Document DG7VK5p94MRxp7LZDXB8nMd5a

1 IN THE DISTRICT COURT 2 CAMERON COUNTY, TEXAS 3 138TH JUDICIAL DISTRICT 4 -- oOo -- 5 SAMUEL OLIPHANT WOOLEY, JR., et al., 6 Plaintiffs, 7 -vs- 8 OWENS-CORNING FIBERGLAS 9 CORPORATION, et al.. No. 94-09-04823 B 10 Defendants. ____ __________________________/ 11 12 13 14 Deposition of 15 DOUGLAS WAYNE MERRILL 16 Monday, November 20, 1995 17 By Allen M. Stewart, Attorney at Law 18 DUPLICATE 19 FILE COPY 20 21 Reported by 22 TERI DARRENOUGUE, CM, CRR CSR NO. 5106 23 24 PENINSULA REPORTING 25 CERTIFIED SHORTHAND REPORTERS 147 WINDSOR DRIVE, SAN CARLOS, CALIFORNIA 94070 26 (415) 594-0677 1 DEPOSITION OF DOUGLAS WAYNE MERRILL 11/20/95 1 MR. STEWART: All right. 2 Q. Back on the record. Mr. Merrill, before the break, 3 we were talking a little bit about dust counts and the 4 like of Kelly-Moore asbestos-containing products. Let me 5 ask you, sir, with respect to the Kelly-Moore 6 asbestos-containing products that were dry powder in 7 25-pound bags, would you agree with me that those 8 products, when they were emptied out of their bag, 9 produced dust? You would agree with me? 10 A. Some dust. 11 Q. And that would be dust that you could see; correct? 12 Visible dust? 13. A. Perhaps, yes. 14 Q. And this would also be dust that could be breathed; 15 correct? 16 A. Correct. 17 Q. And these asbestos containing products, some of 18 them, such as a joint compound, once they were applied 19 would oftentimes be sanded, would they not? 20 A. Sanding occurred on the finishing coat depending on 21 how smooth it was. 22 Q. Well, and sanding could also occur on joint 23 compounds as well; correct? 24 MR. TRUNCALE: Let me interpose more of an 25 objection or question. What do you mean by the term 26 "often"? Go ahead. 103 PENINSULA REPORTING (415) 594-0677