Document V3G80EqgmGVNB1BxarQozqQgN

Page 1942 1 Q Sir, am I right that the amount of time you 2 spent around pipecoverers may have been just once or 3 twice a week? 4 A Well, they were on the job like we was. 5 Q But in the same room, maybe once a week? 6 A It varies. You know, it could have been 7 once a week or it could have been -- it was every day 8 you would be around them. 9 Q Do you remember testifying at your 10 deposition, counsel, page 29, that you worked around 11 them about once a week, maybe for an hour? 12 A No, I don't remember that. 13 Q Let me ask you this question, sir, and I 14 will ask you a question. This deposition was taken, I 15 believe, March 4th, 1996. 16 Do you remember that? 17 A Yes, I do. 18 Q Do you remember being asked this question: 19 "Do you have a specific recollection of ever working 20 in the same room as Mr. Vandergucht when pipecovering 21 was being applied?"