Document 9J6kNXL4abm2zM8jEJVJ6Xm7p

IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS JANE GUDMUNDSON, Individually and as Special Administrator of ) the Estate of HARVEY G. ) GUDMUNDSON, Deceased, ) ) No. 03-L-538 Plaintiff, ) ) vs. ) ) JOHN CRANE, INC., et al., ) ) Defendants. ) ) VIDEOTAPED EVIDENCE DEPOSITION OF ROLAND DOKTOR Taken on behalf of Plaintiff January 18, 2005 Certify Question: Page 114, Line 13 Sarah L. Paszkiewicz, CSR/RMR/CCR Certified Shorthand Reporter License No. 084-004225 C.C.R. No. 801 Page 2 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 OF EXHIBITS Page 3 Page Exhibit 15 -- Drawing 147 Exhibit 16 -- Order 152 Exhibit 17 -- Drawing 155 Exhibit 18 -- Naval Auxiliary Machinery 163 (The original exhibits were attached to the transcript that was sent to the Wise & Julian Law Firm.) Page 4 1 INDEX OF EXAMINATION 2 3 Page 4 Examination by Mr. Iola 10 5 6 7 8 INDEX OF EXHIBITS 9 10 Page 11 Exhibit 1 -- Notice of Deposition 8 12 Exhibit 2 -- Notice of Deposition 8 13 Exhibit 3 -- Letter 21 14 Exhibit 4 -- Military Specification 58 15 Exhibit 5 -- Order 69 16 Exhibit 6 -- Drawing 17 Exhibit 7 -- Order 79 80 18 Exhibit 8 -- Drawing 87 19 Exhibit 9 -- Drawing 96 20 Exhibit 10 -- Instructions for Operation 21 and Maintenance 119 22 Exhibit 11 -- Order 125 23 Exhibit 12 -- Drawing 133 24 Exhibit 13 -- Drawing 136 25 Exhibit 14 -- Order 144 1 IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT 2 MADISON COUNTY, ILLINOIS 3 4 JANE GUDMUNDSON, Individually ) 5 and as Special Administrator of ) the Estate of HARVEY G. ) 6 GUDMUNDSON, Deceased, ) ) No. 03-L-538 7 Plaintiff, ) 8 vs. ) ) ) 9 JOHN CRANE, INC., et al., ) ) 10 Defendants. ) 11 12 VIDEOTAPED EVIDENCE DEPOSITION OF 13 ROLAND DOKTOR, produced, sworn, and examined on behalf of Plaintiff, January 18, 2005, between 14 the hours of eight in the forenoon and five in the afternoon of that day, at the Boston Logan 15 Airport Hilton, 85 Terminal Road, Boston, Massachusetts, before Sarah L. Paszkiewicz, 16 Registered Merit Reporter, Certified Shorthand Reporter and Notary Public. 17 18 A P P E A R A N C E S 19 The Plaintiff was represented by 20 Mr. Randall L. Iola, in association with the law firm of Wise & Julian, P.C., 3555 College Avenue, 21 Alton, IL 62002. 22 23 APPEARING TELEPHONICALLY: The Defendant, Ingersoll-Rand Company, was 24 represented by Mr. Carl McNulty, of the law firm of Burroughs, Hepler, Broom, MacDonald, Hebrank & 25 True, 103 West Vandalia, Edwardsville, IL 62025. 1 (Pages 1 to 4) 1 APPEARING TELEPHONICALLY: The Defendant, ITT Industries, Inc., was represented 2 by Mr. James Kasper, of the law firm of Gunty & McCarthy, 150 South Wacker, Suite 1025, Chicago, 3 IL 60606. 4 5 APPEARING TELEPHONICALLY: The Defendant, Viacom, Inc., was represented by 6 Ms. Beth Gori, of the law firm of Herzog Crebs, L.L.P., 515 North 6th Street, City Centre, 24th 7 Floor, St. Louis, MO 63101. 9 APPEARING TELEPHONICALLY: The Defendants, CertainTeed Corporation, and Parker 10 Hannifin Company, were represented by Mr. Jeff Bash, of the law firm of Heyl, Royster, Voelker & 11 Allen, 103 West Vandalia, Suite 100, Mark Twain Plaza II, P.O. Box 467, Edwardsville, IL 62025. 12 13 The Defendant, Warren Pumps, LLC, was 14 represented by Ms. Lisa A. LaConte, of the law firm of Heyl, Royster, Voelker & Allen, Bank One 15 Building, Suite 600, 124 S.W. Adams Street, Peoria, IL 61602. 16 17 APPEARING TELEPHONICALLY: The 18 Defendant, IMO Industries, Inc., was represented by Ms. Kristen M. Streepey, of the law firm of 19 Matushek, Nilles & Sinars, L.L.C., One North LaSalle Street, Suite 2100, Chicago, IL 60602. 20 21 APPEARING TELEPHONICALLY: The 22 Defendant, John Crane, was represented by Mr. Daniel O'Connell, of the law firm of 23 O'Connell & Associates, P.C., 645 Tollgate Road, Suite 220, Elgin, IL 60123. 24 25 Page 5 1 2 3 4 5 6 7 Page 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 7 IT IS HEREBY STIPULATED AND AGREED by and between Counsel for the Plaintiff and Counsel for the Defendants, that this deposition may be taken in shorthand by SARAH L. PASZKIEWICZ, a Registered Professional Reporter, Certified Shorthand Reporter and Notary Public, and afterwards transcribed into typewriting, and the signature of the witness is not waived by agreement of counsel and the witness. VIDEOGRAPHER: We're now recording and on the record. My name is George Libbares. I'm a certified legal video specialist. The court reporter is Sarah Paszkiewicz. We are with Pohlman Reporting Company. Our business address is One Metropolitan Square, Suite 2950, St. Louis, Missouri 63102. Today is January 18, 2005 and the time is 9:21 a.m. This is the deposition of Roland R. Doktor, in the matter of Jane Gudmundson, et al., Plaintiffs, versus John Page 8 1 The Defendant, Warren Pumps, LLC, was represented by Ms. Judith A. Perritano, of the 2 law firm of Pierce, Davis & Perritano, 10 Winthrop Square, Boston, MA 02110. 3 4 APPEARING TELEPHONICALLY: The 5 Defendant, Garlock, was represented by Ms. Alexis Weed, of the law firm of Segal, McCambridge, 6 Singer & Mahoney, Ltd., One IBM Plaza, Suite 200, Chicago, IL 60611. 7 8 Also Present: The Videographer, 9 Mr. George P. Libbares, in association with Pohlman Reporting Company, One Metropolitan 10 Square, Suite 2040, St. Louis, MO 63102. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 Crane, Inc. et al, Defendants, in the Circuit 2 Court, Third Judicial Circuit, Madison County, 3 Illinois. Civil action 03-L-538. 4 This deposition is being taken at the 5 Airport Hilton in Boston, Massachusetts on behalf 6 of the plaintiffs. The court reporter will now 7 administer the oath. 8 9 10 11 ROLAND DOKTOR, 12 of lawful age, being produced, sworn and examined 13 on the part of the Plaintiff, and after 14 responding "I Do" to the oath administered by the 15 court reporter, deposes and says: 16 17 18 19 (Whereupon, Exhibits 1 and 2 were 20 marked.) 21 VIDEOGRAPHER: Counsel, will now 22 state their appearances. 23 MR. IoLA: Randall Iola on behalf of 24 the plaintiff, Jane Gudmundson. 25 MS. LACONTE: Lisa LaConte on behalf 2 (Pages 5 to 8) POHLMAN REPORTING COMPANY 314-421-0099 Page 9 Page 11 1 of Warren Pumps. 1 A. 82 Bridges Avenue. 2 MS. PERRITANO: Judy Perritano on 2 Q. City? 3 behalf of Warren Pumps. 3 A. Warren, Massachusetts. 4 MR. IOLA: Folks on the phone. 4 Q. Zip? 5 MR. MCNULTY: Carl McNulty on behalf 5 A. 01083. 6 of Ingersoll-Rand. 6 Q. What's your date of birth, please? 7 MR. BASH: Jeff Bash on behalf of 7 A. 11/16/56. 8 CertainTeed Corporation and Parker Hannifin. 8 Q. Your residential address, please? 9 MS. STREEPEY: Kristen Streepey on 9 A. 141 Rice Corner Road, Brookfield, 10 behalf of IMO Industries, Inc. 10 Massachusetts. 11 MR. KASPER: James Kasper on behalf 11 Q. Zip? 12 of ITT Industries, Inc. 12 A. 01506. 13 MS. WEED: Alexis Weed on behalf of 13 Q. Have you ever been deposed before? 14 Garlock. 14 A. Yes. 15 MR. O'CONNELL: Daniel O'Connell on 15 Q. On how many occasions? 16 behalf of John Crane. 16 A. Two. 17 MS. GORI: Beth Gori on behalf of 17 Q. Do you recall when that was? 18 Viacom. 18 A. Not specifically. 19 MR. IOLA: Before we begin, I'd like 19 Q. I know of one deposition you gave on 20 to attach as Deposition Exhibit Number 1, 20 April 24, 2003 in a case in Washington state, 21 Plaintiff's Notice of Videotaped Evidence 21 where the deposition took place here in Boston, 22 Deposition of the representative deponent of 22 correct? 23 Warren Pumps, Incorporated. In addition, I'd 23 A. Yes. 24 like to attach as Deposition Exhibit Number 2, 24 Q. Was there another deposition, an 25 the Notice of Videotaped Evidence Deposition of 25 asbestos deposition, as well? Page 10 Page 12 1 Roland Doktor for this date and time. 1 A. There was one in California. 2 MS. LACONTE: We will put on the 2 Q. Okay. Do you recall if that was 3 record, as well that there are currently pending 3 before or after April 24, 2003? 4 a motion to quash the individual notice of Roland 4 A. It was after. 5 Doktor's deposition; as well as a motion for 5 Q. Do you recall how far after? 6 Protective Order with respect to the corporate 6 A. It was -- I believe, it was late 7 representative deposition. Both of those motions 7 summer, early fall of that same year. 8 are scheduled for hearing today. By agreement of 8 Q. Do you recall who deposed you? 9 counsel, we're going to proceed with the 9 A. No, I do not. I don't remember the 10 deposition and go ahead and allow inquiry while 10 gentleman's name. 11 the hearing is held. And we'll take up further 11 Q. Do you recall the name of the case? 12 matters, as we may need to after that hearing. 12 A. No, sir. 13 [EXAMINATION] 13 Q. Do you recall Mr. Bergman was the 14 QUESTIONS BY MR. IOLA: 14 individual that deposed you on April 24, 2003 15 Q. Sir, will you please state your full 15 here in Boston? 16 name for the record? 16 A. Yes, sir. 17 A. Roland Doktor. 17 Q. The California case deposition, did 18 Q. Do you have a middle name, please? 18 that take place here in Boston, as well? 19 A. Rudolph. 19 A. No, it was in California. 20 Q. You are presently employed, correct? 20 Q. Do you know where in California you 21 A. Yes. 21 went for that? 22 Q. Where are you employed? 22 A. Let's see. It was San Francisco. It 23 A. Warren Pumps, LLC. 23 was across the bay in Oakland. 24 Q. What is the street address for Warren 24 Q. Was it with the McClain Law Firm? 25 Pumps, LLC where you are employed, sir? 25 A. Could be, I just -- I don't remember, 3 (Pages 9 to 12) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 13 Page 15 1 sir. 2 Q. Kazan, McClain ring a bell? 3 A. No, sir. 4 Q. The Hanley, Harley Law Firm ring a 5 bell? 6 A. No, sir. 7 Q. Do you have copies of both of those 8 transcripts in your possession at your office? 9 A. Yes. 10 Q. And have you had an opportunity to 11 read and review those transcripts before you came 12 in here today? 13 A. Yes, I did. 14 Q. In addition to those transcripts, 15 have you had an opportunity to look at any other 16 documents in preparation for your testimony here 17 today? 18 A. Yes. 19 Q. Tell me, please, sir, what documents 20 you've looked at in preparation for your 21 testimony here today? 22 A. I reviewed the documents that were 23 produced at the beginning of this case. I also 24 reviewed the drawings that were in question. I 25 also reviewed Mr. Forest's deposition. 1 night, as well, that was a supplement set to the 2 original set? 3 A. Yes, sir, I did. 4 Q. So the record is correct in 5 reflecting what you reviewed, sir, your testimony 6 is you reviewed the original Bates stamped 7 documents that Warren Pumps produced in the 8 Illinois Warren Pumps litigation, correct? 9 A. Yes. 10 Q. You reviewed the additional 11 supplemental documents that were produced last 12 night that consisted of approximately 56 pages, 13 plus or minus a few pages, correct? 14 A. Yes. 15 Q. And you reviewed the drawings that 16 Warren Pumps previously produced to me that were 17 Bates stamped Warren Pumps Illinois, specific to 18 the Bausell, correct? 19 A. Yes, sir. 20 Q. Are there any other documents that 21 you reviewed in preparation for your testimony 22 here today? 23 A. The interrogatories were also 24 reviewed. 25 Q. And when you say the interrogatories, Page 14 Page 16 1 Q. And Mr. Forest you understand to be a 1 what do you mean? 2 shipmate of Mr. Gudmundson's; is that correct? 2 A. The original questions that were 3 A. Yes, sir. 3 asked in the Illinois cases. 4 Q. On what ship, sir? 4 Q. And whose interrogatories did you 5 A. The Bausell. 5 review? 6 Q. And as you sit here today, you 6 A. I don't understand. 7 understand that Mr. Gudmundson also served upon 7 Q. Very well. If at any time today you 8 the Bausell? 8 don't understand a question I ask, I would 9 A. Yes, sir. 9 appreciate it if you tell me you don't 10 Q. When you reviewed those documents 10 understand, so that I can restate or rephrase the 11 that you said were produced earlier in this 11 question. Okay? 12 litigation, were those Bates stamped numbered 12 A. Thank you. 13 documents? 13 Q. If you answer a question that I ask, 14 A. Yes, sir. 14 I'm going to assume that you fully understood the 15 Q. Do you recall what the Bates stamped 15 question and you're completely answering to the 16 numbering was on them? In other words, how many 16 best of your knowledge and ability; is that fair? 17 of them there were and what the Bates starting 17 A. Yes, sir. 18 number was and what the Bates concluding number 18 Q. Were they the interrogatory answers 19 was? 19 that Warren Pumps answered? 20 A. No, I do not. 20 A. Yes, sir. 21 Q. Do you believe they were Bates 21 Q. Okay. Did you also review 22 stamped WP-IL, meaning Warren Pumps-Illinois? 22 interrogatory answers that Mr. Gudmundson's 23 A. I do not recall. 23 family answered? 24 Q. Okay. Did you also look at a set of 24 A. Not that I'm aware of, sir. 25 documents that was recently produced to me last 25 Q. Okay. The interrogatory answers that 4 (Pages 13 to 16) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 21 Page 23 1 MR. IOLA: I don't have a copy in 1 that happens to be. 2 front of me. 2 Q. (By Mr. Iola) Mr. Doktor, where - 3 MS. LACONTE: Why don't we mark a 3 You understand what we're discussing is that you 4 copy of the letter then? 4 are the designated representative on behalf of 5 MS. PERRITANO: That's the first 5 the Warren Pumps, Incorporated to bind the 6 issue. The second issue is - 7 MR. IOLA: Let the record reflect 6 company with your testimony here today, with 7 respect to the pump products on board the USS 8 that we will mark as Deposition Exhibit Number 3, 8 Bausell that Warren Pumps had, to the best of 9 the letter from Ms. LaConte to Mr. Barry Julian, 9 your knowledge and ability, correct? 10 that's dated January 12, 2005. It consists of 10 A. Yes, sir. 11 six pages and it outlines areas within the notice 11 Q. And before we go there, I want to 12 that Mr. Doktor will be designated as the 12 cover a little bit of background with you. What 13 corporate representative of Warren Pumps, 13 is your present position at Warren Pumps? 14 Incorporated to testify; is that correct? 14 A. I'm the manager of new programs for 15 (Whereupon, Exhibit 3 was marked.) 15 the Navy. 16 Ms. PERRITANO: That is correct. The 16 Q. And you've been in that position for 17 second issue is there is a motion for Protective 17 a time now, correct? 18 Order pending. So to the extent that the notice 18 A. About three years. 19 seeks information beyond the scope of the 19 Q. Roughly around 2001? 20 Gudmundson case, and more specifically, beyond 20 A. Yes, sir. 21 the time frame that we're dealing with in 21 Q. To the present? 22 Gudmundson, Mr. Doktor is not here to testify as 22 A. Yes, sir. 23 to those issues today. So to the extent that 23 Q. In that position as manager of new 24 we're going through the notice and he says, I'm 24 programs for the Navy, what are your duties and 25 here to testify as to Category Number 1, it's 25 responsibilities, please? Page 22 Page 24 1 Category Number 1 within the time frame for 2 purposes of today's deposition. And that is 3 actually spelled out also in the January 12th 4 letter, which has been marked as Exhibit 3. 5 MR. IOLA: That's fine. And if you 6 desire, we can come back to this after the 7 hearing is held in an hour or so and we can more 8 thoroughly flush out the areas then. 9 MS. PERRITANO: Well, it might -- it 10 might make sense for time purposes - 11 MR. IOLA: Okay, let's do that. 12 MS. PERRITANO: -- to deal with the 13 drawings and the Bausell first, because I think 14 that might streamline things a little bit. 15 MR. IOLA: That's fine. We'll do it 16 that way. We'll come back to this area, sir, 17 after the Court has had an opportunity this 18 morning to hear arguments. 19 MS. PERRITANO: And I guess so we're 20 clear, whatever category in this notice deals 21 with -- with the issues of the drawings and the 22 pumps on the ship at issue, he has been 23 designated for that. 24 MR. IOLA: Okay. Very fine. 25 _______MS. PERRITANO: Whatever category 1 A. Provide all information and sales and 2 marketing for new products to the United States 3 Navy -4 Q. When you say new products - 5 A. -- from Warren Pumps. 6 Q. I'm sorry. 7 A. Complete pump units. 8 Q. When you say "new products", what do 9 you mean? 10 A. Those that would be fully 11 manufactured from scratch. 12 Q. As opposed to old products that are 13 not fully manufactured from scratch? 14 A. Well, as opposed to repairs or spare 15 parts. 16 Q. And that's somebody else's duty and 17 responsibility, correct? 18 A. Yes, sir. 19 Q. Who is that individual? 20 A. That would be Vince Ardizzone. 21 Q. Can you spell the last name please, 22 sir? 23 A. A-r-d-i-z-o-n-e, excuse me, 24 A-r-d-i-z-z-o-n-e. 25 Q. And Mr. Vince Ardizzone, what's his_____ 6 (Pages 21 to 24) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 25 Page 27 1 full title? 1 A. Ensure that all documentation and all 2 A. Aftermarket manager. 2 terms and conditions for those contracts were 3 Q. Prior to 2001, what was your position 3 met. 4 with the company, please? 4 Q. What was the position you held at 5 A. Manager of composite components. 5 Warren Pumps, prior to manager of contract 6 Q. In the position of manager of 6 administration in 1990 or '91? 7 composite components, when did you assume that 7 A. Contract administrator. 8 position? 8 Q. When did you first become a contract 9 A. 1999. 9 administrator at Warren Pumps? 10 Q. In the position of manager of 10 A. 1986. 11 composite components, what were your duties and 11 Q. Did you work continuously from 1986 12 responsibilities? 12 to 1990 or '91 as contract administrator at 13 A. Introduce and develop composites 13 Warren Pumps? 14 within the United States Navy for Warren Pumps 14 A. Yes, sir. 15 and other products. 15 Q. What were your duties and 16 Q. And when you say composites, can you 16 responsibilities as a contract administrator at 17 define that for us, please? 17 Warren Pumps from 1986 to 1990 or '91? 18 A. It's -- It's a non-metal product. 18 A. Primarily the same duties as when I 19 Q. Prior to 1999, what was your position 19 was manager. However, when I was manager, I had 20 at Warren Pumps? 20 other people reporting to me who carried out some 21 A. Sales engineer. 21 of the other functions that were required. 22 Q. When did you first assume the 22 Q. As manager, how many other people did 23 position of sales engineer at Warren Pumps? 23 you have reporting to you? 24 A. That would have been -- Let's see. 24 A. Three. 25 1995, '94. 25 Q. What was your position at Warren Page 26 Page 28 1 Q. So continuously for 1994, '95 to 1 Pumps, prior to contract administrator in 1986? 2 1999, you were sales engineer at Warren Pumps? 2 A. Sales engineer. 3 A. Yes, sir. 3 Q. When did you first become sales 4 Q. What were your duties and 4 engineer at Warren Pumps? 5 responsibilities as a sales engineer at Warren 5 A. That would have been -- That would 6 Pumps from 1994, '95 through 1999? 6 have been 1984 through '86. 7 A. Sales of pump units to major 7 Q. As sales engineer from 1984 through 8 shipyards in the U.S. Navy. 8 1986 at Warren Pumps, what were your duties and 9 Q. Prior to 1994 or '95, what was the 9 responsibilities? 10 position you held at Warren Pumps? 10 A. Provide sales and marketing for new 11 A. The contract -- Manager of contract 11 units for supply system depots. 12 administration. 12 Q. D-e-p-o-t-s, correct? 13 Q. How long did you hold the position of 13 A. Yes. That's correct. 14 manager of contract administration for Warren 14 Q. Got to be careful with that term 15 Pumps? 15 around lawyers. 16 A. Three years. 16 A. Depots, I guess, would probably be 17 Q. So did you begin sometime in 1991? 17 the better pronunciation. Depends what part of 18 A. '90 or '91, yes. 18 the country you're in. 19 Q. As manager of contract administration 19 Q. Prior to your employment at Warren 20 at Warren Pumps from 1990, '91 through 1994, what 20 Pumps as a sales engineer in 1984, what was your 21 were your duties and responsibilities? 21 position? 22 A. Administer all contracts for both 22 A. Supervisor of research and 23 commercial and Navy products. 23 development. 24 Q. When you say administration of 24 Q. How long were you supervisor of 25 contracts, what do you mean? 25 research and development for Warren Pumps? 7 (Pages 25 to 28) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 29 Page 31 1 A. Two years. 2 Q. As supervisor of research and 3 development for Warren Pumps in 1982 through 4 1984, what were your duties and responsibilities? 5 A. Supervise union employees on the 6 testing of pumps for the design department. 7 Q. Prior to 1982, what was your position 8 at Warren Pumps? 9 A. Field service engineer. 10 Q. Do you have a resume? 11 A. Yes, sir. I don't have it with me, 12 but I do. 13 Q. Okay. As field service engineer, 14 when did you assume that position? 15 A. 1978. 16 Q. As field service engineer at Warren 17 Pumps from 1978 to 1982, what were your duties 18 and responsibilities? 19 A. Supervise, troubleshoot any pump 20 issues that customers may have. 21 Q. You arrived at Warren Pumps in 1978, 22 correct? 23 A. Yes, sir. 24 Q. Prior to Warren Pumps in 1978, where 25 were you employed? 1 A. Massachusetts Maritime Academy. 2 Q. When did you arrive at Massachusetts 3 Maritime Academy? 4 A. Fall of 1974. 5 Q. How long did you remain at the 6 Massachusetts Maritime Academy beginning in the 7 fall of 1974? 8 A. Graduation in 1978. 9 Q. And immediately upon your graduation, 10 in fact, prior to your graduation, you worked in 11 some internship capacity at Warren Pumps in the 12 summer of 1977, correct? 13 A. Yes, sir. 14 Q. And then you were hired full-time at 15 Warren Pumps upon your graduation from the 16 Massachusetts Maritime Academy in 1978, correct? 17 A. Yes, sir. 18 Q. Is Warren Pumps the only real job, 19 since your graduation from college? 20 A. No, sir. 21 Q. Okay. What else have you done? 22 A. I worked as a sales engineer for 23 Hamilton Standard from April of 1985 to Decembei 24 31st of 1986. 25 MS. PERRITANO: '86 or '85? Page 30 Page 32 1 A. The summer of 1977, I was employed by 1 A. I'm sorry, '85. I'm sorry, '85. 2 Warren Pumps, as well. 2 Q. (By Mr. Iola) For a period of what 3 Q. Okay. Did you have any other 3 appears to be eight months, from April 1985 to 4 employment, prior to the summer of 1977? 4 December of 1985? 5 A. I did work part-time during the 5 A. Yes, sir. 6 summer of the year before for the school 6 Q. And what caused you to go to work for 7 department within the town of Warren. 7 Hamilton Standard during that period of time, 8 Q. You graduated from high school, 8 from April 1985 to December 1985? 9 correct? 9 A. Warren Pumps was going through a 10 A. Yes, sir. 10 leverage buyout and I just wasn't sure what my 11 Q. What year did you graduate high 11 status would be within the company, so I decided 12 school? 12 to try something different. 13 A. 1974. 13 Q. And then you came back to Warren 14 Q. And where did you graduate high 14 Pumps? 15 school? 15 A. I was offered a position after a 16 A. Quaboag Regional. 16 short period of time to come back to Warren, yes. 17 Q. Can you spell that? 17 Q. So when you left to go to Hamilton, 18 A. Q-u-a-b-o-a-g. 18 and that was sometime during the period of time 19 Q. That's located where? 19 between 1984 and 1986, were you in the position 20 A. Warren, Massachusetts. 20 of sales engineer, correct? 21 Q. Upon your graduation from Quaboag 21 A. Yes, sir. 22 High School in Warren, Massachusetts in 1974, did 22 Q. When you left to go to Hamilton, you 23 you attend college? 23 were a sales engineer at Warren Pumps, correct? 24 A. Yes, sir. 24 A. Yes, sir. 25 Q. Where did you attend college? 25 Q. When you came back on January 1, 8 (Pages 29 to 32) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 41 Page 43 1 employed? 2 A. No. 3 Q. Do you know where he is at? 4 A. He is also deceased. 5 Q. Mr. Landberg, is he still employed at 6 Warren? 7 A. No, I do not know where he is any 8 longer. 9 Q. When he left Warren, do you know 10 where he went? 11 A. No, sir, I don't. 12 Q. Mr. Colthard, is he still employed at 13 Warren? 14 A. No. 15 Q. Do you know where he is at? 16 A. He's, unfortunately, also deceased. 17 Q. Okay. 18 A. We had a bad -- a streak of bad luck, 19 I guess. 20 Q. In 1989, Warren Pumps was purchased 21 by IMO Industries, Incorporated, correct? 22 A. Yes, sir. 23 Q. Warren Pumps is currently owned by 24 IMO Industries, Incorporated, correct? 25 A. Yes, sir. 1 correct, to the best of your knowledge and 2 ability, right? 3 MS. PERRITANO: Well, he didn't 4 create it, but if you -- 5 Q. (By Mr. Iola) You can answer. 6 A. I mean, I would assume that the 7 person who actually set up the website got his 8 information somewhere. 9 Q. Warren is now known as Warren Pumps, 10 LLC, correct? 11 A. Yes, sir. 12 Q. The transaction leading to Warren 13 Pumps, LLC took place in 2004, correct? 14 A. Yes, sir. 15 Q. And when did that transaction take 16 place? 17 A. That, I don't know. 18 Q. Do you know when, what quarter in 19 2004, Warren Pumps, Incorporated changed its name 20 to Warren Pumps, LLC? 21 A. No, I do not. 22 Q. Do you know what the purpose was of 23 Warren Pumps, Incorporated changing its corporate 24 structure to Warren Pumps, LLC? 25 A. No, sir. Page 42 Page 44 1 Q. Warren Pumps is currently a member of 2 The Colfax Pump Group, correct? 3 A. Yes, sir. 4 Q. The Colfax Pump Group is a worldwide 5 association of pump manufacturers with 6 headquarters located in Monroe, North Carolina, 7 correct? 8 MS. PERRITANO: Objection, if you 9 know. 10 A. My understanding is, yes, that's 11 correct. 12 Q. (By Mr. Iola) That's information 13 published on your website, correct? 14 A. Well, that's where it is. 15 Q. And you would expect all of the 16 information that's published on Warren website to 17 be factual and correct, right? 18 A. Well, I don't particularly surf our 19 own website all the time, so I really don't know 20 everything that's on it. 21 Q. But you would agree with me, 22 Mr. Doktor, that the purpose of the website is to 23 tell the world about Warren Pumps, correct? 24 A. It is a sales tool, yes. 25 Q. And it's designed to be factually 1 Q. Were you involved in the change from 2 Warren Pumps, Incorporated to Warren Pumps, LLC? 3 A. No, sir. 4 Q. Do you know an individual at Warren 5 Pumps who was involved in that transaction? 6 A. No, I do not. 7 Q. As you sit here today, can you tell 8 me who the person most knowledgeable at Warren 9 Pumps is, that would have knowledge of that 10 transaction from Warren Pumps, Incorporated to 11 Warren Pumps, LLC in 2004? 12 MS. PERRITANO: Objection, if you 13 know. 14 A. I wouldn't -- wouldn't know if 15 anybody was involved. 16 Q. (By Mr. Iola) Who's the president of 17 Warren Pumps, LLC? 18 A. We don't have a president. We have a 19 general manager. 20 Q. Who is that individual? 21 A. Mario DiDomenico. 22 Q. Can you spell that, please? 23 A. D-i-D-o-m-e-n-i-c-o. 24 Q. How long has Mr. DiDomenico been with 25 Warren Pumps? 11 (Pages 41 to 44) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 45 Page 47 1 A. I believe 1995 or 1996. 2 Q. Has he continuously served in the 3 position as general manager since then? 4 A. Yes, sir. 5 Q. Who serves underneath Mr. DiDomenico 6 at Warren Pumps? 7 A. He has several managers that report 8 to him. 9 Q. Who are those? 10 A. Mr. Legault is one, for engineering. 11 Q. John? 12 A. Legault. 13 Q. Legault. Anybody else? 14 A. Gary Young. 15 Q. Y-o-u-n-g? 16 A. Yes, sir. 17 Q. What's his title? 18 A. Controller. 19 Q. Anybody else? 20 A. We have Matt Korzec, K-o-r-z-e-c, 21 manufacturing manager. 22 Q. Anybody else? 23 A. Mr. Ardizzone. 24 MS. PERRITANO: Randall, I want to 25 object to something when he's done. 1 asking Mr. Doktor about, but technically 2 speaking, it goes beyond, I think, the Gudmundson 3 case. So I just want to lodge a general 4 objection as to its relevance, with respect to 5 that case. I'm going to let you ask him, because 6 I think we need -- you know, we can move things 7 along a little bit that way, but I do want it 8 clear on the record that it is beyond the scope. 9 And if we were to play this tape in trial, what 10 was going on in the '80s and '90s in terms of the 11 corporate history, would be something that we 12 would not necessarily agree to being admissible. 13 But you can continue because I think you'll move 14 along. 15 Q. (By Mr. Iola) Mr. Doktor, just to 16 summarize the corporate history structure. 17 Warren Pumps was founded as Warren Steam Pump 18 Company in 19 -- in 1897, correct? 19 A. Yes, sir. 20 Q. Remained as that entity through 1957, 21 correct? 22 A. Yes. 23 Q. Sometime in 1957, it changed names to 24 Warren Pumps, Incorporated, correct? 25 A. Yes. Page 46 Page 48 1 Q. (By Mr. Iola) Okay. Go ahead, sir. 2 MS. PERRITANO: You can answer that. 3 Q. (By Mr. Iola) Mr. Ardizzone's title, 4 again, is aftermarket manager, correct? 5 A. Yes, sir. 6 Q. Anybody else? 7 A. Mark Korzec. 8 Q. M-a-r-k? 9 A. Yes, sir. 10 Q. K-o-r-z-e-c? 11 A. Yes, sir. 12 Q. What is his title? 13 A. Industrial sales manager. 14 Q. Is he related to Matt? 15 A. Yes, sir. 16 Q. Are they brothers? 17 A. Yes, sir. 18 Q. I have some familiarity with working 19 with brothers. Anybody else? 20 A. The last one that I can think of is 21 Robert Bliss. 22 Q. And his title? 23 A. Human resource manager. 24 MS. PERRITANO: My turn. This is, 25 you know, something I have no problem with you 1 Q. It continued to operate continuously 2 from 1957 forward to 2004 as Warren Pumps, 3 Incorporated, correct? 4 A. Yes. 5 Q. Somewhere in 2004, it changed its 6 name to Warren Pumps, LLC, correct? 7 A. Yes. 8 Q. And from 2004 continuously to the 9 present date, it's operated as Warren Pumps, LLC, 10 correct? 11 A. Yes. 12 Q. Warren Pumps is still located in 13 Warren, Massachusetts, correct? 14 A. Yes. 15 Q. At any time have they had a facility 16 in another location, other than Warren, 17 Massachusetts? 18 MS. PERRITANO: And I'm just going to 19 object for the record, again, to the extent that 20 we're talking about facilities that may or may 21 not have been in existence during the Gudmundson 22 time frame. But you can feel free to ask some 23 questions on it, that's fine. I just want the 24 objection on the record. 25 Q. (By Mr. Iola) Any other location, 12 (Pages 45 to 48) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 49 Page 51 1 other than Warren, Massachusetts? 2 A. Yes. 1 be either a screw or gear pump, correct? 2 MS. PERRITANO: Objection, relevance. 3 Q. And that location is where, sir? 3 A. Yes. 4 A. Peace Dale, Rhode Island. 4 Q. (By Mr. Iola) You are aware, 5 Q. And what was in Peace Dale, Rhode 5 Mr. Doktor, that some of Warren's pumps, at 6 Island? 6 various times, may have incorporated gasket or 7 A. It was a small facility to make some 8 end suction pumps. 9 MS. PerRiTANO: Randall, I'm assuming 7 packing components containing asbestos? MS. PERRITANO: Objection, relevance. Q. (By Mr. Iola) Correct? 10 I can just have a continuing objection? 10 A. Yes. 11 MR. IOLA: That's fine. If you want 11 Q. How did Warren obtain these gaskets 12 to mention it each time just briefly, that's 12 or packing components containing asbestos? 13 fine. 13 MS. PERRITANO: Objection. 14 MS. PERRITANO: I really don't want 14 Q. (By Mr. Iola) If you know? 15 to. 15 MS. PERRITANO: I'll let him answer 16 MR. IOLA: It doesn't matter to me. 16 this question, but then, I think, in terms of the 17 MS. PERRITANO: Unless you would like 17 components for the particular pumps, until we get 18 me to break the flow, which maybe I should do. 18 a court ruling on the motion for Protective 19 Q. (By Mr. Iola) How many employees 20 approximately are there at Warren Pumps, 19 Order, I'd like to deal with just the Bausell, if 20 I'm pronouncing that correctly, ship. You can 21 presently? 21 answer generally over my objection, and then 22 A. Around 100. 22 we're going to... 23 Q. Warren Pumps is unionized, correct? 23 A. I wasn't part of the purchasing 24 A. Our shop facility is, yes. 24 department, so I don't really know how they went 25 Q. With the International Electrical 25 about getting that type of materials. Page 50 Page 52 1 Union, AFL-CIO? 1 Q. (By Mr. Iola) But in all fairness, 2 A. Yes. 2 Mr. Doktor, you signed the Verification of 3 Q. Presently, Warren Pumps manufactures 3 Interrogatory Answers in this case, correct? 4 only pumps, correct? 4 MS. PERRITANO: Well, he signed the 5 MS. PERRITANO: Objection, same, 5 Verification as a corporate representative, not 6 relevance as to what's going on presently. 6 as somebody who necessarily knows the -- all of 7 A. Yes. 7 the information contained therein with personal 8 Q. (By Mr. Iola) The last steam pump knowledge. 9 was manufactured at Warren in approximately 1995 Q. (By Mr. Iola) Let's ask the question 10 correct? 10 and get an answer first, then we'll move forward. 11 MS. PERRITANO: Objection, relevance. 11 You signed the Verification of the 12 A. Yes. 12 Warren Pumps, Incorporated Supplemental Answers 13 Q. (By Mr. Iola) Up until 1995, Warren 13 and Objections to Plaintiff's Standard 14 Pumps manufactured reciprocating and centrifugal 14 Interrogatories In Re: All Asbestos Litigation 15 pumps, which handled common material like fluids, 15 Filed by Wise & Julian in Madison County, 16 correct? 16 Illinois. You signed those interrogatory answers 17 MS. PERRITANO: Objection, relevance. 17 on the 3rd day of September 2004; is that 18 A. Yes. 18 correct? 19 Q. (By Mr. Iola) With the introduction 19 MS. PERRITANO: Can you show him the 20 of the Quimby technology, which dates back to 20 signature, so he knows the date? 21 1950, Warren began to pump viscous fluids, oils, 21 MR. IOLA: Sure. 22 fuels, correct? 22 MS. PERRITANO: Because I don't know 23 MS. PERRITANO: Objection, relevance. 23 that he actually knows it was -- 24 A. Yes. 24 Q. (By Mr. Iola) Sure, let me hand you 25 Q. (By Mr. Iola) The Quimby pump would 25 -- Without marking it as an exhibit at this point 13 (Pages 49 to 52) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 53 Page 55 1 in time, sir, let me hand you the interrogatory 2 answers that are the supplemental answers filed 3 in Madison County, Wise & Julian litigation and 4 ask you to turn to the very last page of that 5 document. Do you see that, sir? 6 A. Yes. 7 Q. It's entitled "Verification", 8 correct? 9 A. Yes. 10 Q. It's Warren Pumps, Incorporated by 11 Roland Doktor, correct? 12 A. It's Warren Pumps, LLC. 13 MS. PERRITANO: In September. 14 A. September, okay. Yes. Okay. Yes. 15 Q. (By Mr. Iola) And at the bottom, is 16 a signature line for you, correct? 17 A. Yes. 18 Q. Do you recognize that as your 19 signature? 20 A. Yes. 21 Q. And you signed it in the presence of 22 a notary, correct? 23 A. Yes. 24 Q. Ms. Sylvia Cummings, correct? 25 A. Yes. 1 A. That's what it says, yes. 2 Q. Okay. That's good for now until we 3 get the court's order on this other information. 4 MS. PERRITANO: Why don't we talk 5 about the drawings. 6 MR. IOLA: Yeah, we're getting there. 7 Q. (By Mr. Iola) Warren's largest 8 customer is the United States Navy, correct? 9 MS. PERRITANO: Objection to the 10 extent it seeks information beyond the Gudmundson 11 time period. Go ahead. 12 A. Yes. 13 Q. (By Mr. Iola) Part -14 A. Can I? 15 Q. Yes, sir. 16 A. Or agents of the government. 17 Q. Very well. Part of the process of 18 satisfying the government with respect to 19 products that are put on board naval vessels, is 20 something called the QPL, correct? 21 A. It depends on what time frame we're 22 talking about and what military specification you 23 are talking about. 24 Q. Let's talk about in the 1940s. 25 A. Okay. Page 54 Page 56 1 Q. Is she an employee there at Warren? 1 Q. Was there such a thing in the 1940s, 2 A. Yes, she is. 2 as the QPL or qualified products list? 3 Q. Okay. And you dated it the 3rd day 3 A. I have not seen any documentation for 4 of September 2004, correct? 4 that time period for QPL. 5 A. Yes. 5 Q. When is your understanding that the 6 Q. And in your verification, you 6 QPL was invented? 7 identify that some of these answers, and 7 MS. PERRITANO: Objection to the 8 supplemental answers, may not be based on 8 extent it's after the Gudmundson time frame. You 9 personal knowledge and were prepared based on 9 can answer. 10 documents and information located after a 10 A. My understanding is it was 11 reasonably diligent investigation, under the 11 commensurate with the introduction of military 12 circumstances, with the assistance and advice of 12 specifications. 13 counsel and the answers and supplemental answers 13 Q. (By Mr. Iola) Which was when? 14 set forth subject to inadvertent or undiscovered 14 A. Specifically that date, I don't know. 15 errors, or therefore limited by records and 15 Q. Well, part of the documentation 16 information still in existence presently 16 that's been turned over in this case are some Mil 17 recollected, and thus far discovered in the 17 Specs, right? 18 course of the preparation of these answers and 18 A. Yes. 19 supplemental answers, correct? 19 Q. Mil Specs dealing with pumps, 20 A. Yes. 20 reciprocating, direct-acting and power-driven, 21 Q. And then at the very end, you say 21 correct? 22 that subject to the limitations set forth above, 22 A. Yes. 23 the answers and supplemental answers are true and 23 Q. And those Mil Specs are dated in 24 correct to the best of your current information 24 1955, correct? 25 and belief; is that correct, sir? 25 A. Yes. 14 (Pages 53 to 56) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 57 Page 59 1 MS. PERRITANO: Well, let me just 1 corner of that document, it lists that Mil Spec 2 show him. 2 as what number? 3 Q. (By Mr. Iola) And they supercede 3 A. MIL-P-19158. 4 some Mil Specs that were in effect as early as 4 Q. And it says a date of that Mil Spec, 5 1939, correct? 5 correct? 6 MS. PERRITANO: Objection. Wait. 6 A. Yes. 7 Q. (By Mr. Iola) If you know. 7 Q. And what's the date, sir? 8 MS. PERRITANO: Take a look at the 8 A. 29 December 1955. 9 document. 9 Q. And then it says it supersedes a 10 Q. (By Mr. Iola) Before you look at the 10 prior version of the Mil Spec, correct, sir? 11 document, I want to know what you know from your 11 A. Well, the S47-1 is a specification. 12 memory. Do you know? 12 I would not call that what we would know today as 13 A. The document called a Mil Spec? 13 a Mil Spec, because it doesn't have the MIL 14 Q. No. 14 designation. 15 A. Identified as a Mil Spec? 15 Q. But it is a specification from the 16 Q. The document that I just referred to 16 United States Navy, correct? 17 that was produced in this litigation, is a Mil 17 A. It's a specification from the United 18 Spec dated 1955 that supercedes a Mil Spec dated 18 States Government, whether it was a naval spec or 19 1939; do you know that to be true? 19 a general spec, I don't know. 20 A. I'd have to -- 20 Q. Very well. A specification from the 21 Q. Okay. Very well. 21 U.S. Government dated when? 22 A. First page. 22 A. 1 March 1939. 23 MR. IOLA: Let's just give him the 23 Q. So at least as early as March 1, 1939 24 entire document. We'll mark it. 24 the U.S. Government issued some kind of spec with 25 MS. PERRITANO: Wait a minute. I 25 respect to a portion of what became Military Spec Page 58 Page 60 1 need to get the both-sided copy. 1 19158 dated December 29, 1955, correct? 2 MR. IOLA: Well, here's mine. I 2 A. Yes, sir. 3 don't care. Is what you gave me this morning 3 Q. Can you tell the Members of the Jury, 4 both-sided? 4 Mr. Doktor, what a Military Specification is 5 MS. PERRITANO: I did, but I have 5 designed to do or what it's designed to say and 6 another one for him. 7 MR. IOLA: Okay. 6 to whom it speaks? 7 MS. PERRITANO: Objection to the 8 MS. PERRITANO: Give me one second. 8 extent it's beyond the scope of the deposition. 9 MR. IOLA: One sec, Mr. Doktor. 9 Feel free to -- 10 We're going to pull the correct form of the 10 A. I'm not sure what -- what you're 11 document here with copying of both sides of the 11 really asking. 12 page, so that you'll have a complete set. 13 THE WITNESS: Thank you. 12 Q. (By Mr. Iola) Okay. What I'm asking 13 is why is it relevant for Warren Pumps to have a 14 MS. PERRITANO: Why don't you mark -- 14 Military Specification? 15 MR. IOLA: Here, let me just mark 15 A. We would -- 16 mine. When she finds it, I'll take hers. 16 MS. PERRITANO: Objection, beyond the 17 (Whereupon Exhibit 4 was marked.) 17 scope. 18 Q. (By Mr. Iola) Let me hand you what's 18 A. We would be building pumps for the 19 been marked as Deposition Exhibit Doktor Number 19 government that would be required to be furnished 20 4. 20 under this Military Specification. 21 And ask you if that is the Mil Spec 21 Q. (By Mr. Iola) The government sets 22 that was produced to me this morning, in 22 the specification for which you build a pump to 23 reference to the Gudmundson case? 23 furnish to them, correct? 24 A. Yes. 25 Q. Okay. And at the very top, right 24 A. Yes. 25 MS. PERRITANO: Objection, time 15 (Pages 57 to 60) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 61 Page 63 1 frame. 1 research, either at the naval archives or 2 Q. (By Mr. Iola) They kind of outline 2 elsewhere, to determine when the Bausell was 3 what they require the pump to have and be built 3 constructed and where it was constructed? 4 like; and then you put your heads together to 4 A. I don't know. 5 build the finest pump you can that meets that 5 Q. Okay. As you sit here today, do you 6 outline, correct? 6 have any knowledge about what shipyard 7 MS. PERRITANO: Objection, time 7 constructed the USS Bausell? 8 frame, relevance. 8 A. From the information that we provided 9 A. It is -- It is a document for which 9 you today, it was Bath Iron Works. 10 we would use to design the pump and manufacture 10 Q. And Bath Iron Works is located where? 11 the pump. 12 Q. (By Mr. Iola) What is your 11 A. In Bath, Maine. 12 Q. So why would a military specification 13 understanding of why you produced this Mil Spec 13 from 1955 have anything to do with the equipment 14 that's dated December 29, 1955 in this case? 14 that was supplied to the Bausell when it was 15 A. It's within the time frame that we 15 constructed in the time period of 1941 to 1945? 16 were asked to look at. 16 A. It wouldn't necessarily. 17 Q. And the time frame that you were 17 Q. Okay. Can you testify under oath 18 asked to look at, was what? 18 that Deposition Exhibit Number 4, which is the 19 A. 1951 to 1955. 19 Military Specification for pumps, reciprocating, 20 Q. And in 1951 to 1955 was the time 20 direct-acting and power-driven, which is 21 frame of what? 21 MIL-P-19158 (ships), 29 December, 1955 was a Mil 22 A. Mr. Gudmundson's service on the 22 Spec that was previously in effect at the time 23 Bausell. 23 the Bausell was constructed between 1941 and 24 Q. Okay. And Mr. Gudmundson's service 24 1945? 25 on the Bausell was while he was in the United 25 A. Not previously, no. Page 62 Page 64 1 States Navy, correct? 1 Q. It's your understanding that this Mil 2 A. Yes. 2 Spec came into effect on the date it's dated, 3 Q. But you're aware that the Bausell 3 correct? 4 wasn't built in 1951, correct? 4 A. Yes, sir. 5 A. That's correct. 5 Q. Do you have any knowledge of 6 Q. And pumps that would have been 6 Specification 47-1, March 1, 1939? 7 installed on the Bausell, in its initial 7 A. No, I do not. 8 construction, would have been supplied during the 8 Q. Have you made any attempt to go and 9 construction of the Bausell, correct? 9 locate that specification in this litigation? 10 A. Yes. 10 A. Counsel has, yes. 11 Q. What is your understanding of when 11 Q. Okay. Do you know whether or not 12 the Bausell was constructed? 12 counsel has discovered that specification? 13 A. During the 2nd World War. 13 A. Not to my knowledge, no. 14 Q. What is your understanding, for the 14 Q. Okay. And one other warning I want 15 Members of the Jury, exactly what years that was? 15 to give you, Mr. Doktor, throughout the 16 A. That would be 1941 to 1945. 16 deposition today, I'm not interested in any 17 MS. PERRITANO: The years of the 2nd 17 conversation that you have ever had with any of 18 World War. 18 your lawyers at any point in time. Okay? 19 A. 2nd World War. 19 A. Yes, sir. 20 Q. (By Mr. Iola) Do you know, within 20 Q. Those are privileged communications 21 that window of 1941 to 1945, when the Bausell was 21 and they are not to be disclosed to me or anyone 22 constructed? 22 else. Okay? 23 A. Specifically, no. 23 A. Yes, sir. 24 Q. Have you done any research or are you 24 Q. So if I ask you a question today, I'm 25 aware of anyone else at Warren Pumps who has done 25 asking you the question to either identify who it 16 (Pages 61 to 64) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 65 Page 67 1 was or their name, but don't tell me about the 1 Q. Okay. And when you say a whole group 2 communication. Okay? That's privileged. All 2 of destroyers, you are referring to a group of 3 right? 4 A. Yes, sir. 3 destroyers that were being constructed during the 4 same time period, correct? 5 Q. Do you understand that? 5 A. For the 2nd World War effort, yes. 6 A. Yes, sir. 7 Q. Okay. 6 Q. And were all these destroyers being 7 built at Bath Iron Works? 8 MS. PERRITANO: He understands it. 8 MS. PERRITANO: If you know. 9 THE WITNESS: Do you want this? 9 A. I do not. That, I don't know. 10 Q. (By Mr. Iola) From your review of 10 Q. (By Mr. Iola) Okay. And was there a 11 the documents, you're aware that certain sales of 11 certain class of destroyers that these pumps were 12 pumps by Warren Pumps, Incorporated, actually it 12 being used on? 13 would have been the Warren Steam Pump Company 13 A. Might have been multiple classes. 14 during that period of time, in the 1941 to 1945 14 Q. Okay. Were you aware these pumps 15 period, were sold for the installation on board 15 were used across the Gearing class, 16 the USS Bausell, correct? 16 G-e-h-r-i-n-g? 17 A. Yes. 17 A. No, I -- 18 Q. And you know that because of certain 18 Q. G-e-a-r-i-n-g, I'm sorry. 19 records that you've determined, correct? 19 A. No, I was not. 20 A. Yes. 20 Q. Were you aware of where these pumps 21 Q. As well as certain drawings that you 21 were being installed? 22 have, correct? 22 MS. PERRITANO: If you know. 23 A. Yes. 23 A. What do you mean by installed? 24 Q. And tell me, if you would, or if you 24 Q. (By Mr. Iola) Well, when they go to 25 can, off the top of your head without looking at 25 the shipyard, are you aware of what destroyers, Page 66 Page 68 1 any documents, what type of pumps were on board 1 individually, these pumps were being installed 2 the USS Bausell that Warren manufactured? 2 upon? 3 A. Do you want them by design or do you 3 A. We would know that from the order 4 want them by service? There's a couple of ways I 4 that the customer would have given us. 5 can do that. 5 Q. Okay. And do you have paperwork 6 Q. Yeah, just tell me the names of them. 6 reflecting the order of the customer? 7 A. One was the main circulating pump. 7 A. Yes, that was provided to you this 8 You have the fresh water pump, diesel generator 8 morning. 9 circulating pump, sea water circulating pump. 9 Q. Okay. And I want to be clear that 10 Q. Also known as salt water circulating 10 where you located some of these documents, that 11 pump? 11 were provided to me last night, were from the 12 A. Yes, sir. The emergency feed pump, 12 customers' files that you keep at Warren Pumps, 13 and the fire and bilge pump. 13 correct? 14 Q. Now, what you have just given me is 14 A. They were from the sales file, yes. 15 the name of the various pumps that Warren Pumps 15 Q. Which have not been destroyed, 16 sold for installation on the USS Bausell, 16 correct? 17 correct? 17 MS. PERRITANO: You have what was in 18 A. Yes. 18 the sales file. 19 Q. And are you aware that the USS 19 Q. (By Mr. Iola) But I want to back up 20 Bausell is also known as DD-845? 20 to my question: Has the sales file been 21 A. Yes, sir. 21 destroyed? 22 Q. Okay. And some of these pumps were 22 MS. PERRITANO: Objection. 23 sold in quantities of more than one, correct? 23 A. The only documents that we have, have 24 A. Yes, sir, they were for a whole group 24 been provided to you. 25 of destroyers. 25 Q. (By Mr. Iola) Okay. But those___________ 17 (Pages 65 to 68) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 69 Page 71 1 documents were obtained from the sales file, 1 Q. And the purpose of spare parts is you 2 right? 2 can't just sell a unit to the United States 3 A. What remains of the sales file, yes. 3 Government and/or the United States Navy, you 4 Q. That's my question. Are you aware 4 have to give them some spare parts in case 5 that there are certain portions of the sales file 5 something breaks down, and they got to fix it, 6 that have been destroyed? 6 right? 7 MS. PERRITANO: Objection. If you 7 MS. PERRITANO: Objection, relevance. 8 know. 8 A. In this -- In this case, that was 9 A. I'm only assuming. 9 correct. 10 Q. (By Mr. Iola) And what are you only 10 Q. (By Mr. Iola) I mean in every case 11 assuming? 11 where you sold a pump, almost, you sold them 12 MS. PERRITANO: Don't assume. 12 spares, correct? 13 A. Okay. Then, I don't know. 13 MS. PERRITANO: Objection, relevance. 14 MS. PERRITANO: If you know, tell 14 A. No. 15 him. Otherwise, do not assume. 15 Q. (By Mr. Iola) Okay. There were some 16 A. I do not know what else would have 16 instances where you simply sold the pump, no 17 been in the sales file. 17 spares and that was the end of it, correct? 18 (Whereupon Exhibit 5 was marked.) 18 MS. PERRITANO: Objection, beyond the 19 Q. (By Mr. Iola) Let's start by handing 19 scope, and relevance. 20 him a clean copy of WP-IL Page 1 through 3, I 20 A. Yes. 21 believe, is the first one. Let me hand you, sir, 21 Q. (By Mr. Iola) How about with respect 22 what I've marked as Deposition Exhibit Number 5, 22 to the USS Bausell, was there ever a situation 23 which is dated May 17, 1943, order by Warren 23 where all you sold was the pump? 24 Engineering Company, ship to Bath Iron Works. Do 24 A. According to this information, no. 25 you see that, sir? 25 Q. You always sold spares, in addition, Page 70 Page 72 1 A. Yes. 1 correct? 2 Q. Is there any other identifying number 2 MS. PERRITANO: To the Bausell? 3 or heading on this document that you would call 3 Q. (By Mr. Iola) To the -- With respect 4 this document? 4 to what was sold by Warren Pumps to the 5 A. Just our order number that's at the 5 government for the Bausell, correct? 6 top, upper right-hand corner. 6 A. For this particular pump, yes. 7 Q. Which is C-4647. 7 Q. Okay. And right now, all we're 8 A. No, it's the A-17488. 8 looking at is the main condenser circulating 9 Q. So this is order number A-17488, 9 pump, correct? 10 correct? 10 A. Yes. 11 A. Yes. 11 Q. How many of these main condenser 12 Q. And this is an order from a customer 12 circulating pumps were aboard the Bausell? 13 to Warren Pumps, correct? 13 A. Two. 14 A. Yes. 14 Q. How do you know that? 15 Q. For what? 15 A. Under the special marks column, 16 A. Well, this is not the order from the 16 left-hand column, these are for DD-805 to DD-808 17 customer. This is our order that we would have 17 and there's -- So there's four ships there and 18 put into our system or would have generated the 18 there's eight pumps on the order, so that would 19 demand for the pumps. 19 be two per ship. 20 Q. And what is this an order for? 20 Q. I thought we agreed that the Bausell 21 A. This is for eight 25-inch main 21 was DD-845, right? Is that correct? 22 condenser circulating pumps and spares. 22 A. Yes. 23 Q. And spares is just spare parts; is 23 Q. So DD-845 is not even on this 24 that correct, sir? 24 document, right? 25 A. Yes. 25 A. This particular one does not have the 18 (Pages 69 to 72) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 73 Page 75 1 845 on it. 2 Q. Okay. So back up to my original 3 question: Do you believe there were two main 4 condensing circulating pumps installed, Warren 5 main condensing circulating pumps installed upon 6 the USS Bausell DD-845? 7 A. Yes, I believe the drawings will -- 8 Q. Okay. 9 A. -- provide that information. 10 Q. These two main condensing circulating 11 pumps were installed aboard the Bausell where? 12 A. Should be at Bath Iron Works. 13 Q. Okay. That was the shipyard where 14 the vessel was built, correct? 15 A. Yes. 16 Q. Where, on the Bausell, would a main 17 condensate circulating pump be installed? 18 A. I'm not familiar with that particular 19 ship, so I can't tell you exactly where it would 20 be. 21 Q. Where are they commonly installed, 22 meaning engine room, fire room, boiler room? 23 A. It would be the engine room. 24 Q. Would it be in the aft engine room, 25 as well as the forward engine room? 1 Q. Okay. Let's look at the drawings and 2 if you would, please, sir, show me any drawings 3 that you have regarding the main condensate 4 circulating pumps; and that's what they are, 5 right? 6 A. Main condenser circulating pumps, 7 Q. Okay. 8 A. It's not -- It wasn't in that group 9 that you asked me to look at. 10 MR. IOLA: Okay. Why don't we take a 11 break for a moment and if you can look in any 12 other group that you brought with you of 13 documents, see if you can find any drawings on 14 the main condenser circulating pumps and we'll 15 pick up there after we come back on the record. 16 THE WITNESS: Thank you. 17 VIDEOGRAPHER: The time is 10:28. 18 We're off the record. 19 (Whereupon, a brief break was taken.) 20 VIDEOGRAPHER: The time is 10:41 a.m. 21 We're on the record. 22 Q. (By Mr. Iola) Sir, we're back on the 23 record and you understand you're still under 24 oath? 25 A. Yes. Page 74 Page 76 1 A. If there was an aft and a forward 1 Q. You have located the main condenser 2 engine room. 2 circulating pump drawings; is that correct, sir? 3 Q. There would be one in each, correct? 3 A. Yes. 4 A. Yes. 4 Q. Can you identify them by Bates stamp 5 Q. Do you know whether the Bausell had 5 number for the record, please? 6 an aft and a forward engine room? 6 A. We have WP-IL 00244, WP-IL 00245 and 7 A. Again, I don't -- I'm not familiar 7 WP-IL 00245B, as in boy. 8 with that particular ship. 8 Q. Okay. And what are those exactly, 9 Q. Are you familiar with the Gearing 9 please, sir? 10 class of destroyers, of which the Bausell is one? 10 A. Do you want me to use the Bates 11 A. Just by name. 11 numbers to identify? 12 Q. Are you familiar with whether the 12 Q. That's fine. 13 Gearing class of destroyers had engine rooms both 13 A. Okay. Bates number WP-IL 00244 and 14 in the aft and the forward? 14 00245 is the outline and certification data for 15 A. No. 15 that main condenser circulating pump. And Bates 16 Q. Okay. Just so the record is clear, 16 number 00245B, as in boy, is the sectional 17 sir, did you locate any document, like Deposition 17 assembly and parts list for that pump. 18 Exhibit Number 5, which indicated on the 18 Q. For the main condenser circulating 19 document -- not the drawing, which indicated on 19 pumps, Drawings 244 and 245, is there anything on 20 the document that two main condensate circulating 20 those drawings that indicates any asbestos 21 pumps were installed and sold for installation 21 insulating, insulation, parts, cement, anything 22 aboard the USS Bausell? 22 of the sort? 23 A. Can we just look through? 23 MS. PERRITANO: On the main circ 24 Q. Absolutely. 24 pump, is that what you're talking about? 25 A. It's not in the pile, no. 25 Q. (By Mr. Iola) No, the main condenser 19 (Pages 73 to 76) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 77 Page 79 1 circulating pump? 1 Deposition Exhibit 6 as a group, if you'd like. 2 A. No. 2 MS. PERRITANO: Okay. Why don't we 3 Q. And on drawing 245B, which is the 3 do that just so - 4 sectional assembly and parts list, is there 4 MR. IOLA: Sure. 5 anything that identifies any asbestos-containing 5 MS. PERRITANO: -- it's clear later. 6 gaskets, asbestos-containing insulation, 6 Do you care which of the three drawings - 7 asbestos-containing lagging, anything of the 7 MR. IOLA: I would put it on 244. 8 sort? 8 MS. PERRITANO: Okay. 9 MS. PERRITANO: Objection to the 9 MR. IOLA: And for the record, we're 10 extent it asks for more than one product at the 10 marking as Deposition Exhibit Number 6, drawings 11 same time, so when you answer, just break it 11 WP-IL-00244, 00245 and 00245B together as a 12 down, please. 12 group, as Exhibit Number 6. 13 A. Okay, it -- Just let me find the 13 (Whereupon, Exhibit 6 was marked.) 14 right piece number for you. 14 Q. (By Mr. Iola) Sir, the next item 15 MS. LACONTE: Can whoever is typing, 15 that I believe you listed was the fresh water 16 mute their phone, please? 16 pump, but I want to turn your attention instead 17 A. There is a -- No, it's not identified 17 to the fire and bilge pump. And in the documents 18 on here. There is -- There is a gasket that is 18 that you located last night as supplemental 19 unidentified by material, which is piece number 19 documents, did you locate any orders for fire and 20 703. There is also gasket material -- packing 20 bilge pumps? 21 material, which is piece number 727, and is 21 A. That's what I'm looking for right now 22 identified as plastic metallic rod and by the 23 Navy department specification. 22 for you. 23 Q. I believe, turn your attention to 24 Q. (By Mr. Iola) And do you think that 24 WP-IL 00016 and the pages behind it. 25 gasket material contained asbestos? 25 A. Yes. Page 78 Page 80 1 MS. PERRITANO: Objection, if you 2 know. 3 A. I do not know, based on this 4 information. 5 Q. (By Mr. Iola) Do you think the 6 packing material contained asbestos? 7 MS. PERRITANO: Objection, if you 8 know. 9 A. From this information, it doesn't 10 give me enough. 11 Q. (By Mr. Iola) Okay. So from the 12 drawings we have on the main condenser 13 circulating pumps, including drawings 244, 245 14 and 245B, it's unclear whether or not the main 15 condenser circulating pumps had any 16 asbestos-containing parts or insulation, correct? 17 A. Correct. 18 Q. Okay. Let's move, if we would, 19 sir - 20 MS. PERRITANO: Did you mark - 21 actually mark those as an exhibit? 22 MR. IOLA: No, I don't need to. 23 MS. PERRITANO: You're just going to 24 refer to them as - 25 MR. IOLA: We can mark them as 1 Q. Let's mark as Deposition Exhibit 2 Number 7 what's Bates stamp numbered as WP-IL 3 00016 through WP-IL 00020; is that where you 4 stopped? 5 A. Yes. 6 (Whereupon, Exhibit 7 was marked.) 7 Q. (By Mr. Iola) Does this appear to be 8 the pages of the documents that deal with fire 9 and bilge pumps? 10 A. Yes. 11 Q. Okay. And what is this document that 12 we've just now marked as Deposition Exhibit 13 Number 7? 14 A. This is our sales order for the 15 pumps. 16 Q. Order number A-17909? 17 A. Yes. 18 Q. It's dated November 30, 1943? 19 A. Yes. 20 Q. And it's ordered by Warren 21 Engineering, correct? 22 A. Yes. 23 Q. For Gibbs and Cox, correct? 24 A. Yes. 25 Q. Who is Gibbs and Cox? 20 (Pages 77 to 80) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 81 Page 83 1 A. They were the naval architects. 2 Q. And it says ship to Bath Iron Works 3 Corp., Bath, Maine, correct? 4 A. Yes. 5 Q. And this is -- Under special marks 6 it's for the class of ships DD-829 through 7 DD-849, correct? 8 A. Yes. 9 Q. And that would include the USS 10 Bausell at DD-845, correct? 11 A. Yes. 12 Q. So this document tells us that some 13 fire and bilge pumps were ordered by the 14 engineering department at Warren for sale and 15 installation to Bath Iron Works aboard these 16 Naval ships, correct? 17 A. Yes. 18 Q. And how many fire and bilge pumps? 19 A. 84. 20 Q. 84 total for the whole variety of 21 different ships, correct? 22 A. Yes. 23 Q. And what exactly were they, these 84? 24 A. Could you rephrase? 25 Q. Yeah, were they 6-by-9-by-12 vertical 1 molded ring stuffing box packing, correct? 2 A. Yes. 3 Q. It suggests that there was steam 4 cylinders and valve chest to be suitably 5 insulated and lagged, correct? 6 A. Yes. 7 Q. And what does that tell you? 8 A. That tells me that there was some 9 form of insulation around the steam cylinder. 10 Q. And a steam cylinder is what, 11 Mr. Doktor? 12 A. That's the driving mechanism for the 13 pump. 14 Q. And steam is what? 15 A. Heated water. 16 Q. Okay. Super-heated water? 17 MS. PERRITANO: Objection, if you 18 know. 19 A. Could be. 20 Q. (By Mr. Iola) But at least, it's in 21 excess of 125 degrees to create steam, correct? 22 MS. PERRITANO: Objection. 23 A. 212 degrees. 24 Q. (By Mr. Iola) Even better. That's 25 correct? Page 82 Page 84 1 single fire and bilge pumps with air chambers? 2 A. Yes, that's the description on 3 the order. 4 Q. And is there various types of fire 5 and bilge pumps or is that the fire and bilge 6 pump that Warren made? 7 A. For this particular ship, that was 8 the pump that we made. 9 Q. Okay. There's not a different 10 variety or version, correct? 11 A. Not for the ship. 12 MS. PERRITANO: Objection. 13 Q. (By Mr. Iola) Okay. This document 14 indicates that these 84 vertical single fire and 15 bilge pumps 6-by-9-by-12s were all identical, 16 correct? 17 A. Yes. 18 Q. And they were centrifugally cast, 19 correct? 20 A. The pump cylinder was. 21 Q. Okay. And there's a little 22 description about midway down the page that 23 describes that, correct? 24 A. Yes. 25 Q. It suggests that there was John Crane 1 A. Yes. 2 MS. PERRITANO: Objection. 3 Q. (By Mr. Iola) Steam requires 4 insulation, correct? 5 MS. PERRITANO: Objection, if you 6 know. Beyond the scope of this witness's 7 designation. 8 Q. (By Mr. Iola) You can answer. 9 A. It doesn't necessarily need to be. 10 Q. Okay. It doesn't necessarily need to 11 be to keep steam steam? 12 A. Correct. 13 Q. Okay. You've seen uninsulated steam 14 lines before? 15 MS. PERRITANO: Objection, relevance, 16 beyond the scope. 17 Q. (By Mr. Iola) You can answer. 18 A. Yes. 19 Q. These steam lines or this steam 20 cylinder was insulated, correct? 21 A. And lagged, yes. 22 Q. Okay. What is -- What do you mean by 23 the term "lagged"? 24 A. It's the metal covering that goes 25 over the insulation. 21 (Pages 81 to 84) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 85 Page 87 1 Q. And the design of why there is metal 1 VIDEOGRAPHER: Hold on. Off the 2 covering over the insulation is why? 2 record. I just lost power. 3 A. Protection. 3 (Whereupon, an off-the-record 4 Q. Protection from what? 4 discussion was held.) 5 A. People -6 MS. PeRRITANO: Objection, if you 5 VIDEOGRAPHER: The time is 10:55 a.m. 6 We are now back on the record after a brief power 7 know. 7 outage. 8 A. Again, I'm -- 8 Q. (By Mr. Iola) Mr. Doktor, now in 9 MS. PERRITANO: Don't speculate. 9 front of you is -- are some drawings regarding 10 Q. (By Mr. Iola) If you don't know -- 10 the assembly list of spares and materials 11 A. I don't know. 11 6-by-9-by-12 vertical single fire and bilge 12 MS. PERRITANO: If it's beyond your 12 pumps, correct? 13 knowledge, do not speculate. 13 A. Yes. 14 Q. (By Mr. Iola) The second page of 14 Q. They're labeled Bates number WP-IL 15 this document, WP-IL 00017, indicates on 15 00240 and WP-IL 00241; is that correct, sir? 16 September 12, 1945, DD-845 received four pumps, 16 A. Yes. 17 correct? 17 MR. IOLA: We will mark those as a 18 A. Yes. 18 group as Deposition Exhibit Number 8 and simply 19 Q. And what does it say underneath that? 19 put that at the bottom by the WP number. That 20 A. Well, I can't read the next line, but 20 will be great. 21 the line after that is four air chambers. 21 (Whereupon Exhibit 8 was marked.) 22 Q. And where was a fire and bilge pump 22 Q. (By Mr. Iola) For the record, this 23 installed, if you know? 23 is really one drawing, is it not, Mr. Doktor, 24 A. I don't know. 24 that just happened to be copied on two pages, 25 MS. PERRITANO: On the ship? 25 because it's so long; is that correct? Page 86 Page 88 1 Q. (By Mr. Iola) Yes, sir. 1 A. That's correct. Yes. 2 A. In particular on the ship, I don't 2 Q. But this one drawing is a drawing of 3 know. 3 the assembly list of spares and material for the 4 Q. Are they installed in pairs? 4 6-by-9-by-12 vertical single fire and bilge pump, 5 A. I do not know. 5 correct? 6 Q. But this indicates that four of them 6 A. Yes. 7 were aboard the USS Bausell, correct? 7 Q. And this is the Warren Pumps 8 A. Yes. 8 6-by-9-by-12 vertical single fire and bilge pump 9 Q. Where aboard the USS Bausell, you 9 that was manufactured by Warren Pumps for sale on 10 don't know, correct? 10 various ships, including DD-645, the USS Bausell, 11 A. I do not know. 11 correct? 12 Q. Have you made any research at the 12 A. The 845. 13 naval archives to determine where on the USS 13 Q. 845, I'm sorry. 14 Bausell the fire and bilge pumps were? 14 A. Yes. 15 A. Not that I'm aware of, no. 15 Q. And as I understand these drawings, 16 Q. Have you made any research or 16 we can look right to the left of the description 17 conducted any research at Bath Iron Works, or any 17 of what this drawing is and we see a listing of 18 of their records to determine where the 18 various ships, correct? 19 installation of these fire and bilge pumps was? 19 A. Yes. 20 A. No. 20 Q. And up there we see DD-829 to 849, 21 MS. PERRITANO: On the Bausell? 21 correct? 22 Q. (By Mr. Iola) Yes. 22 A. Yes. 23 A. No, not that I'm aware of. 23 Q. Which tells us that anything in the 24 Q. Now, in front of you, you have some 24 numbers DD-829 through 849 is the ship that this 25 drawings -- 25 was installed upon, correct? 22 (Pages 85 to 88) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 89 Page 91 1 A. Yes. 2 Q. And the next column says DD-809, what 3 does that mean? 4 A. This should be -- if you go down to 5 the bottom of that column, it says purchase -6 purchase order number. 7 Q. Okay. 8 A. So that was the customer's order for 9 those items. 10 Q. And then the next column says WSP 11 Company, Inc. order number, correct? 12 A. Yes. 13 Q. And that would correspond to the A 14 number we mentioned earlier, which is on 15 Deposition Exhibit Number 7, which in this case 16 is order A-17909, correct? 17 A. Yes. 18 Q. And that corresponds identically with 19 DD-829 through 849, correct? 20 A. Yes. 21 Q. On this document under the list of 22 material, we see as material part number 161, a 23 gasket, pump cylinder and heads; is that right? 24 A. Yes, sir. 25 Q. And it says number 2 and then it says 1 A. Yes. 2 Q. And what is this a gasket for? 3 A. Can you give me a second to find 4 out -5 Q. Yes, sir. 6 A. -- exactly where that part number is. 7 It's a gasket that seals the lower head to the 8 pump cylinder and the upper head to the cylinder. 9 Q. Do you know what the purpose is of 10 using an asbestos gasket there? 11 MS. PERRITANO: Objection, if you 12 know. 13 A. The gasket seals any leakage between 14 those two parts. 15 Q. (By Mr. Iola) There's also part 16 number 162, correct? 17 A. Yes. 18 Q. What's 162? 19 A. Gasket pump cylinder and hand hold 20 plate, I believe, is what the description is. 21 Bifocals aren't what they used to be. 22 Q. And what is that? 23 A. That's another gasket. 24 Q. Another gasket that contained 25 asbestos? Page 90 Page 92 1 material asbestos and material specification 2 asbestos, correct? 3 A. Yes. 4 Q. Does that mean that's an 5 asbestos-containing gasket? 6 MS. PERRITANO: Objection. Go ahead. 7 Q. (By Mr. Iola) You can answer. 8 A. That's what the drawing says, yes. 9 Q. That's an asbestos-containing gasket 10 to be used on a single one fire and bilge pump, 11 correct? 12 A. Yes. 13 Q. And if we have four aboard the USS 14 Bausell, then wherever this part number 161 is, 15 we multiply it by four, because we have four such 16 pumps on the Bausell, correct? 17 MS. PERRITANO: Objection. 18 A. We have four pumps on the Bausell. 19 Q. (By Mr. Iola) Okay. Do you know how 20 many of these gaskets containing asbestos for 21 part number 161 are on the pump? 22 A. According to the drawing, let me see, 23 two. 24 Q. So two gaskets for part number 161 25 are on each pump, correct? 1 A. According to this drawing, yes. 2 Q. Part number 163, what is that? 3 A. Pump gasket, pump cylinder and -- and 4 I can't read the rest of that. 5 Q. Another gasket? 6 A. Yes. 7 Q. Containing asbestos? 8 MS. PERRITANO: Objection. 9 A. According to the drawing, yes. 10 Q. (By Mr. Iola) According to the list 11 of material on the drawing, right? 12 A. Yes, sir. 13 Q. How many of those are there on each 14 pump? 15 A. One. 16 Q. Okay. How many part numbers 162 on 17 each pump? 18 A. One. 19 Q. Okay. Part number 164, what is that? 20 A. It's another gasket. 21 Q. Another gasket that's used where? 22 A. On this pump, between the pump 23 cylinder and another piece. 24 Q. How many of those on each pump? 25 A. One. 23 (Pages 89 to 92) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 93 Page 95 1 Q. And is that an asbestos-containing 2 gasket? 3 MS. PERRITANO: Objection, if you 4 know. 5 A. The drawing indicates it has 6 asbestos. 7 Q. (By Mr. Iola) Well, the drawing is 8 what we go by, right? That's what tells us what 9 the part is, correct? 10 A. Yes. 11 Q. So you can look at the drawing and 12 know that that gasket contained asbestos, right? 13 MS. PERRITANO: From the drawing, 14 yes. 15 Q. (By Mr. Iola) You can answer. 16 A. Yes. 17 Q. Do you have any reason to disbelieve 18 the drawing is accurate? 19 A. No. 20 Q. Do you have any reason to disbelieve 21 that gasket did not contain asbestos? 22 MS. PERRITANO: Objection. 23 A. No. 24 Q. (By Mr. Iola) Are there any other 25 asbestos-containing gaskets that you're aware of 1 correct? 2 A. That's correct. 3 Q. So, naturally, you would assume that 4 this is a pump that was manufactured at the 5 Warren manufacturing facility in Warren, 6 Massachusetts, correct? 7 A. Yes. 8 Q. Did Warren purchase these gaskets 9 precut? 10 A. I do not know. 11 Q. Did Warren purchase sheet gaskets? 12 MS. PERRITANO: For this particular 13 pump? 14 Q. (By Mr. Iola) Yes, sir. 15 A. I don't know. 16 Q. Do you know who was the supplier of 17 these asbestos gaskets for the fire and bilge 18 pump? 19 A. No. 20 Q. This fire and bilge pump drawing is 21 dated when? 22 MS. PERRITANO: There it is. 23 A. It was traced or drawn in 1940. 24 Q. (By Mr. Iola) And it was finally 25 approved by Warren Pumps on what date? Page 94 Page 96 1 on this drawing? 2 A. Can you give me a second just to look 3 real quick? 4 Q. Absolutely. 5 MS. PERRITANO: Take your time. 6 THE WITNESS: I need to take my 7 glasses off. 8 A. I did not see any. 9 Q. (By Mr. Iola) Okay. These gaskets 10 are installed during the initial construction of 11 the pump, correct? 12 A. Yes. 13 Q. The initial construction of this pump 14 takes place at the Warren Pumps or Warren Steam 15 Pump Company manufacturing facility, correct? 16 A. Yes. 17 Q. Was this pump, this fire and bilge 18 pump, manufactured at the Warren, Massachusetts 19 Warren Pump facility? 20 MS. PERRITANO: If you know. 21 A. It doesn't indicate on the drawing 22 whether -- whether it was or not. 23 Q. (By Mr. Iola) But it's not the type 24 of pump that you identified earlier was 25 manufactured at the Rhode Island facility, 1 A. It doesn't -- doesn't have a Warren 2 Pumps approval, it has a Bureau of Ships 3 approval, supervisor of ship building approval. 4 Q. And the date of that is what? 5 A. March 20th, 1941. 6 Q. Is it your understanding that this is 7 the drawing that was in effect at the time the 8 fire and bilge pumps installed upon the USS 9 Bausell were constructed? 10 A. Yes. 11 Q. Next -12 MS. PERRITANO: Is that two pages? 13 Q. (By Mr. Iola) Yes. Next I want to 14 turn your attention to Bates stamped drawings 15 WP-IL-00238 and WP-IL-00239. Do you see those 16 documents, sir? 17 A. Yes. 18 MR. IOLA: If you would kindly, 19 please, mark WP-IL 00238 as Deposition Exhibit 20 Number 9. 21 (Whereupon, Exhibit 9 was marked.) 22 Q. (By Mr. Iola) And let me state for 23 the record and ask you to confirm that these two 24 drawings, 238 and 239, are the lagging outline 25 6-by-9-by-12 vertical single fire and bilge pump, 24 (Pages 93 to 96) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 97 Page 99 1 correct? 2 A. Yes. 3 Q. And this is one drawing that, again, 4 is too big to fit on one page, correct? 5 A. Yes. 6 Q. So that's why we're only marking it 7 as Deposition Exhibit Number 9, even though it's 8 two Bates stamp numbers for the record. 9 This is a drawing of Warren Steam 10 Pump Company, Incorporated, correct? 11 A. Yes. 12 Q. Of the lagging outline for the 13 6-by-9-by-12 vertical single fire and bilge pump, 14 correct? 15 A. Lagging and outline, yes. 16 Q. And the lagging and outline for 17 6-by-9-by-12 vertical single fire and bilge pumps 18 installed upon the USS Bausell, correct? 19 A. Yes. 20 Q. Again, it shows the range of DD-829 21 to DD-849, correct? 22 A. Yes. 23 Q. And the purchase order number 24 A-17909, correct? 25 A. Yes. 1 Pumps puts together, correct? 2 A. Yes. 3 Q. And this is intended show the 4 customer what the customer must do with this pump 5 to properly install it and for it to properly 6 operate, correct? 7 MS. PERRITANO: Objection. 8 A. In a manner of speaking, yes. 9 Q. (By Mr. Iola) In other words, if the 10 customer ignored this lagging and outline 11 drawing, would this pump work effectively? 12 MS. PERRITANO: Objection, if you 13 know. 14 A. They wouldn't know how to -- how to 15 run the piping, so that it would run properly. 16 Q. (By Mr. Iola) So the customer has to 17 hook up the pump in accordance with these 18 specifications to properly work and maintain the 19 product that you're selling them, correct? 20 MS. PERRITANO: Objection. 21 A. Yes. 22 Q. (By Mr. Iola) And Warren knows that 23 at the time these drawings are made by Warren, 24 correct? 25 MS. PERRITANO: Objection, beyond the Page 98 Page 100 1 Q. Which we previously discussed is 1 scope, irrelevant. 2 exactly the order number that we previously 2 A. I don't know what Warren's thinking 3 marked as Exhibit Number -- 3 was at that time. 4 MS. PERRITANO: I believe it was 7. 4 Q. (By Mr. Iola) Well, when Warren 5 Q. (By Mr. Iola) 7, correct? 5 makes these drawings, Warren understands that the 6 A. Yes. 6 pump must be installed and lagged in accordance 7 Q. This is a lagging and outline, 7 with these or they wouldn't bother to make the 8 correct? 8 drawings, right? 9 A. Yes. 9 MS. PERRITANO: Objection, relevance, 10 Q. What is a lagging and outline? 10 beyond the scope. 11 A. Well, the outline shows all the 11 A. This is the information the customer 12 critical dimensions of the size of the pump. The 12 would need to make sure it was installed 13 lagging is the metal covering the steam cylinder. 13 properly. 14 Q. And the purpose of this drawing or 14 Q. (By Mr. Iola) But this information 15 these two pages is to do what? 15 comes from Warren, correct? 16 A. To show the customer the exact sizes 16 A. Yes. 17 and locations of all pertinent information that 17 Q. Warren knows it's giving the customer 18 they would need, once the pump was delivered to 18 this information, correct? 19 them. 19 A. Yes. 20 Q. This drawing was made when? 20 Q. Warren is knowledgeable about 21 A. This one was November of 1940. 21 educating the customer about the use of this 22 Q. And it was approved by the Bureau of 22 pump, correct? 23 Ships when? 23 MS. PERRITANO: Objection, beyond the 24 A. March 20th, 1941. 24 scope. 25 Q. And this is a drawing that Warren 25 A. Yes. 25 (Pages 97 to 100) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 101 Page 103 1 Q. (By Mr. Iola) Warren identifies a 2 list of material to be used on this pump, 3 correct? 4 A. Part -- Part of the list of 5 materials, yes. 6 Q. Part of the list of materials, right? 7 A. Yes. 8 Q. Part of the list of materials 9 includes material part number 232, correct? 10 A. Yes. 11 Q. And what is material part number 232? 12 A. Asbestos metallic cloth ring. 13 Q. And what do you understand asbestos 14 metallic cloth ring is? 15 MS. PERRITANO: Objection, if you 16 know. 17 A. Well, there's a further description 18 under remarks. 19 Q. (By Mr. Iola) And what does that 20 say? 21 A. It's 1/16th-by-one-inch wide. 22 Q. And what is the type of material? 23 A. The description on the drawing is 24 asbestos and it's material spec 33P2. 25 Q. And what does that mean, that the 1 a balloon number that's called that's item 232. 2 It goes in the area around the -- between the 3 cylinder and this web, as a cushion between the 4 cylinder and the web and the metal web. 5 Q. And in somebody's writing it says 6 1/16-inch thick wide asbestos cloth ring, 7 correct? 8 A. Yes. 9 Q. There's two of those on the part 10 list, correct? 11 A. That is correct. 12 Q. Part number 233 is insulating 13 material, correct? 14 A. Yes. 15 Q. And there's not a quantity and the 16 material is listed as 85 percent magnesia, 17 correct? 18 A. Yes. It's further described as 19 specification 32M-2. 20 Q. And what does that mean to you? 21 A. That was the naval specification. 22 Q. And do you have an understanding of 23 what 85 percent magnesia insulation is? 24 Ms. PERRITANO: Objection, beyond the 25 scope. Page 102 Page 104 1 asbestos metallic cloth ring is asbestos? 1 A. Yes. 2 MS. PERRITANO: Objection. What do 2 Q. (By Mr. Iola) What is your 3 you mean what does it mean? 3 understanding of what that is, sir? 4 Q. (By Mr. Iola) What does it mean to 4 MS. PERRITANO: Objection, beyond the 5 you, when you read that? 5 scope. 6 MS. PERRITANO: Objection, beyond the 6 A. It's an asbestos material. 7 scope, relevance. What something means to this 7 Q. (By Mr. Iola) Okay. And it's an 8 witness -- 8 asbestos material that is listed on the list of 9 Q. (By Mr. Iola) You can answer. If he 9 material by Warren Steam Pump Company, regarding 10 knows, he can answer. You got an objection. You 10 the vertical single fire and bilge pump, correct? 11 can answer. 11 A. Yes. 12 MR. PERRITANO: I do have an 12 MS. PERRITANO: Objection. 13 objection. And I want to just finish it, please. 13 Q. (By Mr. Iola) And if we look on 14 It is not what -- What his understanding is, is 14 drawing 238 and then extending over to drawing 15 not relevant for purposes of this deposition. If 15 239, we have a drawn out schematic of where the 16 you have an understanding of what that means, go 16 85 percent magnesia asbestos insulation is to go 17 ahead. 17 on the pump, correct? 18 A. I mean, I can only go by what the 18 A. Yes. 19 description on the drawing is. Either it was 19 Q. And we see that about a quarter of 20 made out of asbestos or contained asbestos. 20 the way down on 238 and continuing over to 239, 21 Q. (By Mr. Iola) Where does that part 21 where it says insulation around that block kind 22 go on the drawing? 22 of square, correct? 23 A. It goes under -- Need to look at 23 A. Yes. 24 00239 drawing. On the area that you see that has 24 Q. That is the 85 percent magnesia 25 the webbing on it, it goes -- you'll see there's 25 insulation, correct? 26 (Pages 101 to 104) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 105 Page 107 1 A. It's inside of that, yes. 1 the drawing. 2 Q. Right. It's inside of that for a 2 A. Yeah, it's not -- That part of it is 3 number of inches, correct? 3 not identified. 4 A. Yes. 4 Q. (By Mr. Iola) Okay. On 239, there's 5 Q. And approximately how many inches of 5 a marker that says insulation 6 asbestos 85 magnesia insulation are we talking 6 four-and-three-eighths inch, correct? 7 about right there? 7 MS. PERRITANO: Give me one second to 8 MS. PERRITANO: Objection, if you can 8 find 239, please. 9 tell. 9 A. Yes. Yes. 10 A. A cylinder length, according to the 10 Q. (By Mr. Iola) And that is a space of 11 drawing is 15-and-a-half inches and three inches 11 four-and-three-eighths inches that is filled up 12 deep. 12 with insulation? 13 Q. (By Mr. Iola) So about three inches 13 MS. PERRITANO: Objection, if you 14 of asbestos 85 percent magnesia; is that correct? 14 know. 15 MS. PERRITANO: Objection. 15 A. According to the drawing. 16 A. On the drawing, yes. 16 Q. (By Mr. Iola) And that's 17 Q. (By Mr. Iola) Okay. And the drawing 17 four-and-three-eighths inches that's filled up 18 is what we go by, right? 18 with 85 magnesia asbestos insulation, correct? 19 A. Yes. 19 MS. PERRITANO: Objection. 20 Q. And that part where it's being 20 A. Again, the drawing so noted. 21 insulated, is what? 21 Q. (By Mr. Iola) But the drawing is 22 A. Inside of that is the steam cylinder. 22 what Warren presents to the customer, correct? 23 Q. So that's the steam cylinder and then 23 A. Yes. 24 on the outside of the steam cylinder is the 24 Q. Who puts this insulation on the 25 asbestos insulation, correct? 25 product? Page 106 Page 108 1 A. And outside of that is the lagging. 2 Q. And the lagging is what? 3 A. Is sheet metal. 4 Q. And the lagging is installed where? 5 A. Location or on the pump? 6 Q. On the pump? 7 A. It's installed over the insulation. 8 Q. And location is anywhere there's the 9 insulation, you have lagging on the outside of 10 it, correct? 11 A. Yes. 12 Q. In addition, there's various arrows 13 on 238 and 239 drawings that show insulating 14 material of 85 percent magnesia smooth and 15 pointed with plastic, correct? 16 A. Yes. 17 Q. And one of the arrows shows an inch 18 and an eighth-inch of that, correct? 19 A. Yes. 20 Q. One of the arrows shows -21 A. Well, can -- That inch-and-an-eighth 22 is the size of the cover that goes over that. 23 Q. Okay. And how much insulation is 24 there? 25 MS. PERRITANO: If you can tell from 1 A. Warren. 2 Q. Okay. And the insulation is put on 3 the product at Warren's facility, correct? 4 A. Yes. 5 Q. So Warren actually has to purchase 6 85 percent magnesia asbestos insulation to put on 7 the pump, before it ships it out the door, 8 correct? 9 MS. PERRITANO: Objection. 10 A. Yes. 11 Q. (By Mr. Iola) It's a component part 12 of the manufacturer of the pump, correct? 13 A. Yes. 14 Q. And so Warren then puts the metal -15 metal covering over the 85 percent magnesia 16 asbestos insulation to protect the insulation, 17 for whatever purpose, when it ships the product 18 out the door, correct? 19 MS. PERRITANO: Objection, compound. 20 A. Yes. 21 Q. (By Mr. Iola) In other words, the 22 metal covering, known as the lagging, goes over 23 the insulation containing asbestos, correct? 24 A. Yes. 25 Q. Warren workers actually installed the 27 (Pages 105 to 108) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 109 Page 111 1 asbestos insulation on these pumps, correct? 1 correct? 2 MS. PERRITANO: On the particular 2 A. Depends on what they wanted to do. 3 pumps at issue in this case? 4 Q. (By Mr. Iola) Yes, sir. 3 MS. PERRITANO: Objection, overly 4 broad. 5 A. Yes. 6 Q. Do you know any protection that the 5 Q. (By Mr. Iola) Right, but if they 6 were performing maintenance, for instance, on 7 Warren workers wore when they were using and 7 this area of the pump, correct? 8 handling asbestos-containing insulation? 8 A. You would not have to - 9 MS. PERRITANO: Objection, beyond the 9 MS. PERRITANO: Objection as to the 10 scope. To the extent you're asking about these 10 use of the term "maintenance". 11 particular pumps -12 Q. (By Mr. Iola) If you know. 11 A. You would not have to tear through 12 the insulation to get there. 13 MS. PERRITANO: -- for this 13 Q. (By Mr. Iola) Okay. How would you 14 particular ship, the witness may answer. 14 get there? 15 A. I haven't -- I haven't seen any 15 A. You could remove the cover, this cap 16 documentation or anything to say what they might 16 piece and get to the cylinder that way. 17 have done. 17 Q. Okay. And if you remove the cover or 18 Q. (By Mr. Iola) Do you know where 18 the cap piece to get to the cylinder, you would 19 Warren Steam Pump Company purchased the 19 disturb the seal, correct? 20 85 percent magnesia asbestos insulation that went 20 MS. PERRITANO: Objection. 21 on these fire and bilge pumps that were installed 21 A. You'd have to take the screws out, 22 on the USS Bausell? 22 yes. 23 A. No, I do not. 23 Q. (By Mr. Iola) And you would have to 24 Q. There's another arrow on drawing 239 24 tear out this asbestos cloth ring? 25 that indicates three inches of insulation at the 25 A. No. Page 110 Page 112 1 bottom, I believe, correct? 2 MS. PERRITANO: Give me one second, 3 please. Thank you. 4 A. Yes. 5 Q. (By Mr. Iola) And that's an 6 additional three inches of 85 percent magnesia 7 asbestos insulation, correct? 8 MS. PERRITANO: Objection. 9 A. Yes. 10 Q. (By Mr. Iola) Now, if maintenance 11 had to be done on this part of the pump, the fire 12 and bilge pump, one would have to tear through 13 this insulation, correct? 14 MS. PERRITANO: Objection. Can you 15 define maintenance? 16 Q. (By Mr. Iola) Any type of work 17 maintenance? 18 MS. PERRITANO: Objection. The 19 question - 20 A. Not necessarily. 21 MS. PERRITANO: -- is overly broad. 22 Q. (By Mr. Iola) If someone wanted to 23 get into this part of the pump that was insulated 24 with asbestos, they would have to somehow tear 25 through the asbestos-containing insulation, 1 MS. PERRITANO: Objection. 2 Q. (By Mr. Iola) It would remain 3 intact? 4 A. Yes. 5 Q. And if you had to do any work on the 6 exterior where the insulation was, you would have 7 to get into that, as well, correct? 8 MS. PERRITANO: Objection. 9 A. I don't understand your question. 10 Q. (By Mr. Iola) Okay. If the 11 individual who was performing the work saw the 12 metal lagging and needed to come in that way, you 13 would remove the metal lagging first, correct? 14 MS. PERRITANO: Objection. I'm going 15 to object to the extent that you are asking the 16 witness to speculate as to what might or might 17 not have occurred. 18 MR. IOLA: If he doesn't know, he 19 simply needs to say that. 20 MS. PERRITANO: And he's not here to 21 offer testimony as to hypothetical maintenance 22 and/or other work that may or may not have been 23 done -24 Q. (By Mr. Iola) Mr. Doktor, are you - 25 MS. PERRITANO: -- on these pumps. 28 (Pages 109 to 112) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 113 Page 115 1 Q. (By Mr. Iola) You're not going to 1 MS. PERRITANO: Objection. Do not 2 testify at the time of the trial in this case 2 answer that question. We're talking about a 3 about any maintenance or repair work done on the 3 hypothetical. I would advise you not to answer 4 fire and bilge pump, correct? 5 MS. pErRITANO: Objection, to the 4 that. 5 Q. (By Mr. Iola) Are you refusing to 6 extent we have not made a determination yet as to 6 answer? 7 the extent of Mr. Doktor's testimony at trial. 7 A. Yes. 8 At present, we do not have such a plan. 8 MR. IOLA: Okay. We'll certify that 9 Q. (By Mr. Iola) Okay. Can you 9 one. 10 personally testify, from your knowledge, about 10 Q. (By Mr. Iola) Fire and bilge pumps 11 the nature of how maintenance work would be 11 do what, sir? 12 performed upon these pumps, fire and bilge 12 A. Provide fluid to the fire main system 13 pumps -- 13 in fire condition or would pump out the bilge. 14 MS. PERRITANO: Generally? 14 Q. How many fire and bilge pumps are 15 Q. (By Mr. Iola) -- on board the USS 15 there on board the USS Bausell? 16 Bausell? 16 A. Four. 17 A. Depends on what maintenance they want 17 Q. Four different fire and bilge pumps, 18 to do. 18 correct? 19 Q. In reading through any of the 19 A. When you say different? 20 testimony of Mr. Forest, or anybody else, the 20 Q. Separate entities? 21 interrogatory answers in this case, anything of 21 A. Yes. 22 the nature, have you seen any discussion of work 22 Q. Are they all located in the same 23 performed on this pump? 23 place? 24 A. Not that I can recall, no. 24 A. I do not know. 25 Q. Do you have personal knowledge of how 25 Q. Each fire and bilge pump is driven Page 114 Page 116 1 maintenance work was performed aboard the fire 1 how, by what kind of power system? 2 and bilge pumps aboard the USS Bausell, during 2 A. It's a steam pump, so it uses steam 3 the time period when Mr. Gudmundson was on board 3 as its prime mover. 4 that ship? 4 Q. Is it then driven by a turbine? 5 A. No. 5 A. No. 6 Q. You weren't there, correct? 6 Q. Pure steam? 7 A. Correct. 7 A. Yes. 8 Q. You didn't oversee the others that 8 Q. Is the fire pump separate and 9 were his shipmates on board the ship, who might 9 distinct from the bilge pump or is it called one 10 have performed any maintenance and repair work, 10 fire and bilge pump together? 11 correct? 11 A. It's called -- It's together, serves 12 A. Correct. 12 several functions. 13 Q. You can't give any testimony if any 13 Q. The asbestos cloth ring is also 14 of those shipmates comes forward to say whether 14 installed at the Warren facility, correct? 15 that shipmate is saying -- is true and correct or 15 A. Yes. 16 not, because you weren't there, right? 16 Q. And the product, the fire and bilge 17 MS. PERRITANO: Objection, that calls 17 pump, is shipped out of the Warren facility with 18 for a hypothetical. We don't have any of his 18 the asbestos cloth ring already included, 19 shipmates that have come forward yet with 19 correct? 20 specific testimony. If you have specific 20 A. Yes. 21 testimony that you would like to show this 21 Q. Is there a handbook or an operation 22 witness and ask him to take a look at that, 22 manual that goes out the door with the fire and 23 that's fine, but he's not going to say what might 23 bilge pump to the customer? 24 happen in the future. 24 A. If it was requested. 25 Q. (By Mr. Iola) You can answer. 25 Q. Okay. Have you come across any 29 (Pages 113 to 116) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 117 Page 119 1 manual on fire and bilge pumps that was part of 2 what was sold and installed on the USS Bausell? 3 A. Not that I've seen, no. 4 Q. If one is requested, what types of 5 things are typically inside that manual? 6 MS. PERRITANO: Requested by the 7 customer? 8 MR. IOLA: Sure. 9 MS. PERRITANO: I didn't know if you 10 meant you. Objection, to the extent it's beyond 11 the scope of the depo, but go ahead. 12 A. Whatever their purchase order would 13 require. 14 Q. (By Mr. Iola) Have you made an 15 attempt to try to locate a manual, with respect 16 to what was sold to the USS Bausell in terms of 17 fire and bilge pumps? 18 A. We have conducted a search, yes. 19 Q. And you didn't find anything, 20 correct? 21 A. No, we did not. 22 Q. And you looked everywhere you 23 possibly could think of, correct? 24 A. Yes, sir. 25 Q. And did you contact the Naval 1 record for a minute? 2 MR. IOLA: Yes. 3 VIDEOGRAPHER: The time is 10:27 4 (sic). We're off the record. 5 (Whereupon, an off-the-record 6 discussion was held.) 7 VIDEOGRAPHER: The time is 11:31 a.m. 8 This is cassette 2 in the deposition of Roland 9 Doktor. We're on the record. 10 Q. (By Mr. Iola) Mr. Doktor, you 11 understand we're back on the record and you're 12 still under oath? 13 A. Yes. 14 Q. We have now located, in fact, the 15 Warren Steam Pump Company instructions for 16 operation and maintenance manual of steam-driven 17 reciprocating pumps that was produced in the 18 initial production in this case, with respect to 19 the Gudmundson case and has a Bates stamp number 20 on the lower right corner. Will you read that 21 into the record, please? 22 A. WP-IL 00190 and it continues through 23 WP-IL 00212. 24 (Whereupon, Exhibit 10 was marked.) 25 Q. (By Mr. Iola) And this is entitled Page 118 Page 120 1 archives to determine if there was a handbook 1 Warren Steam Pump Company, Incorporated, Warren, 2 there on fire and bilge pumps that was sold by 2 Massachusetts, instructions for operation and 3 Warren Steam Pump Company? 3 maintenance of steam-driven reciprocating pumps, 4 A. No. 4 correct? 5 MS. PERRITANO: Objection. 5 A. Yes. 6 Q. (By Mr. Iola) Are you aware that you 6 Q. And it covers both fire and bilge 7 have previously produced in other litigation an 7 pumps and emergency feed pumps, correct? 8 instruction manual regarding fire and bilge 8 A. Yes. 9 pumps? 9 Q. And it covers vessels, including 10 A. It's possible. 10 DD-845, the USS Bausell, which was made at the 11 Q. Is there a distinction in your mind 11 Bath Iron Works Corporation, correct? 12 between fire and bilge pumps that are aboard 12 A. Yes. 13 other ships manufactured by Warren Pump Company 13 Q. Is there anywhere in this manual that 14 and the one that was on board the USS Bausell? 14 identifies to the customer a warning or caution 15 MS. PERRITANO: Objection. 15 about asbestos on or in the pump? 16 A. There could be, I don't know. 16 MS. PERRITANO: Objection, to the 17 Q. (By Mr. Iola) Okay. But your 17 extent it's beyond the scope. Why don't you take 18 testimony, as you sit here today, is you never 18 a minute to look through it? 19 located the instruction manual by Warren Steam 19 A. Yeah, can I? 20 Pump Company, Incorporated for operation and 20 Q. (By Mr. Iola) Absolutely. 21 maintenance of steam-driven reciprocating pumps 21 MS. PERRITANO: Relevance, also. 22 that were sold to the United States Navy or the 22 A. I don't see anything identified as a 23 Government for installation on board the USS 23 caution or warning. 24 Bausell DD-845, correct? 24 Q. (By Mr. Iola) In fact, there's 25 MS. PERRITANO: Can we go off the 25 nothing in the document that even states the 30 (Pages 117 to 120) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 121 Page 123 1 asbestos insulation being used on the fire and 1 witness may answer. 2 bilge pump, correct? 2 A. I have not seen any documentation. 3 MS. PERRITANO: Objection, relevance, 3 Q. (By Mr. Iola) Did you know, 4 beyond the scope. 4 Mr. Doktor, at the time you were signing the 5 A. I did not see anything. 5 Verifications to the Interrogatories in the Wise 6 Q. (By Mr. Iola) There's nothing that 6 & Julian Madison County cases, that these fire 7 states in the Warren Steam Pump Company operation 7 and bilge pumps contained 85 percent magnesia 8 and maintenance manual for fire and bilge pumps, 8 asbestos insulation? 9 regarding the care and maintenance of the 9 MS. PERRITANO: Objection. 10 85 percent magnesia asbestos insulation around 10 A. I don't know what documents I looked 11 the steam cylinder on the fire and bilge pump, 11 at during that time period. 12 correct? 12 Q. (By Mr. Iola) So as you sit here 13 MS. PERRITANO: Objection, relevance, 13 today, you can't testify under oath to the 14 beyond the scope. 14 Members of this Jury, that you saw all these 15 A. No. 15 drawings and had all this knowledge in your mind 16 Q. (By Mr. Iola) Are you aware, as you 16 at the time you executed the Verification to the 17 sit here today, of any subsequent period of time 17 Affidavit -- to the Interrogatory Answers, 18 where Warren Steam Pump Company warned or issued 18 correct? 19 a caution regarding the asbestos insulation 19 MS. PERRITANO: Objection. I 20 around the steam cylinder of the fire and bilge 20 think -- I may be wrong, but I think that the 21 pumps that were installed on the USS Bausell? 21 interrogatories are not necessarily in the 22 MS. PERRITANO: Objection, only to 22 Gudmundson case, so I don't know that it's fair 23 the extent that we're dealing with the Bausell. 23 to relate to the interrogatories to this case. 24 Was that the question? Are you talking about the 24 Q. (By Mr. Iola) You can answer. 25 time frame associated with the pumps on the 25 MS. PERRITANO: With that Page 122 Page 124 1 Bausell, while Mr. Gudmundson was on board, 2 correct? 3 MR. IOLA: Well, the pumps on the 4 Bausell we're dealing with. 5 MS. PERRITANO: What was -- Can I 6 have the question, again? 7 MR. IOLA: Sure. 8 MS. PERRITANO: I'm sorry. 9 Q. (By Mr. Iola) Do you know of any 10 other information in the form of a caution or 11 warning that was ever issued, regarding the fire 12 and bilge pumps installed on the USS Bausell, 13 from their date of installation forward that 14 cautioned or warned about the dangers or hazards 15 of asbestos? 16 MS. PERRITANO: I'm going to object 17 to the extent that the question seems to suggest 18 a time period beyond that which we are dealing 19 with in the Gudmundson case. I'm also going to 20 object to the extent that the question assumes 21 that Warren had any duty to warn, in this 22 particular case, or any duty to warn in general. 23 To the extent that the question seeks information 24 concerning the time period that Mr. Gudmundson 25 was on the Bausell and times prior to that, the 1 qualification, if you know, you can answer. 2 A. I don't know. 3 Q. (By Mr. Iola) The interrogatory 4 answers have citations in your answers to the use 5 of asbestos-containing products; do they not? 6 MS. PERRITANO: Objection, beyond the 7 scope. A. Could you rephrase that? Q. (By Mr. Iola) The interrogatory 10 answers have sentences which reflect that Warren 11 products may have contained asbestos, correct? 12 MS. PERRITANO: Objection, beyond the 13 scope, relevance. You can answer that generally. 14 A. Generally, yes. 15 Q. (By Mr. Iola) I mean the 16 interrogatories clearly state that some of the 17 pumps had gasket or packing components that 18 contained asbestos, right? 19 MS. PERRITANO: Objection, relevance, 20 beyond the scope. 21 A. Yes. 22 Q. (By Mr. Iola) And that's consistent 23 with what we've looked at in the drawings, so 24 far, correct? 25 A. Yes. 31 (Pages 121 to 124) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 125 Page 127 1 Q. On board the units that were sold to 2 the United States Navy for installation on the 3 USS Bausell, correct? 4 A. Yes. 5 Q. And in addition, there's mention of 6 other asbestos products on board some of the 7 vessels, pumps, et cetera, that were sold to the 8 United States Government for installation, 9 correct? 10 MS. PERRITANO: Objection, relevance, 11 beyond the scope. 12 A. Yes. 13 Q. (By Mr. Iola) The next document I 14 would like to have you take a peek at, 15 Mr. Doktor - 16 A. Do you want to leave this -17 Q. Yeah, please -- is from the 18 documents, last night, the supplemental group, it 19 would be WP -- Let me look exactly. WP-IL, it 20 looks like 0012 and the succeeding pages, which I 21 believe go through 0015. 22 (Whereupon, Exhibit 11 was marked.) 23 Q. (By Mr. Iola) Let me hand you what 24 we've marked as Deposition Exhibit Number 11, 25 sir, which is Bates stamp number pages WP-IL b 1 Q. The emergency feed pump kicks in if 2 the main feed pump goes down for any reason, 3 correct? 4 A. It doesn't kick in automatically. It 5 has to be started. 6 Q. The emergency feed pump is run by 7 what kind of power unit? 8 A. It's direct-acting steam. 9 Q. Deposition Exhibit Number 11 is dated 10 November 27, 1943, correct? 11 A. Yes. 12 Q. Ordered by Warren Engineering, 13 correct? 14 A. Yes. 15 Q. For Gibbs and Cox, the naval 16 architect, correct? 17 A. Yes. 18 Q. For shipment to the Bath Iron Works 19 in Bath, Maine, correct? 20 A. Yes. 21 Q. Covers ships numbered DD-829 through 22 849, correct? 23 A. Yes. 24 Q. The USS Bausell is included as 25 DD-845, correct? Page 126 Page 128 1 00012 through 00015. Do you see those? 1 A. Yes. 2 A. Yes. 2 Q. In total this is a work order for 42 3 Q. And those deal with what, sir? 3 9-by-6-and-a-half-inch-by-16-inch vertical single 4 A. This is the order for emergency feed 4 emergency feed pumps, correct? 5 pumps. 5 A. Yes. 6 Q. And the order number is what? 6 Q. How many of these vertical single 7 A. A-17908. 7 emergency feed pumps were installed upon the USS 8 Q. These are emergency feed pumps, 8 Bausell? 9 correct? 9 A. Two. 10 A. Yes. 10 Q. How do you know that? 11 Q. What's an emergency feed pump? 11 A. There was 21 ships involved and the 12 A. If the primary feed pump should go 12 order was for 42. 13 down, due to casualty, this pump would be able to 13 Q. If you go to the second page of the 14 pick up some of the boiler load. 14 document, WP-IL-00013, we see a stamp for 15 Q. For purposes of the Jury, what's a 15 August 6, 1945 and underneath that it says 16 feed pump? 16 DD-845, two pumps, correct? 17 A. It supplies the water back into the 17 A. Yes. 18 boiler after it's been used in the main engines. 18 Q. And what is the sentence underneath 19 Q. It's a recirculating system, correct? 19 that, if you know? 20 A. The steam system is, yes. 20 A. I can't read what it says. 21 Q. And so for purposes of the Jury, the 21 Q. Okay. So this indicates that, at 22 idea is if you use the water somewhere else on 22 least on August 6, 1945, two 23 the vessel, it circulates back through the boiler 23 9-inch-by-6-and-a-half-inch-by-16-inch vertical 24 again, correct? 24 single emergency feed pumps were installed upon 25 A. Yes, in simplest terms.__________________ 25 the USS Bausell, correct? 32 (Pages 125 to 128) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 129 Page 131 1 A. Yes. 2 Q. Do you know where they were 3 installed? 4 A. No, I do not. 5 Q. Do you know if they were installed 6 side-by-side? 7 A. No, I do not. 8 Q. Do you know if they were installed in 9 each engine room on board the ship? 10 A. No, I do not. 11 Q. Do you know if the emergency feed 12 pump is typically installed in the engine room on 13 board the ship? 14 A. It would not be -15 MS. PERRITANO: Objection, if you 16 know. 17 A. It would not be in the engine room. 18 Q. (By Mr. Iola) It would not be? 19 A. No. 20 Q. And why is that? 21 A. It's related to the boiler. 22 Q. And so what's your testimony about 23 where it would be installed? 24 A. It would be located in the boiler 25 room. 1 MS. PERRITANO: Objection, beyond the 2 scope, hypothetical, calls for an opinion. 3 A. I haven't seen the -- I haven't seen 4 the documents, so I wouldn't want to render an 5 opinion without seeing them. 6 Q. (By Mr. Iola) But if the naval 7 documents from the U.S. Navy indicate that that's 8 where these pumps were installed, you don't have 9 any reason to disbelieve that, do you? 10 MS. PERRITANO: Objection. 11 A. I mean, again, I haven't seen the 12 documents, but... 13 Q. (By Mr. Iola) Okay. But 14 hypothetically, if that's what they say? 15 A. Then that's probably correct. 16 Q. In other words, those documents 17 probably cover the situation better than your 18 recollection or speculation, correct? 19 MS. PERRITANO: Objection. 20 A. I would assume so, yes. 21 Q. (By Mr. Iola) Back to Deposition 22 Exhibit Number 10, which is the order for the 23 vertical single emergency feed pumps? 24 A. 11. 25 Q. I'm sorry, Number 11. Page 130 Page 132 1 Q. Have you looked at any of the 1 A. Sorry. 2 documents in the naval archives concerning the 2 Q. Correct. It says 42 3 installation of pumps and various other machinery 4 on board the USS Bausell? 3 9-inch-by-6-and-a-half-inch-by-16-inch vertical 4 single piston pumps, correct? 5 A. Not that I'm aware of. 5 A. Yes. 6 Q. Do you have any idea what the naval 7 archives documents at the Bureau of Ships 6 Q. It says they contain John Crane 7 molded ring stuffing box packing, correct? 8 indicates where the emergency feed pump was 8 A. Yes. 9 installed? 9 Q. It says they contain Durabla valves, 10 MS. PERRITANO: Objection, relevance. 10 correct? 11 A. No, I do not. 11 A. Yes. 12 Q. (By Mr. Iola) Do you know of anyone 12 Q. It says no air chambers, correct? 13 at Warren Pumps who has undertaken an 13 A. Yes. 14 investigation to determine what the naval 15 archives records of the USS Bausell indicate 14 Q. Steam cylinders and valve chests to 15 be suitably lagged and insulated, correct? 16 about the emergency feed pumps that were 16 A. Yes. 17 installed? 17 Q. That seems very similar to what we 18 MS. PERRITANO: Objection, relevance, 18 saw in the fire and bilge pumps, correct? 19 and it assumes that we have a duty to do that. 19 A. Yes. 20 A. I do not know. 20 Q. Now, if we turn our attention from 21 Q. (By Mr. Iola) Do you have any 21 Deposition Exhibit Number 10 -- I mean Number 11, 22 reason, hypothetically, if those records indicate 22 I'm sorry, the order document on vertical single 23 that the emergency feed pumps were installed in 23 emergency feed pumps and we look at the drawings 24 each engine room on board the USS Bausell, do you 24 we have on vertical single emergency feed pumps, 25 have any reason to dispute that? 25 do you have any of those drawings in front of 33 (Pages 129 to 132) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 133 Page 135 1 you? 1 the order is correct. 2 A. Yes. 2 Q. And so this is an accurate drawing 3 Q. Do you have any drawings on spare 3 for what was installed on the USS Bausell? 4 parts, regarding vertical single emergency feed 4 A. I believe so, even though the hull 5 pumps? 5 numbers might be indicated incorrectly. 6 A. I have the outline lagging and stroke 6 Q. Okay. On the list of materials, are 7 index and I have the sectional assembly list of 7 there any asbestos-containing materials for the 8 materials and spares. 8 vertical single emergency feed pumps? 9 Q. Okay. On the sectional assembly list 9 A. Give me a second. 10 and spares? 10 Q. You bet. 11 A. That's a mouthful, isn't it? 11 A. Some of this is very difficult to 12 Q. What's the Bates stamp number on that 12 read, because it's such an old drawing. 13 one? 13 MS. PERRITANO: It's also pretty 14 A. WP-IL 00246 and WP-IL 00247. 14 small print. 15 Q. Okay. Is that one drawing that's too 15 A. I don't see anything identified on 16 big to fit on one page? 16 this -- on this particular one in that capacity 17 A. Yes, it is. 17 now. Maybe you can find something. I'm not 18 Q. Okay. Let's mark that as Deposition 18 picking it up. The further away I go, the harder 19 Exhibit Number 12, if you would, please, sir. 19 it is to read. 20 (Whereupon, Exhibit 12 was marked.) 20 Q. (By Mr. Iola) All right. So we 21 Q. (By Mr. Iola) And that again, for 21 don't see anything on the drawing of the 22 purposes of the record, is titled what, sir? 22 sectional assembly list and spares Bates stamp 23 A. Sectional assembly list of material 23 Number 246 and 247 that we've marked as Exhibit 24 and spares 9-by-6-by-16 vertical single emergency 24 Number 12 that contained asbestos, correct? 25 feed pump. 25 A. The drawing does not indicate that. Page 134 Page 136 1 Q. Does that cover vertical feed pumps 1 Q. Let's look at the drawing for the 2 that were installed on the USS Bausell DD-845? 2 outline and lagging and stroke index for the 3 MS. PERRITANO: Do you need this one? 3 9-inch-by-6-and-a-half-by-16-inch vertical single 4 THE WITNESS: Yeah, it's easier to 4 emergency feed pump that it's Bates stamped 5 find it that way. 5 number WP-IL 232 and 233. 6 MS. PERRITANO: This is not part of 6 MS. PERRITANO: Do you want to make 7 it, right? That's the next one? 7 that the next exhibit? 8 THE WITNESS: That's the next one. 8 MR. IOLA: I'm going to ask him a 9 Q. (By Mr. Iola) Order Number A-17908. 9 question first. 10 A. That order is on here. However, it 10 Q. (By Mr. Iola) Do you see that 11 doesn't correspond to the appropriate hull 11 document, sir? 12 numbers. 12 A. Yes. 13 Q. It does not? 13 Q. Is that one drawing that's too large 14 A. Unless I'm reading this -- This says 14 for a single page and consequently is made up of 15 DD-859 to DD-849 for the A-17. 208, is that the 15 two pages? 16 one? 16 A. Yes, it is. 17 Q. 908. 17 Q. Okay. Let's mark that one drawing, 18 A. 908. I mean, like I said, there is a 18 which is WP-IL 232 and 233 entitled, outline 19 little discrepancy between the order and the 19 lagging and stroke index 20 drawing. 20 9-inch-by-6-and-a-half-inch-by-16-inch vertical 21 Q. So do you believe this drawing 21 single emergency feed pump as Deposition Exhibit 22 appropriately reflects the sectional assembly 22 Number 13. 23 list and spares of vertical single emergency feed 23 (Whereupon, Exhibit 13 was marked.) 24 pumps that were installed on the USS Bausell? 24 Q. (By Mr. Iola) This is the outline 25 A. I think this is correct. I believe 25 and lagging schedule for the vertical single 34 (Pages 133 to 136) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 137 Page 139 1 emergency feed pumps, correct? 2 A. Yes. 3 Q. And which includes the vertical 4 single emergency feed pumps installed upon the 5 USS Bausell DD-845, correct? 6 A. Yes. 7 Q. We know that, because the column says 8 DD-829 to 849, correct? 9 A. Yes. 10 Q. And it says Order Number A-17908, 11 correct? 12 A. Yes. 13 Q. Which corresponds to Deposition 14 Exhibit 11, which is the order number we 15 previously talked about for the emergency feed 16 pumps, correct? 17 MS. PERRITANO: I believe that was 18 this one. 19 A. Yes. The drawing, okay. I'm sorry. 20 MS. PERRITANO: That's okay. 21 Q. (By Mr. Iola) So when we -- When was 22 this drawing made? 23 A. December 10th, 1940. 24 Q. And it was signed off by the Bureau 25 of Ships when? 1 A. That's correct. 2 Q. It's 85 percent magnesia that you 3 previously testified is asbestos insulation, 4 correct? 5 MS. PERRITANO: Objection, if you 6 know. 7 A. Yes. 8 MS. PERRITANO: Beyond the scope of 9 his knowledge. 10 Q. (By Mr. Iola) We get back to 11 drawings on steam cylinders on the left-hand side 12 of the page, correct? 13 A. Yes. 14 Q. And around the steam cylinder is 15 insulation, correct? 16 A. It is -17 MS. PERRITANO: Take your time. 18 A. There is a note that it is insulated, 19 yes. 20 Q. (By Mr. Iola) And it says insulating 21 material of 85 percent magnesia smooth and 22 painted with plastic, correct? 23 MS. PERRITANO: Objection. 24 A. Pointed with plastic. 25 Q. (By Mr. Iola) Okay. And down from Page 138 Page 140 1 A. March 10th, 1943. 2 Q. And this drawing, on the list of 3 material, it indicates part 232 is an asbestos 4 metallic cloth ring, again, correct? 5 MS. PERRITANO: Objection. 6 A. The description is, yes. 7 Q. (By Mr. Iola) The description is 8 asbestos metallic cloth ring, correct? 9 A. Yes. 10 Q. The number of them wanted is two, 11 correct? 12 A. Yes. 13 Q. Its material is made up of asbestos, 14 correct? 15 MS. PERRITANO: Objection, if you 16 know. 17 A. The drawing says asbestos, yes. 18 Q. (By Mr. Iola) And the remarks say 19 what? 20 A. 1/16th thick by one-inch wide. 21 Q. Okay. Part number 233 is insulating 22 material, correct? 23 A. Yes. 24 Q. It's not listed the total quantity, 25 correct? 1 that, shows a schematic where there's five and 2 five-eighths inches of insulation, correct? 3 A. In the cover, yes. 4 Q. And that's five and five-eighths 5 inches of asbestos-containing 85 percent magnesia 6 insulation, correct? 7 MS. PERRITANO: Objection, to the 8 extent that you know. 9 A. As noted on the drawing. 10 Q. (By Mr. Iola) And then below that is 11 another drawing indicating three inches at the 12 bottom, correct? 13 A. It's the same drawing, but, yes, 14 three inches. 15 Q. Three inches of asbestos 85 percent 16 magnesia insulation, correct? 17 MS. PERRITANO: Objection, to you 18 know -- to the extent you know. 19 A. Yes. 20 MS. PERRITANO: Beyond the scope. 21 Q. (By Mr. Iola) As you testified 22 previously, from your personal knowledge, this 23 85 percent magnesia asbestos insulation was 24 installed at the Warren Steam Pump Company 25 facility, correct? 35 (Pages 137 to 140) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 141 Page 143 1 MS. PERRITANO: Objection, beyond the 1 about any maintenance work that might have been 2 scope. 2 performed on the vertical single emergency feed 3 A. Yes. 3 pump on board the USS Bausell, correct? 4 Q. (By Mr. Iola) Manufactured in 4 MS. PERRITANO: Objection, beyond the 5 Warren, Massachusetts, correct? 5 scope. 6 A. Yes. 6 A. No. 7 Q. And then delivered to the customer at 7 Q. (By Mr. Iola) Do you have any 8 Bath Iron Works, correct? knowledge as to how maintenance work was 9 A. Yes. performed, as a matter of course, on vertical 10 Q. Do you have knowledge as to where 10 single emergency feed pumps that were made 11 Warren Steam Pump Company purchased this asbestos 11 pursuant to this drawing, that's Deposition 12 85 percent magnesia insulation that was used in 12 Exhibit Number 13? 13 the vertical single emergency feed pump? 13 MS. PERRITANO: Objection, relevance, 14 A. No. 14 and beyond the scope. 15 MS. PERRITANO: Particular pump at 15 A. No. 16 issue? 16 Q. (By Mr. Iola) You can't testify in 17 Q. (By Mr. Iola) Sure. 17 front of this Jury at the time of the trial how 18 A. I have not seen any information. 18 an individual would go about making maintenance 19 Q. With respect to all of these vertical 19 work on vertical single emergency feed pumps as 20 single emergency feed pumps that are in this 20 listed in this drawing, correct? 21 drawing listed as Exhibit Number 13, do you know 21 MS. PERRITANO: Objection, beyond the 22 where Warren Steam Pump Company purchased 22 scope. He is not designated for purposes of 23 85 percent magnesia asbestos insulation? 23 today to talk about what types of work may or may 24 MS. PERRITANO: Objection, beyond the 24 not have been done on the pumps at issue in the 25 scope, relevance. 25 case. We haven't made a decision yet as to Page 142 Page 144 1 A. I do not know. 1 whether he might testify as to those areas in the 2 Q. (By Mr. Iola) Are you familiar with 2 future, but he is not here today to talk about 3 asbestos insulation? 3 that. And if we do, we would let you know ahead 4 MS. PERRITANO: Objection, beyond the 4 of time. 5 scope. 5 MR. IOLA: Yeah, I appreciate that, 6 A. No, I'm not. 6 counsel. And for purposes of the record, in 7 Q. (By Mr. Iola) Do you know anybody at 7 addition to letting me know ahead of time, I 8 Warren Pumps who would be more knowledgeable presume that we also would have an agreement for 9 about the purchase of this asbestos insulation me to come back and redepose - 10 for use on the emergency feed pump and 10 MS. PERRITANO: On those issues, 11 previously, the fire and bilge pump that was 11 absolutely. 12 installed aboard the USS Bausell? 12 MR. IOLA: -- Mr. Doktor on those 13 A. No, I can't think of anybody that 13 issues before he walks into the courtroom in 14 would be. 14 Madison County, Illinois. 15 Q. And you haven't located any records, 15 MS. PERRITANO: Yes. 16 sales records, purchase records, which indicate 16 Q. (By Mr. Iola) Mr. Doktor, let's turn 17 purchases by Warren Steam Pump Company of these 17 our attention to the documents, supplemental 18 spare parts that contained asbestos, including 18 documents, that were delivered last night, 19 the 85 percent magnesia asbestos insulation, 19 document WP-IL 0004 through 00011, which I 20 correct? 20 believe are the orders for the fresh water pumps, 21 A. That's correct. 21 if you would, please, sir. 22 MS. PERRITANO: For the Bausell? 22 MS. PERRITANO: What did you say, 4 23 A. That's correct. Yes. 23 to 11? 24 Q. (By Mr. Iola) You're not familiar 24 MR. IOLA: Yes. 25 and cannot testify, from your own knowledge, 25 (Whereupon, Exhibit 14 was marked.) 36 (Pages 141 to 144) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 145 Page 147 1 Q. (By Mr. Perritano) Sir, I've handed 2 you what we've marked as Deposition Exhibit 3 Number 14, which is Bates stamp WP-IL b 0004 4 through 00011, which is the order for the fresh 5 water pumps; is that correct? 6 A. Yes. 7 Q. And this order covers the fresh water 8 pumps that were installed on the USS Bausell, 9 correct? 10 A. Yes. 11 Q. And this is order number A-17888, 12 correct? 13 A. Yes. 14 Q. Dated November 11, 1943, correct? 15 A. Yes. 16 Q. And this is a total order for 42 17 2-SED-11 fresh water pumps with motors and 18 controls, correct? 19 A. Yes. 20 Q. And these were 42, two-inch single 21 stage, single suction, all bronze, close 22 connected right-hand centrifugal pumps, type 23 SED-11 with vertical discharge, correct? 24 A. That's the description, yes. 25 Q. How many of these pumps were 1 were installed in each engine room aboard the USS 2 Bausell? 3 A. No, I do not. 4 Q. What was the driving power force 5 behind the fresh water pumps installed on the USS 6 Bausell? 7 A. Electric motor. 8 Q. Do you know who manufactured the 9 electric motor? 10 A. Drawing indicates that it was GE. 11 Q. GE being General Electric? 12 A. Yes. 13 Q. The drawing you're referring to in 14 front of you, sir, is that WP-IL 00243? 15 A. Yes, it is. 16 MR. IOLA: Okay. Let's mark as 17 Deposition Exhibit Number 15, WP-IL 00243. 18 (Whereupon, Exhibit 15 was marked.) 19 Q. (By Mr. Iola) Which appears to be 20 the sectional assembly outline, spare parts and 21 tools for the fresh water pump type 2-SED-11 for 22 Warren Steam Pump Company, which includes the 23 fresh water pumps that were installed on the USS 24 Bausell; is that correct? 25 A. Yes. Page 146 Page 148 1 installed on DD-845, the USS Bausell? 1 Q. And this document consists of only 2 A. That would be two. 2 one page of the drawing; is that correct? 3 Q. If you would, please, turn to the 3 A. Yes. 4 second page which is Bates stamped number WP-IL 4 Q. When was this drawing made? 5 B0005; do you see that, sir? 5 A. This one was made four -- April 8th, 6 A. Yes. 6 1943. 7 Q. Midway down the middle column, almost 7 Q. When was it approved by the Bureau of 8 to the bottom, is an entry dated June 22, 1945, 8 Ships? 9 correct? 9 A. It's very difficult to read, but it 10 A. Yes. 10 looks like January 28, 1944. 11 Q. Which says DD-844 through 5, correct? 11 Q. And all these drawings were made by 12 A. Yes. 12 Warren Pumps, correct? 13 Q. And shows four pumps and four motors, 13 A. Yes. 14 correct? 14 Q. And at that time it was known as the 15 A. Yes. 15 Warren Steam Pump Company, Incorporated, correct? 16 Q. And based on that, you can determine 16 A. Yes. 17 that two pumps were installed on DD-844, correct? 17 Q. And we know it covers the Bausell, 18 A. Yes. 18 because it has DD-829 through 849 and it has the 19 Q. And two pumps were installed on 19 order number A-17858, I believe, correct? 20 DD-845, the USS Bausell, correct? 20 A. 888. 21 A. Yes. 21 Q. 888, I'm sorry. Is that correct? 22 Q. Do you know where the fresh water 22 A. Yes. 23 pumps were installed on the USS Bausell? 23 Q. Okay. And the list of material 24 A. No, I do not. 24 indicates on piece number 15 a 1/32nd-inch thick 25 Q. Do you know if the fresh water pumps 25 gasket that is an asbestos sheet gasket, correct? 37 (Pages 145 to 148) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 149 Page 151 1 A. Yes. 2 Q. Do you know what an asbestos sheet 3 gasket is, sir? 4 A. Yes. 5 Q. What is it? 6 A. It's a flat piece of material. 7 Q. And to make it into a gasket, does it 8 have to be cut? 9 A. Yes. 10 Q. And who cuts it? 11 MS. PERRITANO: Objection, if you 12 know, beyond the scope. 13 A. At our facility, it would be one of 14 our assemblers. 15 Q. (By Mr. Iola) One of your assemblers 16 actually cuts the gasket to fit whatever the 17 device is that the gasket is going between, 18 correct? 19 A. Correct. In this case it's a large 20 donut-looking piece. 21 Q. And a large donut-looking piece, is 22 approximately how large? 23 A. It would be approximately about 13 24 inches in diameter and about an inch thick. 25 Q. And that gasket goes between what? 1 Q. (By Mr. Iola) On the USS Bausell? 2 A. I have not seen any documents, no. 3 Q. Okay. Beyond seeing documents, do 4 you have knowledge that you can testify to the 5 Members of this Jury or is it beyond your 6 knowledge, about the maintenance schedule that 7 might be required to maintain and operate these pumps that we have specifically talked about aboard the USS Bausell? 10 MS. PERRITANO: Objection, beyond the 11 scope. 12 A. I don't know particularly about the 13 pumps on the Bausell. 14 Q. (By Mr. Iola) Good. So you're not 15 going testify at the time of the trial to the 16 Members of the Jury about any particular 17 maintenance schedule that these pumps would 18 require aboard the USS Bausell, correct? 19 MS. PERRITANO: Objection, beyond the 20 scope. As we've stated with respect to the other 21 pumps, depending on what evidence is developed, 22 if we intend to ask Mr. Doktor any questions 23 concerning maintenance procedures that were, in 24 fact, performed on the Bausell and want him to 25 comment on that, we will alert you to that ahead Page 150 Page 152 1 A. It goes between pieces number - 1 of time and give you the opportunity to ask him 2 should be number 1 and 2. Pieces number 1 and 2 2 whatever questions you would like over some 3 the casing and the suction head. 3 objections, potentially. 4 Q. Is that the main entry to the pump? 4 Q. (By Mr. Iola) Mr. Doktor, next I 5 A. Yes. 5 want to turn your attention to the order 6 Q. So any time maintenance work is 6 regarding salt water circulating booster pumps 7 performed on the interior of that pump, that 7 and that is WP-IL b 00021 through WP-IL b 00024, 8 gasket has to be removed, correct? 8 I believe; is that correct, sir? 9 MS. PERRITANO: Objection, beyond the 9 MS. PERRITANO: Give me one second. 10 scope, relevance. 1 0 There you go. 11 A. If they had to go inside the pump, 1 1 (Whereupon, Exhibit 16 was marked.) 12 that is correct. 1 2 Q. (By Mr. Iola) We've handed you what 13 Q. (By Mr. Iola) Does this pump require 1 3 we've marked as Deposition Exhibit Number 16, 14 regular maintenance? 1 4 which is the order number A-17910, dated 15 MS. PERRITANO: Objection, beyond the 1 5 December 15, 1943 for 21, 2-SED-6 pumps complete 16 scope, relevance. If you know. 1 6 with motor for salt water circulating booster 17 A. For the internals, no. 1 7 pumps for emergency diesel generator sets, 18 Q. (By Mr. Iola) Okay. Are you able to 1 8 correct? 19 testify from your personal knowledge or knowledge 1 9 A. Yes. 20 that you've gained from your review of documents 20 Q. What are these, exactly? 21 and material from the company, as to maintenance 21 A. This would supply the cooling water 22 schedules with respect to any of these pumps 2 2 to the emergency diesel generator. 23 we've talked about today? 2 3 Q. And that cooling water would be sea 24 MS. PERRITANO: Objection, beyond the 2 4 water? 25 scope. 2 5 A. Yes.___________________________________ 38 (Pages 149 to 152) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 153 Page 155 1 Q. How many of these salt water 1 MS. PERRITANO: Is 257, is that the 2 circulating booster pumps for emergency diesel 2 other half? 3 generator were on board the USS Bausell DD-845? 3 THE WITNESS: That's the other half. 4 A. One. 4 Q. (By Mr. Iola) Okay. So what we've 5 Q. How do you know that? 5 identified is -- And let's mark for the record as 6 A. The order is for 21 pumps and there's 6 Deposition Exhibit Number 17 is WP-IL 256 and 7 21 ships. 7 257; is that correct? 8 Q. And that's DD-829 through DD-849? 8 A. Yes. 9 A. Yes. 9 Q. And that is one drawing that extends 10 Q. Do you see any individual notation, 10 into two pages, correct? 11 like we've seen on some of the previous 11 A. Yes. That's correct. 12 documents, of exactly what date they were 12 Q. And so, consequently, we're going to 13 installed on DD-845 or it was installed on 13 mark it with one exhibit sticker and call it 14 DD-845? 14 Exhibit Number 17. Okay? 15 A. It appears that they were shipped 15 A. Yes. 16 from our facility on June 29, 1945. 16 MS. PERRITANO: Do you want it on 256 17 Q. Okay. 17 or 257? 18 A. That was a tough one to find. 18 MR. IOLA: 256. 19 Q. And it's tough, because it says 19 A. Would you like a moment to look at 20 DD-844 then hyphen five, then hyphen 6 -- 20 this? 21 A. Six, right. 21 (Whereupon, Exhibit 17 was marked.) 22 Q. And we're interpreting that to be 22 Q. (By Mr. Iola) No, that's all right. 23 844, 845 and 846, correct? 23 You can explain it to me. This is the sectional 24 A. Yes. 24 assembly outline tools, spares and details for 25 Q. What type of pumps were these salt 25 the salt water circulating booster pump for Page 154 Page 156 1 water circulating booster pumps for emergency 2 diesel generator? 3 A. These were centrifugal pumps. 4 Q. They had a motor? 5 A. Yes. 6 Q. And what type of motor did they have? 7 A. Electrodynamic. 8 Q. Were these pumps insulated? 9 MS. PERRITAnO: Is there another 10 sheet? 11 THE WITNESS: I only have -12 MS. PERRITANO: One. 13 THE WITNESS: I only have half of -14 Q. (Mr. Iola) One drawing, yeah. I 15 only have -- In terms of the drawings, for the 16 record real quick, we're looking at the drawings, 17 the only drawing I have on salt water circulating 18 booster pumps is WP-IL 00256; is that what you 19 have? 20 A. Yes. And it appears that, again, 21 this is half or this was two -- two sheets. 22 Q. Yeah, this is all I have as well, 23 sir. 24 A. Going through the -- looking at what 25 I have, I can't -- I can't find the pump. 1 emergency diesel generator set type 2-SED-6 by 2 Warren Steam Pump Company, Incorporated, correct? 3 A. Yes. 4 Q. These drawings were made by Warren 5 Steam Pump Company, Incorporated, correct? 6 A. Yes. 7 Q. They were drawn when? 8 A. November 5th, 1941. 9 Q. Doesn't appear they were ever signed 10 off on directly by the Bureau of Ships, at least 11 on 256, does it? 12 A. I do not see a signature there, no. 13 Q. Okay. So we can't really tell what 14 the date of that is, correct? 15 A. That is correct. 16 Q. On the list of material, it indicates 17 on piece number 27 that there's a gasket that is 18 an asbestos sheet gasket, again, correct? 19 A. That is correct. 20 Q. And again, these are drawings of the 21 salt water circulating booster pumps for 22 emergency diesel generator set for the unit that 23 was on board the USS Bausell, DD-845, correct? 24 A. Yes. 25 Q. And we know that because it shows on 39 (Pages 153 to 156) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 157 Page 159 1 the legend that it's DD-829 through 849, correct? 1 if such insulation is present, you would expect 2 A. That is correct. 2 to see it on the drawing, as previously 3 Q. And it shows order number A-17910, 3 identified by some of the other drawings, 4 which corresponds identically with Exhibit Number 4 correct? 5 17, that we previously talked about, correct? 5 A. Yes. 6 A. Yes. 6 Q. And so the mere fact that it's absent 7 Q. I'm sorry, Exhibit Number - 7 from the drawing indicates to you that it's not 8 MS. PERRITANO: 16. there, correct? 9 Q. (By Mr. Iola) 16, that we previously A. Correct. 10 talked about. We're discussing Exhibit Number 10 Q. Just as the mere fact that it's 11 17. And as we have previously talked about 11 present on the drawing, indicates to you that it 12 earlier today, it's fair to look at the legend of 12 is there, correct? 13 all of the various ships that are on this drawing 13 MS. PERRITANO: Objection. 14 and understand that this salt water circulating 14 A. Yes. 15 booster pump was on all those ships, in addition 15 THE WITNESS: Would you mind taking a 16 to the Bausell, correct? 16 break? 17 A. That would be correct, yes. 17 MR. IOLA: Sure. Let's go off the 18 Q. Okay. This gasket, that's an 18 record and take a break. 19 asbestos sheet gasket, went where? 19 VIDEOGRAPHER: The time is 12:19. 20 A. Let me just get the terminology for 20 We're off the record. 21 you, between the casing and the suction head, 21 (Whereupon, a brief break was taken.) 22 piece number 1 and piece number 4. 22 VIDEOGRAPHER: The time is 12:47 p.m. 23 Q. Is this similar to what we just 23 We're on the record. 24 discussed, a moment ago, on the fresh water pump? 24 Q. (By Mr. Iola) Mr. Doktor, you 25 A. Yes, it is. It's just a smaller 25 understand we're back on the record and you're Page 158 Page 160 1 size. 1 still under oath? 2 Q. Smaller size, but again, the gasket 2 A. Yes. Thank you for the break. 3 between the casing and the suction head, which 3 Q. There are just a couple of other 4 means any time you get inside the pump, you have 4 drawings, I believe, that deal with some various 5 to remove this gasket, correct? 5 items, but I don't know that any other drawings 6 MS. PERRITANO: Objection, beyond the 6 -- Do you know if you have any other drawings 7 scope, relevance. 7 that deal with any instruments or pumps that were 8 A. You would have to replace it, if you installed on the Bausell? 9 disturbed it, yes. A. Not that I have -- Not that I have 10 Q. (By Mr. Iola) And how many of these 10 seen. 11 gaskets were there on each salt water circulating 11 Q. Okay. Good. Then we've concluded 12 booster pump for emergency diesel generator? 12 our review then of all the drawings related to 13 A. One. Can I go back and answer the 13 the pumping products and systems that are on the 14 question that you asked when we couldn't find the 14 Bausell; is that correct? 15 drawing? 15 A. I believe so, yes. 16 Q. Sure. 16 Q. Okay. We've talked about the fire 17 A. I do not see that there is any 17 and bilge pump, correct? 18 insulation on this pump. 18 A. Yes. 19 Q. Okay. And you do not see that 19 Q. We've talked about the emergency feed 20 there's any insulation inside the pump, as well, 20 pump, correct? 21 correct? 21 A. Yes. 22 A. No. There is none noted on the 22 Q. We've talked about the diesel 23 drawing and nothing is real visible on the 23 generating salt water circulating booster pump, 24 drawing. 24 correct? 25 Q. And again, you would expect to see -- 25 A. Yes. 40 (Pages 157 to 160) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 161 Page 163 1 Q. We've talked about the fresh water 1 A. Yes. 2 pump? 2 Q. And if we turn further into the 3 A. Yes. 3 preface, it describes that Naval Auxiliary 4 Q. And we started off talking about the 4 Machinery is a revision of Naval Auxiliary 5 main circulating pump, correct? 5 Machinery published by the United States Naval 6 A. Yes. 6 Institute in 1950, correct? 7 Q. And those were all the pumps you 7 A. Yes. 8 initially identified that were on board the USS 8 Q. And this addition came out in May of 9 Bausell, correct? 9 1952, correct? 10 A. Yes. 10 A. Yes. 11 Q. Okay. In addition, last night there 11 Q. And do you understand what the 12 was some supplemental records that were delivered 12 purpose of this document was? 13 to me that apparently you reviewed. One of which 13 A. Not totally, no. 14 was the Naval Auxiliary Machinery sections of the 14 Q. Okay. Do you understand who put this 15 book, correct? 15 document together? 16 A. There was a section of some -- Yes. 16 A. I'm not sure if it was the Navy 17 That's correct. 17 itself or the Naval Academy for use there. 18 Q. You were aware what Naval Auxiliary 18 MR. IOLA: Okay. Let's mark if we 19 Machinery is, what that book is? 19 could -- I'm out of stickers. 20 A. I'm familiar with this -- this 20 MS. PERRITANO: We are on 18. 21 document, yes. 21 (Whereupon, Exhibit 18 was marked.) 22 Q. Okay. This document is basically a 22 Q. (By Mr. Iola) Let's mark, if we 23 subsection from a very large naval machinery 23 could, as Deposition Exhibit Number 18, Naval 24 book; is that correct, sir? 24 Auxiliary Machinery, that's Bates stamp number 25 A. Yes. 25 WP-IL b 00041 through, it appears, 00056; is that Page 162 Page 164 1 Q. Have you ever seen the entirety of 2 the naval machinery book? 3 A. No, I have not. 4 Q. It actually exists in more than one 5 part; are you aware of that? 6 A. I would assume so, yes. 7 Q. Okay. And so you understand that 8 what this is, is various copies of the 9 essentially preface, which are the Roman numeral 10 pages and then Chapter 2, which is the chapter 11 relating to packing and heat insulating 12 materials; is that correct? 13 A. Yes. 14 Q. And is this a document that was in 15 the possession of Warren Pumps that you 16 discovered in your search? 17 A. Yes. 18 Q. Okay. Is this document -- Is this 19 the portion that was discovered? In other words, 20 was a larger book discovered and this is all that 21 was copied or is this all that you had in your 22 records to begin it? 23 A. This was all we were able to find. 24 Q. Okay. And this is a revision dated 25 1952, correct? 1 correct, sir? 2 A. Well, there's IL b 00056. 3 Q. Yes, sir. 4 A. Okay. 5 Q. And that is beginning on Bates stamp 6 Page 45, that's the start of Chapter 2, which is: 7 Packing and Heat Insulating Materials, correct? 8 A. Yes. 9 Q. Did you find this document? 10 A. No, I did not. 11 Q. Who found this document? 12 A. It was a search that counsel had 13 conducted. 14 Q. Did you have an opportunity to review 15 this document and read it from page-to-page? 16 A. Yes, I did. 17 Q. Okay. And what did you learn from 18 your review of this document? 19 MS. PERRITANO: Objection, beyond the 20 scope. 21 A. Like I said, it was just general 22 information for -- you know, just to kind of give 23 everybody the background of why insulation and 24 packing was used or, you know, what type of 25 equipment it might go on. 41 (Pages 161 to 164) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 165 Page 167 1 Q. (By Mr. Iola) And your understanding 1 insulation that we talked about earlier during 2 was this is kind of generally what the Navy was 2 the deposition, correct? 3 talking about, in terms of insulating material, 3 MS. PERRITANO: Objection, if you 4 gaskets, packing, et cetera, during the time 4 know. 5 period that this document was written, correct? 5 A. I don't know specifically. 6 MS. PERRITANO: Objection, relevance. 6 Q. (By Mr. Iola) Okay. It talks also 7 A. Yes. 7 about asbestos insulation, correct? 8 Q. (By Mr. Iola) And this document was 8 A. Number 3, yes. 9 written after the construction of the USS 9 Q. It talks about asbestos pads and 10 Bausell, correct? 10 blankets, correct? 11 A. Yes. 11 A. Yes. 12 Q. But this document, in May of 1952, 12 Q. It talks about asbestos tapes, 13 was precisely during the time period that 13 correct? 14 Mr. Gudmundson served as a shipmate on board the 14 A. Yes. 15 USS Bausell, correct? 15 Q. Then under Subheading 1, it says, "A 16 A. Yes. 16 mixture of magnesia and asbestos containing about 17 Q. And this document talks about the 17 85 percent magnesia predominated in the field of 18 insulating materials that are being used on board 18 heat insulating materials until the advent of 19 this various equipment, correct? 19 steam temperatures in excess of 500 degrees 20 A. Yes. 20 Fahrenheit", correct? 21 Q. And it includes asbestos insulation, 21 A. Yes. 22 correct? 22 MS. PERRITANO: Objection. 23 A. I'm assuming so. I'm not sure what 23 Q. (By Mr. Iola) It talks about on the 24 paragraph you're looking at. 24 very next page under Subheading 3, talks about 25 Q. Okay. I'm looking at Bates stamp 25 molded asbestos insulation of long length Page 166 Page 168 1 Page 47, under the Subheading 2-5 Insulating 1 asbestos fibers is suitable for temperatures up 2 Material? 2 to 850 degrees Fahrenheit, correct? 3 A. Yes. 3 A. Yes, it does. 4 Q. The second paragraph for high 4 Q. And then on Bates stamp Page 51 it 5 temperatures, recourse is had to basic minerals, 5 talks about asbestos finishing cements and 6 such as asbestos and then it continues forward, 6 asbestos pads and blankets, about midway down the 7 correct? 7 page, correct? 8 A. Yes. 8 A. Yes. 9 Q. And then on Subheading 2.6, 9 Q. And you read about all this when you 10 Application of Insulation, it describes how you 10 reviewed this document, correct? 11 can apply pipe covering, block, insulating 11 A. Yes. 12 cement, correct? 12 Q. And you understood that during this 13 A. Yes. 13 period of time in the early 1950s when 14 Q. And then it continues down at the 14 Mr. Gudmundson was aboard the USS Bausell that 15 bottom of that page, as well, with more 15 asbestos-containing insulation products were 16 description. And then over to the next page, it 16 prevalent in use on naval vessels, correct? 17 talks about the use of asbestos felt pads, as 17 MS. PERRITANO: Objection, beyond the 18 well as block insulation and sectional pipe 18 scope, relevance. 19 insulation, correct? 19 A. That's what the document explains, 20 A. Yes. 20 yes. 21 Q. And then under Subheading 2.7, Forms 21 Q. (By Mr. Iola) Other than the 22 of Service Materials, it talks about magnesia and 22 technical manual that we talked about earlier 23 asbestos mixtures, correct? 23 that regarded fire and bilge pumps and emergency 24 A. Yes. 24 feed pumps, did you locate any other technical 25 Q. Similar to the 85 percent magnesia________ 25 manuals with respect to any other of these pumps, 42 (Pages 165 to 168) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 169 Page 171 1 and I include main circulating pump, fresh water 1 deposition. I just read the ones that pertained 2 pump, diesel generating salt water circulating 2 to pumps. 3 booster pump, that were on board the USS Bausell? 3 Q. Okay. Did you read a summary of the 4 A. I don't believe there were any in 4 deposition or did you actually read the 5 the... 5 deposition, itself? 6 Q. Just so the record is clear, the one 6 A. I read the deposition, itself. 7 we identified was a maintenance and service 7 Q. Was it highlighted for you, directing 8 manual for emergency feed pumps and fire and 8 your attention to certain sections? 9 bilge pumps; is that correct? 9 A. No. 10 A. Yes. 10 Q. But you kind of skipped through it 11 Q. And that's the only one you located, 11 just to look at, specifically, about what he said 12 correct? 12 about pumps? 13 A. Yes. 13 A. Yes, sir. 14 Q. Do you have any recollection of what 14 Q. And what did he say about pumps? 15 Mr. Gudmundson's job was aboard the USS Bausell? 15 A. He identified some of the pumps that 16 A. In reading Mr. Forest's deposition, I 16 were on the ship and the different services, and 17 believe he was in the laundry or... 17 some of the things that might have been done to 18 Q. And did you have an understanding of 18 those pumps. 19 what he did in the laundry room? 19 Q. Some of the things that might have 20 A. No, I didn't. 20 been done to those pumps; you mean what? 21 Q. Do you understand from Mr. Forest's 21 A. Whether they were insulated, whether 22 testimony where Mr. Forest worked upon the USS 22 they were worked on, those -- those types of 23 Bausell? 23 issues. 24 A. I mean, he was an electrician, so he 24 Q. And if they were insulated, did he 25 could have been in various spaces. 25 say whether or not they were insulated with Page 170 Page 172 1 Q. Including the engine room? 1 asbestos insulation? 2 A. Potentially, yes. 2 MS. PERRITANO: Objection, to the 3 Q. Including the fire room? 3 extent that your question assumes that the pumps 4 A. Yes. 4 that Mr. Forest identified were actually Warren 5 Q. Including the boiler room? 5 pumps. 6 MR. PERRITANO: Objection, if you 6 A. He did identify them as being 7 know. 7 insulated, yes. 8 A. Yes. 8 Q. (By Mr. Iola) He did identify the 9 Q. (By Mr. Iola) Did he testify about 9 pumps as being insulated with asbestos? 10 some of the work he did while on board the USS 10 MS. PERRITANO: Objection, beyond the 11 Bausell? 11 scope, and also assumes -- To the extent that it 12 A. I do not recall. 12 assumes that the pumps he identified were Warren 13 Q. Did he testify about some of the 13 pumps. 14 maintenance jobs that he performed, which created 14 A. Yes. 15 dust, while he was on board the USS Bausell? 15 Q. (By Mr. Iola) Did he give specific 16 A. I don't remember. 16 testimony, if you recall, about feed pumps? 17 Q. Did he testify about how dust would 17 A. Yes, I believe he did. 18 get on his clothes, when he was performing the 18 Q. And what did he say? 19 maintenance work on board the USS Bausell? 19 A. I think he was asked if they were 20 MS. PERRITANO: Objection. 20 insulated or not. 21 A. I don't remember that. 21 Q. And what did he say? 22 Q. (By Mr. Iola) Did he testify who he 22 MS. PERRITANO: Objection. Same 23 delivered his laundry to on board the USS 23 objection as before. 24 Bausell? 24 A. I believe he said that they were. 25 A. I didn't read the complete______________ 25 Q. (By Mr. Iola) He testified that the 43 (Pages 169 to 172) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 173 Page 175 1 feed pumps were insulated with asbestos, correct? 1 Q. (By Mr. Iola) Do you know whether 2 MS. PERRITANO: Objection, beyond the 2 the emergency feed pumps, after they were shipped 3 scope. 3 out by Warren with the asbestos insulation and 4 A. Yes. 4 the metal lagging on them, after they were 5 MS. PERRITANO: And relevance. 5 installed on the ship, do you know if they were 6 Q. (By Mr. Iola) And the feed pumps 6 insulated with further asbestos insulation? 7 being insulated with asbestos is consistent with 7 MS. PERRITANO: Objection, relevance. 8 what you've testified today in looking at the 8 A. No, I do not. 9 drawings of the feed pumps, correct? 10 MS. PERRITANO: Objection, relevance, 9 Q. (By Mr. Iola) Do you know if the 10 fire and bilge pumps, after they were sent out by 11 beyond the scope and it assumes that Mr. Forest 11 Warren with the asbestos insulation and lagging, 12 was talking about the Warren pumps. 12 if they were further insulated with asbestos 13 A. There are feed pumps and there are 13 insulation while on board the ship? 14 emergency feed pumps. 14 MS. PERRITANO: Objection, relevance. 15 Q. (By Mr. Iola) Okay. 15 A. No. No, I do not. 16 A. I don't know which one he was talking 16 Q. (By Mr. Iola) Do you have any 17 about. 17 knowledge, at all, about whether once a Warren 18 Q. At least with respect to emergency 18 fire and bilge pump or a Warren emergency feed 19 feed pumps on board the USS Bausell, as we 19 pump was shipped to the USS Bausell for 20 previously discussed today, Warren manufactured 20 installation on the USS Bausell, whether it was 21 at least one of those, correct? 21 insulated on board the Bausell after it was 22 A. Yes. 22 installed? 23 Q. And on that document that you and I 23 MS. PERRITANO: Objection, relevance, 24 walked through that was a drawing, you identified 24 beyond the scope. 25 that it was insulated with asbestos, correct? 25 A. I have no knowledge. Page 174 Page 176 1 MS. PERRITANO: Objection, beyond the 2 scope. I think he testified that it was 3 insulated and lagged. 4 A. Correct. 5 Q. (By Mr. Iola) Okay. And it was 6 insulated with asbestos and it had lagging on top 7 of the asbestos insulation, correct? 8 A. That is correct. 9 Q. And that would be consistent with 10 what Mr. Forest testified, correct? 11 MS. PERRITANO: Objection. I think 12 Mr. Forest's testimony related to external 13 insulation on the pumps. I think that would be a 14 fair reading of his testimony. 15 Q. (By Mr. Iola) You can answer. 16 A. Can you repeat? I'm sorry. 17 Q. That would be consistent with what 18 Mr. Forester testified to -- Mr. Forest, 19 F-o-r-e-s-t, I'm sorry? 20 MS. PERRITANO: Objection. I think 21 Mr. Forest's testimony differed. 22 A. From what I read, I believe it was 23 that he was asked if they were insulated with 24 asbestos and he said yes. I think that's as far 25 as the explanation. 1 Q. (By Mr. Iola) Are you aware as to 2 whether Warren sent some of their people to the 3 ship at Bath Iron Works, specifically the USS 4 Bausell, while this equipment was installed? 5 A. I'm not aware of that. 6 Q. Are you aware of what communications 7 salesmen had from Warren Pump Company with the 8 United States Navy for the equipment that was 9 actually sold and installed on the USS Bausell? 10 A. I haven't seen any documentation, no. 11 Q. Are you aware as to whether or not 12 any technical folks, repair, maintenance, anybody 13 like that from Warren Pump ever went and 14 performed maintenance and repair work on any of 15 these pumps that were on board the USS Bausell 16 manufactured by Warren? 17 MS. PERRITANO: Objection, beyond the 18 scope, relevance. 19 A. I haven't seen any documentation, no. 20 Q. (By Mr. Iola) Other than seeing 21 documentation, you're not personally aware of any 22 such thing; is that correct? 23 A. That's correct. 24 Q. In preparation for your testimony 25 today, with respect to the USS Bausell and 44 (Pages 173 to 176) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 177 Page 179 1 Mr. Gudmundson's work on board that ship during 1 board the USS Bausell, with respect to Warren 2 the period of time he was in the United States 2 emergency feed pumps sold to the United States 3 Navy, have you looked at any other naval manuals, 3 Navy? 4 naval technical brochures, regarding installation 4 A. Not specifically, no. 5 of Navy equipment and pumps? 5 Q. Same question with respect to fire 6 A. No, I have not. 6 and bilge pumps. Did you see any brochures 7 Q. Have you seen any brochures that 7 between 1951 and 1959 regarding fire and bilge 8 Warren Pump -- Warren Steam Pump Company had 8 pumps that were sold by Warren Steam Pump Company 9 about any of these products that we talked about 9 to the United States Navy for installation on 10 today that were on board the USS Bausell? 10 board the USS Bausell? 11 A. Specifically, no. 11 A. No. 12 Q. In other words, have you seen any 12 MS. PERRITANO: Randall, you were 13 brochures of Warren Pump Company concerning main 13 saying '59, but I think it's '55. 14 circulating pumps that were sold, during the time 14 MR. IOLA: He was on board the 15 period the Bausell was built, to the United 15 Bausell in '55, I think he was in the Navy from 16 States Navy? 16 1951 to 1959. 17 A. We do have some advertising 17 MS. PERRITANO: To '59. Okay. 18 information, but I think it's after the 1943, '44 18 MR. IOLA: So just to cover that wide 19 time period. 19 scope. 20 Q. Right. And that advertising 20 Q. (By Mr. Iola) Mr. Doktor, tell me if 21 information that you previously turned over to 21 you don't have this knowledge, but do you have 22 us, contained a lot of pumps that weren't really 22 any knowledge as to the type of asbestos that 23 at issue in the Gudmundson case, with respect to 23 85 percent magnesia asbestos insulation was? 24 the Bausell, correct? 24 MS. PERRITANO: Objection, beyond the 25 A. That's correct. Yes. 25 scope. Page 178 Page 180 1 Q. And so my question to you is: As 1 A. No, I do not. 2 counsel would like, more focused on the Bausell 2 Q. (By Mr. Iola) Warren Pump Company 3 itself during the period of time where 3 attached its nameplate to most of these pump 4 Mr. Gudmundson actually served on the Bausell, 4 products, correct? 5 what I want to know is are you aware of any 5 A. Yes. 6 literature by Warren Pump Company regarding the 6 Q. Where would that nameplate go? 7 main circulating pump for the period of time, 7 A. Could be various places on the pump. 8 say, from 1951 through 1959? 8 Sometimes the drawing might show and sometimes il 9 A. Specifically, no. 9 might not. 10 Q. Okay. Did you see any brochures 10 Q. And what would the nameplate be made 11 regarding fresh water pumps sold by Warren to the 11 out of? 12 United States Navy that would have been installed 12 A. Be brass, probably. 13 on the USS Bausell, between that same period of 13 Q. And it would have like the production 14 time, 1951 to 1959? 14 number, the ship name, the ship number, the item 15 A. No. 15 number for the order number? 16 Q. Did you see any brochures regarding 16 A. Some of the drawings might actually 17 diesel generating salt water circulating booster 17 show you exactly what the nameplate contained. 18 pumps sold to the United States Navy by Warren 18 Q. And those drawings designate exactly 19 Pump Company, during the period of time when 19 what's to be on the nameplate, correct? 20 Mr. Gudmundson was in the Navy from '51 to '59, 20 A. That's correct. 21 that were installed on the USS Bausell? 21 Q. And did they designate where the 22 A. For that particular service, no. 22 nameplate is to be placed on the pump? 23 Q. And did you see any brochures 23 A. It may or may not. 24 regarding emergency feed pumps between 1959 - 24 Q. And once that nameplate is placed on 25 '51 to '59 during the time Gudmundson was on 25 the pump, is that nameplate to be covered at any 45 (Pages 177 to 180) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 181 Page 183 1 point in time thereafter? 1 Q. (By Mr. Iola) In other words, have 2 MS. PERRITANO: Objection, beyond the 2 you undertaken any study, review, investigation, 3 scope. If you know. 3 to determine the entire totality of all the naval 4 Q. (By Mr. Iola) If you know. 4 machinery that was on board the USS Bausell when 5 A. I do not know. 5 Mr. Gudmundson was on board? 6 Q. In other words, if the pump is 6 MS. PERRITANO: Objection, beyond the 7 insulated after it leaves Warren Pump's facility, 7 scope. 8 do you know whether or not there's instruction to 8 A. No. 9 leave the area where the nameplate is 9 Q. (By Mr. Iola) Have you spoken, 10 uninsulated? 10 Mr. Doktor, in relation to this case, the 11 MS. PERRITANO: Objection, beyond the 11 Gudmundson case, on behalf of Warren Pumps, have 12 scope, if you know. 12 you had any conversation with anybody who was a 13 A. I do not know. 13 former Admiral in the United States Navy about 14 Q. (By Mr. Iola) Are you aware of any 14 what might have been on board the USS Bausell? 15 communications that any Warren Steam Pump Company 15 A. No. 16 employees had with anybody at the United States 16 Q. Have you had any discussion with any 17 Government or the United States Navy at the time 17 expert, maybe not an Admiral, about the 18 these pumps were sold to the Navy for 18 Gudmundson case and what naval machinery was on 19 installation on the USS Bausell? 19 board during the period of time that 20 A. I haven't seen any documentation. 20 Mr. Gudmundson served on board the USS Bausell? 21 Q. Are you aware of any supplier 21 MS. PERRITANO: Objection, work 22 relationships that Warren Steam Pump Company had 22 product. But he hasn't, so I'll let him answer. 23 with any packing and gasket manufacturers or 23 A. No, I have not. 24 companies, regarding sales during the time period 24 Q. (By Mr. Iola) Haven't had any 25 that these pumps were installed on the USS 25 discussion with Everett Cooper, have you? Page 182 Page 184 1 Bausell? 1 A. No. 2 A. No, I do not. 2 Q. Do you know who Mr. -- Admiral Cooper 3 Q. Are you aware as to whether Warren 3 is? 4 Steam Pump Company had any machinery repairmen 4 A. The name is familiar, but I can't... 5 that were on call to the United States Navy, 5 Q. Have you ever had any discussions 6 during this period of time, when these pumps were 6 with Admiral Cooper? 7 installed on the USS Bausell? 7 A. No. 8 MS. PERRITANO: Objection, it assumes MS. PERRITANO: Ever? 9 they had machinery repairmen at any point in A. They're a little out of my circle. 10 time. 10 MR. IOLA: Never underestimate 11 A. I do not know. 11 yourself, Mr. Doktor. 12 MR. IOLA: Well, I'd ask him that 12 Based on the agreement with counsel, 13 question, but you'd probably tell me that that's 13 concerning our arrangement with respect to the 14 beyond the scope of what we're here for today. 14 Gudmundson case, at this point in time, I'm not 15 MS. PERRITANO: I probably would. 15 going to have any further questions for 16 MS. LACONTE: He catches on quickly. 16 Mr. Doktor, subject to our agreement and the 17 Q. (By Mr. Iola) Are you aware, as you 17 re-review, if necessary, and re-deposition, if 18 sit here today, Mr. Doktor, of any other naval 18 necessary, of Mr. Doktor at a later point in 19 pump machinery that was on board the USS Bausell? 19 time. 20 MS. PERRITANO: Manufactured by 20 MS. PERRITANO: We have no questions. 21 Warren or -- 21 MR. IOLA: Does anybody on the phone 22 Q. (By Mr. Iola) By anybody? 22 have any questions for Mr. Doktor? 23 MS. PERRITANO: Objection, beyond the 23 MS. PERRITANO: Okay. We're done. 24 scope. 24 MR. IOLA: Sir, you have the right to 25 A. No, I don't. 25 read and sign. Counsel may want to advise you. 46 (Pages 181 to 184) POHLMAN REPORTING COMPANY 314-421-0099 [Examination by Mr. Iola] Page 185 1 MS. PERRITANO: He will take that 2 right. Is it 30 days? He will read and sign. 3 MS. LACONTE: It's 30 days. 4 MR. IOLA: Thank you, sir. 5 VIDEOGRAPHER: The time is 1:14 p.m. 6 The deposition is concluded. We're off the 7 record. (Whereupon signature was not waived and the witness was excused.) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 186 1 COMES NOW THE WITNESS, ROLAND DOKTOR, and having read the foregoing transcript of the 2 deposition taken on the 18th day of January, 2005, acknowledges by signature hereto that it is 3 a true and accurate transcript of the testimony given on the date herein above mentioned. 4 5 6 [ROLAND DOKTOR] 1 COUNTY OF SANGAMON ) SS. ) 2 STATE OF ILLINOIS ) 3 NOTARIAL CERTIFICATE 4 5 I, SARAH L. PASZKIEWICZ, Certified Shorthand Reporter and a duly commissioned 6 Notary Public within and for the County of Sangamon, State of Illinois, do hereby certify 7 that there came before me at the Boston Logan Airport Hilton, 85 Terminal Road, Boston, Illinois. 9 ROLAND DOKTOR, 10 who was by me first duly sworn to testify to the 11 truth and nothing but the truth of all knowledge touching and concerning the matters in 12 controversy in cause; that the witness was thereupon carefully examined under oath and said 13 examination was reduced to writing by me; and that this deposition is a true and correct record 14 of the testimony given by the witness. 15 I further certify that I am neither attorney nor counsel for nor related nor employed 16 by any of the parties to the action in which this deposition is taken; further, that I am not a 17 relative or employee of any attorney or counsel employed by the parties hereto or financially 18 interested in this action. 19 IN WITNESS WHEREOF, I have hereunto set my hand and seal this 21st day of January, 2005. 20 My commission expires May 12, 2007. 21 22 23 [NOTARY PUBLIC] 24 25 Page 187 Subscribed to before me this ___ 9 day of, 2005. 10 11 12 [Notary Public] 13 My commission expires: 14 15 16 17 18 19 20 21 22 23 24 25 POHLMAN REPORTING COMPANY 47 (Pages 185 to 187) 314-421-0099 Page 188 A a17 134:15 a17488 70:8,9 a17858 148:19 a17888 145:11 a17908 126:7 134:9 137:10 a17909 80:16 89:16 97:24 a17910 152:14 157:3 ability 16:16 23:9 43:2 able 39:7 126:13 150:18 162:23 aboard 72:12 73:11 74:22 81:15 86:7,9 90:13 114:1,2 118:12 142:12 147:1 151:9,18 168:14 169:15 absent 159:6 absolutely 38:12 74:24 94:4 120:20 144:11 academy 31:1,3,6,16 163:17 accurate 93:18 135:2 186:3 acknowledges 186:2 acquired 38:1,13,15 action 8:3 187:16,18 active 35:9 adams 5:15 addition 9:23 13:14 71:25 106:12 125:5 144:7 157:15 161:11 163:8 additional 15:10 18:12,20 110:6 address 7:19 10:24 11:8 administer 8:7 26:22 administered 8:14 administration 26:12,14,19,24 27:6 administrator 1:5 4:5 27:7,9,12,16 28:1 33:6 admiral 183:13,17 184:2,6 admissible 47:12 advent 167:18 advertising 177:17 177:20 advice 54:12 advise 115:3 184:25 affidavit 123:17 aflcio 50:1 aft73:24 74:1,6,14 aftermarket 25:2 46:4 afternoon 4:14 age 8:12 agents 55:16 ago 17:24 157:24 agree 42:21 47:12 agreed 7:1 72:20 agreement 7:9 10:8 144:8 184:12,16 ahead 10:10 46:1 55:11 90:6 102:17 117:11 144:3,7 151:25 air 82:1 85:21 132:12 airport 4:15 8:5 187:7 al 1:9 4:9 7:25 8:1 alert 151:25 alexis 6:5 9:13 allen 5:11,14 allow 10:10 alton 4:21 answer 16:13 34:3,6 34:7 38:8 43:5 46:2 51:15,21 52:10 56:9 77:11 84:8,17 90:7 93:15 102:9 102:10,11 109:14 114:25 115:2,3,6 123:1,24 124:1,13 158:13 174:15 183:22 answered 16:19,23 17:1 answering 16:15 answers 16:18,22,25 17:2,5,11 52:3,12 52:16 53:2,2 54:7,8 54:13,13,18,19,23 54:23 113:21 123:17 124:4,4,10 anybody 34:20 37:18 40:19 44:15 45:13 45:19,22 46:6,19 113:20 142:7,13 176:12 181:16 182:22 183:12 184:21 anymore 35:23 apparently 161:13 appear 80:7 156:9 appearances 8:22 appearing4:23 5:1,5 5:9,17,21 6:4 appears 32:3 147:19 153:15 154:20 163:25 application 166:10 apply 166:11 appreciate 16:9 144:5 appropriate 36:6 134:11 appropriately 134:22 approval 96:2,3,3 approved 95:25 98:22 148:7 approximately 15:12 18:17 49:20 50:9 105:5 149:22,23 april 11:20 12:3,14 31:23 32:3,8 148:5 architect 127:16 architects 81:1 archives 63:1 86:13 118:1 130:2,7,15 ardizone 24:23 ardizzone 24:20,24 24:25 45:23 ardizzones 46:3 area 22:16 36:12 102:24 103:2 111:7 181:9 areas 19:18,23,25 20:8,11,18,22 21:11 22:8 144:1 arent 91:21 arguments 22:18 arrangement 184:13 arrive 31:2 arrived 29:21 37:24 arrow 109:24 arrows 106:12,17,20 asbestos 11:25 35:10 51:7,12 52:14 76:20 77:25 78:6 90:1,2,20 91:10,25 92:7 93:6,12,21 95:17 101:12,13,24 102:1,1,20,20 103:6 104:6,8,16 105:6,14,25 107:18 108:6,16,23 109:1 109:20 110:7,24 111:24 116:13,18 120:15 121:1,10,19 122:15 123:8 124:11,18 125:6 135:24 138:3,8,13 138:17 139:3 140:15,23 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