Document 4vJX2NMMvmBNXB4oEbyKak54e

278 1 Sayers 2 Q. When specifically, if you recall, did 3 you discard the documents that you no longer have 4 that were in your home? 5 A. Probably a couple decades ago. 6 Q. Did you indicate on direct examination 7 that chrysotile was identical to talc? 8 A. Chemically they are identical. They are 9 a magnesium luminosilicate. 10 Q. Do you work with talc now? 11 A. No, not at all. 12 Q. Are you familiar with any ofthe -13 strike that. 14 Are you familiar with applications to 15 which Calidria was put other than paper 16 manufacturing? 17 A. Yes. 18 Q. Did you ever become aware of Calidria 19 being used as a product in any rust proofing or car 20 body sealing products? 21 A. Yes, 1 do recall an under seal 22 application. 23 Q. Do you know whether or not Calidria was 24 used as an ingredient in a commercially available 25 under seal application? 280 1 Sayers 2 A. Yes, yes. 3 Q. Fair enough. 4 Do you know what visvestos is. 5 V-l-S-V-E-S-T-O-S? 6 A. No. 7 Q. Do you know what super visvestos is? 8 A. No, never heard it. 9 Q. I'm referring to your report. 1 think . 10 it's the second paragraph, if I remember correctly. 11 It's on paragraph 1, which is on page 4, 12 Mr. Sayers. 13 A. Yes. 14 Q. Third paragraph down says, "Carbide's 15 replies have been based upon the two communications 16 sent from New York office on March 22nd, `66, and 17 October 7th of'66." 18 A. Yes. 19 Q. Have you ever seen either of those 20 documents? 21 A. I've seen the former, the first one. 22 Q. That is, the March? 23 A. 1 saw both of them when 1 wrote the 24 report, but lately I've only seen the first. 25 Q. Do you know what the October 7th, 1966, 279 1 Sayers 2 A. I'm not sure whether it was commercial. 3 Q. Tell me what it is that you know about 4 that. 5 A. There were some experiments in the early 6 days where under seals were thickened by the 7 thixotropic property of asbestos. 8 Q. How is it that you know that? 9 A. I'm not sure, to be honest with you. 10 Q. And where were the experiments 11 conducted? 12 A. I'm not too sure of that either. 13 Q. Do you know if they were conducted in 14 the United States as opposed to Europe? 15 A. 1 couldn't be categoric. 16 Q. Do you know whether or not the under 17 seal that you just referred to was -- if one of the 18 purposes of it was a rust-proofing product? 19 A. An under seal is a rust-prevention 20 product. Rust proofing to an English person means 21 something different. 22 Q. Just generally, was part of the purpose 23 of it to inhibit -- 24 A. To prevent. 25 Q. - production of rust? 281 1 Sayers 2 communication from the New York office said, by 3 chance? 4 A. Not specifically, no. 5 Q. Do you know what it said generally? 6 A. No. 7 Q. Do you know who the author was? 8 A. No. 9 Q. Do you know who the recipient was? 10 A. No. 11 Q. You seem to indicate you know something 12 about the aerodynamic flow of fiber or particles. 13 At least that's the impression 1 got. Do you 14 profess to have some knowledge of the aerodynamic 15 properties of either fiber or particles? 16 A. Only from what 1 have read at the time. 17 Q. When you say "only to what 1 have read," 18 are you referring to only what you had read prior 19 to doing your report? 20 A. That is right. 21 Q. Have you learned anything about the 22 aerodynamic properties of fibers or particles since 23 1967? 24 A. No, 1 haven't. 25 Q. Do you know whether or not -- what SPHERION DEPOSITION SERVICES (212)490-3430 71 (Pages 278 to 281)