Document 3Q8X1nRzqm3Qyoamb6v0Z4wdO

' GARY AUSTIN Page 14 Page 16 | l Exhibit 2. 2 Q Okay. Pm just trying to figure out if that label 3 has been marked as an exhibit with the 8-23 letter or 4 if I need to mark it as a separate exhibit. 5 MR. VALLAS: Ms. Court Reporter, was it 6 marked-7 BY MR. VALLAS: 8 Q I guess, Mr. Austin, is a part of the 8-23-85 letter, 9 is it an attachment or an accompaniment to that 10 letter, or do you know? 11 A No. It just appears at the bottom of the letter. 12 That is a Xerox copy. 13 MR. CELBA: Charles, you want it marked. 14 MR. VALLAS: I guess, yeah. I'm just 15 trying to figure out if I've marked it or if I 16 haven't marked it. If I haven't marked it, let's 17 mark it. 18 MR. CELBA: You haven't marked it. 19 MR VALLAS: Okay. Let's mark it. Thanks. 20 (Exhibit No. 4 was marked.) 21 BY MR VALLAS: 22 Q Mr. Austin, I think that letter that you just 23 mentioned, the 8-23-85 letter, on which you were 24 copied and that we marked as an exhibit, I think it 25 mentioned-- I think it used warning labels in the 1 asbestos containing gaskets, correct? 1 2 A Yes, sir. 1 3 Q I'm just wondering, is that over all of the decades I 4 that Dana Victor was making asbestos containing 1 5 gaskets, or do you know? I 6 A No, I do not know. j 7 Q Do you know-- The one label that you are familiar 1 8 with that we've marked here, do you know the first 1 9 year that it was used, the last year that it was 1 10 used? i 11 A The label would have been used beginning in I 12 approximately January of 1985. 13 Q Okay. 1 1 14 A And would have been used until we ceased the use of 1 15 asbestos in our product. 1 16 Q Okay. It's my understanding, correct me if I'm | 17 wrong, from taking your deposition previously, that . 1 18 initially Dana would only place those warning labels I 19 on its asbestos containing gasket products at the I 20 request of the customer; is that correct? I 21 A Yes, thafs correct 22 Q Was there-- I don't remember if I've asked you this 23 question previously. Was there a point in time where 24 Dana started placing an asbestos warning label on 25 every one of its asbestos containing gasket products Page 15 Page 17 1 plural, if I'm not mistaken, did it? 1 whether or not it was requested by the customer? 2 A This is the last one we discussed? 2 A Yes, that is correct. 1 3 Q Yes, sir, Bailey and Oliver. 3 Q And when was that date? I 4 A It refers to with our asbestos warning labels. 4 A It appeared to me that it was in early 19-- well, | 5 Q Okay. Let me explore that a little bit with you. 6 I'm wondering ifyou know whether or not as of August 7 of 1985 was there-- I guess what I'm wondering, if 5 late 1985, possibly early 1986. j 6 Q And what is the- How do you know that, or why do you 1 7 think that? I 8 you know, was there one-- Was Dana-- Did Dana have 8 A I was involved in the manufacturing operation at the j 9 available to put on its products one warning label, 9 time, and part of my responsibility would have been | 10 or were there different versions of it, or do you 10 to be certain that the labels were appropriately put 11 know? 11 on the boxes. 12 A There was only one warning label that went on the 12 Q Is that the only manner in which asbestos warning 13 gaskets. 13 labels accompanied Dana Victor*s asbestos containing 14 Q And that's the one that we have a copy of that it's 14 gaskets, meaning on the boxes? Was there ever- And 15 kind of illegible; is that right? 15 the question is was there any other type ofpackage 16 A Yes, sir, thafs correct. 16 insert or ever any other type ofwarning label on the 17 Q Okay. When you say there was only one warning label 17 product itself that you're aware of on the boxes? 18 that went on the gasket, is that at any time to your 18 A Not that I am aware of. 19 knowledge that Dana Victor was making asbestos 19 Q Okay. What is the next item that you have with you? 20 containing gaskets? Is there only one that you're 20 A I have a copy ofa testimony of a Dr. William 21 aware of over those decades? 21 Longeau. 22 A I'm sorry, Mr. Valias, I don't understand your 22 Q Okay. 23 question. 23 A In a Verta Sutton and P.D. Sutton versus, I believe 24 Q Okay. It was a poor question, sorry. You mentioned 24 ifs Acands, A-C-A-N-D-S, Incorporated. | 25 there was one asbestos warning label that went on the 25 Q Okay. Have you read that deposition? j Henjum Goucher Reporting Services 1-888-656-DEPO 5 (Pages 14 to 17)