Document NGOvYMk8pEo5YmoZxv1NGjV9w

Page 1171 ; 1 Q But you have no knowledge that there were 2 any pipes there? 3 A What they do, they run a pipe up the wall 4 and then every so far they make an access for it so 5 you can get into it or an entrance that you can get 6 into the pipe. 7 Q But that work had been done before you 8 arrived there? 9 A In the particular area where I was working, 10 yes, the bell towers. 11 Q Do you recall testifying at your deposition 12 that the pipes -- you saw pipes in the boiler room at 13 this site? 14 A I was down in that boiler room, yes. 15 Q But you also testified that you never saw 16 Mr. Vandergucht work in that boiler room, right? 17 A I didn't see him working there, no. 18 Q Okay. 19 A But he could have been in there. 20 Q But you didn't see him? 21 A No, I didn't see him.