:12 order 22:10 13 9,17 28:15 29:10 34:14 43:24 44:15 47:17 51:18 51:18 : 11,24 74:11 75 84 104 110 ordered 109 ordering 24 52 10: 2 3,12 OSHA 37 12,15,17 21 52:24 53:16 53:16 21 9,21,24 9,21,24 9,21,24 3,9,19 3,9,19 17,21 Ott 59:19 outlook 84 outstanding outstanding 21:14 21:14 oven 15 27 28:11 17,21 ovens 100 6,7,10 oversaw 21:11 1,2 n 19 e 113 p.m. 117 : packaging packaging packet 80 pad 33 69 76:11 77:18 pads 29 61:14 61:14 82:10 82:10 86:24 Pagano 19 91 18:25 22:10 99 pages 57 58 paid 82:23 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index paint..point paint 11 67 92:20 percent picked 11:14 15:22 pass 54:21 28:23 picture painted 15:17 21 Pam 21 41:15 64:14 65:15 65:15 67:10 passed 10,11 53:25 60:10 60:10 62 : 68:16 68:16 percentage 72 : 94 103 perimeter 76:14 80 pictures 77 piece piece 20:15 20:15 32:22 33 Paperlink 21,22,23 10,12,13 paperwork 98:20 passing 97 patent 17,18 : 17,18 93:24 94 perimeter perimeter period 49:20 98:25 98:25 2,20 46 pigs 55 place 23:19 25:21 25:21 parking 78:25 78:25 102 Patterson periodicalperiodilcally y 49:25 54:20 11: 3 6,14 16,20 15:11 2,4 20:20 38:15 39:13 4,5 51 12,13 65 67 76 : 11: 4 particles 33:10 partly 99 partners 60:14 parts 28:24 pay 43:20 43:20 payment 82:24 payroll 18,24 Peero 113 : Pemco 6:24 8:18 Penn 11:14 Pennsylvania 83:16 , 102 113 people 21:16 22,25 81:17 8413 person 60 43 personal 115 persons perspective 43 Phillips 4 phone 1 6:22 52:12 photo photo 15:11 phrase 79:10 physically 78:10 pick 4,5 75:20 plaintiffs plaintifs 7:25 6:16 7:25 plant 12:18 21 15:11 13,23 20:19 38:14 53:17 44 536,8,32 ,81,21 66 : 91 14 111 Pneumo 6:20 6:20 point 10:23 4,18 22 26:20 37:24 40:22 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index poles..production 42:25 presses 99 process 60:13 poles 112 popular 86:16 25 portion 25:22 position 9:19 16:21 21 38:14 43:15 positive pretty 14 11 18 21 27:19 10,14 2,4,6 42:12 57 58 59 25 60:14 63:12 66:19 84:21 17:24 24 25:23 26 7,22 7,10 7,10 6,16 36:22 45:17 50:15 51:11 52:20 68:21 71 64:20 12,18 69:24 70 17,20 : 17,20 7,22 76 78:21 84:18 85 1,2 3,14 88:16 18,22 possibly 13:11 23:12 104 potential 82 precise 46:14 prejudice 2 prepare 97:16 prepped prescribed 28:15 president 12,16 42:24 43 press 47 60 4,6 13,18 112 114 116 price 83:10 110 Price 83:11 pricing 83:21 prime 60 prior 11 priority 59:22 problem 85:12 99:19 problems 47:25 82:17 2,7 89:23 93:20 94:24 100 processes 100 processing 26:25 processing produced 110 product 20:24 23:23 27:11 28:23 29:17 30:10 9,16 38 45:16 46:14 49:21 52:19 53:14 : 17,18 , 25 104 106 14,21 108 14,15 112 114 production 22:15 29:23 31:21 8,19 39 13,19 52:24 52:24 54:15 21,23 58 59 83 84 5 87:25 103 104 5,6,15 4,11 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index productions..ran 13,14 productions pulled 101 pulls 20:13 question's Q 106 : 40 products pully 111 quantities 104 questions 91:17 23:21 29 34:20 36 47:11 50:18 79:24 87 97 103 promoting 82 promotional promotional 76 Pronounced 13:12 Pronounced properly 45:21 46:17 48 58 101 proprietary 25:24 Prosecutor's 10 protect 92 protpre oteccttioin on purpose 11: 2 purposes 26 35:23 70:16 70:16 push 51:13 pushed 30:25 put 7:16 28:11 29 30:14 37:1327:12 43:25 440 0 8 48:16 52:23 75:21 76:24 77:25 78:10 78:10 22,25 80:19 82:10 88:20 89:13 90 quarter : 12,19 110 quarter quarter 4,7,14 4,7,14 4,7,14 , 15,23 5,9 3,14 31:10 34:22 10,11 13 7,8 13,25 47 20,23 3,4,7 9,13,16 72:17 74:13 75 81 15,23 106 109 110 12,15 98 102 110 111 quick 9 11 quote 88 R d 61:16 w 11:17 rack 11 101 6 racks 4,6 raise 42:13 43:25 44 Ralph 57 ran 17:20 11,12 13,14 23 25:10 56 68 provided 107 publicly 93:17 pull pull 32:19 95:15 99:20 100 : putting 93:22 67 5,7,12 25:13 14,16 question 12:14 17,20 4,19 45:13 6,8 47:18 9,23 2,9 2,9 57 58 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index randomly..release 15,16,17 21 59 15,21,24 21,22 24 5,6 57 real 9 11 66:22 recall 16 91:18 recognize 57:11 107 18,21 1,6,22 105 106 2,23 5,6,16 89:15 7,8,9 5,18 101 112 116 randomly 24:25 54 rarely 40 54 raw 17:19 19:21 20:22 52:17 53 103 104 Raybestos 95:25 Raymond 3 91 116 RBW 23:24 read 30:14 35:13 107 ready 54 2,3,23 66:13 94 95:25 9,11 8,15 112 recalled 65:25 received 7:14 14:21 33 22:11 : 34 46:20 46:20 50:23 50:23 64 97:18 103 106 receiving 11:22 15:20 21 22:16 27 29 34:13 35 64:20 73:17 82:21 82:21 8,9 99:22 104 recently 15:17 23 85:23 record 7:16 9,25 36 16,18 21 Redco 41 10 75:24 76:13 77 Reddaway 6:18 6 10:24 11 2,15 2,15 16,20 16,20 17: ,24 17,24 17:11 36 11,25 6,9 44:21 61:25 10,25 1,2 68:15 75:23 75:23 76 : 77:24 79:24 78 81:17 84:13 84:13 96:25 82 92 : 109 5,12 13,19 111 114 115 Reddaway's 97 109 refer 25 14:17 reflect 32:11 refresh 14 18:17 36:14 77:18 68 6,15 106 regulators 10,14 relates 64 relaxed 47:24 release 73:16 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index remaining..rollers remaining 3 51:11 67 reports 37 representations 7:24 responsibilities 78 7,8 102 River 9:12 14 63 remember 13 14 19:12 37 3,7 representative 6 request responsibility 16,21 22 104 responsible riveted 11,12 81 : 58:14 59:20 63 64 84 85:13 5,11 114 requested 97:23 reserving 17,20 rest 17:24 7,14 15,19 74:20 = road 18:25 40 65:14 113 repair 2 :10 33:19 98:13 repairs repairs 7,10,15 99 Repeat 81:15 rephrase 12:14 rerp eplaced laced 22:19 116 report 22 : reported 97:21 reporter 9,13 15 3 Reporting 6:11 resign resign 95:18 95:18 resigned 91:24 3,4 resin 26:13 27:25 48 69:25 23,25 72 84:24 3,20 5,20 948 948 resins 28 45:15 93:24 13 4 respirator 55:20 respirators 6,9 18,25 Restano 96 restrung 61 retire 17 12,18 retired 21:19 13,14 64:22 64:22 5,10 91 3,25 96:10 113 retirement 95:13 retiring 16:19 revealed 93:17 revenues 82:18 roll 26:24 26:24 27:1815,16 15,16 4,8 51:12 19,23 57:21 : 60:13 58 75:22 4,18,25 11,14 11,14 80:17 97:19 100 104 rolled 27 5,10 13,22 32:12 89:24 89:24 rollers 27:21 32:13 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index rolling..send rolling 24:19 47:25 rolls 17:23 22:14 24 : 27 4,8,18 28 29:10 30 68:21 73:23 : 4,22 11,14 11,14 99:23 1,3,6 13,14,2 13,14,2 18 49 10,18,20 59:12 21,23 21,23 13,: 17 112 running 43:25 46:22 46:22 runs 20:14 113 11,19 salesmen 38:24 8,22 salesperson 65:13 sample 45 9 10,24 8,15 48 : 88:23 88:23 13,18 57 Saturdays 57 scale 53 scales 43:20 scared 105 school 11 : 10:19 Scott scrap 8 67 room 3 27:17 p 112 109 samples screw 30 41:18 10,13 sad 62:13 19:16 1,4,13 secret 92 93:21 ro rope pe 18:19 18:19 18:19 70 Ross 3 roughly 10 22 84 : 38 rout routeses 87:18 Roy 60 run 16:19 19:18 22:24 22:24 24:21 45:25 46 47 15,17 15,17 20 48:10 33:13 47 49:14 salaries salaries 53:23 43:20 salary 44 sales 25 33:20 34 17,19 88 2,5,24 4,9,19 109 7,11 : 13,23 6,9 40 41 sampling 53:19 55:17 89:25 65 8,11,14 : 8,11,14 8,11,14 90:12 : : Sanroman 60:10 5,6,18 91:13 1102 0,13 10,13 17 110 saturated 57:25 58 Saturday secrets 92 section 10: 1 sell 79:24 80 86:20 3,4 110 selling 34:24 36:16 6,20 9,24 86:23 send 12 send : 7 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index sense..sized sense 86:16 separately 46 served 8:11 114 sheets 68 shift 15,18 shop 1,3 86 99 4 shore 63 30 signs 19,23 112 service 108 shifts 111 short 63:21 96:19 simply single 106 set 19:14 23:16 45 482,12 49:18 54 85 101 116 ship 81 shipment 98:18 shipments 98 shortly 95:11 95:11 show 33:20 42 44:18 50:20 67:15 68 11,12 sir 8:24 10 100 108 110 setting 45:22 setup 48:15 shipped 28:20 35:22 68:13 68:13 8,22 73:13 74 3,17,19 showed 33 111 sit 91 situated 92:10 she'll 25:25 shed 16:16 4,15 4,15 20:18 21 5,13 20,24 43:17 43:17 49:24 50 61 : 22,23 97 shipping 11:22 15:19 15:19 17:23 21 22:16 27 29 34 12 8, : 23 36 64:20 73:16 6,24 shower 66:17 showing 72:15 72:15 shown 97 14 114 shuttle 23:14 58:16 71 size 17:22 24:15 24:15 25 : 19,20 22 28:13 28:13 29:25 30 416:015,17 47:14 47:14 48 : 72:16 73 74 104 : 112 11: 5 sheet 68 14 107 22 108 97 9,21 : 2,20 shoe 112 shoes 66:21 14,18 side 70:16 sides 70:15 sign 15:14 16,22 signature : 17,18 6,13 99:14 99:14 6,9,10 109 sized 99 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 sizes 10 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index sizes..stayed 18 24:16 smell 15 66 specifically 98:17 start 7:15 14 24 9,11,13 28:19 30:25 40:10 45 48 59 60:23 71 72:20 74:12 77:11 75 78:24 1,2,4 80 88:15 99:14 103 106 108 6,10 23 skin 66:19 smelled 66 Smith 6:19 70:22 9,14,19 87 96:16 5,6 106 110 1,25 116 soak 26:25 soaked 71:23 soaking 57:21 sold 80:16 son 41:21 64:17 speculation 81:20 115 Speights 112 spell 2 13 19 spelled 11:16 spend 49:24 50 113 spending 83 spent 102 spoke 91:22 102 30 41:24 42:15 46:14 64 7,8 started 10:23 11 17:10 20:21 18 22:20 23:17 29:20 37:25 30 23,24 42 62 64:10 65:12 17,22 23 85 104 slitted 60:12 slitting 51:17 sort 26:13 27:24 29:14 40:13 spools 19:22 6,9 4,10 88:20 105 starting 61:18 87:21 slow 56:23 61:25 spouse 41:14 90:12 slowing 40:16 soup 54:12 special spun 19:24 23:13 state 9,24 10:21 35 small 28:24 29 smaller 28:19 29 46:15 47:13 53 28:17 44:16 61:15 94 specialty 28:18 60:13 squeeze 101 Sr 39:11 stamped 76:20 8,15 statement 29:15 stating 77:13 stations 101 103 specific 90 stand 74:23 stayed 32 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index staying..tape 40 59:25 112 staying strength 69 strip 48:14 9:20 21:22 supplied supplied 20 system 37:12 53:24 54 111 43:21 89:15 112 stencil 76:11 17,21 stenciled stenciled 77:25 78:10 stripped 30:24 stripping 30:21 30:21 struggling 83 supply 116 supposed 112 surface 21,25 18,20 T tag 29:18 54:16 77:13 tagged 76:17 tags 29:19 stencils stepped 37:17 stepson 41:22 Stuart 39:22 stuff 32 61:18 62 65:25 67:14 68:23 surfaces 79:21 surprise 54 swear 6:13 6:13 54:17 tail 32 taking 53:23 talk 18 62:15 stock 22:16 24:12 27 20,21 8,16 99 : stop stop 79:23 stopped 66 : 113 stopping 45:23 strand 12,15 strands 10,11 70:13 streamline 92:12 70:19 92:21 subsubmergemd erged submerged 40:12 successor 8:17 sudden 47:23 sued 62:11 suing 62 summer 21:12 21 summers superintendent 65:21 supervision supervision 21:24 supervisor supervisor swing 25 switch switch 24:24:24 24 2,3 104 114 switched 21,23 46 99:20 105 switching 45 : 86:10 86:10 sworn 7:10 Sylvester 96 synthetic synthetic 45:11 84:13 103 talked 57:18 66:10 tatlakilnkging 15:12 8,25 53 57:20 62 : talks 35:20 67:17 tall 51:18 tank 18 92:14 , 92:14 tanks 100 tape tape 2 : 20,23 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index taught..Todd taught 21 67:24 90 37:10 39 time 7 22:24 6,9,11 technican technician technician 5,7 Texas 40 113 texture 45:12 45:12 42 46:15 58:16 62:14 78:17 83 91:17 10:23 12:11 32 36:23 43:14 47:20 48 52 telling 107 temperatures 28:12 ten 9:17 21:19 11: 2 thicker 40:10 46:15 47:24 48 77 80 109 thickness thinking 26 36:24 thinner 25 30:25 31:11 , 31:11 : 20,23 48 60:23 77:10 50 : 65 : 16,19 88 89 8,21 8,21 97 98:25 7,19 2,20 5,11 tended 103 term 20:10 86:15 86:17 86:17 terms : tested 33 53:21 61:16 testified 7:10 48:22 73 : testimony 66:11 115 testing 2,13 47 54 47:19 47:1947:19 58 : 8 thicknes es thicknesses 20:17 72:14 10,13 16 110 thin 47:14 72:16 88:18 thing 27:10 37:21 40:13 55:11 56 68 : things 22 17:15 24:24 112 thinnest 60:22 three 89:15 87:15 87:15 throwing 31 52:21 thrown 10,17 tied 89:16 tiers 23 tighter 46 til til 64:19 64:19 Till 38:18 116 times 21 1,19 41 53:21 55:15 66 83 88:19 89 91:11 104 title 65 51:10 today 4 66:11 : 66:11 66:11 92 12 97 Today's Today's 6 : Todd 4 38:23 38:23 17,20 , 24 17,20 : Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL ET AL , Raymond J. Lecki on 05/17/2012 Index told..Volkswagen told..Volkswagen 64:16 trial 48 45:10 upstairs 1,12 13 83:19 20 95 told 18 16:10 37:20 48:12 62 trim 46 8,9 trimmed 89:22 trip 66:23 typical 29:10 U huh 14:24 101 user 20 80:18 V 1,24 18,20 15,16 114 15 107 114 vacuumed 101 tolerance 47:22 trucker 11:19 unbranded 12,17 variable 47:19 tolerances 37:19 47:21 . Toms 14 9:11 63 tons 87:15 top 43 67:16 total 26:20 68:22 totally 15,19 27 115 ttoouch uch 40:25 touched 23 trucking 11:13 tugboat 32:20 turn 16:21 44 58 96:13 turned 19:15 Twenty 10:10 type 16:10 16:10 18:18 15,17 46:12 48 61:15 67:10 69:15 70 77:11 uncle 11 12,13,19 understand 4 12 13 61:22 understanding 13:15 53 78:13 86 5,7,21 23 113 understood 2,3 81 uniform 112 uniforms 54:23 54:23 74:12 114 variables 79 106 varied 103 versus 4 video 21 96:18 Vince 61:11 62:12 89:25 Vincent 33 96 99:11 visit 39:25 44:11 44:11 54:23 93:21 train 44 83:23 16,19 97:22 66:21 11,12 unluona lodaedded visited 83:15 59:25 types 19:23 37:25 upper 101 Volkswagen 95:10 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY INTERNATIONAL , ET AL Raymond J. Lecki on 05/17/2012 Index waiting..work waiwatitinig ng 116 walk walk 11 : 17:13 20:25 24 49:25 54:13 64 Warren 13:18 16 64:12 4,9,10 82:19 washed 66:22 washers 80 washup 66:19 waste 52:22 115 Weber 113 WednesdayWednesday 82:23 week 22 24:10 56:21 25 1,2 65:18 65:18 82:22 31:11 81 108 wife wife 61:24 64:14 65:22 66 wife's 9:24 William 39:11 38:23 : 17,20 24 1,7 49:23 6,16 4,7,15 22 95 112 113 : Walker's 44:19 48:21 48:21 76 87:23 89 90:13 wanted 16 37:18 24,25 43:20 76:13 79:25 80 83:24 84 86:19 warning 1,1,7 7,9 ,9 1,7,9 water 100 way wayss 80:10 80:10 wear 54:22 5,8 20 wearing 55:22 69 weave 71 86 weaving 16:16 4,15 20:18 5,13 19,24 43:16 49:24 50 58:23 61 22,23 68:20 71:10 99:16 99:16 104 : 112 weeks 6,9 51:11 51:11 weigh 101 weight 24:17 101 weird 61:14 wing wing 13:10 13:10 44 winging 37 19 winter 38:19 65:17 wells 80 wet 26:16 17,19,23 27 18,22 18,22 58 : 66:16 66:16 wetter 58 white 29:17 45:12 96 104 wide 25:11 108 109 width 25:10 10: 8 wire 68:25 70:14 70:14 8,9 8,9 wires 17 69:16 withstanding 115 woman 98:10 women 21:18 24 22:22 61 98:10 word word 43:25 43:25 words 77:21 wore 53:23 67:25 25:10 work 8 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index worked..Yup worked..Yup 10,11 10 11 15:17 working 10:23 11 86 6,16 6,16,22 53 69:16 10,14 21 38:23 106 1,20 17 21:12 22:21 43 41:24 44:13 107 3,11 9,11,13 83:22 56:24 58 60 61 66:21 85 97 11,16 17 49:23 51:11 53:25 66 20 109 2,20 115 116 16,20 22 3,4 17 6,7 91:10 105 112 worked 11 14 14:10 15:21 16:20 16:20 1,6,16 45:18 47:12 49:22 57 23,24 23,24 3,4,5 78 91 99 113 11: 5 workings 47:18 48 works 47:17 52:25 62 64:24 65 113 workweek 68 : WOW 54:20 wrapped 35:21 write 15 32:16 written 66 wrong 30 33 wrote 14 2,3,4 15,16,17 : 1,2 yarns 19:23 24 37:25 45 : 51:15 51:15 84 98 99:10 year 10:20 65:13 65:13 91:16 2,7 63 wove 17:18 X years 9:17 10:10 66:18 8,9,10 17 92 4,9 4,9 111 112 113 114 worker 55 workers 5,8 6,14 6,14 2,14,16 2,14,16 2,14,16 4,13 15,23 15,23 8,20 71 12,20 25 73:23 4,12 77 85:25 Y y'all 10 yard 98 yarn 19:24 19:24 6,13 22:11 10,13 4,5,12 30:24 31 50 51:12 5,20 22,25 17,19 63 : 64:25 64:25 95:14 102 yellowish 50:11 Yup 41 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs. ALBANY , INTERNATIONAL ET AL Raymond J. Lecki on 05/17/2012 Index zinc..zinc Z zinc 19:25 1,2,3 4,9,11,12 , 17,19 2,4,5 14,24 6,8 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889