Document Gmo59yZggZzYpZqBe2kg60YOq

FILE NAME: Kerr (KR) DATE: 2021 Jan 29 DOC#: KR103 DOCUMENT DESCRIPTION: Legal - Deposition of Lawrence J. Girling Lawrence Girling January 29, 2021 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO ---o O o --- DAVID SPRINGER and DOROTHY SPRINGER, I I I Plaintiffs, vs. ASBESTOS COMPANIES, et al., Defendants. CERTIFIED ORIGINAL ) ) ) ) Case No. ) ) ) ) ) ) ) CGC-20-276849 VIDEOTAPED VIRTUAL DEPOSITION OF L A W R E N C E J. G I R L I N G Friday, J a n u a r y 29, 2021 9:31 a.m. R E P O R T E D BY: GISELLE GIRARD CSR #12901 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 2 1 VIRTUAL APPEARANCES: 1 2 2 For Plaintiffs: 3 3 GOLD LAW FIRM 4 4 BY: H.W. TREY JONES, ESQ. 555 Montgomery Street 5 5 Suite 605 San Francisco, California 94111 6 6 415-986-1338 415-373-4579 Fax 7 7 trey@treyjoneslaw.com 8 8 9 9 For Defendant Kerr Corporation and the Witness: 10 OIUM REYEN & PRYOR 10 BY: KEITH REYEN, ESQ. 11 220 M ontgomery Street 11 Suite 910 12 San Francisco, California 94104 12 415-392-8300 13 415-421-1254 Fax 13 keith@orplaw.com 14 14 15 SWANSON, MARTIN & BELL, LLP 15 BY: R I C H A R D P. T A U R A S , ESQ. 330 North W abash 16 16 Chicago, Illinois 60611 312-321-9100 17 17 312-321-0990 Fax rtauras@smbtrials.com 18 18 19 19 Fo r D e f e n d a n t 84 L u m b e r Company: 20 20 HAWKINS PARNELL & YOUNG, LLP 21 21 BY: SOLOMON PANTUCH, ESQ. 1 Post Street 22 22 Suite 2400 San Francisco, California 94104 23 23 415-766-3218 415-766-3250 Fax 24 24 spantuch@hpylaw.com 25 25 1 VIRTUAL APPEARANCES (Continued): Page 3 1 2 For Defendant BASF Catalysts LLC: 2 3 LITTLETON PARK JOYCE UGHETTA & KELLY, LLP 3 BY: JASON SCHMITZ, ESQ. 4 141 West Front Street 4 Suite 120 5 Red Bank, New Jersey 07701 5 732-530-9100 6 732-530-9115 Fax 6 jason.schmitz@littletonpark.com 7 7 8 For D e f e n d a n t DAP, Inc. k / n / a La M i r a d a Pro d u c t s Co., Inc., erroneously sued as DAP, Inc., and Champion Home 8 9 Builders: 10 TUCKER ELLIS, LLP 9 BY: N I C O L E E. GAGE, ESQ. 11 201 Mission Street 10 Suite 2310 11 12 San Francisco, California 94105 12 415-617-2105 13 13 415-617-2409 Fax 14 nicole.gage@tuckerellis.com 14 15 15 For Defendant Darby Dental Supply: 16 SMITHAMUNDSEN AEROSPACE 16 BY: MICHAEL MCGRORY, ESQ. 17 150 North Michigan Avenue 17 Suite 3300 18 Chicago, Illinois 60601 18 312-894-3200 19 19 312-894-3200 Fax mmcgrory@salawus.com 20 20 21 For Defendant Henry Schein, Inc.: 21 22 HARRIS BEACH, PLLC BY: SY E D K. RIZVI, ESQ. 22 23 100 Wall Street New York, New York 10005 23 24 212-687-0659 212-687-0659 Fax 24 25 zrizvi@harrisbeach.com 25 VIRTUAL APPEARANCES (Continued): For Defendant Hill Brothers Chemical Company: MORGAN LEWIS & BOCKIUS, LLP BY: M A R I S A R. CHAVES, ESQ. One Market Street Spear Street Tower San Francisco, California 94105 415-442-1141 415-442-1001 Fax marisa.chaves@morganlewis.com 2..5 Page 4 For Defendant New Coleman Holdings, Inc.: HAWKINS PARNELL & YOUNG, LLP BY: J E F F R E Y T. THAYER, ESQ. 1 Post Street Suite 2400 San Francisco, California 94104 415-766-3204 415-766-3250 Fax jthayer@hpylaw.com For Defendant Patterson Dental and True Value Company: WALSWORTH FRANKLIN BEVINS & MCCALL, LLP BY: H I L L A R Y H. HUTH, ESQ. 601 Montgomery Street Ninth Floor San Francisco, California 94111 415-781-7072 415-391-6258 Fax hhuth@wfbm.com For Defendant Ransom & Randolph Company: GOODELL, DEVRIES, LEECH & DANN, LLP BY: THOMAS J.S. WAXTER, III, ESQ. One South Street 20th Floor Baltimore, Maryland 21202 410-783-4000 410-783-4040 Fax tjw@gdldlaw.com VIRTUAL APPEARANCES (Continued): For Defendant The Scotts Company, LLC: HAWKINS PARNELL & YOUNG, LLP BY: A N A T. RE E G , ESQ. 1 Post Street Suite 2400 San Francisco, California 94104 415-766-3221 510-508-1816 Fax areeg@hpylaw.com HUNTON ANDREWS KURTH, LLP BY: EMILY MORDECAI, ESQ. Riverfront Plaza, East Tower 951 East Byrd Street Richmond, Virginia 23219 804-788-8200 804-788-8218 Fax emordecai@huntonak.com For Defendant SS White: SCHIFF HARDIN, LLP BY: JILL BERRY, ESQ. 1185 Avenue of the Americas Suite 3000 New York, New York 10036 212-745-9557 212-753-5044 Fax jberry@schiffhardin.com Page 5 For Defendant University of Southern California: POLSINELLI, LLP BY: J O S E P H L. GREE N S L A D E , ESQ. 2049 Century Park East Suite 2900 Los Angeles, California 90067 310-556-1801 310-556-1802 Fax jgreenslade@polsinelli.com Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 VIRTUAL APPEARANCES (Continued): For Defendant Whip Mix Corporation: SELMAN BREITMAN, LLP BY: S U Z A N N E E. R I S C H M A N , ESQ. 4 33 N ew M o n t g o m e r y Street Sixth Floor 5 San Francisco, California 94105 415-979-2004 6 415-979-2099 Fax srischman@selmanlaw.com 7 8 Also Present: 9 SPENCER BENVENISTE, VIDEOGRAPHER 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 6 EXHIBITS 6..9 Page 8 L A WRENCE J. GI R L I N G D a v i d Springer, et al. vs. A s b e s t o s Companies, et al. Friday, J a n u a r y 29, 2021 PLAINTIFFS' DESCRIPTION EXH 1 J A D A H azards of A s b e s t o s in D e n t i s t r y (2 pgs.) 8 EXH 2 Federal R e gister 6/7/72 Vo l u m e 37 9 No. 110 Part 1 (10 pgs.) 10 EXH 3 Kerr Do c u m e n t Pro d u c t i o n (52 pgs.) 11 12 13 14 15 16 17 -oOo 18 19 20 21 22 23 24 25 PAGE 37 EXAMINATION INDEX Page 7 1 Friday, January 29, 2021 Page 9 J a n u a r y 29, 2021 3 WITNESS 4 EXAMINATION BY PAGE 2 3 4 MR. JONES: The parties have stipulated that the 5 court reporter can swear in the witness remotely, as she 5 L A W R E N C E J. G I R L I N G 6 7 8 9 10 MR. JONES MR. REYEN 10, 124 121 6 is not at the same location as the witness. The parties 7 have also stipulated that an objection by any defense 8 counsel is good for all present; that includes motions 9 to strike. 10 Counsel need not opt out of an objection or a 11 11 motion; should they choose to do so, they can make that 12 12 election at trial. So stipulated? 13 13 MR. REYEN: So stipulated. 14 WITNESS INSTRUCTED NOT TO ANSWER 14 MR. JONES: The parties also agree that the 15 15 stipulations can be on the written and not the video PAGE LINE 16 record. All right. Let's go on the record, the video 16 17 record. 18 THE VIDEOGRAPHER: We are going on the record. 17 18 19 The time is 9:32 a.m., and the date is January 29, 2021. 19 20 This is the video deposition of Lawrence Girling, 20 21 Volume I, in the matter of David Springer, et al., 21 22 versus Asbestos Companies, et al. 22 23 This deposition is being held via Zoom (sic), and 23 24 24 my name is Spencer Benveniste from Asbestos Reporters of 25 25 California, a GPS Partner. The court reporter is Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 10 1 Giselle Girard. Counsel's appearance will be reflected 1 2 in the written record. 2 3 Will the court reporter please swear in the 3 4 witness. 4 5 5 6 LAWRENCE J. GIRLING, 6 7 having been first duly affirmed, was examined and 7 8 testified as follows: 8 9 9 10 MR. JONES: He said yes; right? 10 11 THE WITNESS: Yes. 11 12 MR. JONES: Just making sure. 12 13 13 14 EXAMINATION 14 15 BY MR. JONES: 15 16 Q. Mr. Girling, thank you for being with us this 16 17 morning, though it may be this afternoon where you are. 17 18 Where are you today? 18 19 A. I'm in Brighton, Michigan. 19 20 Q. What is your full name? 20 21 A. Lawrence Jay Girling. 21 22 Q. And where in Michigan do you live? 22 23 A. I live in Brighton. 23 24 Q. Okay. So you're near your home? 24 25 A. Yes. 25 10..13 Page 12 Q. Okay. You started working at Kerr Corporation in 1967; is that true? A. Correct. Q. What was Kerr when you started working there? MR. REYEN: Objection; vague. THE WITNESS: I -- I don't know. What do you mean, what was Kerr? BY MR. JONES: Q. Was it called Kerr Corporation then? A. Kerr Dental. Q. It was called Kerr Dental. Was it a corporation? A. I can't speak to that for sure. Q. Okay. When you were hired, you were hired by Bob Kerr? A. I was interviewed by Bob Kerr. Q. Bob Kerr was the president of Kerr Dental at the time? A. Yes. Q. What did Kerr Dental do, meaning what did they make, what did they sell -- what was their business? A. They made dental supplies. Q. Like? A. Impression materials, filling materials, endodontic materials, investment materials. Q. And we'll talk about it a little more. But the Page 11 Page 13 1 Q. The reason I wanted to speak to you today is that 1 investment materials, that's the product that was sold 2 you are retired from working at Kerr Corporation; is 2 with an asbestos tape; true? 3 that correct? 3 A. Yes. 4 A. Correct. 4 Q. Did Kerr, as part of its business, work with 5 Q. And when you were at Kerr Corporation, you had 5 chemicals? 6 some responsibility for ordering asbestos products that 6 A. Chemicals, yes. 7 went into Kerr products; correct? 7 Q. Tell me a little bit about that. 8 A. Correct. 8 A. They manufactured an impression paste made from 9 Q. And you also had some involvement in the process 9 chemicals. 10 of removing asbestos from Kerr products; is that 10 Q. Did Kerr, when you started in nineteen -- strike 11 correct? 11 that. 12 MR. REYEN: Objection; misstates facts not in 12 When you started in 1967, did Kerr have a 13 evidence; misleading. 13 laboratory where they worked with chemicals? 14 You can answer, Larry. 14 A. They had, I believe -- I can't speak for sure. 15 THE WITNESS: What do you mean by removing 15 But they had quality control departments, yes. 16 asbestos? 16 Q. They also had a research and development 17 BY MR. JONES: 17 department? 18 Q. I just mean that generally speaking, there was a 18 A. Yes. 19 period of time where Kerr decided that they didn't want 19 Q. You started in Detroit. What facilities did Kerr 20 to put asbestos with their products anymore, and you 20 have in Detroit? 21 were somehow involved in it. And we'll talk about that 21 A. Well, they had a plant on 12th Street in Detroit. 22 involvement in a minute. Okay? 22 And they had a refractories plant on Milwaukee Street in 23 A. Okay. 23 Detroit. 24 Q. Is that basically correct, what I said? 24 Q. When you started, which -- which one of those 25 A. Yes. 25 plants did you work at? Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 A. Both. Page 14 1 2 Q. What did they do at the plant on 12th Street? 2 3 A. They made endodontic files and reamers, 3 4 impression materials, filling materials, cavity liners. 4 5 Q. So that's one of the places where they worked 5 6 with different chemicals to make the impression 6 7 materials? 7 8 A. Yes. 8 9 Q. What did they do at the refractories plant on 9 10 Milwaukee Street? 10 11 A. They made gypsums and investments. 11 12 Q. Did Kerr have any other offices or plants, 12 13 factories, anything like that, when you started working 13 14 for them in 1967? And by that, I mean worldwide. 14 15 A. No -- well, not that I'm aware of at '67, no. 15 16 Q. What different divisions did they have at Kerr 16 17 when you started in 1967? 17 18 A. I don't know what you mean by divisions. 18 19 Departments or divisions? 19 20 Q. Departments. 20 21 A. Production department, finance, sales and 21 22 marketing, quality control and research. 22 23 MR. JONES: Giselle, can you read that back real 23 24 quick, please. 24 25 (Record read.) 25 1 BY MR. JONES: Page 15 1 2 Q. When you say research, is that the research and 2 3 development? 3 4 A. Yes, that was called research. 4 5 Q. Did they have human resources? 5 6 A. Yes, they did. 6 7 Q. Human resources was the department in charge of 7 8 safety at Kerr when you started in 1967; is that true? 8 9 A. I don't know that for a fact. 9 10 Q. So you've -- you first testified on behalf of 10 11 Kerr Corporation in 1996, I believe? 11 12 A. I -- I can't -- I can't recall the dates. That's 12 13 probably true. 13 14 Q. It was a case in Louisiana in the mid '90s. Does 14 15 that sound about right? 15 16 A. Yes. 16 17 Q. And then you've given several other depositions 17 18 on behalf of Kerr Corporation over the years; true? 18 19 A. True. 19 20 Q. And I've read several of those depositions, so a 20 21 lot of this is going to be kind of going through some of 21 22 the things that I've read in your previous testimony. 22 23 And one of the things I've read was that human 23 24 resources handled safety. Is that not your recollection 24 25 today? 25 14..17 Page 16 A. Safety, I know in the '80s and perhaps the '70s -- but I'm not too sure what they handled when I joined the company. Q. Got it. So later on when you got more involved, you knew that human resources handled safety? MR. REYEN: Objection to the extent that it is vague as to what is referred to by safety. I would expect that HR safety meant employee safety issues. MR. JONES: Just stick to legal objections, please. Do you have the question in mind, Mr. Girling? THE WITNESS: Do I have a question? BY MR. JONES: Q. The same objection will apply. The way I understand your answer was that when you started in 1967, you weren't really sure who was in charge of safety; but later on, you learned it was the human resources department. Is that fair? MR. REYEN: I will object that the question is vague and ambiguous as to what is referred to by safety. MR. JONES: Go ahead. THE WITNESS: The HR department, as I recall, in the '80s, '90s, dealt with HR resource issues as well as responsibility for health and safety in the plant. /// BY MR. JONES: Page 17 Q. Kerr had a -- someone that was in charge of regulatory issues. Was that the quality control people? A. That's where it was. Q. So later on in the '70s, there was a gentleman named Ken Kovac, I believe? A. Yes. Q. What was his job? A. I believe he was -- I can't define his job, but he was head of the quality control department called quality and regulatory. Q. And he was a vice president, I believe; is that true? A. At some point he became a vice president, yes. Q. Now, I've seen some testimony where you said that Bob Kerr was president of Kerr, and he interviewed you; but that when you started, Russ Nelson was the president of Kerr in 1967. Was there more than one entity, or did Bob Kerr step aside -- or help me with this, please. A. Bob Kerr sold the business. Q. When did he do that? A. '68, I believe it was. Q. Okay. So not long after Mr. Kerr sold the business, a gentleman named Russ Nelson became the president of Kerr? Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 A. Correct. Page 18 1 2 Q. Mr. Nelson's background was in finance. It 2 3 wasn't in dentistry; is that right? 3 4 A. Correct. 4 5 Q. So Kerr -- 100 percent of -- well, maybe not 5 6 100 percent. Almost all of Kerr's business in the '60s 6 7 and '70s was the sale of products for the use of the 7 8 dental -- I don't want to call it industry. I'm going 8 9 to try it again. 9 10 When you started in 1967, almost all of Kerr's 10 11 business was related to the sale of dental products; 11 12 true? 12 13 A. I can't say for sure because we also sold jewelry 13 14 investment products. 14 15 Q. Did you sell enough jewelry investment products 15 16 that it was more than 50 percent of the sales of the 16 17 company? 17 18 A. No. 18 19 Q. Was it more than 20 percent of the sales of the 19 20 company? 20 21 A. I can't guess. I have no idea. 21 22 Q. But most of the sales had to do with dental 22 23 products; right? 23 24 A. Right. 24 25 Q. Okay. Did Kerr employ any dentists? 25 A. When? 18..21 Page 20 Q. When you started. A. I can't tell you when I started who was on there. I was just a production control clerk. Q. All right. When you first became familiar with who was on the management team, who was on it? A. The head of -- the head of each of the functional departments. Q. Had a production, had a finance, sales and marketing -- all those? A. Yes. Q. Okay. And at some point in your career, you became the head of one of those departments; right? A. Yes. Q. Who did the heads of those different departments report to? A. The president. Q. So when Mr. Kerr sold the company, the heads of the departments reported to Russ Nelson? MR. REYEN: Objection; lacks foundation. BY MR. JONES: Q. Is that right? A. Yeah. While he was president, correct. Q. Is the management team the group that made decisions for Kerr Corporation? Page 19 1 A. I'm speaking from memory. At one point in time, 1 Page 21 MR. REYEN: Objection; overbroad as to time; 2 we had a dentist on the staff who had a dental chair set 2 lacks foundation. 3 up in the research department. 3 THE WITNESS: I don't -- I don't think decisions 4 Q. Around when was that? 4 were made by the management team. I think Russ Nelson 5 A. I can't recall. That's my -- that's too long 5 made the primary decisions. 6 ago. That's 40, 50 years ago. 6 BY MR. JONES: 7 Q. Fair enough. So at some point in time, Kerr had 7 Q. Got it. Russ Nelson is where the proverbial buck 8 a dentist on staff, but not all the time you worked 8 stopped; true? 9 there; is that fair? 9 A. Yep. 10 A. That's fair. 10 Q. Did the management team have meetings? 11 Q. Okay. We talked about some of the different -- 11 A. Yes. 12 I'm going to need somebody to mute. 12 Q. How often? 13 All right. We talked about some of the different 13 MR. REYEN: Overbroad as to time. 14 departments. Did Eaton also have a management team? 14 THE WITNESS: I can't -- when I attended, it was 15 A. I didn't catch the question. Did who? 15 once a month. 16 Q. Did -- oh, my brain is on another case right now 16 MR. JONES: Okay. 17 and something snuck out. 17 THE WITNESS: That was in the '80s, late '80s. 18 When you were at Kerr, did Kerr have a management 18 BY MR. JONES: 19 department? 19 Q. Well, we're going to talk about a 20 A. I -- yeah, yes. Yes, they did. 20 particular -- well, actually let me -- was there a 21 Q. Like a management team, I guess, is a better way 21 management meeting separate from the group of the 22 of putting it. 22 department heads and the president? 23 A. Yes. 23 A. No. 24 Q. Who -- who was the management team? Who was on 24 Q. Okay. When the management team got together to 25 that team? 25 make decisions for the corporation, how did they Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 22 1 communicate those decisions to the other departments? 1 2 MR. REYEN: Objection; overbroad. 2 3 THE WITNESS: Yeah, I have no idea what -- that's 3 4 huge. 4 5 BY MR. JONES: 5 6 Q. Well, when you guys had those management 6 7 meetings, did someone keep track of what you talked 7 8 about? 8 9 A. I don't know. 9 10 Q. Did you guys have minutes of meetings so you'd 10 11 know what decisions you made? 11 12 A. I can't say for sure there was, and no one sat in 12 13 the meeting and took minutes. 13 14 Q. Okay. Did -- did people take notes? 14 15 A. I took notes. 15 16 Q. Okay. And then if there was some decision, it 16 17 would have to be communicated outside of that management 17 18 team; right? 18 19 MR. REYEN: Objection; lacks foundation; 19 20 misstates facts not in evidence; overbroad. 20 21 THE WITNESS: I think that you're -- the 21 22 management committee meetings were mainly reporting 22 23 meetings, what's going on in your departments, what's 23 24 going on in the sales area -- that's the style of 24 25 meetings the monthly meetings were. 25 Q. And you wrote memos? 22..25 Page 24 A. I'm not saying I took -- wrote memos about the meetings. I don't think so. I took notes and went back and reviewed them by departments heads. Q. I'm not asking about the meetings, but while you worked at Kerr from 1967 -- until 2003; right? A. Yes. Q. At some point during that time, you wrote a memo. A. Yes. Q. And at some point during that time, people wrote memos to you. A. Correct. Q. And one of the ways that Kerr Corporation communicated its policies and procedures to its employees was through memos. A. I think you're stretching it but... Q. How many people worked at Kerr when you were there in the '60s and '70s? A. I can't tell you. I'd be guessing. Q. Roundabout. A. I still can't tell you. I'd be -- there was less than 100 people when I joined in '67. Q. Okay. A. A little less than a hundred. Q. So you're saying that everything that worked in 1 BY MR. JONES: Page 23 Page 25 1 this corporation -- that had a production department and 2 Q. Okay. But at some point, the president of Kerr 2 had a finance department, a sales and marketing 3 or the department heads made decisions that would affect 3 department, a quality control department, a research and 4 the rest of the corporation -- like, you know, no 4 development department and a human resources 5 more -- 5 department -- that in order to communicate with all 6 A. Yes. 6 those departments, Kerr just used word of mouth? 7 Q. -- overtime this year or stop parking in the back 7 A. No, I didn't say that. 8 parking lot, or we're going to change the color on the 8 Q. That would be a bad policy to use word of mouth 9 box of the Kerr products -- or something like that; 9 to communicate all your policies, wouldn't it? 10 right? 10 A. I didn't say that. 11 A. They made decisions, correct. 11 Q. Well, I'm saying it would be a bad policy if you 12 Q. And they had to communicate those decisions to 12 relied on word of mouth, wouldn't it? 13 the people that were going to carry them out; right? 13 MR. REYEN: Objection; calling for lay opinion. 14 A. The managers that were at the meeting did that. 14 BY MR. JONES: 15 Q. And they would communicate those decisions 15 Q. Right? 16 through memos? 16 A. Right on what? 17 A. Not necessarily -- 17 Q. Why would it be a bad idea to rely on word of 18 MR. REYEN: Objection. 18 mouth to communicate the policies and procedures of Kerr 19 BY MR. JONES: 19 to the employees? 20 Q. Not necessarily, but that was one way that they 20 MR. REYEN: Objection; calls for lay opinion. 21 would communicate things; correct? 21 THE WITNESS: I don't know. Policies and 22 A. Possible. 22 procedures can be communicated many ways, in verbal, 23 Q. Well, you know for sure that you personally wrote 23 written -- whatever you're talking about, I don't know 24 memos; right? 24 where you're going with it. 25 A. I took notes. 25 /// Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 BY MR. JONES: Page 26 1 2 Q. Okay. My point is that at Kerr Corporation, 2 3 people wrote stuff down; right? 3 4 MR. REYEN: Objection; overbroad. 4 5 THE WITNESS: Some things were written down, 5 6 correct. 6 7 BY MR. JONES: 7 8 Q. Okay. In 1967, you started as a production 8 9 planner in the chemical division; true? 9 10 A. Yes. 10 11 Q. Is that another department, chemical, or is that 11 12 part of production? 12 13 A. It's part of production. 13 14 Q. So at Kerr Corporation, when you started, we had 14 15 the departments we'd talked about, and then we had 15 16 divisions within those departments? 16 17 A. Divisions within production, yes. 17 18 Q. And your job as the planner was to determine what 18 19 had to be produced and what materials were needed to 19 20 produce those things. 20 21 A. Correct. 21 22 Q. How would you do that? 22 23 A. Based on analyzing sales requirements, forecasts 23 24 that marketing would provide. 24 25 Q. So how would -- so marketing would send you sales 25 26..29 Page 28 Q. Roundabout late '60s/early '70s, something like that? A. Probably true. Q. All right. A. My deposition would show it, probably. Q. And then in 1973, you were promoted to the materials manager? A. Okay. Q. Does that sound about right? A. Yes, somewhere in that area. Q. Fair enough. When you were a materials manager, that's the first thing you ever had anything to do with asbestos; is that right? A. Yes, that was the purchasing end of it. Q. So in 1973, it became your responsibility to purchase the asbestos tape that was used with Kerr's investment products; true? A. I can't speak to the exact date I took that on. Q. Fair enough. Around -- we'll say around 1973. Is that okay? A. It's close probably. I'm not sure the dates. Q. Fair enough. Whenever you became the materials manager at Kerr, that's when you first had responsibility for purchasing the asbestos products that were used with Kerr's products; right? 1 forecasts? Page 27 1 A. Correct. Page 29 2 A. Every year. 2 Q. How was asbestos used with Kerr's products? 3 Q. And as a planner, you would have to plan how to 3 A. I don't know. What -- what do you mean use? How 4 make enough product to meet the sales that marketing 4 was it used? 5 forecast? 5 Q. Yeah. Why did -- 6 A. Correct. 6 A. By a dentist, you mean -- or by a dentist or 7 Q. And then who did you work with as a planner? 7 what? 8 A. Oh, I was there 35 years. I worked with a lot of 8 Q. Sure. Why -- why did Kerr have to put an 9 people. 9 asbestos product with its products? 10 Q. I mean what job titles, I would say. Like, as 10 A. It was part of the casting procedure. 11 the planner, who did you report to? 11 Q. How so? 12 A. I reported to, at that time, manager of 12 A. I'm not a chemist, but it was used in the 13 production control in '67. 13 investment casting process to line the flasks. 14 Q. And did he report to the vice president of 14 Q. And the crucible? 15 production? 15 A. Could be crucibles. I wasn't that familiar with 16 A. I think he did. 16 the crucibles. 17 Q. So when you were planning out what -- what 17 Q. So the asbestos product that Kerr used with its 18 products needed to be made and what materials Kerr 18 investment products was an asbestos tape; true? 19 needed to make those products, how did you communicate 19 A. The asbestos product that Kerr used with the 20 that information to other people in the company? 20 investment was an asbestos tape, yes. 21 A. We made out schedules that got delivered to the 21 Q. Okay. And Kerr bought that asbestos tape from 22 department managers. 22 other companies; right? 23 Q. In 1969 you were promoted to supervisor in 23 A. Yes. 24 planning for the chemical division; is that true? 24 Q. Those companies were Nicolet and Celotex? 25 A. I can't recall the dates. 25 A. Yes. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 30 1 Q. When the asbestos tape came to Kerr -- well, 1 2 let's start here. If a customer of Kerr's bought a 2 3 product that included asbestos tape, that asbestos tape 3 4 would be in either a bag or a box; right? 4 5 A. Correct. 5 6 Q. And the bag or the box of asbestos tape would be 6 7 put into a box with the investment powder? 7 8 A. No, the box was never put into the container with 8 9 investment powder. 9 10 Q. Okay. If I -- if someone bought investment 10 11 powder that came with asbestos tape, how would the 11 12 asbestos tape come with it? 12 13 A. In bags. 13 14 Q. Okay. So if someone bought Kerr investment 14 15 powder in the late 1960s/early 1970s, they would get a 15 16 box with packets of investment powder; right? 16 17 A. Are you -- are you asking what containers that we 17 18 sold investment in? 18 19 Q. Yeah. 19 20 A. We sold it in three-and-a-half-pound cans, 20 21 ten-pound cans, 20-pound boxes, 35-pound pails and 21 22 hundred-pound drums. 22 23 Q. Did it ever come in a box where there were little 23 24 packets of individually -- individual -- I want to call 24 25 them servings, but individual-use packets of investment 25 Q. Sure -- 30..33 Page 32 A. -- say that again. Q. When Kerr sold the kit you talked about with the individual packets of investment powder... A. Yes. Q. The Kerr employee would just take a package of the asbestos strips and put it in the Kerr box with the powder; right? A. Correct, yes. Q. Meaning there was nobody at Kerr that had to cut the asbestos tape to the right size; right? A. Correct. Q. There was nobody at Kerr that had to take -- if it was an asbestos strip that was precut, nobody had to gather up the ten or 12 strips to put it in a separate package. They were already packaged when you got it from the supplier; right? A. Correct, correct. Q. So at Kerr in the manufacturing facility, generally speaking the workers didn't handle the asbestos tape; it was in a package? A. Correct. Q. Okay. So Kerr had asbestos tape that it sold in rolls, it had asbestos tape strips that were sold with those kits you described, and it had asbestos tape 1 material? Page 31 1 strips sold as crucible liners; true? Page 33 2 A. Yes, we had a kit that we sold to universities. 2 A. I can't speak to the crucible liners because I 3 Q. So if you got that kit, you got precut strips of 3 believe those were gone when we -- when I joined the 4 asbestos; right? 4 company. 5 A. Correct. 5 Q. Okay. In 1977 you became the operations manager, 6 Q. If you got one of the boxes or the other packages 6 roundabout. 7 you talked about, you got a roll of asbestos tape in a 7 A. Okay. 8 bag? 8 Q. Is that true? 9 A. Correct. 9 A. Sounds true. My deposition would tell me. 10 Q. You could also buy asbestos tape on its own from 10 Q. Yeah. At some point in the late '70s, you became 11 Kerr? 11 the operations manager; correct? 12 A. Yes. 12 A. Yes. 13 Q. And that would be in a box? 13 Q. And what was your job as the operations manager? 14 A. Correct. 14 A. Not only materials but also production. 15 Q. When the asbestos tape got to Kerr's factory, it 15 Q. Couple three years later, around 1980, you became 16 was either in a bag or a box? 16 the director of manufacturing? 17 A. Correct. 17 A. Yes. 18 Q. It was already packaged to be put in the Kerr 18 Q. And then a few years after that, you became the 19 package, if that makes sense? 19 vice president of manufacturing? 20 A. Yes. 20 A. Yes. 21 Q. Meaning if someone had the Kerr kit with the 21 Q. And you were the vice president of manufacturing 22 packets of investment, all they'd need to do would be to 22 for Kerr Corporation from the mid 1980s until you 23 grab a prepackaged thing of asbestos strips and put it 23 retired in 2003? 24 in the Kerr box; right? 24 A. Correct. 25 A. I didn't follow that one -- 25 Q. At one point you owned stock in Kerr Corporation. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 Is that still true? Page 34 1 2 MR. REYEN: Objection. Seeking financial 2 3 information from the witness. 3 4 I don't know that you have to answer that, 4 5 Mr. Girling. 5 6 THE WITNESS: Yeah. 6 7 MR. JONES: He's already answered it before, and 7 8 it goes to bias. 8 9 MR. REYEN: It -- it doesn't show bias if he 9 10 doesn't presently own it and -- 10 11 MR. JONES: I agree. 11 12 MR. REYEN: -- it's not your business. 12 13 MR. JONES: Let's find out. You can instruct him 13 14 not to answer. You can't suggest he shouldn't answer. 14 15 That's -- that's a speaking objection, and we'll have to 15 16 take it up later. If you want to instruct him, you can 16 17 instruct him. I'll ask the question again, and then you 17 18 can make your decision what to do. 18 19 Q. Mr. Girling, do you own stock in Kerr 19 20 Corporation? 20 21 A. No, I do not. 21 22 Q. Do you still have a pension from Kerr 22 23 Corporation? 23 24 A. Yes. 24 25 Q. Now, at one point in your career, did you start 25 asbestos in dentistry. 34..37 Page 36 A. I saw an article on asbestos, Hazards of Asbestos in Dentistry. Q. All right. Give me one second, and I'm going to pull that document up and put it on the screen. Kerr produced in this case, I think, 52 pages of documents. Do you have those documents with you today? A. I do not. Q. Okay. Do you know if the lawyer sitting next to you has them? A. He does not. Q. That's all right. I can put it up. Okay. If this worked right, then something popped up on your screen, and it should be the 1976 hazards in dentistry article. MR. REYEN: I'm not seeing an exhibit myself right now, Trey. THE WITNESS: I don't see it either. Now I see it. MR. JONES: Boom. MR. REYEN: Okay. Larry, it's smaller than it appears. I don't know -- up in the right-hand corner, you can make it larger if need be. THE WITNESS: Right. Whoops. It went away. I lost it. It went away. 1 attending these monthly management meetings? Page 35 1 Page 37 MR. JONES: Okay. I'm going to mark this as 2 A. When I became vice president. We actually -- I 2 Girling No. 1. 3 think -- well, my memory escapes me, but it may have 3 (Plaintiffs' Exhibit 1 was marked for 4 been before that, too, as a director. 4 identification and attached hereto.) 5 Q. Well, I know that you were at one particular 5 MR. JONES: It went away? 6 meeting of Kerr executives, and that's one in 1976 where 6 THE WITNESS: There it is. 7 they talked about the American Dental Association 7 BY MR. JONES: 8 article; right? 8 Q. All right. On the bottom left-hand side, I put a 9 A. Yes. 9 little sticker that says Exhibit Girling No. 1. Do you 10 Q. Now, by 1976 Kerr had been selling investment 10 see that? 11 products with investment tape for decades; true? 11 A. Let me make it bigger here. Yes, I see that. 12 A. I know they were selling it when I joined the 12 Q. Excellent. What is Exhibit 1? 13 company. 13 MR. REYEN: Larry, make sure you can see it fully 14 Q. In 1967? 14 and read it before answering. 15 A. Yes. 15 THE WITNESS: Yeah, I can't see it. It's just a 16 Q. And you know that they were selling it before you 16 bunch of lines. 17 got there; right? 17 MR. JONES: And it's -- for your reference, it's 18 A. I don't -- I don't know for sure but -- I believe 18 Kerr -51 and Kerr -52; that's the Bates numbers. 19 they were but I -- 19 THE WITNESS: It's from the Council of 20 Q. I think you've seen price lists that go back to 20 Dental Therapeutics, is that -- 21 the '50s and maybe before for investment products with 21 BY MR. JONES: 22 asbestos tape; right? 22 Q. Council of dental -- at the top it says Hazards 23 A. I didn't see any price lists in the '50s. 23 of Asbestos in Dentistry -- 24 Q. Okay. In 1976 you're familiar with the article 24 A. Yes. 25 in the American Dental Association journal about 25 Q. -- do you see that? Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 A. I got that. Page 38 1 2 Q. All right. And then under it, it says Council on 2 3 Dental Therapeutics, Council on Dental Materials and 3 4 Devices. Do you see that? 4 5 A. I got that, yep. 5 6 Q. What is Exhibit 1? 6 7 A. It looks like a letter they put out. 7 8 Q. How are you familiar with Exhibit 1? 8 9 A. I saw this letter in a meeting we had with 9 10 Ken Kovac. 10 11 Q. Okay. And you called it a letter. It's really 11 12 an article that was published in the Journal of the 12 13 American Dental Association; true? 13 14 A. I don't know that -- 14 15 Q. Can you -- 15 16 A. -- where it was published. 16 17 Q. Can you look at the bottom right of the first 17 18 page. 18 19 A. It says Reports -- 19 20 MR. JONES: Hey, can -- Spencer, let's go off the 20 21 record. 21 22 THE VIDEOGRAPHER: Okay. The time is 10:19 a.m. 22 23 We are off the record. 23 24 (Recess from 10:19 a.m. to 10:38 a.m.) 24 25 THE VIDEOGRAPHER: Okay. We're back on the 25 38..41 Page 40 Q. Okay. And what the bottom of this page indicates is that this was published in the April 1976 Journal of the American Dental Association; right? MR. REYEN: The document speaks for itself. MR. JONES: Just wait till I'm done. Is this like a moot court thing? Are you trying to show off your objection skills? I'm just trying to identify the document we're looking at. All right. I get it, you know how to object; you're very talented at it. Q. All right. Mr. Girling. A. Yes. Q. The bottom of the first page indicates this document was published in the Journal of American Dental Association in April of 1976 -MR. REYEN: Same objections. BY MR. JONES: Q. -- true? You've got to wait till I'm done, Keith. Don't speak over me. MR. REYEN: I thought you were done. MR. JONES: Well, you'll know because there'll be silence. Same objection applies; you don't need to make it again. MR. REYEN: Okay. Larry, just make sure you wait after he finishes a question so that I have a chance to 1 record, and the time is 1:38 p.m. (sic). Page 39 1 object. Page 41 2 BY MR. JONES: 2 THE WITNESS: Okay. 3 Q. Okay. Mr. Girling, while we were off the record, 3 BY MR. JONES: 4 did you get a chance to look at Exhibit 1? 4 Q. Mr. Girling, you can see from the bottom of the 5 A. Yes. 5 first page, it indicates that this was published in the 6 Q. Okay. And when you looked it over, did you 6 April 1976 Journal of the American Dental Association. 7 confirm that this was something that was published in 7 A. Correct. 8 the journal of the American Dental Association? 8 Q. When did you first see this document, the first 9 MR. REYEN: Objection; lacks foundation; calls 9 time ever? 10 for speculation. 10 A. In a meeting with Kovac in the fall of -- I 11 THE WITNESS: That's what it says down on the 11 believe it was the fall, somewhere around that 12 bottom. 12 timetable. 13 BY MR. JONES: 13 Q. Do you think it's around when this document was 14 Q. I didn't think that was a controversial thing. I 14 published in April, or do you think it was later in the 15 thought your interrogatories said that, but okay -- 15 year closer to 1977? 16 MR. REYEN: All right. He's not here to 16 A. I can't speak to the specific exact timeline. 17 authenticate this document. 17 Q. Fair enough. And the meeting you were in was a 18 MR. JONES: Well, he's here to answer whatever 18 meeting with Kerr executives; right? 19 question I have, but I don't know why you care. 19 A. Yes. 20 MR. REYEN: I don't -- I don't care, but he's -- 20 Q. Ken Kovac was there; true? 21 MR. JONES: All right. Well, let me do it -- 21 A. True. 22 MR. REYEN: -- I'm just -- I made an objection. 22 Q. And Ken Kovac at the time was the vice president 23 You wanted me to make an objection. I made an 23 of what? 24 objection. 24 A. I can't speak to his title. I don't know if he 25 MR. JONES: All right. 25 was vice president in '76. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 42 1 Q. What you've said in the past was that Ken Kovac 1 2 was in charge of regulatory and QA. Does that sound 2 3 right? 3 4 A. Yes. 4 5 Q. What is QA? 5 6 A. Quality assurance. 6 7 Q. Okay. That's maybe what we called quality 7 8 control before? 8 9 A. Yes. 9 10 Q. All right. So it was Mr. Kovac's job to monitor 10 11 regulatory developments that affected Kerr Corporation; 11 12 right? 12 13 A. I don't know that for sure. 13 14 Q. Well, if he's in charge of regulatory, what was 14 15 he in charge of? 15 16 A. I -- I don't know his job description -- 16 17 Q. All right. 17 18 A. -- I didn't see it. 18 19 Q. All right. So Mr. Kovac was there. Also Bob 19 20 Probst was there? 20 21 A. Yes. 21 22 Q. Who is Bob Probst? 22 23 A. He was the director of research at the time. 23 24 Q. Bob Ransdell was in the meeting. What was Bob 24 25 Ransdell's job? 25 42..45 Page 44 A. I can't speak for others. I just -- I was surprised to see that, the hazards of asbestos in dentistry. Q. And actually the first sentence of this article in the Journal of the American Dental Association in 1976 discusses a product sold by Kerr at that time; true? MR. REYEN: Objection; document speaks for itself. THE WITNESS: That is not true. We did not sell binders for periodontal dressings. BY MR. JONES: Q. The whole sentence is, "Asbestos is chiefly used in dentistry as a binder in periodontal dressings and as a lining material for casting rings and crucibles." A. The second part is correct. Q. Did I read the entire sentence correctly? A. Yes. Q. And Kerr certainly sold asbestos lining material for casting rings and crucibles in 1976 when this document was published? A. Correct. We did not sell the periodontal dressings. Q. Fair enough. So this was important to Kerr Corporation because Kerr Corporation was selling one of Page 43 Page 45 1 A. I can't be -- I'm not certain, positive. He was 1 the products that this article talks about; right? 2 either head of the marketing or he was president at the 2 A. Correct. 3 time; I don't remember which. 3 Q. And then if you look at the second paragraph, it 4 Q. You previously testified in a deposition that 4 says that, "It has been documented that airborne 5 Mr. Ransdell was the president of Kerr at the time of 5 asbestos is related causally to the development of 6 this meeting. Does that sound right? 6 pulmonary asbestosis and fibrosis, lung cancer and 7 A. That's probably right, if I just testified to it 7 pleural and peritoneal mesotheliomas." 8 back in -- 20 years ago. 8 MR. REYEN: Document speaks for itself. 9 Q. All right. Do you want me to pull that up? I 9 BY MR. JONES: 10 can show it to you so you don't have -- 10 Q. Did I read that correctly? 11 A. Nope. I believe you. I believe it. 11 A. Correct. 12 Q. Okay. Okay. So -- and then you were there. And 12 MR. JONES: You can have a running objection to 13 in the late '70s, your job was the materials manager or 13 document speaks for itself. That's not a legal 14 Operations Manager 1. Does that sound right? 14 objection, though, unless you can cite me the 15 A. Probably correct, yes. 15 Evidence Code. Maybe it's in there. 16 Q. Why did Mr. Kovac bring this article to the 16 MR. REYEN: I don't know -- 17 executive meeting in 1976? 17 MR. JONES: In moot court -- you would lose 18 MR. REYEN: Calls for speculation. 18 points in moot court for that objection; that's all I'm 19 THE WITNESS: I have no idea. He -- that was 19 saying. 20 part of his presentation at the meeting. 20 MR. REYEN: All right. Well, you'd probably lose 21 BY MR. JONES: 21 points for just demonstrating that you can read. 22 Q. So why did he present that at the meeting? 22 MR. JONES: I don't know because I read it 23 A. Informative to the group. 23 correct. 24 Q. And why was this article important to the group 24 Q. Now, Mr. Girling, that sentence is significant 25 of executives at Kerr Corporation? 25 because it indicates that asbestos can cause really bad Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 diseases; right? Page 46 1 2 A. That's what it says. 2 3 Q. So in 1976, Mr. Kovac brought this article to an 3 4 executive meeting of Kerr Corporation informing those 4 5 executives that the article says that a product sold by 5 6 Kerr includes an ingredient that can cause cancer; true? 6 7 A. True. 7 8 Q. If someone at Kerr Corporation was going to make 8 9 a decision about whether Kerr should keep selling that 9 10 product, the asbestos liner, or should stop selling it 10 11 or should put a warning on the product or should change 11 12 the product to nonasbestos, that decision would 12 13 ultimately be made by the president of Kerr Corporation, 13 14 who was Bob Ransdell at the time; true? 14 15 A. I don't know the process. Kovac might have made 15 16 that, the president might have done it -- I'm not sure 16 17 who. 17 18 Q. One of the executives in that management meeting 18 19 would have made the decision; right? 19 20 A. To exit the business, you're saying? 20 21 Q. Correct. 21 22 A. I don't think -- well, not based on this letter, 22 23 just on the letter. 23 24 Q. Well, what I'm saying is you told us at the 24 25 beginning -- I kind of asked you how did the structure 25 46..49 Page 48 Q. Okay. So Mr. Kovac, the head of regulatory and quality assurance, brings this article informing the executives of Kerr that they are selling a product that this article says includes a cancer causing ingredient. What does Kerr do? What do those executives do? MR. REYEN: Okay. I'm going to object just to the extent that this line of questioning in its entirety -- I won't make it again -- is not reasonably calculated to the lead to the discovery of admissible evidence based upon Mr. -- Dr. Springer's testimony that he didn't use the product after 1974. But you can go ahead and answer, Larry. I'm just putting that on the record. THE WITNESS: I need -- I need the question again, sir. BY MR. JONES: Q. Sure. So Mr. Kovac, the head of regulatory issues and quality assurance, brings this article into the executive meeting informing the executives that Kerr is selling a product that this article says includes a cancer causing ingredient; right? A. Correct. Q. What do those executives do? What happens in that meeting? A. The article was discussed. The article primarily Page 47 Page 49 1 work, who made the decisions, and you told me that the 1 referred to periodontal paste and the ADA pulling their 2 president made the corporate decisions. And I even 2 recognition of periodontal paste, they would not -- no 3 asked you, I said, so that means the proverbial buck 3 longer consider eligible to be accepted by the ADA. 4 stops at Mr. Nelson. That's who we were talking about 4 Okay. The ADA made acceptance decisions on a lot of 5 in the beginning. Do you remember that? 5 different products. They did not -- they did not drop 6 A. Correct. 6 acceptance on the asbestos rolls. 7 Q. So if anybody in that executive meeting was going 7 They cautioned that they should be used under 8 to make a decision for Kerr Corporation, it would be the 8 controlled conditions by the laboratory or the dentist, 9 president, who was Mr. Ransdell, at that time; right? 9 and they should be removed, they should be cut -- they 10 A. Or someone make a recommendation to him. 10 should be used in a wet manner. The key thing that we 11 Q. But ultimately Mr. Ransdell would make the 11 took away from that meeting was that we potentially 12 decision? 12 could have -- potentially could have -- a problem with 13 A. He would have to agree on a course of action. 13 asbestos. 14 Q. Okay. If somebody said let's stop selling this 14 Q. So what you're saying is that when Kerr's 15 stuff and Mr. Ransdell disagreed, then Kerr would not 15 executives read this article published in the American 16 stop selling it; true? 16 Dental Association called Hazards of Asbestos in 17 A. I can't speak to that. I'm not sure how that 17 Dentistry, their takeaway was that the problem was not 18 process would work. 18 with Kerr's products? 19 Q. Well, you know - 19 A. No. There is a potential for asbestos exposure 20 A. He may - 20 if the product is not used properly; that's what was the 21 Q. You know that the president makes the decision. 21 takeaway. 22 You know that; right? 22 Q. What the article says -- and if you look on the 23 A. Ultimately. 23 first page, the right-hand column, the first complete 24 Q. The buck stops there; right? 24 sentence beginning with "Also"... Do you see that? 25 A. Yes. 25 A. Yes. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 Q. It says, Page 50 1 2 "Also exposure to airborne fibers may 2 3 occur in dental laboratories where asbestos 3 4 is used to line casting rings or crucibles 4 5 for casting machines and in general is kept 5 6 in the laboratory in large rolls. Here the 6 7 danger lies in the tendency for personnel to 7 8 carelessly cut sections off these rolls and 8 9 thus release asbestos into the ambient air." 9 10 Did I read that correctly? 10 11 A. That's correct. 11 12 Q. They are talking about a product sold by Kerr; 12 13 true? 13 14 A. Correct. 14 15 Q. Kerr sold asbestos tape in rolls for use by 15 16 dentists; true? 16 17 A. True. 17 18 Q. For a dentist or a lab technician to use that 18 19 tape, they had to tear the tape to a piece -- 19 20 A. No, they did not have to tear it. They were 20 21 supposed to cut the tape. 21 22 Q. Oh, I'm sorry. Did -- did Kerr Corporation put a 22 23 warning on their asbestos tape boxes saying to cut the 23 24 tape, not to tear it? 24 25 A. No. 25 agree? 50..53 Page 52 A. I don't know that he said yea, yea, you've got the stamp of approval. We set about trying to find a substitute. Q. Okay. And there was a lot of work involved in finding a substitute for asbestos; correct? A. Correct. Q. Several different departments were involved; correct? A. Yes. Q. Mr. Kovac was in charge of the program; true? A. I don't know that he maintained responsibility throughout the whole program, no. Q. At some point Jack Everard, the manager of purchasing, got involved? A. Correct. Q. So the purchasing department got involved because they had to find an alternative, some sort of product that could be used as a liner that didn't have asbestos; right? A. Correct. Q. Once the manager of purchasing got that material, it had to be sent to the research and development people so they could test it; right? A. Correct. 1 Q. Was there any -- Page 51 1 Page 53 Q. And I believe it's been your testimony that it 2 A. In the directions for inlay, I think, 2 took some time for research and development to find a 3 Cristobalite inlay, it said that the tape was cut. 3 suitable replacement for the asbestos tape; true? 4 Q. Okay. So are -- are you saying that there's an 4 A. Correct. 5 important difference to Kerr between cutting or tearing 5 Q. When the -- part of the decision in finding a 6 the tape? 6 replacement for the asbestos tape was how much to charge 7 A. Well, that's what they're saying here. If it's 7 for the replacement; right? 8 carelessly cut or torn, there's a chance for asbestos to 8 A. I have no idea about that decision process. 9 be released in the air, if it's done carelessly. 9 Q. Well, you know that the cost of materials is 10 Q. What they're saying is that that's what people 10 something taken into account when setting the price of a 11 are doing in the labs; right? 11 product; right? 12 A. If they do it carelessly, correct. 12 A. True. 13 Q. Okay. So are you suggesting that if people would 13 Q. You can't sell the product for less than the cost 14 have just followed Kerr's instructions and cut the tape, 14 of the materials or you won't make money; right? 15 then there wouldn't have been a problem? 15 A. True. 16 A. No. 16 Q. So if the asbestos tape is more or less expensive 17 Q. Okay. What did people in that meeting recommend 17 than the replacement, that's something that has to be 18 when they got this information? 18 taken into account when setting the price of the 19 A. The recommendation from Kovac was that this isn't 19 product; right? 20 going in the right direction, it looks like asbestos has 20 MR. REYEN: Objection; argumentative; lacks 21 got a hazardous problem with it, and we need to get a 21 foundation. 22 replacement. 22 THE WITNESS: That wasn't the goal, to find a 23 Q. Anything else? 23 more economical solution. The goal was to replace 24 A. Not that I can recall. That's 50 years ago. 24 asbestos. 25 Q. Okay. Did the president of Kerr Corporation 25 /// Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 BY MR. JONES: Page 54 1 2 Q. I'm not suggesting it was the goal to find a more 2 3 economical solution. I'm suggesting that whatever the 3 4 solution was had to be taken into account in the pricing 4 5 of the product; true? 5 6 A. True. 6 7 Q. If the replacement costs two bucks and you're 7 8 charging $1 for the product, you're not going to make 8 9 money like that; right? 9 10 A. Correct. 10 11 Q. So we've got purchasing involved, research and 11 12 development. Who would handle pricing issues? Is that 12 13 marketing or is that finance? 13 14 A. Marketing. 14 15 Q. So marketing is involved. Whenever they find a 15 16 replacement, they got to change all the price sheets and 16 17 all the catalogs; right? 17 18 A. Correct. 18 19 Q. Is that marketing also? 19 20 A. Yes. 20 21 Q. Whenever Kerr R&D finds that one of the materials 21 22 purchasing sends them isn't working, they have got to 22 23 communicate that to purchasing; right? 23 24 A. Correct. 24 25 Q. When they find the thing that does work, they 25 that are working to replace asbestos; true? 54..57 Page 56 MR. REYEN: Objection; lacks foundation; calls for speculation. THE WITNESS: It was communication by taking -- I can tell you what happened. Jack Everard would get a sample in, and he would walk it down to technical research and say, "Here, try this one." And then they would cast it and see if it worked or not. And they'd say to Jack, "No, lousy." BY MR. JONES: Q. Did they -- this is research and development; right? A. Yeah, it's one or two people. Q. And the research and development department hired people that were trained in the scientific method; right? A. I don't know what their criteria was for hiring people. Q. Well, when you're doing research and development, research means looking into stuff; right? A. Correct. Q. Development means developing something based on your research; right? A. Your products, yep. Q. Yep. And then you're telling me they're doing Page 55 1 have to communicate that to purchasing; right? 1 testing of these different products; right? Page 57 2 A. Right. 2 A. Actual casting. 3 Q. And then that's got to be communicated to the 3 Q. Yeah. And you're saying that the research and 4 marketing people; right? They're the ones that are 4 development department at Kerr Corporation didn't write 5 going to sell it. 5 things down? 6 A. They weren't in the loop during the development 6 A. I can't speak to that. 7 process. During the sampling and testing process, 7 Q. Well, I mean, so they never kept notes, they 8 marketing wasn't even involved in that process at that 8 didn't have log books or journals or anything like that? 9 time. 9 A. I have - 10 Q. They find out at the end? 10 MR. REYEN: Objection - 11 A. Exactly. 11 THE WITNESS: -- no idea. That's not -- that was 12 Q. Okay. Now, the executives, the people that were 12 not my responsibility. I don't know. 13 in that meeting, they're staying apprised of the 13 BY MR. JONES: 14 development of the nonasbestos replacement; right? 14 Q. None of these different departments sent 15 A. Yes. 15 memoranda to each other about how the process was going? 16 Q. So the president of Kerr Corporation is keeping 16 A. I can't speak for other departments. I know what 17 tabs on it; right? 17 happened within purchasing and production; that's it. 18 A. I don't know if he was directly keeping tabs; I 18 Q. Okay. You're off to the side a little bit on 19 can't speak to that. 19 your video. I need you to - 20 Q. Well, he was in the meetings where you're talking 20 A. Okay. I just got this thing in front of me. I 21 about it; right? 21 can't see the picture. 22 A. He was in the meeting, but I don't know what he 22 Q. That's all right. That's all right. 23 did after that. I can't speak to his -- what he did. 23 Okay. So are you telling me that there was a 24 Q. I agree. During this time period, there's a lot 24 meeting where someone brought in an article published in 25 of communication between these different departments 25 the American -- I mean your -- almost all of Kerr's Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 58 1 business in 1976 is selling dental products; right? 1 2 A. Correct. 2 3 Q. It's got dental in the name; right? 3 4 A. Correct. 4 5 Q. So - 5 6 A. Not all the products that they recommended, 6 7 correct. 7 8 Q. So - 8 9 A. Periodontal paste was the main focus of the 9 10 article. 10 11 Q. We talked about that. In one sentence, the first 11 12 thing it says is periodontal paste. The second thing it 12 13 says is the asbestos products sold by Kerr Corporation, 13 14 which is asbestos liner for casting rings and crucibles; 14 15 right? 15 16 A. Correct. But my point was that the only product 16 17 that they decertified was the periodontal paste. They 17 18 did not say anything about asbestos rolls 18 19 decertification. 19 20 Q. Okay. Meaning you could keep selling it if you 20 21 wanted to. 21 22 A. They did not tell us to stop selling it, correct. 22 23 Q. And Kerr in 1976 did not stop selling it; true? 23 24 A. True. 24 25 Q. So is it your testimony that a vice president 25 58..61 Page 60 A. Just in general, anything that we bought - correct. Q. Yeah. A. Yes. Q. And you had to keep -- if you wanted to buy something new, you had to have a record of how much that cost; right? A. Correct. Q. So if you wanted to get some material different from asbestos, you would have to have something written down saying how much it cost in comparison to asbestos; right? A. I don't know at that point whether they even looked at cost. They were looking for materials that would work. Q. At some point they had to look at cost because they had to know how much to charge for the thing; right? A. Only when they found a material that would work. Q. Fair enough. So if they were charging $2 with the asbestos, and the nonasbestos thing was more expensive, they might have to change that price; right? A. I'm sure. I don't make those decisions. Okay. Q. I agree. But at some point, there would be something written down about this is the cost of Page 59 Page 61 1 brings an article into an executive meeting with other 1 asbestos, this is the cost of the new product, this is 2 vice presidents and the president of the company - 2 the cost that it's going to be for us to make it, this 3 A. They weren't - 3 is what we should charge for the new product -- right? 4 MR. REYEN: Asked and answered. 4 MR. REYEN: Lacks foundation; calls for 5 MR. JONES: Wait till I'm done. 5 speculation; compound; argumentative. 6 Q. Is it your testimony that the head of regulatory 6 THE WITNESS: I can't speak to that. 7 and quality assurance brings an article to an executive 7 BY MR. JONES: 8 meeting that includes the president of the company, that 8 Q. What do you mean you can't speak to it? You were 9 that article says that an ingredient in one of Kerr's 9 in the planning department. You were in production - 10 products has the ability to cause cancer; in that 10 A. I don't - 11 meeting, the suggestion is made to change the product, 11 Q. -- this was your job. 12 the management committee puts the wheels in motion to 12 A. I don't decide when to change prices, when to 13 change the product; they involve purchasing, research 13 mark up products; that's not my role. 14 and development, quality assurance to change the 14 Q. But you do communicate the information about the 15 product, and there were no memoranda or notes or other 15 cost of production to the people that do set prices; 16 documents written down involved in that process? 16 true? 17 MR. REYEN: Objection; compound question. 17 A. Communicate -- individual products, no. 18 THE WITNESS: I cannot speak to that. I know 18 Q. Okay. So is it your testimony that nobody wrote 19 what we did in purchasing, and that's -- I don't know 19 anything down about this article that says the Kerr 20 what other departments did in terms of notes, 20 product has an ingredient that causes cancer? Nobody 21 departments, whatever. 21 wrote that down? 22 BY MR. JONES: 22 A. I can't speak to that. Like I said, I don't 23 Q. Well, in purchasing, you for sure had records. 23 know. 24 You had to keep track of how much you were paying for 24 Q. Okay. In 1976 - 25 stuff; right? 25 A. Are we done with the article? Can I take it down Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 now or? Page 62 1 2 Q. No, we're not. 2 3 A. Okay. 3 4 Q. In 1976 -- well, yeah, you can take it down. 4 5 Yeah, go ahead and take it down. 5 6 A. Okay. 6 7 Q. Why did Kerr want to -- why did the Kerr 7 8 executives in 1976 decide to change the tape from 8 9 asbestos to nonasbestos? 9 10 A. Because the asbestos had the potential to become 10 11 airborne, be hazardous. 11 12 Q. They were worried about dentists or dentist lab 12 13 technicians getting hurt? 13 14 A. I can't -- I don't know what -- I can't say that 14 15 they were. 15 16 Q. I mean -- 16 17 A. Dentists -- 17 18 Q. I mean, was the -- in the meeting, were they 18 19 concerned that, oh, no, our product might hurt people? 19 20 A. I can't say that. I don't think that was... 20 21 Q. Well, when they got this article, they weren't 21 22 worried that someone might work with Kerr asbestos tape 22 23 that's discussed in the article and that they might get 23 24 the diseases discussed in the article like lung cancer 24 25 or mesothelioma? 25 Q. What was the hazard? 62..65 Page 64 A. Exactly what we just read. Q. Cancer; right? Right? A. Pardon me? Q. Cancer. MR. REYEN: Calls for expert opinion. MR. JONES: Cancer was a hazard. THE WITNESS: It was hazardous; let's put it that way. BY MR. JONES: Q. Well, but you knew. This article said it's hazardous because it can cause asbestosis and fibrosis, lung cancer and pleural and peritoneal mesotheliomas; true? A. That's what the article said, but I don't -- I didn't -- I didn't say that. Q. I understand. So did somebody in that room say: We should test our tape and find out if it releases asbestos? A. I don't know if they did or not, quite frankly. Q. Did somebody say: We need to do some more research and find out how bad this asbestos is? A. I don't know. I can't speak to that. Q. If dentists using Kerr's asbestos tape got hurt from it after this article came out, that would be a Page 63 1 MR. REYEN: Lacks foundation; calls for 1 problem for Kerr; right? Page 65 2 speculation; calls for the state of mind of other 2 MR. REYEN: Objection; calls for speculation. 3 persons. 3 MR. JONES: What was the answer? 4 THE WITNESS: Again, I can't -- I can't speak for 4 THE WITNESS: Could be. 5 others. I don't know what their thinking was. 5 BY MR. JONES: 6 BY MR. JONES: 6 Q. Why would that be a problem? 7 Q. Well, I'm asking you what they did. Did anybody 7 A. Just what you said, they got exposed to 8 in the room say something to the effect of: Oh, no, our 8 something. 9 product might hurt people, we better do something about 9 Q. And why would that be a problem for Kerr? 10 it? 10 A. I don't know where you're going. What do you 11 MR. REYEN: Objection; calls for hearsay. 11 want? 12 THE WITNESS: The only thing that was said in 12 Q. You seem to be looking off to the side. And I 13 that vein was that our product did have a potential for 13 don't have a video on the other attorney, so I don't 14 fibers being exposed and looks -- didn't look very good 14 know if you're looking at him or -- 15 for the future and let's get out of it; let's get it 15 A. No, I'm not. I'm not looking at Richard or 16 replaced. 16 anybody -- 17 BY MR. JONES: 17 Q. -- anything like that going on, this is going -- 18 Q. What do you mean it didn't look good for the 18 A. No -- 19 future? 19 Q. -- big problem. I'm just letting you know. 20 MR. REYEN: Objection; misstates testimony. 20 You're kind of pausing and looking off -- 21 THE WITNESS: There was a potential for the 21 A. No. 22 asbestos tape to give off fibers; that's what we meant. 22 Q. -- it's going to be a big problem if that's 23 BY MR. JONES: 23 what's going on. 24 Q. And what does -- why is that bad? 24 MR. REYEN: Okay. Ask a question, and you can 25 A. Because it was showing that it could be a hazard. 25 talk about big problems later. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 MR. JONES: Now, where was I... Page 66 1 2 MR. REYEN: You were asking him to speculate on 2 3 what could happen if something happened after your 3 4 client stopped using the product. 4 5 MR. JONES: That Keith is just so smart. I can't 5 6 come up with a comeback for him. I wish I had something 6 7 snappy. 7 8 Q. Kerr understood that it could be liable for 8 9 people that got hurt from this asbestos product; right? 9 10 A. I don't know. That's way beyond my scope. 10 11 Q. Well, you personally knew about lawsuits back 11 12 then; right? 12 13 A. No, this -- no. 13 14 Q. You'd never heard of a lawsuit before? 14 15 A. Kerr lawsuits on asbestos, no. 15 16 Q. I agree, there weren't any then. But you'd heard 16 17 of lawsuits; right? 17 18 A. Lawsuits are common knowledge. 18 19 Q. Yeah. And Kerr has been sued before, not for 19 20 asbestos but for other things -- 20 21 A. Not aware -- 21 22 Q. -- right? 22 23 A. -- of it. I was not aware of it. 23 24 Q. You'd never heard of Kerr being sued about 24 25 anything? 25 66..69 Page 68 true? A. The asbestos was not our expertise area. That was supplied by vendors, other companies that manufactured the asbestos. We were not -- Q. Okay. A. We were not experts in asbestos. Q. Well, Kerr was experts in chemicals; right? MR. REYEN: Objection; overbroad. MR. JONES: Right? THE WITNESS: No, I don't -- I wouldn't call us experts in chemicals. BY MR. JONES: Q. Your first job was a planner in the chemical division; right? A. Correct. Q. Employees at Kerr Corporation worked with dangerous chemicals every day; right? A. I don't -- I don't believe that's totally true. Q. Kerr knew how to protect its employees from chemicals; right? A. It's so vague, I don't know what you're referring to. What chemicals, what -- how to protect from what? Q. Any chemicals. A. Fire hazards, tornadoes, or what? It's vague. Q. Did Kerr work with chemicals that caused 1 A. No, I did not. Page 67 1 tornadoes? Page 69 2 Q. Okay. But you had heard of lawsuits; right? 2 A. No. I mean, you said Kerr works to protect their 3 A. Correct. 3 people with chemicals. I don't know -- 4 Q. I mean, you'd heard that if somebody slips and 4 Q. No. I'm sorry -- 5 falls in a grocery store, they might bring a lawsuit; 5 A. -- it's so vague -- it's so vague, I don't know 6 right? 6 what you're referring to. 7 A. Correct. 7 Q. Kerr knew how to protect its employees from the 8 Q. And you'd heard maybe if somebody got in a car 8 dangerous chemicals they worked with; true? 9 accident and rear-ended somebody else, there could be a 9 A. True, if they worked with any. 10 lawsuit; right? 10 Q. Right. And Kerr had people whose job was to make 11 A. Correct. 11 sure that Kerr's employees weren't hurt by the chemicals 12 Q. And you knew if somebody sold a product that hurt 12 they worked with; right? 13 somebody, there could be a lawsuit; right? 13 A. Someone was responsible, correct. 14 A. Correct. 14 Q. So Kerr Corporation was familiar with working 15 Q. And in 1976, Kerr knows that it's selling a 15 with chemicals that could be dangerous; right? 16 product that the American Dental Association says could 16 A. I don't know if I would classify any of the 17 hurt somebody; right? 17 chemicals we made for impression materials to be 18 A. Possibly. 18 dangerous -- 19 Q. Okay. So in 1976, there's a possibility that 19 Q. Okay. 20 Kerr can be sued if people get sick from the asbestos in 20 A. -- quite frankly. 21 the tape; right? 21 Q. Well, the only way they would know is if they 22 A. Correct. 22 looked up information about the chemical to find out if 23 Q. And Kerr didn't do anything to make dentists or 23 it was dangerous or not; right? 24 dental technicians or anything else aware of the 24 A. Or the supplier provided that information, 25 asbestos hazards of the asbestos tape that Kerr sold; 25 correct. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 70 1 Q. Okay. Kerr certainly had the ability to research 1 2 the hazards of different chemicals; right? 2 3 A. I can't say they did. I was in manufacturing. 3 4 Q. Well, when you started, Kerr was in Detroit, 4 5 Michigan? 5 6 A. Yes. 6 7 Q. Detroit, Michigan is near two major universities; 7 8 right? 8 9 A. Correct. 9 10 Q. Detroit, Michigan has libraries; right? 10 11 A. Correct. 11 12 Q. Kerr could have sent someone to a library to do 12 13 research on a chemical if they wanted to; right? 13 14 A. If they needed to, correct. 14 15 Q. Okay. The reason Kerr decided to stop selling 15 16 asbestos is because it did not want to be sued; true? 16 17 MR. REYEN: Misstates testimony; lacks 17 18 foundation. 18 19 THE WITNESS: I don't know that that's the reason 19 20 we stopped selling asbestos. We just wanted to make 20 21 sure we didn't expose the company to potential hazardous 21 22 material. 22 23 MR. JONES: Well -- go ahead. 23 24 THE WITNESS: It always said it was a potential 24 25 for hazard. 25 70..73 Page 72 its customers, the dentists and dental technicians working with them; true? MR. REYEN: Lacks foundation; calls for speculation. And when you say what Kerr did, it makes it sound like you're asking for his testimony as a person most knowledgeable about what Kerr thought, which is not what this deposition is today. THE WITNESS: I just can't -- I can't speak to that whole -- the logic of what you're just saying why we -- why we stopped asbestos. BY MR. JONES: Q. Well, if Kerr was really worried about the health of its customers, the dentists and the dental technicians, then they would have done more to protect them; right? MR. REYEN: Objection - THE WITNESS: I can't speak to that. BY MR. JONES: Q. What's that? A. That's not my knowledge base. Q. Well, you know that when the asbestos tape came from the suppliers to Kerr, it was in packaging already marked with Kerr's name on it; right? A. Yes. Q. Kerr's the one that decided what to write on the 1 BY MR. JONES: Page 71 1 boxes of asbestos tape or the bags; true? Page 73 2 Q. Your employees in the factory didn't really 2 A. Yes. 3 handle it, though. It was in a package whenever they 3 Q. In 1976, when Mr. Kovac brought the article into 4 handled it. They -- it was in a package in one box, and 4 the executive meeting, Kerr didn't start putting 5 then they moved it in a package to another box; right? 5 warnings on the asbestos tape that went out to 6 A. Yes. 6 customers; true? 7 Q. The people that were working with this hazardous 7 A. True, we did not, nor did the vendors. 8 thing were the dentists and the dental technicians; 8 Q. And I'm asking about Kerr. The meeting we're 9 right? 9 talking about is in 1976 with Kerr executives; true? 10 A. Yes. 10 A. True. 11 Q. And Kerr was worried that one of those dentists 11 Q. In 1976 the president of Kerr had the ability, if 12 could get sick and sue Kerr; right? 12 he wanted to, to start putting warnings on the asbestos 13 A. I don't know if that was in the forefront of 13 tape; true? 14 their thinking all the time. 14 A. That would -- I can't speak for him. If that was 15 Q. But it was part of it? 15 his goal, yes. 16 A. Could be. 16 Q. He did not do that; true? 17 Q. We know that Kerr didn't do it to protect 17 A. True. 18 dentists and dental technicians; true? 18 Q. From 1976 until asbestos was phased out, Kerr 19 A. Didn't do what, now? 19 never put a warning on the product about asbestos; true? 20 Q. Kerr didn't -- Kerr didn't do anything because it 20 A. True. 21 was worried about dentists and dental -- dental - 21 Q. In fact Kerr made no effort, Kerr didn't do 22 strike that. When Kerr found out -- strike that. 22 anything, to inform its customers that the asbestos tape 23 When Kerr made the decision to stop using 23 could hurt you; true? 24 asbestos with its investment materials, it did not make 24 A. True. 25 that decision because it was worried about the health of 25 Q. Kerr dealt with suppliers to sell its products; Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 true? Page 74 1 2 A. Manufacturers, yes. 2 3 Q. Well, it dealt with suppliers like Henry Schein 3 4 or Patterson or Buffalo Dental, those kind of companies; 4 5 right? 5 6 A. Distributors, yes. 6 7 Q. And Kerr would train those distributors about 7 8 Kerr's products so that they would be able to sell them; 8 9 right? 9 10 A. I don't -- that's not my job. I don't know. 10 11 Q. You've previously testified that Kerr trained the 11 12 distributors about the products. Do you recall that? 12 13 A. I don't recall that. 13 14 MR. JONES: Okay. 14 15 MR. REYEN: As far as I know, there's no question 15 16 pending. 16 17 MR. JONES: That's correct. 17 18 Q. Mr. Girling, I want to refresh your recollection 18 19 about this, if I can. So I've put up -- hopefully you 19 20 can see it -- a copy of your deposition taken in the 20 21 Witkowski case. That was a California case out of 21 22 San FTancisco County July 15, 2004. Do you see it? 22 23 A. Yes. 210 pages. 23 24 Q. Yes, sir. And it says Deposition of Larry 24 25 Girling. That's you; right? 25 products. 74.77 Page 76 It didn't say -- it's not specific to the asbestos products. Q. I agree. A. I think that was your question before, was we provided training on the asbestos products to the dealers, and I -- I don't recall that. Q. My question did not have to do with asbestos, but I appreciate the confusion. My question is Kerr provided training about its products to distributors and salespeople; right? A. Correct. Q. Kerr wanted its distributors and salespeople to know their products so that they could sell them; right? A. I assume that's why they did it. Q. And Kerr for sure wanted to sell products; right? A. Always. Q. Yeah. And the distributors and salespeople are the ones that actually met with the people that bought the products; right? A. Correct. Q. So they were in between you, Kerr and the dentists; right? A. Correct. Q. Kerr never provided any training to its distributors about the asbestos hazards associated with 1 A. Correct. Page 75 1 tape; true? Page 77 2 MR. REYEN: Is it large enough for you to read, 2 A. I can't speak to that. I'm not aware of any. 3 Larry? 3 Q. Kerr went to the American Dental Association 4 THE WITNESS: I'm going to make it a little 4 trade show every year in Chicago? 5 bigger now. Okay. 5 A. They did attend it. I don't know if every year 6 BY MR. JONES: 6 or what but... 7 Q. So this is your testimony in a prior case; right? 7 Q. Had a booth? 8 A. Okay. 8 A. Correct. 9 Q. Is that true? 9 Q. The idea was at the American Dental Association 10 A. I -- yes. If I said it in a deposition as 10 trade show that they would interact with people that 11 testimony, then I default to the testimony, quite 11 might buy their dental products; right? 12 frankly. 12 A. I don't -- I can't say the motive for the show, 13 Q. Fair enough. Can you go to Page 161 of the 13 but they were there. 14 deposition. You're going to have to scroll down. Let 14 Q. It's a trade show; right? 15 me know when you're there. 15 A. Trade -- yes, competitors were there. 16 A. I'm at 150. 16 Q. Right. And the idea was that Kerr would be at 17 Q. Keep going. 17 this trade show to hopefully trade their products; 18 A. There, 161. 18 right? 19 Q. 161 around Line 15, you talk about Kerr providing 19 A. Correct. 20 training to the distributors. Do you see that? 20 Q. Kerr never informed anyone at these ADA trade 21 A. Yes. 21 shows about what it learned about the hazards of 22 Q. Okay. Does that reflect your recollection that 22 asbestos in its products; right? 23 Kerr provided training about its products to its 23 A. I don't know. I don't know. 24 distributors? 24 Q. Did Kerr ever take the asbestos tape off the 25 A. Yeah, a -- we did train sales reps on our 25 shelves whenever it found a replacement? Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 A. Can you say that again. Page 78 1 2 Q. Yeah. Did Kerr ever take the asbestos tape off 2 3 the shelves whenever it found a replacement? 3 4 A. Take - 4 5 Q. Like recall it. 5 6 A. Not that I'm aware of. 6 7 Q. So whenever Kerr came up with the nonasbestos 7 8 tape, did they take all the rest of their asbestos tape 8 9 in inventory and throw it away? 9 10 A. It was -- the new tape was phased in as we ran 10 11 out of -- as the new tape became available, it was put 11 12 into production right away because it them took time 12 13 to -- for the developers to get the tape process down 13 14 pat. 14 15 Q. So the new tape was phased in, and the old 15 16 asbestos tape was phased out? 16 17 A. Correct. 17 18 Q. And the way the old -- so the new tape was sold 18 19 once the old tape was gone? 19 20 A. No. The new tape was put into production as soon 20 21 as we could get it available by size. 21 22 Q. So did you throw away the asbestos tape that 22 23 hadn't been sold yet? 23 24 MR. REYEN: Objection - 24 25 THE WITNESS: I -- I can't speak to that. We 25 BY MR. JONES: 78..81 Page 80 Q. Do you know what the Federal Register is? A. Federal Register for what? Q. The Federal Register where the federal government prints laws and notifications and requests for hearing in the Federal Register. A. I'm not familiar with it, no. Q. Okay. Who in Kerr had responsibility to review the Federal Register to determine whether there were any labeling requirements with respect to asbestos-containing products? A. I don't know. Q. Mr. Girling, I've just displayed your deposition in the Girling -- pardon me -- in the Blackledge case. That -- I think this is the first deposition you ever gave in an asbestos case out of Louisiana. Can you see it? A. I see it. Q. Okay. And then at the top, it says the deposition of Larry Girling. Do you see that? A. Yeah, it's handwritten in. Q. Yeah. And that's you; right? A. Correct. Q. Okay. And this is your testimony? A. Yes. Page 79 1 only -- it wouldn't be very much if it was thrown away 1 Page 81 MR. REYEN: Why don't -- you want him to read the 2 because it got delivered every month, every 30 days, so 2 whole thing? You know, assuming, Trey, that it is an 3 the quantities would be very small. 3 accurate thing, we will testify as to -- we will 4 Q. Did you -- did Kerr call its distributors and 4 stipulate to the authenticity of it. We won't waive any 5 tell them to take the asbestos tape off the shelves and 5 relevant objections, but we'll stipulate to the 6 start selling the new nonasbestos tape? 6 authenticity of it but... 7 A. I don't know. 7 MR. JONES: Okay. I'm just -- look at the first 8 Q. There would be some record of that; right? 8 page, it asks the full name, and I'm just asking the 9 A. I don't know. 9 witness -- I'll do it. 10 Q. Back to Ken Kovac. You would agree with me that 10 Q. If you look at the second page of the document, 11 one of the roles of the quality assurance group was to 11 the beginning of the questioning, you can see that this 12 stay abreast of all the Federal Regulations; true? 12 is a deposition of you; true? 13 A. True. 13 A. True. 14 Q. One of the ways that Kerr's quality assurance 14 Q. Okay. And you're testifying on behalf of Kerr 15 group stayed abreast of Federal Regulations was to read 15 Corporation. You can see that at the bottom of that 16 the Federal Register; correct? 16 page; right? 17 MR. REYEN: Objection; lacks foundation; calls 17 A. You mean as a person of knowledge or what? 18 for speculation - 18 Q. Actually when this is taken, you're still 19 THE WITNESS: I can't - 19 employed by Kerr Corporation. Do you see that? You're 20 MR. REYEN: -- calls - 20 still working at Kerr Corporation when this deposition 21 THE WITNESS: -- speak to that. I don't know how 21 took place. 22 they did their job. 22 A. What's the date on it? 23 MR. REYEN: Larry, you've got to let me finish my 23 Q. '96. But at the bottom, you're asked who you're 24 objection. 24 employed, and you say Kerr Corporation. 25 THE WITNESS: I'm sorry. 25 A. Okay. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 82 1 Q. If you can please go to page -- it's going to be 1 2 the 24th page of the PDF; the deposition page will say 2 3 26. So scroll down to 24. 3 4 A. Okay, I've got 24. 4 5 Q. And at the top -- you see the number 26 in the 5 6 top right? 6 7 A. Yes. 7 8 Q. Okay. Around Line 6, you're asked about OSHA 8 9 requiring warnings. Do you see that? 9 10 A. Yes. 10 11 Q. At Line 9 you're asked: 11 12 "Q. What, if anything, did you do to 12 13 determine whether OSHA did have any such 13 14 requirements?" 14 15 Your answer at Line 11: "We were never 15 16 notified by OSHA or any other federal agency 16 17 that we would have to label asbestos 17 18 differently. Normally the notification 18 19 process is through the Federal Register, 19 20 which it would have come out in there." 20 21 Did I read that correctly? 21 22 A. Correct. 22 23 Q. So that was your testimony; right? 23 24 A. Correct. 24 25 Q. The next question is what I asked you a moment 25 Page 83 1 ago: "Well, who in Kerr had responsibility to review 1 2 the Federal Register to determine whether there were any 2 3 labeling requirements with respect to 3 4 asbestos-containing products?" 4 5 Your answer at Line 20: "The QA group, Kovac's 5 6 group, basically." Did I read that correctly? 6 7 A. Correct. 7 8 Q. Okay. So does that refresh your recollection 8 9 that it was Ken Kovac's job, as the vice president of 9 10 quality assurance, to monitor the Federal Register? 10 11 A. Correct. 11 12 Q. Okay. So if there was something in the Federal 12 13 Register talking about one of Kerr's products, Kerr had 13 14 someone employed to find that stuff and communicate it 14 15 to the company; right? 15 16 A. It -- yes. 16 17 Q. And that person was -- in the '70s was Ken Kovac; 17 18 true? 18 19 A. True. 19 20 Q. I'm going to show you -- 20 21 Giselle, this -- I've only marked one exhibit; 21 22 right? 22 23 THE REPORTER: Right. 23 24 MR. JONES: I'm going to show you what I'll mark 24 25 as Exhibit No. 2, and the sticker is actually going to 25 say Girling -- Exhibit Girling No. 2. 82..85 Page 84 (Plaintiffs' Exhibit 2 was marked for identification and attached hereto.) BY MR. JONES: Q. Okay. Can you see what I've marked as Exhibit No. 2? A. Yes. Q. What is Exhibit No. 2? A. It says it's a Federal Register, Highlights of This Issue. Q. And what's the date on it? A. June 7th, 1972. Q. So it was Ken Kovac's job at Kerr to monitor this publication; right? A. Correct. Q. And in 19 -- on June 7, 1972, Kerr Corporation is selling asbestos tape to dentists and dental technicians to use in casting gold; true? A. Yeah, whatever they were casting. I'm not sure what they were casting. Q. And in 1972, Kerr is buying rolls of asbestos tape and strips of asbestos tape, and its employees are taking that tape and putting it in individual packages to ship to customers; right? A. Correct. Page 85 Q. Okay. So if the Federal Register had some requirement that Kerr was to warn about asbestos, it was Ken Kovac's job to communicate that to the company; right? MR. REYEN: Objection; over -- well, if Ken Kovac was in that position at this time. THE WITNESS: Yeah, it -BY MR. JONES: Q. If not him, somebody. Whoever is in charge of quality assurance is supposed to make sure that Kerr is following regulations; right? A. Correct. MR. JONES: Can you please go to the sixth page of the document. MR. REYEN: Well, Mr. -- Mr. Girling, before today have you ever seen this document? MR. JONES: Wait. No, no, no. You'll do that on redirect. MR. REYEN: No, but you're -- this is improper cross-examination -MR. JONES: You can do that on redirect. You're not examining him during my examination. Now, if you want to suspend the deposition, you can suspend it. And that's exactly what I'm going to do if you start interrupting my examination. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 86 1 MR. REYEN: Well, you can do what you want, but 1 2 this is not the proper use -- this is not the proper use 2 3 of a document, and it's not the proper -- it's not 3 4 proper cross-examination. 4 5 MR. JONES: Well, make your objection. 5 6 MR. REYEN: I just made it. Go ahead. 6 7 MR. JONES: All right. Thank you. 7 8 Q. Okay. Are you on the sixth page, Mr. Girling? 8 9 A. Yes. 9 10 Q. On the left-hand column about the middle, it says 10 11 Title 29 Labor Chapter XVII Occupational Safety and 11 12 Health Administration, Department of Labor, Part 1910 12 13 Occupational Safety and Health Standards, and then it 13 14 says Standard for Exposure to Asbestos Dust. Did I read 14 15 that correctly? 15 16 A. Correct. 16 17 Q. And Kerr -- 17 18 A. This was OSHA's guidelines for inspection; right? 18 19 Q. For asbestos. It's the standard for exposure to 19 20 asbestos -- 20 21 A. For -- 21 22 Q. -- do you see that? 22 23 A. -- anybody -- anybody that manufactured asbestos. 23 24 Q. Well, you hadn't seen this before; right? 24 25 A. No. But is that what this is for, is OSHA's 25 published in the Federal Register on 86..89 Page 88 January 12, 1972." Did I read that correctly? A. Cbrrect. Q. So what they're saying is two things were published in the Federal Register about asbestos before this, the emergency standard, and then they asked for comments; right? MR. REYEN: Lacks foundation; calls for speculation; beyond the scope of this person's presence here -- THE WITNESS: I can't speak to what they're doing, what OSHA's -- what -- what their sequence was. BY MR. JONES: Q. Well, this is my point. If Kerr had someone whose job it was to monitor the Federal Register for regulations that applied to it, this is saying that there were two other things published about asbestos in the Federal Register; right? A. Two other things published -- Q. Yeah. A. -- that they -- they -- OSHA was establishing their OSHA limits for exposure to asbestos fibers in the dental laboratories, also, by the way, who are subject to that and in the dental office. Page 87 1 guidelines for the manufacturers of asbestos? 1 Q. Which -- Page 89 2 Q. Not just manufacturers but people that use it 2 A. And -- and the manufacturer also. 3 also. 3 Q. What's your point? 4 MR. REYEN: I don't know that that's correct. I 4 A. We were not a manufacturer. That's what it -- 5 object to that. Ask a question, but, you know, again, I 5 this OSHA spec did not apply to our plants. 6 don't think this is a proper line of questioning. And 6 Q. Are you saying it's the dentists' fault? 7 you're not -- it's an improper use of the document. 7 A. No. I'm saying the dentist was under the same 8 BY MR. JONES: 8 OSHA guidelines -- 9 Q. Okay. So Kerr was familiar with OSHA; right? 9 Q. So -- 10 A. OSHA came out in 1972. 10 A. -- to make sure -- make sure that the fiber 11 Q. And Kerr was familiar with that; right? 11 exposure was not above the limits when he -- when he 12 A. We worked with OSHA, yes. 12 made his castings in his lab. 13 Q. Okay. And Kerr had employees that were subject 13 Q. Okay. So what you're saying is that it's the 14 to OSHA regulations; right? 14 dentists' fault if they're exposed to asbestos while 15 A. Correct. 15 working with asbestos tape -- 16 Q. Okay. And if you look at the -- under the title, 16 A. I did not say that. I did not say that. I 17 it says: 17 said -- 18 "On December 7, 1971, an emergency 18 Q. -- follows -- 19 temporary standard concerning exposure to 19 A. -- the dentist could be subject to OSHA 20 asbestos fibers was published in the Federal 20 guidelines the same way any manufacturer was. 21 Register. In accordance with the Section 6 21 Q. Okay. So what you're saying is that it's -- the 22 (C)(3) of the Williams-Steiger Occupational 22 dentist had a responsibility to protect themselves from 23 Safety and Health Act of 1970, a notice of 23 Kerr's asbestos tape? 24 proposed rulemaking regarding a permanent 24 A. I'm not saying that. I'm saying they'd have to 25 standard for exposure to asbestos fibers was 25 abide by -- abide by OSHA guidelines as well as any Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 other manufacturer. Page 90 1 2 Q. Okay -- 2 3 MR. REYEN: Okay. If that's the question, we're 3 4 going to take a break here for five minutes. 4 5 MR. JONES: Sure. 5 6 THE VIDEOGRAPHER: 2:50 p.m., we are off the 6 7 record. 7 8 (Recess from 11:50 a.m. to 12:06 p.m.) 8 9 THE VIDEOGRAPHER: Okay. We're back on the 9 10 record, and the time is 3:06 p.m. 10 11 BY MR. JONES: 11 12 Q. Okay. Mr. Girling, did you have a chance to talk 12 13 to your lawyers over the break? 13 14 A. I talked to Richard. 14 15 Q. Did you get a chance to look at this OSHA exhibit 15 16 any further? 16 17 A. No, I did not. 17 18 Q. Okay. Can you scroll over to the middle column, 18 19 the bottom paragraph of that same page, starts with "No 19 20 one"... 20 21 MR. REYEN: Okay. I'm going to object. This is 21 22 improper cross-examination. You have not established 22 23 that he ever saw this document before today. You've not 23 24 established that he is an expert on OSHA regulations. 24 25 If you want to ask a question, you can ask a 25 90..93 Page 92 duration is causally related to asbestosis and cancers." MR. REYEN: Same objections. MR. JONES: I'm not done. Q. "The dispute is as to the determination of a specific level below which exposure is safe." Did I read that correctly? A. Yes. Q. Okay. If you go to the right column, second full paragraph, so it's kind of toward the middle, it says "In view of"... Do you see that? A. Yes. Q. "In view of the undisputed grave consequences from exposure to asbestos fibers, it is essential that the exposure be regulated now, on the basis of the best evidence available now, even though it may not be as good as scientifically desirable." Did I read that correctly? A. Correct. Q. And then at the bottom of the paragraph, it says, "Lives of employees are at stake." Did I read that correctly? A. Correct. Q. Kerr didn't put a -- well, strike that. Can you go to the next to last page of the document. Page 91 1 question, but you're not going to introduce this 1 A. Yep. Page 93 2 document, which is a hearsay document, through the 2 Q. On the right-hand column, kind of toward the 3 cross-examination. 3 upper middle, there's something that says Caution 4 MR. JONES: I actually established that he had 4 Labels Do you see that? 5 never seen it before today. 5 A. Yes. 6 MR. REYEN: Yeah, so why do you keep asking him 6 Q. Okay. It says Caution Labels, Labeling: 7 questions about it? 7 "Caution labels shall be affixed to all 8 MR. JONES: You know why. If you didn't know, 8 raw materials, mixtures, scrap, waste debris 9 you wouldn't care. 9 and other products containing asbestos 10 MR. REYEN: Well, you know, he is not -- he is 10 fibers or to their containers except that no 11 not here as an expert witness. He is not here as a PMK 11 label is required where asbestos fibers have 12 for Kerr. You have not established that he is familiar 12 been modified by a bonding agent, coating, 13 with OSHA or who it applied to and under what 13 binder or other material so that during any 14 circumstances it applied. 14 reasonably foreseeable use, handling, 15 But go ahead. I reserve -- those objections will 15 storage, disposal, processing or 16 relate to this entire line of questioning, which I think 16 transportation, no airborne concentrations 17 is harassing and wasting time. 17 of asbestos fibers in excess of the exposure 18 MR. JONES: I will stipulate to a running 18 limits prescribed in Paragraph B of this 19 objection. 19 section will be released." 20 Q. All right. Mr. Girling, are you with me? 20 Did I read that correctly? 21 A. Yes. 21 A. Yes. 22 Q. Okay. So this document published in the Federal 22 Q. And then under that -- well, let me ask you, so 23 Register on June 7, 1972, that middle column at the 23 the asbestos tape, I mean, it wasn't -- it wasn't dipped 24 bottom says, "No one has disputed that exposure to 24 in rubber or plastic or anything. It wasn't covered in 25 asbestos of high enough intensity and long enough 25 cement It was just a tape; right? Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 94 1 MR. REYEN: Objection; lacks foundation; calls 1 2 for speculation. 2 3 THE WITNESS: I don't know the formulation that 3 4 the manufacturers used to make the tape. 4 5 BY MR. JONES: 5 6 Q. Well, I'm not asking you the formulation. You 6 7 saw it with your own two eyes; right? 7 8 A. Well, I -- 8 9 MR. REYEN: Objection -- objection. He doesn't 9 10 have an -- electron microscope eyes. 10 11 MR. JONES: I just -- I'm just asking about his 11 12 regular old eyeballs, not his Superman eyeballs. 12 13 MR. REYEN: He is not here -- you can establish 13 14 whether or not he is familiar with the chemical 14 15 composition, the constituents, the binders that were 15 16 used with it if he knows; but if he doesn't know, he 16 17 doesn't know. 17 18 MR. JONES: I can really ask anything I want. 18 19 MR. REYEN: Well, you -- you are proving that. 19 20 You're not necessarily asking things that are admissible 20 21 or proper, but you are. 21 22 MR. JONES: We'll find out. We'll find out. 22 23 Q. All right. Are you with me -- 23 24 A. Yes. 24 25 Q. -- Mr. Girling? Keith Reyen is wasting our time. 25 Assumes facts not in evidence. 94..97 Page 96 Can you hear that? MR. JONES: Yes. THE REPORTER: Yes. MR. TAURAS: Okay. Thank you. Sorry about that. BY MR. JONES: Q. All right. Do you have my question in mind because I forgot it? A. No, I don't know. Q. All right. The same objection will apply. Mr. Girling, you would agree with me that Kerr never put the warning in this Federal Register OSHA document on its asbestos tape products; right? A. We never put warnings, correct. Q. So after this was published in the Federal Register in 1972, Kerr didn't do anything different; right? A. Correct. Q. Kerr kept selling asbestos tape; true? A. Yes. Q. It didn't put a warning on it; true? A. True. Q. And it didn't do anything to tell dentists or dental technicians that the asbestos could hurt people; true? A. True. 1 I just want to get this done. All right? Page 95 1 Page 97 Q. Okay. Now, Kerr was first sued in asbestos 2 A. Okay. 2 litigation in around 1990 or 1991; right? 3 Q. Now, my question to you is you personally saw 3 A. I don't know for a fact. 4 with your own two eyes the asbestos tape; right? 4 Q. Well, it's around -- 1990 or 1991 is around when 5 A. I saw some tape, yes. 5 lawyers asked you to do a search in Kerr Corporation's 6 Q. And it wasn't covered in rubber or cement or 6 files to find documents about asbestos; right? 7 plastic; right? 7 A. Yes. 8 A. Correct. 8 Q. Okay. And you knew that the reason that you were 9 Q. Okay. Now, if you look below, there's a caution. 9 doing that was because Kerr had been sued; right? 10 It says: "Caution, Contains Asbestos Fibers, Avoid 10 A. Correct. 11 Creating Dust, Breathing Asbestos Dust May Cause Serious 11 Q. Okay. The search was for sales records, purchase 12 Bodily Harm." 12 records, specifications, brochures or anything dealing 13 Did I read that correctly? 13 with asbestos products; right? 14 A. Correct. 14 A. It was very broad. 15 Q. Did Kerr ever put that warning on its products 15 Q. And you were one of the people that did that 16 that included asbestos tape? 16 search. You personally worked on it; right? 17 MR. TAURAS: I'm going to object... 17 A. Or the purchasing department, correct. 18 THE REPORTER: I'm sorry. Is there an objection? 18 Q. Well, my understanding is that Kerr went to each 19 MR. JONES: It sounds like an objection was made 19 department and asked for them to search for all the 20 under water. 20 records; right? 21 MR. TAURAS: I'm objecting. Assumes facts... 21 A. Anything that said something to do with asbestos, 22 THE REPORTER: I can't hear. 22 correct. 23 MR. JONES: It sounds like the attorney is 23 Q. And whatever you found, you packaged up and sent 24 getting a swirly while trying to object. 24 to Sybron; right? 25 MR. TAURAS: All right. Note my objection: 25 A. No. We gave it to Kovac. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 98 1 Q. My understanding of your testimony is that all 1 2 the documents were forwarded to Sybron's legal counsel. 2 3 A. I believe Kovac forwarded them. 3 4 Q. Okay. And Sybron was the parent company of Kerr 4 5 Corporation at that time in 1990 or '91? 5 6 A. Correct. 6 7 Q. Okay - 7 8 MR. REYEN: Actually can I have that question 8 9 read back. 9 10 (Record read.) 10 11 MR. REYEN: Okay. Your question lacks 11 12 specificity as to what Sybron entity but... 12 13 MR. JONES: You can tell me. 13 14 MR. REYEN: It was Sybron International, I 14 15 believe, at that time. 15 16 MR. JONES: All right. All I know is I sent them 16 17 a subpoena, and they didn't respond to it, and I moved 17 18 to compel. 18 19 MR. REYEN: I understand. But you sent a 19 20 subpoena to Sybron Dental Specialties, not to Sybron 20 21 International. 21 22 MR. JONES: All right. I'll send another one. 22 23 Sybron International. 23 24 MR. REYEN: The other -- the response on the 24 25 other one will come, but there is a distinction. 25 98..101 Page 100 are the documents you located in 1990 or '91 or whenever it was. Okay? A. Okay. MR. JONES: All right. We'll go off the record. So what -- however much -- about how much time you think you need? THE WITNESS: 15 minutes. MR. JONES: All right. We'll give you 15 minutes and come back. THE VIDEOGRAPHER: Okay. The time is twelve - I'm sorry -- 3:20 p.m. We are off the record. (Recess from 12:20 p.m. to 12:30 p.m.) THE VIDEOGRAPHER: Okay. We're back on the record, and the time is 12:30 -- or I'm sorry - 3:30 p.m. BY MR. JONES: Q. Mr. Girling, I have attached 52 pages of documents as Exhibit 3 to the deposition. Can you tell me what is Exhibit 3. A. Exhibit 3, where -- all 52 are Exhibit 3? Q. Yes. Collectively what is -- what is it? A. Documents found at Kerr Corporation. Q. Okay. Are these the documents that you found in your search in 1990 or 1991? A. I found the first two. Page 99 Page 101 1 MR. JONES: I can subpoena all day. 1 Q. Okay. The first two pages, you mean? 2 Q. Okay. Mr. Girling, I'm going to show you what 2 A. First two pages. 3 was represented to me to be everything you found when 3 Q. Okay. 4 you searched for asbestos documents in 1990 or 1991. 4 A. First two documents. 5 All right. 5 Q. Okay. It was represented to me by Kerr's lawyers 6 A. Okay. 6 that these are all of the documents that Kerr has 7 MR. JONES: I am going to mark this as Exhibit 3; 7 dealing with its sale of asbestos products; is that 8 right? 8 true? 9 (Plaintiffs' Exhibit 3 was marked for 9 A. I can't speak to that. I know what I found, and 10 identification and attached hereto.) 10 that's what I provided. 11 MR. JONES: Giselle, does that sound right? 11 Q. Okay. So when you were involved in this search 12 THE REPORTER: Oh, yes, yes. 12 for documents and you gathered everything up, about how 13 MR. JONES: All right. You've been around me 13 many pages did everybody find in total? 14 enough. You know you've got to watch this kind of 14 A. I don't know. I found two. 15 thing. I might switch to letters or symbols if you 15 Q. Okay. Now, in this deposition earlier, we talked 16 don't monitor the situation. 16 about all of Kerr's efforts to find a substitute for 17 Q. All right. Mr. Girling, this is a total of 52 17 asbestos; right? 18 pages. What I'd like to do -- and actually we'll go off 18 A. Yes. 19 the record to do it. But what I'd like you to do is 19 Q. It took many different people and several 20 just scroll through it to become generally familiar with 20 different divisions a while to do that; right? 21 what's in there. Okay. I'm not -- you don't -- I'm not 21 A. Yes. 22 going to ask you any questions about it. If I do, I'll 22 Q. Correct me if I'm wrong, but there are only 23 show it to you. 23 two -- well, pardon me. There's only one page in this 24 So I'm not asking you to memorize it. I'm just 24 document production related to Kerr's efforts to replace 25 asking you to scroll through it and confirm that these 25 asbestos tape with a nonasbestos product; true? Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 102 1 A. I don't know. I haven't gone -- I haven't 1 2 counted to see what's in there but... 2 3 Q. Scroll through. The only thing I see is your 3 4 memo dated October 19, 1978. That's all I see. But do 4 5 me a favor: Please scroll through the documents and let 5 6 me know if you see any other documents dealing with 6 7 Kerr's efforts to replace asbestos tape with a 7 8 nonasbestos product. 8 9 A. I see that one memo requesting a replacement. 9 10 Q. Okay. That's the only one you see in there; 10 11 right? 11 12 A. Correct, yes. 12 13 Q. Now, if you look at your memo -- first of all, 13 14 this does show that Kerr sent memos about this project; 14 15 right? 15 16 A. My memo was at the end of the project, correct. 16 17 Q. Do you think that's the only memo they ever sent 17 18 about the project? 18 19 MR. REYEN: Objection; calls -- 19 20 THE WITNESS: I don't -- 20 21 MR. REYEN: Calls for speculation. 21 22 THE WITNESS: I don't know. 22 23 BY MR. JONES: 23 24 Q. Well, the first thing you say is to -- so your 24 25 memo is the 50th page. At the bottom right, it says 25 102..105 Page 104 Q. There's no memos from marketing about this in the documents you've produced; right? A. I don't know. I didn't search marketing memos. Q. Well, if this is everything, it would be here; right? MR. TAURAS: Objection. THE WITNESS: I can't say. BY MR. JONES: Q. So I'm not -- so I'm not asking you if this is everything. I don't know. I filed a motion to compel Kerr to produce everything, and we'll find out if a judge grants it and if they comply with the order. My question to you is -- I'll start over. Do you see anywhere in these 52 pages any documents discussing marketing's agreement to market the new Carborundum 97-A material under the Kerr name of Flask Liner? A. No. Q. There's no documents from purchasing talking about buying the new material; right? A. I don't see any, yes. Q. There's no documents from research and development talking about their tests of the material; right? A. I didn't search research. Q. I'm asking you about in these pages. In these Page 103 1 Kerr zero-zero-zero-zero-zero-five-zero, Kerr -50. You Page 105 1 pages, there's no documents from research and 2 see that? 2 development talking about their tests of the new 3 A. No. I've got to make it bigger. Yes. 3 material; true? 4 Q. Okay. The first thing you say is, "Please 4 A. True. 5 circulate a PPL to discontinue supplying asbestos rolls 5 Q. There's no documents from finance talking about 6 in our investment packages and also individual sale of 6 how much the material costs and how that will affect the 7 boxed asbestos rolls." 7 price of the products; true? 8 Did I read that correctly? 8 A. Yes. 9 A. Yes. 9 Q. There's no documents -- no memoranda at all from 10 Q. What is a PPL? 10 Kerr's executives; right? Correct? 11 A. Product planning log. 11 A. Yes. 12 Q. And what does that mean? 12 Q. Ken Kovac, the person whose job it was to monitor 13 A. It's usually initiated to discontinue a product 13 things like the Federal Register, there's no memos from 14 or add a new product to the -- to the system. 14 Mr. Kovac; true? 15 Q. Okay. Your -- your memo mentions a PPL, but the 15 A. Yes. 16 PPL itself is not in these documents; right? 16 Q. There are no memos or any other documents talking 17 A. It is not. 17 about the 1976 American Dental Association document; 18 Q. What happened to it? 18 true? 19 A. I have no idea. 19 A. True. 20 Q. The next paragraph says, "Marketing has agreed to 20 Q. And we have the document, but nobody wrote a 21 market the new Carborundum 97-A (sic) material in boxes 21 memo -- there's no -- well, I don't know. 22 of 50 and 100 feet lengths under the Kerr name of Flask 22 Do you think somebody wrote a memo about it? 23 Liner." 23 A. I don't know -- 24 Do you see that? 24 MR. REYEN: Objection; calls for speculation. 25 A. Yes. 25 THE WITNESS: I can't guess about that. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 BY MR. JONES: Page 106 1 2 Q. All right. But, I mean, in your experience at 2 3 the company, is that something that would just spread by 3 4 word of mouth, that they would get this article and then 4 5 just kind of talk about it down the hall? 5 6 A. A lot of that did go on. 6 7 Q. Okay. So -- so you think the reason we're not 7 8 finding these documents is because Kerr got this 8 9 information that the product they sell could cause 9 10 cancer, and then they found a replacement for the 10 11 product, after testing several different candidates and 11 12 then found the replacement, and then informed marketing 12 13 to change the marketing materials to include the 13 14 place -- the replacement, and they did all of this by 14 15 word of mouth? 15 16 MR. REYEN: Objection -- 16 17 THE WITNESS: No -- 17 18 MR. REYEN: Hold on a second, Larry. 18 19 That is compound; it is argumentative; it calls 19 20 for speculation; and lacks foundation. 20 21 You can answer if you understand the question. 21 22 Go ahead, Larry. 22 23 THE WITNESS: What was the question, now? 23 24 BY MR. JONES: 24 25 Q. Is it your -- is it your testimony that this 25 106..109 Page 108 regulatory affairs that are discussing asbestos hazards; true? A. Yes. Q. There's no documents from manufacturing discussing the switchover from asbestos to nonasbestos; true? A. No. My -- I'm representing manufacturing. I sent the document out to Probst. Q. One page. A. Summary of all of -- of everything, yeah. Q. You're right. It's a summary of everything, but the everything -- all the documents that go into the everything are not in these 52 pages; right? A. Yes. Q. The PPL's not in there; right? A. Yes. Q. Okay. There's no documents from marketing talking about changing the price lists or marketing the new nonasbestos product, anything like that; right? A. Yes. Q. You told me that every year, Kerr's sales team did marketing forecasts; right? A. Yes. Q. The way you do marketing forecasts is you figure out how much you sold the year before, and then you make Page 107 Page 109 1 entire process involved with identifying the hazard of 1 a guess about if you're going to sell more or less; 2 the product and replacing the product was done through 2 right? 3 word of mouth? 3 A. Yes. 4 A. No. 4 Q. Educated guess, we'll call it; right? 5 Q. If there were memos about it, they're not here. 5 A. Yes. 6 They're not in these 52 pages; right? 6 Q. And a company keeps track of its sales to see how 7 MR. REYEN: Objection; calls for speculation; 7 it's doing year over year; right? 8 lacks foundation. 8 A. As far as I know. 9 THE WITNESS: I didn't search all the 9 Q. And Kerr kept records of its sales; true? 10 departments. I don't know. 10 A. I don't know about kept records. I know they 11 MR. JONES: I'm not -- 11 track sales, correct. 12 THE WITNESS: -- this is 18 years after the 12 Q. Well, and the reason they track sales is for 13 fact -- 13 accounting; right? You have to know how much you sold; 14 BY MR. JONES: 14 right? 15 Q. I'm not asking about all the departments. I'm 15 A. I can't speak to that. I'm a manufacturing guy. 16 asking about in the 52 pages you have in front of you, 16 Q. Well, I mean, you know generally that the company 17 you would agree with me that in those 52 pages, there 17 you worked at -- when you were in meetings with the 18 are no documents discussing asbestos hazards with Kerr's 18 marketing people and the other executives, you knew that 19 asbestos tape other than the ADA article; true? 19 they kept track of how much stuff they sold; right? 20 A. Yes. 20 A. Yes. 21 Q. There are no documents discussing Kerr's efforts 21 Q. And they wanted to do better than the year 22 to replace the asbestos tape with a nonasbestos tape; 22 before; right? 23 true? 23 A. I can't speak to that. 24 A. Yes. 24 Q. Wait. You're saying that when you were at the 25 Q. There are no documents from quality assurance and 25 corporation, there were years where you'd be in a Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 110 1 management meeting and somebody would say, you know, I 1 2 hope we don't sell as much this year? That never 2 3 happened, did it? 3 4 A. No. 4 5 Q. You always wanted to sell more; right? 5 6 A. I assumed they did. I'm not the -- I'm not the 6 7 person making that decision. What I'm saying, I'm a 7 8 manufacturing person; that's not my decision process. 8 9 Q. And you had to keep track of your customers 9 10 because you wanted to know who bought before so you 10 11 could make sure to sell them stuff again; right? 11 12 A. I can't speak to that. Again, I don't know. 12 13 Q. You don't -- you do know that Kerr kept sales 13 14 records; true? 14 15 A. I knew they had some sales records. 15 16 Q. And you know that all of the sales records 16 17 related to the sale of asbestos products have been 17 18 destroyed. 18 19 A. I guess. Couldn't find them. 19 20 Q. And what you've previously testified is that the 20 21 sales invoices, shipment invoices were destroyed and we 21 22 couldn't locate them, any of them in 1990, '91 on our 22 23 asbestos products; true? 23 24 A. That's what I said in a deposition, correct. 24 25 Q. So at some point between Kerr getting that 1976 25 October 19 of 1978; true? 110..113 Page 112 A. True. Q. So that means you sold the asbestos tape through almost all of 1978; right? A. Right. Q. And you never took the product off the shelf; right? A. I can't say that we did or didn't. Q. You never did a product recall; right? A. I don't know if we did or not. Q. You know what a product recall is? A. Yes, I do. Q. What is a product recall? A. Asking for product back. Q. Why? A. Defective. Q. Maybe it could hurt somebody; right? A. Possible. Q. When you were at Kerr, do you ever remember Kerr doing a product recall of asbestos tape? A. I don't remember. Q. The search for records in 1990 or 1991 did not include a search for corporate board of director meeting minutes; true? A. I don't know. Page 111 1 article in the American Dental Association journal and 1 Page 113 Q. Let me show you your testimony from the Witnowski 2 1990, when you searched for records, at some point in 2 case -- Witkowski. I'm sorry. Apologize to the 3 between, Kerr's sales/shipment invoices were destroyed; 3 Witkowski family. 4 true? 4 Can you please go to Page 63 of this deposition. 5 A. Can't speak to that. I don't know. 5 A. Okay. 6 Q. Well, you know they existed, and you know they 6 Q. You were asked -- this is your testimony, again; 7 were destroyed; right? 7 right? 8 A. I don't know -- 8 A. I believe so. 9 MR. REYEN: Objection; lacks foundation. 9 Q. You were asked at Line 13: "Back in '90/'91, 10 BY MR. JONES: 10 when this search was conducted for documents, did anyone 11 Q. Well, you know in 1976, Kerr sold asbestos tape; 11 look through the corporate board of director meeting 12 right? 12 minutes?" 13 A. Yes. 13 Your answer at Line 16: "I know our plant 14 Q. Those records are destroyed; correct? 14 response wouldn't require that. I don't know about the 15 A. I don't know if they're destroyed or missing or 15 corporate level." 16 lost or what. 16 Did I read that correctly? 17 Q. You said destroyed. 17 A. Yes. 18 A. Okay. That's what it was told me. 18 Q. We know that the documents you've produced don't 19 Q. Okay. 1977 Kerr sold asbestos tape. Those 19 include the meeting minutes for any of the managerial 20 records are destroyed; true? 20 meetings that you attended where they discussed 21 A. We couldn't find them, correct. 21 asbestos; true? 22 Q. 1978 Kerr sold asbestos tape. Those records are 22 A. Yes. 23 destroyed? 23 Q. And we know those documents don't include any 24 A. We stopped selling asbestos in 1978. 24 board meeting minutes; true? 25 Q. Well, according to your memo, it was sent in 25 A. Yes. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 114 1 Q. In fact there are no documents from an executive 1 2 of Kerr except for your one page; true? 2 3 A. Yes. 3 4 Q. And at that time, you weren't the person that 4 5 would make the decision to phase out asbestos. You were 5 6 the person that would carry out that decision; right? 6 7 A. Yes. 7 8 Q. Someone would have to communicate that decision 8 9 to you; right? 9 10 A. Not necessarily. The reason for the PPL was to 10 11 get people to sign off to make that decision. 11 12 Q. What does that mean? 12 13 A. That means that each of the functions had to sign 13 14 off: The president, vice president, sales, marketing 14 15 finance. By signing off, they gave the authorization to 15 16 make the change. 16 17 Q. So there would be communications about that 17 18 decision. 18 19 A. Only on a PPL, yes. 19 20 Q. Everything else would be word of mouth? 20 21 A. I don't know. 21 22 Q. We don't have the PPL or anything talking about 22 23 the PPL except for your one page; right? 23 24 A. As far as I know. 24 25 Q. Other than the sales records, do you know if Kerr 25 114..117 Page 116 of time required in the policy, it can then be thrown away; right? A. That's -- if that's what it says, correct. Q. And the first document retention policy you're aware of was in the 1980s at some time; right? A. My memory says '80 sometime - Q. Okay. A. -- after the merger. Q. What merger is that? A. Kerr was merged with Ormco and moved -- moved to California basically. Q. Did those -- did the Detroit office, where the marketing files and the R&D files and the executive files and purchasing files, did all of that move? A. I don't know. I was in charge of the manufacturing group, so I don't know what everything - got done with everything. Q. Well, I mean, did anything move from Michigan to California with the merger? A. I know some offices and desks got moved there. Q. Okay. Do you know if that document retention policy in the '80s instructed people to keep documents dealing with asbestos? A. I can't remember what -- I'd have to look at it. I can't remember what it said. Page 115 1 has destroyed any other records dealing with its sale of 1 Page 117 Q. Do you know if any documents related to asbestos 2 asbestos products? 2 were destroyed according to that document retention 3 A. I don't know. 3 policy in the 1980s? 4 Q. Okay. Did Kerr, while you were there, have a 4 A. Repeat that one. We weren't in asbestos in the 5 policy that you should keep any records related to its 5 '90s. 6 sale of asbestos products? 6 Q. Well, I know, but did the -- I'm asking about the 7 A. No. 7 '80s. And my question is were any documents related to 8 Q. Did Kerr destroy any records relating to its sale 8 Kerr's sale of asbestos products destroyed in the 1980s 9 of asbestos products in the normal course of business? 9 pursuant to a document retention policy. 10 A. I don't know. 10 A. Oh, I don't know. 11 Q. Did Kerr have a document retention policy? 11 Q. When's the first -- so is '90 or '91 the first 12 A. No. 12 time anyone ever told you that we need to find all the 13 Q. When's the first time Kerr had a document 13 asbestos documents and keep them? 14 retention policy? 14 A. Yes. 15 A. You're asking memory, and I -- it's after some of 15 Q. And you don't know what happened to those 16 the mergers we had. Maybe in '87, in the '80s or 16 documents before you looked for them; right? 17 something. 17 A. Yes. 18 Q. Okay. And what is a document retention policy? 18 Q. Did you have a file cabinet in your office? 19 A. It's specific guidelines on documents, I believe, 19 A. I did. 20 from what I can recall. 20 Q. How many file cabinets did you have? 21 Q. A document retention policy is a corporate policy 21 A. I can't remember. 22 that tells people in the corporation what documents to 22 Q. Roundabout. 23 keep and how long to keep them; right? 23 A. Couple -- maybe a couple. 24 A. Yes. 24 Q. Two or three? 25 Q. And once a document has been kept for the amount 25 A. Probably. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 118 1 Q. What did you keep in the file cabinets? 1 2 A. I, quite frankly, can't tell you everything I 2 3 kept in there. I know I had personnel performance 3 4 appraisals. 4 5 Q. Probably had different folders with documents for 5 6 different projects you worked on; right? 6 7 A. I could have. I don't know. It's a long time 7 8 ago. 8 9 Q. Okay. Other people had file cabinets; right? 9 10 You weren't the only person at Kerr in the '70s and '80s 10 11 that had a file cabinet; right? 11 12 A. Sure. 12 13 Q. Probably almost every office you went into had 13 14 file cabinets; right? 14 15 A. Possible. 15 16 Q. And in those file cabinets, people kept records 16 17 related to the stuff they were working on; right? 17 18 A. I don't know what they kept in them. 18 19 Q. Well, that's what you did; right? You kept in 19 20 file cabinets records of the stuff you worked on; right? 20 21 A. In purchasing, we did. 21 22 Q. All right. And so in 1990, did you search 22 23 through all -- everybody's file cabinets to find 23 24 asbestos stuff? 24 25 A. Yes. 25 118..121 Page 120 and the powders were in individual envelopes; right? A. Yes. Q. One serving per envelope; right? A. Correct. Q. And then it had a package of strips of asbestos so that the dental students wouldn't have to tear them; right? A. Yes. Q. So you know that Kerr marketed its investment products with asbestos tape to dental schools because it had a product specifically for dental schools; right? A. Yes. Q. You would expect that one of the dental schools Kerr marketed its products to would be the University of Southern California School of Dentistry; true? MR. REYEN: Objection; lacks foundation; calls for speculation. THE WITNESS: I -- I can't say that we shipped to California for sure. No idea. BY MR. JONES: Q. Is there any reason they wouldn't want to sell products to the University of Southern California School of Dentistry? A. There was many other competitors out there. I'm not sure. I don't know. Some of them were done on big 1 Q. And by 19 - Page 119 1 basis. Page 121 2 A. In purchasing, we did. 2 Q. I get it. But if USC would buy it, Kerr would 3 Q. By 1990, out of all those file cabinets at Kerr, 3 sell it; true? 4 the only documents left about asbestos are the 52 pages 4 A. I don't know if we had them as a customer. 5 we attached as Exhibit 3 to this deposition; true? 5 Q. I'm not asking you if you did. I'm saying if 6 A. I can't speak to that. I know the two that I 6 they would buy it, Kerr would sell it; right? 7 found. 7 A. If we offered -- if it would be offered, sure. 8 Q. All right. Well, do you know -- are there any 8 MR. JONES: Okay. All right. Mr. Girling, 9 other documents you remember finding that aren't in 9 that's all my questions. Thank you so much. 10 these 52 pages? 10 THE WITNESS: Wow. Thank you. 11 A. No. 11 MR. REYEN: Mr. Girling, before you go, I have a 12 Q. The last thing I want to ask you about is Kerr's 12 couple questions. Keith Reyen. 13 marketing of products to dental schools at universities. 13 THE WITNESS: Yes. 14 You know that Kerr marketed products to universities; 14 15 true? 15 EXAMINATION 16 A. Yes. 16 BY MR. REYEN: 17 Q. That included the investment products with 17 Q. Mr. Girling, when did Kerr stop selling 18 asbestos tape; true? 18 investment? 19 A. I can't say for sure that they bought those. But 19 A. It was in the mid '80s, early '80s. 20 we did have a product that was just -- was made for the 20 Q. Why did Kerr stop selling investments? 21 universities, correct. 21 A. We were losing market share rapidly. The 22 Q. Yeah. Kerr actually had a product specific for 22 Fiber Frax material really did not work very well. 23 university dental students; right? 23 Q. Okay. In your role in procurement, did you ever 24 A. Yes. 24 receive any information about any factors which limited 25 Q. And that product was a box of investment powders, 25 Kerr's presence selling investment on the West Coast? Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 122 1 MR. JONES: Lacks foundation; calls for 1 2 speculation. 2 3 THE WITNESS: Yes, I was approached numerous 3 4 times by people in Kerr about our Cristobalite 4 5 investment being uncompetitive on the West Coast because 5 6 we shipped it all the way from Michigan, and the freight 6 7 would make it unattractive to the -- to the labs or the 7 8 dealers. 8 9 MR. JONES: Move to strike on the same basis. 9 10 BY MR. REYEN: 10 11 Q. Okay. Is it correct, sir, that the -- that the 11 12 investment was sort of the main course, and the strip 12 13 asbestos was something that was needed to be used in 13 14 conjunction with that use? 14 15 A. That's correct. 15 16 Q. Okay. And is it correct that there are different 16 17 manufacturers of investment, and there's different 17 18 formulations of investment within companies? 18 19 A. Yes. 19 20 Q. And is it correct that -- 20 21 MR. JONES: Move to strike -- I'm sorry. Move to 21 22 strike as lacking foundation; and calling for 22 23 speculation. 23 24 BY MR. REYEN: 24 25 Q. Is it correct -- 25 A. Yes. 122..125 Page 124 Q. And the plastic bags were the ones that were put into the containers of investment; is that correct? A. That's correct. Q. Okay. And which form -- or which form of packaging did Kerr receive more of, the boxes or the bags? A. The bags -- the bags were the high volume items. We sold fewer boxed rolls than we did the bagged material. Q. Okay. Do you know of any reason that a consumer of investments and strip asbestos would have a preference for one brand of strip asbestos over another? MR. REYEN: Lacks foundation; calls for speculation. THE WITNESS: They were identical in my eyes and everybody else's eyes. MR. REYEN: All right. Thank you, sir. THE WITNESS: You're welcome. EXAMINATION BY MR. JONES: Q. So, Mr. Girling, one of Whip Mix's -- pardon me. Mr. Girling, one of Kerr's competitors was Whip Mix; right? 1 MR. JONES: Speculative -- Page 123 1 A. That was one. Page 125 2 BY MR. REYEN: 2 MS. RISCHMAN: Calls for speculation. 3 Q. Is it your understanding that those investments 3 BY MR. JONES: 4 had different properties? 4 Q. Whip Mix had to ship their product all the way 5 MR. JONES: Move to strike -- oh, pardon me. 5 from Kentucky; right? 6 Object; it lacks foundation; calls for speculation. 6 MS. RISCHMAN: Same objections. 7 THE WITNESS: Yes, yes, they were made for 7 THE WITNESS: I don't know for sure. We 8 different specific purposes. 8 understood there was some people that had distribution 9 MR. JONES: Move to strike on the same grounds. 9 warehouses in California. 10 BY MR. REYEN: 10 BY MR. JONES: 11 Q. And do you have any understanding as to whether 11 Q. Well, you had distribution in California; right? 12 or not the strip asbestos that was used in the lost wax 12 You distributed through Patterson; true? 13 process had similar differences or whether it was more 13 A. No, no. I'm telling you that they shipped 14 of a generic product? 14 investment products in bulk in carloads to distribution 15 MR. JONES: Lacks foundation; calls for 15 centers in California. 16 speculation. 16 Q. Well, if Kerr sells their product to Patterson or 17 THE WITNESS: We were told it was generic because 17 Henry Schein or Darby Dental in Michigan, and then Darby 18 our supplier told us he supplied everybody. 18 Dental or Henry Schein or whoever shipped it to 19 BY MR. REYEN: 19 California to a warehouse, then that product is in a 20 Q. Okay. And which suppliers were those? 20 warehouse in California; right? 21 A. Celotex, Nicolet. 21 A. Correct, at a higher cost. 22 Q. Okay. Kerr received strip asbestos from Nicolet 22 Q. And it's a lower cost than Whip Mix coming from 23 and Celotex in boxes; is that correct? 23 Kentucky; right? 24 A. Yes. 24 A. I don't think so. Kentucky was closer to the 25 Q. Okay. And it received it in plastic bags? 25 West Coast than Michigan. Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Page 126 1 Q. Well, I don't -- Mr. Girling, I don't want to 1 2 insult your geographic knowledge, but Kentucky is on the 2 3 East Coast, and Michigan is in the Midwest; right? 3 4 A. Kentucky is below Michigan. 4 5 Q. But it's east of Michigan? 5 6 A. I - 6 7 Q. To go from Kentucky to California, you have to go 7 8 past Michigan; right? 8 9 A. No, no, no. 9 10 Q. Now, you told me before that you really didn't 10 11 have much knowledge of what the marketing people did. 11 12 Do you remember that? 12 13 A. I do not. 13 14 Q. And you said you were in manufacturing; marketing 14 15 wasn't your job. Right? 15 16 A. Correct. 16 17 Q. How is it that all of a sudden you know they had 17 18 all these troubles selling stuff to the West Coast? 18 19 A. Because my sales guys, when they would come into 19 20 the home office, would say, "You guys got to do 20 21 something; we can't compete." 21 22 Q. Okay. But all of the other competing companies 22 23 were on the East Coast. Baker was in New Jersey; Whip 23 24 Mix was in Kentucky. 24 25 A. Pat supply was in Los Angeles. 25 126..129 Page 128 Q. You said that you went through a search and that, quote, The sales invoices, shipment invoices were destroyed, and we couldn't locate any of them in 1990, '91 on our asbestos products; true? A. That's correct, that's correct. I searched the purchasing department. Q. So we don't have the records of sales which have been destroyed. So now you're telling us that through word of mouth from salespeople that they didn't really sell much to the West Coast; true? A. We were not a factor in the West Coast like Whip Mix. Q. So you're saying Whip Mix from Kentucky was much more of a factor in the West Coast than Kerr in Michigan? A. To my understanding - MS. RISCHMAN: I'm going to object. Calls for speculation; lacks foundation. This is Suzanne - MR. JONES: Suzanne, you've got to go next on this. Q. I mean, maybe I got the geography wrong, but I'm pretty sure if you're going from Kentucky to the Kentucky Derby, you've got to go past Michigan and The Big House to get to the Rose Bowl. Right? Did Kerr's lawyers explain this geography to you when they told you 1 Q. What's that? Page 127 1 to tell this story in the deposition? Page 129 2 A. Other companies were on the West Coast, other 2 MR. REYEN: Objection. 3 competitors. 3 Don't answer that question. You know... 4 Q. Which one? 4 MR. JONES: It's just a question. 5 A. I can't say for sure. I've heard other 5 MR. REYEN: No, it's not a just a question. Go 6 competitors had distribution or production on the West 6 ahead. You're kind of losing it, but go ahead. Ask 7 Coast. 7 a -- ask a proper - 8 Q. Okay. So do you mean to suggest that if 8 MR. JONES: -- if you're going to come up with a 9 David Springer testified that he purchased Kerr asbestos 9 phony-bologna story and feed it to your witness, you've 10 tape in California that that was not possible? 10 got to make sure the geography works out. All right. 11 A. No, I'm not testifying that way. 11 That's all I'm saying. 12 Q. In fact you know that Kerr sold asbestos tape in 12 MR. REYEN: I'm going to reserve my right to take 13 California; true? 13 your comments to the court. 14 A. True, yes, we did. 14 MR. JONES: Okay. 15 Q. And if Kerr still had its asbestos tape sales 15 Q. Do you have any other evidence that Kerr wasn't 16 records, we would know exactly where Kerr sold its tape; 16 selling products on the West Coast other than what 17 true? 17 you've just described? 18 A. 12 years later, I don't know. 18 A. We didn't say we weren't selling products on the 19 Q. But Kerr does not have its asbestos sales 19 West Coast. We had a lower market share on the 20 records. They have been destroyed; true? 20 West Coast. 21 A. I don't know. 21 BY MR. JONES: 22 Q. You've previously testified that Kerr's asbestos 22 Q. Okay. And you don't have any documents saying 23 sales records have been destroyed; true? 23 that? 24 A. I was told -- I was told. I don't have personal 24 A. Absolutely not. 25 knowledge that they were. 25 Q. And you're -- you don't have any meeting minutes Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 talking about that; right? Page 130 1 2 A No, no. 2 3 Q And your job was production 100 percent of the 3 4 time at Kerr; true? 4 5 A True. 5 6 Q It was never in sales; true? 6 7 A True. 7 8 Q It was never in marketing; true? 8 9 A True. 9 10 MR. JONES: Pass the witness. 10 11 MR. REYEN: No further questions. That's it, 11 12 then 12 13 MR. JONES: All right. Thank you. 13 14 MR. TAURAS: Under California... 14 15 THE REPORTER: What's that? 15 16 MR. TAURAS: Under California law, do we read and 16 17 reserve or? 17 18 MR. JONES: Just do it to the Code. If you want 18 19 to, you can. You don't have to. 19 20 MR. TAURAS: Yeah, we'll reserve. We'll read it. 20 21 MR. JONES: We'll just do it whatever the law 21 22 says All right. Signing off. 22 23 THE VIDEOGRAPHER: Off the record, Counsels? 23 24 MR. REYEN: Yeah, thank you. 24 25 THE VIDEOGRAPHER: Okay. The time is 4:11 p.m. 25 130..133 Page 132 DECLARATION UNDER PENALTY OF PERJURY I, LAWRENCE J. GIRLING, do hereby certify under penalty of perjury that I have read the foregoing transcript of my deposition taken on January 29, 2021; that I have made such corrections as appear noted on the Deposition Errata Page, attached hereto, signed by me; that my testimony as contained herein, as corrected, is true and correct. Dated this 2 0 , at day of , , California. LAWRENCE J. GIRLING Page 131 1 This is the end of the videotaped deposition of Lawrence 1 DEPOSITION ERRATA SHEET 2 Girling, Volume I, dated January 29, 2021. We are off 2 Page No. Line No. 3 the record. 3 Change: 4 (Whereupon, at the hour of 1:11 p.m., the 4 Reason for Change: 5 deposition was adjourned.) 5 Page No. Line No. 6 6 Change: 7 7 Reason for Change: 8 8 Page No. Line No. 9 9 Change: 10 10 Reason for Change: 11 11 Page No. Line No. 12 12 Change: 13 13 Reason for Change: 14 14 Page No. Line No. 15 15 Change: 16 16 Reason for Change: 17 17 Page No. Line No. 18 18 Change: 19 19 Reason for Change: 20 20 Page No. Line No. 21 21 Change: 22 22 Reason for Change: 23 23 24 24 25 25 LAWRENCE J. GIRLING DATED Page 133 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 1 STATE OF CALIFORNIA ) Page 134 ) 2 COUNTY OF LOS ANGELES ) 3 4 I, Giselle Girard, a Certified Shorthand 5 Reporter, do herby certify: 6 That prior to being examined, the witness in 7 the foregoing proceedings was by me duly sworn to 8 testify to the truth, the whole truth, and nothing but 9 the truth; 10 That said proceedings were taken before me 11 at the time therein set forth and were taken down by me 12 in shorthand and thereafter transcribed into typewriting 13 under my direction and supervision; 14 I further certify that I am neither counsel 15 for, nor related to, any party to said proceedings, nor 16 in any way interested in the outcome thereof. 17 In witness whereof, I have hereunto 18 subscribed my name. 19 Dated: February 10, 2021 20 21 22 23 24 Giselle Girard CSR No. 12901 25 Page 135 1 Asbestos Reporters, a GPS Partner February 10, 2021 7119 West Sunset Boulevard 2 Suite 440 Los Angeles, California 90046 3 4 LAWRENCE J. GIRLING C/O: KEITH P. REYEN, ESQ. 5 OIUM REYEN & PRYOR 220 Montgomery Street 6 Suite 910 San Francisco, California 94104 7 8 Re: David Springer, et al. Vs. Asbestos Companies, et al. 9 Date of Deposition: January 29, 2021 10 Dear Mr. Girling, 11 The original transcript of your deposition taken 12 in the above-referenced matter is available at this office for your review. If it is more convenient to 13 read a copy of the transcript and waive signature of the original transcript, please notify our office by letter 14 sent certified or registered mail of any changes made, with copies sent to all counsel. 15 In the event you have not read, corrected and signed your deposition within thirty (30) days of the 16 receipt of this letter, it may be used with the full force and effect as though it had been read, corrected 17 and signed. If you wish to arrange an appointment to review 18 the original transcript, please contact this office at (888) 779-9974. 19 20 Sincerely, 21 Asbestos Reporters/GPS 22 Production Department Cc: All counsel 23 The deponent 24 Original: Original transcript 25 Asbestos Reporters/ a GPS Partner 888-779-9974 134..135 Lawrence Girling January 29, 2021 Exhibits Ex 1 8:7 37:3,12 38:6,8 39:4 EX 2 8:8 83:25 84:2,6,8 EX 3 8:10 99:7,9 100:18, 19,20 119:5 ___________ $_________ $1 54:8 $2 60:20 ( (C)(3) 87:22 -50 103:1 -51 37:18 -52 37:18 1 I 37:2,3,9,12 38:6,8 39:4 43:14 100 18:5,6 24:22 103:22 130:3 10:19 38:22,24 10:38 38:24 I I 82:15 11:50 90:8 12 32:15 88:2 127:18 12:06 90:8 12:20 100:12 12:30 100:12,14 12th 13:21 14:2 13 113:9 15 74:22 75:19 100:7,8 150 75:16 16 113:13 161 75:13,18,19 18 107:12 19 84:16 102:4 112:1 119:1 1910 86:12 1960s/early 30:15 1967 12:2 13:12 14:14,17 15:8 16:16 17:18 18:10 24:6 26:8 35:14 1969 27:23 1970 87:23 1970s 30:15 1971 87:18 1972 84:12,16,21 87:10 88:2 91:23 96:15 1973 28:6,15,19 1974 48:11 1976 35:6,10,24 36:14 40:2,14 41:6 43:17 44:6, 20 46:3 58:1,23 61:24 62:4,8 67:15,19 73:3,9,11, 18 105:17 110:25 111:11 1977 33:541:15 111:19 1978 102:4 111:22,24 112:1,4 1980 33:15 Index: $1..3:20 1980s 33:22 116:5 117:3,8 1990 97:2,4 98:5 99:4 100:1,24 110:22 111:2 112:22 118:22 119:3 128:3 1991 97:2,4 99:4 100:24 112:22 1996 15:11 1:38 39:1 2 2 83:25 84:1,2,6,8 20 18:19 43:8 83:5 20-pound 30:21 2003 24:6 33:23 2004 74:22 2021 9:1,19 210 74:23 24 82:3,4 24th 82:2 26 82:3,5 29 9:1,1986:11 2:50 90:6 3 3 99:7,9 100:18,19,20 119:5 30 79:2 35 27:8 35-pound 30:21 3:06 90:10 3:20 100:11 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 3:30 100:15 4 40 19:6 4:11 130:25 5 50 18:16 19:6 51:24 103:22 50s 35:21,23 50th 102:25 52 36:6 99:17 100:17,20 104:14 107:6,16,17 108:13 119:4,10 6 6 82:8 87:21 60s 18:6 24:18 60s/early 28:1 63 1134 67 14:15 24:22 27:13 68 17:22 7 7 84:16 87:18 91:23 70s 16:2 17:5 18:7 24:18 28:1 33:10 43:13 83:17 118:10 76 41:25 7th 84:12 8 80 116:6 80s 16:1,23 21:17 115:16 116:22 117:7 118:10 121:19 87 115:16 9 9 82:11 90 117:11 90/'91 113:9 90s 15:14 16:23 117:5 91 98:5 100:1 110:22 117:11 128:4 96 81-23 97-A 103:21 104:15 9:32 9:19 A a.m. 9:19 38:22,24 90:8 abide 89:25 ability 59:10 70:1 73:11 abreast 79:12,15 Absolutely 129:24 acceptance 49:4,6 accepted 49:3 accident 67:9 accordance 87:21 account 53:10,18 54:4 accounting 109:13 Index: 3:30..American accurate 81:3 Act 87:23 action 47'13 Actual 57:2 ADA 49:1,3,4 77:20 107:19 add 103:14 Administration 86:12 admissible 48:9 94:20 affairs 108:1 affect 23:3 105:6 affected 42:11 affirmed 10:7 affixed 93:7 afternoon 10:17 agency 82:16 agent 93:12 agree 9:1434:11 47:13 52:1 55:24 60:24 66:16 76:3 79:10 96:10 107:17 agreed 103:20 agreement 104:15 ahead 16:21 48:12 62:5 70:23 86:6 91:15 106:22 129:6 air 50:9 51:9 airborne 45:4 50:2 62:11 93:16 alternative 52:18 ambient 50:9 ambiguous 16:20 American 35:7,25 38:13 39:8 40:3,13 41:6 44:5 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 49:15 57:25 67:16 77:3,9 105:17 111:1 amount 115:25 analyzing 26:23 Angeles 126:25 answering 37:14 anymore 11:20 Apologize 113:2 appearance 10:1 appears 36:22 applied 88:1791:13,14 applies 40:22 apply 16:14 89:5 96:9 appraisals 118:4 apprised 55:13 approached 122:3 approval 52:3 April 40:2,14 41:6,14 area 22:24 28:10 68:2 argumentative 53:20 61:5 106:19 article 35:8,24 36:2,15 38:12 43:16,24 44:4 45:1 46:3,5 48:2,4,18,20,25 49:15,22 57:24 58:10 59:1,7,961:19,25 62:21, 23.24 64:11,15,25 73:3 106:4 107:19 111:1 asbestos 9:22,24 11:6,10, 16,20 13:2 28:13,16,24 29:2,9,17,18,19,20,21 30:1,3,6,11,1231:4,7,10, 15,23 32:7,11,14,21,23, 24.25 35:22 36:1,2 37:23 44:2,13,19 45:5,25 46:10 49:6,13,16,19 50:3,9,15, 23 51:8,20 52:6,19 53:3,6, 16.24 56:1 58:13,14,18 60:10,11,21 61:1 62:9,10, 22 63:22 64:19,22,24 66:9,15,20 67:20,25 68:2, 4,6 70:16,20 71:24 72:10, 21 73:1,5,12,18,19,22 76:2,5,7,25 77:22,24 78:2, 8.16.22 79:5 80:16 82:17 84:17,21,22 85:2 86:14, 19.20.23 87:1,20,25 88:6, 18.23 89:14,15,23 91:25 92:13 93:9,11,17,23 95:4, 10,11,1696:12,18,23 97:1,6,13,21 99:4 101:7, 17.25 102:7 103:5,7 107:18,19,22 108:1,5 110:17,23 111:11,19,22, 24 112:3,20 113:21 114:5 115:2,6,9 116:23 117:1,4, 8,13 118:24 119:4,18 120:5,10 122:13 123:12, 22 124:12,13 127:9,12,15, 19.22 128:4 asbestos-containing 80:11 83:4 asbestosis 45:6 64:12 92:1 asks 81:8 Association 35:7,25 38:13 39:8 40:3,14 41:6 44:5 49:16 67:16 77:3,9 105:17 111:1 assume 76:14 assumed 110:6 Assumes 95:21 96:1 assuming 81:2 assurance 42:6 48:2,18 Index: am o u n t..b a s ic a lly 59:7,14 79:11,14 83:10 85:10 107:25 attached 37:4 84:3 99:10 100:17 119:5 attend 77:5 attended 21:14 113:20 attending 35:1 attorney 65:13 95:23 authenticate 39:17 authenticity 81:4,6 authorization 114:15 Avoid 95:10 aware 14:15 66:21,23 67:24 77:2 78:6 116:5 B back 14:23 23:7 24:3 35:20 38:25 43:8 66:11 79:10 90:9 98:9 100:9,13 112:14 113:9 background 18:2 bad 25:8,11,17 45:25 63:24 64:22 bag 30:4,6 31:8,16 bagged 124:9 bags 30:13 73:1 123:25 124:2,7,8 Baker 126:23 base 72:20 based 26:23 46:22 48:10 56:22 basically 11:24 83:6 116:11 Asbestos Reporters/ a GPS Partner 888-779-9974 Law rence G irling January 29, 2021 basis 92:14 121:1 122:9 Bates 37:18 beginning 46:25 47:5 49:24 81:11 behalf 15:10,18 81:14 Benveniste 9:24 bias 34:8,9 big 65:19,22,25 120:25 128:24 bigger 37:11 75:5 103:3 binder 44:14 93:13 binders 44:11 94:15 bit 13:7 57:18 Blackledge 80:14 board 112:23113:11,24 Bob 12:13,15,16 17:16,19, 20 42:19,22,24 46:14 Bodily 95:12 bonding 93:12 books 57:8 Boom 36:20 booth 77:7 bottom 37:8 38:17 39:12 40:1,12 41:4 81:15,23 90:19 91:24 92:19 102:25 bought 29:21 30:2,10,14 60:1 76:18 110:10 119:19 Bowl 128:24 box 23:9 30:4,6,7,8,16,23 31:13,16,24 32:7 71:4,5 119:25 boxed 103:7 124:9 boxes 30:21 31:6 50:23 73:1 103:21 123:23 124:6 brain 19:16 brand 124:13 break 90:4,13 Breathing 95:11 Brighton 10:19,23 bring 43:16 67:5 brings 48:2,18 59:1,7 broad 97:14 brochures 97:12 brought 46:3 57:24 73:3 buck 21:7 47:3,24 bucks 54:7 Buffalo 74:4 bulk 125:14 bunch 37:16 business 12:20 13:4 17:20,24 18:6,11 34:12 46:20 58:1 115:9 buy 31:10 60:5 77:11 121:2,6 buying 84:21 104:19 C cabinet 117:18 118:11 cabinets 117:20118:1,9, 14,16,20,23 119:3 calculated 48:9 California 9:25 74:21 116:11,19 120:15,19,22 125:9,11,15,19,20 126:7 127:10,13 130:14,16 Index: b asis..catalo g s call 18:8 30:24 68:10 79:4 109:4 called 12:9,11 15:4 17:10 38:11 42:7 49:16 calling 25:13 122:22 calls 25:20 39:9 43:18 56:2 61:4 63:1,2,11 64:6 65:2 72:3 79:17,20 88:9 94:1 102:19,21 105:24 106:19 107:7 120:16 122:1 123:6,15 124:14 125:2 128:17 cancer 45:6 46:6 48:4,21 59:10 61:20 62:24 64:3,5, 7,13 106:10 cancers 92:1 candidates 106:11 cans 30:20,21 car 67:8 Carborundum 103:21 104:15 care 39:19,20 91:9 career 20:12 34:25 carelessly 50:8 51:8,9,12 carloads 125:14 carry 23:13 114:6 case 15:14 19:16 36:6 74:21 75:7 80:14,16 113:2 cast 56:8 casting 29:10,13 44:15,20 50:4,5 57:2 58:14 84:18, 19,20 castings 89:12 catalogs 54:17 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 catch 19:15 causally 45:5 92:1 caused 68:25 causing 48:4,21 caution 93:3,6,7 95:9,10 cautioned 49:7 cavity 14:4 Celotex 29:24 123:21,23 cement 93:25 95:6 centers 125:15 chair 19:2 chance 39:4 40:25 51:8 90:12,15 chanqe 23:8 46:11 54:16 59:11,13,1460:22 61:12 62:8 106:13 114:16 changing 108:18 Chapter 86:11 charge 15:7 16:16 17:2 42:2,14,15 52:11 53:6 60:17 61:3 85:9 116:15 charging 54:8 60:20 chemical 26:9,11 27:24 68:13 69:22 70:13 94:14 chemicals 13:5,6,9,13 14:6 68:7,11,17,20,22,23, 25 69:3,8,11,15,17 70:2 chemist 29:12 Chicago 77:4 chiefly 44:13 choose 9:11 circulate 103:5 circumstances 91:14 cite 45:14 classify 69:16 clerk 20:4 client 66:4 close 28:21 closer 41:15 125:24 Coast 121:25 122:5 125:25 126:3,18,23 127:2, 7 128:10,11,14 129:16,19, 20 coating 93:12 Code 45:15 130:18 Collectively 100:21 color 23:8 column 49:23 86:10 90:18 91:23 92:8 93:2 comeback 66:6 comments 88:8 129:13 committee 22:22 59:12 common 66:18 communicate 22:1 23:12, 15,21 25:5,9,18 27:19 54:23 55:1 61:14,17 83:14 85:3 114:8 communicated 22:17 24:14 25:22 55:3 communication 55:25 56:4 communications 114:17 companies 9:22 29:22,24 68:3 74:4 122:18 126:22 127:2 company 16:3 18:17,20 20:18 27:20 33:4 35:13 Index: catch..corner 59:2,8 70:21 83:15 85:3 98:4 106:3 109:6,16 comparison 60:11 compel 98:18 104:10 compete 126:21 competing 126:22 competitors 77:15 120:24 124:24 127:3,6 complete 49:23 comply 104:12 composition 94:15 compound 59:17 61:5 106:19 concentrations 93:16 concerned 62:19 conditions 49:8 conducted 113:10 confirm 39:7 99:25 confusion 76:8 conjunction 122:14 consequences 92:12 constituents 94:15 consumer 124:11 container 30:8 containers 30:17 93:10 124:3 control 13:15 14:22 17:3, 10 20:4 25:3 27:13 42:8 controlled 49:8 controversial 39:14 copy 74:20 corner 36:22 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 corporate 47:2 112:23 113:11,15 115:21 corporation 11:2,5 12:1,9, 11 15:11,1820:25 21:25 23:4 24:13 25:1 26:2,14 33:22,25 34:20,23 42:11 43:25 44:25 46:4,8,13 47:8 50:22 51:25 55:16 57:4 58:13 68:16 69:14 81:15,19,20,24 84:16 98:5 100:22 109:25 115:22 Corporation's 97:5 correct 11:3,4,7,8,11,24 12:3 18:1,4 20:23 23:11, 21 24:12 26:6,21 27:6 29:1 30:5 31:5,9,14,17 32:9,12,18,22 33:11,24 41:7 43:15 44:16,22 45:2, 11,23 46:21 47:6 48:22 50:11,1451:1252:6,7,9, 16.21.25 53:4 54:10,18,24 56:21 58:2,4,7,16,22 60:2, 8 67:3,7,11,14,22 68:15 69:13,25 70:9,11,14 74:17 75:1 76:11,20,23 77:8,19 78:17 79:16 80:23 82:22, 24 83:7,11 84:15,25 85:12 86:16 87:4,15 88:4 92:18, 22 95:8,14 96:13,17 97:10,17,22 98:6 101:22 102:12,16 105:10 109:11 110:24 111:14,21 116:3 119:21 120:4 122:11,15, 16.20.25 123:23 124:3,4 125:21 126:16 128:5 costs 54:7 105:6 Council 37:19,22 38:2,3 counsel 9:8,10 98:2 Counsel's 10:1 Counsels 130:23 counted 102:2 County 74:22 couple 33:15 117:23 121:12 court 9:5,25 10:3 40:6 45:17,18 129:13 covered 93:24 95:6 Creating 95:11 Cristobalite 51:3 122:4 criteria 56:17 cross-examination 85:20 86:4 90:22 91:3 crucible 29:14 33:1,2 crucibles 29:15,16 44:15, 20 50:4 58:14 customer 30:2 121:4 customers 72:1,13 73:6, 22 84:24 110:9 cut 32:10 49:9 50:8,21,23 51:3,8,14 cutting 51:5 D correctly 44:17 45:10 50:10 82:21 83:6 86:15 88:3 92:6,17,21 93:20 95:13 103:8 113:16 danger 50:7 dangerous 68:17 69:8,15, 18,23 cost 53:9,13 60:7,11,14, Darby 125:17 16.25 61:1,2,15 125:21,22 Index: c o rp o rate ..d e n ta l date 9:19 28:18 81:22 84:11 dated 102:4 dates 15:12 27:25 28:21 David 9:21 127:9 day 68:17 99:1 days 79:2 dealers 76:6 122:8 dealing 97:12 101:7 102:6 115:1 116:23 dealt 16:23 73:25 74:3 debris 93:8 decades 35:11 December 87:18 decertification 58:19 decertified 58:17 decide 61:12 62:8 decided 11:19 70:15 72:25 decision 22:16 34:18 46:9,12,19 47:8,12,21 53:5,8 71:23,25 110:7,8 114:5,6,8,11,18 decisions 20:25 21:3,5,25 22:1,11 23:3,11,12,15 47:1,2 49:4 60:23 default 75:11 Defective 112:16 defense 9:7 define 17:9 delivered 27:21 79:2 demonstrating 45:21 dental 12:10,11,16,19,21 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 18:8,11,22 19:2 35:7,25 37:20,22 38:3,13 39:8 40:3,13 41:6 44:5 49:16 50:3 58:1,3 67:16,24 71:8, 18,21 72:1,13 74:4 77:3,9, 11 84:17 88:24,25 96:23 98:20 105:17 111:1 119:13,23 120:6,10,11,13 125:17,18 dentist 19:2,8 29:6 49:8 50:18 62:12 89:7,19,22 dentistry 18:3 36:1,3,14 37:23 44:3,14 49:17 120:15,23 dentists 18:25 50:16 62:12,17 64:24 67:23 71:8,11,18,21 72:1,13 76:22 84:17 96:22 dentists' 89:6,14 department 13:17 14:21 15:7 16:18,22 17:10 19:3, 19 21:22 23:3 25:1,2,3,4,5 26:11 27:22 52:17 56:14 57:4 61:9 86:12 97:17,19 128:6 departments 13:15 14:19, 20 19:1420:8,13,15,19 22:1,23 24:4 25:6 26:15, 16 52:8 55:25 57:14,16 59:20,21 107:10,15 deposition 9:20,23 28:5 33:9 43:4 72:7 74:20,24 75:10,1480:13,15,20 81:12,20 82:2 85:23 100:18 101:15 110:24 113:4 119:5 129:1 depositions 15:17,20 Derby 128:23 description 42:16 desirable 92:16 desks 116:20 destroy 115:8 destroyed 110:18,21 111:3,7,14,15,17,20,23 115:1 117:2,8 127:20,23 128:3,8 determination 92:4 determine 26:18 80:9 82:13 83:2 Detroit 13:19,20,21,23 70:4,7,10 116:12 developers 78:13 developing 56:22 development 13:16 15:3 25:4 45:5 52:23 53:2 54:12 55:6,14 56:11,14, 19,22 57:4 59:14 104:22 105:2 developments 42:11 Devices 38:4 difference 51:5 differences 123:13 differently 82:18 dipped 93:23 direction 51:20 directions 51:2 directly 55:18 director 33:16 35:4 42:23 112:23 113:11 disagreed 47:15 discontinue 103:5,13 Index: d e n tis t..d o c u m e n ts discovery 48:9 discussed 48:25 62:23,24 113:20 discusses 44:6 discussing 104:14 107:18,21 108:1,5 diseases 46:1 62:24 displayed 80:13 disposal 93:15 dispute 92:4 disputed 91:24 distinction 98:25 distributed 125:12 distribution 125:8,11,14 127:6 distributors 74:6,7,12 75:20,24 76:10,12,17,25 79:4 division 26:9 27:24 68:14 divisions 14:16,18,19 26:16,17 101:20 document 36:5 39:17 40:4,8,13 41:8,13 44:8,21 45:8,13 81:10 85:14,16 86:3 87:7 90:23 91:2,22 92:25 96:12 101:24 105:17,20 108:8 115:11, 13,18,21,25 116:4,21 117:2,9 documented 45:4 documents 36:6,7 59:16 97:6 98:2 99:4 100:1,18, 22,23 101:4,6,12 102:5,6 103:16 104:2,14,18,21 105:1,5,9,16 106:8 107:18,21,25 108:4,12,17 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 113:10,18,23 114:1 115:19,22 116:22 117:1,7, 13,16 118:5 119:4,9 129:22 dressings 44:11,14,23 drop 49:5 drums 30:22 duly 10:7 duration 92:1 Dust 86:14 95:11 E earlier 101:15 early 121:19 east 126:3,5,23 Eaton 19:14 economical 53:23 54:3 Educated 109:4 effect 63:8 effort 73:21 efforts 101:16,24 102:7 107:21 election 9:12 electron 94:10 eligible 49:3 else's 124:17 emergency 87:18 88:7 employ 18:25 employed 81:19,2483:14 employee 16:8 32:6 employees 24:15 25:19 68:16,1969:7,11 71:2 84:22 87:13 92:20 end 28:14 55:10 102:16 endodontic 12:24 14:3 entire 44:17 91:16 107:1 entirety 48:8 entity 17:1898:12 envelope 120:3 envelopes 120:1 escapes 35:3 essential 92:13 establish 94:13 established 90:22,24 91:4,12 establishing 88:22 etal 9:21,22 Everard 52:14 56:5 everybody's 118:23 evidence 11:13 22:20 45:15 48:10 92:15 96:1 129:15 exact 28:18 41:16 examination 10:14 85:22, 25 121:15 124:21 examined 10:7 examining 85:22 Excellent 37:12 excess 93:17 executive 43:17 46:4 47:7 48:19 59:1,7 73:4 114:1 116:13 executives 35:6 41:18 43:25 46:5,18 48:3,5,19, 23 49:15 55:12 62:8 73:9 Index: d re s s in g s ..fa c to rs 105:10 109:18 exhibit 36:16 37:3,9,12 38:6,8 39:4 83:21,25 84:1, 2,6,8 90:15 99:7,9 100:18, 19,20 119:5 existed 111:6 exit 46:20 expect 16:8 120:13 expensive 53:16 60:22 experience 106:2 expert 64:6 90:24 91:11 expertise 68:2 experts 68:6,7,11 explain 128:25 expose 70:21 exposed 63:14 65:7 89:14 exposure 49:19 50:2 86:14,19 87:19,25 88:23 89:11 91:24 92:5,13,14 93:17 extent 16:6 48:7 eyeballs 94:12 eyes 94:7,10 95:4 124:16, 17 F facilities 13:19 facility 32:19 fact 15:9 73:21 97:3 107:13 114:1 127:12 factor 128:11,14 factories 14:13 factors 121:24 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 factory 31:15 71:2 facts 11:12 22:20 95:21 96:1 fair 16:18 19:7,9,10 28:11, 19,22 41:17 44:24 60:20 75:13 fall 41:10,11 falls 67:5 familiar 20:5 29:15 35:24 38:8 69:14 80:7 87:9,11 91:12 94:14 99:20 family 113:3 fault 89:6,14 favor 102:5 federal 79:12,15,16 80:2, 3,4,6,9 82:16,19 83:2,10, 12 84:9 85:1 87:20 88:1,6, 16,1991:22 96:11,14 105:13 feed 129:9 feet 103:22 fewer 124:9 fiber 89:10 121:22 fibers 50:2 63:14,22 87:20,25 88:23 92:13 93:10,11,17 95:10 fibrosis 45:6 64:12 figure 108:24 file 117:18,20 118:1,9,11, 14,16,20,23 119:3 filed 104:10 files 14:3 97:6 116:13,14 filling 12:23 14:4 finance 14:21 18:2 20:9 25:2 54:13 105:5 114:15 financial 34:2 find 34:13 52:3,18 53:2,22 54:2,15,25 55:10 64:18,22 69:22 83:14 94:22 97:6 101:13,16 104:11 110:19 111:21 117:12 118:23 finding 52:6 53:5 106:8 119:9 finds 54:21 finish 79:23 finishes 40:25 Fire 68:24 Flask 103:22 104:16 flasks 29:13 focus 58:9 folders 118:5 follow 31:25 forecast 27:5 forecasts 26:23 27:1 108:22,24 forefront 71:13 foreseeable 93:14 forgot 96:7 form 124:5 formulation 94:3,6 formulations 122:18 forwarded 98:2,3 found 60:19 71:22 77:25 78:3 97:23 99:3 100:22, 23,25 101:9,14 106:10,12 119:7 foundation 20:20 21:2 22:19 39:9 53:21 56:2 Index: factory..Girling 61:4 63:1 70:18 72:3 79:17 88:9 94:1 106:20 107:8 111:9 120:16 122:1, 22 123:6,15 124:14 128:18 Francisco 74:22 frankly 64:20 69:20 75:12 118:2 Frax 121:22 freight 122:6 Friday 9:1 front 57:20 107:16 full 10:20 81:8 92:8 fully 37:13 functional 20:7 functions 114:13 future 63:15,19 G gather 32:15 gathered 101:12 gave 80:16 97:25 114:15 general 50:5 60:1 generally 11:18 32:20 99:20 109:16 generic 123:14,17 gentleman 17:5,24 geographic 126:2 geography 128:21,25 129:10 Girard 10:1 Girling 9:20 10:6,16,21 16:11 34:5,19 37:2,9 39:3 Asbestos Reporters/ a GPS Partner 888-779-9974 Law rence G irling January 29, 2021 40:10 41:4 45:24 74:18,25 80:13,14,20 84:1 85:15 86:8 90:12 91:20 94:25 96:10 99:2,17 100:17 121:8,11,17 124:23,24 126:1 Giselle 10:1 14:23 83:21 99:11 give 36:4 63:22 100:8 goal 53:22,23 54:2 73:15 gold 84:18 good 9:8 63:14,18 92:16 government 80:4 GPS 9:25 grab 31:23 grants 104:12 grave 92:12 grocery 67:5 grounds 123:9 group 20:24 21:21 43:23, 24 79:11,1583:5,6 116:16 guess 18:21 19:21 105:25 109:1,4 110:19 guessing 24:19 guidelines 86:18 87:1 89:8,20,25 115:19 guy 109:15 guys 22:6,10 126:19,20 gypsums 14:11 H hall 106:5 handle 32:20 54:12 71:3 handled 15:24 16:2,5 71:4 handling 93:14 handwritten 80:21 happen 66:3 happened 56:5 57:17 66:3 103:18 110:3 117:15 harassing 91:17 Harm 95:12 hazard 63:25 64:1,7 70:25 107:1 hazardous 51:21 62:11 64:8,12 70:21 71:7 hazards 36:2,14 37:22 44:2 49:16 67:25 68:24 70:2 76:25 77:21 107:18 108:1 head 17:10 20:7,13 43:2 48:1,17 59:6 heads 20:15,18 21:22 23:3 24:4 health 16:24 71:25 72:12 86:12,13 87:23 hear 95:22 96:1 heard 66:14,16,24 67:2,4, 8 127:5 hearing 80:5 hearsay 63:11 91:2 held 9:23 Henry 74:3 125:17,18 hereto 37:4 84:3 99:10 Hey 38:20 high 91:25 124:8 higher 125:21 Index: G is e lle ..in c lu d e Highlights 84:9 hired 12:1356:14 hiring 56:17 Hold 106:18 home 10:24 126:20 hope 110:2 House 128:24 HR 16:8,22,23 huge 22:4 human 15:5,7,23 16:5,17 25:4 hundred 24:24 hundred-pound 30:22 hurt 62:13,19 63:9 64:24 66:967:12,1769:11 73:23 96:23 112:17 I idea 18:21 22:3 25:17 43:19 53:8 57:11 77:9,16 103:19 120:19 identical 124:16 identification 37:4 84:3 99:10 identify 40:7 identifying 107:1 important 43:24 44:24 51:5 impression 12:23 13:8 14:4,6 69:17 improper 85:19 87:7 90:22 include 106:13 112:23 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 113:19,23 included 30:3 95:16 119:17 includes 9:8 46:6 48:4,20 59:8 individual 30:24 32:4 61:17 84:23 103:6 120:1 individual-use 30:25 individually 30:24 industry 18:8 inform 73:22 information 27:20 34:3 51:18 61:14 69:22,24 106:9 121:24 Informative 43:23 informed 77:20 106:12 informing 46:4 48:2,19 ingredient 46:6 48:4,21 59:9 61:20 initiated 103:13 inlay 51:2,3 inspection 86:18 instruct 34:13,16,17 instructed 116:22 instructions 51:14 insult 126:2 intensity 91:25 interact 77:10 International 98:14,21,23 interrogatories 39:15 interrupting 85:25 interviewed 12:15 17:16 introduce 91:1 inventory 78:9 investment 12:24 13:1 18:14,1528:1729:13,18, 20 30:7,9,10,14,16,18,25 31:22 32:4 35:10,11,21 71:24 103:6 119:17,25 120:9 121:18,25 122:5,12, 17,18 124:3 125:14 investments 14:11 121:20 123:3 124:12 invoices 110:21 111:3 128:2 involve 59:13 involved 11:21 16:4 52:5, 8,15,1754:11,1555:8 59:16 101:11 107:1 involvement 11:9,22 Issue 84:10 issues 16:8,23 17:3 48:18 54:12 items 124:8 J Jack 52:14 56:5,9 January 9:1,19 88:2 Jay 10:21 Jersey 126:23 jewelry 18:13,15 job 17:8,9 26:18 27:10 33:13 42:10,16,25 43:13 61:11 68:13 69:10 74:10 79:22 83:9 84:13 85:3 88:16 105:12 126:15 130:3 Index: in clu d ed ..K eith joined 16:3 24:22 33:3 35:12 JONES 9:4,14 10:10,12,15 11:17 12:8 14:23 15:1 16:9,13,21 17:1 20:21 21:6,16,1822:5 23:1,19 25:1426:1,7 34:7,11,13 36:20 37:1,5,7,17,21 38:20 39:2,13,18,21,25 40:5,16,21 41:3 43:21 44:12 45:9,12,17,22 48:16 54:1 56:10 57:13 59:5,22 61:7 63:6,17,23 64:7,10 65:3,5 66:1,5 68:9,12 70:23 71:1 72:11,18 74:14,17 75:6 80:1 81:7 83:24 84:4 85:8,13,17,21 86:5,7 87:8 88:14 90:5,11 91:4,8,1892:394:5,11,18, 22 95:19,23 96:2,5 98:13, 16,22 99:1,7,11,13 100:4, 8,16 102:23 104:8 106:1, 24 107:11,14 111:10 120:20 121:8 122:1,9,21 123:1,5,9,15 124:22 125:3,10 128:19 129:4,8, 14,21 130:10,13,18,21 journal 35:25 38:12 39:8 40:2,1341:6 44:5 111:1 journals 57:8 judge 104:12 July 74:22 June 84:12,16 91:23 K keeping 55:16,18 Keith 40:18 66:5 94:25 121:12 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Ken 17:6 38:10 41:20,22 42:1 79:10 83:9,17 84:13 85:3,5 105:12 Kentucky 125:5,23,24 126:2,4,7,24 128:13,22,23 Kerr 11:2,5,7,10,19 12:1, 4,7,9,10,11,14,15,16,19 13:4,10,12,19 14:12,16 15:8,11,18 17:2,16,18,19, 20.23.25 18:5,25 19:7,18 20:18,25 23:2,9 24:6,13, 17 25:6,18 26:2,14 27:18 28:23 29:8,17,19,21 30:1, 1431:11,18,21,24 32:3,6, 7.10.13.19.23 33:22,25 34:19,22 35:6,10 36:5 37:18 41:18 42:11 43:5,25 44:6,19,24,25 46:4,6,8,9, 13 47:8,15 48:3,5,19 50:12,15,22 51:5,25 54:21 55:16 57:4 58:13,23 61:19 62:7,22 65:1,9 66:8,15,19, 24 67:15,20,23,25 68:7, 16.19.25 69:2,7,10,14 70:1,4,12,1571:11,12,17, 20.22.23 72:4,6,12,22 73:4,8,9,11,18,21,25 74:7, 11 75:19,23 76:9,12,15, 21,24 77:3,16,20,24 78:2, 7 79:4 80:8 81:14,19,20, 24 83:1,13 84:13,16,21 85:2,10 86:17 87:9,11,13 88:15 91:12 92:23 95:15 96:10,15,18 97:1,5,9,18 98:4 100:22 101:6 102:14 103:1,22 104:11,16 106:8 109:9 110:13,25 111:11, 19,22 112:19 114:2,25 115:4,8,11,13 116:10 118:10 119:3,14,22 120:9, 14 121:2,6,17,20 122:4 123:22 124:6 125:16 127:9,12,15,16,19 128:14 129:15 130:4 Kerr's 18:6,10 28:16,25 29:2 30:2 31:1549:14,18 51:14 57:25 59:9 64:24 69:11 72:23,25 74:8 79:14 83:13 89:23 101:5,16,24 102:7 105:10 107:18,21 108:21 111:3 117:8 119:12 121:25 124:24 127:22 128:24 key 49:10 kind 15:21 46:25 65:20 74:4 92:9 93:2 99:14 106:5 129:6 kit 31:2,3,21 32:3 kits 32:25 knew 16:5 64:11 66:11 67:12 68:19 69:7 97:8 109:18 110:15 knowledge 66:18 72:20 81:17 126:2,11 127:25 knowledgeable 72:6 Kovac 17:638:1041:10, 20,22 42:1,19 43:16 46:3, 1548:1,1751:1952:11 73:3 79:10 83:17 85:5 97:25 98:3 105:12,14 Kovac's 42:10 83:5,9 84:13 85:3 L lab 50:18 62:12 89:12 label 82:17 93:11 labeling 80:10 83:3 93:6 labels 93:4,6,7 Index: K en ..leg al Labor 86:11,12 laboratories 50:3 88:24 laboratory 13:1349:8 50:6 labs 51:11 122:7 lacking 122:22 lacks 20:20 21:2 22:19 39:9 53:20 56:2 61:4 63:1 70:17 72:3 79:17 88:9 94:1 98:11 106:20 107:8 111:9 120:16 122:1 123:6, 15 124:14 128:18 large 50:6 75:2 larger 36:23 Larry 11:14 36:21 37:13 40:24 48:12 74:24 75:3 79:23 80:20 106:18,22 late 21:17 28:1 30:15 33:10 43:13 law 130:16,21 Lawrence 9:20 10:6,21 laws 80:5 lawsuit 66:14 67:5,10,13 lawsuits 66:11,15,17,18 67:2 lawyer 36:9 lawyers 90:13 97:5 101:5 128:25 lay 25:13,20 lead 48:9 learned 16:17 77:21 left 119:4 left-hand 37:8 86:10 legal 16:9 45:13 98:2 Asbestos Reporters/ a GPS Partner 888-779-9974 Law rence G irling January 29, 2021 lengths 103:22 letter 38:7,9,11 46:22,23 letters 99:15 letting 65:19 level 92:5 113:15 liable 66:8 libraries 70:10 library 70:12 lies 50:7 limited 121:24 limits 88:23 89:11 93:18 liner 46:1052:1958:14 103:23 104:16 liners 14:4 33:1,2 lines 37:16 lining 44:15,19 lists 35:20,23 108:18 litigation 97:2 live 10:22,23 Lives 92:20 locate 110:22 128:3 located 100:1 location 9:6 log 57:8 103:11 logic 72:9 long 17:23 19:5 91:25 115:23 118:7 longer 49:3 looked 39:6 60:14 69:22 117:16 loop 55:6 Los 126:25 lose 45:17,20 losing 121:21 129:6 lost 36:25 111:16 123:12 lot 15:21 23:8 27:8 49:4 52:5 55:24 106:6 Louisiana 15:14 80:16 lousy 56:9 lower 125:22 129:19 lung 45:6 62:24 64:13 M machines 50:5 made 12:21 13:8 14:3,11 20:24 21:4,5 22:11 23:3, 11 27:18,21 39:22,23 46:13,15,19 47:1,2 49:4 59:11 69:17 71:23 73:21 86:6 89:12 95:19 119:20 123:7 main 58:9 122:12 maintained 52:12 major 70:7 make 9:11 12:20 14:6 21:25 27:4,19 34:18 36:23 37:11,13 39:23 40:22,24 46:8 47:8,10,11 48:8 53:14 54:8 60:23 61:2 67:23 69:10 70:20 71:24 75:4 85:10 86:5 89:10 94:4 103:3 108:25 110:11 114:5,11,16 122:7 129:10 makes 31:19 47:21 72:4 making 10:12 110:7 management 19:14,18,21, Index: len g th s..m aterial 24 20:6,24 21:4,10,21,24 22:6,17,22 35:1 46:18 59:12 110:1 manager 27:12 28:7,11,23 33:5,11,1343:13,14 52:14,22 managerial 113:19 managers 23:14 27:22 manner 49:10 manufactured 13:8 68:4 86:23 manufacturer 89:2,4,20 90:1 manufacturers 74:2 87:1, 2 94:4 122:17 manufacturing 32:19 33:16,19,21 70:3 108:4,7 109:15 110:8 116:16 126:14 mark 37:1 61:13 83:24 99:7 marked 37:3 72:23 83:21 84:2,5 99:9 market 103:21 104:15 121:21 129:19 marketed 119:14 120:9,14 marketing 14:22 20:10 25:2 26:24,25 27:4 43:2 54:13,14,15,19 55:4,8 103:20 104:1,3 106:12,13 108:17,18,22,24 109:18 114:14 116:13 119:13 126:11,14 130:8 marketing's 104:15 material 31:1 44:15,19 52:22 60:9,19 70:22 93:13 103:21 104:16,19,22 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 105:3,6 121:22 124:10 materials 12:23,24 13:1 14:4,7 26:19 27:18 28:7, 11,22 33:14 38:3 43:13 53:9,14 54:21 60:14 69:17 71:24 93:8 106:13 matter 9:21 meaning 12:19 31:21 32:10 58:20 means 47:3 56:20,22 112:3 114:13 meant 16:8 63:22 meet 27:4 meeting 21:21 22:13 23:14 35:6 38:9 41:10,17, 18 42:24 43:6,17,20,22 46:4,18 47:7 48:19,24 49:11 51:17 55:13,22 57:24 59:1,8,11 62:18 73:4,8 110:1 112:23 113:11,19,24 129:25 meetings 21:10 22:7,10, 22.23.25 24:3,5 35:1 55:20 109:17 113:20 memo 24:8 102:4,9,13,16, 17.25 103:15 105:21,22 111:25 memoranda 57:15 59:15 105:9 memorize 99:24 memory 19:135:3115:15 116:6 memos 23:16,24 24:1,2, 11,15 102:14 104:1,3 105:13,16 107:5 mentions 103:15 merged 116:10 merger 116:8,9,19 mergers 115:16 mesothelioma 62:25 mesotheliomas 45:7 64:13 met 76:18 method 56:15 Michigan 10:19,22 70:5,7, 10 116:18 122:6 125:17, 25 126:3,4,5,8 128:15,23 microscope 94:10 mid 15:14 33:22 121:19 middle 86:10 90:18 91:23 92:9 93:3 Midwest 126:3 Milwaukee 13:22 14:10 mind 16:11 63:2 96:6 minute 11:22 minutes 22:10,13 90:4 100:7,8 112:24 113:12,19, 24 129:25 misleading 11:13 missing 111:15 misstates 11:12 22:20 63:20 70:17 Mix 124:25 125:4,22 126:24 128:12,13 Mix's 124:23 mixtures 93:8 modified 93:12 moment 82:25 money 53:14 54:9 Index: m ate ria ls..n o rm a l monitor 42:10 83:10 84:13 88:16 99:16 105:12 month 21:15 79:2 monthly 22:25 35:1 moot 40:6 45:17,18 morning 10:17 motion 9:11 59:12 104:10 motions 9:8 motive 77:12 mouth 25:6,8,12,18 106:4, 15 107:3 114:20 128:9 move 116:14,18 122:9,21 123:5,9 moved 71:5 98:17 116:10, 20 mute 19:12 N named 17:6,24 necessarily 23:17,20 94:20 114:10 needed 26:1927:18,19 70:14 122:13 Nelson 17:17,24 20:19 21:4,7 47:4 Nelson's 18:2 Nicolet 29:24 123:21,22 nineteen 13:10 nonasbestos 46:12 55:14 60:21 62:9 78:7 79:6 101:25 102:8 107:22 108:5,19 normal 115:9 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 Note 95:25 notes 22:14,15 23:25 24:3 57:7 59:15,20 notice 87:23 notification 82:18 notifications 80:5 notified 82:16 number 82:5 numbers 37:18 numerous 122:3 O object 16:1940:941:1 48:6 87:5 90:21 95:17,24 123:6 128:17 objecting 95:21 objection 9:7,10 11:12 12:5 16:6,14 20:20 21:1 22:2,19 23:18 25:13,20 26:4 34:2,15 39:9,22,23, 24 40:7,22 44:8 45:12,14, 18 53:20 56:2 57:10 59:17 63:11,20 65:2 68:8 72:16 78:24 79:17,24 85:5 86:5 91:19 94:1,9 95:18,19,25 96:9 102:19 104:6 105:24 106:16 107:7 111:9 120:16 129:2 objections 16:9 40:15 81:5 91:15 92:2 125:6 Occupational 86:11,13 87:22 occur 50:3 October 102:4 112:1 offered 121:7 office 88:25 116:12 117:18 118:13 126:20 offices 14:12 116:20 operations 33:5,11,13 43:14 opinion 25:13,20 64:6 opt 9:10 order 25:5 104:12 ordering 11:6 Ormco 116:10 OSHA 82:8,13,16 87:9,10, 12,14 88:22,23 89:5,8,19, 25 90:15,24 91:13 96:11 OSHA's 86:18,25 88:13 overbroad 21:1,13 22:2, 20 26:4 68:8 overtime 23:7 owned 33:25 P p.m. 39:1 90:6,8,10 100:11,12,15 130:25 package 31:19 32:6,16,21 71:3,4,5 120:5 packaged 31:18 32:16 97:23 packages 31:6 84:23 103:6 packaging 72:22 124:6 packets 30:16,24,25 31:22 32:4 pages 36:6 74:23 99:18 100:17 101:1,2,13 104:14, 25 105:1 107:6,16,17 Index: N ote..p eo p le 108:13 119:4,10 pails 30:21 paragraph 45:3 90:19 92:9,19 93:18 103:20 pardon 64:4 80:14 101:23 123:5 124:23 parent 98:4 parking 23:7,8 part 13:426:12,1329:10 43:20 44:16 53:5 71:15 86:12 parties 9:4,6,14 Partner 9:25 Pass 130:10 past 42:1 126:8 128:23 paste 13:8 49:1,2 58:9,12, 17 pat 78:14 126:25 Patterson 74:4 125:12,16 pausing 65:20 paying 59:24 PDF 82:2 pending 74:16 pension 34:22 people 17:3 22:14 23:13 24:10,17,22 26:3 27:9,20 51:10,13,17 52:23 55:4,12 56:13,15,1861:1562:19 63:9 66:9 67:20 69:3,10 71:7 76:18 77:10 87:2 96:23 97:15 101:19 109:18 114:11 115:22 116:22 118:9,16 122:4 125:8 126:11 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 percent 18:5,6,16,19 130:3 performance 118:3 period 11:19 55:24 periodontal 44:11,14,22 49:1,2 58:9,12,17 peritoneal 45:7 64:13 permanent 87:24 person 72:6 81:17 83:17 105:12 110:7,8 114:4,6 118:10 person's 88:10 personal 127:24 personally 23:23 66:11 95:3 97:16 personnel 50:7 118:3 persons 63:3 phase 114:5 phased 73:1878:10,15,16 phony-bologna 129:9 picture 57:21 piece 50:19 place 81:21 106:14 places 14:5 plaintiffs' 37:3 84:2 99:9 plan 27:3 planner 26:9,18 27:3,7,11 68:13 planning 27:17,24 61:9 103:11 plant 13:21,22 14:2,9 16:24 113:13 plants 13:25 14:12 89:5 plastic 93:24 95:7 123:25 124:2 pleural 45:7 64:13 PMK 91:11 point 17:14 19:1,7 20:12 23:2 24:8,10 26:2 33:10, 25 34:25 52:14 58:16 60:13,16,24 88:15 89:3 110:25 111:2 points 45:18,21 policies 24:14 25:9,18,21 policy 25:8,11 115:5,11, 14,18,21 116:1,4,22 117:3,9 popped 36:13 position 85:6 positive 43:1 possibility 67:19 Possibly 67:18 potential 49:19 62:10 63:13,21 70:21,24 potentially 49:11,12 powder 30:7,9,11,15,16 32:4,8 powders 119:25 120:1 PPL 103:5,10,15,16 114:10,19,22,23 PPL's 108:15 precut 31:3 32:14 preference 124:13 prepackaged 31:23 prescribed 93:18 presence 88:10 121:25 Index: percent..process present 9:8 43:22 presentation 43:20 presently 34:10 president 12:16 17:12,14, 16,17,25 20:17,23 21:22 23:2 27:14 33:19,21 35:2 41:22,25 43:2,5 46:13,16 47:2,9,21 51:25 55:16 58:25 59:2,8 73:11 83:9 114:14 presidents 59:2 pretty 128:22 previous 15:22 previously 43:4 74:11 110:20 127:22 price 35:20,23 53:10,18 54:16 60:22 105:7 108:18 prices 61:12,15 pricing 54:4,12 primarily 48:25 primary 21:5 prints 80:5 prior 75:7 problem 49:12,17 51:15, 21 65:1,6,9,19,22 problems 65:25 Probst 42:20,22 108:8 procedure 29:10 procedures 24:14 25:18, 22 process 11:929:13 46:15 47:18 53:8 55:7,8 57:15 59:16 78:13 82:19 107:1 110:8 123:13 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 processing 93:15 procurement 121:23 produce 26:20 104:11 produced 26:19 36:6 104:2 113:18 product 13:1 27:4 29:9, 17,19 30:3 44:6 46:5,10, 11,12 48:3,11,20 49:20 50:12 52:18 53:11,13,19 54:5,8 58:16 59:11,13,15 61:1,3,20 62:1963:9,13 66:4,9 67:12,16 73:19 101:25 102:8 103:11,13, 14 106:9,11 107:2 108:19 112:6,9,11,13,14,20 119:20,22,25 120:11 123:14 125:4,16,19 production 14:21 20:4,9 25:1 26:8,12,13,17 27:13, 1533:1457:1761:9,15 78:12,20 101:24 127:6 130:3 products 11:6,7,10,20 18:7,11,14,15,23 23:9 27:18,19 28:17,24,25 29:2,9,18 35:11,21 45:1 49:5,18 56:24 57:1 58:1,6, 1359:1061:13,17 73:25 74:8,12 75:23 76:1,2,5,10, 13,15,1977:11,17,22 80:11 83:4,13 93:9 95:15 96:12 97:13 101:7 105:7 110:17,23 115:2,6,9 117:8 119:13,14,17 120:10,14, 22 125:14 128:4 129:16, 18 program 52:11,13 project 102:14,16,18 projects 118:6 promoted 27:23 28:6 proper 86:2,3,4 87:6 94:21 129:7 properly 49:20 properties 123:4 proposed 87:24 protect 68:19,22 69:2,7 71:17 72:14 89:22 proverbial 21:7 47:3 provide 26:24 provided 69:24 75:23 76:5,9,24 101:10 providing 75:19 proving 94:19 publication 84:14 published 38:12,16 39:7 40:2,13 41:5,14 44:21 49:15 57:24 87:20 88:1,6, 18,20 91:22 96:14 pull 36:5 43:9 pulling 49:1 pulmonary 45:6 purchase 28:16 97:11 purchased 127:9 purchasing 28:14,24 52:15,17,22 54:11,22,23 55:1 57:17 59:13,19,23 97:17 104:18 116:14 118:21 119:2 128:6 purposes 123:8 pursuant 117:9 put 11:20 29:8 30:7,8 31:18,23 32:7,15 36:5,12 37:8 38:7 46:11 50:22 Index: p ro c e s s in g ..ra p id ly 64:8 73:19 74:19 78:11,20 92:23 95:15 96:11,13,20 124:2 puts 59:12 putting 19:22 48:13 73:4, 12 84:23 Q QA 42:2,5 83:5 quality 13:15 14:22 17:3, 10,11 25:3 42:6,7 48:2,18 59:7,14 79:11,14 83:10 85:10 107:25 quantities 79:3 question 16:11,12,19 19:15 34:17 39:19 40:25 48:14 59:17 65:24 74:15 76:4,7,9 82:25 87:5 90:3, 25 91:1 95:3 96:6 98:8,11 104:13 106:21,23 117:7 129:3,4,5 questioning 48:7 81:11 87:6 91:16 questions 91:7 99:22 121:9,12 130:11 quick 14:24 quote 128:2 R R&d 54:21 116:13 ran 78:10 Ransdell 42:24 43:5 46:14 47:9,11,15 Ransdell's 42:25 rapidly 121:21 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 raw 93:8 read 14:23,25 15:20,22,23 37:14 44:17 45:10,21,22 49:15 50:10 64:2 75:2 79:15 81:1 82:21 83:6 86:14 88:3 92:6,17,21 93:20 95:13 98:9,10 103:8 113:16 130:16,20 real 14:23 reamers 14:3 rear-ended 67:9 reason 11:1 70:15,19 97:8 106:7 109:12 114:10 120:21 124:11 recall 15:12 16:22 19:5 27:25 51:24 74:12,13 76:6 78:5 112:9,11,13,20 115:20 receive 121:24 124:6 received 123:22,25 recess 38:24 90:8 100:12 recognition 49:2 recollection 15:24 74:18 75:22 83:8 recommend 51:17 recommendation 47:10 51:19 recommended 58:6 record 9:16,17,18 10:2 14:25 38:21,23 39:1,3 48:13 60:6 79:8 90:7,10 98:10 99:19 100:4,11,14 130:23 records 59:23 97:11,12,20 109:9,10 110:14,15,16 111:2,14,20,22 112:22 114:25 115:1,5,8 118:16, 20 127:16,20,23 128:7 redirect 85:18,21 reference 37:17 referred 16:7,20 49:1 referring 68:21 69:6 reflect 75:22 reflected 10:1 refractories 13:22 14:9 refresh 74:18 83:8 Register 79:16 80:2,3,4,6, 9 82:19 83:2,10,13 84:9 85:1 87:21 88:1,6,16,19 91:23 96:11,15 105:13 regular 94:12 regulated 92:14 regulations 79:12,15 85:11 87:14 88:17 90:24 regulatory 17:3,11 42:2, 11,1448:1,17 59:6 108:1 relate 91:16 related 18:11 45:592:1 101:24 110:17 115:5 117:1,7 118:17 relating 115:8 release 50:9 released 51:993:19 releases 64:18 relevant 81:5 relied 25:12 rely 25:17 remember 43:3 47:5 112:19,21 116:24,25 117:21 119:9 126:12 Index: raw ..research remotely 9:5 removed 49:9 removing 11:10,15 Repeat 117:4 replace 53:23 56:1 101:24 102:7 107:22 replaced 63:16 replacement 51:22 53:3,6, 7,17 54:7,16 55:14 77:25 78:3 102:9 106:10,12,14 replacing 107:2 report 20:1627:11,14 reported 20:19 27:12 reporter 9:5,25 10:3 83:23 95:18,22 96:3 99:12 130:15 Reporters 9:24 reporting 22:22 Reports 38:19 represented 99:3 101:5 representing 108:7 reps 75:25 requesting 102:9 requests 80:5 require 113:14 required 93:11 116:1 requirement 85:2 requirements 26:23 80:10 82:14 83:3 requiring 82:9 research 13:16 14:22 15:2,4 19:3 25:3 42:23 52:23 53:2 54:11 56:7,11, Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 14,19,20,23 57:3 59:13 64:22 70:1,13 104:21,24 105:1 reserve 91:15 129:12 130:17,20 resource 16:23 resources 15:5,7,24 16:5, 18 25:4 respect 80:10 83:3 respond 98:17 response 98:24 113:14 responsibility 11:6 16:24 28:15,24 52:12 57:12 80:8 83:1 89:22 responsible 69:13 rest 23:4 78:8 retention 115:11,14,18,21 116:4,21 117:2,9 retired 11:2 33:23 review 80:8 83:1 reviewed 24:4 Reyen 9:13 11:12 12:5 16:6,1920:20 21:1,13 22:2,19 23:18 25:13,20 26:4 34:2,9,12 36:16,21 37:13 39:9,16,20,22 40:4, 15.20.24 43:18 44:8 45:8, 16.20 48:6 53:20 56:2 57:10 59:4,17 61:4 63:1, 11.20 64:6 65:2,24 66:2 68:8 70:17 72:3,16 74:15 75:2 78:24 79:17,20,23 81:1 85:5,15,19 86:1,6 87:4 88:9 90:3,21 91:6,10 92:2 94:1,9,13,19,25 98:8, 11.14.19.24 102:19,21 105:24 106:16,18 107:7 111:9 120:16 121:11,12, 16 122:10,24 123:2,10,19 124:14,18 129:2,5,12 130:11,24 Richard 65:15 90:14 right-hand 36:22 49:23 93:2 rings 44:15,20 50:4 58:14 RISCHMAN 125:2,6 128:17 role 61:13 121:23 roles 79:11 roll 31:7 rolls 32:24 49:6 50:6,8,15 58:18 84:21 103:5,7 124:9 room 63:8 64:17 Rose 128:24 roundabout 24:20 28:1 33:6 117:22 rubber 93:24 95:6 rulemaking 87:24 running 45:12 91:18 Russ 17:17,24 20:19 21:4, 7 S safe 92:5 safety 15:8,24 16:1,5,7,8, 17,20,24 86:11,13 87:23 sale 18:7,11 101:7 103:6 110:17 115:1,6,8 117:8 sales 14:21 18:16,19,22 20:9 22:24 25:2 26:23,25 27:4 75:25 97:11 108:21 Index: reserve..sell 109:6,9,11,12 110:13,15, 16,21 114:14,25 126:19 127:15,19,23 128:2,7 130:6 sales/shipment 111:3 salespeople 76:10,12,17 128:9 sample 56:6 sampling 55:7 San 74:22 sat 22:12 schedules 27:21 Schein 74:3 125:17,18 School 120:15,22 schools 119:13120:10, 11,13 scientific 56:15 scientifically 92:16 scope 66:10 88:10 scrap 93:8 screen 36:5,14 scroll 75:14 82:3 90:18 99:20,25 102:3,5 search 97:5,11,16,19 100:24 101:11 104:3,24 107:9 112:22,23 113:10 118:22 128:1 searched 99:4 111:2 128:5 section 87:21 93:19 sections 50:8 Seeking 34:2 sell 12:20 18:15 44:10,22 53:13 55:5 73:25 74:8 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 76:13,15 106:9 109:1 110:2,5,11 120:21 121:3,6 128:10 selling 35:10,12,16 44:25 46:9,10 47:14,16 48:3,20 58:1,20,22,23 67:15 70:15,20 79:6 84:17 96:18 111:24 121:17,20,25 126:18 129:16,18 sells 125:16 send 26:25 98:22 sends 54:22 sense 31:19 sentence 44:4,13,17 45:24 49:24 58:11 separate 21:21 32:15 sequence 88:13 serving 120:3 servings 30:25 set 19:2 52:3 61:15 setting 53:10,18 share 121:21 129:19 sheets 54:16 shelf 112:6 shelves 77:25 78:3 79:5 ship 84:24 125:4 shipment 110:21 128:2 shipped 120:18 122:6 125:13,18 show 28:5 34:9 40:6 43:10 77:4,10,12,14,17 83:20,24 99:2,23 102:14 113:1 showing 63:25 shows 77:21 sic 9:23 39:1 103:21 sick 67:20 71:12 side 37:8 57:18 65:12 sign 114:11,13 significant 45:24 signing 114:15 130:22 silence 40:22 similar 123:13 sir 48:15 74:24 122:11 124:18 sitting 36:9 situation 99:16 sixth 85:13 86:8 size 32:11 78:21 skills 40:7 slips 67:4 small 79:3 smaller 36:21 smart 66:5 snappy 66:7 snuck 19:17 sold 13:1 17:20,23 18:13 20:18 30:18,20 31:2 32:3, 23,24 33:1 44:6,19 46:5 50:12,1558:1367:12,25 78:18,23 108:25 109:13, 19 111:11,19,22 112:3 124:9 127:12,16 solution 53:23 54:3,4 sort 52:18 122:12 sound 15:15 28:9 42:2 43:6,14 72:5 99:11 sounds 33:9 95:19,23 Index: s e llin g ..stam p Southern 120:15,22 speak 11:1 12:12 13:14 28:18 33:2 40:19 41:16,24 44:1 47:17 55:19,23 57:6, 16 59:18 61:6,8,22 63:4 64:23 72:8,17 73:14 77:2 78:25 79:21 88:12 101:9 109:15,23 110:12 111:5 119:6 speaking 11:18 19:1 32:20 34:15 speaks 40:4 44:8 45:8,13 spec 89:5 Specialties 98:20 specific 41:16 76:1 92:5 115:19 119:22 123:8 specifically 120:11 specifications 97:12 specificity 98:12 speculate 66:2 speculation 39:10 43:18 56:3 61:5 63:2 65:2 72:4 79:18 88:10 94:2 102:21 105:24 106:20 107:7 120:17 122:2,23 123:6,16 124:15 125:2 128:18 Speculative 123:1 Spencer 9:24 38:20 spread 106:3 Springer 9:21 127:9 Springer's 48:10 staff 19:2,8 stake 92:20 stamp 52:3 Asbestos Reporters/ a GPS Partner 888-779-9974 L aw ren ce G irling January 29, 2021 standard 86:14,19 87:19, 25 88:7 Standards 86:13 start 30:2 34:25 73:4,12 79:6 85:24 104:13 started 12:1,413:10,12, 19,24 14:13,17 15:8 16:15 17:17 18:10 20:2,3 26:8, 14 70:4 starts 90:19 state 63:2 stay 79:12 stayed 79:15 staying 55:13 step 17:19 stick 16:9 sticker 37:9 83:25 stipulate 81:4,5 91:18 stipulated 9:4,7,12,13 stipulations 9:15 stock 33:25 34:19 stop 23:7 46:10 47:14,16 58:22,23 70:15 71:23 121:17,20 stopped 21:8 66:4 70:20 72:10 111:24 stops 47:4,24 storage 93:15 store 67:5 story 129:1,9 Street 13:21,22 14:2,10 stretching 24:16 strike 9:9 13:10 71:22 92:23 122:9,21,22 123:5,9 strip 32:14 122:12 123:12, 22 124:12,13 strips 31:3,23 32:7,15,24 33:1 84:22 120:5 structure 46:25 students 119:23 120:6 stuff 26:3 47:15 56:20 59:25 83:14 109:19 110:11 118:17,20,24 126:18 style 22:24 subject 87:13 88:24 89:19 subpoena 98:17,20 99:1 substitute 52:4,6 101:16 sudden 126:17 sue 71:12 sued 66:19,24 67:20 70:16 97:1,9 suggest 34:14 127:8 suggesting 51:13 54:2,3 suggestion 59:11 suitable 53:3 summary 108:10,11 Superman 94:12 supervisor 27:23 supplied 68:3 123:18 supplier 32:17 69:24 123:18 suppliers 72:22 73:25 74:3 123:20 supplies 12:21 supply 126:25 Index: sta n d a rd ..ta p e supplying 103:5 supposed 50:21 85:10 surprised 44:2 suspend 85:23 Suzanne 128:18,19 swear 9:5 10:3 swirly 95:24 switch 99:15 switchover 108:5 Sybron 97:24 98:4,12,14, 20,23 Sybron's 98:2 symbols 99:15 system 103:14 T tabs 55:17,18 takeaway 49:17,21 taking 56:4 84:23 talented 40:9 talk 11:21 12:25 21:19 65:25 75:19 90:12 106:5 talked 19:11,13 22:7 26:15 31:7 32:3 35:7 58:11 90:14 101:15 talking 25:23 47:4 50:12 55:20 73:9 83:13 104:18, 22 105:2,5,16 108:18 114:22 130:1 talks 45:1 tape 13:2 28:16 29:18,20, 21 30:1,3,6,11,12 31:7,10, 15 32:11,21,23,24,25 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 35:11,22 50:15,19,21,23, 24 51:3,6,14 53:3,6,16 62:8,22 63:22 64:18,24 67:21,25 72:21 73:1,5,13, 22 77:1,24 78:2,8,10,11, 13,15,16,18,19,20,22 79:5,6 84:17,22,23 89:15, 23 93:23,25 94:4 95:4,5, 16 96:12,18 101:25 102:7 107:19,22 111:11,19,22 112:3,20 119:18 120:10 127:10,12,15,16 TAURAS 95:17,21,25 96:4 104:6 130:14,16,20 team 19:14,21,24,25 20:6, 24 21:4,10,24 22:18 108:21 tear 50:19,20,24 120:6 tearing 51:5 technical 56:6 technician 50:18 technicians 62:13 67:24 71:8,1872:1,1484:17 96:23 telling 56:25 57:23 125:13 128:8 tells 115:22 temporary 87:19 ten 32:15 ten-pound 30:21 tendency 50:7 terms 59:20 test 52:24 64:18 testified 10:8 15:10 43:4,7 74:11 110:20 127:9,22 testify 81:3 testifying 81:14 127:11 testimony 15:22 17:15 48:10 53:1 58:25 59:6 61:18 63:20 70:17 72:5 75:7,11 80:24 82:23 98:1 106:25 113:1,6 testing 55:7 57:1 106:11 tests 104:22 105:2 Therapeutics 37:20 38:3 there'll 40:21 thing 28:12 31:23 39:14 40:6 49:10 54:25 57:20 58:12 60:17,21 63:12 71:8 81:2,3 99:15 102:3,24 103:4 119:12 things 15:22,23 23:21 26:5,20 57:5 66:20 88:5, 18,20 94:20 105:13 thinking 63:5 71:14 thought 39:15 40:20 72:6 three-and-a-half-pound 30:20 throw 78:9,22 thrown 79:1 116:1 till 40:5,18 59:5 time 9:19 11:19 12:17 19:1,7,821:1,1324:8,10 27:12 38:22 39:1 41:9,22 42:23 43:3,5 44:6 46:14 47:9 53:2 55:9,24 71:14 78:12 85:6 90:10 91:17 94:25 98:5,15 100:5,10,14 114:4 115:13 116:1,5 117:12 118:7 130:4,25 timeline 41:16 times 122:4 Index: T A U R A S ..tru e timetable 41:12 title 41:24 86:11 87:16 titles 27:10 today 10:18 11:1 15:25 36:7 72:7 85:16 90:23 91:5 told 46:24 47:1 108:21 111:18 117:12 123:17,18 126:10 127:24 128:25 top 37:22 80:19 82:5,6 torn 51:8 tornadoes 68:24 69:1 total 99:17 101:13 totally 68:18 track 22:7 59:24 109:6,11, 12,19 110:9 trade 77:4,10,14,15,17,20 train 74:7 75:25 trained 56:15 74:11 training 75:20,23 76:5,9, 24 transportation 93:16 Trey 36:17 81:2 trial 9:12 troubles 126:18 true 12:2 13:2 15:8,13,18, 19 17:13 18:1221:8 26:9 27:24 28:3,17 29:18 33:1, 8,9 34:1 35:11 38:13 40:17 41:20,21 44:7,10 46:6,7,14 47:16 50:13,16, 17 52:11 53:3,12,15 54:5, 6 56:1 58:23,24 61:16 64:14 68:1,18 69:8,9 70:16 71:18 72:2 73:1,6,7, Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 9.10.13.16.17.19.20.23.24 vendors 68:3 73:7 74:1 75:9 77:1 79:12,13 81:12,1383:18,1984:18 96:18,20,21,24,25 101:8, verbal 25:22 versus 9:22 25 105:3,4,7,14,18,19 vice 17:12,14 27:14 33:19, 107:19,23 108:2,6 109:9 21 35:2 41:22,25 58:25 110:14,23 111:4,20 112:1, 59:2 83:9 114:14 2.24 113:21,24 114:2 119:5,15,18 120:15 121:3 video 9:15,16,20 57:19 125:12 127:13,14,17,20, 65:13 23 128:4,10 130:4,5,6,7,8, view 92:10,12 9 volume 9:21 124:8 twelve 100:10 U ultimately 46:13 47:11,23 W wait 40:5,18,24 59:5 85:17 109:24 unattractive 122:7 waive 81:4 uncompetitive 122:5 walk 56:6 understand 16:15 64:17 98:19 106:21 understanding 97:18 98:1 123:3,11 128:16 wanted 11:1 39:23 58:21 60:5,9 70:13,20 73:12 76:12,15 109:21 110:5,10 warehouse 125:19,20 understood 66:8 125:8 warehouses 125:9 undisputed 92:12 warn 85:2 universities 31:2 70:7 119:13,14,21 warning 46:11 50:23 73:19 95:15 96:11,20 university 119:23 120:14, 22 warnings 73:5,12 82:9 96:13 upper 93:3 waste 93:8 USC 121:2 wasting 91:17 94:25 watch 99:14 V water 95:20 vague 12:5 16:7,20 68:21, 24 69:5 vein 63:13 wax 123:12 ways 24:13 25:22 79:14 West 121:25 122:5 125:25 Index: tw e lve..w ro n g 126:18 127:2,6 128:10,11, 14 129:16,19,20 wet 49:10 wheels 59:12 When's 115:13 117:11 Whip 124:23,24 125:4,22 126:23 128:12,13 Whoops 36:24 Williams-steiger 87:22 Witkowski 74:21 113:2,3 Witnowski 113:1 word 25:6,8,12,17 106:4, 15 107:3 114:20 128:9 work 13:4,25 27:7 47:1,18 52:5 54:25 60:15,19 62:22 68:25 121:22 worked 13:13 14:5 19:8 24:6,17,25 27:8 36:13 56:8 68:16 69:8,9,12 87:12 97:16 109:17 118:6, 20 workers 32:20 working 11:2 12:1,4 14:13 54:22 56:1 69:14 71:7 72:2 81:20 89:15 118:17 works 69:2 129:10 worldwide 14:14 worried 62:12,22 71:11, 21,25 72:12 Wow 121:10 write 57:4 72:25 written 9:15 10:2 25:23 26:5 59:16 60:10,25 wrong 101:22 128:21 Asbestos Reporters/ a GPS Partner 888-779-9974 Lawrence Girling January 29, 2021 wrote 23:23 24:1,2,8,10 26:3 61:18,21 105:20,22 X XVII 86:11 Y yea 52:2 year 23:7 27:2 41:15 77:4, 5 108:21,25 109:7,21 110:2 years 15:18 19:6 27:8 33:15,18 43:8 51:24 107:12 109:25 127:18 Z zero-zero-zero-zero-zerofive-zero 103:1 Zoom 9:23 Index: w ro te..Z o o m Asbestos Reporters/ a GPS Partner 888-779-9974