Document 99egQvJvVLg96ez2L7rKm23D5

FILE NAME Eaton EAT DATE 0000 DOC EAT005 DOCUMENT DESCRIPTION Notes from J. Ruckdeschel EATON Date 2008_09_08 fromfrom J. Ruckderchel Ruckderchel Did Eaton Warn Its Customers And End Users Sworn Statement Deposition Kolasinski Witness Hobbie Claim Q Sir would you agree with me based on your prior testimony that Eaton never provided any warnings with its brakes concerning the potential health hazards of asbestos OBJECTION A I'd say yes they ever did I don't believe 232 20-233 20-233 Q And Mr. Hobbie would you would you agree with me that if warnings on the dangers asbestos were placed on brake linings that were purchased by Eaton for use in their products it would be reasonable to expect Eaton to pass those warnings on to its customers OBJECTION A I guess it would be reasonable idea 245 - 246 2010_09_08 Deposition Bankhead Hobbie Eaton shipped its asbestos- containing as part ofaxle assemblies in totes returnable metal boxes or on pallets - No asbestos warnings on the packaging 155- 156 2011_05_11 Deposition Stillman Hobbie In the 1980s Eaton warned in its manuals not to blow dust out of its brake drums with compressed air because of asbestos hazards 189 - 189 Eaton warned in the mid- 1980s because of the issue of asbestos and what OSHA had to say about it and those types of things 191 Eaton's warnings were limited to manuals 191 - 191 The 1980s warnings did not warn of the risk of death or the risk of cancer 274 4274 4274 | The warning in the manual was the only warning ever given by Eaton 274- 275 Hobbie testified that he has never seen a warning on a box and that there are no Eaton documents to indicate that a warning was placed on a box 4-4-6 62 4-2 62 Eaton did not put a warning label on itsbrake products 2017_11_15 Deposition Crowe Hobbie 47 47 Eaton placed a caution statement in service manuals 47:10 - 47:12 The caution went into the service manuals in 1982 65:21 - 65:24 Were there any warnings put on the boxes of Eaton replacement brakes There were a - a eight and half by eleven sheet with that same warning stamped or printed into the center of that sheet placed inside the box with certain brake shoes lining shoe and lining assemblies 171 171 When did this start to happen It was in the seventies I don't have a firm handle on that 171 - 171 Eaton claims it placed an 8.5 x 11 sheet of paper with an asbestos warning in each box of replacement c brake shoes - it never placed a sticker on the boxes of a brake shoes because Sticker could have fallen off / Sheet of paper inside the box as long as the box retained its seal | 2018_12_10 2005 ! Interrogatories Fisher Hobbie - 2018_12_11 Deposition testimony of Eaton Rep Miles L. Tuttle Franklin v General Motors Cor Anderson 179 179 When did Eaton label it's c products as being c products A " think it was 1982 was the first time that we published a warning in one of our manuals 157 - 157 Warnings on boxes Interrogatory No. 9 Identify all Products Eaton Supplied to Entities in Question from 1958 through 1978 Interrogatory No. 10 Identify all products supplied to Equipment Manufacturers Interrogatory No. 11 When and why asbestos was used Interrogatory No. 12 Any impediments preventing warnings Answer " Beginning in or about 1983 boxes containing brake shoes with containing linings included a warning label that included warnings relating - to asbestos Q And tell me specifically what warnings Eaton Corporation gave relating to asbestos and tell me the best you can recall when that first occurred Cir Ct Kentucky Case 04 00274 2011_02_28 | DeBlase Verified by , Interrogatories | Hobbie | California In Re Complex Asbestos | ' Litigation Case No 828684 - Interrogatory | No. 57 and Eaton's verified Answer A It occurred in the early | eighties and we put a cautionary warning in our service manuals for technicians who work on the product to - - not to blow the dust in their face when they blow it out with air and not to use air if they could find other means 26 - 26 Q [ The language or words that Eaton Corporation used to warn the public about asbestos did they do that Did Eaton actually put a warning label on some containicon ntaigning products A NO 24:22 - 25 Q Okay So you worked with warnings but you didn't put them on any products A That's correct 25- 25 a Beginning in the mid 1980s Eaton included warnings in its products advising individuals not to use compressed air to blow out dust from the interior of brake drums because of the potential harmful effect of the inhalation of asbestos dust 2008_08_03 thereto Kolasinski Matter Verified by Hobbie Eaton Corporation's Responses to Plaintiffs Interrogatories Interrogatory [ THIS IS A WARNING TO OTHERS Did Eaton ever publish or distribute any books manuals pamphlets brochures or other writings which indicated that exposure to any of the that sic asbestos in any brake shoes or linings incorporated as component parts in its axles wheel assemblies or replacement brake shoes or linings was potentially dangerous to human health Objections omitted Eaton is unaware ofany causal connection between the use of its axles or brake assemblies and any disease process Further answering Eaton is aware that during the 1970s and 1980s OSHA considered and published certain standards regarding airborne asbestos dust and that those standards were based on the possible connection between the inhalation of certain types of airborne asbestos dust at certain levels and the potential for an increased risk ofcertain types of adverse health effects Eaton further believed that based on its own experience that threshold limit values of : asbestos dust from brake linings were not exceeded and that there was no asbestos related health hazards related to its axle or brake products i NONE IDENTIFIED BY EATON IN ITS RESPONSE 2009_10_28 Larry Williams v Advance Auto Parts Inc Cir Ct 3rd Jud Cir Madison Co. Ill Case 537 Interrogatory No. 68 and Eaton's verified Answer thereto Verified by Hobbie Rogg 68 If Defendant any predecessor or related company obtained raw asbestos and asbestos containing material used by Defendant any predecessor or related company to manufacture or process any product listed in response to Interrogatory 16 friction linings manufactured by third parties unrelated to Eaton ] did such raw asbestos and asbestos containing material contain any warning of any type - - either affixed to the container contained within the container or affixed to the product itself- - when received by the Defendant any predecessor or related company ANSWER OBJECTION Vague Without in any way waiving this objection and based on the information currently available to Eaton no Compare this answer to Eaton's internal training program from 1986 in which Eaton tells its employees that incoming a brakes are coming into Eaton's facilities with a label SEE 2008_09_08 Kolasinski transcript Ex 28 to tx that states Certain types of brake lining used in this facility in the manufacture of brake shoes contain asbestos The 1 containerisn which these brake linings are received from suppliers have asbestos warning labels affixied Other types of brake linings used in this facility do not contain asbestos the containers in which these linings are received do not have asbestos warning | labels affixed Date 2008_09_08 When Did Eaton Know About Dangers Source Deposition Kolasinski Witness _ Hobbie Claim Q ] Would you agree with me ; then that that Eaton as member of the friction industry would have been aware of the potential health hazards of asbestos sometime in the mid 70s 2011_02_28 Verification Date 2011_02_27 | DeBlase Interrogatories California In Re Complex Asbestos Verified by | Hobbie Litigation Case No 82684 Interogatory Interogatory No. 33 and Eaton's verified Answer 2011_02_28 Verification Date 2011_02_27 theret | DeBl DeBl : Interatories Interatories Calif nia In Re Complex | Asbes s Verified by | Hobbie Litigation Litigation Case OBJECTION A I'd say at a low level yes as a developing issue Early 1970s OSHA published standards regarding asbestos based on possible connection between inhalation ofcertain types and amounts of airborne asbestos dust at certain levels and the potential for an increased risk ofcertain types of adverse health effects | | b Eaton may have been a member of the National Safety | Council from time to time | | during the 1960s through the | 1970s and 1980s 2008_10_28 No 878684878684 Inter gatory No. 1 and Eaton verified Answer thereto Larry Alliams Ad ce utots utots Inc ir Jud ir f.dison P. 19-1- 19-1- Case nie gatory 0.7 . d ; aton erified Answ Verified by Hobbie State the date on which any official of Defendant or any predecessor or any related company first had knowledge notice information or understanding that exposure to asbestos would could or might cause each of the following A. Pleural disease B. Asbestosis C. Mesothelioma D. Lung Cancer E. Any other : forms of cancer Answer Eaton is unaware of any causal connection between the use of brake assemblies axles or transmissions and any disease process Eaton is not able to determine when any of its employees first learned of an alleged relationship between any type of asbestos and exposure and any particular type ofdisease Further answering Eaton is aware that during the 1970s and 1980s OSHA considered and published certain standards regarding airborne asbestos dust and that those standards were based on the possible connection between the inhalation of certain types of airborne asbestos dust at certain levels and the potential for an increased risk of certain types of adverse health effects Eaton further believed that based on its own experience that threshold limit values of asbestos dust from brake linings axles and transmissions were not exceeded and that there was no asbestos related health hazards related to its transmission axle or brake : products ' CLAIMING NO KNOWLEDGE | despite OSHA Eaton believes that Roger Hobbie has the broadest based knowledge of any one individual concerning Enton's incorporation of containing friction linings into its brake assemblies February 28 2011 Interrogatory No. 10 and Response in California Case 828684 In Re Complex Asb Litigation Roger Hobbie is the person most knowledgeable about Eaton's A product and their packaging and witten witten instructions wrapping or printed insert which was or in placed in the contam ., package or carton with each such product and the inclusive period of time during which each instruction wrapping or printed insert was placed in the conta er package or carton February 28 2011 Interrogatory No. 43 and Response in California Case 828684 In Re Complex Asb Litigation