Document LJYEBkKd6L3D3RDmrQ6KBokZ7

Page 78 1 A Now these questions are all between 1978 and 2 1985 . 3 Q That's correct, and I'd like you to assume so 4 that we can continue, that all the brake pads that 5 we're talking about have asbestos in them. For 6 example, would loosening the lug nuts of the wheel and 7 taking the wheel off have a potential for exposure to 8 airborne asbestos? 9 MR. LANKFORD: Incomplete hypothetical. 10 THE WITNESS: I'm not sure about that. I'm not 11 sure you'd be able to measure anything. 12 BY MR. RUCKDESCHEL: 13 Q Have you seen documents or studies that have 14 discussed that as a potential avenue for exposure? 15 A I'm not sure that I remember anybody 16 specifically talking about that task. You could infer 17 or assume there was some potential exposure but it's 18 not something that we focused on. 19 Q Okay. 20 A "We" meaning the scientific community. 21 Q I understand. And then if we move forward, 22 the drum is removed and cleaned out; is that correct? 23 A If it's a drum brake, yes, sir. 24 Q And I want to confine our discussion here to 25 drum brakes today. And the drum is then cleaned? ESQUIRE DEPOSITION SERVICES (415) 288-4280