Document RJ650MNow1kbRVEax7pMnjpZn

Page 3057 1 MR. McGOWAN: Line 21, Ms. Sheridan. 2 READING OF DEPOSITION OF ROBERT SILWICK 3 TAKEN ON APRIL 1, 1996 4 (Whereupon, the questions were read by Mr. 5 McGowan, and the answers were read by Ms. Sheridan.) 6 (CONTINUED) 7 BY MR. McGOWAN: 8 Q And what were you doing on this particular 9 jobsite, sir? 10 A Spraying some beams and portions of a deck, 11 metal decking. 12 Q Now, was this job like the others that you 13 have already described, that you would spray some and 14 then lath some and then spray some? 15 A Yes, sir. 16 Q And is this when you were working with Mr. 17 Vandergucht? 18 A Yes, sir. 19 Q Did you do tampering yourself also with Mr. 20 Vandergucht? Did you tamp yourself, or did you just 21 spray? Page 3058 1 A No. I did the spray, and Jean did the 2 tamping 3 Q Now, do you recall seeing Mr. Vandergucht 4 plaster on this job, also? 5 A Yes. 6 Q Other than tamping? 7 A Yes. 8 Q Did you see him use the white coat and the 9 brown coat? 10 A Yes. 11 Q Do you recall who the manufacturer of the 12 white coat was? 13 A USG. 14 Q And the manufacturer of the brown coat? 15 A USG. 16 Q Do you recall the manufacturer of the spray 17 you were using? 18 A Cafco. 19 Q Of the trades that you have listed for us 20 in the prior sites, of those trades that were there at 21 the Normandy Village Mall, are there any other trades 1 other than the sprayers and the plasterers that you Page 3059 2 believe used asbestos-containing products? 3 A The pipecoverers or insulators, whatever you 4 want to call them. 5 Q Do you know who employed these 6 pipecoverers? 7 A McCormick. 8 Q And do you recall, did these pipecoverers 9 employed by McCormick use the same type of materials 10 that you described for us earlier? 11 A Yes, sir. 12 Q Are there any other materials that you 13 didn't describe for us that you believe they may have 14 used? 15 A I don't remember - 16 Q Did they use anything other than the 17 pipecovering and the wet mud? 18 A I don't recall any. 19 Q Do you recall either the make,trade name, 20 or manufacturers of the products that were used? 21 A Armstrong. 1 Q Now, is that for the pipecovering and Page 3060 2 cement? 3 A Yes. 4 MR. MCGOWAN: Page 77, line 7. 5 BY MR. McGOWAN: 6 Q Did you use more than 15 or 20 bags of Cafco 7 at this jobsite? 8 A For the whole job? 9 Q Yes, sir. 10 A Yes. 11 Q Sir, do you know whether the white coat 12 that you used at this jobsite contained asbestos? 13 A What? 14 Q Do you know whether the white coat you used 15 on this jobsite contained asbestos? 16 A Did I know at that particular time that it 17 contained asbestos? 18 Q That is my first question, yes. 19 A No. 20 Q Do you know now if the white coat you used 21 in that jobsite contained asbestos? Page 3061 1 A I have been informed that that particular 2 product had asbestos in it. 3 Q Who informed you of that? 4 A The employer. 5 Q Someone from Hampshire? 6 A Yes. 7 Q When they informed you that the white coat 8 contained asbestos, did they tell you that the white 9 coat that you were using on this jobsite contained 10 asbestos or just in general that the white coat 11 contained asbestos? 12 A The material itself, no matter what jobsite 13 you used it on. 14 Q Is that what the person told you? 15 A That is what I was informed. 16 Q Do you know how the Armstrong products got 17 up to this jobsite? 18 A You are serious, ain't you? 19 Q I am very serious, sir. 20 A By truck. 21 Q Whose truck? 1 A Armstrong1s truck. Page 3062 2 Q So McCormick employees were using Armstrong 3 products that came in an Armstrong truck, is that what 4 you are telling us? 5 A No. 6 Q What, part of the statement is wrong? 7 You told us that the McCormick -- McCormick 8 was the insulation contractor, correct? 9 A No, I didn't say that. 10 Well, I stand corrected because they 11 weren1t on the job. It was Armstrong. 12 Q Armstrong was the insulation contractor? 13 A Yes. 14 MR. McGOWAN: Your Honor, I believe that is 15 it. 16 THE COURT: Okay. 17 MR. McGOWAN: Thank you. 18 THE COURT: You are welcome. 19 Thank you, Ms. Sheridan. 20 Mr. Williams. f 21 MR. WILLIAMS: Yes, Your Honor, Ford now ------------------------------------------------------------------------------------------------------------------------------------------------j