Document LKOQzGBZpMmX2xMK0g05E4nxX
FILE NAME: Asbestos Cement Pipe and Sheet (ACPS) DATE: 2014 Oct 8 DOC#: ACPS132 DOCUMENT DESCRIPTION: Legal - Deposition Summary of Lewis Armstrong
Summary of Lewis Armstrong Deposition of October 8, 2014
PAGE
76 years old good health
11
Worked for JM Manufacturing from 1983 to 1987
13
Worked in the shipping department
13
AC pipe is light grey in color
14
Worked from Johns Manville in the same plant before 1983
14
May 1960 is when Armstrong started with JMand worked continuously for 14-
JM at the Denison plant until JMM took over in 1983
15
Composition of water and sewer pipe is identical except that the sewer pipe 16
is not pressure tested
Armstrong saw both Canadian fiber and Calavaras fiber and blue African 18
fiber
Same asbestos fiber was used by JM and by JMM
19
Armstrong began in the shipping department at Denison in about 1980 and 22-
continued in the shipping department until he left in 1987
23
Remembers change of management in 1983. But for the work he did,
23
nothing changed after 1983. "Everything remained the same."
There was no labeling on a new piece of pipe that was made and was ready 24
to ship
Never saw any kind of stencil or writing on the pipe re: asbestos cautions 25
Armstrong is shown what purports to be a Johns Manville caution label. Armstrong says he never saw any such label on Johns Manville pipe or on
2526
JMM pipe. Never saw the caution label until shown in the deposition.
Armstrong saw hundreds of 1000s of pieces of pipe at JM Manufacturing 26
When JM Manufacturing took over management of the Denison plant there 27
was no change in the way the asbestos cement was manufactured.
There was pipe made by Johns Manville that was in inventory when JMM
took over on Jan 1,1983; Armstrong can't say that the inventory was ever
all depleted.
JBOONREGSWVASR. NER MORSE TEC
LEWIS ARMSTRONG, VOL. 1
Page 2
1
SUPERIOR COURT OF THE STATE OF CALIFORNIA 1
APPEARANCES
2
COUNTY OF LOS ANGELES
2 FOR THE PLAINTIFFS:
3
COURT OF UNLIMITED JURISDICTION 3
Mr. Christian H. Hartley
MAUNE RAICHLE HARTLEY FRENCH & MUDD, LLC
4
5
ROBERT W. JONES, SR-, and )
SHARON E. JONES,
)
6
Plaintiffs, )
7
4
300 West Coleman Boulevard, Suite 200
Mount Pleasant, South Carolina 29464
5
Phone: 843-388-1330
Fax: 803-753-9931
6
E-mail: chartley@mrhfmlaw.com
7 FOR THE DEFENDANT, J-M MANUFACTURING:
vs.
) Case No. BC541164
8
8
BORGWARNER MORSE TEC, INC., j
9
et al..
9
Mr. Anthony S. Miller MANION GAYNOR & MANNING 201 Spear Street, 18th Floor San Francisco, California 94105
10
Defendants.
10
Phone: 415-512-4381
Fax: 415-512-6791
11
11
E-mail: Amiller@mgmlaw.com
12
12 FOR THE DEFENDANT, CALAVERAS ASBESTOS LIMITED and
MUELLER COMPANY:
13
13
Mr. John Loomis (Via Telephone)
14
VOLUME I
14
FOLEY & MANSFIELD
300 South Grand Avenue, Suite 2800
15
DEPOSITION OF LEWIS ARMSTRONG 15
Los Angeles, California 90071
Phone: 213-283-2100
16
Wednesday, October 8, 2014
16
E-mail: jloomis@foleymansfield.com
17
Denison, Texas
17 FOR THE DEFENDANT, CERTAINTEED CORPORATION:
18
18
Mr. Joe Greenslade (Via Telephone)
POLSINELLI LLP
19
19
2049 Century Park East, Suite 2300
20
Los Angeles. California 90067
20
Phone: 310-556-1801
21
21 FOR THE DEFENDANT, WESTERN AUTO SUPPLY CO.:
22
REPORTED BY:
23
KEATON HOUGEN
CSR NO. 8754
24
JOB NO.
25
77876MAU
22
Mr. Howard Ruddell (Via Telephone)
POND NORTH, LLP
23
350 South Grand Avenue, Suite 3300
Los Angeles, California 90071
24
Phone: 213-617-6170
ALSO PRESENT:
25
Mr. Chase Huddleston, Videographer
Page 1
1
SUPERIOR COURT OF THE STATE OF CALIFORNIA 1
2
COUNTY OF LOS ANGELES
2
INDEX
3
COURT OF UNLIMITED JURISDICTION
3 Appearances ..............................
4
ROBERT W. JONES, SR., and )
SHARON E. JONES,
)
5
Plaintiffs,
)
6
VS.
7
BORGWARNER MORSE TEC,
j
8
INC., et al.,
)
4 LEWIS ARMSTRONG
5
Examination by Mr. H a r t l e y ...........
6
| NO.BC541164
7
Examination by Mr. Miller............. Examination by Mr. Loomis.............
8
Examination by Mr. Miller.............
9
Defendants.
)
9
Examination by Mr. H a r t l e y ...........
10
10
Examination by Mr. Miller.............
11
11 Reporter's Certificate ...................
12 ****************************************************** 12
EXHIBITS
13
ORAL AND VIDEOTAPED DEPOSITION OF 13 NO. DESCRIPTION
14
LEWIS ARMSTRONG
14 1 Notice of D e p o s i t i o n ..................
15
October 8, 2014
15 2 Caution Statement......................
16 ****************************************************** 16 3 Photos of P i p e ........................
17
17 4 Declaration.............................
18
ORAL AND VIDEOTAPED DEPOSITION OF LEWIS ARMSTRONG, 18
19 produced as a witness at the instance of the Plaintiffs, 19 20 and duly sworn, was taken in the above-styled and 20
2 1 -numbered cause on the 8th day of October, 2014, from 21 22 9:05 a.m. to 2:55 p.m., live and via telephone, before 22 23 Keaton Hougen, CSR in and for the State of Texas, 23 24 reported by machine shorthand, at the Hampton Inn & 24 25 Suites, 3415 Ansley Boulevard, Denison, Texas 75020. 25
Page 3
2
7 40 135 158 162 167 171
PAGE 25 25 3 6
120
. >>
LUDWIG KLEIN REPORTERS & VIDEO, INC. - 800.540.0681
(1) Pages 1-3