Document 7nvBva1xXjr48O0gVNvXywre

Page 296 1 expected to have the most grinding, it's again Facility 2 G which I think is actually almost the same report. So 3 not a lot of grinding that I can document during this 4 time period. 5 Q Was there grinding occurring -- I'm sorry, 6 this is the wrong questions. Let me start out with, 7 which of the time-weighted average samples that form 8 part of the basis of your average time-weighted average 9 in your 2003 paper involve grinding? 10 A You can't tell because the descriptions of 11 these workers is such that I have to infer it's part of 12 their daily practice, even though I know during this 13 time period grinding was decreasing. As you know from 14 the discussion I mentioned this. I can't tell you 15 which employees when sampled with involved in grinding 16 and which were not. 17 Q How many of the time-weighted average samples 18 included in the time-weighted average samples that 19 formed your average occurred during a time when there 20 was substantial grinding? 21 A Well, I don't want to say substantial grinding. 22 I just want to say during the era collected -- 23 Q Okay. 24 A -- there was grinding occurring. I'm not going 25 to say it was substantial during that era. ESQUIRE DEPOSITION SERVICES (415) 288-4280 !