Document LJVEOw3gZ2VVR3OZxa1YDMpjw

1 people that have opinions that I believe aren't well Page 312 2 founded. 3 Q And that would be people on my side of the 4 table? 5 A That's yet to be seen. We haven't been to 6 court yet. 7 Q All right. Now talking about small businesses j 8 versus large corporations would you agree that a small 9 business the size Imbergia Paving would be unlikely to 10 have industrial hygienists on staff? | 11 A I think that's true. 12 Q And they would be largely dependent on 13 information provided to them by their material 14 suppliers for information regarding potential hazards 15 of those materials? 16 A Either the material supplier in one form or 17 another, in this case you'd either have the brake box 18 or you'd have the service manual. 19 Q Okay. With regard to your 2003 paper -- 20 A And by the way, at this time frame he should 21 have had exposure to both. He should have had warnings 22 both the through brakes and service manuals. ! 23 Q If you bought the vehicles used would you have 24 to ask the manufacturer for the service manual if the 25 person you bought it from did not have it? ESQUIRE DEPOSITION SERVICES (415) 288-4280