Document MMRLzKeE1BJ3N6V67726zg77x

1 A Pretty good size school out there. Page 861 2 Q And was this new construction that was going 3 on? 4 A Yes, it was, just being built. 5 Q And were there pipecoverers present? 6 A They had pipecoverers, carpenters, 7 electricians, plumbers, pipefitters. Had everything 8 out there on that job. 9 Q Was the jobsite similar as what you 10 described for Loch Raven Apartments, Hamilton and 11 Northern, was it a similar-type situation? 12 A Yes. 13 Q Did you have occasion and Mr. Vandergucht 14 have occasion to be in the area when pipecoverers 15 would be sawing or cutting the pipecovering? 16 A You couldn't help but be in there because if 17 they were working in one room, you would go through 18 that room to go to another room to work or you might 19 have to go to work on some ceilings and they would be 20 working all around in the area. They had right good 21 size areas out there to work in.