Document RK3DGzOo55yM7OzGkLQQ3BnV

FILE NAME Kerr KR DATE 2021 Jan 29 DOC KR103 DOCUMENT DESCRIPTION Legal - Deposition of Lawrence J. Girling Lawrence Girling January 29 2021 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO - --000--- DAVID SPRINGER SPRINGER and DOROTHY Plaintiffs vs. ASBESTOS COMPANIES et al Defendants CERTIFIED ORIGINAL ee ee ) ee Case No. ) ) ee ee Ne Nee Nee 20-276849 VIDEOTAPED VIRTUAL DEPOSITION OF LAWRENCE J. GIRLING Friday January 29 2021 9:31 a.m. REPORTED BY GISELLE GIRARD CSR 12901 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 VIRTUAL APPEARANCES 2 For Plaintiffs 3 Page 2 2 3 GOLD LAW FIRM 4 4 BY H.W. TREY JONES ESQ 555 Montgomery Street 55 5 Suite 605 San Francisco California 94111 10 6 415-986-1338 415-373-4579 Fax 789 7820 trey@treyjoneslaw.com 789 789 Corporation Witness For and the Witness 7820 Defendant Kerr Corporation 10 BY KEITH REYEN ESQ 11 Street Suite Montgomery 11 12 San Francisco California 94104 12 415-392-8300 13 415-421-1254 keith@orplaw.com Fax 13 keith@orplaw.com 14 14 15 SWANSON , MARTIN & BELL , LLP 15 BY RICHARD P. TAURAS ESQ 16 330 North Wabash 16 Chicago Illinois 60611 17 312-321-9100 17 312-321-0990 Fax 18 rtauras@smbtrials.com 18 19 19 For Defendant 84 Lumber Company 20 20 HAWKINS PARNELL & YOUNG LLP 21 23 BY SOLOMON PANTUCH ESQ 1 Post Street 22 22 Suite 2400 San Francisco California 94104 23 23 415-766-3218 415-766-3250 Fax 24 24 spantuch@hpylaw.com 25 25 Page 3 123 VIRTUAL APPEARANCES Continued 123 2 For Defendant BASF Catalysts LLC 123 3 LITTLETON PARK JOYCE UGHETTA & KELLY LLP 3 BY JASON SCHMITZ ESQ 4 141 West Front Street 4 Suite 120 5 Red Bank New Jersey 07701 5 732-530-9100 6 732-530-9115 Fax 60 littletonpark.com 7 7 8 For Defendant DAP Inc. n La Mirada Products Co. Inc. erroneously sued as DAP Inc. and Champion Home 8 9 Builders 9 10 TUCKER ELLIS LLP BY NICOLE E. GAGE ESQ 10 11 201 Mission Street Suite 2310 12 San Francisco California 94105 1234 415-617-2409 1234 13 Fax 1234 nicole.nicoleg.gage@tauckerellgis.com e@tuckerellis.nicole.gage@tuckerelis.com com 14 15 15 For Defendant Darby Dental Supply SMITHAMUNDSEN 16 : AEROSPACE . 16 , Michigan Suite Michigan 17 Avenue 17 Suite 18 Chicago Illinois 60601 18 312-894-3200 19 19 312-894-3200 Fax mmcgrory@salawus.com 20 222 Schein 222 For Defendant Henry Schein Inc 21 22 HARRIS BEACH PLLC BY SYED K. RIZVI ESQ 22 23 100 Wall Street New York New York 10005 23 24 212-687-0659 212-687-0659 Fax 24 25 zrizvi@harrisbeach.com 25 VIRTUAL APPEARANCES Continued For Defendant Hill Brothers Chemical MORGAN LEWIS & BOCKIUS LLP BY MARISA R. CHAVES ESQ One Market Street Company Spear Street Tower San Francisco California 415-442-1141 94105 415-442-1001 Fax marisa.chaves@morganlewis.com 2..5 Page 4 For Defendant New Coleman Holdings HAWKINS PARNELL & YOUNG LLP BY JEFFREY T. THAYER ESQ 1 Post Street Inc Suite 2400 San Francisco 415-766-3204 California 94104 415-766-3250 Fax jthayer@hpylaw.com For Defendant Patterson Dental and WALSWORTH FRANKLIN BEVINS & BY: HILLARY H. HUTH ESQ True Value Company MCCALL LLP 601 Montgomery Ninth Floor San Francisco 415-781-7072 Street California California California 94111 415-391-6258 Fax hhuth@wfbm.com For Defendant Ransom & Randolph Company GOODELL DEVRIES LEECH & DANN LLP BY One THOMAS J.S. South Street WAXTER III ESQ 20th Floor Baltimore Maryland 410-783-4000 21202 410-783-4040 Fax tjw@gdldlaw.com VIRTUAL APPEARANCES Continued For Defendant The Scotts Company LLC HAWKINS PARNELL & YOUNG LLP BY ANA T. REEG ESQ 1 Post Street Suite 2400 San Francisco 415-766-3221 California 94104 510-508-1816 Fax areeg@hpylaw.com HUNTON ANDREWS KURTH LLP BY EMILY MORDECAI ESQ Riverfront Plaza East Tower 951 East Byrd Street Richmond Virginia 23219 804-788-8200 804-788-8218 Fax emordecai@huntonak.com Page 5 For Defendant SS White SCHIFF HARDIN LLP BY JILL BERRY ESQ of the Americas Suite Avenue New York New York 10036 212-745-9557 212-753-5044 Fax jbery@schifhardin.com jbery@schifhardin.com jbery@schifhardin.com jbery@schifardin.com jbery@schifardin.com jberry@schiffhardin.com For Defendant University of Southern California POLSINELLI LLP BY JOSEPH L. GREENSLADE 2049 Century Suite 2900 Park East ESQ Los Angeles 310-556-1801 California 90067 310-556-1802 Fax jgreenslade@polsinelli.com Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 VIRTUAL APPEARANCES Continued 2 For Defendant Whip Mix Corporation 3 SELMAN BREITMAN LLP BY SUZANNE E. RISCHMAN ESQ 4 33 New Montgomery Street Sixth Floor 5 San Francisco California 94105 415-979-2004 6 415-979-2099 Fax srischman@selmanlaw.com 7 8 Also Present 9 SPENCER BENVENISTE VIDEOGRAPHER 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 6 1 2 3 4 5 6 7 00 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 6..9 EXHIBITS Page 8 LAWRENCE J. GIRLING David Springer et al vs. Asbestos Companies et al Friday January 29 2021 PLAINTIFFS DESCRIPTION EXH 1 in JADA Hazards of Asbestos in DeD nteisnttryistDentristry y Dentistry ( 2 pgpgs s PAGE 37 EXH 2 Federal Register 6/7/72 Volume 37 84 No. 110 Part 1 10 pgs EXH 3 Kerr Document Production 52 pgs 99 o0o Page 7 Page 9 1 EXAMINATION INDEX 1 Friday January 29 2021 January 29 2021 3 WITNESS EXAMINATION BY 2 3 PAGE 4 MR JONES The parties have stipulated that the 4 5 LAWRENCE J. GIRLING 6 MR JONES MR REYEN 10 124 121 5 court reporter can swear in the witness remotely as she 6 is not at the same location as the witness The parties 7 have also stipulated that an objection by any defense 8 counsel is good for all present that includes motions 8 9 9 to strike 10 10 Counsel need not opt out of an objection or a 11 11 motion should they choose to do so they can make that 12 12 election at trial So stipulated 13 stipulated 13 MR REYEN So stipulated 14 WITNESS INSTRUCTED NOT TO ANSWER 14 MR JONES The parties also agree that the 15 15 stipulations can be on the written and not the video PAGE LINE 16 record All right Let's go on the record the video 16 17 record 128 21 going 18 THE VIDEOGRAPHER We are going on the record 17 18 19 The time is 9:32 a.m. and the date is January 29 2021 19 20 This is the video deposition of Lawrence Girling 20 21 Volume I in the matter of David Springer et al 21 22 versus Asbestos Companies et al 23 This deposition is being held via Zoom sic and 23 2222 24 my name is Spencer Benveniste from Asbestos Reporters of 25 25 California a GPS Partner The court reporter is Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 10 1 Giselle Girard Counsel's appearance will be reflected 1 2 in the written record 2 3 Will the court reporter please swear in the 3 4 witness 4 5 5 6 LAWRENCE J. GIRLING 6 7 having been first duly affirmed was examined and 7 8 testified as follows 8 9 9 10 MR JONES He said yes right 10 11 THE WITNESS Yes 11 12 MR JONES Just making sure 12 13 13 14 EXAMINATION 14 15 BY MR JONES 15 16 Q. Mr. Girling thank you for being with us this 16 17 morning though it may be this afternoon where you are 17 18 Where are you today 18 19 A. I'm in Brighton Michigan 19 20 Q. What is your full name 20 21 A. Lawrence Jay Girling 21 22222 Q. And where in Michigan do you live 22 22222 A. I live in Brighton 23 22222 Q. Okay So you're near your home 24 22222 A. Yes 25 10..13 Page 12 Q. Okay You started working at Kerr Corporation in 1967 is that true A. Correct Q. What was Kerr when you started working there MR REYEN Objection vague THE WITNESS I -- I don't know What do you mean what was Kerr BY MR JONES Q. Was it called Kerr Corporation then A. Kerr Dental Q. A. Q. Kerr It was called Kerr Dental Was it a corporation I can't speak to that for sure Okay When you were hired you were hired by Bob A. Q. time I was interviewed by Bob Kerr Bob Kerr was the president of Kerr Dental at the A. Yes Q. What did Kerr Dental do meaning what did they make what did they sell -- what was their business A. They made dental supplies Q. Like A. Impression materials filling materials endodontic materials investment materials Q. And we'll talk about it a little more But the Page 11 1 Q. The reason I wanted to speak to you today is that 1 2 you are retired from working at Kerr Corporation is 2 3 that correct 3 4 A. Correct 4 5 Q. And when you were at Kerr Corporation you had 5 6 some responsibility for ordering asbestos products that 6 7 went into Kerr products correct 7 8 A. Correct 8 9 Q. And you also had some involvement in the process 9 10 of removing asbestos from Kerr products is that 10 11 correct 11 12 MR REYEN Objection misstates facts not in 12 13 evidence misleading 13 14 You can answer Larry 14 15 THE WITNESS What do you mean by removing 15 16 asbestos 16 BY MR JONES 17 18 Q. I just mean that generally speaking there was a 18 19 period of time where Kerr decided that they didn't want 19 20 to put asbestos with their products anymore and you 20 22222 were somehow involved in it And we'll talk about that | 21 22222 involvement in a minute Okay 22 22222 A. Okay 23 22222 Q. Is that basically correct what I said 24 22222 A. Yes 25 Page 13 investment materials that's the product that was sold with an asbestos tape true A. Yes Q. Did Kerr as part of its business work with chemicals A. Chemicals yes Q. Tell me a little bit about that A. They manufactured an impression paste made from chemicals Q. that Did Kerr when you started in nineteen -- strike When you started in 1967 did Kerr have a laboratory where they worked with chemicals A. They had I believe -- I can't speak for sure But they had quality control departments yes Q. They also had a research and development department A. Yes Q. You started in Detroit have in Detroit What facilities did Kerr A. Well they had a plant on 12th Street in Detroit And they had a refractories plant on Milwaukee Street in Detroit Q. When you started which -- which one of those plants did you work at Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 A. Both Page 14 1 2 Q. What did they do at the plant on 12th Street 2 3 A. They made endodontic files and reamers 3 4 impression materials filling materials cavity liners 4 5 Q. So that's one of the places where they worked 5 6 with different chemicals to make the impression 6 7 materials 7 8 A. Yes 8 9 Q. What did they do at the refractories plant on 9 10 Milwaukee Street 10 11 A. They made gypsums and investments 11 12 Q. Did Kerr have any other offices or plants 12 13 factories anything like that when you started working 13 14 for them in 1967 And by that I mean worldwide 14 15 A. No -- well not that I'm aware of at '67 no 15 16 Q. What different divisions did they have at Kerr 16 17 when you started in 1967 17 18 A. I don't know what you mean by divisions 18 19 Departments or divisions 19 20 Q. Departments 20 21 A. Production department finance sales and 21 2222 marketing quality control and research 22 2222 MR JONES Giselle can you read that back real | 23 2222 quick please 24 2222 Record read 25 14..17 Page 16 A. Safety I know in the 80s and perhaps the 70s -- but I'm not too sure what they handled when I joined the company Q. Got it So later on when you got more involved you knew that human resources handled safety MR REYEN Objection to the extent that it is vague as to what is referred to by safety I would expect that HR safety meant employee safety issues MR JONES Just stick to legal objections please Do you have the question in mind Mr. Girling THE WITNESS Do I have a question BY MR JONES Q. The same objection will apply The way I understand your answer was that when you started in 1967 you weren't really sure who was in charge of safety but later on you learned it was the human resources department Is that fair MR REYEN I will object that the question is vague and ambiguous as to what is referred to by safety MR JONES Go ahead THE WITNESS The HR department as I recall in the 80s 90s dealt with HR resource issues as well as responsibility for health and safety in the plant /// 1 BY MR JONES Page 15 1 BY MR JONES Page 17 2 Q. When you say research is that the research and 2 Q. Kerr had a -- someone that was in charge of 3 development 3 regulatory issues Was that the quality control people 4 A. Yes that was called research 4 A. That's where it was 5 Q. Did they have human resources 5 Q. So later on in the 70s there was a gentleman 6 A. Yes they did 6 named Ken Kovac I believe 7 Q. Human resources was the department in charge of 7 A. Yes 8 safety at Kerr when you started in 1967 is that true 8 Q. What was his job 9 A. I don't know that for a fact 9 A. I believe he was -- I can't define his job but 10 Q. So you've -- you first testified on behalf of 10 he was head of the quality control department called 11 Kerr Corporation in 1996 I believe 11 quality and regulatory 12 A. I -- I can't -- I can't recall the dates That's | 12 Q. And he was a vice president I believe is that 13 probably true 13 true 14 Q. It was a case in Louisiana in the mid 90s Does | 14 15 that sound about right 15 A. At some point he became a vice president yes Q. Now I've seen some testimony where you said that 16 A. Yes 16 Bob Kerr was president of Kerr and he interviewed you 17 Q. And then you've given several other depositions 17 but that when you started Russ Nelson was the president 18 on behalf of Kerr Corporation over the years true 18 of Kerr in 1967. Was there more than one entity or did 19 A. True 19 Bob Kerr step aside -- or help me with this please 20 Q. And I've read several of those depositions so | 20 21 lot of this is going to be kind of going through some of | 21 22 the things that I've read in your previous testimony 22 A. Bob Kerr sold the business Q. When did he do that A. '68 I believe it was 23 And one of the things I've read was that human 23 Q. Okay So not long after Mr. Kerr sold the 22 resources handled safety Is that not your recollection | 24 business a gentleman named Russ Nelson became the 25 today 25 president of Kerr Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 A. Correct Page 18 1 2 Q. Mr. Nelson's background was in finance It 2 3 wasn't in dentistry is that right 3 4 A. Correct 4 5 Q. So Kerr -- 100 percent of -- well maybe not 5 6 100 percent Almost all of Kerr's business in the 60s 6 7 and 70s was the sale of products for the use of the 7 8 dental -- I don't want to call it industry I'm going 8 9 to try it again 9 10 When you started in 1967 almost all of Kerr's 10 11 business was related to the sale of dental products 11 12 true 12 13 A. I can't say for sure because we also sold jewelry | 13 14 = investment products 14 15 Q. Did you sell enough jewelry investment products 15 16 that it was more than 50 percent of the sales of the 16 17 company 17 18 A. No. 18 19 Q. Was it more than 20 percent of the sales of the 19 20 company 20 21 A. I can't guess I have no idea 21 22222 Q. But most of the sales had to do with dental 22 22222 products right 23 24 A. Right 24 25 Q. Okay Did Kerr employ any dentists 25 A. When 18..21 Page 20 Q. When you started A. I can't tell you when I started who was on there was just a production control clerk Q. All right When you first became familiar with who was on the management team who was on it A. The head of -- the head of each of the functional departments Q. Had a production had a finance sales and marketing -- all those A. Yes Q. Okay And at some point in your career you became the head of one of those departments right A. Yes Q. Who did the heads of those different departments report to A. The president Q. So when Mr. Kerr sold the company the heads of the departments reported to Russ Nelson MR REYEN Objection lacks foundation BY MR JONES Q. Is that right A. Yeah While he was president correct Q. Is the management team the group that made decisions for Kerr Corporation Page 19 1 A. I'm speaking from memory At one point in time 1 MR REYEN Page 21 Objection overbroad as to time 2 we had a dentist on the staff who had a dental chair set | 2 lacks foundation 3 up in the research department 3 THE WITNESS I don't -- I don't think decisions 4 Q. Around when was that 4 were made by the management team I think Russ Nelson 5 A. I can't recall That's my -- that's too long 5 made the primary decisions 6 ago That's 40 50 years ago 6 BY MR JONES 7 Q. Fair enough So at some point in time Kerr had 7 Q. Got it Russ Nelson is where the proverbial buck 8 dentist on staff but not all the time you worked 8 stopped true 9 there is that fair 9 A. Yep 10 A. That's fair 10 Q. Did the management team have meetings 11 Q. Okay We talked about some of the different -- 11 A. Yes 12 I'm going to need somebody to mute 12 Q. How often 13 All right We talked about some of the different | 13 14 departments Did Eaton also have a management team 14 MR REYEN Overbroad as to time THE WITNESS I can't -- when I attended it was 15 A. I didn't catch the question Did who 15 once a month 16 Q. Did -- oh my brain is on another case right now | 16 17 and something snuck out 17 MR JONES Okay THE WITNESS That was in the 80s late 80s 18 When you were at Kerr did Kerr have a management | 18 BY MR JONES 19 department 19 Q. Well we're going to talk about a 22 A. I yeah yes Yes they did 20 particular -- well actually let me -- was there a 22 Q. Like a management team I guess is a better way 21 management meeting separate from the group of the 22 of putting it 22 department heads and the president 23 A. Yes 23 A. No. 22 Q. Who -- who was the management team Who was on 25 that team 24 Q. Okay When the management team got together to 25 make decisions for the corporation how did they Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 22 1 communicate those decisions to the other departments 1 2 MR REYEN Objection overbroad 2 3 THE WITNESS Yeah I have no idea what -- that's 3 4 huge 4 5 BY MR JONES 5 6 Q. Well when you guys had those management 6 7 meetings did someone keep track of what you talked 7 8 about 8 9 A. I don't know 9 10 Q. Did you guys have minutes of meetings so you'd 10 11 know what decisions you made 11 12 A. I can't say for sure there was and no one sat in | 12 13 the meeting and took minutes 13 14 Q. Okay Did -- did people take notes 14 15 A. I took notes 15 16 Q. Okay And then if there was some decision it 16 17 would have to be communicated outside of that management | 17 18 team right 18 19 MR REYEN Objection lacks foundation 19 222222 misstates facts not in evidence overbroad 20 21 THE WITNESS I think that you're -- the 21 222222 management committee meetings were mainly reporting 22 222222 meetings what's going on in your departments what's 23 24 going on in the sales area -- that's the style of 24 222222 meetings the monthly meetings were 25 22..25 Q. And you wrote memos Page 24 A. I'm not saying I took -- wrote memos about the meetings I don't think so I took notes and went back and reviewed them by departments heads Q. I'm not asking about the meetings but while you worked at Kerr from 1967 -- until 2003 right A. Yes Q. At some point during that time you wrote a memo A. Yes Q. And at some point during that time people wrote memos to you A. Correct Q. And one of the ways that Kerr Corporation communicated its policies and procedures to its employees was through memos A. I think you're stretching it but Q. How many people worked at Kerr when you were there in the 60s and 70s A. I can't tell you I'd be guessing Q. Roundabout A. I still can't tell you I'd be -- there was less than 100 people when I joined in '67 Q. Okay A. A little less than a hundred Q. So you're saying that everything that worked in 1 BY MR JONES Page 23 Page 25 1 this corporation -- that had a production department and 2 Q. Okay But at some point the president of Kerr 2 had a finance department a sales and marketing 3 or the department heads made decisions that would affect 3 department a quality control department a research and 4 the rest of the corporation -- like you know no 4 development department and a human resources 5 more -- 5 department -- that in order to communicate with all 6 A. Yes 6 those departments Kerr just used word of mouth 7 Q. -- overtime this year or stop parking in the back | 7 8 parking lot or we're going to change the color on the 8 A. No I didn't say that Q. That would be a bad policy to use word of mouth 9 box of the Kerr products -- or something like that 9 to communicate all your policies wouldn't it 10 right 10 A. I didn't say that 11 A. They made decisions correct 11 Q. Well I'm saying it would be a bad policy if you 12 Q. And they had to communicate those decisions to 12 relied on word of mouth wouldn't it 13 the people that were going to carry them out right 13 MR REYEN Objection calling for lay opinion 14 A. The managers that were at the meeting did that 14 BY MR JONES 15 Q. And they would communicate those decisions 15 Q. Right 16 through memos 16 A. Right on what 17 A. Not necessarily -- 17 Q. Why would it be a bad idea to rely on word of 18 MR REYEN Objection 18 mouth to communicate the policies and procedures of Kerr 19 BY MR JONES 19 to the employees 222222 Q. Not necessarily but that was one way that they 20 MR REYEN Objection calls for lay opinion 222222 would communicate things correct 21 THE WITNESS I don't know Policies and 222222 A. Possible 22 procedures can be communicated many ways in verbal 222222 Q. Well you know for sure that you personally wrote | 23 written -- whatever you're talking about I don't know 222222 memos right 24 where you're going with it 222222 A. I took notes 25 /// Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 BY MR JONES Page 26 1 2 Q. Okay My point is that at Kerr Corporation 2 3 people wrote stuff down right 3 4 MR REYEN Objection overbroad 4 5 THE WITNESS Some things were written down 5 6 correct 6 7 BY MR JONES 7 8 Q. Okay In 1967 you started as a production 8 9 planner in the chemical division true 9 10 A. Yes 10 11 Q. Is that another department chemical or is that 11 12 part of production 12 13 A. It's part of production 13 14 Q. So at Kerr Corporation when you started we had 14 15 the departments we'd talked about and then we had 15 16 divisions within those departments 16 17 A. Divisions within production yes 17 18 Q. And your job as the planner was to determine what | 18 19 had to be produced and what materials were needed to 19 20 produce those things 20 21 A. Correct 21 22222 Q. How would you do that 22 22222 A. Based on analyzing sales requirements forecasts 23 22222 that marketing would provide 24 22222 Q. So how would -- so marketing would send you sales | 25 1 forecasts Page 27 1 2 A. Every year 2 3 Q. And as a planner you would have to plan how to 3 4 make enough product to meet the sales that marketing 4 5 forecast 5 6 A. Correct 6 7 Q. And then who did you work with as a planner 7 8 A. Oh I was there 35 years I worked with a lot of 8 9 people 9 10 Q. I mean what job titles I would say Like as 10 11 the planner who did you report to 11 12 A. I reported to at that time manager of 12 13 production control in '67 13 14 Q. And did he report to the vice president of 14 15 production 15 16 A. I think he did 16 17 Q. So when you were planning out what -- what 17 18 products needed to be made and what materials Kerr 18 19 needed to make those products how did you communicate 19 20 that information to other people in the company 20 21 A. We made out schedules that got delivered to the 21 22222 department managers 22 23 Q. In 1969 you were promoted to supervisor in 23 22222 planning for the chemical division is that true 24 22222 A. I can't recall the dates 25 26..29 Q. that Page 28 Roundabout late early 70s something like A. Probably true Q. All right A. My deposition would show it probably Q. And then in 1973 you were promoted to the materials manager A. Okay Q. Does that sound about right A. Yes somewhere in that area Q. Fair enough When you were a materials manager that's the first thing you ever had anything to do with asbestos is that right A. Yes that was the purchasing end of it Q. So in 1973 it became your responsibility to purchase the asbestos tape that was used with Kerr's investment products true A. I can't speak to the exact date I took that on Q. Fair enough Around -- we'll say around 1973 Is that okay A. It's close probably I'm not sure the dates Q. Fair enough Whenever you became the materials manager at Kerr that's when you first had responsibility for purchasing the asbestos products that were used with Kerr's products right A. Correct Page 29 Q. How was asbestos used with Kerr's products A. I don't know What -- what do you mean use was it used How Q. A. what Yeah Why did -By a dentist you mean -- or by a dentist or Q. Sure Why -- why did Kerr have to put an asbestos product with its products A. It was part of the casting procedure Q. How so A. I'm a chemist but it was used in the investment casting process to line the flasks Q. And the crucible A. Could be crucibles I wasn't that familiar with the crucibles Q. So the asbestos product that Kerr used with its investment products was an asbestos tape true A. The asbestos product that Kerr used with the investment was an asbestos tape yes Q. Okay And Kerr bought that asbestos tape from other companies right A. Yes Q. Those companies were Nicolet and Celotex A. Yes Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 30 1 Q. When the asbestos tape came to Kerr -- well 1 2 let's start here If a customer of Kerr's bought a 2 3 product that included asbestos tape that asbestos tape 3 4 would be in either a bag or a box right 4 5 A. Correct 5 6 Q. And the bag or the box of asbestos tape would be 6 7 put into a box with the investment powder 7 8 A. No the box was never put into the container with | 8 9 investment powder 9 10 Q. Okay If I -- if someone bought investment 10 11 powder that came with asbestos tape how would the 11 12 asbestos tape come with it 12 13 A. In bags 13 14 Q. Okay So if someone bought Kerr investment 14 15 powder in the late early 1970s they would get a 15 16 box with packets of investment powder right 16 17 A. Are you -- are you asking what containers that we | 17 18 sold investment in 18 19 Q. Yeah 19 20 A. We sold it in pound cans 20 21 pound cans pound boxes pound pails and 21 22222 hundred drums 22 22222 Q. Did it ever come in a box where there were little | 23 22222 packets of individually -- individual -- I want to call | 24 22222 them servings but individual packets of investment | 25 1 material Page 31 1 2 A. Yes we had a kit that we sold to universities 2 3 Q. So if you got that kit you got precut strips of 3 4 asbestos right 4 5 A. Correct 5 6 Q. If you got one of the boxes or the other packages 6 7 you talked about you got a roll of asbestos tape in 7 8 bag 8 9 A. Correct 9 10 Q. You could also buy asbestos tape on its own from | 10 11 Kerr 11 12 A. Yes 12 13 Q. And that would be in a box 13 14 A. Correct 14 15 Q. When the asbestos tape got to Kerr's factory it 15 16 was either in a bag or a box 16 17 A. Correct 17 18 Q. It was already packaged to be put in the Kerr 18 19 package if that makes sense 19 20 A. Yes 20 21 Q. Meaning if someone had the Kerr kit with the 21 2222 packets of investment all they'd need to do would be to | 22 2222 grab a prepackaged thing of asbestos strips and put it 23 2222 in the Kerr box right 24 2222 A. I didn't follow that one 25 30..33 Q. Sure - Page 32 A. -- say that again Q. When Kerr sold the kit you talked about with the individual packets of investment powder A. Yes Q. The Kerr employee would just take a package of the asbestos strips and put it in the Kerr box with the powder right A. Correct yes Q. Meaning there was nobody at Kerr that had to cut the asbestos tape to the right size right A. Correct Q. There was nobody at Kerr that had to take -- if it was an asbestos strip that was precut nobody had to gather up the ten or 12 strips to put it in a separate package They were already packaged when you got it from the supplier right A. Correct correct Q. So at Kerr in the manufacturing facility generally speaking the workers didn't handle the asbestos tape it was in a package A. Correct Q. Okay So Kerr had asbestos tape that it sold in rolls it had asbestos tape strips that were sold with those kits you described and it had asbestos tape strips sold as crucible liners true Page 33 A. I can't speak to the crucible liners because I believe those were gone when we -- when I joined the company Q. Okay roundabout In 1977 you became the operations manager A. Okay Q. Is that true A. Sounds true My deposition would tell me Q. Yeah At some point in the late 70s you became the operations manager correct A. Yes Q. And what was your job as the operations manager A. Not only materials but also production Q. Couple three years later around 1980 you became the director of manufacturing A. Yes Q. And then a few years after that you became the vice president of manufacturing A. Yes Q. And you were the vice president of manufacturing for Kerr Corporation from the mid 1980s until you retired in 2003 A. Correct Q. At one point you owned stock in Kerr Corporation Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 Is that still true Page 34 1 2 MR REYEN Objection Seeking financial 2 3 information from the witness 3 4 I don't know that you have to answer that 4 5 Mr. Girling 5 6 THE WITNESS Yeah 6 7 MR JONES He's already answered it before and 7 8 it goes to bias 8 9 MR REYEN It -- it doesn't show bias if he 9 10 doesn't presently own it and -- 10 11 MR JONES I agree 11 12 MR REYEN -- it's not your business 12 13 MR JONES Let's find out You can instruct him | 13 14 not to answer You can't suggest he shouldn't answer 14 15 That's -- that's a speaking objection and we'll have to 15 16 take it up later If you want to instruct him you can 16 17 instruct him I'll ask the question again and then you | 17 18 can make your decision what to do 18 19 Q. Mr. Girling do you own stock in Kerr 19 20 Corporation 20 21 A. No I do not 21 2222 Q. Do you still have a pension from Kerr 22 2222 Corporation 23 2222 A. Yes 24 2222 Q. Now at one point in your career did you start 25 34..37 asbestos in dentistry Page 36 A. I saw an article on asbestos Hazards of Asbestos in Dentistry Q. All right Give me one second and I'm going to pull that document up and put it on the screen Kerr produced in this case I think 52 pages of documents Do you have those documents with you today A. I do not Q. Okay Do you know if the lawyer sitting next to you has them A. He does not Q. That's all right I can put it up Okay If this worked right then something popped up on your screen and it should be the 1976 hazards in dentistry article MR REYEN I'm not seeing an exhibit myself right now Trey THE WITNESS I don't see it either Now I see it MR JONES Boom MR REYEN Okay Larry it's smaller than it appears I don't know -- up in the right corner you can make it larger if need be THE WITNESS Right Whoops It went away I lost it It went away 1 attending these monthly management meetings Page 35 1 MR JONES Okay Page 37 I'm going to mark this as 2 A. When I became vice president We actually -- I 2 Girling No. 1 3 think -- well my memory escapes me but it may have 3 Plaintiffs Exhibit 1 was marked for 4 been before that too as a director 4 identification and attached hereto 5 Q. Well I know that you were at one particular 5 MR JONES It went away 6 meeting of Kerr executives and that's one in 1976 where 6 THE WITNESS There it is 7 they talked about the American Dental Association 7 BY MR JONES 8 article right 8 Q. All right On the bottom hand side I put a 9 A. Yes 9 little sticker that says Exhibit Girling No. 1. Do you 10 Q. Now by 1976 Kerr had been selling investment 10 see that 11 products with investment tape for decades true 11 A. Let me make it bigger here Yes I see that 12 A. I know they were selling it when I joined the 12 Q. Excellent What is Exhibit 1 13 company 13 MR REYEN Larry make sure you can see it fully 14 Q. In 1967 14 and read it before answering 15 A. Yes 15 THE WITNESS Yeah I can't see it It's just a 16 Q. And you know that they were selling it before you | 16 bunch of lines 17 got there right 17 MR JONES And it's -- for your reference it's 18 A. I don't -- I don't know for sure but -- I believe | 18 Kerr -51 and Kerr -52 that's the Bates numbers 19 they were but I -- 19 THE WITNESS It's from the Council of 20 Q. I think you've seen price lists that go back to 20 Dental Therapeutics is that 21 the 50s and maybe before for investment products with 21 BY MR JONES 22 asbestos tape right 22 Q. Council of dental -- at the top it says Hazards 23 A. I didn't see any price lists in the 50s 23 of Asbestos in Dentistry -- 22 Q. Okay In 1976 you're familiar with the article 24 A. Yes 25 in the American Dental Association journal about 25 Q. -- do you see that Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 A. I got that Page 38 1 2 Q. All right And then under it it says Council on | 2 3 Dental Therapeutics Council on Dental Materials and 3 4 Devices Do you see that 4 5 A. I got that yep 5 6 Q. What is Exhibit 1 6 7 A. It looks like a letter they put out 7 8 Q. How are you familiar with Exhibit 1 8 9 A. I saw this letter in a meeting we had with 9 10 = Ken Kovac 10 11 Q. Okay And you called it a letter It's really 11 12 an article that was published in the Journal of the 12 13 American Dental Association true 13 14 A. I don't know that -- 14 15 Q. Can you -- 15 16 A. -- where it was published 16 17 Q. Can you look at the bottom right of the first 17 18 page 18 19 A. It says Reports -- 19 222222 MR JONES Hey can -- Spencer let's go off the | 20 21 record 21 222222 THE VIDEOGRAPHER Okay The time is 10:19 a.m. 22 222222 We are off the record 23 24 Recess from 10:19 a.m. to 10:38 a.m. 24 25 THE VIDEOGRAPHER Okay We're back on the 25 38..41 Page 40 Q. Okay And what the bottom of this page indicates is that this was published in the April 1976 Journal of the American Dental Association right MR REYEN The document speaks for itself MR JONES Just wait till I'm done Is this like a moot court thing Are you trying to show off your objection skills I'm just trying to identify the document we're looking at All right I get it you know how to object you're very talented at it Q. All right Mr. Girling A. Yes Q. The bottom of the first page indicates this document was published in the Journal of American Dental Association in April of 1976 -- MR REYEN Same objections BY MR JONES Q. -- true You've got to wait till I'm done Keith Don't speak over me MR REYEN I thought you were done MR JONES Well you'll know because there'll be silence Same objection applies you don't need to make it again MR REYEN Okay Larry just make sure you wait after he finishes a question so that I have a chance to 1 record and the time is 1:38 p.m. sic Page 39 1 object Page 41 2 BY MR JONES 2 THE WITNESS Okay 3 Q. Okay Mr. Girling while we were off the record 3 BY MR JONES 4 did you get a chance to look at Exhibit 1 4 Q. Mr. Girling you can see from the bottom of the 5 A. Yes 5 first page it indicates that this was published in the 6 Q. Okay And when you looked it over did you 6 April 1976 Journal of the American Dental Association 7 confirm that this was something that was published in 7 A. Correct 8 the journal of the American Dental Association 8 Q. When did you first see this document the first 9 MR REYEN Objection lacks foundation calls 9 time ever 10 for speculation 10 A. In a meeting with Kovac in the fall of -- I 11 THE WITNESS That's what it says down on the 11 believe it was the fall somewhere around that 12 bottom 12 timetable 13 BY MR JONES 13 Q. Do you think it's around when this document was 14 Q. I didn't think that was a controversial thing I | 14 published in April or do you think it was later in the 15 thought your interrogatories said that but okay -- 15 year closer to 1977 16 MR REYEN All right He's not here to 16 A. I can't speak to the specific exact timeline 17 authenticate this document 17 Q. Fair enough And the meeting you were in was a 18 MR JONES Well he's here to answer whatever 18 meeting with Kerr executives right 19 question I have but I don't know why you care 19 A. Yes 222222 MR REYEN I don't -- I don't care but he's -- 20 Q. Ken Kovac was there true 222222 MR JONES All right Well let me do it -- 21 A. True 222222 MR REYEN -- I'm just -- I made an objection 22 Q. And Ken Kovac at the time was the vice president 222222 You wanted me to make an objection I made an 23 of what 222222 objection 24 A. I can't speak to his title I don't know if he 222222 MR JONES All right 25 was vice president in '76 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 42 1 Q. What you've said in the past was that Ken Kovac 1 2 was in charge of regulatory and QA Does that sound 2 3 right 3 4 A. Yes 4 5 Q. What is QA 5 6 A. Quality assurance 6 7 Q. Okay That's maybe what we called quality 7 8 control before 8 9 A. Yes 9 10 Q. All right So it was Mr. Kovac's job to monitor 10 11 regulatory developments that affected Kerr Corporation 11 12 right 12 13 A. I don't know that for sure 13 14 Q. Well if he's in charge of regulatory what was 14 15 he in charge of 15 16 A. I -- I don't know his job description -- 16 17 Q. All right 17 18 A. -- I didn't see it 18 19 Q. All right So Mr. Kovac was there Also Bob 19 20 Probst was there 20 21 A. Yes 21 2222 Q. Who is Bob Probst 22 2222 A. He was the director of research at the time 23 24 Q. Bob Ransdell was in the meeting What was Bob 24 25 Ransdell's job 25 42..45 Page 44 A. I can't speak for others I just -- I was surprised to see that the hazards of asbestos in dentistry Q. And actually the first sentence of this article in the Journal of the American Dental Association in 1976 discusses a product sold by Kerr at that time true MR REYEN itself Objection document speaks for THE WITNESS That is not true We did not sell binders for periodontal dressings BY MR JONES Q. The whole sentence is Asbestos is chiefly used in dentistry as a binder in periodontal dressings and as a lining material for casting rings and crucibles A. The second part is correct Q. Did I read the entire sentence correctly A. Yes Q. And Kerr certainly sold asbestos lining material for casting rings and crucibles in 1976 when this document was published A. Correct We did not sell the periodontal dressings Q. Fair enough So this was important to Kerr Corporation because Kerr Corporation was selling one of Page 43 Page 45 1 A. I can't be -- I'm not certain positive He was 1 the products that this article talks about right 2 either head of the marketing or he was president at the 2 A. Correct 3 time I don't remember which 3 Q. And then if you look at the second paragraph it 4 Q. You previously testified in a deposition that 4 says that It has been documented that airborne 5 Mr. Ransdell was the president of Kerr at the time of 5 asbestos is related causally to the development of 6 this meeting Does that sound right 6 pulmonary asbestosis and fibrosis lung cancer and 7 A. That's probably right if I just testified to it 7 pleural and peritoneal mesotheliomas 8 back in -- 20 years ago 8 MR REYEN Document speaks for itself 9 Q. All right Do you want me to pull that up I 9 BY MR JONES 10 can show it to you so you don't have -- 10 Q. Did I read that correctly 11 A. Nope I believe you I believe it 11 A. Correct 12 Q. Okay Okay So -- and then you were there And | 12 MR JONES You can have a running objection to 13 in the late 70s your job was the materials manager or 13 document speaks for itself That's not a legal 14 Operations Manager 1. Does that sound right 14 objection though unless you can cite me the 15 A. Probably correct yes 15 Evidence Code Maybe it's in there 16 Q. Why did Mr. Kovac bring this article to the 16 MR REYEN I don't know - 17 executive meeting in 1976 17 MR JONES In moot court -- you would lose 18 MR REYEN Calls for speculation 18 points in moot court for that objection that's all I'm 19 THE WITNESS I have no idea He -- that was 19 saying 20 part of his presentation at the meeting 20 MR REYEN All right Well you'd probably lose 21 BY MR JONES 21 points for just demonstrating that you can read 22 Q. So why did he present that at the meeting 22 MR JONES I don't know because I read it 23 A. Informative to the group 23 ~ correct 22 Q. And why was this article important to the group 24 Q. Now Mr. Girling that sentence is significant 25 of executives at Kerr Corporation 25 because it indicates that asbestos can cause really bad Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 diseases right Page 46 1 2 A. That's what it says 2 3 Q. So in 1976 Mr. Kovac brought this article to an 3 4 executive meeting of Kerr Corporation informing those 4 5 executives that the article says that a product sold by 5 6 Kerr includes an ingredient that can cause cancer true 6 7 A. True 7 8 Q. If someone at Kerr Corporation was going to make 8 9 decision about whether Kerr should keep selling that 9 10 product the asbestos liner or should stop selling it 10 11 or should put a warning on the product or should change 11 12 the product to nonasbestos that decision would 12 13 ultimately be made by the president of Kerr Corporation 13 14 who was Bob Ransdell at the time true 14 15 A. I don't know the process Kovac might have made 15 16 that the president might have done it -- I'm not sure 16 17 who 17 18 Q. One of the executives in that management meeting 18 19 would have made the decision right 19 222222 A. To exit the business you're saying 20 222222 Q. Correct 21 222222 A. I don't think -- well not based on this letter 22 222222 just on the letter 23 222222 Q. Well what I'm saying is you told us at the 24 222222 beginning -- I kind of asked you how did the structure 25 46..49 Page 48 Q. Okay So Mr. Kovac the head of regulatory and quality assurance brings this article informing the executives of Kerr that they are selling a product that this article says includes a cancer causing ingredient What does Kerr do What do those executives do MR REYEN Okay I'm going to object just to the extent that this line of questioning in its entirety -- I won't make it again -- is not reasonably calculated to the lead to the discovery of admissible evidence based upon Mr. -- Dr. Springer's testimony that he didn't use the product after 1974 But you can go ahead and answer Larry I'm just putting that on the record THE WITNESS I need -- I need the question again sir BY MR JONES Q. Sure So Mr. Kovac the head of regulatory issues and quality assurance brings this article into the executive meeting informing the executives that Kerr is selling a product that this article says includes a cancer causing ingredient right A. Correct Q. What do those executives do What happens in that meeting A. The article was discussed The article primarily Page 47 Page 49 1 work who made the decisions and you told me that the 1 referred to periodontal paste and the ADA pulling their 2 president made the corporate decisions And I even 2 recognition of periodontal paste they would not -- no 3 asked you I said so that means the proverbial buck 3 longer consider eligible to be accepted by the ADA 4 stops at Mr. Nelson That's who we were talking about 4 Okay The ADA made acceptance decisions on a lot of 5 the beginning Do you remember that 5 different products They did not -- they did not drop 6 A. Correct 6 acceptance on the asbestos rolls 7 Q. So if anybody in that executive meeting was going | 7 They cautioned that they should be used under 8 to make a decision for Kerr Corporation it would be the 8 controlled conditions by the laboratory or the dentist 9 president who was Mr. Ransdell at that time right 9 and they should be removed they should be cut -- they 10 A. Or someone make a recommendation to him 10 should be used in a wet manner The key thing that we 11 Q. But ultimately Mr. Ransdell would make the 11 took away from that meeting was that we potentially 12 decision 12 could have -- potentially could have -- a problem with 13 A. He would have to agree on a course of action 13 asbestos 14 Q. Okay If somebody said let's stop selling this 14 Q. So what you're saying is that when Kerr's 15 stuff and Mr. Ransdell disagreed then Kerr would not 15 executives read this article published in the American 16 stop selling it true 16 Dental Association called Hazards of Asbestos in 17 A. I can't speak to that I'm not sure how that 17 Dentistry their takeaway was that the problem was not 18 process would work 18 with Kerr's products 19 Q. Well you know -- 19 A. No. There is a potential for asbestos exposure 20 A. He may -- 20 if the product is not used properly that's what was the 21 Q. You know that the president makes the decision 21 takeaway 2222 You know that right 22 Q. What the article says and if you look on the 2222 A. Ultimately 23 first page the right column the first complete 2222 Q. The buck stops there right 24 sentence beginning with Also Do you see that 2222 A. Yes 25 A. Yes Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 Q. It says Page 50 1 2 Also exposure to airborne fibers may 2 3 occur in dental laboratories where asbestos 3 4 is used to line casting rings or crucibles 4 5 for casting machines and in general is kept 5 6 in the laboratory in large rolls Here the 6 7 danger lies in the tendency for personnel to 7 8 carelessly cut sections off these rolls and 8 9 thus release asbestos into the ambient air 9 10 Did I read that correctly 10 11 A. That's correct 11 12 Q. They are talking about a product sold by Kerr 12 13 true 13 14 A. Correct 14 15 Q. Kerr sold asbestos tape in rolls for use by 15 16 dentists true 16 17 A. True 17 18 Q. For a dentist or a lab technician to use that 18 19 tape they had to tear the tape to a piece -- 19 20 A. No they did not have to tear it They were 20 21 supposed to cut the tape 21 22222 Q. Oh sorry Did -- did Kerr Corporation put a | 22 22222 warning on their asbestos tape boxes saying to cut the 23 24 tape not to tear it 24 22222 A. No. 25 50..53 agree Page 52 A. I don't know that he said yea yea you've got the stamp of approval We set about trying to find a substitute Q. Okay And there was a lot of work involved in finding a substitute for asbestos correct A. Correct Q. Several different departments were involved correct A. Yes Q. Mr. Kovac was in charge of the program true A. I don't know that he maintained responsibility throughout the whole program no Q. At some point Jack Everard the manager of purchasing got involved A. Correct Q. So the purchasing department got involved because they had to find an alternative some sort of product that could be used as a liner that didn't have asbestos right A. Correct Q. Once the manager of purchasing got that material it had to be sent to the research and development people so they could test it right A. Correct 1 Q. Was there any -- Page 51 1 Page 53 Q. And I believe it's been your testimony that it 2 A. In the directions for inlay I think 2 took some time for research and development to find a 3 Cristobalite inlay it said that the tape was cut 3 suitable replacement for the asbestos tape true 4 Q. Okay So are -- are you saying that there's an 4 A. Correct 5 important difference to Kerr between cutting or tearing 5 Q. When the -- part of the decision in finding a 6 the tape 6 replacement for the asbestos tape was how much to charge 7 A. Well that's what they're saying here If it's 7 for the replacement right 8 carelessly cut or torn there's a chance for asbestos to | 8 9 be released in the air if it's done carelessly 9 A. I have no idea about that decision process Q. Well you know that the cost of materials is 10 Q. What they're saying is that that's what people 10 something taken into account when setting the price of a 11 are doing in the labs right 11 product right 12 A. If they do it carelessly correct 12 A. True 13 Q. Okay So are you suggesting that if people would | 13 Q. You can't sell the product for less than the cost 14 have just followed Kerr's instructions and cut the tape | 14 of the materials or you won't make money right 15 then there wouldn't have been a problem 15 A. True 16 A. No. 16 Q. So if the asbestos tape is more or less expensive 17 Q. Okay What did people in that meeting recommend 17 than the replacement that's something that has to be 18 when they got this information 18 taken into account when setting the price of the 19 A. The recommendation from Kovac was that this isn't | 19 product right 222222 going in the right direction it looks like asbestos has | 20 MR REYEN Objection argumentative lacks 222222 got a hazardous problem with it and we need to get a 21 ~~ foundation 222222 replacement 22 THE WITNESS That wasn't the goal to find a 222222 Q. Anything else 23 more economical solution The goal was to replace 222222 A. Not that I can recall That's 50 years ago 24 asbestos 222222 Q. Okay Did the president of Kerr Corporation 25 /// Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 BY MR JONES Page 54 1 2 Q. I'm not suggesting it was the goal to find more | 2 3 economical solution I'm suggesting that whatever the 3 4 solution was had to be taken into account in the pricing | 4 5 of the product true 5 6 A. True 6 7 Q. If the replacement costs two bucks and you're 7 8 charging $ for the product you're not going to make 8 9 money like that right 9 10 A. Correct 10 11 Q. So we've got purchasing involved research and 11 12 development Who would handle pricing issues Is that 12 13 marketing or is that finance 13 14 A. Marketing 14 15 Q. So marketing is involved Whenever they find a 15 16 replacement they got to change all the price sheets and | 16 17 all the catalogs right 17 18 A. Correct 18 19 Q. Is that marketing also 19 20 A. Yes 20 21 Q. Whenever Kerr D finds that one of the materials | 21 22222 purchasing sends them isn't working they have got to 22 22222 communicate that to purchasing right 23 24 A. Correct 24 25 Q. When they find the thing that does work they 25 54..57 that are working to replace asbestos true Page 56 MR REYEN Objection lacks foundation calls for speculation THE WITNESS It was communication by taking -- I can tell you what happened Jack Everard would get a sample in and he would walk it down to technical research and say Here try this one And then they would cast it and see if it worked or not And they'd say to Jack No lousy BY MR JONES Q. Did they -- this is research and development right A. Yeah it's one or two people Q. And the research and development department hired people that were trained in the scientific method right A. I don't know what their criteria was for hiring people Q. Well when you're doing research and development research means looking into stuff right A. Correct Q. Development means developing something based on your research right A. Your products yep Q. Yep And then you're telling me they're doing Page 55 1 have to communicate that to purchasing right 1 testing of these different products right Page 57 2 A. Right 2 A. Actual casting 3 Q. And then that's got to be communicated to the 3 Q. Yeah And you're saying that the research and 4 marketing people right They're the ones that are 4 development department at Kerr Corporation didn't write 5 going to sell it 5 things down 6 A. They weren't in the loop during the development 6 A. I can't speak to that 7 process During the sampling and testing process 7 Q. Well I mean so they never kept notes they 8 marketing wasn't even involved in that process at that 8 didn't have log books or journals or anything like that 9 time 9 A. I have -- 10 Q. They find out at the end 10 MR REYEN Objection 11 A. Exactly 11 THE WITNESS -- no idea That's not -- that was 12 Q. Okay Now the executives the people that were 12 not my responsibility I don't know 13 in that meeting they're staying apprised of the 13 BY MR JONES 14 development of the nonasbestos replacement right 14 Q. None of these different departments sent 15 A. Yes 15 memoranda to each other about how the process was going 16 Q. So the president of Kerr Corporation is keeping 16 A. I can't speak for other departments I know what 17 tabs on it right 17 happened within purchasing and production that's it 18 A. I don't know if he was directly keeping tabs I 18 Q. Okay You're off to the side a little bit on 19 can't speak to that 19 your video I need you to -- 20 Q. Well he was in the meetings where you're talking | 20 A. Okay I just got this thing in front of me I 21 about it right 21 can't see the picture 22 A. He was in the meeting but I don't know what he 22 Q. That's all right That's all right 23 did after that I can't speak to his -- what he did 23 Okay So are you telling me that there was a 22 Q. I agree During this time period there's a lot | 24 meeting where someone brought in an article published in 25 of communication between these different departments 25 the American -- I mean your -- almost all of Kerr's Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 58 1 business in 1976 is selling dental products right 1 58..61 Page 60 A. Just in general anything that we bought 2 A. Correct 2 correct 3 Q. It's got dental in the name right 4 A. Correct 3 Q. Yeah 4 A. Yes 5 Q. So 5 Q. And you had to keep -- if you wanted to buy 6 A. Not all the products that they recommended 6 something new you had to have a record of how much that 7 correct 7 cost right 8 Q. So -- 8 A. Correct 9 A. Periodontal paste was the main focus of the 9 Q. So if you wanted to get some material different 10 article 10 from asbestos you would have to have something written 11 Q. We talked about that In one sentence the first 11 down saying how much it cost in comparison to asbestos 12 thing it says is periodontal paste The second thing it 12 right 13 says is the asbestos products sold by Kerr Corporation 13 A. I don't know at that point whether they even 14 which is asbestos liner for casting rings and crucibles | 14 looked at cost They were looking for materials that 15 right 15 would work 16 A. Correct But my point was that the only product 16 Q. At some point they had to look at cost because 17 that they decertified was the periodontal paste They 17 they had to know how much to charge for the thing 18 did not say anything about asbestos rolls 19 decertification 18 = right 19 A. Only when they found a material that would work 2222 Q. Okay Meaning you could keep selling it if you 20 Q. Fair enough So if they were charging $ with 21 wanted to 21 the asbestos and the nonasbestos thing was more 2222 A. They did not tell us to stop selling it correct | 22 expensive they might have to change that price right 23 Q. And Kerr in 1976 did not stop selling it true 23 A. sure I don't make those decisions Okay 24 A. True 24 Q. I agree But at some point there would be 22 Q. So is it your testimony that a vice president 25 something written down about this is the cost of Page 59 Page 61 1 brings an article into an executive meeting with other 1 asbestos this is the cost of the new product this is 2 vice presidents and the president of the company -- 2 the cost that it's going to be for us to make it this 3 A. They weren't -- 3 is what we should charge for the new product -- right 4 MR REYEN Asked and answered 4 MR REYEN Lacks foundation calls for 5 MR JONES Wait till I'm done 5 speculation compound argumentative 6 Q. Is it your testimony that the head of regulatory 6 THE WITNESS I can't speak to that 7 and quality assurance brings an article to an executive 7 BY MR JONES 8 meeting that includes the president of the company that 8 Q. What do you mean you can't speak to it You were 9 that article says that an ingredient in one of Kerr's 9 in the planning department You were in production -- 10 products has the ability to cause cancer in that 10 A. I don't -- 11 meeting the suggestion is made to change the product 11 Q. -- this was your job 12 the management committee puts the wheels in motion to 12 A. I don't decide when to change prices when to 13 change the product they involve purchasing research 13 mark up products that's not my role 14 and development quality assurance to change the 14 Q. But you do communicate the information about the 15 product and there were no memoranda or notes or other 15 cost of production to the people that do set prices 16 documents written down involved in that process 16 true 17 MR REYEN Objection compound question 17 A. Communicate -- individual products no 18 THE WITNESS I cannot speak to that I know 18 Q. Okay So is it your testimony that nobody wrote 19 what we did in purchasing and that's -- I don't know 19 anything down about this article that says the Kerr 20 what other departments did in terms of notes 20 product has an ingredient that causes cancer Nobody 21 departments whatever 21 wrote that down 22 BY MR JONES 22 A. I can't speak to that Like I said I don't 23 Q. Well in purchasing you for sure had records 23 know 24 You had to keep track of how much you were paying for 24 Q. Okay In 1976 -- 25 stuff right 25 A. Are we done with the article Can I take it down Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 now or Page 62 1 2 Q. No we're not 2 3 A. Okay 3 4 Q. In 1976 -- well yeah you can take it down 4 5 Yeah go ahead and take it down 5 6 A. Okay 6 7 Q. Why did Kerr want to -- why did the Kerr 7 8 executives in 1976 decide to change the tape from 8 9 asbestos to nonasbestos 9 10 A. Because the asbestos had the potential to become 10 11 airborne be hazardous 11 12 Q. They were worried about dentists or dentist lab 12 13 technicians getting hurt 13 14 A. I can't -- I don't know what -- I can't say that 14 15 they were 15 16 Q. I mean -- 16 17 A. Dentists -- 17 18 Q. I mean was the -- in the meeting were they 18 19 concerned that oh no our product might hurt people 19 20 A. I can't say that I don't think that was 20 21 Q. Well when they got this article they weren't 21 22 worried that someone might work with Kerr asbestos tape | 22 222 that's discussed in the article and that they might get | 23 24 the diseases discussed in the article like lung cancer 24 25 or mesothelioma 25 62..65 Q. What was the hazard A. Exactly what we just read Q. Cancer right Right A. Pardon me Page 64 Q. Cancer MR REYEN Calls for expert opinion MR JONES Cancer was a hazard THE WITNESS It was hazardous let's put it that way BY MR JONES Q. Well but you knew This article said it's hazardous because it can cause asbestosis and fibrosis lung cancer and pleural and peritoneal mesotheliomas true A. That's what the article said but I don't -- I didn't -- I didn't say that Q. I understand So did somebody in that room say We should test our tape and find out if it releases asbestos A. I don't know if they did or not quite frankly Q. Did somebody say We need to do some more research and find out how bad this asbestos is A. I don't know I can't speak to that Q. If dentists using Kerr's asbestos tape got hurt from it after this article came out that would be a Page 63 1 MR REYEN Lacks foundation calls for 1 2 speculation calls for the state of mind of other 2 3 persons 3 4 THE WITNESS Again I can't -- I can't speak for 4 5 others I don't know what their thinking was 5 6 BY MR JONES 6 7 Q. Well I'm asking you what they did Did anybody 7 8 in the room say something to the effect of Oh no our 8 9 product might hurt people we better do something about 9 10 it 10 11 MR REYEN Objection calls for hearsay 11 12 THE WITNESS The only thing that was said in 12 13 that vein was that our product did have a potential for 13 14 fibers being exposed and looks -- didn't look very good 14 15 for the future and let's get out of it let's get it 15 16 = replaced 16 BY MR JONES 17 18 Q. What do you mean it didn't look good for the 18 19 = future 19 222222 MR REYEN Objection misstates testimony 20 222222 THE WITNESS There was a potential for the 21 222222 asbestos tape to give off fibers that's what we meant 22 222222 BY MR JONES 23 222222 Q. And what does -- why is that bad 24 25 A. Because it was showing that it could be a hazard | 25 problem for Kerr right Page 65 MR REYEN Objection calls for speculation MR JONES What was the answer THE WITNESS Could be BY MR JONES Q. Why would that be a problem A. Just what you said they got exposed to something Q. And why would that be a problem for Kerr A. I don't know where you're going What do you want Q. You seem to be looking off to the side And I don't have a video on the other attorney so I don't know if you're looking at him or -- A. No I'm I'm not looking at Richard or anybody -- Q. -- anything like that going on this is going -- A. No Q. -- big problem I'm just letting you know You're kind of pausing and looking off - - A. No. Q. -- it's going to be a big problem if that's what's going on MR REYEN Okay Ask a question and you can talk about big problems later Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 MR JONES Now where was ... Page 66 1 2 MR REYEN You were asking him to speculate on 2 3 what could happen if something happened after your 3 4 client stopped using the product 4 5 MR JONES That Keith is just so smart I can't 5 6 come up with a comeback for him I wish I had something | 6 7 snappy 7 8 Q. Kerr understood that it could be liable for 8 9 people that got hurt from this asbestos product right 9 10 A. I don't know That's way beyond my scope 10 11 Q. Well you personally knew about lawsuits back 11 12 then right 12 13 A. No this -- no 13 14 Q. You'd never heard of a lawsuit before 14 15 A. Kerr lawsuits on asbestos no 15 16 Q. I agree there weren't any then But you'd heard | 16 17 of lawsuits right 17 18 A. Lawsuits are common knowledge 18 19 Q. Yeah And Kerr has been sued before not for 19 20 asbestos but for other things -- 20 21 A. Not aware -- 21 22 Q. -- right 22 23 A. -- of it I was not aware of it 23 24 Q. You'd never heard of Kerr being sued about 24 25 anything 25 66..69 true Page 68 A. The asbestos was not our expertise area was supplied by vendors other companies that manufactured the asbestos We were not -- That Q. Okay A. We were not experts in asbestos Q. Well Kerr was experts in chemicals right MR REYEN Objection overbroad MR JONES Right THE WITNESS No I don't -- I wouldn't call us experts in chemicals BY MR JONES Q. Your first job was a planner in the chemical division right A. Correct Q. Employees at Kerr Corporation worked with dangerous chemicals every day right A. I don't -- I don't believe that's totally true Q. Kerr knew how to protect its employees from chemicals right A. It's so vague I don't know what you're referring to What chemicals what -- how to protect from what Q. Any chemicals A. Fire hazards tornadoes or what It's vague Q. Did Kerr work with chemicals that caused 1 A. No I did not Page 67 1 2 Q. Okay But you had heard of lawsuits right 2 3 A. Correct 3 4 Q. I mean you'd heard that if somebody slips and 4 5 falls in a grocery store they might bring a lawsuit 5 6 right 6 7 A. Correct 7 8 Q. And you'd heard maybe if somebody got in a car 8 9 accident and ended somebody else there could be a 9 10 = lawsuit right 10 11 A. Correct 11 12 Q. And you knew if somebody sold a product that hurt | 12 13 somebody there could be a lawsuit right 13 14 A. Correct 14 15 Q. And in 1976 Kerr knows that it's selling a 15 16 product that the American Dental Association says could 16 17 hurt somebody right 17 18 A. Possibly 18 19 Q. Okay So in 1976 there's a possibility that 19 20 Kerr can be sued if people get sick from the asbestos in | 20 21 ~~ the tape right 21 22 A. Correct 22 23 Q. And Kerr didn't do anything to make dentists or 23 22 dental technicians or anything else aware of the 24 25 asbestos hazards of the asbestos tape that Kerr sold 25 tornadoes Page 69 A. No. I mean you said Kerr works to protect their people with chemicals I don't know -- Q. No. I'm sorry -A. -- it's so vague -- it's so vague I don't know what you're referring to Q. Kerr knew how to protect its employees from the dangerous chemicals they worked with true A. True if they worked with any Q. Right And Kerr had people whose job was to make sure that Kerr's employees weren't hurt by the chemicals they worked with right A. Someone was responsible correct Q. So Kerr Corporation was familiar with working with chemicals that could be dangerous right A. I don't know if I would classify any of the chemicals we made for impression materials to be dangerous Q. Okay A. -- quite frankly Q. Well the only way they would know is if they looked up information about the chemical to find out if it was dangerous or not right A. Or the supplier provided that information correct Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 70 1 Q. Okay Kerr certainly had the ability to research 1 2 the hazards of different chemicals right 2 3 A. I can't say they did I was in manufacturing 3 4 Q. Well when you started Kerr was in Detroit 4 5 Michigan 5 6 A. Yes 6 7 Q. Detroit Michigan is near two major universities 7 8 right 8 9 A. Correct 9 10 Q. Detroit Michigan has libraries right 10 11 A. Correct 11 12 Q. Kerr could have sent someone to a library to do 12 13 research on a chemical if they wanted to right 13 14 A. If they needed to correct 14 15 Q. Okay The reason Kerr decided to stop selling 15 16 asbestos is because it did not want to be sued true 16 17 MR REYEN Misstates testimony lacks 17 18 foundation 18 19 THE WITNESS I don't know that that's the reason | 19 20 we stopped selling asbestos We just wanted to make 20 21 sure we didn't expose the company to potential hazardous | 21 22222 material 22 23 MR JONES Well -- go ahead 23 24 THE WITNESS It always said it was a potential 24 22222 for hazard 25 70..73 Page 72 its customers the dentists and dental technicians working with them true MR REYEN Lacks foundation calls for speculation And when you say what Kerr did it makes it sound like you're asking for his testimony as a person most knowledgeable about what Kerr thought which is not what this deposition is today THE WITNESS I just can't -- I can't speak to that whole -- the logic of what you're just saying why we -- why we stopped asbestos BY MR JONES Q. Well if Kerr was really worried about the health of its customers the dentists and the dental technicians then they would have done more to protect them right MR REYEN Objection -THE WITNESS I can't speak to that BY MR JONES Q. What's that A. That's not my knowledge base Q. Well you know that when the asbestos tape came from the suppliers to Kerr it was in packaging already marked with Kerr's name on it right A. Yes Q. Kerr's the one that decided what to write on the 1 BY MR JONES Page 71 1 boxes of asbestos tape or the bags true Page 73 2 Q. Your employees in the factory didn't really 2 A. Yes 3 handle it though It was in a package whenever they 3 Q. In 1976 when Mr. Kovac brought the article into 4 handled it They -- it was in a package in one box and | 4 the executive meeting Kerr didn't start putting 5 then they moved it in a package to another box right 5 warnings on the asbestos tape that went out to 6 A. Yes 6 customers true 7 Q. The people that were working with this hazardous 7 A. True we did not nor did the vendors 8 thing were the dentists and the dental technicians 8 Q. And I'm asking about Kerr The meeting we're 9 right 9 talking about is in 1976 with Kerr executives true 10 A. Yes 10 A. True 11 Q. And Kerr was worried that one of those dentists 11 Q. In 1976 the president of Kerr had the ability if 12 could get sick and sue Kerr right 12 he wanted to to start putting warnings on the asbestos 13 A. I don't know if that was in the forefront of 13 tape true 14 their thinking all the time 14 A. That would -- I can't speak for him If that was 15 Q. But it was part of it 15 his goal yes 16 A. Could be 16 Q. He did not do that true 17 Q. We know that Kerr didn't do it to protect 17 A. True 18 dentists and dental technicians true 18 Q. From 1976 until asbestos was phased out Kerr 19 A. Didn't do what now 19 never put a warning on the product about asbestos true 222222 Q. Kerr didn't -- Kerr didn't do anything because it | 20 222222 was worried about dentists and dental -- dental -- 21 A. True Q. In fact Kerr made no effort Kerr didn't do 222222 strike that When Kerr found out -- strike that 22 anything to inform its customers that the asbestos tape 222222 When Kerr made the decision to stop using 23 could hurt you true 222222 asbestos with its investment materials it did not make 24 A. True 222222 that decision because it was worried about the health of | 25 Q. Kerr dealt with suppliers to sell its products Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 true Page 74 1 2 A. Manufacturers yes 2 3 Q. Well it dealt with suppliers like Henry Schein 3 4 or Patterson or Buffalo Dental those kind of companies 4 5 right 5 6 A. Distributors yes 6 7 Q. And Kerr would train those distributors about 7 8 Kerr's products so that they would be able to sell them 8 9 right 9 10 A. I don't -- that's not my job I don't know 10 11 Q. You've previously testified that Kerr trained the | 11 12 distributors about the products Do you recall that 12 13 A. I don't recall that 13 14 MR JONES Okay 14 15 MR REYEN As far as I know there's no question | 15 16 pending 16 17 MR JONES That's correct 17 18 Q. Mr. Girling I want to refresh your recollection 18 19 about this if I can So I've put up -- hopefully you 19 20 can see it -- a copy of your deposition taken in the 20 21 Witkowski case That was a California case out of 21 22222 San Francisco County July 15 2004. Do you see it 22 22222 A. Yes 210 pages 23 24 Q. Yes sir And it says Deposition of Larry 24 22222 Girling That's you right 25 74..77 products Page 76 It didn't say -- it's not specific to the asbestos products Q. I agree A. I think that was your question before was we provided training on the asbestos products to the dealers and I -- I don't recall that Q. My question did not have to do with asbestos but I appreciate the confusion My question is Kerr provided training about its products to distributors and salespeople right A. Correct Q. Kerr wanted its distributors and salespeople to know their products so that they could sell them right A. I assume that's why they did it Q. And Kerr for sure wanted to sell products right A. Always Q. Yeah And the distributors and salespeople are the ones that actually met with the people that bought the products right A. Correct Q. So they were in between you Kerr and the dentists right A. Correct Q. Kerr never provided any training to its distributors about the asbestos hazards associated with 1 A. Correct Page 75 1 tape true Page 77 2 MR REYEN Is it large enough for you to read 2 A. I can't speak to that I'm not aware of any 3 Larry 3 Q. Kerr went to the American Dental Association 4 THE WITNESS I'm going to make it a little 4 trade show every year in Chicago 5 bigger now Okay 5 A. They did attend it I don't know if every year 6 BY MR JONES 6 or what but 7 Q. So this is your testimony in a prior case right 7 Q. Had a booth 8 A. Okay 8 A. Correct 9 Q. Is that true 9 Q. The idea was at the American Dental Association 10 A. I yes If I said it in a deposition as 10 trade show that they would interact with people that 11 testimony then I default to the testimony quite 11 might buy their dental products right 12 ~~ frankly 13 Q. Fair enough Can you go to Page 161 of the 12 A. I don't -- I can't say the motive for the show 13 but they were there 14 deposition You're going to have to scroll down Let 14 Q. It's a trade show right 15 me know when you're there 15 A. Trade -- yes competitors were there 16 A. I'm at 150 16 Q. Right And the idea was that Kerr would be at 17 Q. Keep going 17 this trade show to hopefully trade their products 18 A. There 161 18 = right 19 Q. 161 around Line 15 you talk about Kerr providing | 19 A. Correct 20 training to the distributors Do you see that 20 Q. Kerr never informed anyone at these ADA trade 21 A. Yes 21 shows about what it learned about the hazards of 22 Q. Okay Does that reflect your recollection that 23 Kerr provided training about its products to its 24 distributors 25 A. Yeah a -- we did train sales reps on our 22 asbestos in its products right 23 A. I don't know I don't know 24 Q. Did Kerr ever take the asbestos tape off the 25 shelves whenever it found a replacement Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 A. Can you say that again Page 78 2 Q. Yeah Did Kerr ever take the asbestos tape off 3 the shelves whenever it found a replacement 4 A. Take -- 5 Q. Like recall it 6 A. Not that I'm aware of 7 Q. So whenever Kerr came up with the nonasbestos 8 tape did they take all the rest of their asbestos tape 9 in inventory and throw it away 10 A. It was -- the new tape was phased in as we ran 11 out of -- as the new tape became available it was put 12 into production right away because it them took time 13 to -- for the developers to get the tape process down 14 pat 15 Q. So the new tape was phased in and the old 16 asbestos tape was phased out 17 A. Correct 78..81 1 BY MR JONES Page 80 2 Q. Do you know what the Federal Register is 3 A. Federal Register for what 4 Q. The Federal Register where the federal government 5 prints laws and notifications and requests for hearing 6 in the Federal Register 7 A. not familiar with it no 8 Q. Okay Who in Kerr had responsibility to review 9 the Federal Register to determine whether there were any 10 labeling requirements with respect to 11 containing products 12 A. I don't know 13 Q. Mr. Girling I've just displayed your deposition 14 in the Girling -- pardon me -- in the Blackledge case 15 That -- I think this is the first deposition you ever 16 gave in an asbestos case out of Louisiana Can you see it 18 Q. And the way the old -- so the new tape was sold 18 A. I see it 19 once the old tape was gone 19 Q. Okay And then at the top it says the 20 A. No. The new tape was put into production as soon | 20 deposition of Larry Girling Do you see that 21 as we could get it available by size 21 A. Yeah it's handwritten in 22222 Q. So did you throw away the asbestos tape that 22 Q. Yeah And that's you right 23 hadn't been sold yet 23 A. Correct 24 MR REYEN Objection -- 24 Q. Okay And this is your testimony 25 THE WITNESS I -- I can't speak to that We 25 A. Yes Page 79 1 only -- it wouldn't be very much if it was thrown away 1 MR REYEN Page 81 Why don't -- you want him to read the 2 because it got delivered every month every 30 days so 2 whole thing You know assuming Trey that it is an 3 the quantities would be very small 3 accurate thing we will testify as to -- we will 4 Q. Did you -- did Kerr call its distributors and 4 stipulate to the authenticity of it We won't waive any 5 tell them to take the asbestos tape off the shelves and 5 relevant objections but we'll stipulate to the 6 start selling the new nonasbestos tape 6 authenticity of it but 7 A. I don't know 7 MR JONES Okay I'm just -- look at the first 8 Q. There would be some record of that right 8 page it asks the full name and I'm just asking the 9 A. I don't know 9 witness -- I'll do it 10 Q. Back to Ken Kovac You would agree with me that 11 one of the roles of the quality assurance group was to 12 stay abreast of all the Federal Regulations true 13 A. True 10 Q. If you look at the second page of the document 11 the beginning of the questioning you can see that this 12 is a deposition of you true 13 A. True 14 Q. One of the ways that Kerr's quality assurance 14 Q. Okay And you're testifying on behalf of Kerr 15 group stayed abreast of Federal Regulations was to read 15 Corporation You can see that at the bottom of that 16 the Federal Register correct 16 page right 17 MR REYEN Objection lacks foundation calls 17 A. You mean as a person of knowledge or what 18 for speculation -- 18 Q. Actually when this is taken you're still 19 THE WITNESS I can't -- 19 employed by Kerr Corporation Do you see that You're 222222 MR REYEN -- calls -- 20 still working at Kerr Corporation when this deposition 222222 THE WITNESS -- speak to that I don't know how | 21 took place 222222 they did their job 22 A. What's the date on it 222222 MR REYEN Larry you've got to let me finish my | 23 Q. '96 But at the bottom you're asked who you're 222222 objection 24 employed and you say Kerr Corporation 222222 THE WITNESS I'm sorry 25 A. Okay Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 82 1 Q. If you can please go to page -- it's going to be 1 2 the 24th page of the PDF the deposition page will say 2 3 26. So scroll down to 24 3 4 A. Okay I've got 24 4 5 Q. And at the top -- you see the number 26 in the 5 6 top right 6 7 A. Yes 7 8 Q. Okay Around Line 6 you're asked about OSHA 8 9 requiring warnings Do you see that 9 10 A. Yes 10 11 Q. At Line 9 you're asked 11 12 Q. What if anything did you do to 12 13 determine whether OSHA did have any such 13 14 requirements 14 56282222222 Your answer at Line 11 We were never 15 56282222222 notified by OSHA or any other federal agency 16 17 that we would have to label asbestos 17 56282222222 differently Normally the notification 18 56282222222 process is through the Federal Register 19 56282222222 which it would have come out in there 20 21 Did I read that correctly 21 56282222222 A. Correct 22 56282222222 Q. So that was your testimony right 23 56282222222 A. Correct 24 56282222222 Q. The next question is what I asked you a moment 25 82..85 say Girling -- Exhibit Girling No. 2 Plaintiffs Exhibit 2 was marked for identification and attached hereto BY MR JONES Page 84 Q. Okay Can you see what I've marked as Exhibit No. 2 A. Yes Q. What is Exhibit No. 2 A. It says it's a Federal Register Highlights of This Issue Q. And what's the date on it A. June 7th 1972 Q. So it was Ken Kovac's job at Kerr to monitor this publication right A. Correct Q. And in 19 -- on June 7 1972 Kerr Corporation is selling asbestos tape to dentists and dental technicians to use in casting gold true A. Yeah whatever they were casting I'm not sure what they were casting Q. And in 1972 Kerr is buying rolls of asbestos tape and strips of asbestos tape and its employees are taking that tape and putting it in individual packages to ship to customers right A. Correct Page 83 1 ago Well who in Kerr had responsibility to review 1 2 the Federal Register to determine whether there were any 2 3 labeling requirements with respect to 3 4 containing products 4 LO Your answer at Line 20 The QA group Kovac's 5 6 group basically Did I read that correctly 6 7 A. Correct 7 8 Q. Okay So does that refresh your recollection 8 9 that it was Ken Kovac's job as the vice president of 9 10 quality assurance to monitor the Federal Register 10 11 A. Correct 11 12 Q. Okay So if there was something in the Federal 12 13 Register talking about one of Kerr's products Kerr had 13 14 someone employed to find that stuff and communicate it 14 15 to the company right 15 16 A. It -- yes 16 17 Q. And that person was -- in the 70s was Ken Kovac | 17 18 true 18 19 A. True 19 222222 Q. I'm going to show you - 222222 Giselle this -- I've only marked one exhibit 222222 ~~ right 222222 THE REPORTER Right 222222 MR JONES I'm going to show you what I'll mark 25 as Exhibit No. 2 and the sticker is actually going to 20 21 22 23 | 24 25 Page 85 Q. Okay So if the Federal Register had some requirement that Kerr was to warn about asbestos it was Ken Kovac's job to communicate that to the company right MR REYEN Objection over -- well if Ken Kovac was in that position at this time THE WITNESS Yeah it -- BY MR JONES Q. If not him somebody Whoever is in charge of quality assurance is supposed to make sure that Kerr is following regulations right A. Correct MR JONES of the document Can you please go to the sixth page MR REYEN Well Mr. -- Mr. Girling before today have you ever seen this document MR JONES Wait No no no You'll do that on = redirect MR REYEN No but you're -- this is improper examination -- MR JONES You can do that on redirect You're not examining him during my examination Now if you want to suspend the deposition you can suspend it And that's exactly what I'm going to do if you start interrupting my examination Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 86 1 MR REYEN Well you can do what you want but 1 2 this is not the proper use -- this is not the proper use | 2 3 of a document and it's not the proper -- it's not 3 4 proper examination 4 5 MR JONES Well make your objection 5 6 MR REYEN I just made it Go ahead 6 7 MR JONES All right Thank you 7 8 Q. Okay Are you on the sixth page Mr. Girling 8 9 A. Yes 9 10 Q. On the hand column about the middle it says | 10 11 Title 29 Labor Chapter XVII Occupational Safety and 11 12 Health Administration Department of Labor Part 1910 12 13 Occupational Safety and Health Standards and then it 13 14 says Standard for Exposure to Asbestos Dust Did I read | 14 15 that correctly 15 16 A. Correct 16 17 Q. And Kerr -- 17 18 A. This was OSHA's guidelines for inspection right | 18 19 Q. For asbestos It's the standard for exposure to 19 222222 asbestos -- 20 21 A. For -- 21 222222 Q. -- do you see that 22 222222 A. -- anybody -- anybody that manufactured asbestos | 23 222222 Q. Well you hadn't seen this before right 24 222222 A. No. But is that what this is for is OSHA's 25 86..89 published in the Federal Register on January 12 1972. Did I read that correctly A. Correct Page 88 Q. So what they're saying is two things were published in the Federal Register about asbestos before this the emergency standard and then they asked for comments right MR REYEN Lacks foundation calls for speculation beyond the scope of this person's presence here -- THE WITNESS I can't speak to what they're doing what OSHA's -- what -- what their sequence was BY MR JONES Q. Well this is my point If Kerr had someone whose job it was to monitor the Federal Register for regulations that applied to it this is saying that there were two other things published about asbestos in the Federal Register right A. Two other things published -- Q. Yeah A. -- that they -- they -- OSHA was establishing their OSHA limits for exposure to asbestos fibers in the dental laboratories also by the way who are subject to that and in the dental office Page 87 1 guidelines for the manufacturers of asbestos 1 2 Q. Not just manufacturers but people that use it 2 3 also 3 4 MR REYEN I don't know that that's correct I 4 Q. Which -A. And -- and the manufacturer also Page 89 Q. What's your point A. We were not a manufacturer That's what it - 5 object to that Ask a question but you know again I 5 this OSHA spec did not apply to our plants 6 don't think this is a proper line of questioning And 6 Q. Are you saying it's the dentists fault 7 you're not -- it's an improper use of the document 7 A. No. I'm saying the dentist was under the same 8 BY MR JONES 8 OSHA guidelines 9 Q. Okay So Kerr was familiar with OSHA right 9 Q. So -- 10 A. OSHA came out in 1972 10 A. -- to make sure -- make sure that the fiber 11 Q. And Kerr was familiar with that right 11 exposure was not above the limits when he -- when he 12 A. We worked with OSHA yes 12 made his castings in his lab 13 Q. Okay And Kerr had employees that were subject 13 Q. Okay So what you're saying is that it's the 14 to OSHA regulations right 14 dentists fault if they're exposed to asbestos while 15 A. Correct 15 working with asbestos tape -- 16 Q. Okay And if you look at the -- under the title | 16 A. I did not say that I did not say that I 17 it says 17 said -- 18 On December 7 1971 an emergency 18 Q. -- follows -- 19 temporary standard concerning exposure to 19 A. -- the dentist could be subject to OSHA 222222 asbestos fibers was published in the Federal 20 guidelines the same way any manufacturer was 222222 Register In accordance with the Section 6 21 Q. Okay So what you're saying is that it's -- the 222222 C of the Williams Occupational 22 dentist had a responsibility to protect themselves from 222222 Safety and Health Act of 1970 a notice of 23 Kerr's asbestos tape 222222 proposed rulemaking regarding a permanent 24 A. not saying that I'm saying they'd have to 222222 standard for exposure to asbestos fibers was 25 abide by -- abide by OSHA guidelines as well as any Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 other manufacturer Page 90 1 2 Q. Okay -- 2 3 MR REYEN Okay If that's the question we're 3 4 going to take a break here for five minutes 4 5 MR JONES Sure 5 6 THE VIDEOGRAPHER 2:50 p.m. we are off the 6 7 record 7 8 Recess from 11:50 a.m. to 12:06 p.m. 8 9 THE VIDEOGRAPHER Okay We're back on the 9 10 record and the time is 3:06 p.m. 10 11 BY MR JONES 11 12 Q. Okay Mr. Girling did you have a chance to talk | 12 13 to your lawyers over the break 13 14 A. I talked to Richard 14 15 Q. Did you get a chance to look at this OSHA exhibit | 15 16 = any further 16 17 A. No I did not 17 18 Q. Okay Can you scroll over to the middle column 18 19 the bottom paragraph of that same page starts with No 19 20 one 20 21 MR REYEN Okay I'm going to object This is 21 22222 improper examination You have not established 22 23 that he ever saw this document before today You've not | 23 24 established that he is an expert on OSHA regulations 24 22222 If you want to ask a question you can ask a 25 90..93 Page 92 duration is causally related to asbestosis and cancers MR REYEN Same objections MR JONES I'm not done Q. The dispute is as to the determination of a specific level below which exposure is safe Did I read that correctly A. Yes Q. Okay If you go to the right column second full paragraph so it's kind of toward the middle it says In view ... Do you see that A. Yes Q. In view of the undisputed grave consequences from exposure to asbestos fibers it is essential that the exposure be regulated now on the basis of the best evidence available now even though it may not be as good as scientifically desirable Did I read that correctly A. Correct Q. And then at the bottom of the paragraph it says Lives of employees are at stake Did I read that correctly A. Correct Q. Kerr didn't put a -- well strike that Can you go to the next to last page of the document Page 91 1 question but you're not going to introduce this 1 A. Yep Page 93 2 document which is a hearsay document through the 2 Q. On the right column kind of toward the 3 examination 3 upper middle there's something that says Caution 4 MR JONES I actually established that he had 4 Labels Do you see that 5 never seen it before today 5 A. Yes 6 MR REYEN Yeah so why do you keep asking him 6 Q. Okay It says Caution Labels Labeling 7 questions about it 7 Caution labels shall be affixed to all 8 MR JONES You know why If you didn't know 8 raw materials mixtures scrap waste debris 9 you wouldn't care 9 and other products containing asbestos 10 MR REYEN Well you know he is not -- he is 10 fibers or to their containers except that no 11 not here as an expert witness He is not here as a PMK 11 label is required where asbestos fibers have 12 for Kerr You have not established that he is familiar 12 been modified by a bonding agent coating 13 with OSHA or who it applied to and under what 13 binder or other material so that during any 14 circumstances it applied 14 reasonably foreseeable use handling 15 But go ahead I reserve -- those objections will | 15 16 relate to this entire line of questioning which I think | 16 17 is harassing and wasting time 17 storage disposal processing or transportation no airborne concentrations of asbestos fibers in excess of the exposure 18 MR JONES I will stipulate to a running 18 limits prescribed in Paragraph B of this 19 objection 19 section will be released 20 Q. All right Mr. Girling are you with me 20 Did I read that correctly 21 A. Yes 21 Yes 22 Q. Okay So this document published in the Federal | 22 Q. And then under that -- well let me ask you so 23 Register on June 7 1972 that middle column at the 23 the asbestos tape I mean it wasn't -- it wasn't dipped 24 bottom says No one has disputed that exposure to 24 in rubber or plastic or anything It wasn't covered in 25 asbestos of high enough intensity and long enough 25 cement It was just a tape right Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 94 1 MR REYEN Objection lacks foundation calls 1 2 for speculation 2 3 THE WITNESS I don't know the formulation that 3 4 the manufacturers used to make the tape 4 5 BY MR JONES 5 6 Q. Well I'm not asking you the formulation You 6 7 saw it with your own two eyes right 7 8 A. Well I -- 8 9 MR REYEN Objection -- objection He doesn't 9 10 have an -- electron microscope eyes 10 11 MR JONES I just -- I'm just asking about his 11 12 regular old eyeballs not his Superman eyeballs 12 13 MR REYEN He is not here -- you can establish 13 14 whether or not he is familiar with the chemical 14 15 composition the constituents the binders that were 15 16 used with it if he knows but if he doesn't know he 16 17 doesn't know 17 18 MR JONES I can really ask anything I want 18 19 MR REYEN Well you -- you are proving that 19 222222 You're not necessarily asking things that are admissible | 20 21 or proper but you are 21 222222 MR JONES We'll find out We'll find out 22 222222 Q. All right Are you with me -- 23 24 A. Yes 24 222222 Q. - Mr. Girling Keith Reyen is wasting our time | 25 1 I just want to get this done All right Page 95 1 2 A. Okay 2 3 Q. Now my question to you is you personally saw 3 4 with your own two eyes the asbestos tape right 4 5 A. I saw some tape yes 5 6 Q. And it wasn't covered in rubber or cement or 6 7 plastic right 7 8 A. Correct 8 9 Q. Okay Now if you look below there's a caution 9 10 It says Caution Contains Asbestos Fibers Avoid 10 11 Creating Dust Breathing Asbestos Dust May Cause Serious | 11 12 Bodily Harm 12 13 Did I read that correctly 13 14 A. Correct 14 15 Q. Did Kerr ever put that warning on its products 15 16 that included asbestos tape 16 17 MR TAURAS I'm going to object 17 18 THE REPORTER I'm sorry Is there an objection | 18 19 MR JONES It sounds like an objection was made 19 222222 under water 20 21 MR TAURAS I'm objecting Assumes facts 21 222222 THE REPORTER I can't hear 22 23 MR JONES It sounds like the attorney is 23 222222 getting a swirly while trying to object 24 25 MR TAURAS All right Note my objection 25 94..97 Assumes facts not in evidence MR JONES Yes Page 96 Can you hear that THE REPORTER Yes MR TAURAS BY MR JONES Okay Thank you Sorry about that Q. All right Do you have my question in mind because I forgot it A. No I don't know Q. All right The same objection will apply Mr. Girling you would agree with me that Kerr never put the warning in this Federal Register OSHA document on its asbestos tape products right A. We never put warnings correct Q. So after this was published in the Federal Register in 1972 Kerr didn't do anything different right A. Correct Q. Kerr kept selling asbestos tape true A. Yes Q. It didn't put a warning on it true A. True Q. And it didn't do anything to tell dentists or dental technicians that the asbestos could hurt people true A. True Page 97 Q. Okay Now Kerr was first sued in asbestos litigation in around 1990 or 1991 right A. I don't know for a fact Q. Well it's around -- 1990 or 1991 is around when lawyers asked you to do a search in Kerr Corporation's files to find documents about asbestos right A. Yes Q. Okay And you knew that the reason that you were doing that was because Kerr had been sued right A. Correct Q. Okay The search was for sales records purchase records specifications brochures or anything dealing with asbestos products right A. It was very broad Q. And you were one of the people that did that search You personally worked on it right A. Or the purchasing department correct Q. Well my understanding is that Kerr went to each department and asked for them to search for all the records right A. Anything that said something to do with asbestos correct Q. And whatever you found you packaged up and sent to Sybron right A. No. We gave it to Kovac Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 98 1 Q. My understanding of your testimony is that all 1 2 the documents were forwarded to Sybron's legal counsel 2 3 A. I believe Kovac forwarded them 3 4 Q. Okay And Sybron was the parent company of Kerr 4 5 Corporation at that time in 1990 or '91 5 6 A. Correct 6 7 Q. Okay -- 7 8 MR REYEN Actually can I have that question 8 9 read back 9 10 Record read) 10 11 MR REYEN Okay Your question lacks 11 12 specificity as to what Sybron entity but 12 13 MR JONES You can tell me 13 14 MR REYEN It was Sybron International I 14 15 believe at that time 15 16 MR JONES All right All I know is I sent them | 16 17 a subpoena and they didn't respond to it and I moved 17 18 to compel 18 19 MR REYEN I understand But you sent a 19 222222 subpoena to Sybron Dental Specialties not to Sybron 20 21 International 21 222222 MR JONES All right I'll send another one 22 222222 Sybron International 23 222222 MR REYEN The other -- the response on the 24 222222 other one will come but there is a distinction 25 98..101 are the documents you located in 1990 or Page 100 '91 or whenever it was Okay A. Okay MR JONES All right We'll go off the record So what -- however much -- about how much time you think you need THE WITNESS 15 minutes MR JONES and come back All right We'll give you 15 minutes THE VIDEOGRAPHER Okay The time is twelve - I'm sorry -- 3:20 p.m. We are off the record Recess from 12:20 p.m. to 12:30 p.m. THE VIDEOGRAPHER Okay We're back on the record and the time is 12:30 -- or I'm sorry -- 3:30 p.m. BY MR JONES Q. Mr. Girling I have attached 52 pages of documents as Exhibit 3 to the deposition Can you tell me what is Exhibit 3 A. Exhibit 3 where -- all 52 are Exhibit 33 Q. Yes Collectively what is -- what is it A. Documents found at Kerr Corporation Q. Okay Are these the documents that you found in your search in 1990 or 1991 A. I found the first two Page 99 1 MR JONES I can subpoena all day 2 Q. Okay Mr. Girling I'm going to show you what 3 was represented to me to be everything you found when 4 you searched for asbestos documents in 1990 or 1991 5 All right 6 A. Okay 7 MR JONES I am going to mark this as Exhibit 3 8 right 9 Plaintiffs Exhibit 3 was marked for 10 identification and attached hereto 11 MR JONES Giselle does that sound right 12 THE REPORTER Oh yes yes 13 MR JONES All right You've been around me 14 = enough You know you've got to watch this kind of 15 thing I might switch to letters or symbols if you 16 don't monitor the situation Page 101 1 Q. Okay The first two pages you mean 2 A. First two pages 3 Q. Okay 4 A. First two documents 5 Q. Okay It was represented to me by Kerr's lawyers 6 that these are all of the documents that Kerr has 7 dealing with its sale of asbestos products is that 8 true 9 A. I can't speak to that I know what I found and 10 = that's what I provided 11 Q. Okay So when you were involved in this search 12 for documents and you gathered everything up about how 13 many pages did everybody find in total 14 A. I don't know I found two 15 Q. Okay Now in this deposition earlier we talked 16 about all of Kerr's efforts to find a substitute for 17 Q. All right Mr. Girling this is a total of 52 17 asbestos right 18 pages What I'd like to do -- and actually we'll go off | 18 19 the record to do it But what I'd like you to do is 19 A. Yes Q. It took many different people and several 20 just scroll through it to become generally familiar with | 20 different divisions a while to do that right 21 what's in there Okay I'm not -- you don't -- not | 21 A. Yes 22 going to ask you any questions about it If do I'll | 22 Q. Correct me if I'm wrong but there are only 23 show it to you 23 two -- well pardon me There's only one page in this 24 So I'm not asking you to memorize it I'm just 24 document production related to Kerr's efforts to replace 25 asking you to scroll through it and confirm that these 25 asbestos tape with a nonasbestos product true Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 102 1 A. I don't know I haven't gone -- I haven't 1 2 counted to see what's in there but 2 3 Q. Scroll through The only thing I see is your 3 4 memo dated October 19 1978. That's all I see But do 4 5 me favor Please scroll through the documents and let 5 6 me know if you see any other documents dealing with 6 7 Kerr's efforts to replace asbestos tape with a 7 8 nonasbestos product 8 9 A. I see that one memo requesting a replacement 9 10 Q. Okay That's the only one you see in there 10 11 right 11 12 A. Correct yes 12 13 Q. Now if you look at your memo -- first of all 13 14 this does show that Kerr sent memos about this project 14 15 right 15 16 A. My memo was at the end of the project correct 16 17 Q. Do you think that's the only memo they ever sent 17 18 about the project 18 19 MR REYEN Objection calls - 19 222222 THE WITNESS I don't -- 20 222222 MR REYEN Calls for speculation 21 222222 THE WITNESS I don't know 22 222222 BY MR JONES 23 222222 Q. Well the first thing you say is to -- so your 24 222222 memo is the 50th page At the bottom right it says 25 102..105 Page 104 Q. There's no memos from marketing about this in the documents you've produced right A. I don't know I didn't search marketing memos Q. Well if this is everything it would be here right MR TAURAS Objection THE WITNESS I can't say BY MR JONES Q. So I'm not -- so I'm not asking you if this is everything I don't know I filed a motion to compel Kerr to produce everything and we'll find out if a judge grants it and if they comply with the order My question to you is -- I'll start over Do you see anywhere in these 52 pages any documents discussing marketing's agreement to market the new Carborundum 97 material under the Kerr name of Flask Liner A. No. Q. There's no documents from purchasing talking about buying the new material right A. I don't see any yes Q. There's no documents from research and development talking about their tests of the material right A. I didn't search research Q. I'm asking you about in these pages In these Page 103 Page 105 1 Kerr zero Kerr -50 You 1 pages there's no documents from research and 2 see that 2 development talking about their tests of the new 3 A. No. I've got to make it bigger Yes 3 material true 4 Q. Okay The first thing you say is Please 4 A. True 5 circulate a PPL to discontinue supplying asbestos rolls 5 Q. There's no documents from finance talking about 6 in our investment packages and also individual sale of 6 how much the material costs and how that will affect the 7 boxed asbestos rolls 7 price of the products true 8 Did I read that correctly 8 A. Yes 9 A. Yes 9 Q. There's no documents -- no memoranda at all from 10 Q. What is a PPL 10 Kerr's executives right Correct 11 A. Product planning log 11 A. Yes 12 Q. And what does that mean 12 Q. Ken Kovac the person whose job it was to monitor 13 A. It's usually initiated to discontinue a product 13 things like the Federal Register there's no memos from 14 or add a new product to the -- to the system 14 Mr. Kovac true 15 Q. Okay Your -- your memo mentions a PPL but the 15 A. Yes 16 PPL itself is not in these documents right 16 Q. There are no memos or any other documents talking 17 A. It is not 17 about the 1976 American Dental Association document 18 Q. What happened to it 18 true 19 A. I have no idea 19 A. True 20 Q. The next paragraph says Marketing has agreed to | 20 Q. And we have the document but nobody wrote a 21 market the new Carborundum 97 sic material in boxes 21 memo -- there's no -- well I don't know 22 of 50 and 100 feet lengths under the Kerr name of Flask 22 Do you think somebody wrote a memo about it 23 Liner 23 A. I don't know -- 24 Do you see that 25 A. Yes 24 MR REYEN Objection calls for speculation 25 THE WITNESS I can't guess about that Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 BY MR JONES Page 106 1 2 Q. All right But I mean in your experience at 2 3 the company is that something that would just spread by | 3 4 word of mouth that they would get this article and then | 4 5 just kind of talk about it down the hall 5 6 A. A lot of that did go on 6 7 Q. Okay So -- so you think the reason we're not 7 8 finding these documents is because Kerr got this 8 9 information that the product they sell could cause 9 10 cancer and then they found a replacement for the 10 11 product after testing several different candidates and 11 12 then found the replacement and then informed marketing 12 13 to change the marketing materials to include the 13 14 place -- the replacement and they did all of this by 14 15 word of mouth 15 16 MR REYEN Objection - 16 17 THE WITNESS No -- 17 18 MR REYEN Hold on a second Larry 18 19 That is compound it is argumentative it calls 19 222222 for speculation and lacks foundation 20 21 You can answer if you understand the question 21 222222 Go ahead Larry 22 23 THE WITNESS What was the question now 23 24 BY MR JONES 24 222222 Q. Is it your -- is it your testimony that this 25 106..109 Page 108 regulatory affairs that are discussing asbestos hazards true A. Yes Q. There's no documents from manufacturing discussing the switchover from asbestos to nonasbestos true A. No. My -- I'm representing manufacturing I sent the document out to Probst Q. One page A. Summary of all of -- of everything yeah Q. You're right It's a summary of everything but the everything -- all the documents that go into the everything are not in these 52 pages right A. Yes Q. The PPL's not in there right A. Yes Q. Okay There's no documents from marketing talking about changing the price lists or marketing the new nonasbestos product anything like that right A. Yes Q. You told me that every year Kerr's sales team did marketing forecasts right A. Yes Q. The way you do marketing forecasts is you figure out how much you sold the year before and then you make Page 107 Page 109 1 entire process involved with identifying the hazard of 1 a guess about if you're going to sell more or less 2 the product and replacing the product was done through 2 right 3 word of mouth 3 A. Yes 4 A. No. 5 Q. If there were memos about it they're not here 6 They're not in these 52 pages right 7 MR REYEN Objection calls for speculation 8 lacks foundation 4 Q. Educated guess we'll call it right 5 A. Yes 6 Q. And a company keeps track of its sales to see how 7 it's doing year over year right 8 A. As far as I know 9 THE WITNESS I didn't search all the 9 Q. And Kerr kept records of its sales true 10 departments I don't know 10 A. I don't know about kept records I know they 11 MR JONES I'm not -- 11 track sales correct 12 THE WITNESS -- this is 18 years after the 12 Q. Well and the reason they track sales is for 13 fact -- 13 accounting right You have to know how much you sold 14 BY MR JONES 14 right 15 Q. I'm not asking about all the departments I'm 15 A. I can't speak to that I'm manufacturing guy 16 asking about in the 52 pages you have in front of you 16 Q. Well I mean you know generally that the company 17 you would agree with me that in those 52 pages there 17 you worked at -- when you were in meetings with the 18 are no documents discussing asbestos hazards with Kerr's | 18 marketing people and the other executives you knew that 19 asbestos tape other than the ADA article true 19 they kept track of how much stuff they sold right 20 A. Yes 20 A. Yes 21 Q. There are no documents discussing Kerr's efforts 21 Q. And they wanted to do better than the year 22 to replace the asbestos tape with a nonasbestos tape 22 before right 23 true 23 A. I can't speak to that 24 A. Yes 24 Q. Wait You're saying that when you were at the 25 Q. There are no documents from quality assurance and 25 corporation there were years where you'd be in Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 110 1 management meeting and somebody would say you know I 1 2 hope we don't sell as much this year That never 2 3 happened did it 3 4 A. No. 4 5 Q. You always wanted to sell more right 5 6 A. I assumed they did I'm not the -- I'm not the 6 7 person making that decision What I'm saying I'm 7 8 manufacturing person that's not my decision process 8 9 Q. And you had to keep track of your customers 9 10 because you wanted to know who bought before so you 10 11 could make sure to sell them stuff again right 11 12 A. I can't speak to that Again I don't know 12 13 Q. You don't -- you do know that Kerr kept sales 13 14 records true 14 15 A. I knew they had some sales records 15 16 Q. And you know that all of the sales records 16 17 related to the sale of asbestos products have been 17 18 = destroyed 18 19 A. I guess Couldn't find them 19 20 Q. And what you've previously testified is that the | 20 21 sales invoices shipment invoices were destroyed and we | 21 22222 couldn't locate them any of them in 1990 '91 on our 22 22222 asbestos products true 23 24 A. That's what I said in a deposition correct 24 22222 Q. So at some point between Kerr getting that 1976 25 110..113 October 19 of 1978 true A. True Page 112 Q. So that means you sold the asbestos tape through almost all of 1978 right A. Right Q. And you never took the product off the shelf right A. I can't say that we did or didn't Q. You never did a product recall right A. I don't know if we did or not Q. You know what a product recall is A. Yes I do Q. What is a product recall A. Asking for product back Q. Why A. Defective Q. Maybe it could hurt somebody right A. Possible Q. When you were at Kerr do you ever remember Kerr doing a product recall of asbestos tape A. I don't remember Q. The search for records in 1990 or 1991 did not include a search for corporate board of director meeting minutes true A. I don't know Page 111 1 article in the American Dental Association journal and 1 2 1990 when you searched for records at some point in 2 3 between Kerr's shipment invoices were destroyed 3 4 true 4 5 A. Can't speak to that I don't know 5 6 Q. Well you know they existed and you know they 6 7 were destroyed right 7 8 A. I don't know 8 9 MR REYEN Objection lacks foundation 9 10 BY MR JONES 10 11 Q. Well you know in 1976 Kerr sold asbestos tape 11 12 right 12 13 A. Yes 13 14 Q. Those records are destroyed correct 14 15 A. I don't know if they're destroyed or missing or 15 16 = lost or what 16 17 Q. You said destroyed 17 18 A. Okay That's what it was told me 18 19 Q. Okay 1977 Kerr sold asbestos tape Those 19 20 records are destroyed true 20 21 A. We couldn't find them correct 21 22 Q. 1978 Kerr sold asbestos tape Those records are 22 23 destroyed 23 22 A. We stopped selling asbestos in 1978 24 25 Q. Well according to your memo it was sent in 25 Page 113 Q. Let me show you your testimony from the Witnowski case -- Witkowski sorry Apologize to the Witkowski family Can you please go to Page 63 of this deposition A. Okay Q. You were asked -- this is your testimony again right A. I believe so Q. You were asked at Line 13 Back in '91 when this search was conducted for documents did anyone look through the corporate board of director meeting minutes Your answer at Line 16 I know our plant response wouldn't require that I don't know about the corporate level Did I read that correctly A. Yes Q. We know that the documents you've produced don't include the meeting minutes for any of the managerial meetings that you attended where they discussed asbestos true A. Yes Q. And we know those documents don't include any board meeting minutes true A. Yes Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 114 1 Q. In fact there are no documents from an executive 1 2 of Kerr except for your one page true 2 3 A. Yes 3 4 Q. And at that time you weren't the person that 4 5 would make the decision to phase out asbestos You were 5 6 the person that would carry out that decision right 6 7 A. Yes 7 8 Q. Someone would have to communicate that decision 8 9 to you right 9 10 A. Not necessarily The reason for the PPL was to 10 11 get people to sign off to make that decision 11 12 Q. What does that mean 12 13 A. That means that each of the functions had to sign | 13 14 off The president vice president sales marketing 14 15 finance By signing off they gave the authorization to | 15 16 make the change 16 17 Q. So there would be communications about that 17 18 decision 18 19 A. Only on a PPL yes 19 20 Q. Everything else would be word of mouth 20 21 A. I don't know 21 2222 Q. We don't have the PPL or anything talking about 22 2222 the PPL except for your one page right 23 24 A. As far as I know 24 2222 Q. Other than the sales records do you know if Kerr | 25 Page 115 1 has destroyed any other records dealing with its sale of 1 2 asbestos products 2 3 A. I don't know 3 4 Q. Okay Did Kerr while you were there have a 4 5 policy that you should keep any records related to its 5 6 sale of asbestos products 6 7 A. No. 7 8 Q. Did Kerr destroy any records relating to its sale 8 9 of asbestos products in the normal course of business 9 10 A. I don't know 10 11 Q. Did Kerr have a document retention policy 11 12 A. No. 12 13 Q. When's the first time Kerr had a document 13 14 retention policy 14 15 A. You're asking memory and I -- it's after some of | 15 16 the mergers we had Maybe in '87 in the 80s or 16 17 something 17 18 Q. Okay And what is a document retention policy 18 19 A. It's specific guidelines on documents I believe | 19 20 from what I can recall 20 21 Q. A document retention policy is a corporate policy | 21 22 that tells people in the corporation what documents to 22 23 keep and how long to keep them right 23 22 A. Yes 24 25 Q. And once a document has been kept for the amount 25 114..117 Page 116 of time required in the policy it can then be thrown away right A. That's -- if that's what it says correct Q. And the first document retention policy you're aware of was in the 1980s at some time right A. My memory says '80 sometime -Q. Okay A. -- after the merger Q. What merger is that A. Kerr was merged with Ormco and moved -- moved to California basically Q. Did those -- did the Detroit office where the marketing files and the D files and the executive files and purchasing files did all of that move A. I don't know I was in charge of the manufacturing group so I don't know what everything got done with everything Q. Well I mean did anything move from Michigan to California with the merger A. I know some offices and desks got moved there Q. Okay Do you know if that document retention policy in the 80s instructed people to keep documents dealing with asbestos A. I can't remember what -- I'd have to look at it I can't remember what it said Page 117 Q. Do you know if any documents related to asbestos were destroyed according to that document retention policy in the 1980s A. Repeat that one We weren't in asbestos in the 90s Q. Well I know but did the -- I'm asking about the 80s And my question is were any documents related to Kerr's sale of asbestos products destroyed in the 1980s pursuant to a document retention policy A. Oh I don't know Q. When's the first -- is '90 or '91 the first time anyone ever told you that we need to find all the asbestos documents and keep them A. Yes Q. And you don't know what happened to those documents before you looked for them right A. Yes Q. Did you have a file cabinet in your office A. I did Q. How many file cabinets did you have A. I can't remember Q. Roundabout A. Couple -- maybe a couple Q. Two or three A. Probably Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 118 1 Q. What did you keep in the file cabinets 1 2 A. I quite frankly can't tell you everything I 2 3 kept in there I know I had personnel performance 3 4 appraisals 4 5 Q. Probably had different folders with documents for 5 6 different projects you worked on right 6 7 A. I could have I don't know It's a long time 7 8 ago 8 9 Q. Okay Other people had file cabinets right 9 10 You weren't the only person at Kerr in the 70s and 80s | 10 11 that had a file cabinet right 11 12 A. Sure 12 13 Q. Probably almost every office you went into had 13 14 file cabinets right 14 15 A. Possible 15 16 Q. And in those file cabinets people kept records 16 17 related to the stuff they were working on right 17 18 A. I don't know what they kept in them 18 19 Q. Well that's what you did right You kept in 19 20 file cabinets records of the stuff you worked on right | 20 21 A. In purchasing we did 21 22 Q. All right And so in 1990 did you search 22 222 through all -- everybody's file cabinets to find 23 222 asbestos stuff 24 222 A. Yes 25 1 Q. And by 19 -- Page 119 1 2 A. In purchasing we did 2 3 Q. By 1990 out of all those file cabinets at Kerr 3 4 the only documents left about asbestos are the 52 pages 4 5 we attached as Exhibit 3 to this deposition true 5 6 A. I can't speak to that I know the two that I 6 7 found 7 8 Q. All right Well do you know -- are there any 8 9 other documents you remember finding that aren't in 9 10 these 52 pages 10 11 A. No. 11 12 Q. The last thing I want to ask you about is Kerr's 12 13 marketing of products to dental schools at universities | 13 14 You know that Kerr marketed products to universities 14 15 true 15 16 A. Yes 16 17 Q. That included the investment products with 17 18 asbestos tape true 18 19 A. I can't say for sure that they bought those But / 19 20 we did have a product that was just -- was made for the | 20 21 universities correct 21 22 Q. Yeah Kerr actually had a product specific for 22 23 university dental students right 23 24 A. Yes 24 25 Q. And that product was a box of investment powders | 25 118..121 Page 120 and the powders were in individual envelopes right A. Yes Q. One serving per envelope right A. Correct Q. And then it had a package of strips of asbestos so that the dental students wouldn't have to tear them right A. Yes Q. So you know that Kerr marketed its investment products with asbestos tape to dental schools because it had a product specifically for dental schools right A. Yes Q. You would expect that one of the dental schools Kerr marketed its products to would be the University of Southern California School of Dentistry true MR REYEN Objection lacks foundation calls for speculation THE WITNESS I -- I can't say that we shipped to California for sure No idea BY MR JONES Q. Is there any reason they wouldn't want to sell products to the University of Southern California School of Dentistry A. There was many other competitors out there I'm not sure I don't know Some of them were done on big basis Page 121 Q. I get it But if USC would buy it Kerr would sell it true A. I don't know if we had them as a customer Q. not asking you if you did I'm saying if they would buy it Kerr would sell it right A. If we offered -- if it would be offered sure MR JONES Okay All right Mr. Girling that's all my questions Thank you so much THE WITNESS Wow Thank you MR REYEN Mr. Girling before you go I have a couple questions Keith Reyen THE WITNESS Yes EXAMINATION BY MR REYEN Q. Mr. Girling when did Kerr stop selling investment A. It was in the mid 80s early 80s Q. Why did Kerr stop selling investments A. We were losing market share rapidly The Fiber Frax material really did not work very well Q. Okay In your role in procurement did you ever receive any information about any factors which limited Kerr's presence selling investment on the West Coast Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 122 1 MR JONES Lacks foundation calls for 1 2 speculation 2 3 THE WITNESS Yes I was approached numerous 3 4 times by people in Kerr about our Cristobalite 4 5 investment being uncompetitive on the West Coast because 5 6 we shipped it all the way from Michigan and the freight 6 7 would make it unattractive to the -- to the labs or the 7 8 dealers 8 9 MR JONES Move to strike on the same basis 9 10 BYBY MR REYEN 10 11 Q. Okay Is it correct sir that the -- that the 11 12 investment was sort of the main course and the strip 12 13 asbestos was something that was needed to be used in 13 14 conjunction with that use 14 15 A. That's correct 15 16 Q. Okay And is it correct that there are different | 16 17 manufacturers of investment and there's different 17 18 formulations of investment within companies 18 19 A. Yes 19 20 Q. And is it correct that -- 20 21 MR JONES Move to strike -- I'm sorry Move to | 21 22222 strike as lacking foundation and calling for 22 22222 speculation 23 24 BY MR REYEN 24 22222 Q. Is it correct -- 25 122..125 A. Yes Page 124 Q. And the plastic bags were the ones that were put into the containers of investment is that correct A. That's correct Q. Okay And which form -- or which form of packaging did Kerr receive more of the boxes or the bags A. The bags -- the bags were the high volume items We sold fewer boxed rolls than we did the bagged material Q. Okay Do you know of any reason that a consumer of investments and strip asbestos would have a preference for one brand of strip asbestos over another MR REYEN Lacks foundation calls for speculation THE WITNESS They were identical in my eyes and everybody else's eyes MR REYEN All right Thank you sir THE WITNESS You're welcome EXAMINATION BY MR JONES Q. So Mr. Girling one of Whip Mix's -- pardon me Mr. Girling one of Kerr's competitors was Whip Mix right 1 MR JONES Speculative -- Page 123 1 A. That was one Page 125 2 BY MR REYEN 2 MS RISCHMAN Calls for speculation 3 Q. Is it your understanding that those investments 3 BY MR JONES 4 had different properties 4 Q. Whip Mix had to ship their product all the way 5 MR JONES Move to strike -- oh pardon me 5 from Kentucky right 6 Object it lacks foundation calls for speculation 6 MS RISCHMAN Same objections 7 THE WITNESS Yes yes they were made for 7 THE WITNESS I don't know for sure We 8 different specific purposes 8 understood there was some people that had distribution 9 MR JONES Move to strike on the same grounds 9 warehouses in California 10 BY MR REYEN 10 BY MR JONES 11 Q. And do you have any understanding as to whether 11 Q. Well you had distribution in California right 12 or not the strip asbestos that was used in the lost wax 12 You distributed through Patterson true 13 process had similar differences or whether it was more 13 A. No no I'm telling you that they shipped 14 of a generic product 14 investment products in bulk in carloads to distribution 15 MR JONES Lacks foundation calls for 15 centers in California 16 speculation 16 Q. Well if Kerr sells their product to Patterson or 17 THE WITNESS We were told it was generic because | 17 Henry Schein or Darby Dental in Michigan and then Darby 18 our supplier told us he supplied everybody 18 Dental or Henry Schein or whoever shipped it to 19 BY MR REYEN 19 California to a warehouse then that product is in 20 Q. Okay And which suppliers were those 20 warehouse in California right 21 A. Celotex Nicolet 21 A. Correct at a higher cost 22 Q. Okay Kerr received strip asbestos from Nicolet | 22 Q. And it's a lower cost than Whip Mix coming from 23 and Celotex in boxes is that correct 23 Kentucky right 22 A. Yes 24 A. I don't think so Kentucky was closer to the 25 Q. Okay And it received it in plastic bags 25 West Coast than Michigan Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Page 126 1 Q. Well I don't -- Mr. Girling I don't want to 1 2 insult your geographic knowledge but Kentucky is on the | 2 3 East Coast and Michigan is in the Midwest right 3 4 A. Kentucky is below Michigan 4 5 Q. But it's east of Michigan 5 6 A. I 6 7 Q. To go from Kentucky to California you have to go | 7 8 past Michigan right 8 9 A. No no no 9 10 Q. Now you told me before that you really didn't 10 11 have much knowledge of what the marketing people did 11 12 Do you remember that 12 13 A. do not 13 14 Q. And you said you were in manufacturing marketing | 14 15 wasn't your job Right 15 16 A. Correct 16 17 Q. How is it that all of a sudden you know they had 17 18 all these troubles selling stuff to the West Coast 18 19 A. Because my sales guys when they would come into 19 20 the home office would say You guys got to do 20 21 something we can't compete 21 22 Q. Okay But all of the other competing companies 22 222 were on the East Coast Baker was in New Jersey Whip 23 222 Mix was in Kentucky 24 222 A. Pat supply was in Los Angeles 25 126..129 Page 128 Q. You said that you went through a search and that quote The sales invoices shipment invoices were destroyed and we couldn't locate any of them in 1990 '91 on our asbestos products true A. That's correct that's correct I searched the purchasing department Q. So we don't have the records of sales which have been destroyed So now you're telling us that through word of mouth from salespeople that they didn't really sell much to the West Coast true A. We were not a factor in the West Coast like Whip Mix Q. So you're saying Whip Mix from Kentucky was much more of a factor in the West Coast than Kerr in Michigan A. To my understanding -MS RISCHMAN I'm going to object Calls for speculation lacks foundation This is Suzanne -MR JONES Suzanne you've got to go next on this Q. I mean maybe I got the geography wrong but I'm pretty sure if you're going from Kentucky to the Kentucky Derby you've got to go past Michigan and The Big House to get to the Rose Bowl Right Did Kerr's lawyers explain this geography to you when they told you 1 Q. What's that Page 127 1 to tell this story in the deposition Page 129 2 A. Other companies were on the West Coast other 2 MR REYEN Objection 3 competitors 3 Don't answer that question You know 4 Q. Which one 4 MR JONES It's just a question 5 A. I can't say for sure I've heard other 5 MR REYEN No it's not a just a question Go 6 competitors had distribution or production on the West 6 ahead You're kind of losing it but go ahead Ask 7 Coast 7 a ask a proper -- 8 Q. Okay So do you mean to suggest that if 8 MR JONES -- if you're going to come up with a 9 David Springer testified that he purchased Kerr asbestos 9 bologna story and feed it to your witness you've 10 tape in California that that was not possible 10 got to make sure the geography works out All right 11 A. No I'm not testifying that way 11 That's all I'm saying 12 Q. In fact you know that Kerr sold asbestos tape in 12 MR REYEN I'm going to reserve my right to take 13 California true 13 your comments to the court 14 A. True yes we did 14 MR JONES Okay 15 Q. And if Kerr still had its asbestos tape sales 15 Q. Do you have any other evidence that Kerr wasn't 16 records we would know exactly where Kerr sold its tape | 16 selling products on the West Coast other than what 17 true 17 you've just described 18 A. 12 years later I don't know 18 A. We didn't say we weren't selling products on the 19 Q. But Kerr does not have its asbestos sales 19 West Coast We had a lower market share on the 20 records They have been destroyed true 21 A. I don't know 20 West Coast 21 BY MR JONES 22 Q. You've previously testified that Kerr's asbestos 23 sales records have been destroyed true 22 A. I was told -- I was told I don't have personal 25 knowledge that they were 22 Q. Okay And you don't have any documents saying 23 that 24 A. Absolutely not 25 Q. And you're -- you don't have any meeting minutes Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 talking about that right Page 130 1 2 A. No no 2 3 Q. And your job was production 100 percent of the 3 4 time at Kerr true 4 5 A. True 5 6 Q. It was never in sales true 6 7 A. True 7 8 Q. It was never in marketing true 8 9 A. True 9 10 MR JONES Pass the witness 10 11 MR REYEN No further questions That's it 11 12 then 12 13 MR JONES All right Thank you 13 14 MR TAURAS Under California 14 15 THE REPORTER What's that 15 16 MR TAURAS Under California law do we read and | 16 17 reserve or 17 18 MR JONES Just do it to the Code If you want | 18 19 to you can You don't have to 19 222222 MR TAURAS Yeah we'll reserve We'll read it | 20 21 MR JONES We'll just do it whatever the law 21 222222 says All right Signing off 22 23 THE VIDEOGRAPHER Off the record Counsels 23 24 MR REYEN Yeah thank you 24 25 THE VIDEOGRAPHER Okay The time is 4:11 p.m. 25 Page 131 1 This is the end of the videotaped deposition of Lawrence 1 2 Girling Volume I dated January 29 2021. We are off 2 3 the record 3 4 Whereupon at the hour of 1:11 p.m. the 4 5 deposition was adjourned 5 6 6 7 7 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 2222 22 2222 23 2222 24 2222 25 130..133 Page 132 DECLARATION UNDER PENALTY OF PERJURY I LAWRENCE J. GIRLING do hereby certify under penalty of perjury that I have read the foregoing transcript of my deposition taken on January 29 2021 that I have made such corrections as appear noted on the Deposition Errata Page attached hereto signed by me that my testimony as contained herein as corrected is true and correct Dated this 20 at day of ' , California LAWRENCE J. GIRLING DEPOSITION ERRATA SHEET Page Line No. Change Reason for Change Page No. Line No. Change Reason for Change Page No. Line No. Change Reason for Change Page No. Line No. Change Reason for Change Page No. Line No. Change Reason for Change Page No. Line No. Change Reason for Change Page No. Line No. Change Reason for Change Page 133 LAWRENCE J. GIRLING DATED Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 1 STATE OF CALIFORNIA ) ) 2 COUNTY OF LOS ANGELES ) 3 Page 134 4 I Giselle Girard a Certified Shorthand 5 Reporter do herby certify 6 That prior to being examined the witness in 7 the foregoing proceedings was by me duly sworn to 8 testify to the truth the whole truth and nothing but 9 the truth 10 That said proceedings were taken before me 11 at the time therein set forth and were taken down by me 12 in shorthand and thereafter transcribed into typewriting 13 under my direction and supervision 14 I further certify that I am neither counsel 15 for nor related to any party to said proceedings nor 16 in any way interested in the outcome thereof 17 In witness whereof I have hereunto 18 subscribed my name 19 Dated February 10 2021 20 21 22 23 24 Giselle Girard CSR No. 12901 25 1 Asbestos Reporters a GPS Partner 7119 West Sunset Boulevard Page 135 February 10 2021 2 Suite 440 Los Angeles California 90046 34 34 LAWRENCE J. GIRLING O KEITH P. REYEN ESQ 5 OIUM REYEN & PRYOR 220 Montgomery Street 60 Suite 910 San Francisco California 94104 7 8 Re David Springer et al Vs. Asbestos Companies et al 9 Date of Deposition January 29 2021 10 Dear Mr. Girling 11 The original transcript of your deposition taken 12 in the referenced matter is available at this office for your review If it is more convenient to 13 read a copy of the transcript and waive signature of the original transcript please notify our office by letter 14 sent certified or registered mail of any changes made with copies sent to all counsel 15 In the event you have not read corrected and signed your deposition within thirty 30 days of the 16 receipt of this letter it may be used with the full force and effect as though it had been read corrected 17 and signed If you wish to arrange an appointment to review 18 the original transcript please contact this office at 888 779-9974 19 20 Sincerely 21 22 Cc All counsel Asbestos Reporters Production Department 23 The deponent 24 Original Original transcript 25 Asbestos Reporters a GPS Partner 888-779-9974 134..135 Lawrence Girling January 29 2021 Exhibits Ex 1 8 3,12 6,8 39 EX 2 8 83:25 2,6,8 EX 3 8:10 7,9 100 19,20 119 $ 54 2 60:20 C 87:22 -50 103 -51 37:18 -52 37:18 1 1 2,3,9,12 6,8 39 43:14 100 5,6 24:22 103 130 10:19 22,24 10:38 38:24 11 82:15 11:50 90 12 32:15 88 127 12:06 90 12:20 100 12:30 12,14 12th 13:21 14 13 113 15 74:22 75:19 100 150 75:16 16 113 161 13,18,19 18 107 19 84:16 102 112 119 1910 86:12 1960s 30:15 1967 12 13:12 14,17 15 16:16 17:18 18:10 24 26 35:14 1969 27:23 1970 87:23 1970s 30:15 1971 87:18 1972 12,16,21 87:10 88 91:23 96:15 1973 6,15,19 1974 48:11 1976 6,10,24 36:14 2,14 41 43:17 44 20 46 1,23 61:24 4,8 15,19 3,9,11 18 105 110 111 1977 33 41:15 111 1978 102 22,24 112 1980 33:15 Index 1..3 1980s 33:22 116 117 1990 2,4 98 99 1,24 110 111 112 118 119 128 1991 2,4 99 100 112 1996 15:11 1:38 39 2 2 83:25 1,2,6,8 20 18:19 43 83 pound 30:21 2003 24 33:23 2004 74:22 2021 1,19 210 74:23 24 3,4 24th 82 26 3,5 29 1,19 86:11 2:50 90 3 3 7,9 18,19,20 119 30 79 35 27 pound 30:21 3:06 90:10 3:20 100 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 3:30 100 40 19 4:11 130 5 50 18:16 19 51:24 103 50s 21,23 50th 102 52 36 99:17 17,20 104 6,16,17 108 4,10 6 82 87:21 60s 18 24:18 early 28 63 113 67 14:15 24:22 27:13 68 17:22 7 7 84:16 87:18 91:23 70s 16 17 18 24:18 28 33:10 43:13 83:17 118 76 41:25 7th 84:12 80 116 80s 1,23 21:17 115 116 117 118 121 87 115 9 82:11 90 117 90/91 113 90s 15:14 16:23 117 91 98 100 110 117 128 96 81:23 97 103 104 9:32 9:19 A a.m. 9:19 22,24 90 abide 89:25 ability 59:10 70 73:11 abreast 12,15 Absolutely 129 acceptance 4,6 accepted 49 accident 67 accordance 87:21 account 10,18 54 accounting 109 Index 30..American accurate 81 Act 87:23 action 47:13 Actual 57 ADA 1,3,4 77:20 107 add 103 Administration 86:12 admissible 48 94:20 affairs 108 affect 23 105 affected 42:11 affirmed 10 affixed 93 afternoon 10:17 agency 82:16 agent 93:12 agree 9:14 34:11 47:13 52 55:24 60:24 66:16 76 79:10 96:10 107 agreed 103 agreement 104 ahead 16:21 48:12 62 70:23 86 91:15 106 129 air 50 51 airborne 45 50 62:11 93:16 alternative 52:18 ambient 50 ambiguous 16:20 American 7,25 38:13 39 3,13 41 44 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 49:15 57:25 67:16 3,9 105 111 amount 115 analyzing 26:23 Angeles 126 answering 37:14 anymore 11:20 Apologize 113 appearance 10 appears 36:22 applied 88:17 13,14 applies 40:22 apply 16:14 89 96 appraisals 118 apprised 55:13 approached 122 approval 52 April 2,14 6,14 area 22:24 28:10 68 argumentative 53:20 61 106 article 8,24 2,15 38:12 16,24 44 45 3,5 2,4,18,20,25 15,22 57:24 58:10 1,7,9 19,25 62:21 23,24 11,15,25 73 106 107 111 asbestos 22,24 6,10 16,20 13 13,16,24 2,9,17,18,19,20,21 1,3,6,11,12 4,7,10 15,23 7,11,14,21,23 24,25 35:22 1,2 37:23 2,13,19 5,25 46:10 6,13,16,19 3,9,15 23 8,20 6,19 3,6 16,24 56 13,14,18 10,11,21 61 9,10 22 63:22 19,22,24 9,15,20 20,25 68 4,6 16,20 71:24 72:10 21 1,5,12,18,19,22 2,5,7,25 22,24 78 8,16,22 79 80:16 82:17 17,21,22 85 86:14 19,20,23 1,20,25 88 18,23 14,15,23 91:25 92:13 9,11,17,23 95 10,11,16 12,18,23 1,6,13,21 99 101 17,25 102 103 18,19,22 108 17,23 11,19,22 24 3,20 113 114 2,6,9 116 117 8,13 118 4,18 5,10 122 123 22 12,13 9,12,15 19,22 128 containing 80:11 83 asbestosis 45 64:12 92 asks 81 Association 7,25 38:13 39 3,14 41 44 49:16 67:16 3,9 105 111 assume 76:14 assumed 110 Assumes 95:21 96 assuming 81 assurance 42 2,18 Index amount..basically 7,14 11,14 83:10 85:10 107 attached 37 84 99:10 100 119 attend 77 attended 21:14 113 attending 35 attorney 65:13 95:23 authenticate 39:17 authenticity 4,6 authorization 114 Avoid 95:10 aware 14:15 21,23 67:24 77 78 116 B back 14:23 23 24 35:20 38:25 43 66:11 79:10 90 98 9,13 112 113 background 18 bad 8,11,17 45:25 63:24 64:22 bag 4,6 8,16 bagged 124 bags 30:13 73 123 2,7,8 Baker 126 base 72:20 based 26:23 46:22 48:10 56:22 basically 11:24 83 116 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 basis 92:14 121 122 Bates 37:18 beginning 46:25 47 49:24 81:11 behalf 10,18 81:14 Benveniste 9:24 bias 8,9 big 19,22,25 120 128 bigger 37:11 75 103 binder 44:14 93:13 binders 44:11 94:15 bit 13 57:18 Blackledge 80:14 board 112 11,24 Bob 13,15,16 16,19 20 19,22,24 46:14 Bodily 95:12 bonding 93:12 books 57 Boom 36:20 booth 77 bottom 37 38:17 39:12 1,12 41 15,23 90:19 91:24 92:19 102 bought 29:21 2,10,14 60 76:18 110 119 Bowl 128 box 23 4,6,7,8,16,23 13,16,24 32 4,5 119 boxed 103 124 boxes 30:21 31 50:23 73 103 123 124 brain 19:16 brand 124 break 4,13 Breathing 95:11 Brighton 19,23 bring 43:16 67 brings 2,18 1,7 broad 97:14 brochures 97:12 brought 46 57:24 73 buck 21 3,24 bucks 54 Buffalo 74 bulk 125 bunch 37:16 business 12:20 13 20,24 6,11 34:12 46:20 58 115 buy 31:10 60 77:11 121 buying 84:21 104 C cabinet 117 118 cabinets 117 118 14,16,20,23 119 calculated 48 California 9:25 74:21 11,19 15,19,22 9,11,15,19,20 126 10,13 14,16 Index basis..catalogs call 18 30:24 68:10 79 109 called 9,11 15 17:10 38:11 42 49:16 calling 25:13 122 calls 25:20 39 43:18 56 61 1,2,11 64 65 72 17,20 88 94 19,21 105 106 107 120 122 6,15 124 125 128 cancer 45 46 4,21 59:10 61:20 62:24 3,5 7,13 106 cancers 92 candidates 106 cans 20,21 car 67 Carborundum 104 103 care 19,20 91 career 20:12 34:25 carelessly 50 8,9,12 carloads 125 carry 23:13 114 case 15:14 19:16 36 74:21 75 14,16 113 cast 56 casting 10,13 15,20 4,5 57 58:14 84:18 19,20 castings 89:12 catalogs 54:17 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 catch 19:15 causally 45 92 caused 68:25 causing 4,21 caution 3,6,7 9,10 cautioned 49 cavity 14 Celotex 29:24 21,23 cement 93:25 95 centers 125 chair 19 chance 39 40:25 51 12,15 change 23 46:11 54:16 11,13,14 60:22 61:12 62 106 114 changing 108 Chapter 86:11 charge 15 16:16 17 2,14,15 52:11 53 60:17 61 85 116 charging 54 60:20 chemical 9,11 27:24 68:13 69:22 70:13 94:14 chemicals 5,6,9,13 14 7,11,17,20,22,23 25 3,8,11,15,17 70 chemist 29:12 Chicago 77 chiefly 44:13 choose 9:11 circulate 103 circumstances 91:14 cite 45:14 classify 69:16 clerk 20 client 66 close 28:21 closer 41:15 125 Coast 121 122 125 3,18,23 127 7 10,11,14 16,19 20 coating 93:12 Code 45:15 130 Collectively 100 color 23 column 49:23 86:10 90:18 91:23 92 93 comeback 66 comments 88 129 committee 22:22 59:12 common 66:18 communicate 22 23:12 15,21 5,9,18 27:19 54:23 55 14,17 83:14 85 114 communicated 22:17 24:14 25:22 55 communication 56 55:25 communications 114 companies 9:22 22,24 22,24 68 74 122 126 127 company 16 17,20 20:18 27:20 33 35:13 Index catch..corner 2,8 70:21 83:15 85 98 106 6,16 comparison 60:11 compel 98:18 104 compete 126 competing 126 competitors 77:15 120 124 127 complete 49:23 comply 104 composition 94:15 compound 59:17 61 106 concentrations 93:16 concerned 62:19 conditions 49 conducted 113 confirm 39 99:25 confusion 76 conjunction 122 consequences 92:12 constituents 94:15 consumer 124 container 30 containers 30:17 93:10 124 control 13:15 14:22 17 10 20 25 27:13 42 controlled 49 controversial 39:14 copy 74:20 corner 36:22 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 corporate 47 112 11,15 115 corporation 2,5 1,9 11 11,18 20:25 21:25 23 24:13 25 2,14 22,25 20,23 42:11 43:25 44:25 4,8,13 47 50:22 51:25 55:16 57 58:13 68:16 69:14 15,19,20,24 84:16 98 100 109 115 Corporation's 97 correct 3,4,7,8,11,24 12 1,4 20:23 23:11 21 24:12 6,21 27 29 30 5,9,14,17 9,12,18,22 11,24 41 43:15 16,22 45 11,23 46:21 47 48:22 11,14 51:12 6,7,9 16,21,25 53 10,18,24 56:21 2,4,7,16,22 60 8 3,7,11,14,22 68:15 13,25 9,11,14 74:17 75 11,20,23 8,19 78:17 79:16 80:23 82:22 24 7,11 15,25 85:12 86:16 4,15 88 92:18 22 8,14 13,17 10,17,22 98 101 12,16 105 109 110 14,21 116 119 120 11,15 16,20,25 123 124 125 126 128 correctly 44:17 45:10 50:10 82:21 83 86:15 88 6,17,21 93:20 95:13 103 113 cost 9,13 7,11,14 16,25 1,2,15 21,22 costs 54 105 Council 19,22 2,3 counsel 8,10 98 Counsel's 10 Counsels 130 counted 102 County 74:22 couple 33:15 117 121 court 5,25 10 40 17,18 129 covered 93:24 95 Creating 95:11 Cristobalite 51 122 criteria 56:17 examination 85:20 86 90:22 91 crucible 29:14 1,2 crucibles 15,16 44:15 20 50 58:14 customer 30 121 customers 1,13 73 22 84:24 110 cut 32:10 49 8,21,23 3,8,14 cutting 51 D danger 50 dangerous 68:17 8,15 18,23 Darby 125 Index corporate..dental date 9:19 28:18 81:22 84:11 dated 102 dates 15:12 27:25 28:21 David 9:21 127 day 68:17 99 days 79 dealers 76 122 dealing 97:12 101 102 115 116 dealt 16:23 73:25 74 debris 93 decades 35:11 December 87:18 decertification 58:19 decertified 58:17 decide 61:12 62 decided 72:25 11:19 70:15 decision 22:16 34:18 9,12,19 8,12,21 5,8 23,25 110 5,6,8,11,18 decisions 20:25 3,5,25 1,11 3,11,12,15 1,2 49 60:23 default 75:11 Defective 112 defense 7 define 17 delivered 27:21 79 demonstrating 45:21 dental 10,11,16,19,21 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 8,11,22 19 7,25 20,22 3,13 39 3,13 41 44 49:16 50 1,3 16,24 71 18,21 1,13 74 3,9 11 84:17 24,2245,25 96:23 98:20 105 111 13,23 6,10,11,13 17,18 dentist 2,8 29 49 50:18 62:12 7,19,22 dentistry 18 1,3,14 37:23 3,14 49:17 15,23 dentists 18:25 50:16 12,17 64:24 67:23 8,11,18,21 1,13 76:22 84:17 96:22 dentists 6,14 department 13:17 14:21 15 18,22 17:10 19 19 21:22 23 1,2,3,4,5 26:11 27:22 52:17 56:14 57 61 86:12 17,19 128 departments 13:15 14:19 20 19:14 8,13,15,19 1,23 24 25 26:15 16 52 55:25 14,16 20,21 10,15 deposition 20,23 28 33 43 72 20,24 10,14 13,15,20 12,20 82 85:23 100 101 110 113 119 129 depositions 17,20 Derby 128 description 42:16 desirable 92:16 desks 116 destroy 115 destroyed 18,21 3,7,14,15,17,20,23 115 117 20,23 128 determination 92 determine 26:18 80 82:13 83 Detroit 19,20,21,23 4,7,10 116 developers 78:13 developing 56:22 development 13:16 15 25 45 52:23 53 54:12 6,14 11,14 19,22 57 59:14 104 105 developments 42:11 Devices 38 difference 51 differences 123 differently 82:18 dipped 93:23 direction 51:20 directions 51 directly 55:18 director 33:16 35 42:23 112 113 disagreed 47:15 discontinue 5,13 Index dentist..documents discovery 48 discussed 48:25 23,24 113 discusses 44 discussing 104 18,21 108 diseases 46 62:24 displayed 80:13 disposal 93:15 dispute 92 disputed 91:24 distinction 98:25 distributed 125 distribution 127 8,11,14 distributors 6,7,12 20,24 10,12,17,25 79 division 26 27:24 68:14 divisions 16,18,19 16,17 101 document 36 39:17 4,8,13 8,13 8,21 8,13 81:10 14,16 86 87 90:23 2,22 92:25 96:12 101 17,20 108 115 13,18,21,25 4,21 117 documented 45 documents 6,7 59:16 97 98 99 1,18 22,23 4,6,12 102 103 2,14,18,21 1,5,9,16 106 18,21,25 4,12,17 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 10,18,23 114 19,22 116 117 13,16 118 119 129 dressings 11,14,23 drop 49 drums 30:22 duly 10 duration 92 Dust 86:14 95:11 E earlier 101 early 121 east 3,5,23 Eaton 19:14 economical 53:23 54 Educated 109 effect 63 effort 73:21 efforts 16,24 102 107 election 9:12 electron 94:10 eligible 49 else's 124 emergency 87:18 88 employ 18:25 employed 19,24 83:14 employee 16 32 employees 24:15 25:19 16,19 7,11 71 84:22 87:13 92:20 end 28:14 55:10 102 endodontic 12:24 14 entire 44:17 91:16 107 entirety 48 entity 17:18 98:12 envelope 120 envelopes 120 escapes 35 essential 92:13 establish 94:13 established 22,24 4,12 establishing 88:22 et al 21,22 Everard 52:14 56 everybody's 118 evidence 11:13 22:20 45:15 48:10 92:15 96 129 exact 28:18 41:16 examination 10:14 85:22 25 121 124 examined 10 examining 85:22 Excellent 37:12 excess 93:17 executive 43:17 46 47 48:19 1,7 73 114 116 executives 35 41:18 43:25 5,18 3,5,19 3,5,19 23 49:15 55:12 62 73 Index dressings..factors 105 109 exhibit 36:16 3,9,12 6,8 39 21,25 84 2,6,8 90:15 7,9 100 19,20 119 existed 111 exit 46:20 expect 16 120 expensive 53:16 60:22 experience 106 expert 64 90:24 91:11 expertise 68 experts 6,7,11 explain 128 expose 70:21 exposed 63:14 65 89:14 exposure 49:19 50 14,19 19,25 88:23 89:11 91:24 5,13,14 93:17 extent 16 48 eyeballs 94:12 eyes 7,10 95 124 17 F facilities 13:19 facility 32:19 fact 15 73:21 97 107 114 127 factor 11,14 factories 14:13 factors 121 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 factory 31:15 71 facts 11:12 22:20 95:21 96 fair 16:18 7,9,10 28:11 19,22 41:17 44:24 60:20 75:13 fall 10,11 falls 67 familiar 20 29:15 35:24 38 69:14 80 9,11 91:12 94:14 99:20 family 113 fault 6,14 favor 102 federal 12,15,16 80 3,4,6,9 16,19 2,10 12 84 85 87:20 1,6 16,19 91:22 11,14 105 feed 129 feet 103 fewer 124 fiber 89:10 121 fibers 50 14,22 20,25 88:23 92:13 10,11,17 95:10 fibrosis 45 64:12 figure 108 file 18,20 1,9,11 14,16,20,23 119 filed 104 files 14 97 13,14 filling 12:23 14 finance 14:21 18 20 25 54:13 105 114 financial 34 find 34:13 3,18 2,22 2,15,25 55:10 18,22 69:22 83:14 94:22 97 13,16 104 110 111 117 118 finding 52 53 106 119 finds 54:21 finish 79:23 finishes 40:25 Fire 68:24 Flask 103 104 flasks 29:13 focus 58 folders 118 follow 31:25 forecast 27 forecasts 26:23 27 22,24 forefront 71:13 foreseeable 93:14 forgot 96 form 124 formulation 3,6 formulations 122 forwarded 2,3 found 60:19 71:22 77:25 78 97:23 99 100 23,25 9,14 10,12 119 foundation 20:20 21 22:19 39 53:21 56 Index factory..Girling 61 63 70:18 72 79:17 88 94 106 107 111 120 122 22 6,15 124 128 Francisco 74:22 frankly 64:20 69:20 75:12 118 Frax 121 freight 122 Friday 9 front 57:20 107 full 10:20 81 92 fully 37:13 functional 20 functions 114 future 15,19 G gather 32:15 gathered 101 gave 80:16 97:25 114 general 50 60 generally 11:18 32:20 99:20 109 generic 14,17 gentleman 5,24 geographic 126 geography 21,25 129 Girard 10 Girling 9:20 6,16,21 16:11 5,19 2,9 39 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 40:10 41 45:24 18,25 13,14,20 84 85:15 86 90:12 91:20 94:25 96:10 2,17 100 8,11,17 23,24 126 Giselle 10 14:23 83:21 99:11 give 36 63:22 100 goal 22,23 54 73:15 gold 84:18 good 8 14,18 92:16 government 80 GPS 9:25 grab 31:23 grants 104 grave 92:12 grocery 67 grounds 123 group 20:24 21:21 43:23 24 11,15 5,6 116 guess 18:21 19:21 105 109 110 guessing 24:19 guidelines 86:18 87 8,20,25 115 guy 109 guys 6,10 19,20 gypsums 14:11 H hall 106 handle 32:20 54:12 71 handled 15:24 2,5 71 handling 93:14 handwritten 80:21 happen 66 happened 56 57:17 66 103 110 117 harassing 91:17 Harm 95:12 hazard 63:25 1,7 70:25 107 hazardous 51:21 62:11 8,12 70:21 71 hazards 2,14 37:22 44 49:16 67:25 68:24 70 76:25 77:21 107 108 head 17:10 7,13 43 1,17 59 heads 15,18 21:22 23 24 health 16:24 71:25 72:12 12,13 87:23 hear 95:22 96 heard 14,16,24 2,4 8 127 hearing 80 hearsay 63:11 91 held 9:23 Henry 74 17,18 hereto 37 84 99:10 Hey 38:20 high 91:25 124 higher 125 Index Giselle..include Highlights 84 hired 12:13 56:14 hiring 56:17 Hold 106 home 10:24 126 hope 110 House 128 HR 8,22,23 huge 22 human 5,7,23 5,17 25 hundred 24:24 hundred 30:22 hurt 13,19 63 64:24 66 12,17 69:11 73:23 96:23 112 idea 18:21 22 25:17 43:19 53 57:11 9,16 103 120 identical 124 identification 37 84 99:10 identify 40 identifying 107 important 43:24 44:24 51 impression 12:23 13 4,6 69:17 improper 85:19 87 90:22 include 106 112 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 19,23 included 30 95:16 119 includes 8 46 4,20 59 individual 30:24 32 61:17 84:23 103 120 individual 30:25 individually 30:24 industry 18 inform 73:22 information 27:20 34 51:18 61:14 22,24 22,24 106 121 Informative 43:23 informed 77:20 106 informing 46 2,19 ingredient 46 4,21 59 61:20 initiated 103 inlay 2,3 inspection 86:18 instruct 13,16,17 instructed 116 instructions 51:14 insult 126 intensity 91:25 interact 77:10 International 14,21,23 interrogatories 39:15 interrupting 85:25 interviewed 12:15 17:16 introduce 91 inventory 78 investment 12:24 13 14,15 28:17 13,18 13,18 20 7,9,10,14,16,18,25 31:22 32 10,11,21 71:24 103 17,25 120 18,25 5,12 17,18 124 125 investments 14:11 121 123 124 invoices 128 110 111 involve 59:13 involved 11:21 16 52 8,15,17 11,15 55 59:16 101 107 involvement 9,22 Issue 84:10 issues 54:12 8,23 17 48:18 items 124 J Jack 52:14 5,9 January 1,19 88 Jay 10:21 Jersey 126 jewelry 13,15 job 8,9 26:18 27:10 33:13 10,16,25 43:13 61:11 68:13 69:10 74:10 79:22 83 84:13 85 88:16 105 126 130 Index included..Keith joined 16 24:22 33 35:12 JONES 4,14 10,12,15 11:17 12 14:23 15 9,13,21 17 20:21 6,16,18 22 23 25:14 1,7 7,11,13 36:20 1,5,7,17,21 38:20 2,13,18,21,25 5,16,21 41 43:21 44:12 9,12,17,22 48:16 54 56:10 57:13 5,22 61 6,17,23 7,10 3,5 1,5 9,12 70:23 71 11,18 14,17 75 80 81 83:24 84 8,13,17,21 5,7 87 88:14 5,11 4,8,18 92 5,11,18 22 19,23 2,5 98:13 16,22 1,7,11,13 100 8,16 102 104 106 24 11,14 111 120 121 1,9,21 1,5,9,15 124 3,10 128 129 14,21 10,13,18,21 journal 35:25 38:12 39 2,13 41 44 111 journals 57 judge 104 July 74:22 June 12,16 91:23 K keeping 16,18 Keith 40:18 66 94:25 121 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Ken 17 38:10 20,22 42 79:10 9,17 84:13 3,5 105 Kentucky 5,23,24 2,4,7,24 13,22,23 Kerr 2,5,7,10,19 12 4,7,9,10,11,14,15,16,19 4,10,12,19 12,16 8,11,18 2,16,18,19 2,16,18,19 20,23,25 5,25 7,18 18,25 2,9 6,13 17 6,18 2,14 27:18 28:23 8,17,19,21 30 14 11,18,21,24 3,6 7,10,13,19,23 22,25 19,22 6,10 36 37:18 41:18 42:11 5,25 6,19,24,25 4,6,8,9 13 8,15 3,5,1 12,15,22 5,25 54:21 55:16 57 13,23 61:19 7,22 1,9 66 8,15,19 24 15,20,23,25 68 16,19,25 2,7,10,14 1,4,12,15 11,12,17 20,22,23 4,6,12,22 4,8,9,11,18,21,25 74 11 19,23 9,12,15 21,24 3,16,20,24 78 7 79 80 14,19,20 24 1,13 13,16,21 13,16,21 2,10 86:17 9,11,13 88:15 91:12 92:23 95:15 10,15,18 1,5,9,18 98 100 101 102 1,22 11,16 106 109 13,25 111 19,22 112 2,25 4,8,11,13 116 118 3,14,22 120 14 2,6,17,20 122 123 124 125 9,12,15,16,19 128 129 130 Kerr's 6,10 16,25 29 30 31:15 14,18 51:14 57:25 59 64:24 69:11 23,25 74 79:14 83:13 89:23 5,16,24 102 105 18,21 108 111 117 119 121 124 127 128 key 49:10 kind 15:21 46:25 65:20 74 92 93 99:14 106 129 kit 2,3,21 32 kits 32:25 knew 16 64:11 66:11 67:12 68:19 69 97 109 110 knowledge 66:18 72:20 81:17 2,11 127 knowledgeable 72 Kovac 17 38:10 41:10 20,22 1,19 43:16 46 15 1,17 51:19 52:11 73 79:10 83:17 85 97:25 98 12,14 Kovac's 42:10 5,9 84:13 85 L lab 50:18 62:12 89:12 label 82:17 93:11 labeling 80:10 83 93 labels 4,6,7 Index Ken..legal Labor 11,12 laboratories 50 88:24 laboratory 13:13 49 50 labs 51:11 122 lacking 122 lacks 20:20 21 22:19 39 53:20 56 61 63 70:17 72 79:17 88 94 98:11 106 107 111 120 122 123 15 124 128 large 50 75 larger 36:23 Larry 11:14 36:21 37:13 40:24 48:12 74:24 75 79:23 80:20 18,22 late 21:17 28 30:15 33:10 43:13 law 16,21 Lawrence 9:20 6,21 laws 80 lawsuit 66:14 5,10,13 lawsuits 11,15,17,18 67 lawyer 36 lawyers 90:13 97 101 128 lay 13,20 lead 48 learned 16:17 77:21 left 119 hand 37 86:10 legal 16 45:13 98 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 lengths 103 letter 7,9,11 22,23 letters 99:15 letting 65:19 level 92 113 liable 66 libraries 70:10 library 70:12 lies 50 limited 121 limits 88:23 89:11 93:18 liner 46:10 52:19 58:14 103 104 liners 14 1,2 lines 37:16 lining 15,19 lists 20,23 108 litigation 97 live 22,23 Lives 92:20 locate 110 128 located 100 location 6 log 57 103 logic 72 long 17:23 19 91:25 115 118 longer 49 looked 39 60:14 69:22 117 loop 55 Los 126 lose 17,20 losing 121 129 lost 36:25 111 123 lot 15:21 23 27 49 52 55:24 106 Louisiana 15:14 80:16 lousy 56 lower 125 129 lung 45 62:24 64:13 M machines 50 made 12:21 13 3,11 20:24 4,5 22:11 23 11 18,21 22,23 13,15,19 1,2 49 59:11 69:17 71:23 73:21 86 89:12 95:19 119 123 main 58 122 maintained 52:12 major 70 make 9:11 12:20 14 21:25 4,19 34:18 36:23 11,13 39:23 22,24 46 8,10,11 48 53:14 54 60:23 61 67:23 69:10 70:20 71:24 75 85:10 86 89:10 94 103 108 110 5,11,16 122 129 makes 31:19 47:21 72 making 10:12 110 management 14,18,21 Index lengths..material 24 6,24 4,10,21,24 6,17,22 35 46:18 59:12 110 manager 27:12 7,11,23 5,11,13 13,14 14,22 managerial 113 managers 23:14 27:22 manner 49:10 manufactured 86:23 13 68 manufacturer 2,4,20 90 manufacturers 2 94 122 74 87 manufacturing 32:19 16,19,21 70 108 109 110 116 126 mark 37 61:13 83:24 99 marked 37 72:23 83:21 2,5 99 market 103 104 121 129 marketed 119 9,14 marketing 14:22 20:10 25 24,25 27 43 13,14,15,19 4,8 103 104 12,13 17,18,22,24 109 114 116 119 11,14 130 marketing's 104 material 31 15,19 52:22 9,19 70:22 93:13 103 16,19,22 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 105 121 124 materials 23,24 13 4,7 26:19 27:18 28 11,22 33:14 38 43:13 9,14 54:21 60:14 69:17 71:24 93 106 matter 9:21 meaning 12:19 31:21 32:10 58:20 means 47 20,22 112 114 meant 16 63:22 meet 27 meeting 21:21 22:13 23:14 35 38 10,17 18 42:24 6,17,20,22 4,18 47 19,24 49:11 51:17 13,22 57:24 1,8,11 62:18 4,8 110 112 11,19,24 129 meetings 21:10 7,10 22,23,25 3,5 35 55:20 109 113 memo 24 4,9,13,16 17,25 103 21,22 111 memoranda 57:15 59:15 105 memorize 99:24 memory 116 19 35 115 memos 16,24 1,2 11,15 102 104 13,16 107 mentions 103 merged 116 merger 8,9,19 mergers 115 mesothelioma 62:25 mesotheliomas 45 64:13 met 76:18 method 56:15 Michigan 19,22 5,7 10 116 122 125 25 3,4,5,8 15,23 microscope 94:10 mid 15:14 33:22 121 middle 86:10 90:18 91:23 92 93 Midwest 126 Milwaukee 13:22 14:10 mind 16:11 63 96 minute 11:22 minutes 10,13 90 100 112 12,19 24 129 misleading 11:13 missing 111 misstates 11:12 22:20 63:20 70:17 Mix 124 4,22 126 12,13 Mix's 124 mixtures 93 modified 93:12 moment 82:25 money 53:14 54 Index materials..normal monitor 42:10 83:10 84:13 88:16 99:16 105 month 21:15 79 monthly 22:25 35 moot 40 17,18 morning 10:17 motion 9:11 59:12 104 motions 8 motive 77:12 mouth 6,8,12,18 106 15 107 114 128 move 14,18 9,21 123 moved 71 98:17 116 20 mute 19:12 N named 6,24 necessarily 17,20 94:20 114 needed 26:19 18,19 70:14 122 Nelson 17,24 20:19 4,7 47 Nelson's 18 Nicolet 29:24 21,22 nineteen 13:10 nonasbestos 46:12 55:14 60:21 62 78 79 101 102 107 5,19 normal 115 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 Note 95:25 notes 14,15 23:25 24 57 15,20 notice 87:23 notification 82:18 notifications 80 notified 82:16 number 82 numbers 37:18 numerous 122 -- object 16:19 40 41 48 87 90:21 17,24 123 128 objecting 95:21 objection 7,10 11:12 12 6,14 20:20 21 2,19 23:18 13,20 26 2,15 9,22,23 24 7,22 44 12,14 18 53:20 56 57:10 59:17 11,20 65 68 72:16 78:24 17,24 85 86 91:19 1,9 18,19,25 96 102 104 105 106 107 111 120 129 objections 16 40:15 81 91:15 92 125 Occupational 11,13 87:22 occur 50 October 102 112 offered 121 office 88:25 116 117 118 126 offices 14:12 116 operations 5,11,13 43:14 opinion 13,20 64 opt 9:10 order 25 104 ordering 11 Ormco 116 OSHA 8,13,16 9,10 12,14 22,23 5,8,19 25 15,24 91:13 96:11 OSHA'S 18,25 88:13 overbroad 1,13 22 20 26 68 overtime 23 owned 33:25 P p.m. 39 6,8,10 11,12,15 130 package 31:19 6,16,21 3,4,5 120 packaged 31:18 32:16 97:23 packages 31 84:23 103 packaging 72:22 124 packets 16,24,25 31:22 32 pages 36 74:23 99:18 100 1,2,13 104 25 105 6,16,17 Index Note..people 108 4,10 pails 30:21 paragraph 45 90:19 9,19 93:18 103 pardon 64 80:14 101 123 124 parent 98 parking 7,8 part 13 12,13 29:10 43:20 44:16 53 71:15 86:12 parties 4,6,14 Partner 9:25 Pass 130 past 42 126 128 paste 13 1,2 58 9,12 17 pat 78:14 126 Patterson 74 12,16 pausing 65:20 paying 59:24 PDF 82 pending 74:16 pension 34:22 people 17 22:14 23:13 10,17,22 26 9,20 10,13,17 52:23 4,12 13,15,18 61:15 62:19 63 66 67:20 3,10 71 76:18 77:10 87 96:23 97:15 101 109 114 115 116 9,16 122 125 126 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 percent 5,6,16,19 130 performance 118 period 11:19 55:24 periodontal 11,14,22 1,2 9,12,17 peritoneal 45 64:13 permanent 87:24 person 72 81:17 83:17 105 110 114 118 person's 88:10 personal 127 personally 23:23 66:11 95 97:16 personnel 50 118 persons 63 phase 114 phased 73:18 10,15,16 bologna 129 picture 57:21 piece 50:19 place 81:21 106 places 14 plaintiffs 37 84 99 plan 27 planner 9,18 3,7,11 68:13 planning 17,24 61 103 plant 21,22 2,9 16:24 113 plants 13:25 14:12 89 plastic 93:24 95 123 124 pleural 45 64:13 PMK 91:11 point 17:14 1,7 20:12 23 8,10 26 33:10 25 34:25 52:14 58:16 13,16,24 88:15 89 110 111 points 18,21 policies 24:14 9,18,21 policy 8,11 5,11 14,18,21 1,4,22 117 popped 36:13 position 85 positive 43 possibility 67:19 Possibly 67:18 potential 49:19 62:10 13,21 21,24 potentially 11,12 powder 7,9,11,15,16 4,8 powders 119 120 PPL 5,10,15,16 10,19,22,23 PPL's 108 precut 31 32:14 preference 124 prepackaged 31:23 prescribed 93:18 presence 88:10 121 Index percent..process present 8 43:22 presentation 43:20 presently 34:10 president 12:16 12,14 16,17,25 17,23 21:22 23 27:14 19,21 35 22,25 2,5 13,16 2,9,21 51:25 55:16 58:25 2,8 73:11 83 114 presidents 59 pretty 128 previous 15:22 previously 43 74:11 110 127 price 20,23 10,18 54:16 60:22 105 108 prices 12,15 pricing 4,12 primarily 48:25 primary 21 prints 80 prior 75 problem 12,17 51:15 21 1,6,9,19,22 problems 65:25 Probst 20,22 108 procedure 29:10 procedures 24:14 25:18 22 process 11 29:13 46:15 47:18 53 7,8 57:15 59:16 78:13 82:19 107 110 123 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 processing 93:15 procurement 121 produce 26:20 104 produced 26:19 36 104 113 product 13 27 29 17,19 30 44 5,10 11,12 3,11,20 49:20 50:12 52:18 11,13,19 5,8 58:16 11,13,15 1,3,20 62:19 9,13 4,9 12,16 73:19 101 102 11,13 14 9,11 107 108 6,9,11,13,14,20 20,22,25 120 123 4,16,19 production 14:21 4,9 25 8,12,13,17 27:13 15 33:14 57:17 9,15 12,20 101 127 130 products 6,7,10,20 7,11,14,15,23 23 18,19 17,24,25 2,9,18 11,21 45 5,18 56:24 57 1,6 13 59:10 13,17 73:25 8,12 75:23 1,2,5,10 13,15,19 11,17,22 80:11 4,13 93 95:15 96:12 97:13 101 105 17,23 2,6,9 117 13,14,17 10,14 22 125 128 129 18 program 11,13 project 14,16,18 projects 118 promoted 27:23 28 proper 2,3,4 87 94:21 129 properly 49:20 properties 123 proposed 87:24 protect 19,22 2,7 71:17 72:14 89:22 proverbial 21 47 provide 26:24 provided 69:24 75:23 5,9,24 101 providing 75:19 proving 94:19 publication 84:14 published 12,16 39 2,13 5,14 44:21 49:15 57:24 87:20 1,6 18,20 91:22 96:14 pull 36 43 pulling 49 pulmonary 45 purchase 28:16 97:11 purchased 127 purchasing 14,24 15,17,22 11,22,23 55 57:17 13,19,23 97:17 104 116 118 119 128 purposes 123 pursuant 117 put 11:20 29 7,8 18,23 7,15 5,12 37 38 46:11 50:22 Index processing..rapidly 64 73:19 74:19 11,20 92:23 95:15 11,13,20 124 puts 59:12 putting 19:22 48:13 73 12 84:23 Q QA 2,5 83 quality 13:15 14:22 17 10,11 25 6,7 2,18 7,14 11,14 83:10 85:10 107 quantities 79 question 11,12,19 19:15 34:17 39:19 40:25 48:14 59:17 65:24 74:15 4,7,9 82:25 87 90 25 91 95 96 8,11 104 21,23 117 3,4,5 questioning 48 81:11 87 91:16 questions 91 99:22 9,12 130 quick 14:24 quote 128 R R 54:21 116 ran 78:10 Ransdell 42:24 43 46:14 9,11,15 Ransdell's 42:25 rapidly 121 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 raw 93 read 23,25 20,22,23 37:14 44:17 10,21,22 49:15 50:10 64 75 79:15 81 82:21 83 86:14 88 6,17,21 93:20 95:13 9,10 103 113 16,20 real 14:23 reamers 14 ended 67 reason 11 15,19 97 106 109 114 120 124 recall 15:12 16:22 19 27:25 51:24 12,13 76 78 9,11,13,20 115 receive 121 124 received 22,25 recess 38:24 90 100 recognition 49 recollection 75:22 83 15:24 74:18 recommend 51:17 recommendation 47:10 51:19 recommended 58 record 16,17,18 10 14:25 38 21,23 1,3 48:13 60 79 7,10 98:10 99:19 4,11,14 130 records 59:23 11,12,20 9,10 14,15,16 2,14,20,22 112 114 1,5,8 118 20 16,20,23 128 redirect 18,21 reference 37:17 referred 7,20 49 referring 68:21 69 reflect 75:22 reflected 10 refractories 13:22 14 refresh 74:18 83 Register 79:16 2,3,4,6 9 82:19 2,10,13 84 85 87:21 1,6,16,19 91:23 11,15 105 regular 94:12 regulated 92:14 regulations 12,15 85:11 87:14 88:17 90:24 regulatory 3,11 42 11,14 1,17 59 108 relate 91:16 related 18:11 45 92 101 110 115 117 118 relating 115 release 50 released 51 993 releases 64:18 relevant 81 relied 25:12 rely 25:17 remember 43 47 19,21 24,25 117 119 126 Index raw..research remotely 5 removed 49 removing 10,15 Repeat 117 replace 53:23 56 101 102 107 replaced 63:16 replacement 51:22 3,6 7,17 7,16 55:14 77:25 78 102 10,12,14 replacing 107 report 20:16 11,14 reported 20:19 27:12 reporter 5,25 10 83:23 18,22 96 99:12 130 Reporters 9:24 reporting 22:22 Reports 38:19 represented 99 101 representing 108 reps 75:25 requesting 102 requests 80 require 113 required 93:11 116 requirement 85 requirements 26:23 80:10 82:14 83 requiring 82 research 13:16 14:22 2,4 19 25 42:23 52:23 53 54:11 7,11 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 14,19,20,23 57 59:13 64:22 1,13 21,24 105 reserve 91:15 129 17,20 resource 16:23 resources 18 25 5,7,24 16 respect 80:10 83 respond 98:17 response 98:24 113 responsibility 11 16:24 15,24 52:12 57:12 80 83 89:22 responsible 69:13 rest 23 78 retention 11,14,18,21 4,21 117 retired 11 33:23 review 80 83 reviewed 24 Reyen 9:13 11:12 12 6,19 20:20 1,13 2,19 23:18 13,20 26 2,9,12 16,21 37:13 9,16,20,22 40 15,20,24 43:18 44 45 16,20 48 53:20 56 57:10 4,17 61 63 11,20 64 2,24 66 68 70:17 3,16 74:15 75 78:24 17,20,23 81 5,15,19 1,6 87 88 3,21 6,10 92 1,9,13,19,25 98 11,14,19,24 19,21 105 16,18 107 111 120 11,12 16 10,24 2,10,19 14,18 2,5,12 11,24 Richard 65:15 90:14 hand 36:22 49:23 93 rings 15,20 50 58:14 RISCHMAN 125 128 role 61:13 121 roles 79:11 roll 31 rolls 32:24 49 6,8,15 58:18 84:21 103 124 room 63 64:17 Rose 128 roundabout 24:20 28 33 117 rubber 93:24 95 rulemaking 87:24 running 45:12 91:18 Russ 17,24 20:19 21 7 safe 92 safety 8,24 1,5,7,8 17,20,24 11,13 87:23 sale 7,11 101 103 110 1,6,8 117 sales 14:21 16,19,22 20 22:24 25 23,25 27 75:25 97:11 108 Index reserve..sell 6,9,11,12 13,15 16,21 14,25 126 15,19,23 128 130 shipment 111 salespeople 10,12,17 128 sample 56 sampling 55 San 74:22 sat 22:12 schedules 27:21 Schein 74 17,18 School 15,22 schools 11,13 119 120 scientific 56:15 scientifically 92:16 scope 66:10 88:10 scrap 93 screen 5,14 scroll 75:14 82 90:18 20,25 102 search 5,11,16,19 100 101 3,24 107 22,23 113 118 128 searched 99 111 128 section 87:21 93:19 sections 50 Seeking 34 sell 12:20 18:15 10,22 53:13 55 73:25 74 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 13,15 106 109 2,5,11 120 121 128 selling 10,12,16 44:25 9,10 14,16 3,20 58 1,20,22,23 67:15 15,20 79 84:17 96:18 111 17,20,25 126 16,18 sells 125 send 26:25 98:22 sends 54:22 sense 31:19 sentence 4,13,17 45:24 49:24 58:11 separate 21:21 32:15 sequence 88:13 serving 120 servings 30:25 set 19 52 61:15 setting 10,18 share 121 129 sheets 54:16 shelf 112 shelves 77:25 78 79 ship 84:24 125 shipment 110 128 shipped 120 122 13,18 show 28 34 40 43:10 4,10,12,14,17 20,24 2,23 102 113 showing 63:25 shows 77:21 sic 9:23 39 103 sick 67:20 71:12 side 37 57:18 65:12 sign 11,13 significant 45:24 signing 114 130 silence 40:22 similar 123 sir 48:15 74:24 122 124 sitting 36 situation 99:16 sixth 85:13 86 size 32:11 78:21 skills 40 slips 67 small 79 smaller 36:21 smart 66 snappy 66 snuck 19:17 sold 13 20,23 18:13 20:18 18,20 31 32 23,24 33 6,19 46 12,15 58:13 12,25 18,23 108 109 19 11,19,22 112 124 12,16 solution 53:23 3,4 sort 52:18 122 sound 15:15 28 42 6,14 72 99:11 sounds 33 19,23 Index selling..stamp Southern 15,22 speak 11 12:12 13:14 28:18 33 40:19 16,24 44 47:17 19,23 57 16 59:18 6,8,22 63 64:23 8,17 73:14 77 78:25 79:21 88:12 101 15,23 110 111 119 speaking 11:18 19 32:20 34:15 speaks 40 44 8,13 spec 89 Specialties 98:20 specific 41:16 76 92 115 119 123 specifically 120 specifications 97:12 specificity 98:12 speculate 66 speculation 39:10 43:18 56 61 63 65 72 79:18 88:10 94 102 105 106 107 120 2,23 6,16 124 125 128 Speculative 123 Spencer 9:24 38:20 spread 106 Springer 9:21 127 Springer's 48:10 staff 2,8 stake 92:20 stamp 52 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 standard 14,19 87:19 25 88 Standards 86:13 start 30 34:25 4,12 79 85:24 104 started 1,4 10,12 19,24 13,17 15 16:15 17:17 18:10 2,3 26 14 70 starts 90:19 state 63 stay 79:12 stayed 79:15 staying 55:13 step 17:19 stick 16 sticker 37 83:25 stipulate 4,5 91:18 stipulated 4,7,12,13 stipulations 9:15 stock 33:25 34:19 stop 23 46:10 14,16 22,23 70:15 71:23 17,20 stopped 21 66 70:20 72:10 111 stops 4,24 storage 93:15 store 67 story 129 Street 21,22 2,10 stretching 24:16 strike 9 13:10 71:22 92:23 9,21,22 123 strip 32:14 122 123 22 12,13 strips 3,23 7,15,24 33 84:22 120 structure 46:25 students 119 120 stuff 26 47:15 56:20 59:25 83:14 109 110 17,20,24 126 style 22:24 subject 87:13 88:24 89:19 subpoena 17,20 99 substitute 4,6 101 sudden 126 sue 71:12 sued 19,24 67:20 70:16 1,9 suggest 34:14 127 suggesting 51:13 2,3 suggestion 59:11 suitable 53 summary 10,11 Superman 94:12 supervisor 27:23 supplied 68 123 supplier 32:17 69:24 123 suppliers 72:22 73:25 74 123 supplies 12:21 supply 126 Index standard..tape supplying 103 supposed 50:21 85:10 surprised 44 suspend 85:23 Suzanne 18,19 swear 5 10 swirly 95:24 switch 99:15 switchover 108 Sybron 97:24 4,12,14 20,23 Sybron's 98 symbols 99:15 system 103 T tabs 17,18 takeaway 17,21 taking 56 84:23 talented 40 talk 11:21 12:25 21:19 65:25 75:19 90:12 106 talked 11,13 22 26:15 31 32 35 58:11 90:14 101 talking 25:23 47 50:12 55:20 73 83:13 104 22 2,5,16 108 114 130 talks 45 tape 13 28:16 18,20 21 1,3,6,11,12 7,10 15 11,21,23,24,25 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 11,22 15,19,21,23 15,19,21,23 24 3,6,14 3,6,16 8,22 63:22 18,24 21,25 72:21 1,5,13 22 1,24 2,8,10,11 13,15,16,18,19,20,22 5,6 17,22,23 89:15 23 23,25 94 4,5 16 12,18 101 102 19,22 11,19,22 3,20 119 120 10,12,15,16 TAURAS 17,21,25 96 104 14,16,20 team 14,21,24,25 20 24 4,10,24 22:18 108 tear 19,20,24 120 tearing 51 technical 56 technician 50:18 technicians 62:13 67:24 8,18 1,14 84:17 96:23 telling 56:25 57:23 125 128 tells 115 temporary 87:19 ten 32:15 pound 30:21 tendency 50 terms 59:20 test 52:24 64:18 testified 10 15:10 4,7 74:11 110 9,22 testify 81 testifying 81:14 127 testimony 15:22 17:15 48:10 53 58:25 59 61:18 63:20 70:17 72 7,11 80:24 82:23 98 106 113 testing 55 57 106 tests 104 105 Therapeutics 37:20 38 there'll 40:21 thing 28:12 31:23 39:14 40 49:10 54:25 57:20 58:12 17,21 63:12 71 2,3 99:15 3,24 103 119 things 22,23 23:21 5,20 57 66:20 88 18,20 94:20 105 thinking 63 71:14 thought 39:15 40:20 72 pound 30:20 throw 9,22 thrown 79 116 till 5,18 59 time 9:19 11:19 12:17 1,7,8 1,13 8,10 27:12 38:22 39 9,22 42:23 3,5 44 46:14 47 53 9,24 71:14 78:12 85 90:10 91:17 94:25 5,15 5,10,14 114 115 116 117 118 4,25 timeline 41:16 times 122 Index TAURAS..true timetable 41:12 title 41:24 86:11 87:16 titles 27:10 today 10:18 11 15:25 36 72 85:16 90:23 91 told 46:24 47 108 111 117 17,18 126 127 128 top 37:22 80:19 5,6 torn 51 tornadoes 68:24 69 total 99:17 101 totally 68:18 track 22 59:24 6,11 12,19 110 trade 4,10,14,15,17,20 train 74 75:25 trained 56:15 74:11 training 20,23 5,9 24 transportation 93:16 Trey 36:17 81 trial 9:12 troubles 126 true 12 13 8,13,18,183,18 19 17:13 18:12 21 26 27:24 3,17 29:18 33 8,9 34 35:11 38:13 40:17 20,21 7,10 6,7,14 47:16 50 13,16 17 52:11 3,12,15 54 6 56 23,24 61:16 64:14 1,18 8,9 70:16 71:18 72 1,6,7 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 9,10,13,16,17,19,20,23,24 74 75 77 12,13 12,13 18,19 84:18 18,20,21,24,25 101 25 3,4,7,14,18,19 19,23 108 109 14,23 4,20 112 2,24 21,24 114 5,15,18 120 121 125 13,14,17,20 23 4,10 4,5,6,7,8 9 twelve 100 U ultimately 46:13 11,23 unattractive 122 uncompetitive 122 understand 16:15 64:17 98:19 106 understanding 97:18 98 3,11 128 understood 66 125 undisputed 92:12 universities 31 70 13,14,21 university 119 120 22 upper 93 USC 121 vague 12 7,20 68:21 24 69 vein 63:13 vendors 68 73 verbal 25:22 versus 9:22 vice 12,14 27:14 33:19 21 35 22,25 58:25 59 83 114 video 15,16,20 57:19 65:13 view 10,12 volume 9:21 124 W wait 5,18,24 59 85:17 109 waive 81 walk 56 wanted 11 39:23 58:21 5,9 13,20 73:12 12,15 109 5,10 warehouse 19,20 warehouses 125 warn 85 warning 46:11 50:23 73:19 95:15 11,20 warnings 5,12 82 96:13 waste 93 wasting 91:17 94:25 watch 99:14 water 95:20 wax 123 ways 24:13 25:22 79:14 West 121 122 125 Index twelve..wrong 126 127 10,11 14 16,19,20 wet 49:10 wheels 59:12 When's 115 117 Whip 23,24 4,22 126 12,13 Whoops 36:24 Williams 87:22 Witkowski 74:21 113 Witnowski 113 word 6,8,12,17 106 15 107 114 128 work 4,25 27 1,18 52 54:25 15,19 62:22 68:25 121 worked 13:13 14 19 6,17,25 27 36:13 56 68:16 8,9,12 87:12 97:16 109 118 20 workers 32:20 working 11 1,4 14:13 54:22 56 69:14 71 72 81:20 89:15 118 works 69 129 worldwide 14:14 worried 12,22 71:11 21,25 72:12 Wow 121 write 57 72:25 written 9:15 10 25:23 26 59:16 10,25 wrong 101 128 Asbestos Reporters a GPS Partner 888-779-9974 Lawrence Girling January 29 2021 wrote 23:23 1,2,8,10 26 18,21 20,22 XVII 86:11 yea 52 year 23 27 41:15 77 5 21,25 7,21 110 years 15:18 19 27 15,18 43 51:24 107 109 127 Z zero- zero 103 Zoom 9:23 Index wrote..Zoom Asbestos Reporters a GPS Partner 888-779-9974