Document QM2BzwvXEBnOy62Qqzyqb8rov

1 But based on what I know, it should apply to 2 virtually everyone. That is to say, any reasonable 3 number of brake changes in a career. 4 Q Are you familiar with Mr. Mallia's testimony 5 regarding the number and frequency of brake repair 6 work -7 A Yes. 8 Q -- that he performed during his lifetime? jPage 62 I | J .1 i l 1 1 j 9 A Yes, I'm familiar with that. 10 Q Do you question the veracity of that 1 11 testimony? 12 A Well, it's inconsistent so I have to question 13 the veracity of it. 14 Q Okay. 15 A At some point he and his brother say thousands 16 and it can't be thousands when you work out the math. 17 And then later he says, you know, it's so many times 18 per week or per day. You know, ultimately I' try to 19 infer that, what I could from the testimony, and it 20 looked like if he did what he said he did, I would say 21 he would fit in with the kind of people that were 22 described in my 2003 paper. 23 Q The data that goes into the 2003' paper upon 24 which the average exposure that you calculate, were the 25 individuals that were performing the work that form the ESQUIRE DEPOSITION SERVICES (415) 288-4280