Document ZrXqk3Og1MgoJ9gm7e7X2V0

FILE NAME Reddaway Manufacturing REDD DATE 2012 Apr 13 DOC REDD011 DOCUMENT DESCRIPTION Legal - Deposition - Todd Walker ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Page 1 IN THE UNITED FOR THE EASTERN STATES DISTRICT COURT DISTRICT OF PENNSYLVANIA ERIK ROSS PHILLIPS and TINA LANDERS Spouse VS ALBANY INTERNATIONAL CORPORATION et al EDPA FILE NO 600074 CIVIL ACTION MDL 975 NO Friday April 13 2012 10 Videotaped Deposition of TODD WALKER 11 was taken pursuant to Notice at the law offices of 12 COZEN O'CONNOR 457 Haddonfield Road Suite 300 13 LibertyView Cherry Hill NJ 08002 on the above date 14 before DEBRA G. SPALLONE CCR RPR Delaware 15 CSR Notary Public in and for the States of 16 Pennsylvania New Jersey and Delaware and a 17 Federally Approved Reporter of the United States 18 District Court commencing on or about 10:12 a.m. 19 20 21 22 23 24 25 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 2..5 1 APPEARANCES 2 Page 2 1 EXHIBITS Continued 2 Ex 6 Redo Process and Procedure Page 4 5 jhughes@wallacegraham.com 5 6 Representing the Plaintiff 6 7 7 8 DEXTER COZEN R. HAMILTON ESQUIRE 8 9 Philadelphia PA 19103 9 10 dhamilton@cozen.com dhamilton@cozendh.amilcton@ocozemn.com 10 Representing 11 Representing the Defendant Reddaway Manufacturing 11 12 12 13 LEATH BOUCH & KEEKINGS LLP 13 14 BOUCH ESQUIRE 92 Broad Street 14 15 29401 Charleston937-8811 15 tbouch@leathbtboucho@leathbouchlaw.ucom ctbouchh@leathblouchlawa.com wtbouc.h@leathbouchclaw.com oDefmendant Pneumo 16 17 17 18 19 VIA TELEPHONE DEAN GIBSON PLLC 18 19 301 McDow Stree et lESl QUIRE 20 Ex 8 Ex 9 Ex 10 Ex 11 Ex 12 Ex 13 Reddaway Manufacturing Company Inc. Invoice File Copy dated 1/27/88 57 Redco Reddaway Manufacturing Company Inc. Brochure 71 Material Safety Data Sheet Reddaway Mfg Co. Inc. 91 Videotaped Deposition of F. William Barton 102 Re-ddaway Manufacturing Company Inc Response to Plaintiff's Interrogatories and Request For Production of Documents 110 Material Safety Data Sheet U.S. Department of Labor Reddaway Manufacturing Co. 22 adrayton@deanandgibson.com 23 Representing the Defendant PEMCO 24 25 22222 Ex 14 ~ -Material Safety Data Sheet 22222 U.S. Department of Labor 22222 Reddaway Manufacturing Co. 22222 Inc. 133 Page 3 1 INDEX 1 2 ee 2 3 TESTIMONY OF TODD WALKER 3 4 By Mr. Hughes 5 By Mr. Bouch 6 9 4 233 5 6 7 7 8 EXHIBITS 8 9 a ee 9 10 EXHIBIT 11 NUMBER DESCRIPTION 12 PAGE 10 MARKED 11 12 13 Ex 1 Second Amended Notice of 13 14 Deposition of Reddaway 14 15 Manufacturing Company 10 56282222222 16 Ex 2 Abex Corporation Purchase 56282222222 17 Order dated 2/13/84 17 56282222222 18 Ex 3 Reddaway Manufacturing Company 56282222222 19 Product Information Sheet 23 56282222222 222222 Ex 4 Redco Private Brand Non- 56282222222 222222 Asbestos Lining Discount 56282222222 222222 Schedule 23 56282222222 222222 Ex 5 222222 Gipp vs. Abex 11-8-93 William Todd Walker 56282222222 43 56282222222 222222 56282222222 EXHIBITS Continued Ex 15 Caution Labels Ex 16 Material Safety Data Sheet U.S. Department of Labor Reddaway Manufacturing Co. Inc. Ex 17 Friction Materials Standards Ex 18 Ex 19 Ex 20 Ex 21 Institute Inc. dated November 6 1972 Affidavit of Todd W. Walker President of Reddaway Manufacturing Company Inc. Abex Corporation Account Reddaway Manufacturing Company Inc. Invoice File Copy dated 3/23/84 Abex 1986 File Card Ex 22 Ex 23 Ex 24 Letter from Redco Edward F. Eggert to David L. Erenstoft Dated December 30 1991 Redco Redco News dated August 86 Redco July 86 Facts in Friction Page 5 137 139 141 148 162 163 167 176 178 184 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 6..9 1 EXHIBITS Continued, 2 Ex 25 Defendant Reddaway Manufacturing 3 Co. Inc.'s Answers to Plaintiffs Page 6 1 ee 2 PROCEEDINGS 3 Page 8 4 Master Interrogatories to all 5 Defendants 194 6 Ex 26 Friction Materials Standards 7 Institute Inc. 196 8 Ex 27 Answers of Reddaway Mfg Co. 9 Inc. To Plaintiff's 10 Interrogatories and Request 11 For Production of Documents 208 4 --- 5 It is stipulated and agreed by and 6 between counsel that reading signing sealing and 7 certification of the within deposition be waived and 8 that all objections except as to the form of the 9 question be reserved until the time of trial 10 Dee 11 VIDEO TECHNICIAN This is the 12 Ex 28 13 14 Ex 29 15 16 Redco List Prices for Molded Flat Sheet Stock 210 Defendant Reddaway Manufacturing Co. Inc.'s Initial Disclosures Pursuant to Federal Rule of 12 beginning of tape one volume one in the deposition 13 of Todd Walker in the matter of Erik Ross Phillips 14 and Tina Landers Spouse versus Albany International 15 Corporation et al Civil action number MDL 875 in 16 the United States District Court for the Eastern 17 Civil Procedure 26 A 212 18 Ex 30 Redco In Compliance with 19 O.S.H.A. Citation G1688-050 17 District of Pennsylvania 18 Today's date is Friday April 13 19 2012 and the time on the monitor is 10:13 a.m. 20 21 22 23 Ex 31 24 Ex 32 25 the following Respiratory Protection has become Effective Immediately 215 Redco Brochure 215 Redco Brake Block Industrial Set Group Listing 218 20 My name is Alan Paller the 21 videotape specialist with Huseby Court Reporting and 22 the court reporter is Debra Johnson also with 23 Huseby 222 At this time counsel please 222 introduce yourselves after which the court reporter 1 EXHIBITS Continued 2 Ex 33 Redco Product Information 3 Sheet Type RNAW Reddaway 4 Asbestos Woven Brake 5 60 Ex 34 7 Lining Letter from Ralph L. Lanz to Mr. Vincent LaCarrubba dated 8 November 11 1975 9 Ex 35 10 11 Reddaway Manufacturing Company Inc. Invoice File Copy 12 13 14 15 16 17 18 19 20 21 22222 22222 24 25 Page 7 1 will swear in the witness Page 9 2 3 plaintiffs 4 MR HUGHES John Hughes for the MR HAMILTON Dexter Hamilton for 221 5 Reddaway and representing the witness 6 MR BOUCH Tim Bouch for 7 Pneumo 226 229 8 MS DRAYTON Amy Drayton for 9 defendant PEMCO on the phone 10 VIDEO TECHNICIAN At this time the 11 court reporter will please swear in the witness 12 wo ee 13 TODD WALKER after having been first 14 duly sworn as a witness testified as follows 15 ---- 16 VIDEO TECHNICIAN 17 Proceed 18 EXAMINATION 19 see 20 BY MR HUGHES 21 Q. Sir I'm going to be taking your 22 deposition today 222222 Have you been deposed before 222222 A. Yes 25 Q. How many times Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 222222 | 222222 222222 222222 222222 25 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 10..13 A. Q. Dakota -- Once Was that in 1993 the North Page 10 1 2 3 A. Yes 4 Q. Have you ever testified at trial 5 A. No. 6 Q. I'm going to ask you a series of 7 questions If you don't understand a question tell 8 me I'll try to rephrase it 9 If you want to take a break tell 10 me We'll take a break 11 All right 12 A. Okay 13 Q. You understand that your answers 14 today are going to be on behalf of Reddaway 15 Corporation 16 A. Yes 17 Q. Okay 18 -- 19 A. That's all we had Page 12 Q. That's all you could find A. That's all that is in the plant We searched everywhere and there was no other documents Q. All right Have you talked to any present or former Reddaway employees to get ready for the deposition A. No I have not Q. What's your understanding of what this case is about A. asbestosis It's a lawsuit Somebody has Q. And do you have any understanding of what their allegations are against Reddaway in terms of exposure to products that may have originally been manufactured by Reddaway A. Yes At which time a Second Amended Notice of Deposition of Reddaway Manufacturing Company was received and marked as Deposition Exhibit 1 for identification by the court reporter --- 20 Q. 21 A. 22 Q. 23 regard 24 A. 25 Q. What's your understanding Repeat that again What's your understanding in that I'm missing the question Okay 1 CONTINUATION 2 BY MR HUGHES Page 11 1 A. 2 question I thought it was a yes or no Page 13 3 Q. I'm going to hand you what we marked 4 as Exhibit That is the Notice of Deposition 5 Let me ask you what have you done 6 to get ready for the deposition 7 A. Basically met with my lawyers 3 Q. All right 4 Do you understand that in this 5 case the plaintiff Mr. Phillips he alleges that he 6 worked around brake linings -- 7 A. Yes 8 Q. 9 10 A. 11 Q. 12 A. 13 deposition Okay Did you look at any documents Yes I did What did you look at The -- the exhibits from the past 8 Q. -- that were manufactured by 9 Reddaway for Abex 10 A. Okay Yes 11 Q. Okay 12 Have you reviewed any depositions in 13 the case 14 Q. Anything else 14 A. 15 A. Everything that -- in trying to find | 15 Q. 16 all the records we went through all that stuff which | 16 17 you guys had asked for 17 today 18 Q. Okay 18 A. 19 In that regard when I went up to 19 Q. 20 the Reddaway facility we were not able to locate a 20 A. My previous deposition All right Are you still working for Reddaway Yes I am What's your position there President 21 folder of 1986 sales records as to Abex 21 Q. 22 A. Okay 22 23 Q. Subsequently a few sales records for | 23 in 1987 24 '86 were produced 24 A. Okay And you started with Reddaway back Yes 25 Do you know if that -- 25 Q. And that was after you got a college Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 14..17 1 degree in business 2 A. Yes Page 14 1 Page 16 And does RNAW stand for Reddaway 2 asbestos woven 3 Q. Okay 4 So when you started at Reddaway is 5 it correct that Reddaway was completely out of the 6 asbestos business -- 7 A. Yes it is 3 A. Yes 4 Q. Okay 5 For a period of time is it correct 6 that Reddaway sold both the asbestos woven and 7 the asbestos woven 8 Q. -- at that time 9 A. Yes 10 Q. And the description of Reddaway's 11 business today would be manufacturer of asbestos 12 friction materials for industrial use 8 A. Yes it was but when we converted 9 in 1983 to the asbestos those sizes which were 10 the smaller industrial sizes we never went back to 11 asbestos We continued the larger sizes in the oil 12 field 13 A. Woven friction materials 14 Q. Okay 15 But molded -- and so there's two 16 types of woven friction linings right 17 A. Yes 18 Q. There's the woven -- 19 A. Yes 20 Q. -- and the molded 21 A. Yes 2224 Q. 2224 asbestos -- And both of those used to be 2224 A. Yes 2224 Q. -- right or in part -- 13 Q. Okay 14 When you say smaller sizes can 15 you be more specific 16 A. 1/4 inch 16's 8's and a half 17 Those looms were changed over to the asbestos 18 and they had to be changed over early 80's in order 19 for them to have inventory in 1983 20 Q. So you said 1/4 inch 222225 A. 16's 222225 Q. 16's 222225 A. 8's and a half 222225 Q. Okay 222225 And those measurements what do they 1 A. Yes Page 15 Page 17 1 -- if I have a roll of woven brake lining does that 2 Q. -- and now they're not 2 -- the width the depth what is that 3 A. Yes 3 A. Thickness 4 Q. Okay 5 And at all times as to the molded 6 Reddaway would purchase that from Raybestos 7 A. Yes 4 Q. Thickness 5 Did the rolls always come in a 6 standard length 7 A. 25 feet 8 Q. Okay 8 Q. And so the thickness -- the width 9 And as to the woven Reddaway would 9 would be from one end to the other from side to side 10 manufacture that itself 11 A. Yes 12 Q. Okay 13 And once -- when was the date that 14 Reddaway switched to asbestos 15 A. Basically they switched in 1983 10 A. The width yes 11 Q. And you're talking about thickness 12 that would be from say the top to the bottom 13 A. Top face to the bottom face 14 Q. Okay 15 A. Yes 16 Q. Okay 16 Q. Okay 17 Now in 1983 Reddaway introduced 17 -- - 18 the RNAW -- 18 At which time an Abex Corporation 19 A. Yes 19 Purchase Order dated 2/13/84 was received 20 Q. -- product 20 and marked as Deposition Exhibit 2 for 21 Is that right 21 identification by the court reporter 22 A. Yeah They actually started 22 --- 23 manufacturing it years prior and they actually 24 started selling it in 1983 23 CONTINUATION 24 BY MR HUGHES 25 Q. Okay 25 Q. Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 18..21 Page 18 1 I've handed you Exhibit Number 1 Q. Okay Page 20 2 and I'll represent that I went to the Reddaway 2 It shows that it's going to be 3 facility and flagged a bunch of folders of sales 3 delivered to Abex 4 records regarding Abex and then they were 4 That's stamped on there right 5 subsequently released to me and you'll see a number 5 A. Yes it is 6 on the bottom right 6 Q. Okay 7 Do you see the number 7 Now what it says is two packages or 8 It says Reddaway580 8 two bales of asbestos brake lining 9 A. Yes 9 Do you see that 10 Q. Okay . 10 A. Yes 11 Now let me ask you this invoice 11 Q. Okay 12 Iam I correct it's -- hang on 12 Now is it your contention that this 13 This is dated February 13th 1984 13 wasn't asbestos brake lining 14 right on the top right 14 A. I would assume it's asbestos 15 A. Yes 15 We probably did not change these forms until I would 16 Q. And this is reflecting an order from 16 -- I would assume '86 '87 17 Abex to Reddaway correct 17 Q. Give me -- well first of all you 18 A. Yes 18 will agree with me that what the form says on its 19 Q. And what -- can you tell from 19 face is two bales of asbestos brake lining correct 20 looking at the order what it appears that they are 20 A. Correct 21 ordering 21 Q. Okay 22 A. They ordered five by a 1/4 250 22 But your testimony is you believe 23 feet That came in 25 foot rolls They ordered 100 | 23 that even though the form says that that it was 24 feet of three by 8's and it says the following 24 really asbestos 25 heavy duty woven lining 25 Is that what you are saying 1 Q. Okay Page 19 1 A. Yes 2 And where it says Part Number 258 2 Q. Tell me -- Page 21 3 do those part numbers have any meaning to you 4 A. I have no idea what that is 5 Q. 6 numbers So perhaps those may be Abex part 3 A. And the reason I'm saying that is in 4 early 1983 we were in full production of the 5 asbestos We turn our inventory three times a 6 year So this would mean there would be no more 7 A. Yes It's not our number 7 asbestos in those sizes 8 Q. Okay 9 Now go in a few pages to the page 10 that's bottom right Reddaway584 11 A. 584 8 Q. 9 10 A. 11 8's Okay And when you say those sizes -- The thickness the 1/4 and the 12 Q. Okay 12 Q. Okay 13 What is this document if you know 13 Are there any documents that would 14 A. I would assume the Bill of Lading 14 support your contention that Reddaway switched to 15 It's part of the paperwork 15 asbestos for these sizes prior to 1984 16 Q. Right 16 Are there any documents 17 Does it appear to be dated 17 A. Yes there is 18 April 3rd 1984 19 A. Yes it does 20 Q. Okay 22222 And this is a Reddaway form right 22222 It says Reddaway on the top right 23 A. Yes it is 24 Q. Then there's the tradename Redco 25 A. Yes 18 Q. What documents would support that 19 A. There's a price -- there's new 20 pricing on it 21 Q. Where would you have those 22 documents 23 If you need to take a break to talk 24 to your lawyer you're welcome to do it 25 Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 22..25 1 A. Okay Page 22 1 Page 24 The first page of Exhibit tell me 2 Q. When you say pricing documents 2 what that is 3 what do you mean 3 A. Basically this is a spec sheet on 4 A. Sent to all of the customers 4 asbestos RNAW woven brake lining 5 There was a new pricing and a new -- 5 6 a new sheet on the asbestos material and it's 6 Q. Okay And then the document behind it the 7 dated early 1983 and it says it will be replacing 8 the asbestos in the sizes I had given you 7 page behind it what's that if you know 8 A. That's just pricing Discount 9 Q. 10 document When's the last time you saw this 9 pricing 10 Q. Okay 11 Have you ever seen it 11 And the second page I don't see any 12 A. Yes 12 prices on it 13 Q. And when did you see it 13 I do see -- for example on the top 14 A. Week ago One week ago 14 right it says less 80-30 percent from list RNAW 15 Q. Okay 15 A. Yeah They have -- they'd have a 16 MR HUGHES Dexter do you know if 16 full price list of all these and that's the discount 17 that's been produced 17 that they would take -- 18 MR HAMILTON I would have to look 18 Q. Okay 19 through the production I assume that you know it | 19 A. and this would be for a Regional 20 was available whenever you wanted to pull So I 20 Warehouse Distributor 21 would have to look at the production 21 Q. And that's what's on the top left 22 MR HUGHES Okay 2222 A. Yes 222 MR HAMILTON Let's take a break 2222 Q. Right 222 and I can see if -- see if -- can we take a break 2222 A. Yes 222 MR HUGHES Sure let's take -- 2222 Q. Okay 1 let's go off a few minutes Page 23 1 Page 25 Now the full price list do you 2 VIDEO TECHNICIAN Off the record 2 know if that still exists 3 The time is 10:20 3 A. No that would not exist 4 --- 5 Discussion held off the record 6 --- 4 Q. Okay 5 Now going back to the first page 6 Tell me where on this document it 7 8 record VIDEO TECHNICIAN Back on the 7 indicates that Reddaway will no longer be selling the 8 -- the RBW 9 The time is 10:29 9 A. It does not indicate that but these 10 --- 10 looms took six months to a year to change over 11 At which time a Reddaway 11 There's thousands of spools of yarn on them that had 12 Manufacturing Co. Inc. Product Information 12 to be retrofitted for the new yarn So they 13 Sheet and a Redco Private Brand Sheet was 13 couldn't be -- you couldn't just go back and forth 14 received and marked as Deposition Exhibits 3 | 14 with the asbestos and the asbestos It would be 15 and 4 for identification by the court 15 impossible Once they were changed over that was 16 reporter 17 --- 16 it 17 Q. Okay 18 CONTINUATION 22222222 So now -- and you weren't at the 19 BY MR HUGHES 22222222 company when this happened 20 Q. Sir if you would look at what I 21 have marked as Exhibit 22222222 22222222 information So where -- where did you get this 22 A. Yes 23 Q. Do you see that 24 A. Yes 25 Q. Okay 22222222 A. Through Bill Barton F.W. Barton and 22222222 Warren Conway 22222222 Q. Bill Barton is he still alive 22222222 A. He's deceased Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 26..29 Page 26 1 Q. When did you get the information 1 2 from him with regard to what you're stating in terms 2 3 of switching to asbestos 3 4 A. From the time I started working at 4 5 Reddaway until the point he -- he passed away I got | 5 6 information from him on a daily basis 6 7 Q. Okay 7 8 And what is it that your testimony 8 9 -- what's your testimony in terms of what Bill Barton | 9 10 told you about the switching to asbestos 10 11 A. He -- he told me when we changed 11 12 over why we did the sizes that we did first and 12 13 that there was still a big demand in Canada for the 13 14 oil field So they ran that until the end Those 14 15 oil field sizes are 4's inch inch and an 1/8 15 16 MR BOUCH You said 4's 16 17 I'm sorry would you repeat that 17 18 | The oil field sizes are 4's -- 18 19 THE WITNESS Well the big oil 19 20 field sizes are one inch and an inch and an 1/8 and 20 21 then there was some 4's used in the oil field 21 22 --- 22 Barton Page 28 A. Yeah Q. Okay When did he pass away if you know If you don't know -- A. I don't have that exact date Q. Okay Warren Conway is he still alive A. He's deceased also Q. the company A. Okay What was Mr. Barton's position at President Q. And what was Mr. Conway's position A. Vice President Q. thick Okay Okay So you mentioned the one inch So what you're saying is it was offered through 1985 to '86 not sure the exact cutoff but believes the last of it went to Canada A. Yes 2222 CONTINUATION 2222 BY MR HUGHES 23 Q. 24 in Canada That's because there were oil fields 25 Q. Okay 25 A. Yes Page 27 1 So if it was an inch thick it was 1 2 not -- well strike that 2 3 How long are you saying that 3 4 Reddaway offered the inch thick -- 4 5 A. The inch thick 5 6 Q. -- asbestos version of the woven 6 17 A. Until '86 7 8 Q. Okay 8 9 And it was offered right up through 9 10 = November of 186 10 11 A. I wouldn't know exactly the -- the 11 12 cutoff point 12 13 Q. Okay 13 14 A. I do know that the last of it went 14 15 to Canada 15 16 Q. So it was offered through sometime 16 17 in '86 is what you think 17 18 A. '85 '86 In that -- in that range 18 19 Q. And the last of it went to Canada 19 20 A. Yes 20 21 Q. And what's your basis for saying 21 2222 that the last of it went to Canada 22 2222 A. Through conversations with Warren 23 2222 Conway and F.W. Barton 24 2222 Q. F.W. Barton is the same as Bill 25 Page 29 Q. And your basis for that is talking to Mr. Barton and Mr. Conway A. Yes Q. Okay Have you seen any documents to support that part of what you're saying A. There is a document It's -- could have been a Reddaway Newsletter Q. Okay A. It was -- it was given to you Q. What did it say if you remember A. It said that we're ceasing production of asbestos lining Q. Okay That was one of those 1986 documents A. Yes Q. Okay Like the Facts and Fiction A. Yes Q. Okay Then -- A. It also said on that that our Canada customers were using it to the end or something to that effect Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 30..33 1 Q. Okay Page 30 1 Q. That many 2 A. It does mention the Canadian 2 A. Yes Page 32 3 customers on there 3 4 Q. Okay 4 5 Going back you said an inch and an 5 6 1/8 Would that be in the category that was offered 6 7 through '85 or '86 7 8 A. Yes 8 Q. So you would have 4000 or 5000 -- A. Yes Q. -- spools of yarn A. Yes Q. -- on the machine A. Yes 9 Q. Okay 10 And was it the same reason because 11 it was being used for oil fields 12 A. Yes 13 Q. And you said 4's inch 14 A. Yes 9 Q. 10 A. 11 Q. 12 A. 13 Q. 14 machines How big would the machine be Size of this room -- Okay with everything Do you all still have any of those 15 Q. Was that also in this group that you /| 15 16 were saying was offered through 1985 '86 16 A. Yes Q. So for the 3/4 inch -- for the 3/4 17 A. Yes 17 inch are we talking about one machine or more than 18 I'm sure that the 4's was phased 18 one 19 out before the inch an inch and an 1/8 Each one of | 19 A. One 222222 these is made in a separate loom separate machine 20 Q. One machine 222222 Q. Okay 21 All right 222222 So -- all right Okay 22 And so what steps did Reddaway have 222222 So I guess taking the 3/4 inch 222 to go through for the 3/4 inch -- 222222 walk me through the machinery that it was made on 222 A. Okay 222222 that's pertinent to the switching to asbestos 25 Q. -- to get it to asbestos 1 A. Okay Page 31 1 Page 33 A. It's the same for all of the looms 2 Q. You mentioned a loom and you're 2 but on the 3/4 what they -- what they did they ran 3 going to have to forgive my ignorance on this one 3 a complete -- ran all of the asbestos yarn out -- 4 So the asbestos -- Reddaway bought 4 Q. Yes sir 5 -- yarn 5 A. -- and then once the asbestos yarn 6 A. Yes 6 was run out they'd run it -- they'd run all of the 7 Q. -- as a raw material 7 spools down to the minimum which is as low as they 8 Never bought powder right 8 could run it Then they would tie all of the new 9 A. No. 9 asbestos yarn in to pull it through -- 10 Q. Okay 10 Q. Okay 11 And the yarn comes in spools -- 11 A. - and then at that point it didn't 12 A. Yes 12 work 13 Q. -- right 14 And now tell me what for the 3/4 15 inch what would you do -- how would you turn those 16 spools into the product 17 A. Okay 18 On the 3/4 inch that -- that 2222222 machine only made 3/4 inch one thickness 2222222 Q. What machine 2222222 A. It's called a 3/4 inch machine or 2222222 loom 2222222 Q. Okay 2222222 A. Then on that machine there's 2222222 roughly between four and 5,000 spools of yarn 13 Q. Okay 14 A. So we had big problems because the 15 yarns were different the tensions were different 16 Everything was different about them 17 Q. Okay 18 A. So they thought that maybe -- they 19 really weren't sure how it was going to go It went 20 terribly 21 So springs had to be changed 22 Research and development through all this had -- had 23 to be changed and they got the new yarn in it and to 24 run in the machines 25 So once they did that there was a Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 34..37 Page 34 1 lot of parts that had to be changed they couldn't go | 1 2 backwards 2 Q. Okay A. - back then Page 36 3 Q. Now -- 3 They definitely started with the 4 A. None of the machines ever used 4 much smaller thickness though 5 asbestos after they went to asbestos because 5 Q. How do you know that again 6 they had to do too much work to get them to change 6 A. I was told that 7 them to run the new yarn 7 Q. By Mr. Conway and Mr. Barton 8 Q. Okay 8 A. Yes There's less yarn in the -- in 9 So what you're saying is when -- 9 the 1/4 inch versus the 16's and versus the 8's 10 when the company switched to asbestos it turned | 10 So that would be the first loom that they changed 11 out that the yarn had different qualities -- 11 over and then they -- they just kept going up the 12 A. Yes 12 line 13 Q. -- in terms of things like the 13 14 tension that needed to be maintained and you all had | 14 15 to modify or retrofit -- 15 16 A. Yes 16 17 Q. -- the loom machinery -- 17 18 A. Yes 18 19 Q. -- to accommodate the asbestos 19 20 = yarn 20 21 A. Yes 21 22 Q. I suppose that -- would that problem | 22 23 have first been noticed when you were trying to make | 23 24 the first change to asbestos on one of these 24 25 machines 25 Q. Okay So there would -- so if it is 1/4 inch thick presumably it uses less yarn to produce A. Yes Less spools of yarn on it Q. To produce the same length A. Yes Q. Okay So would the machine for the 1/4 inch have less spools on it A. Yes Q. Would it have thousands of spools A. Let me -- let me explain Page 35 1 A. Yes That's why in the late 70's 1 2 they actually started this process Maybe early 2 80's 3 4 Q. So in the late 70's or early 80's 4 5 is when you're saying the process of switching to 5 6 asbestos started 6 7 A. Yes 7 8 Q. And when do you believe -- when 8 9 would have been the first time that Reddaway 9 10 physically started trying to run asbestos yarn 10 11 for any of its sizes 11 12 A. It had to be early 80's because in 12 | 13 1983 they actually had a stock of it It was ready 13 14 to be sold | 14 15 Q. And so when the conversion's being 15 16 made in the early 80's would that have been for 16 17 for example the 1/4 inch thickness 17 18 A. Yes 18 19 Q. And then you mentioned 16's 19 20 Would that have been -- 20 21 A. Yes 21 22 Q. Now would those be two different 23 looms one for 1/4 inch and one for 16's or do you 24 ~~ know 25 A. Wouldn't know on that -- 22 | 23 24 25 Q. Okay Page 37 A. Okay Let's take 1/4 inch and 1/2 inch just round numbers say 1/4 inch loom has 2000 spools of yarn on it Q. Yeah A. 1/2 inch would have 4000 Those aren't the numbers but that's just you know it would double by thickness Q. Okay A. It's probably say 1000 -- say 1000 spools on the 1/4 and 2000 on the 1/2 In those ranges Q. Okay Now the switch -- so you are saying -- now you mentioned -- I wrote down earlier -- 1/4 inch 16's 8's and 1/2 inch A. Yes Q. Are you saying all four -- all of those four sizes were switched at the same time or were they switched sequentially or do you know A. Do not know Q. Okay All right Do you believe that all four of those sizes were switched in the same early 80's Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 38..41 1 time period 2 A. Yes Page 38 1 Page 40 Q. Because when you set out your 2 product information sheet on April 1 1983 you 3 Q. And is that because you're saying 3 already had stock ready to sell 4 that by 1983 Reddaway had stock of those four 4 A. Yes 5 sizes 5 Q. Okay 6 A. Yes 6 Now what is your basis for saying 7 Q. Okay 8 A. That sheet Exhibit -- 7 that there wasn't a period of time when Reddaway 8 wasn't selling say the 1/4 inch asbestos and 9 Q. Right 9 also the 1/4 inch asbestos 10 A. -- that just confirms what I was 10 Are you saying that would take two 11 told 11 separate looms to make if you wanted to do them both 12 Q. Okay and that's what I was looking 12 A. Yeah They never did both 13 for 13 Q. Okay 14 Okay 14 A. Once they changed the loom over 15 Now if I look at Exhibit page 15 that was it 16 one it says sizes available thickness 1/4 16 Q. And they would have one loom for -- 17 16's 8's and one half right 17 so for 1/4 inch -- 18 A. Yes 18 A. Yes 19 Q. Okay 222222 And is the reason why Reddaway 222222 switched those sizes first did it have to do with 222222 there being less spools in the machine or had to do 222222 with the market with regards to oil fields or 222222 something different 25 A. This was not an oil field size 19 Q. -- there would be one particular 20 loom that would make it -- 21 A. Yes 22 Q. - and not two looms 23 A. One loom 22 Q. Okay 25 And Reddaway at all times just had Page 39 1 This was an industrial size 1 one facility Page 41 2 Q. Right 2 A. Yes that's it 3 A. So the industrial got switched 3 Q. And manufacturing and the office are 4 before the oil field 4 in the same facility 5 Q. But was the thing that was driving 5 A. Yes 6 it you're saying was the fact that it was less spools | 60 7 on the loom or something else 7 Q. Okay The looms - machines -- so the 8 A. It could have been that and then 8 looms say that had to be -- strike that 9 also that it was the industrial sizes that they 9 So for the 1/4 inch would that 10 switched over first 10 loom have had to have the alterations because of the 11 Q. Okay 12 A. It was the demand The industrial 13 side of it went to asbestos before the oil field 14 side of it 15 Q. But why 16 What would be the driver for that 17 A. That's -- that's just how it was 18 Q. But your testimony under oath is 19 that from Mr. Barton and Mr. Conway your 20 understanding is that those -- the sizes from a 1/4 21 inch to 1/2 inch were switched first 22 A. Yes 11 tensions being different 12 A. Every -- every loom had to be 13 changed over 14 Q. Okay 15 Would there be records that would 16 show those changes for example drawings or engineer 17 -- 18 A. No. 19 Q. -- or anything like that 20 A. No. 21 Q. How do you know there aren't any 2222 A. I searched for them 222 Q. And that happened prior to April 1 2222 222 1983 2222 Q. Okay So that the machine that makes the 25 A. Yes it did 25 1/4 inch is that machine still at Reddaway today Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 42..45 1 A. Yes Page 42 Page 44 1 will see it towards the bottom of the page you're 2 Q. What's it called 2 being asked about the switch and November 1986 says 3 Does it have a little brand name 3 the date when your company is completely out of 4 A. No. 5 Q. You never named it 4 asbestos 5 Do you see that 6 A. Nope 6 A. Yes 7 Q. Do you know who made it originally 7 Q. Okay 8 A. They are all handmade probably in 8 And look at the top of page 66 9 the early or in the late 1800's right in the 9 What you said in your answer there 10 factory They were built into the floors 10 was basically November 186 we were completely 11 Q. Oh really 11 out of it We started purging the system prior to 12 A. Yeah 12 that year That was the deadline We wanted 13 Q. So -- 13 everything out of the plant All asbestos products 14 A. These -- these looms were all like 14 in any way shape or form And we were already in 15 1890 15 the process We already had our asbestos out 16 Q. Wow Okay 16 back in 1985 we were running the asbestos 17 A. We're not a real modern facility 17 lining 18 Q. Okay 19 Now -- 18 Do you see that 19 A. Yes 222222 Pause 20 Q. Okay 222222 MR HUGHES Let me find something 21 Now in that answer it refers to 222222 Actually let's do this 22 1985 as being the year when there was some amount of 222222 Let's go off for a second 23 asbestos 222222 VIDEO TECHNICIAN Off the record 24 Are you now saying that there was 222222 The time is 10:48 25 asbestos being produced prior to 1985 Page 43 Page 45 1 --- 1 MR HAMILTON Objection to the 2 Discussion held off the record 2 form 3 --- 3 THE WITNESS What was the question 4 At which time a Gipp vs. Abex 4 - ee 5 11-8-93 Deposition Transcript of William 5 CONTINUATION 6 Todd Walker was received and marked as 6 BY MR HUGHES 7 Deposition Exhibit 5 for identification by 8 the court reporter 9 --- 10 VIDEO TECHNICIAN Back on the 11 record 10:58 12 --- 13 CONTINUATION 209222222222 BY MR HUGHES 209222222222 Q. Sir I've handed you a transcript 209222222222 from your deposition back in the 1993 case 209222222222 A. Yes 7 Q. Well why did you say 1985 in this 8 deposition in the 1993 deposition 9 A. The asbestos already on hand 10 The asbestos Okay 11 In 1985 we were running the 12 asbestos lining I never said we weren't -- we 13 weren't running asbestos 14 What was the question again 15 Q. Well here you're saying we had 16 = asbestos out in 1985 right 17 A. Yes 209222222222 Q. Okay 209222222222 Let me ask you first to go to page 209222222222 65 and there's four pages on each page It's kind 209222222222 of confusing but on the top right it will say page 209222222222 65 18 Q. Okay 19 But what you're saying now is the 20 company actually switched to asbestos for some of 21 its lining even before 1983 right 22 A. Yes 209222222222 A. Okay Yes 23 Q. Okay 209222222222 Q. Okay 24 If you look at page -- look at page 209222222222 Now if -- if you look there you 25 83 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 46..49 1 All right Page 46 Page 48 1 switch from asbestos to asbestos in the lining 2 At page 83 -- at the bottom of page 2 A. I wouldn't know that 3 82 you're asked what is the RNAW and that is the 4 asbestos woven right 5 A. Yes 6 Q. Then you're asked what's the RBW 7 That's the Redco bonded woven 8 That's the asbestos 3 Q. Okay 4 The product information sheet that's 5 Exhibit was that internal or was that sent outside 6 of the company 7 Do you know 8 A. I don't have three 9 A. Yes 10 Q. Okay 11 And then at the bottom of page 83 12 there's the question so both were being 13 manufactured prior to that time 14 And you said yes right 15 Do you see that at the bottom of the 16 page 17 A. asbestos being manufactured 18 prior -- wait -- wait 19 Q. It says was asbestos being 20 manufactured prior to November 18 '86 21 You said yes 22222 A. Yes 22222 Q. And then -- so both were being 22222 manufactured prior to that time 25 A. Yes 9 Q. It's probably underneath there 10 A. Oh three 11 No. This would have been sent to 12 our customers 13 Q. Okay 14 If you know was the asbestos 15 the RNAW was that able to hold up under the same 16 conditions as the RBW the asbestos version 17 A. Yes 18 Q. Okay 19 A. It was a direct replacement 20 Q. Okay 21 Did Reddaway publicize to its 22 customers when it was switching to asbestos for 23 any given run of these widths of the woven line or 24 did Reddaway just do it didn't say anything about 25 it because they both work the same 1 Q. Okay Page 47 1 A. I wouldn't know 2 But what you're saying now is when 2 Q. You don't know Page 49 3 both were being manufactured what that meant was 3 A. Couldn't answer that 4 say the 1/4 inch might have switched to 5 asbestos -- 6 A. Yes 7 Q. -- but the one inch was still on 8 asbestos because you hadn't fixed the loom yet 9 A. Yes 10 Q. Is that what you're saying 11 A. Yes 12 Q. Okay 13 Let me show you some more of these 4 Q. All right 5 So you don't know when if ever 6 Abex might have learned that the lining it was buying 7 no longer had asbestos in it 8 A. I wouldn't know that either 9 Q. Okay 10 And just to go back to this last 11 page of Exhibit 12 When was a price list first issued 13 that showed the RNAW on it 14 invoices 15 Let see 16 If you go -- go back to Exhibit 17 which is the one with the invoices or the sales 18 record -- 14 15 16 17 18 Do you know A. I wouldn't know that either Q. Have you ever seen the actual price list that's being referenced on the last page of the -- 19 A. Okay 20 Q. -- and then Exhibit the Product 22222 Information Sheet 22222 Would something have been sent to 22222 Abex if you know 22222 Would anything have been sent from 25 Reddaway to Abex informing Abex that there was a 19 A. No I have not 20 Q. Okay 21 Do you know if that price list 22 showed prices for both asbestos containing and 23 asbestos containing products 24 Do you know one way or the other 25 A. I wouldn't know because I've never Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 50..53 1 seen it 2 Q. 3 4 A. 5 Q. 6 A. Okay I'm just checking And then on Exhibit -- Okay -- it's a page exhibit Here it is Yeah Page 50 1 Q. Okay Page 52 2 A. It went out exactly the same way 3 If you looked at two different 4 accounts it would be -- you wouldn't be able to know 5 which was what It had the tags on it Everything 6 was identical 7 Q. Yeah that says private brand 7 Q. Okay 8 Is that the same thing as 8 So if you had Abex ordering some 9 branding or no 9 rolls and then -- and they are going to end up 10 Or do you know 10 selling it as Abex and then another company orders 11 A. I don't understand that question 11 it just the Reddaway -- 12 Q. Okay 12 A. Yes 13 Is it correct that some of the woven | 13 Q. -- it's going to look the same 14 lining Reddaway sold it was the Reddaway brand 14 A. Exactly the same 15 right 15 Q. Okay 16 A. People sold it as the Reddaway 16 Either way 17 brand 18 Q. Yeah 17 18 burlap bag And typically it was in a bag -- a 19 A. Yes 19 A. Yes 20 Q. And it would be in a burlap bag 20 Q. Okay 21 typically right 22 A. Yes 21 And did the burlap bag have a 22 warning on it or a caution statement 23 Q. Okay 23 A. Yes it did 24 But then for Abex Reddaway would 24 Q. How do you know that 25 sell it to Abex with the idea that Abex is going to 25 A. To this day we still put on warnings 1 sell it under its own brand -- Page 51 1 2 A. Yes 2 3 Q. -- right 3 4 A. Yes 4 5 Q. And that was also done for S.K. 5 6 Wellman I think 6 7 A. It could have been yes 7 8 Q. Okay 8 9 And was there a company called SECO 9 10 A. Yes 10 11 Q. Was it done for SECO 11 12 A. Yes 12 13 Q. Let me ask you this first 13 14 What was the if you know what was 14 15 the difference between -- if I saw a roll of the 15 16 = lining -- 16 17 A. There was no difference 17 18 Q. Okay 18 19 Did it have anything different in 19 222222 terms of the -- the -- anything printed or -- 20 222222 A. No. 21 222222 Q. -- put on the roll 22 222222 A. It was the pricing 23 222222 Q. It was the price 24 222222 A. That was the only difference 25 that say asbestos Page 53 Fiberglass could cause harm if you breath -- breath it They were very -- very firm about these labels -- putting these labels on Q. Okay When was the caution statement first put on A. 1972 Q. A. rules . And what's your basis for that OSHA We followed all of the OSHA Q. Okay But who told you that For example did Mr. Barton tell you A. Oh yeah that constantly They were very -- told me Q. Okay A. I asked them what -- there was no asbestos when I first started working for them But I asked them you know with these labels why are we required to put these Fiberglass labels on They said we're not required to but we're going to put them on just in case Fiberglass does the same thing that asbestos does So to this -- to this day we still Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 54..57 1 put them on everything Page 54 1 2 Q. Okay 2 3 A. I think we're the only ones in the 3 Page 56 received and marked as Deposition Exhibit 7 for identification by the court reporter - 4 industry that do that 4 CONTINUATION 5 oe 5 BY MR HUGHES 6 At which time a Redco Process and 6 Q. Okay 7 Procedure for Packing using Burlap was 7 You're looking at Exhibit 8 received and marked as Deposition Exhibit 6 8 Is that the caution label that you 9 for identification by the court reporter 9 are talking about 10 --- 10 A. Yes This is the caution label that 11 CONTINUATION 12 BY MR HUGHES 13 Q. Exhibit have you seen this 14 document before 15 A. Yes I have 16 Q. And this is showing how the rolls 17 would be packaged up 18 A. Yes 19 Q. Okay 20 Looking at the photo on the first 21 page is the caution label on there 22 A. 23 label Yes Caution label is the larger 24 Q. You've got -- let's see 25 There's two white labels Sort of 11 was put on all of the asbestos lining 12 Q. Okay 13 Now are you saying that when 14 Reddaway switched to asbestos they would still 15 use a caution label that says asbestos 16 A. No the caution label would say 17 Fiberglass -- 18 Q. Okay 19 A. -- at that point 20 Q. So -- but where it refers to 21 asbestos it would change to Fiberglass 22 A. Yes 23 Q. And -- So when -- and you're saying 24 Reddaway switched for the 1/4 inch to the 1/2 inch in 25 the early 80's that's what you are saying right Page 55 1 the skinnier rectangular one and a more square one 1 2 underneath it 2 3 A. Yes The more square one underneath 3 4 is it the caution label -- 4 5 Q. Okay 5 6 A. and the label above that which 6 7 went on every product had the size of the material 7 8 Q. Okay 8 9 And would you have expected that 9 10 for sales to Abex what we see in Exhibit is 10 11 typically how it would have been packaged 11 12 A. Exactly the same 12 13 Q. Okay 13 14 The caution label -- are you saying 14 15 the same caution label language was continued after 15 16 it switched to asbestos 16 17 A. Yes 17 18 MR HAMILTON Objection to form 18 19 No that's fine 19 20 MR HUGHES He has to object once 20 222222 in awhile to preserve the objection but you can 21 222222 still answer unless he tell's you not to 22 23 MR HAMILTON Right 23 222222 - -- 24 25 At which time Caution Labels were 25 Page 57 A. Yes Started manufacturing it yes Q. Okay But they had it in stock by 1983 A. Yes Q. Okay So are you saying that this -- the material they had in stock by 1983 would have had the caution label saying Fiberglass or do you know A. I wouldn't know --- At which time a Reddaway File Copy Invoice dated 1/27/88 was received and marked as Deposition Exhibit 8 for identification by the court reporter --- MR HAMILTON Number eight COURT REPORTER Yes --- CONTINUATION BY MR HUGHES Q. Okay Looking at Exhibit The top page appears to be a sales document from 1988 right A. Yes Q. Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 58..61 Page 58 1 And that one says unbranded 1 have been asbestos Page 60 2 asbestos woven brake lining -- 2 A. It -- it's hard to say because in 3 A. Yes 3 '83 they changed over There's no way really to 4 Q. - right 4 tell 5 A. Yes 5 Q. Okay 6 Q. That says 16's 6 Well the invoice dated April 30 7 A. Yes 7 1984 which refers to 50 feet of three inch by 1/4 8 Q. Now if you compare the earlier -- 8 inch unbranded heavy duty woven brake lining right 9 the 1984 sales records -- 9 A. Yes 10 A. Yes 11 MR HAMILTON Exhibit 10 Q. Okay 11 Would that have been asbestos 12 MR HUGHES Yes 13 Okay 14 --- 15 CONTINUATION 16 BY MR HUGHES 17 Q. On Exhibit go to page Reddaway 18 585 12 containing asbestos or don't know 13 A. Don't know 14 Q. Okay 15 How come you don't know 16 I thought what you were saying 17 earlier is for 1/4 inch the company had changed the 18 loom to asbestos before 1984 19 A. Okay 20 Q. Okay 21 And that's -- that's a Reddaway 22 invoice dated April 30 1984 right 23 A. Yes 24 Q. And at the top there it says 25 50 feet of three inch by 1/4 inch unbranded heavy 19 A. We did change the loom 20 Q. Okay 21 Could you have still had asbestos 22 ~~ lining in stock 23 A. That's what I don't know 24 Q. Okay All right 25 Do you know -- let's see 1 duty woven brake lining right Page 59 1 Page 61 Do you have any idea how much of the 2 A. Yes 2 asbestos woven lining would have still been in stock 3 Q. Okay 3 as of April 1984 4 Then the one in Exhibit the 4 A. No I don't 5 invoice from 1988 says unbranded asbestos woven 5 6 brake lining -- 6 Q. Okay And would there be any records that 7 A. Yes 7 would tell us 8 Q. -- right 8 A. No records 9 A. Yes 9 Q. Okay 10 Q. Okay 10 Do you know one way or the other 11 If the invoice from 1984 was 11 whether there was some of the asbestos lining still 12 asbestos how come it doesn't say that on it 12 in stock in 1985 13 A. In -- in looking through some of 13 A. I wouldn't -- wouldn't know that 14 these invoices it seems like there was -- there's no 14 either 15 -- it looks like after 1986 everything said 15 Q. Okay 16 asbestos RNAW or non asbestos or the word 17 asbestos in it 16 A. I was told that most of it was gone 17 but what sizes I don't know 18 Prior to that it -- I don't know 18 Q. Okay 19 what -- I don't know who typed the orders what they | 19 In the time period from say 1983 20 did I don't know 20 through -- well after November 1986 Reddaway flat 21 It says unbranded heavy duty woven | 21 out didn't sell any asbestos products right 22 It doesn't say RBW It doesn't say RNAW 22 A. Yes 23 Q. Okay 24 But the one from 1984 it's for the 25 1/4 inch it's still your testimony that that would 23 Q. In other words after November 24 1986 not only did Reddaway stop manufacturing 25 products with the asbestos but they wouldn't sell Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 62..65 Page 62 Page 64 1 stock that had asbestos if there were any leftover 1 RBW It doesn't say RNAW It just says heavy duty 2 stock that -- 2 woven Yes sir 3 A. I came in '87 There was nothing in 3 Q. All right 4 the building -- 4 And that -- that appears to be a 5 Q. Okay 5 Reddaway form invoice right A. -- at all 6 A. Which one 7 Q. So it was all gone by then 8 A. Yes 7 Q. The Reddaway 585 8 A. 0585 9 Q. Okay 9 Q. Yeah it's on Exhibit 10 But sitting here today you don't 10 A. Yes that is 11 know one way or the other whether Reddaway still had | 11 Q. Okay All right 12 some of the asbestos woven brake lining in stock for | 12 Let's see The next page that's 13 say the 1/4 inch size in 1985 13 another Reddaway form Looks like a shipping form 14 A. Wouldn't know 14 right Reddaway 586 15 Q. Okay 15 A. Yeah it's just another copy 16 And that would be the same answer 16 Q. Okay 17 for 1986 up through November 17 If you go to Reddaway 589 a few 18 A. Yes 18 more pages -- Reddaway 589 where it says at the top 19 Q. Okay 19 225 feet 20 What you know is that when you came | 20 21 in 1987 there was nothing in there that had 21 So would that be a series of rolls A. Yes 2222 asbestos 22 Q. Okay 2222 A. No. 23 Once again we can't tell from that 2222 Q. Okay 24 whether it was asbestos or not right 2222 And when exactly did you come in 25 A. Nope Page 63 1 1987 was it more towards the beginning of the year 1 Q. 2 the end the year or don't know 2 3 A. I'd have to look I don't -- I 4 don't even know 3 again 4 Okay Page 65 Looking at Reddaway 593 same thing Can't tell if it's asbestos or 5 Q. Okay Fair enough 6 But you graduated in 187 -- 7 A. Yes 8 Q. 9 date - and that's how you remember the 10 A. Yeah So I'm sure it's middle -- 11 past the middle 5 asbestos right 6 A. Same -- same thing 7 Q. Okay 8 Let me ask you 9 Was it the same prices 10 Could you tell from the price 11 whether it was asbestos or asbestos 12 Q. All right 12 A. I don't have any idea 13 A. Yeah 13 Q. Okay 14 Q. That would make sense 14 And on that one I'd ask through your 15 A. Okay 15 lawyer that you all go and check because that would 16 Q. So just to dot the I on this 16 be important 17 On the Exhibit the April 30 1984 | 17 18 invoice Reddaway 585 sitting here today you don't | 18 For example look at Reddaway 594 -- A. 594 19 know one way or the other whether that was the 19 Q. Another page or two 20 asbestos version that was being sold out of stock or | 20 On that one you see where it has 22222 whether it was the asbestos that was being 22 produced on the altered loom you just don't know 21 the at sign and it says for example 1295 22 A. No. Where 22222 A. Don't know 23 1295. Okay 22222 Q. Okay 24 Q. Do you see that 22222 A. It doesn't say -- it doesn't say 25 A. Yeah Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 66..69 Page 66 . 1 Q. Does that look like a per unit or 1 they changed that form Page 68 2 per foot price or do you know 2 Q. Okay 3 A. I wouldn't know on that 3 How do you know -- are you certain 4 Q. Okay Okay 4 that back in 1984 the form that said asbestos would 5 A. Well wait a minute 5 be used whether the order was being filled with 6 It would have to be -- it would have 6 asbestos or asbestos 7 to be per foot because if you have times A hundred | 7 8 feet times 12.95 wouldn't that give you 1295 8 9 Q. Yeah 9 10 A. It's got to be per foot 10 A. I don't have that answer Q. Okay VIDEO TECHNICIAN Go ahead - 11 Q. Yeah Okay 11 CONTINUATION 12 Sitting here today you don't know 12 BY MR HUGHES 13 whether the 12.95 per foot could help us rule out one | 13 Q. And are you certain in 1984 14 way or the other whether it was the asbestos or 14 whether Reddaway had generated a non -- a form that 15 asbestos 15 said asbestos as of 1984 16 A. 17 Q. 18 A. 19 then 20 Q. 21 Wouldn't have any idea -- Okay -- what -- what the pricing was back . All right If Reddaway is able to figure that 16 Do you know one way or the other 17 A. I don't know I don't know that 18 information either 19 Q. Okay 20 Would there be anybody that you can 21 think of that would know 22 out reverse engineer that way to figure out whether | 22 23 that was asbestos or not as we proceed in the case 23 24 A. There would be no way to figure that | 24 25 out 25 A. I would be the only one Q. Okay Pause Q. All right Page 67 1 Q. Well if you could find a price 1 Page 69 When Reddaway was producing the RBW 2 list couldn't you figure it out that way 2 with the asbestos am I correct that Reddaway does 3 A. We don't have one though 3 not know -- can not provide a complete list of its 4 Q. Okay 4 raw material suppliers 5 Then look at Reddaway 601 just a 9 few more pages in 5 A. We don't have any of that 6 information anymore 7 A. 601 8 Q. So this is another Bill of Lading 9 now It should be Reddaway 601 10 A. Yeah 11 Q. This is another Bill of Lading a 12 shipping document -- 7 Q. Okay 8 And from the time period of say 9 towards the end from say 1980 through 1986 are you 10 able -- is Reddaway able to tell me a complete list 11 of all the possible asbestos yarn suppliers 12 A. No I'm not 13 A. Yep 13 Q. Okay 14 Q. -- right 14 In the later years am I correct 15 A. huh 15 that Amatex was a major supplier of the yarn -- 16 Q. All right 16 A. Yes 17 And it's showing delivery to Abex in | 17 Q. -- from a facility an ore mine in 18 the Winchester plant 18 Mexico 19 A. Yes 19 A. I don't know that 20 Q. Okay 21 So once again the form indicates 22 six -- it says six bales asbestos brake lining 23 right 24 A. Yeah That was our standard form 25 I don't know when they changed I don't know when 20 Q. Okay 21 A. I just know the name Amatex 22 Q. Oh but because of lack of records 23 Reddaway is unable to say under oath that Amatex was 24 the only supplier of the yarn in that time period 25 MR BOUCH Object to the form of Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 70..73 1 that question Page 70 Page 72 1 if I had a test result that purported to show that 2 ee 2 the brake lining was tested in the 1980's and it 3 CONTINUATION 3 showed the presence of crocidolite or amosite in the 4 BY MR HUGHES 4 sample am I correct then that Reddaway would have no 5 Q. Okay 5 basis to dispute that either way 6 Was Amatex the only supplier of yarn 6 MR HAMILTON Objection to the 7 in that time period 7 form 8 A. I wouldn't know that 9 Q. Okay 10 What is your understanding of how 11 Reddaway would have gone about ordering yarn 12 A. Verbally 13 Q. Just pick up the phone 14 A. Pick up the phone 15 Q. Okay 16 Are you aware one way or the other 17 of whether asbestos yarn was ever sold on the market 18 that had crocidolite or amosite in it 8 MR BOUCH Object to the form 9 --- 10 CONTINUATION 11 BY MR HUGHES 12 Q. Am I correct 13 MR HAMILTON You can answer 14 MR HUGHES In other words 15 Reddaway -- 16 THE WITNESS I wouldn't -- wouldn't 17 have any idea 18 --- 19 A. I wouldn't know any of that 19 CONTINUATION 20 Q. Okay 20 BY MR HUGHES 22222 So do you know whether any of the 21 Q. Okay 22222 yarn that Reddaway used from the time period 1980 to | 22 And is it correct that Reddaway 22222 1986 had crocidolite or amosite in it 23 itself never tested the asbestos brake lining to see 22222 A. I wouldn't know that 24 what kind of asbestos was in it 22222 Q. Okay 25 A. We did not Page 71 1 Is there anybody at Reddaway that 1 Q. Okay Page 73 2 would know 2 Roughly what percentage of total 3 A. No there's not 3 sales in the 80's of Reddaway products would consist 4 Q. Okay 4 of the woven lining 5 When Reddaway was ordering raw 5 Was that the primary product 6 material it was always yarn it was never -- 6 A. Yes Yes 7 A. It was always yarn 8 Q. Okay 9 And we just don't have records 10 anymore that -- 11 A. No. 12 Q. -- would completely account for 7 Q. That was the product 8 A. Yes 9 Q. Okay 10 The exhibit put in front of you 11 Number have you seen that before 12 A. Yes 13 those orders 13 14 A. We don't have any records that go 14 Q. Okay And looking just on the front there 15 back that far 15 -- actually let's go in a page 16 Q. Okay 17 ~-- 16 If you go in a page do you see -- 17 is that actually a picture of what the -- the woven 18 At which time a Friction Products 18 brake lining looked like 19 by Redco Brochure was received and marked as | 19 A. Yes 20 Deposition Exhibit 9 for identification by 20 Q. Okay 21 the court reporter 21 Is that how it would be -- well 22 - 22 strike that 222 CONTINUATION 222 BY MR HUGHES 222 Q. Before I get to this exhibit if -- 23 The way it would have been shipped 24 to Abex would it look like that except it would be 25 put into a burlap bag -- Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 74..77 1 A. Yes 2 Q. -- is that right 3 A. Yes 4 Q. Okay Page 74 1 Page 76 Q. And you're saying that both of the 2 labels that we see on the burlap bag on Exhibit 3 both of those labels have would been put physically 4 on the roll LO Would there have been any labeling 5 A. Yes 6 Now you told me about the label 6 7 that was on the burlap bag 7 Q. Okay Would the labels that we see on 8 A. Yes 9 Q. Would there have been any labeling 10 on the roll of lining itself 8 Exhibit on the bag would either of those labels 9 have said Reddaway or Redco on it 10 A. Yes 11 A. Yes 11 Q. Okay Then help me out 12 Q. Okay 12 In a case of where Reddaway is 13 What would have been on the roll of 13 selling the roll to Abex -- 14 lining 15 A. 16 Q. 17 A. A warning label Okay Go ahead A warning label and then the other 14 A. Okay 15 Q. -- and Abex is branding it and 16 selling it as an Abex product are you testifying 17 that in that case it would still have a label on it 18 size label above it 19 Q. Okay 20 In a prior deposition one of the 21 witnesses indicated it was speculation in terms of 18 that said Reddaway 19 MR HAMILTON Objection to the 20 = form 21 You can answer 22 whether there was actually a second label that was on | 22 THE WITNESS I -- I don't know what 23 the roll itself 24 A. There was always a label on both 25 Q. How do you know that 23 they do with it after they got it 22 I know how it went out of our plant 25 --- Page 75 1 A. I was told that from Bill Barton and 1 CONTINUATION Page 77 2 Warren Conway and to this day we still do it the 2 BY MR HUGHES 3 same way with the Fiberglass labels We put one on 4 the outside and we put one on every roll 5 Q. Okay 3 Q. 4 5 right Okay But you weren't there prior to '87 6 So your testimony is that there 6 A. No but we do it the same way to 7 would have been a label on the burlap bag right 7 this day 8 A. Yes 8 Q. Okay 9 Q. And there also would be a label 9 10 physically on the roll 10 So let me ask you this After 1987 is it correct that 11 A. On the roll 12 Q. Okay 11 Reddaway still sold the roll lining to Abex under the 12 branding agreement right 13 A. Each roll We had special tacks 13 14 that we -- the labels were self adhesive and then we 14 form MR HAMILTON Objection to the 15 actually tacked them on also They weren't easy to 15 --- 16 get off 16 CONTINUATION 17 Q. Okay 17 BY MR HUGHES 18 A. The other thing we do the labels 18 Q. Or Reddaway -- how long did Reddaway 19 were placed on the roll in a certain place 19 continue to sell the rolls of lining to Abex if you 20 If you look at the little flap where | 20 know 21 it comes around like when you roll something up we j 21 A. I don't have an exact date 2222 put it right by that flap so if it ever did rub up 22 23 against anything it couldn't take the label off It | 23 Q. Okay A. I don't have that memorized 2222 was like protected 24 Q. Okay 2222 We do it the same way today 25 The invoices that you all produced Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 78..81 Page 78 Page 80 1 I think it went into at least the early 90's 1 had a -- it had the warning on it too the caution 2 A. That was the last date 2 statement 3 Q. Okay 4 So what is your testimony in terms 5 of if I looked at one of those rolls that was being 6 sold to Abex say in 1989 or 1990 the later years 7 are you saying it would have a label on it that said 8 Reddaway 9 A. The label could -- it said -- it 10 could have said bonded woven It have could have 11 said woven lining but it was our label 3 A. Yes but they were Fiberglass 4 caution labels 5 6 asbestos Remember I wasn't there with the 7 Q. All right 8 You never saw a roll of lining being 9 sold to Abex that had the asbestos caution on it 10 because when you got there -- 11 A. True 12 Q. Okay 12 13 A. Everybody knew what our label looked | 13 14 like because it was like a hard little manila 14 Q. -- the company had switched Is that correct A. True 15 label 16 Q. Okay 17 But -- and you're saying that that 18 label actually said Reddaway or Redco on it 19 A. I wouldn't know exactly -- it could 20 have said woven At that time period I don't know 21 I know at one point it did say -- it 22 just said Redco on it I know at one point it just 23 said heavy duty woven I know at one point it said 24 ~~ woven 25 I don't know the different points of 15 16 17 18 19 | 20 21 22 23 24 25 Q. Okay The copy of your old deposition Exhibit can you go to page 24 A. Okay Q. Okay Now in this deposition -- I'm going to start halfway down that page The question was when you say baled or boxed it Answer we put a burlap sack over 1 -- of when they changed it -- Page 79 1 Do you see that Page 81 2 Q. Okay 2 A. Where are you at 3 A. -- but it was the same little manila 3 Q. Halfway down on page 24 4 label that everybody knew 5 Q. Okay 4 A. Okay 5 Q. Do you see where it says and these 6 A. Like if I saw a lining in 6 stickers would have been on the burlap bag 7 somebody's plant I knew it was mine just by the 7 Is that correct 8 label 9 Q. Did you physically see rolls that 10 were sold to Abex that had the labels on them 8 A. And these stickers would have been 9 on the burlap bag 10 Yes 11 A. Repeat that 12 That Reddaway shipped out 11 Q. And the answer is yes right 12 A. Yes 13 Q. Yeah -- 14 A. Yes 15 Q. ~- to Abex 16 A. To Abex 13 Q. Okay 14 And then you say so everybody - 15 they were visible for everybody to see 16 A. Yes 17 Q. You saw some of those rolls 18 A. Yes 19 Q. Okay 17 Q. Okay 18 Next question was were they ever 19 actually placed on the friction block themselves 20 And what did you see 21 Did they have the labels on them 22 A. It had a manila little label on it 23 that had the size on it 20 Answer they could have been 21 A. Okay 2222 You are talking a friction block 2222 That's a whole different -- that's not a roll of 24 Q. Okay 2222 lining 25 And you are saying that it had -- it | 2222 Q. Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 82..85 Page 82 1 Page 84 So as to the friction block then 1 A. There could have been on each block 2 the question is you're speculating at this time 2 but there was always one on the outside of the box 3 Answer yes 3 because it was packaged in a box 4 So the way I read that is you're 5 not sure whether a label was actually put on the 6 friction blocks 4 Q. Okay 5 But as to the rolls of lining 6 you're saying -- you are sure there was a label each 7 A. That's a friction block 7 one 8 9 form MR HAMILTON Objection to the 10 11 12 lining 13 MR HUGHES Okay THE WITNESS That's not a roll of 7+ 14 CONTINUATION 15 BY MR HUGHES 16 Q. 17 18 A. 19 20 lining 21 Q. 22 222 A. 222 222 Q. Okay First tell me the difference Okay A friction block is just a block of Okay Would it be woven or molded Yeah Okay What would happen -- okay -Just walk me through it in your own 8 A. Every lining had -- roll of lining | 9 had a label on it 10 You got to remember a block is a 11 finished product drilled ready to bolt on There's 12 no cutting No drilling There's nothing that has 13 to be done to that 14 A roll of lining has to be cut 15 Therefore OSHA regulations state that it has to have 16 the tag on every roll of lining 17 Q. Okay 18 A. We technically didn't even have to 19 put it on the box but we put it on the box of every 20 brake block that went out even though it was 21 completely -- no drilling no cutting to be done 22 Q. Okay 23 And your testimony is you believe 222 that the asbestos warning was actually put on the 25 roll itself -- 1 words Page 83 1 2 A. Let me read this Okay 2 3 This is comp -- okay 3 4 First of all friction block didn't 4 5 -- didn't go in burlap 5 6 Q. Okay 6 7 A. See they changed it They -- you 7 8 were talking about rolls then they started talking 8 9 about blocks Blocks are packaged in a box 9 10 Q. Okay 10 11 A. We never sold blocks to Abex or 11 12 anything 12 13 Q. Right 13 14 Because all you sold to Abex was the 14 15 rolls right 15 16 A. Yeah This was an oil field -- 16 17 . Q. One of the oil field products 17 18 A. Yes 18 19 Q. Okay 19 20 A. Yes 20 21 Q. So what you're saying is after 21 22 those friction blocks you're not sure if there is | 22 23 label on it or not 23 24 A. On the friction blocks 24 25 Q. Right on the friction blocks 25 A. Yes Page 85 Q. -- even when it was sold to Abex -- A. Yes Q. - under a branding arrangement A. Yes MR HAMILTON Object to the form MR HUGHES All right Let me ask you this -- CONTINUATION BY MR HUGHES Q. If you look at Exhibit again will you agree that the picture of the roll -- of the woven lining on page two it doesn't show a label on it right A. Well that wouldn't show a label That's just for somebody to see the roll ready to be shipped That's not Q. Okay Well looking at that picture where are you saying the label would be put on here A. little flap so that if it Label was always put -- see It was always put right under ever rubbed against anything the the flap there's no way the label could be scraped off or the warning Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 86..89 1 scraped off 2 Q. Okay Page 86 Page 88 1 your testimony as to when it -- well did it switch 2 from asbestos to asbestos 3 A. If you put it on top and it rubbed 3 A. Yes Everything switched 4 against something you know it was a chance of that 4 Q. Okay 5 happening that's why we always put them in a certain | 5 So as to the molded rolls of lining 6 place | 6 which were bought from Raybestos can you tell me 7 And they were self adhesive and 7 when it would have switched 8 tacked on We had special tacks and then when the 8 A. I wouldn't -- I wouldn't have any of 9 pneumatic staple guns came out they were stapled on | 9 that information 10 Q. Okay 10 Q. Okay 11 But you yourself did not 12 personally see an asbestos caution statement on a 13 roll of lining that was going to Abex 14 A. We didn't have asbestos when I 11 A. That was such a small -- we bought 12 very little of that That was almost nothing 13 Q. Okay 14 So if the evidence would show that 15 worked there 15 Abex was purchasing some of the molded rolls of 16 Q. I understand 16 lining in the time period 1984 through 1986 -- 17 Just to make it clear on the record | 17 A. I was told they never purchased 22222222 A. Yes sir 18 MR HAMILTON Let him finish the 22222222 Q. So you'll agree that you yourself 19 question 22222222 never personally saw -- 20 7 22222222 A. 22222222 Q. 22222222 label -- 22222222 22222222 Q. I never personally saw -- a roll of lining with an asbestos Correct -- with asbestos caution on it 21 CONTINUATION 22 BY MR HUGHES 23 Q. I'm asking you if -- if the 24 evidence showed that they did purchase some of the 25 rolls -- 1 A. True Page 87 1 A. Oh if they did okay Page 89 2 Q. Still looking at Exhibit the next 2 Q. You wouldn't be able to tell me from 3 page 3 the time period of '84 to '86 whether it was 4 That's the flexible molded rolls on 4 asbestos or asbestos 5 the bottom left right 6 A. Yes 5 6 form MR HAMILTON Objection to the 7 Q. Okay 7 8 Is it your testimony that that 8 MR BOUCH Object to the form MR HUGHES That's fine 9 product as well would have a label 9 You can answer 10 A. Yes 10 THE WITNESS What's that 11 Q. Okay 11 I don't know what that means 12 And affixed in the same way 12 MR HAMILTON Just something we're 13 A. Yes 13 doing You should answer his question unless I tell 14 Q. All right 14 you not to 15 And that's the product that 16 Reddaway instead of manufacturing they would 17 purchase it from Raybestos 15 THE WITNESS Okay 16 MR BOUCH It's a question the 17 Judge will rule on because we've said -- 18 A. Yes 18 THE WITNESS Okay | 19 Q. If you know when the molded rolls 19 MR BOUCH -- he's trying to call 20 would come in from Raybestos do you know if they had 20 for speculation and we are putting your testimony 21 any particular labeling or packaging 21 against the other and he has no foundation for if 22 A. I wouldn't have any idea on that I | 223 THE WITNESS Okay 23 know when it went out of our plant that it did 223 Thank you 24 Q. Okay 24 MR HUGHES That's the alleged 25 And as to the molded lining what is 25 reason Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 90..93 1 2 CONTINUATION 3 BY MR HUGHES --- Page 90 1 2 3 Page 92 Deposition Exhibit 10 for identification by the court reporter ii 4 Q. Okay 5 Now I think you were saying a 6 minute ago -- let me ask you 7 Did Reddaway ever sell the molded 8 rolls of lining to Abex 9 A. No. We did not 10 Q. How do you know that you didn't 11 A. They made their own 12 They were a molded manufacturer 13 They weren't going to buy that from us 14 Q. Okay 15 So your understanding is Abex was 16 able to manufacture the molded rolls of lining 17 A. I really don't know 18 I mean they're a molded plant 19 Q. Okay 20 A. So I don't know what they did 21 but -- 22 Q. But what you're telling me is that 23 if I looked through all of the Reddaway sales 24 records I'm not going to see -- 25 A. It's all woven 4 CONTINUATION 5 BY MR HUGHES 6 Q. Sir Exhibit 7 Have you seen that document before 8 A. Yes I have 9 Q. Okay 10 And your understanding that is a 11 Material Safety Data Sheet -- 12 A. Yes it is 13 Q. -- or what some people call an MSDS 14 A. Yes 15 Q. Okay 16 What was if you know Reddaway's 17 policy on providing MSDS sheets to its customers 18 A. When a new customer bought from us 19 they would always get a packet and it would always 20 have the Material Safety Data Sheet in it 21 Q. Okay 22 A. Every couple of years we just send 23 out to all of our customers a new updated one 24 every time we updated it It could have been two or 25 three years 1 Q. All woven Page 91 1 Page 93 Sometimes a customer required on 2 A. All woven 2 every shipment they'd want a Material Safety Data 3 Q. No molded 3 Sheet So they were -- if they asked us for that 4 A. No molded 4 then every shipment they got would have one in the 5 VIDEO TECHNICIAN Okay 5 packing slip 6 Five minutes on the tape 6 Q. Okay 7 MR HUGHES All right 7 As to Abex and you understand Abex 8 Let's take a break 8 in the past has also been known as Pneumo -- 9 VIDEO TECHNICIAN This concludes 9 A. Yes 10 tape number one of the videotape deposition of 10 11 Todd Walker 11 Q. -- and American Brake Lining A. Yes 12 The time is 11:40 12 Q. I think that Reddaway first was 13 We are off the record 13 selling to Abex in the 60's 14 --- 14 Does that sound right 15 Recess was taken at this time 15 A. Yes 16 --- 16 Q. Okay 17 VIDEO TECHNICIAN This begins tape 18 number two of the videotape deposition of Todd 17 Do you have any knowledge as to what 18 -- what Reddaway would have been doing with Abex in 19 Walker 19 terms of sending MSDS sheets 20 The time is 11:50 20 MR BOUCH Objection to the form 21 We're on the record 21 THE WITNESS It would have been 22 --- 22 exactly the same If they requested one in every 23 At which time a U.S. Department of 23 shipment they would have got one on every shipment 24 Labor Material Safety Data Sheet Reddaway | 24 Abex basically on their Material 25 Mfg Co. Inc. was received and marked as 25 Safety Data Sheets you know they got -- the product Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 94..97 1 didn't change 2 MR HUGHES Okay Page 94 1 Page 96 Q. How do you know that the MSDS sheet 2 we've marked as Exhibit was sent to Abex 3 THE WITNESS Our products you 4 know our RBW was the same for however many years we 3 A. It was our policy We sent it to 4 all of our customers 5 manufactured it 6 MR HUGHES Okay 7 So -- 8 THE WITNESS And we also followed 9 in '72 OSHA's regulation and we followed those 5 Q. Okay Let's see 6 So this a MSDS sheet this is for 7 the product RBW the woven brake lining rolls 8 right 9 A. Yes 10 steps to what they wanted with -- with the Material 11 Safety Data Sheets 12 7 10 Q. Okay 11 And the raw material yarn would be 12 about 75 percent asbestos 13 CONTINUATION 14 BY MR HUGHES 13 14 form MR HAMILTON Objection to the 15 Q. Okay 16 That leads to my next question 17 When did -- if you know did 18 Reddaway first put out an MSDS sheet for the RBW 22222222 A. I know that we had it in 1972 22222222 Prior to that I wouldn't have that 15 MR HUGHES Just in reading old 16 depositions of 30 6 witnesses for Reddaway I 17 read that the yarn's raw material would have about 18 75 percent asbestos and then once it was turned into 19 the RBW it would go down to about 50 percent 20 asbestos 22222222 information 22222222 Q. Okay 21 22 form MR HAMILTON Objection to the 22222222 And Exhibit on the bottom right 23 22222222 it says Form OSHA Then underneath it says Rev. | 24 22222222 or revised May '72 right 25 CONTINUATION MR BOUCH Objection to the form --- 1 A. Yes Page 95 1 BY MR HUGHES Page 97 2 Q. So is it your testimony that 3 Exhibit that list MSDS sheet may have dated back 4 to 1972 5 MR BOUCH Object to the form of 6 that question 7 THE WITNESS Let me read this 8 Yes 2 Q. Is that your understanding 3 A. I wouldn't have any information on 4 that I don't have the knowledge 5 Q. Okay 6 So as to the amount of asbestos in 7 the yarn roll material you don't know how much of it 8 was asbestos 9 -- 9 A. I -- I wouldn't have any idea 10 CONTINUATION 10 Q. Okay 11 BY MR HUGHES 11 A. It's not -- not those amounts 12 Q. Okay 12 though in talking to Bill Barton It was lower 13 Do you know if this MSDS sheet 13 amounts 20's 30's in the percentage wise 14 Exhibit if this form of MSDS sheet was ever sent | 14 Q. In the yarn 15 to Abex 16 A. Yes it was It was sent to all of 15 A. Yeah I never heard 70 yeah I've 16 never heard 75 17 our customers 17 Q. So - 18 Q. Okay 18 A. It would be impossible for it to be 19 When it was sent do you know 19 75 because half of the material is resins The 20 whether anything was sent with it 20 other half is yarn 30 percent of the yarn -- or 21 A. Sometimes they sent just the 21 30 percent of the yarn is brass So right there 22 Material Safety Data Sheets to all of the customers | 22 puts it at a completely different ratio 23 Like if we updated it basically it was the date 23 Q. In your deposition from 1993 24 because we didn't change anything on it Then they 24 Exhibit if you go to page 48 25 would have been sent a new one at that time 25 A. Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 98..101 1 Q. Okay Page 98 | /1 2 Look at what you said on the top of 2 I got it 7 Page 100 3 page 48 | 3 CONTINUATION 4 A. This was a common yarn in the 4 BY MR HUGHES 5 industry Anybody in our industry bought the same 5 6 yarn It was called a commercial grade asbestos It | 6 7 was 75 percent asbestos and 25 percent organic 7 8 Okay Okay Okay so -- okay 8 9 So so put it at 75 percent but 9 10 then the other -- the other fit so that would still | 10 11 put it at 35 40 percent just what I just said 11 12 Q. Okay 12 13 Well -- 13 14 A. See because you're going by the 14 15 MSDS sheet which has the resins and the yarn 15 16 = together 16 17 Q. Right 17 18 The MSDS sheet reflects what's in 18 19 the final product the RBW product that Reddaway 19 Q. What's the percentage of asbestos -- well do you have any understanding as to the percentage of the finished product that was asbestos A. Just going by these percentages -- Q. Okay A. of my knowledge roughly 30 percent to the best Q. Okay So first looking back at the MSDS sheet what's the MSDS sheet say A. That says 50 percent asbestos Q. Okay Are you saying under oath the MSDS sheet was wrong A. No. 222222 would manufacture -- 222222 A. Okay 222222 Q. -- right 222222 A. 50 to 60 percent of the product is 20 MR BOUCH Objection to form 21 Calling on the witness 22 23 form MR HAMILTON Objection to the 222222 resin So if the yarn was 100 percent that would 24 222222 still only put it at 40 or 50 percent asbestos but 25 MR HUGHES Okay THE WITNESS It would be 30 40 Page 99 1 the yarn actually has 30 percent brass in it It's 1 50 percent It's not 75 though 2 just one of the ingredients So that knocks it down | 2 --- 3 -- that knocks the yarn down that much more 3 CONTINUATION Page 101 4 See what I'm saying 4 BY MR HUGHES 5 Q. Okay We're getting there 6 So the yarn itself when the yarn 7 would come in on spools -- 8 A. Yes . 5 Q. Okay 6 But would you -- the MSDS sheet 7 indicates 50 percent asbestos -- 8 A. Yes 9 Q. -- is it correct that the yarn would 9 10 be 75 percent asbestos 25 percent organic 10 Q. -- Correct A. Yes 11 A. Yes 12 Q. Okay 11 Q. And 50 percent aromatic 12 hydrocarbons -- 13 And I can tell you in Mr. Barton's 13 A. Yes 14 deposition in 1995 that's what he said as well 14 15 A. Yes 15 Q. -- which would include resin -- A. Yes 16 Q. Okay 16 Q. - phenolic resin right 17 MR BOUCH Objection to the form 17 A. Yes 18 THE WITNESS But then when you add 18 19 the resin -- now say that's 40 percent of the whole | 19 Q. Okay So would you agree with me that up 20 product 222222 to 50 percent of the RBW product could be asbestos 21 MR HUGHES Right 21 A. I would agree 22 THE WITNESS So now you've got it 222222 MR BOUCH Objection 23 -- that brings it down to what I -- I'm going by the | 222222 MR HAMILTON Objection 24 finished product 222222 --- 25 MR HUGHES Okay 222222 CONTINUATION Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 102..105 1 BY MR HUGHES Page 102 1 2 Q. And that's what the MSDS sheet says 2 Page 104 Do you agree with that testimony MR BOUCH Objection to form 3 right 4 3 | MR HAMILTON Objection to the |4 MR HAMILTON Objection to form MR BOUCH Back in the 30's and | 5 form 5 40's Not the 80's 6 MR BOUCH Objection 6 MR HUGHES That's all right 7 MR HAMILTON You can answer it 7 - > 8 THE WITNESS Yes 8 CONTINUATION 9 ~-- 9 BY MR HUGHES | 10 At which time a Videotaped 10 Q. Do you agree with that testimony 11 Deposition of F. William Barton was received 11 A. Yes I do 12 and marked as Deposition Exhibit 11 for 13 identification by the court reporter 14 s+ 15 CONTINUATION 12 Q. Okay 13 Then it says question what you're 14 indicating is the finished material the woven lining 15 would be roughly fifty percent asbestos contained 16 BY MR HUGHES 17 Q. I mentioned earlier the deposition 16 17 Maybe less Answer about that I suppose 18 of William Barton from 1995 18 19 I put a copy in front of you 19 Is that what it says A. Yes 222222 A. Okay 222222 Q. First of all have you ever seen 222222 this deposition before 222222 A. Yes I have 222222 Q. Okay Go to page 15 222222 A. Okay 20 Q. Okay 21 First question do you agree that 22 that's the percentages back in the 30's and 40's 23 MR HAMILTON Objection to the 24 = form 25 MR BOUCH Calls for speculation : 1 Q. Okay Page 103 1 THE WITNESS Page 105 I wouldn't have any 2 Now at the top of the page do you 2 idea but -- : 3 see where it says question do you know back in the | 3 4 1930's and 40's what the percentage of asbestos was | 4 CONTINUATION 5 that was used in the linings 5 BY MR HUGHES --- 6 At the top of the page 7 Do you see that question 8 A. Do you know back in the 30's and 9 40's what the percentage of asbestos that was used 10 in the linings 6 Q. Okay 7 Was the formula for the woven rolls 8 of lining ever changed over the years or no 9 MR HAMILTON Objection to the 10 form 11 Yes 11 12 Q. Okay 12 13 Then it says answer well it was 13 14 a commercial grade asbestos which is 75 percent 14 You can answer THE WITNESS Could you ask that MR HUGHES Yeah --- 15 asbestos 25 percent organic could be cotton or 15 CONTINUATION 16 something else 16 BY MR HUGHES 17 Right 18 A. Yes 19 Q. Then he says now in the finished 20 material that could only be finished with about 21 50 percent of the 75 in the finished material by 22 weight because there are resins and things of that 23 nature in it 17 Q. Do you have any knowledge as to what 18 the formula was -- what the stuff was that was put in 19 the woven lining say in the 1950's 20 A. I wouldn't have any idea 21 Q. 22 23 50's on Okay Do you know if it changed from the 24 A. Yes 25 Q. Okay 24 A. From the 50's on 25 No. Probably uncharged Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 106..109 Page 106 1 Q. Did it change -- okay 1 2 All right 2 3 Going back to Exhibit 3 4 A. Okay 4 5 Q. Okay 5 6 Second page of Exhibit -- 6 7 A. Okay 7 8 Q. -~ it says at the top left effects 8 9 of " overexposure 9 10 Underneath it's typed in suspected | 10 11 carcinogen correct 11 12 MR BOUCH Objection to the form 12 13 Documents speaks for itself 13 14 THE WITNESS Yes It says that 14 15 -- 15 16 = CONTINUATION 16 17 BY MR HUGHES 17 18 Q. Okay 18 19 And then what does it say below that | 19 20 for emergency and first aid procedures 20 21 A. Where do you see that 21 22 Oh right there Oh yeah 22 23 Avoid breathing dust Use approved | 23 24 respiratory mask 24 25 Q. Okay 25 Page 108 And for respiratory protection it says avoid creating dust correct A. Avoid creating dust yes Q. Use adequate ventilation correct A. Yes Q. Okay Tell me what steps if any Reddaway took to avoid creating dust and have adequate ventilation in the plant A. If we ever -- if we ever -- when we had to cut the lining we had a vacuum system Q. Okay When did the vacuum system come into effect if you know A. I don't have any idea on that Before 172 Q. Was it before 1972 A. Yeah Q. Okay Do you know how long before A. I have no idea It could have been at 172 or -- or before information I wouldn't have any of that Q. Okay Do you know what the nature of the Page 107 Page 109 1 And when OSHA came in the early 1 vacuum system was when it was installed 2 70's did Reddaway institute a policy requiring some | 2 A. What do you mean the nature of it 3 of its workers to wear respiratory masks 3 Q. Well what was it -- 4 5 form MR HAMILTON Objection to the 4 5 A. A big -- Q. -- a vacuum cleaner 6 THE WITNESS Yes we did But we 7 were under the limit We didn't have to but just 8 you know as a safeguard -- 9 MR HUGHES Okay 10 THE WITNESS -- they did issue them 6 A. 7 Q. 8 9 10 ceiling No. They are big dust collectors Okay Just help me out Describe them Are they in the walls In the 11 and have them wear them 12 To this day we still do 13 -- 14 CONTINUATION 11 A. No. Big -- they stand up Big -- 12 big metal dust collectors with a lot of bags inside 13 of them individual bags They were standard in the 14 industry 15 BY MR HUGHES 15 Q. Okay 16 Q. Okay 16 A. So when you cut the material there 17 What's -- do you know the purpose of 17 was virtually no dust 18 the respiratory mask 18 Q. Okay | 19 A. Keep dust -- dust out of your lungs 19 A. The system ran to eat -- any saw 20 Q. Okay Let's see 20 that we would have there would be a hose going right 21 Down towards the bottom of the page | 21 up to it right at the point where the blade would 2222 you see where it says Section VIII special 22 meet the lining 2222 protection information 222 Q. Say that again 2222 A. Okay Yes 2222 Q. Okay 222 A. There would be like a big -- big 25 inch vacuum hose that would go right up to where Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 110..113 Page 110 | 1 the blade would -- would -- would interact with the i1 Page 112 A. I guess part of the OSHA regulations 2 lining So there was virtually no dust ' 2 wanted you to do this and submit it to them 3 Q. Okay Okay 4 At some point was a water mist 5 system or a water mist weaving steel system 6 installed 7 A. 8 9 you these 10 Weaving steel MR HUGHES Let me -- let me show tied 3 Q. Okay 4 A. We did whatever they required 5 Q. Okay 6 And then it says air sampling 7 ~~ count done by outside hygienist 8 In other words Reddaway would bring 9 someone in do the sampling right 10 A. Yes 11 At which time Reddaway 11 Q. Okay 12 Manufacturing Company Inc.'s Response to 12 And the last one is what I was 13 Plaintiff's Interrogatories and Request for | 13 referring to you earlier quote water mist 14 Production of Documents Set 1 was received 14 installed by weaving steel unquote 15 and marked as Deposition Exhibit 12 for 15 Do you see that 16 identification by the court reporter 16 A. Yeah I don't know -- 17 --- 18 MR HAMILTON Number 12 19 COURT REPORTER Yes 20 --- 21 CONTINUATION 22 BY MR HUGHES 17 Q. Do you know what that means 18 A. We have a water mist system -- 19 Q. Okay 222222 A. -- you know over the looms I 21 don't know what that weaving steel means 222222 That must be an error 23 Q. Looking at Exhibit do these 23 24 appear to be Redco Responses to Interrogatories and 222222 Q. It could be a typo A. Yes 25 Requests for Production in a case called Gipp -- 222222 Q. Something that was dictated 1 A. Yes Page 111 1 Page 113 So there is a water mist system 2 Q. -- in North Dakota 2 A. Yes 3 A. Yes they do 4 Q. Okay 5 Look at page 14 3 Q. Okay 4 Tell me about that system 5 How does it work 6 A. Okay 7 Q. All right 8 Question number 49 asks about 9 asbestos dust monitoring tests 10 Do you see that 11 A. Yes 12 Q. Okay 13 And then it says am I correct 14 looking at this response air sampling for asbestos 15 dust started in 1978. 16 A. Yes I see that 17 Q. Okay 18 And it was done once a year right 6 A. Basically what it's for it 7 lubricates the yarn going in because all of the 8 strands -- these 4000 strands of yarn are all going 9 into the front of a machine So this is over the 10 top of it -- 11 Q. Okay 12 A. -- and it would keep -- it would 13 keep any dust down but it was also a lubrication 14 It did two different things 15 Q. Okay 16 Do you have any idea when the water 17 mist system was installed 18 A. No idea 19 A. Yes 20 Q. Okay 19 Q. Okay 20 Do you know if it could have been 21 When it says results submitted to 21 before 1972 22 OSHA 23 24 A. 25 Q. Do you see that Yes What does that mean 22 A. It could have been in the 40's 23 I have no idea 24 Q. Okay 25 The purpose of the water mist -- Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 114..117 1 what is the purpose of it if you know Page 114 1 with that statement Page 116 2 A. It -- it would keep any dust down 12 A. No I don't 3 and lubricates the yarn as it goes through the 4 machine 5 Q. Okay 6 And when you came in 1987 it was 7 already installed 8 A. Yes 9 Q. Okay 3 Q. Okay 4 But I take it from your testimony 5 you don't know why the dust collector -- or do you 6 know why the dust collector system was put in 7 MR BOUCH Object to the form 8 THE WITNESS Witness shakes head 9 --- 10 Go to page 22 on those responses 11 MR HAMILTON I would just like to 12 ask I don't see a Bates number on these 13 Are these from our production or 14 from someplace else 15 MR HUGHES I don't remember 16 17 18 remember MR HAMILTON Okay MR HUGHES Sorry I really don't 2222222 THE WITNESS Okay 22 10 CONTINUATION 11 BY MR HUGHES 12 Q. Okay 13 If the dust collection system was 14 put in in the late 40's or early 50's would it be 15 fair to say that Reddaway must have had some 16 awareness of dust hazards 17 A. No. 18 MR HAMILTON Objection to form 19 me 2222222 MR HUGHES These might -- off the 20 CONTINUATION 2222222 top of my head I think that this particular copy I 21 BY MR HUGHES 2222222 got from other plaintiff's lawyers but I think that / 22 Q. Why not 2222222 you all produced the same thing -- 23 A. Absolutely not 2222222 MR HAMILTON Okay 24 It's -- you know if you are cutting 2222222 MR HUGHES -- Bates numbered 25 wood in a wood shop there is no hazards to that but Page 115 Page 117 1 MR HAMILTON We'll check to that 1 people always -- you know you can't be working you 2 extent I will object but I will check that 2 know with stuff flying around So you always have 3 MR HUGHES Okay 3 a dust collector system 4 I also can tell you you all did , 4 It has nothing to do with knowing 5 produce a bunch of interrogatory responses and they 5 anything about asbestos It would be with anything 6 were pretty much the same 6 even you know we -- we make crates We make all 7 7 -- 7 our own We have the same stuff in there from the 8 CONTINUATION 8 40's Same -- same type of dust collection system 9 BY MR HUGHES 9 whether we're cutting brake lining or cutting wood to 10 Q. But anyway on page 22 this is what | 10 make our crates 11 I was referring to earlier to you 12 Do you see where it says question 11 Q. Do you know why the dust collection 12 system was installed 13 72A at the top of the page 14 A. Yes 15 Q. And it's asking about a dust 16 collection system 17 A. Yes 13 A. Do I know why 14 Q. Yeah 15 MR HAMILTON Object to the form 16 THE WITNESS I really don't know 17 how to answer that 18 Q. Okay 18 --- 19 And then in terms of when the system 20 came in the answer says late 1940's or early 21 1950's 22 Do you see that 23 A. Yes 24 Q. Okay 25 Do you have any reason to disagree 19 CONTINUATION 20 BY MR HUGHES 21 Q. Okay 2222 Do you know if one reason why it was 2222 installed could have been to reduce dust 2222 MR BOUCH Objection 2222 MR HAMILTON Objection to the Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 118..121 1 form 2 3 Page 118 1 Q. THE WITNESS Could have been 2 - +e 3 doing that Okay If you know Page 120 why did Reddaway start 4 CONTINUATION 4 A. OSHA required it in 1972 5 BY MR HUGHES 5 Q. Okay 6 Q. Okay 6 And do you have any understanding of 7 And does that -- is that what a dust 7 why OSHA required it 8 collection system does it reduces dust 9 A. It reduces dust 8 9 form MR HAMILTON Objection to the 10 Q. Okay 10 11 Do you know one way or the other 11 12 whether Reddaway had any awareness of asbestos 12 13 dangers in the 40's or 50's 13 14 A. No. 1972 14 15 MR BOUCH Object to the form 15 16 ~- 16 17 CONTINUATION 17 18 BY MR HUGHES 18 THE WITNESS Why they required it MR HUGHES Yeah THE WITNESS I think -MR HAMILTON If you know MR HUGHES If you know THE WITNESS I don't know MR HUGHES Okay Pause --- 19 Q. Now Reddaway's position is they 19 20 first learned of the dangers in 1972 20 21 A. Yes That's when it all came out 21 22 Q. What's your basis for believing 22 23 Reddaway first learned of the dangers in 1972 23 24 A. 25 stuff That's when OSHA published all their | 24 25 At which time a U.S Department of Labor Material Safety Data Sheet Reddaway Mfg Co. Inc. was received and marked as Deposition Exhibit 13 for identification by the court reporter --- MR HUGHES All right 1 Q. Okay Page 119 1 2 Have you spoken to folks at Reddaway | 2 3 that told you that 3 MR BOUCH 13 MR HAMILTON Yes - oe Page 121 4 A. Oh yeah 4 CONTINUATION 5 Q. Who did you talk to 5 BY MR HUGHES 6 A. Bill Barton Warren Conway 7 Q. Okay 8 Pause 9 Q. Okay 10 Page 15 of those responses 11 A. 15 Okay 12 Q. Okay 6 Q. Okay 7 Looking at Exhibit first let me 8 ask you to page through it 9 It's a collection of documents 10 My first question is have you seen 11 any of these documents before 12 A. Yes 13 14 51 15 I'm looking at response to number Did there come a time when Reddaway 13 Q. Okay 14 Starting at the first page at the 15 bottom right it says Reddaway 1294 16 began giving the employees annual physical check | 16 A. Yes Yes 17 A. Starting in 1972 18 Q. Okay 17 Q. Okay 18 Do you know what that document is 19 And that included chests rays -- 19 MR BOUCH Objection 20 A. Yes 20 Document speaks for itself ~~ 21 Q. -- and pulmonary function tests 21 THE WITNESS Material Safety Data 2222 A. Yes 22 Sheet 2222 Q. And the results would actually be 23 --- 2222 given to the employees right 24 CONTINUATION 25 A. Yes 25 BY MR HUGHES Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 122..125 1 Q. Okay Page 122 1 BY MR HUGHES 2 Can you tell what product this is 2 Q. Or is it 3 A. Redco RBW 3 A. I'm not sure Page 124 4 Q. Okay 5 So would this data sheet -- the 6 first page of Exhibit be for the same product as 7 the MSDS sheet in Exhibit 8 A. Where's Exhibit 9 Where's 10 10 Q. Here You can have my copy 4 Q. Okay 5 Well let me ask you this 6 The one -- the document at Reddaway 7 1296 can you tell what the date is of this MSDS 8 document on the top right 9 A. Not on this sheet It says date 10 prepared November 15th 1987 11 A. I got it 12 Q. You got it 13 A. Right 11 Q. Okay 12 What does that mean if you know 13 A. The date -- the date this sheet was 14 Q. So would you agree that both of 14 prepared 15 these MSDS sheets say they're for Redco RBW 15 Q. Okay 16 A. Let's see 16 And does that have -- is that Ed 17 Yes 17 Eggert's name under there 18 Q. Okay 18 A. It looks like it 19 The MSDS sheet at Exhibit do you | 19 Q. Okay 20 have any understanding of when this MSDS sheet is 20 And Ed Eggert was at Reddaway for a 21 issued 21 period of time 22 Pause 22 A. Yes 23 A. Well if you go back to 1296 it 24 says date prepared November 15th 1987 25 Q. Okay 23 24 | 25 Q. He was at Reddaway as of 1987 Is that right A. Yes Page 123 1 And that's where I will get that in 1 2 this collection of documents 2 Q. Okay . Page 125 And then it talks about -- it 3 Reddaway Okay 3 mentions asbestos at Section II 4 If you look at Reddaway which 5 is the top page notice how at the top left it has 6 Section I and then it says Section II -- 7 A. Yes 8 Q. -- Section III 9 Okay 10 And then the next page Reddaway 11 1295 goes on Section V VI VII right 12 A. Yep 13 Q. Okay 14 Then if you go to Reddaway 1296 it 15 starts over again with Section I right 16 A. Yes 17 Q. Okay 18 So does it appear that Reddaway 19 1296 is the first page of another Material Safety 20 Data Sheet 21 22 form MR HAMILTON Objection to the 4 Do you see that 5 A. Section II yeah asbestos 6 Q. Okay 7 I guess my question is if the 8 company switched to asbestos in November of 1986 9 can you walk me through why we have this MSDS 10 document that says '87 asbestos 11 A. Customers could still have some and 12 need -- need to post this safety data sheet 13 People could have asked for this 14 sheet for years afterward because they had -- they 15 had to do what OSHA said and they had to post it to 16 protect their employees 17 Q. Okay 18 So are you saying in 19 -- what 19 you're saying is in 1987 you could have a customer 20 that bought the asbestos rolls earlier 21 A. Yeah Could have bought them in -- 22 in 1986 -- 23 24 25 CONTINUATION Pause --- 23 MR BOUCH Objection to form 24 MR HUGHES Okay 25 THE WITNESS -- for the oil field Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 126..129 Page 126 1 and they needed a Material Safety Data Sheet just 1 2 because maybe an employee asked them something about | 2 3 it because now the awareness was throughout all -- 3 4 all industries 4 5 MR HUGHES Okay 5 6 THE WITNESS That wasn't uncommon 6 7 8 9 CONTINUATION 10 = BY MR HUGHES MR HUGHES All right --- 7 8 _ |9 10 11 Q. Was there any chance that Reddaway 11 12 was selling asbestos lining out of stock in November 12 13 1987 13 14 MR BOUCH Objection to form 14 15 MR HAMILTON Objection to the 15 16 = form 16 17 THE WITNESS I wouldn't -- I 17 18 wouldn't have that information 18 19 MR HUGHES Now -- 19 222222 THE WITNESS I -- oh no I was 20 222222 there yeah No there was no asbestos -- 21 A. Yes I just saw that Page 128 Q. Okay Then on the -- on Reddaway 1297 which is the next page -- A. Okay Q. All right -- am I correct that at Section IV I think it says quote increased risk of asbestosis and mesothelioma unquote A. Yes Q. statement And does Reddaway agree with that form MR HAMILTON Objection to the MR BOUCH Objection to the form THE WITNESS That's what we are required to put on by OSHA MR HUGHES Okay THE WITNESS It's not for us to challenge them 7 222222 MR HUGHES Okay 222222 THE WITNESS -- in -- in November 222222 of 187. I worked for the company then 222222 MR HUGHES Okay 22 CONTINUATION 23 BY MR HUGHES 24 Q. Okay 25 Do you -- sitting here today would 1 So -- Page 127 1 2 THE WITNESS Yeah 2 There was absolutely no asbestos on 3 4 that date So it would be impossible on -- on 4 5 November 1987 for Reddaway to sell any asbestos as | 5 6 there wasn't any there 6 7 7 -- 8 CONTINUATION 8 9 BY MR HUGHES 9 10 Q. Okay 10 11 So what you're saying tell me if 11 12 reading -- tell me if I'm understanding you 12 13 correctly this MSDS sheet it is dated 1987 but it | 13 14 would apply to RBW that was sold -- 14 15 A. Yeah 15 16 Q. -- earlier -- 16 17 MR BOUCH Objection to form 17 18 MR HUGHES -- right 18 19 THE WITNESS Yes 19 20 MR HUGHES Okay 20 21 - 21 22 CONTINUATION 22 23 BY MR HUGHES 23 22 Q. And on the top left it does say 24 25 Redco RBW 25 you dispute that statement MR HAMILTON form Page 129 Objection to the idea THE WITNESS I wouldn't have any MR HUGHES THE WITNESS Okay I'm not a doctor 7 CONTINUATION BY MR HUGHES Q. All right And then the next page which is Reddaway 1298 in which -- A. Q. at Section 1 Okay Okay Does this appear to start over again A. Wait a minute Where are you at on -- Q. next page Hang on Reddaway 1298. It's the This says Material Safety Data Sheet at the top right -- A. Yes Q. - but this one says Raymark Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 130..133 Page 130 : Page 132 1 A. Yes this isn't ours 1 product type woven That's all I see on it 2 Witness indicating 2 Q. Okay 3 Q. Okay 3 And your testimony is this is -- 4 But this was produced by you all 4 this product was never bought from Raymark by 5 Do you have any understanding of how 5 Reddaway 6 Reddaway ended up with this document 7 A. I'm trying to see what -- what it 6 A. Not by -- no we never purchased 7 this product 8 actually is 9 10 Okay It's a heavy duty woven lining an 8 Q. Okay 9 A. We may have had it you know as a 10 comparison or something 11 M2010 We never -- it's a Raymark part We never 11 12 bought that from them I have no idea 12 13 Q. Okay 13 Q. Okay A. It's hard to tell why we had it MR BOUCH Objection to form 14 So let's see 14 --- 15 Top left it says Raymark and that 16 was the subsequent name of Raybestos 17 Is that right 18 A. Yes 2222222 Q. Okay 2222222 A. This is their sheet 2222222 Q. Okay 2222222 It's their sheet 2222222 It is not Reddaway's right 2222222 A. Yes 2222222 Q. But Reddaway produced it in this 15 CONTINUATION 16 BY MR HUGHES 17 Q. The Raymark product the M2010 18 would this have been a product that competed against 19 -- 20 A. I've never even heard of 2010 21 Q. Okay 22 A. I have no idea what it is 23 Q. Okay 24 A. It says it's heavy duty woven but 25 I've never heard of that number 1 case right Page 131 1 23 A. Did we 2 23 Q. I mean it's Bates numbered with the 3 4 Reddaway at the bottom right -- 4 5 MR HAMILTON Yeah so -- 5 6 MR HUGHES - right 6 7 THE WITNESS Yeah 7 7+ Page 133 At which time a U.S. Department of Labor Material Safety Data Sheet Reddaway Mfg Co. Inc. was received and marked as Deposition Exhibit 14 for identification by the court reporter) -- 8 7s 9 CONTINUATION 10 BY MR HUGHES 11 Q. Do you know if this document came 12 from the business records of Reddaway 13 A. I have no idea 14 MR HAMILTON We'll represent that 15 it came from the records of Reddaway 16 MR HUGHES Okay 17 -- 18 CONTINUATION 19 BY MR HUGHES 20 Q. Let's see 22222 Now it says on the hand side 22222 material number M2010 8 CONTINUATION 9 BY MR HUGHES 10 Q. Okay Exhibit 11 Have you seen this document before 12 A. Yes It's a Reddaway Material 13 Safety Data Sheet 14 Q. Okay 15 On the bottom right does it 16 indicate that the form was revised in March of 1984 17 A. Yes OSHA -- 18 MR HAMILTON Objection to the 19 form 20 THE WITNESS OSHA was the one who 21 ~~ revised these forms 22 --- 22222 22222 ~~ that mean 22222 A. From your prior answer what does I just looked over and it says 23 CONTINUATION 24 BY MR HUGHES 25 Q. Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 134..137 Page 134 | 1 So presumably am I right that 1 2 this Reddaway document -- I guess the earliest it 2 Recess was taken at this time --- Page 136 3 could have dated it would have been March of 184 4 MR BOUCH Objection to form 5 - + 3 VIDEO TECHNICIAN This begins tape 4 number three of the videotape deposition of Todd 5 Walker 6 CONTINUATION 7 BY MR HUGHES 8 Q. Is that right 6 The time is 12:55 7 We're on the record 8 i 9 A. I don't have any idea 9 CONTINUATION 10 Q. Okay 11 You don't have any idea of the date 12 of this form 13 A. There's no date on it no 10 BY MR HUGHES 11 Q. Mr. Walker was there ever an MSDS 12 sheet for the RNAW product 13 A. Yes 14 Q. Okay 15 And do you know if there is a second 16 page to this form somewhere 17 A. I wouldn't know that either 14 Q. When was that MSDS sheet first 15 issued if you know 16 A. I wouldn't know -- I wouldn't know 17 that 18 Q. Okay 18 Q. Does Reddaway have a copy of the 19 But this appears to be another MSDS 19 MSDS sheet for the RNAW 222222 Sheet for the Redco RBW 222222 MR HAMILTON Objection to the 20 A. Yes It would be a current one 21 Current date 222222 form 222222 222222 it 222222 This doesn't have a Bates stamp on MR HUGHES I know but it was -- 22 Q. Does Reddaway have any of the 23 historical MSDS sheets for the RNAW 24 A. 25 came out They're destroyed after the new ones 1 it was Deposition Exhibit from the old -- Page 135 1 23 4 5 RBW MR HAMILTON Okay 2 MR HUGHES -- Walker deposition 3 THE WITNESS It says it is Redco 4 5 6 MR HUGHES Right and it also says 6 7 50 percent asbestos 7 8 THE WITNESS It says the same as 8 9 the other sheet 9 10 MR HUGHES Okay Okay 10 11 Let's go off for a sec 11 12 VIDEO TECHNICIAN Off the record 12 13 Time is 12:27 13 14 --- 14 15 Recess was taken at this time 15 16 --- 16 17 VIDEO TECHNICIAN Back on the 17 18 record 18 19 The time is 12:27 19 20 It's 12:27 20 21 We're going off the record for 21 22 lunch Also ending this tape 22 222 The time is 12:27 23 222 We're off the record 24 222 oo 25 Q. Okay Page 137 MR HUGHES I'd asked that you all produce the new one for what it's worth --- At which time Reddaway Labels were received and marked as Deposition Exhibit 15 for identification by the court reporter ie that MR HAMILTON We'll take a look at MR HUGHES Thank you - 7 CONTINUATION BY MR HUGHES Q. Number All right You have been handed Exhibit This is a series of documents that was produced by Reddaway and if you look at the first three pages appear -- appear to show three different forms of the caution label A. Yes Q. Okay Do you know which one of these forms would have been the caution label that was put on the Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 138..141 1 rolls of -- the RBW brake lining Page 138 1 Page 140 So this was the Raybestos or 2 A. It would have been all of them 2 Raymark molded lining that Reddaway resold 3 Q. Explain 3 A. Yes 4 5 time 6 A. They weren't all put on at the same No. Depending on the size of the 4 Q. Do you know if this MSDS sheet had 5 other pages aside from the page we're looking at 6 A. I wouldn't know that 7 roll 8 Q. 9 A. Okay Smaller label for the smaller rolls 7 Q. Okay Okay 8 In the MSDS sheets for the RBW for 9 example if we go back to Exhibit -- 10 Q. Okay 10 A. Okay | 11 Just out of curiosity the last page 11 Q. -- my question is where it says 12 here do you know what that is 12 50 percent asbestos 50 percent aromatic 13 A. Yes That was the tag of where it 14 was shipped to that was sewn on the burlap 13 hydrocarbons if you know how did Reddaway go about 14 getting that information 15 That's why it has a hole in it 15 How did Reddaway go about figuring 16 Q. Okay 16 out the percentage of asbestos in the Redco RBW 17 Now is that different from the 17 A. I don't have that information 18 rectangular label that we saw on the picture 19 A. Yeah That's -- that's -- on the 20 picture that's telling you the size of the lining 21 and the warning label and this is actually on the 18 Q. Okay 19 So you don't know if Reddaway got 20 that from one of the suppliers of the yarn or -- 21 A. I would have no idea 22 outside of the burlap to show the shipping company 23 where to send it where to take it 24 MR HUGHES Okay 25 - 22 Q. Okay 23 But you're not aware of any tests of 24 samples that Reddaway -- 25 A. No. Page 139 1 Page 141 At which time a U.S. Department of 1 Q. The -- the product the RBW lining 2 Labor Material Safety Data Sheet Reddaway 2 and then the RNAW the asbestos do you know what 3 Mfg Co. Inc. was received and marked as 3 the color was of each of those products 4 Deposition Exhibit 16 for identification by 4 A. Looked very similar Tannish color 5 the court reporter 5 Q. So there was not a marked color 6 --- 6 difference between the asbestos and the asbestos 7 CONTINUATION 7 versions 8 BY MR HUGHES 8 A. No. 9 Q. Exhibit I believe this is 9 10 another MSDS sheet 10 MR HUGHES Okay 7 11 A. Yes 11 At which time a Letter from 12 Q. Okay 12 Friction Material Standards Institute Inc. 13 Have you seen this document before 13 dated November 6 1972 was received and 14 A. Yes I have 14 marked as Deposition Exhibit 17 for 15 Q. Okay 15 identification by the court reporter 16 Can you tell which product this MSDS / 16 --- 17 sheet was for 17 CONTINUATION 18 A. It was for Raybestos flexible 18 BY MR HUGHES 19 molded 20 Q. Okay 21 So this -- and it says Redco RFM 2222 at the top right 2222 A. Yes It says Redco and then RFM 2222 Raymark Flex Molded 2222 Q. Okay 19 Q. Exhibit 20 Have you seen this document before 21 A. Yes I have 22 Q. What is it 23 A. It's a document -- it's a document 24 from Friction Materials Standards Institute 25 Q. Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 142..145 Page 142 144 1 And was Reddaway a member of the Page 1 subsequent operations will be performed - cutting 2 FMSI for a period of time 2 grooving drilling and grinding unquote 3 A. Yes they were 3 Do you see that 4 Q. Okay 4 A. Yes 5 What period of time were they a 5 Q. Okay 6 member of the FMSI 7 A. I don't have that information 6 Is it correct that the Reddaway 7 woven roll lining that some of the users of that 8 Q. Okay 8 lining might have been cutting grooving drilling or 9 Is there a date on Exhibit 9 grinding it 10 A. Yes It says November 6th 1972 10 MR BOUCH Objection 11 Q. Okay 11 MR HAMILTON Objection to the 12 And does it indicate who this 12 form 13 document -- what does it say the document is to on 13 -- 14 the top left 15 A. To Delegates and Alternates 14 = CONTINUATION 15 BY MR HUGHES 16 Asbestos Study Committee 16 Q. Is that correct 17 Q. Okay 17 A. That's correct 18 Do you know if Reddaway was a member | 18 Q. Okay 19 of the FMSI as of 1972 19 Given the lining was sold in rolls 222222 A. In 1972 they were a member 20 did Reddaway expect that end users of the product 222222 Q. They were a member 21 would cut pieces of the lining off the roll to use 222222 A. Witness nods 22 it 222222 Q. Okay 222222 Was this a document that Reddaway 222222 received from the FMSI in 1972 23 24 ~ form 25 MR HAMILTON Objection to the MR BOUCH Objection to form 1 A. Yes Page 143 1 THE WITNESS Yes Page 145 2 Q. Okay 2 3 On the top left under two on the 3 MR HUGHES ~- Okay 4 first page this says to Delegates and Alternates 4 CONTINUATION 5 Asbestos Study Committee 5 BY MR HUGHES 6 Do you see that 7 A. Yes 8 Q. Okay 6 Q. And grooving -- where it says 7 grooving on Exhibit do you have any understanding 8 of what that means 9 Was Reddaway a member of the 10 Asbestos Study Committee of the FMSI 9 A. 10 cut in it Just put a grove in the lining a 11 A. I don't have any idea on that 11 Q. Okay 12 Q. Okay 12 Would that be to make it fit on 13 You don't know one way or the other 14 A. No. 15 Q. Okay 16 Where it says Delegates and 17 Alternates -- Delegates and Alternates do you know 18 what that means 19 A. Not really 20 Q. Let's see 13 brake or do you know 14 A. It could be grooved to run in oil -- 15 Q. Okay 16 A. -- drilling 17 Q. For example would you have expected 18 some of Reddaway's end users of the lining to drill 19 holes in the lining in order to fix it under a brake 20 band 21 In the middle of the page - 21 22 A. Okay 22 ~~ form 23 Q. -- it says quote the problem in 23 24 this case is the shipment of asbestos containing 24 25 brake linings or clutch facings where in many cases | 25 MR HAMILTON Objection to the THE WITNESS Yeah MR BOUCH Object to form THE WITNESS It could be drilled Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 146..149 Page 146 1 A lot of people have glued it on Page 148 1 don't have applications or anything like that 2 MR HUGHES Okay 2 MR HUGHES Okay 3 THE WITNESS Either way 3 --- 4 ~-- 5 CONTINUATION 6 BY MR HUGHES 7 Q. And the lining -- tell me what your 8 understanding was of the industrial uses for the RBW 9 lining 10 MR BOUCH Objection 11 MR HAMILTON Object to the form 12 THE WITNESS Industrial 13 --- 14 CONTINUATION 4 CONTINUATION 5 BY MR HUGHES 6 Q. 7 equipment 8 9 form Could it be used for mining MR HAMILTON Objection to the 10 MR BOUCH Objection to the form 11 THE WITNESS Like I said I 12 wouldn't have any idea where they used it 13 MR HUGHES Okay 14 --- 15 BY MR HUGHES 16 Q. Yeah 17 To start with it was not used for 18 cars or trucks in the normal course right 19 A. Yes it was not 222222 Q. Okay 15 16 17 18 19 20 At which time an Affidavit of Todd W. Walker President of Reddaway Manufacturing Company Inc. was received and marked as Deposition Exhibit 18 for identification by the court reporter --- 222222 It could have been used for 22 something like an emergency brake 222222 222222 222222 form MR BOUCH Objection MR HAMILTON Objection to the 21 MR HUGHES You've been handed -- I 22 think that's 18 23 COURT REPORTER Yes 24 THE WITNESS Yes 25 - Page 147 1 --- 1 CONTINUATION Page 149 2 CONTINUATION 2 BY MR HUGHES 3 BY MR HUGHES 4 Q. 5 A. 6 Q. 7 A. 8 Q. 9 10 form Is that correct Emergency brake on what On heavy equipment -- It could -- like an earth mover MR HAMILTON Objection to the 11 THE WITNESS Yes 12 MR HUGHES Okay 13 77 14 CONTINUATION 3 Q. If you can look it over 4 My first question is is this an 5 affidavit that you signed back in 197 6 A. Yes it is 7 Q. Okay 8 Look at paragraph three 9 A. Reading document 10 Q. Do you see where it says that 11 Reddaway manufactures industrial brake linings and 12 clutch linings for such uses as mining equipment 13 winches hoist brakes and steam shovel brakes 14 A. Yes 15 BY MR HUGHES 16 Q. Tell me what other uses if you 17 know would the RBW lining have had 18 MR HAMILTON Objection to the 19 form 20 Are you asking him 15 Q. Okay 16 VIDEO TECHNICIAN Off the record 17 The time is 1:07 18 Pause 19 VIDEO TECHNICIAN Back on the 20 record 1:08 21 THE WITNESS I really don't know 21 ~~ 22 We sold it We wouldn't know where our customers 23 would use it 24 MR HUGHES Okay 25 THE WITNESS We wouldn't -- we 22 CONTINUATION 23 BY MR HUGHES 24 Q. The uses that I just noted on 25 paragraph three of your affidavit -- Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 150..153 1 A. Yes Page 150 1 Q. What kind Page 152 2 Q. -- was the RBW roll lining used for 2 A. All types 3 any of those uses to your knowledge 3 I mean when we sell to a 4 A. It could be 5 Q. Okay 6 So is it correct that the RBW roll 7 lining could be used for mining equipment 8 MR BOUCH Objection to form 9 THE WITNESS Yes 4 distributor we don't know where it goes or what it's , 5 used in -- 6 Q. Okay 7 A. -- you know there is -- depending 8 where the distributor is if it's -- you know we 9 would have no idea 10 = 23 CONTINUATION MR HAMILTON Objection -- 10 Q. So the RBW could be used for mining 11 equipment winches hoist brakes or steam shovel 12 brakes 23 BY MR HUGHES 13 14 Q. Could it be used for winches 14 Is that right A. Yes 15 A. 16 17 form 18 19 Yes MR HAMILTON Objection to the MR BOUCH Objection to the form MR HUGHES What's the basis for 15 16 17 18 19 CONTINUATION MR BOUCH Objection Asked and answered MR HUGHES Okay --- 20 MR BOUCH Speculation 222222 BY MR HUGHES 21 MR HAMILTON Speculation 222222 Q. How about elevators 2222 MR BOUCH It could be made of 222222 Could it be used for elevators 2222 green cheese I mean -- 23 2222 MR HAMILTON It's not really fair 222222 25 to the witness to ask him to -- once something leaves | 222222 A. Maybe some of the older elevators Q. Okay How about cranes Page 151 1 his hands to speculate what people may or may not 1 2 have done with it He's just trying to be helpful 2 3 but that's not a fair question 3 4 ~ 4 5 CONTINUATION 5 6 BY MR HUGHES 6 7 Q. All right 7 8 In paragraph three of your 8 9 Affidavit tell me which Reddaway products were you 9 10 referring to in sentence one of paragraph three of 10 11 your affidavit 11 12 Pause 12 13 A. What was the question 13 14 Q. Which Reddaway products were you 14 15 referencing in that sentence in your Affidavit 15 16 A. It could be any of the products 16 17 Q. Okay 17 18 So would that include the RBW roll 18 19 = lining 20 A. It could include that too 21 Q. Okay 2222 Sitting here today do you know any 2222 of the uses that people actually used the RBW lining 2222 for 19 20 21 22 | 23 24 2222 A. For brakes 25 form MR HAMILTON Page 153 Objection to the --- CONTINUATION BY MR HUGHES Q. Could it be it used for cranes A. It's hard to tell Cranes are all hydraulic So I really wouldn't know that MR HAMILTON John I'm just trying to -- is it your contention that these were applications used for this particular case I'm really trying to get a sense of -- I don't know think your client in this case alleged any of those uses So I'm really at a loss why you're going into such detail and such length MR HUGHES Tom our allegation is it was used for a range of industrial uses MR HAMILTON That your client says he was involved in those uses MR for our client was HUGHES No. A particular use of course the brake bands on the back stands of the paper machines MR HAMILTON And what's your basis for then looking for the uses beyond what your client said that he used it for -- Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 154..157 Page 154 Page 156 1 MR HUGHES To show -- 1 think They can't just randomly pick whatever and 2 MR HAMILTON -- in this case 2 put -- put it on it 3 MR HUGHES Sure 3 MR HUGHES Okay 4 To show that Reddaway could 4 ie 5 reasonably foresee that its product could be used for | 5 CONTINUATION 6 any range of industrial uses 6 BY MR HUGHES 7 MR HAMILTON I'm going to object 7 Q. Would there have been any kind of 8 to this line of questioning because I just think 8 underlying written agreement governing the sales from 9 it's irrelevant 9 Reddaway to Abex 10 I would appreciate it if you would 10 A. I'm not understanding the question 11 just move on off of that I mean -- because we know 12 what your client said he used it for or thought it 13 was used for and going into all these sorts of 11 Q. I take it that there wasn't any 12 underlying contract that Reddaway signed with Abex 13 A. Nothing in writing no 14 applications just don't see how that is -- that is 14 Q. Okay Got it 15 relevant or -- 16 MR HUGHES Okay 15 Did Reddaway ever buy anything from 16 Abex to your knowledge 17 18 time 19 MR HAMILTON -- a good use of our 17 18 --- 19 A. Wouldn't have any idea Not to my knowledge Q. Okay 20 CONTINUATION 21 BY MR HUGHES 20 Did Reddaway ever sell brake lining 21 to companies called Clark Akin or PEMCO 22 Q. Do you have any understanding of how | 22 A. No never heard of them 23 the brake lining was used with regard to my client 24 A. To how it was used 25 Q. Yeah 23 Q. Okay 24 Do you have any understanding of how 25 an end user would put a piece of the roll lining on Page 155 1 A. You can explain it to me 1 brake Page 157 2 Q. Okay 3 My client alleges that it was used 4 on circular brake bands that were used on the 5 rolls of paper on a paper machine 6 A. Okay 2 A. Could be a variation of different 3 ways 4 Q. Okay 5 Do you know any of the different 6 ways it could be used 7 Q. Would you -- would that -- does that 7 8 sound like what you would expect to be a reasonable 8 9 use of this roll lining 9 A. Could be glued on Q. All right A. Could be riveted on -- 10 11 form MR HAMILTON Objection to the 10 11 Q. Okay A. -~ or it could be bolted on | 12 THE WITNESS See I really wouldn't 12 Q. In order for it to be riveted on 13 know I don't know the machines or -- 13 would someone have to drill holes in it 14 MR HUGHES Okay 15 THE WITNESS -- you know the 16 manufacturer or the spec molded or what they would 17 -- spec what goes on it so -- 18 MR HUGHES Right 14 A. 15 Q. 16 17 18 form Yes they would Okay Could that generate dust MR HAMILTON Objection to the 19 ~ 20 CONTINUATION 19 20 could THE WITNESS I don't think it 21 BY MR HUGHES 21 ~~ 22222 Q. So in other words there might be 22222 drawings that would show -- 22222 MR BOUCH Objection to form 22222 THE WITNESS That's what I would 22 CONTINUATION 23 BY MR HUGHES 24 Q. Okay 25 What about when someone cut the Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 158..161 1 brake lining Page 158 1 the MSDS it does Page 160 2 A. These are -- what size lining are we 2 Q. But you don't know where that 3 talking about 3 information came from right 4 You're just using general lining 4 MR BOUCH Objection to form 5 I mean if you're cutting a little 5 Pause 6 16's piece of lining or a 1/4 inch or 8's no 6 THE WITNESS It was somebody at 7 there's not going to be any dust 7 Reddaway who knew what was in it 8 Q. Okay 8 mt 9 A. It's -- it's -- it's sealed in 9 CONTINUATION 10 phenolic resin 11 Q. Okay 12 So is it your testimony Reddaway 13 doesn't believe any dust could be generated by 14 cutting the roll lining 15 MR HAMILTON Objection to the 16 form 10 BY MR HUGHES 11 Q. Do you know who -- who prepared 12 these MSDS sheet 13 A. No I don't 14 Q. Okay 15 A. I would assume it was Mr. -- 16 Mr. Barton 17 MR BOUCH Objection to the form 18 THE WITNESS See I wouldn't know 19 how they're cutting it 20 They could shear it 21 MR HUGHES All right 22 THE WITNESS Big metal shear 222 MR HUGHES Okay 222 --- 25 CONTINUATION 17 Q. You know whether Reddaway ever 18 purchased yarn from the Thedford D 19 area of Canada 20 21 = form 22 MR HAMILTON Objection to the THE WITNESS Never heard of that 23 MR BOUCH Well that would send 24 35 years of litigation on its end if Thedford 25 produced yarn 1 BY MR HUGHES Page 159 1 2 Q. Do you know whether Reddaway ever 2 3 purchased asbestos yarn from any suppliers outside of | 3 4 the U.S 4 5 MR HAMILTON Objection to form 5 6 THE WITNESS I have no idea on 6 7 that 7 8 MR BOUCH Objection to the form 8 9 MR HUGHES Okay 9 10 aii 10 11 = CONTINUATION 11 12 BY MR HUGHES 12 13 Q. If you go back to Exhibit which 13 14 is one of the MSDS sheets -- 14 15 A. Okay 15 16 Q. -- does that MSDS sheet indicate 16 17 chrysotile asbestos on the hand side 17 22222222 A. Yes it does 18 22222222 Q. Do you know where Reddaway got that 19 22222222 information 20 22222222 A. I wouldn't have any idea 21 22222222 Q. Okay 22 22222222 Do you know whether the Redco RBW 23 24 actually had chrysotile in it or not in every case 24 22222222 A. It shows on -- well if it shows on 25 MR HUGHES Page 161 I'm just going -- I'm just going by what Mr. Eggert said in his deposition MR BOUCH Just stating it MR HUGHES Let's see --- CONTINUATION BY MR HUGHES Q. Is there anybody alive today who would have personal knowledge of where Reddaway got its yarn when they were using asbestos MR BOUCH Objection to form THE WITNESS No there's not MR HUGHES Okay --- CONTINUATION BY MR HUGHES Q. When Abex received the rolls from Reddaway does Reddaway have any knowledge or information as to what Abex did with it A. We wouldn't have any idea Q. Okay So Reddaway doesn't know what Abex may have done or not done in terms of putting that slip logo on it A. We wouldn't have any -- once it left Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 162..165 Page 162 1 our plant with the warning labels on it I wouldn't 1 CONTINUATION Page 164 2 have any idea where it went where it was used or 2 BY MR HUGHES 3 what happened to it 3 Q. If you go -- all right 4 Q. Okay 5 Pause 4 If you go halfway down the first 5 page of the -- where it says Reddaway 516 -- 6 se 6 A. Yes 7 At which time an Abex Corporation 7 Q. Okay 8 Handwritten Account Payable Log was received | 8 ~~ you'll see a handwritten invoice 9 and marked as Deposition Exhibit 19 for 9 number 34188 and I'm pointing to where it is on my 10 identification by the court reporter 10 copy 11 - 7 11 Do you see that 34188 12 CONTINUATION 12 A. Let's see 13 BY MR HUGHES 14 Q. Looking at Exhibit can you tell 15 me what that is 16 A. This is a card file that they had 17 years ago in the office which is still in the 18 office which we supplied you with this -- 19 Q. Yes sir 20 A. -- and this would be sales to Abex 13 Oh yeah Yeah I see 14 MR HAMILTON That is 15 November 23rd right 16 MR HUGHES Yeah 17 MR HAMILTON There's the dates on 18 the other side 19 MR HUGHES Yes 20 THE WITNESS Yes Those are 21 Q. Okay 22 So the first page what year or 222 years of sales is that first page 222 A. 1983 21 invoice numbers 22 23 CONTINUATION 24 BY MR HUGHES --- 222 Q. Okay 25 Q. Okay Page 163 Page 165 1 And so -- let's see 1 And actually that might be March 2 So first it has a date right 2 Does that appear to be March 23rd 3 like June 15th for the first one on the top left 3 MR HAMILTON Oh March yeah I'm 4 right -- 4 sorry That's March yeah January 5 A. Yes 5 THE WITNESS Yeah March it looks 6 Q. -- and the invoice number that 6 like 7 would be the Reddaway invoice 8 A. I really don't know 9 Q. Okay 10 A. These are old records 11 Q. Yeah 12 MR HUGHES Let me show you an 13 example and we'll do it that way 14 se 7 - 8 CONTINUATION 9 BY MR HUGHES 10 Q. Okay 11 Then if we go to Exhibit do you 12 see the same invoice number 13 A. Yes Yes It is the invoice 14 number 15 At which time a Reddaway 15 Q. Okay 16 Manufacturing Company Inc. File Copy 16 And it shows the same day 222222222 Invoice for Abex Corporation dated 3/23/84 17 March 23rd 1984 222222222 was received and marked as Deposition 18 A. Yes it does 222222222 Exhibit 20 for identification by the court 19 Q. Okay 222222222 reporter 222222222 --- 222222222 MR HUGHES Is that 20 20 So would it appear then that the 21 invoice number references the Reddaway invoice 22 number 222222222 COURT REPORTER Yes 23 A. Yes 222222222 MR HUGHES Okay 222222222 see 24 Q. Okay 25 And so going back to Exhibit am Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 166..169 Page 166 1 I correct that all of the sales to Abex by invoice 1 2 number would be recorded on these cards some of 2 3 which are in Exhibit 3 4 A. I would assume so 4 LO Q. Okay 5 6 So if -- on Exhibit if I turn 6 7 to the second page it's showing more of the 1984 7 8 invoices right 8 9 A. Yes 9 10 Q. And -- then if I go to Reddaway 518 10 11 it starts to going into 1985 - 11 12 A. Yes 12 13 Q. ~~ correct 13 14 A. Yes 14 15 Q. Okay 15 16 And then Reddaway 519 goes into 16 1986 17 18 A. Yes 18 19 Q. Okay 19 20 I will represent to you that I went 20 21 through the 1986 Reddaway sales documents that you 21 22 all were able to locate and the ones I found that 22 23 begin at invoice number 38872 which is towards the 23 24 bottom of the page it's Reddaway 519 24 25 A. Yes 25 second page in Page 168 A. Oh 1061. Oh okay Q. Okay And that's invoice number 38872 A. Yes Q. Okay page 519 -- If I compare that to Exhibit A. Okay Q. - do you see the same invoice number at the bottom left A. Yes I do Q. Okay And then you can see how -- A. 317 Q. -- and next to that invoice number on Exhibit you see the price -- A. Yup Q. -- of 4637.62 correct A. Yes Q. And that's reflected on the bottom of Exhibit on this page right A. Yes Q. Okay On the invoice itself can you tell Page 167 Page 169 1 Q. Do you see that invoice number 1 me what products Reddaway is selling to Abex 2 A. Yep 2 according to this invoice 3 Q. And so can you tell me -- do you 3 A. On 1061 4 agree that some of the actual invoices for the 1986 5 sales to Abex they can't presently be located 6 A. Yes 7 Q. Okay 8 -- 9 At which time an Abex 1986 file 10 card was received and marked as Deposition 11 Exhibit 21 for identification by the court 12 reporter 13 -- 4 Q. Yep 5 A. Unbranded EBONY woven brake lining 6 that is a light -- light duty woven -- 7 Q. Okay 8 A. -- and unbranded heavy duty woven 9 brake lining That's heavy duty woven brake lining 10 Q. Okay 11 And the part numbers -- well the 12 numbers 257-840 and 258 are different numbers after 13 that 14 CONTINUATION 14 Those are not -- 15 BY MR HUGHES 15 A. I don't know 16 Q. Okay 16 Q. -- Reddaway numbers 17 Exhibit Number am I correct that | 17 A. I don't know what those mean 18 this is a collection of 1986 Reddaway invoices to 18 19 Abex 19 Q. Okay The unbranded EBONY woven brake 20 A. Yes 22222 Q. Okay 22222 And the first one which is at page 22222 1061 that has invoice number 38872 correct 20 lining you said that's light duty 21 A. Yes 22 Q. Okay 23 Tell me how does it differ from the 22222 A. What's -- what page number 24 heavy duty woven brake lining 22222 Q. It's Reddaway 1061 on Exhibit 25 A. It has no -- we don't grind it No Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 170..173 1 final grind 2 Q. Okay Page 170 | _1 2 THE WITNESS Page 172 I couldn't tell you --- 3 And would it have used if you know 4 the same MSDS sheet as the heavy duty 5 A. It would be the same 6 Q. Okay 7 Would it have had the same 8 approximate amount of asbestos in it 9 A. Yes 3 CONTINUATION 4 BY MR HUGHES 5 Q. Okay 6 Does Reddaway have any information 7 as to whether Abex ever asked Reddaway for asbestos 8 brake lining or asbestos brake lining at any 9 time 10 Q. Okay 10 A. No information on that 11 Did there come a point in time when 11 12 -- as to the EBONY woven brake lining that it was 12 MR BOUCH Object to the form --- 13 transitioned from asbestos containing to 13 CONTINUATION 14 asbestos 14 BY MR HUGHES 15 A. Yes 15 Q. When Reddaway first announced the 16 Q. When did that happen 16 asbestos in 1983 would Reddaway have 17 A. I'm not sure 17 communicated that to Abex in any way 18 Q. Okay 18 MR BOUCH Objection to form 19 A. In the same time frame 19 THE WITNESS I'm sure they related 222222 Q. All right 20 it to every account they had 222222 Looking at this invoice from 1986 21 - 222222 can you tell me on behalf of Reddaway whether this | 22 CONTINUATION 222222 particular package of the EBONY brake lining had 23 BY MR HUGHES 222222 asbestos or not 222222 A. No way to tell 24 Q. 25 accounts They publicized it to all their 1 Q. Okay Let's see Page 171 1 A. Yes Page 173 2 The next page of Exhibit 3 Reddaway 1062 that shows -- that lists the EBONY 4 woven brake lining again 5 Is that correct 6 A. Yes 2 Q. Okay 3 Still looking at Reddaway 1063 do 4 you know whether -- for sales in October 1986 do 5 you know whether if it was asbestos it would 6 have said that on the invoice 7 Q. And then the next page 1063 shows 7 8 it's an invoice from October 22nd 1986 right 8 9 A. Yes 9 10 Q. And that one is invoice number 10 MR BOUCH Objection to form THE WITNESS I don't know I wouldn't have any idea --- 11 39131 correct 12 A. Yes 13 Q. Which once again you can see it 14 over on the card of invoices right 16282222222 A. Yep 16282222222 Q. Okay 16282222222 That one Reddaway 1063 that's for 16282222222 the heavy duty woven correct 16282222222 A. . Yes 16282222222 Q. Okay 16282222222 And sitting here today can you tell 16282222222 me whether that particular package of heavy duty 16282222222 woven that was shipped to Abex in 1986 was asbestos 16282222222 containing or asbestos 16282222222 MR BOUCH Object to the form 11 = CONTINUATION 12 BY MR HUGHES 13 Q. 14 15 last page -- Okay All right If you go to Reddaway 1066 the very 16 A. Okay 17 Q. ~- what's the date of that invoice 18 A. 11/24/86 19 Q. Okay 20 And is it your understanding that 21 the last date that Reddaway sold asbestos products of 22 any sort was November 17 1986 23 Is that right 24 A. Yes 25 Q. Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 174..177 Page 174 Page 176 1 So for this invoice here do we 1 version or the asbestos 2 know whether this was asbestos or asbestos 2 A. No. 3 A. I would assume this would be 3 4 asbestos 4 5 Q. Okay LO MR BOUCH Objection to the form Pause --- 6 And the reason why is because it is 7 dated after November 17th -- 8 A. Yes 9 Q. -- 1986 correct 10 A. Yes 11 Q. Okay 12 The price -- let's see for the 1/3 13 inch by 1/4 inch 50 foot on that last page -- it's 14 the middle entry -- 15 A. Okay 16 Q. Do you see that 6 At which time a Letter from Redco 7 Edward Eggert to David L. Erenstoft East 8 Paterson Machine dated December 30 1991 9 was received and marked as Deposition 10 Exhibit 22 for identification by the court 11 reporter ) 12 ee 13 MR HAMILTON 22 14 COURT REPORTER 22 15 --- 16 CONTINUATION 17 A. Yes BY MR HUGHES 18 Q. -- it appears to show a per unit or 19 per foot price of 17.30 right 20 A. Yes 21 Q. Okay 22 Now if you go back to page -- the 23 second page of the same document -- 24 Okay 25 A. Okay 18 Q. Looking at Exhibit Number have 19 you seen this document before 20 A. Yes I have 21 Q. What is it 22 A. A customer asked us for product 23 liability insurance 24 Q. What are the circumstances if you 25 know that led to this letter being sent Page 175 1 Q. -- that page -- does that page 1 A. I have no idea Page 177 2 appear to show a purchase of 100 feet four inch by 3 1/4 inch of the same EBONY brake lining as the top 4 entry 5 A. Yes 6 Q. 7 8 17.30 Okay And does it show the same price of , 2 Q. Okay 3 A. I would -- I would assume the 4 customer called up and -- 5 MR HAMILTON Don't assume 6 He's asking if you know 7 THE WITNESS I don't know I don't 8 know 9 A. Yes it does 9 10 Q. Okay 10 11 Do you know one way or the other 11 12 whether the asbestos had the same price or a 12 MR BOUCH Objection No question pending Object Move to strike - 13 different price per foot for the EBONY brake lining | 13 CONTINUATION 14 A. I don't know that 14 BY MR HUGHES 15 MR BOUCH Objection to form 16 --- 17 CONTINUATION 18 BY MR HUGHES 19 Q. You do not know 222222 A. I do not 15 Q. So the letter says at the beginning 16 that since the early 80's product liability 17 insurance has not been available to the brake lining 18 industry at an affordable price et cetera 19 Do you see that 20 A. Yes 222222 Q. You're not aware of any documents 222222 that would clarify that 222222 A. No. 222222 Q. So the fact that the price is the 222222 same doesn't tell us whether it was the asbestos 21 Q. Okay 22 Let me ask you 23 Do you know was that one of the 24 reasons why Reddaway sought to move to asbestos 25 MR BOUCH Objection to form Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 178..181 Page 178 1 MR HAMILTON Objection to form 1 CONTINUATION 2 THE WITNESS I have no idea 2 BY MR HUGHES Page 180 3 MR HUGHES Okay 4 ~-- 5 At which time a Reddaway 6 Manufacturing Co. Inc. Redco News August 7 '86 was received and marked as Deposition 8 Exhibit 23 for identification by the court 9 reporter 10 --- 11 CONTINUATION 12 BY MR HUGHES 13 Q. Exhibit have you seen this 14 document before 15 A. Yes 3 Q. Well do you -- where it says we 4 are stopping the production of RBW asbestos lining 5 effective November 17th 1986 is that an accurate 6 statement 7 A. We have officially told all of our 8 customers that we are stopping the production of RBW 9 asbestos lining effective November 17 1986 yes 10 Q. Okay 11 So is it possible that Reddaway was 12 still producing all of the different kinds of RBW 13 asbestos lining up until November 17 1986 14 MR HAMILTON Objection to the 15 form 16 Q. What is it 16 17 A. It's a Redco newsletter from August 17 186 18 MR BOUCH Objection to the form THE WITNESS No it's not --- 19 Q. Who is it sent to 19 CONTINUATION 20 A. This would have been sent to all of 22222 our distributors 22222 Q. Okay 22222 Would it have been sent to Abex 22222 A. Yes it would have 22222 Q. Okay 20 = BY MR HUGHES 21 Q. 22 A. Why not Because we have the other exhibit 23 showing that we were making asbestos and it was 24 available on those different sizes 25 Q. And it's your testimony that when Page 179 Page 181 1 Why was it sent 1 the switch was made to asbestos for different 2 MR BOUCH Objection to form 2 sizes -- 3 THE WITNESS Just giving our 3 A. We never went back 4 distributors information 5 moe 6 CONTINUATION 7 BY MR HUGHES 8 Q. Okay 9 Now at the top it says that in 4 Q. Okay Let's see 5 They are -- the next to the last big 6 paragraph the one where it says as of today 7 August 18 do you see that 8 A. Yes 9 Q. Let's see 10 part quote we have officially told all of our 11 customers that we are stopping the production of RBW 12 asbestos lining effective November 17th 1986 end 13 quote 14 Have I stated that accurately 10 It says we have 13 working weeks 11 to process our remaining asbestos yarn and rolled 12 goods inventory 13 Do you see that 14 A. Yes 15 A. Yes 16 Q. Okay 17 Is there any reason why that 18 statement -- why is it -- I don't see anywhere in 19 this document that it says they stopped producing 20 some of the RBW earlier than 1986 21 MR HAMILTON Objection to form 22 MR BOUCH Object to the form 15 Q. What does that mean if you know 16 MR BOUCH Objection to form 17 Pause 18 THE WITNESS It means that they 19 were trying to get the last of the asbestos 20 processed which would have been on the oil field on 21 the larger loom 22 - ee 23 THE WITNESS Say the question 23 CONTINUATION 24 again 24 BY MR HUGHES 25 --- 25 Q. So where it says rolled goods -- Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 182..185 1 Do you see that 2 A. Yes Page 182 1 2 3 Q. -- would that include the RBW rolled 3 MR HAMILTON Page 184 Object to the form MR BOUCH Object to the form se 4 products do you know 4 CONTINUATION 5 6 7 yes 8 MR BOUCH Objection to form THE WITNESS It's all the same see 9 CONTINUATION 10 BY MR HUGHES 11 Q. Okay 12 A little bit further down it 13 discusses completed all grinding and slitting by 14 that date 5 BY MR HUGHES 6 Q. Is that a fair reading of it 7 MR HAMILTON Objection to form 8 MR BOUCH Objection to the form 9 THE WITNESS I really don't know 10 how they -- they would interpret it 11 MR HUGHES Okay 12 THE WITNESS It says -- 13 MR HAMILTON There's no question 14 - 15 Do you see that phrase 16 A. Yes 15 CONTINUATION 16 BY MR HUGHES 222222222 Q. What does grinding mean 17 Q. It refers to Canada in the next 222222222 A. Type of process 18 sentence 222222222 It's part of our process 19 A. Right 222222222 Q. Can you give me a little more detail | 20 Q. That would be the oil fields that 222222222 on what the grinding consists of 21 you referred to earlier 222222222 What does it -- 22 A. Yes 222222222 A. Just what it says grinding the 23 222222222 material Putting it through a grinder 24 222222222 Q. Why was that done 25 --- At which time a Redco Facts in Friction July 186 was received and marked Page 183 1 A. That's just part of the process 1 2 Q. Slitting what would that mean 2 3 A. Slitting it into widths 3 4 Q. Okay 4 5 The width of the roll 5 6 A. Width of the roll 6 7 Q. Okay 7 8 The next paragraph it says quote 8 9 the finished RBW will still be legal for sale after 9 10 = November 18th unquote 10 11 Do you see that 11 12 A. Yes 12 13 Q. Do you have any understanding what 13 14 that sentence means 14 15 A. I guess it means that it will still 15 16 be legal if somebody has it 16 17 Q. Okay 17 18 So -- 18 19 A. 20 panic They probably didn't want to start a | 19 20 21 Q. Okay 21 22 So in other words am I fair to 22 22 read it as they are saying to the customers we're 23 22 stopping all asbestos production on November 17th 24 25 186 but that doesn't mean you can't sell it anymore | 25 Page 185 as Deposition Exhibit 24 for identification by the court reporter --- MR HAMILTON We are up to 24 COURT REPORTER Yes --- CONTINUATION BY MR HUGHES Q. First page of Exhibit which is Reddaway 1289 have you seen that document before A. Yes Q. Okay And it appears to be a page document right A. Yes Q. Okay And it's dated July 1986 A. Yes Q. sent to Okay Do you know who this document was A. distributors Would have been sent to all of our Q. Okay When you say distributors would Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 186..189 1 Abex be considered a distributor Page 186 1 form Page 188 2 A. Yes they would 3 MR BOUCH Object to the form 4 --- 5 CONTINUATION 6 BY MR HUGHES 7 Q. Why 8 A. They're a distributor 2 THE WITNESS Whatever OSHA 3 required they did 4 MR HUGHES Okay 5 THE WITNESS He may have just taped- 6 this on here I don't know what -- if that's 7 actually what they required on that date that's what 8 we did 9 Q. Because they buy it and resell it 9 --- 10 A. Yes 10 CONTINUATION 11 Q. Okay 12 So this -~ a copy of this document 13 would have been sent to Abex 14 A. Yes All distributors 15 Q. Okay 16 And can you tell me why this 17 document was sent to the distributors 18 MR BOUCH Objection to form 19 THE WITNESS To make them aware of 20 OSHA -- of the new OSHA regulation 21 --- 22 CONTINUATION 23 BY MR HUGHES 11 BY MR HUGHES 12 Q. Okay 13 Let me try it this way 14 Your testimony is that whatever 15 OSHA required is what Reddaway did right 16 A. Yes 17 Q. But it sounds like you don't have 18 personal knowledge of whether Reddaway actually used 19 a label that said for example cancer and lung 20 disease hazard 21 MR BOUCH Objection to the form 22 MR HAMILTON Object to the form 23 7 24 Q. Of the different steps -- you see 25 Steps 1 through 5 on the first page 24 CONTINUATION 25 BY MR HUGHES 1 A. 2 Q. 3 4 steps Yes Page 187 1 Q. Okay Did Reddaway have to implement those 2 right 3 A. 4 5 A. Let's see what they are 5 6 Pause 6 7 A. Yes We had to abide by all the 7 8 OSHA Standards 8 Page 189 You don't know one way or the other Hold on one second Pause MR HAMILTON Is there a question MR HUGHES Yeah there is Yeah there is - 7 9 Q. Okay 9 CONTINUATION 10 So was a warning label prepared 11 that would have the language that we see in Step 12 Number 3 there 13 Pause 14 A. Yes Those labels were put on 15 Q. Does Reddaway still have any copies 16 of those labels 17 Pause 18 A. Let's see We have the OSHA 19 approved labels 20 Q. I understand but I didn't see this 10 BY MR HUGHES 11 Q. I was asking do you have personal 12 knowledge of whether Reddaway actually changed this 13 label at any time that had this language in it 14 MR BOUCH That wasn't the 15 question That wasn't the last question 16 So I object 17 18 again THE WITNESS Ask me the question 19 MR HUGHES Sure 20 -- 21 language in them so that's why I'm asking 22 Are you sure that Reddaway switched 23 to this label language 24 MR BOUCH Objection to the form 25 MR HAMILTON Objection to the 21 = CONTINUATION 22 BY MR HUGHES 23 Q. Did Reddaway ever revise its warning 24 label to have the language that we see under 25 paragraph number three on Exhibit Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 190..193 Page 190 1 MR HAMILTON Objection to form 1 right 2 Asked and answered 2 A. 3 MR BOUCH Objection 3 4 THE WITNESS If we were required to 5 do it we did it 4 5 CONTINUATION Page 192 That we had MR HAMILTON -- Objection to form 6 -- 6 BY MR HUGHES 7 CONTINUATION 8 BY MR HUGHES 9 Q. Okay 7 Q. So if Reddaway had used this 8 language you would have provided us a copy of it 9 A. No. If I had it 10 Does Reddaway today have copies of 10 We would only buy a small amount of 11 any warning labels with this language on it 11 them because we were getting out of it 12 A. No. You guys have copies of all the | 12 Q. But do you know -- 13 warning labels that we have 13 A. It was only for several months 14 Q. Okay 14 So I'm sure they used them all 15 Have you produced to us a copy the 15 Q. But do you know -- do you have any 16 warning labels with this language on it 16 personal knowledge that Reddaway ever did that 17 Pause 17 A. Yes they did 18 A. No we have not 18 MR HAMILTON Objection to form 19 Q. Okay 19 MR BOUCH Object to form 20 Why not 20 - 21 Pause 21 CONTINUATION 22 A. We probably couldn't find one 22 BY MR HUGHES 23 24 available 25 MR HAMILTON You have what was THE WITNESS We gave a copy of 23 Q. 24 A. 25 Conway What's your basis for saying that Through Bill Barton and Warren 1 everything that we had Page 191 1 2 MR BOUCH I object to the form 2 Q. What did they tell you Page 193 A. That they complied to all of the 3 THE WITNESS So this warning label 4 was put on only for a couple months 3 OSHA regulations When the rules changed they 4 changes with them 5 Okay 5 Q. Okay 6 MR HUGHES I understand 7 THE WITNESS Because we got out of 8 the asbestos 9 MR BOUCH Objection to the form of 10 the question 11 There is no foundation for any of 6 But did they specifically tell you 7 anything about this warning label 8 MR HAMILTON Objection to form 9 THE WITNESS That's the same thing 10 MR BOUCH Objection to form 11 THE WITNESS If we conformed to 12 the questions he's asked for the last four questions 12 everything it would be part of the warning labels 13 It is a when did you stop beating 13 MR BOUCH Assuming they even sent 14 your wife question 15 MR HUGHES Sure 16 I mean everything that I've seen 14 any asbestos after July of 186 which the testimony 15 is for the products at issue in this case they 16 didn't 17 indicates that this language was never used 18 So that's why I'm asking 19 MR HAMILTON Objection to the 20 form 17 You're fishing John 18 MR HUGHES No. The witness said 19 he didn't know whether they sold it out of inventory 20 or not 21 ~e 22 CONTINUATION 23 BY MR HUGHES 24 Q. If -- if -- if you produced a copy 25 of all the warning label language that you all had 21 MR BOUCH He also said they turned 22 inventory three times and if they stopped making it 23 in '83 they turned it over at least 15 times by '86 24 So none of your questions have a 25 foundation John and you're fishing Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 194..197 Page 194 1 Pause 1 Ed Eggert went Page 196 Okay Q. 2 2 - + , 3 At which time a Defendant Reddaway {| 3 --- 4 Manufacturing Co. Inc.'s Answers to 4 At which time a Friction Materials 5 Plaintiff's Master Interrogatories to All 5 Standards Institute Inc. was received and 6 Defendants was received and marked as 6 marked as Deposition Exhibit 26 for 7 Deposition Exhibit 25 for identification by 7 identification by the court reporter 8 the court reporter 8 --- 9 -- 10 CONTINUATION 11 BY MR HUGHES 12 Q. I've handed you a copy of the 13 Reddaway discovery responses in our case 14 Have you seen these before 15 A. Yes 9 MR HAMILTON I'm sorry 10 What number are we up to 11 COURT REPORTER 26 12 MR HUGHES Tom Exhibit these 13 are some documents that I found and I sent them to 14 you Mr. Hamilton last night 15 -- 16 Q. On page two top of the page it 17 talks about the documents that were reviewed 18 Do you see that 19 A. Yes 222222 Q. Okay 222222 One is sales invoices 222222 A. Yes 222222 Q. Okay 222222 Am I correct that all of the 1986 222222 sales invoices that Reddaway can find have been 16 CONTINUATION 17 BY MR HUGHES 18 Q. The first page do you agree that at 19 some point in time Reddaway was a member of the 20 Friction Material Standards Institute 22225 A. Yes 22225 Q. Okay 22225 The second page it appears to show 22225 Reddaway as a member 22225 A. Yes 1 produced Page 195 1 Page 197 Q. It's dated 1962 on the bottom left 2 A. Yes 3 Q. Okay 4 Page three was Reddaway ever a 5 member of the Asbestos Information Association 2 A. Yes 3 Q. Okay 4 Was my understanding correct that 5 Reddaway was a member of the FMSI in 1962 6 A. Yes 6 A. That's what it shows here 7 Q. Okay 7 Q. Okay 8 Do you know if Reddaway was a member 9 of any committees or subcommittees of that group 8 9 News If you go to this page it says FMSI 10 A. 11 knowledge I wouldn't have any of that 12 Q. Do you know who went to the 13 meetings if anybody 14 A. 15 either Wouldn't have any of that knowledge 10 MR BOUCH I am going to object 11 These documents if any of the pages 12 are dated many of the pages are unrelated and 13 seeing that the first four pages are a list of 14 members the shipper only one of them has a date on 15 it 16 Q. And I take it Reddaway doesn't have 17 any materials they may have received from them 18 A. Nothing no 19 Q. For the FMSI am I reading this 20 correct it was Mr. Eggert and Mr. Barton that would 21 have attended the meetings for the FMSI 16 The last one two -- or the next two 17 pages appear to be bulletins dated in the 80's and 18 then the last -- next two pages rather appear to be 19 lists of members again undated and the last page 20 is an attendance list at a meeting that has a date on 21 it 22 Is that right 23 A. Yeah I think I think Mr. Barton 24 most of the time | yeah 25 Maybe one year or two years I think 22 So to the extent counsel is trying 23 to imply that if you're listed on the '62 list it 24 continued to the '85 list I object -- or '81 25 '81 list I object Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 198..201 1 2 objection Page 198 Page 200 MR HAMILTON I join in the 1 page is FMSI News and this one is dated from July 2 1980 correct 3 MR HUGHES Okay 3 A. Yes 4 5 CONTINUATION -- 4 Q. Okay 5 And does this one also list 6 BY MR HUGHES 7 Q. Do you see the FMSI News page which 8 is -- it says BP 8548 at the bottom right 9 A. Yes 6 Mr. Barton about halfway down the page 7 A. Yes it does 8 Q. Okay 9 And does it indicate that he was 10 Q. Okay 10 elected as a Director 11 Does it appear to list Mr. Barton of | 11 A. Yes it does 12 Reddaway under the Officers and Directors 13 A. Yes 12 Q. Okay 13 When was the first date that 14 15 form MR HAMILTON Objection to the 14 Reddaway was -- ever received any kind of 15 asbestos claim 16 I mean the documents speaks for 16 A. I wouldn't have any idea 17 themselves So I'm not sure what -- and he told you | 17 18 that Reddaway was a member So I'm not sure what 18 Q. Okay Is it correct that in 1984 Reddaway 19 else you are looking for from him -- 19 was told not to throw anything away 20 - 20 A. Yes 21 CONTINUATION 22 BY MR HUGHES 21 Q. 22 that Do you know why Reddaway was told 23 Q. So am I correct that Mr. Barton was | 222 A. In case we're in future cases so we 24 an Officer or Director of the FMSI -- 222 can see if we sold to people 25 A. New Officers and Directors 25 Q. Okay 1 Q. -- at some point Page 199 1 Page 201 And I'm not interested in the 2 MR HAMILTON Object to the form 3 --- 4 CONTINUATION 5 BY MR HUGHES 2 contents of discussions with lawyers 3 Okay 4 Was -- was Reddaway a party to any 5 asbestos lawsuits as of 1984 6 Q. Is that correct 7 A. According to this document yeah 8 Q. And do you have any reason to 9 dispute that 10 A. No. Looks like a legitimate 6 7 8 9 10 all that MR HAMILTON Object to the form You say '84 -- 1984 MR HUGHES huh THE WITNESS My lawyers would have 11 document. 11 - 12 Q. Okay 12 CONTINUATION 13 Do you know if Reddaway would have 13 BY MR HUGHES 14 gotten a copy of the FMSI News 15 A. Never seen one 16 Q. Okay 14 Q. Okay 15 Do you know who was representing 16 Reddaway in 1984 17 Do you know if Reddaway may have 17 22222222 gotten copies and then subsequently discarded them / 18 A. My current lawyers may know I have no idea 22222222 A. I wouldn't have any idea 22222222 MR BOUCH Object to form 22222222 ~-- 19 Q. And do you know -- do you know when 20 the first year was that Reddaway was ever sued in an 21 asbestos case 22222222 CONTINUATION 22 22222222 BY MR HUGHES 23 22222222 Q. Okay 24 22222222 The next page do you see the next 25 A. Wouldn't have any idea MR BOUCH Objection to form Asked and answered -e Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 202..205 1 CONTINUATION Page 202 1 Page 204 I think what you testified to 2 BY MR HUGHES 3 Q. Okay 2 earlier today is when I showed you specific invoices : 3 to Abex as late as 1985/1986 you couldn't tell me 4 But Reddaway was told in 1984 not 5 to throw anything away right 4 one way or the other as to whether that product was | 5 the asbestos containing or the asbestos 6 MR HAMILTON Objection to the 6 A. Witness nods 7 form 8 MR BOUCH Objection 7 Q. Okay 8 So how do I square that with this 9 THE WITNESS What's that 10 --- 11 CONTINUATION 12 BY MR HUGHES 9 interrogatory response that says in early 1980's 10 Reddaway stopped selling the asbestos lining 11 MR HAMILTON Objection to the 12 ~~ form 13 Q. Reddaway was told in 1984 not to 13 MR BOUCH Objection to the form 14 throw anything away right 14 THE WITNESS That's when we -- in 15 A. I heard that yes 15 1983 started with all those sizes 16 Q. And your understanding is that was 16 17 because of at least the prospect of litigation 17 That would be the early 80's 7+: 18 MR HAMILTON Objection to form 18 CONTINUATION 19 MR BOUCH Objection to form 19 BY MR HUGHES 222222 222222 why 222222 222222 222222 that 222222 THE WITNESS I really didn't know MR HUGHES Okay THE WITNESS So I can't answer MR HUGHES Okay 20 Q. Okay 21 But you were still selling asbestos 22 lining out of stock right 23 A. For a while I'm sure we did But I 24 don't know how long We turned our inventory three 25 times a year so -- Page 203 1 - - - Page 205 1 Q. What did that mean turn our 2 CONTINUATION 2 inventory 3 BY MR HUGHES 4 Q. Okay LO If you go to page seven of the 6 interrogatory responses -- 7 A. What number is this 3 A. That means basically that you 4 manufacture a certain amount of brake lining You 5 sell it all You manufacture another amount and you 6 sell it all and you manufacture a third amount and 7 you sell it all 8 Q. Yeah 9 A. What page 10 Q. Page seven 8 Q. Okay 9 And you said that you turned two or 10 three times a year 11 A. Okay 12 Q. Okay 13 Middle of the page -- do you see 14 where it says the company began using asbestos in 11 A. That's about what we turned over 12 two or three times a year 13 Q. What does that mean three times a 14 year 15 its brake linings in the 40's 16 Pause 17 A. Yes 18 Q. Okay 19 And then it says quote in the 15 MR BOUCH Objection to the form 16 THE WITNESS It means we sell 17 everything out of inventory Make new Sell it 18 again Make new Sell it again three times 19 --- 20 early 1980's Reddaway stopped selling asbestos 21 containing brake linings to its industrial account 22 customers unquote 23 Do you see that 24 A. Yes 25 Q. Okay 20 CONTINUATION 21 BY MR HUGHES 22 Q. Okay 23 So for the -- the thinner line -- 24 the machinery you're saying was changed to use the 25 asbestos spools in what 1980 1981 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 206..209 1 A. 2 information 3 Q. 4 A. 5 Q. I wouldn't have that exact Okay I know we had -It was before 1983 Page 206 1 2 , i3 4 5 called an edge code A. No. Page 208 Q. codes or -- Okay Would Reddaway have stamped any 6 A. It was before 1983 yes 7 Q. Okay 8 And so what you are -- is what you 9 are telling me that all of the asbestos -- let's -- 10 let's say that the loom for the thin lining was 11 switched in 1982 12 Okay 13 A. Okay 14 Q. If that's the date so that would 15 mean that the last asbestos containing rolls were 16 manufactured prior to when the loom is changed in 1982 right 6 A. No. 7 Q. -- on its product 8 Okay 9 Would Reddaway have sent any of the 10 rolls of yarn to Abex in a boxes instead of bags 11 A. Didn't have boxes back then 12 Q. Okay 13 Pause 14 Q. Do you know if Reddaway was ever a 15 member of the Asbestos Textile Institute 16 A. I haven't heard of that 17 - 18 A. Yes 18 19 Q. Okay 19 20 If that's the case what would be 20 21 the latest inventory turnover -- is what you're 21 22 saying the latest that stock would be sold would be | 22 23 what a few months later 222 24 A. It's hard to say It's hard to say | 222 25 Q. Okay 222 At which time Answers of Reddaway Mfg Co. Inc. to Plaintiff's Interrogatories and Request for Production of Documents Set I was received and marked as Deposition Exhibit 27 for identification by the court reporter --- MR HAMILTON 27 Page 207 1 If the inventory is turned three 1 2 times a year could there still be some items in 2 MR HUGHES -- Yeah Page 209 3 there that stay in there for the whole year or does 4 all of the inventory get sold and all new product 5 gets put into the inventory 6 MR HAMILTON Objection to the 7 form 8 MR BOUCH Objection to the form 9 THE WITNESS There could be some 10 MR HUGHES Okay 11 Pause 12 --- 13 CONTINUATION 14 BY MR HUGHES 15 Q. Did Reddaway make any sales to a 16 company called Genuine Parts Company 17 A. No. 18 Q. Did Reddaway ever make any sales to 19 a entity called Raylon 20 A. No. 21 Q. 22 NAPA stores Did Reddaway make any sales to any 23 A. No. 24 Q. Okay 25 Have you ever heard of something 3 CONTINUATION 4 BY MR HUGHES 5 Q. Looking at Exhibit if you go to 6 page seven at the top of page seven number 23 7 Do you see that 8 A. Yeah 9 Who gave this 10 Q. These are some interrogatory 11 responses that were produced to us and you may or 12 may not have ever seen them before 13 The last page shows that they were 14 verified by Mr. Eggert -- 15 A. Okay 16 Q. -- not by you -- 17 A. Okay 18 Q. -- but the reason I'm showing them 19 to you look at page seven at the top -- 20 A. Okay 21 Q. -- it says quote Reddaway 22 believes that at one point it may have been a member 23 of the Asbestos Textile Institute but does not know 24 any particulars unquote 25 A. I've never heard of it myself Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 210..213 Page 210 1 Q. So you don't know where that came 1 no Page 212 2 from 3 A. No -- no idea 2 Q. Okay 3 Who is John Grumble 4 Q. 5 Institute 6 A. 7 Q. 8 9 You have never heard of that Never heard of it Okay --- At which time a Redco List Prices 4 A. 5 Q. 6 A. 7 8 something 9 I haven't heard that name John M How do you spell the last name MR HUGHES Let me show you ~-- 10 for Molded Flat Sheet Stock was received and | 10 At which time Defendant Reddaway 11 marked as Deposition Exhibit 28 for 11 Manufacturing Co. Inc.'s Initial 12 identification by the court reporter 12 Disclosures Pursuant to Federal Role of 13 --- 13 Civil Procedure 26 was received and 14 MR HUGHES 28 15 COURT REPORTER 28 16 7+ 14 marked as Deposition Exhibit 29 for 15 identification by the court reporter 16 --- 17 ~ CONTINUATION 18 BY MR HUGHES 17 CONTINUATION 18 BY MR HUGHES 19 Q. Exhibit Number This is a 19 Q. Exhibit this is some disclosures 20 document that I found and produced 20 that Reddaway sent to us and the second item on the 21 And my first question is is this an | 21 first page references a John Grumble 22 example of a price list that Reddaway would have 22 A. It would have to be Trumble maybe 23 issued from time to time 222 not a Grumble I'm thinking who is this 24 A. This is -- yes 222 Q. Okay 25 Q. Okay 25 A. John Trumble Page 211 1 So and this particular one this 1 2 isn't for the -- this was not for the roll lining -- 2 on our part 3 A. No. 3 MR HAMILTON Page 213 That would be a typo --- 4 Q. -- correct 4 CONTINUATION 5 But is it your testimony that there 5 BY MR HUGHES 6 would have been a price list like this for the roll 6 7 lining in the past 7 Q. Okay So there's a John Trumble- Trumble- 8 A. I don't know if it would have been 8 Yes 9 like this This is for molded sheets 9 Q. -- which is a much better last name 10 Q. Okay 10 Who is John Trumble 11 And if you look at the top here it 12 says East Paterson Machine Company 13 A. Yes 14 Q. Do you see that 15 A. Yes 16 Q. 17 is -- So it may be a price list that 18 A. This is 1973 -- 19 Q. I know 11 A. He's a -- my shipping manager 12 Q. Okay 13 Have you talked to him about this 14 lawsuit or to get ready for this deposition 15 A. I've asked him questions 16 Q. What have you -- can you tell me 17 what you asked him 18 A. With the labeling and stuff to 19 confirm what I was told 20 A. -- and I've never seen any price 22222 lists like this 22222 Q. Okay All right 20 Q. Okay 21 And so if I deposed him would he 22 -- say to your knowledge he would say the same 22222 So -- and what you testified 23 thing that it was labeled twice on the bag and then 22222 earlier Reddaway just doesn't have any price lists | 24 the product itself 22222 A. We have no price lists like that 25 MR BOUCH Objection to form Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 214..217 1 2 3 CONTINUATION Page 214 THE WITNESS Yes he would 1 2 -- 3 Page 216 Do you have a copy of that correct MR BOUCH Yes 7 4 BY MR HUGHES 4 CONTINUATION 5 Q. Okay 5 BY MR HUGHES 6 Is there anything else that you 7 asked him about for purposes of this case this 8 deposition 9 A. That's all he would really know 10 about 11 Q. Tell me why would Mr. Trumble know 12 about the labels 13 14 on A. He actually put some of the labels 15 Q. He actually puts the labels on 16 Do you know how far back he goes 17 with the company roughly 18 A. Little bit further back than me 19 Q. So he actually was working when it 222222 was -- before November of 1986 222222 A. Yes 222222 MR HUGHES Okay 222222 Let's take a break 222222 VIDEO TECHNICIAN This concludes 222222 tape number three in the video deposition of Todd 6 Q. Okay 7 Sir Exhibit have you seen this 8 document before sir 9 I can represent it was a deposition 10 exhibit from your old deposition 11 A. I don't remember it but -- 12 Q. Okay 13 At the top it says in compliance 14 with OSHA citation number G1688-050 15 Do you see that 16 A. Yes 17 7s 18 Discussion held off the record 19 --- 20 VOICE ON PHONE Hello there 21 doesn't appear to be any activity in this meeting 22 If you would like to stay on the line until others 23 join please press one 24 If not I'll end the meeting 25 MR HUGHES Let's just keep going 1 Walker 23 The time is 2:06 Page 215 1 2 Where are we --- Page 217 23 We are off the record 3 CONTINUATION 4 se 4 BY MR HUGHES 5 Recess was taken at this time 6 ee 7 At which time a Reddaway 8 Manufacturing Co. Inc. in compliance with 9 O.S.H.A. Citation G1688-050 was received 10 and marked as Deposition Exhibit 30 for 11 identification by the court reporter 12 --- 13 VIDEO TECHNICIAN This begins tape 14 number four of the videotape deposition of Todd 15 Walker 16 The time is 2:16 17 We are on the record 18 - 5 Q. Okay 6 It references -- it says OSHA 7 citation at the top 8 Do you see that 9 A. Yeah 10 What date is this 11 Q. I don't know 12 My question is do you know did 13 Reddaway ever get cited by OSHA for any violations 14 A. I never heard we have 15 Q. Okay 16 Item four on here -- at the end of 17 item four it references a film on the hazards of 18 airborne dust 19 At which time a Friction Products 19 20 by Redco Brochure was received and marked as | 20 A. 21 Deposition Exhibit 31 for identification by | 21 Q. 22 the court reporter 22 = film 23 - oe 22 A. 24 MR HUGHES I -- that one you were 22 Q. 25 telling me about 25 Do you see that Yeah I see that Do you know anything about that No. Okay Is it correct that all personnel in Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 218..221 Page 218 1 the Weaving Department were required to wear 1 Q. 2 respirators after OSHA 2 A. 3 A. Yeah throughout the plant 4 Q. Okay All right 3 Q. 41 5 Exhibit is this an example -- it 6 looks like a brochure from Reddaway -- 5 application 6 7 A. Yes 7 A. So these are molded All molded yeah Okay All right The next to last column Do you see that Yes Page 220 8 Q. -- and the second page once again 9 that shows us the RBW the bonded woven correct 10 A. Yes Yes : 11 Q. And again there's no labels on 12 there but your testimony is that a label would have 8 Q. Okay 9 Is that -- just looking at that 10 does that describe the application -- is it your 11 understanding that describes the application that 12 these blocks would be used for 13 been put on there -- 14 A. Before it was shipped | 13 A. 14 idea I've never seen this so I have no 15 Q. -- before it was shipped 16 A. The labels weren't put on until it 17 was in the shipping area 18 Q. Okay 15 Q. 16 17 18 about -- Is that what you used to do MR HAMILTON Object to the form THE WITNESS I have no idea 19 Pause 19 7 20 - 20 CONTINUATION 21 At which time a Redco Brake Block 21 BY MR HUGHES Okay 22 Industrial Set Group Listing was received 22 Q. 23 and marked as Deposition Exhibit 32 for 23 It does have the Redco name at the 24 identification by the court reporter 24 top right 25 7 25 A. Yeah 1 2 33 3 Page 219 MR HUGHES Exhibit -- what's that 1 Page 221 I don't understand why it has Redco THE WITNESS Yes 2 Grey Rock S.K. Wellman Raybestos 3 Q. You've never seen it before 4 MR HUGHES 32 5 COURT REPORTER 32 6 THE WITNESS 32 7 --- 4 A. No. 5 Q. Okay 6 VIDEO TECHNICIAN Can you raise 7 your microphone 8 CONTINUATION 8 MR HAMILTON You mean John 9 BY MR HUGHES 9 - 10 Q. This is a document that I found 10 At which time a Redco Product 11 Have you ever seen 11 Information Sheet was received and marked as 12 A. Never seen it 13 Q. Okay 12 Deposition Exhibit 33 for identification by 13 the court reporter 14 Did Reddaway sell various kinds of 14 --- 15 brake blocks at some point for industrial use 16 A. What I figured out with this is -- 17 Q. Yeah 18 A. -- we bought them all from 19 Raybestos Look at Raybestos part numbers We 20 added an R to all of their parts numbers 21 Q. Okay 22 A. Everybody else has their own part 15 CONTINUATION 16 BY MR HUGHES 17 Q. Exhibit the first page we've 18 already talked about -- 19 A. Okay 20 Q. - right 21 That is the RNAW product sheet 22 A. Yes 23 number We don't make -- we don't make this stuff 23 Q. | Okay 24 so we had to buy it from somebody So that's who we 24 Now the second and third pages 25 bought it from 25 what are those if you know Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 222..225 Page 222 1 Second page looks like it's a 1 CONTINUATION Page 224 2 Reddaway invoice selling - 2 BY MR HUGHES 3 A. Yeah This -- this is a little part 4 made out of RNAW asbestos woven brake lining -- 5 Q. Okay 6 A. ~~ -- per per drawing It says per 7 drawing So they sent us a drawing -- 8 Q. Yup 9 A. -- and we made a part out of it 10 Q. Okay 11 A. Then we sent 100 parts back to them 3 Q. -- but they didn't use that phrase 4 for any of the invoices to Abex before 1986 5 A. This is completely different This 6 is -- we had a drawing The drawing may have 7 specified that exact term on it 8 Q. Okay 9 So this -- these -- and this 10 fabricated product was made out of the RNAW 11 asbestos sheet 12 Q. 13 roll So that -- this was not sent as a 14 A. No. 15 Q. All right 16 But was the -- can you tell from 17 this was the roll lining used by Reddaway to 18 fabricate the part 19 A. I don't know what it was RNAW 20 asbestos I don't know if it was in roll or 21 not 22 Q. Okay 221 A. Probably not 221 Q. Okay 25 Well if it's 1/4 inch RNAW 12 A. I don't know what it was made out 13 of It was made out of RNAW asbestos I don't 14 know I don't even know what the part looks like 15 Q. Okay 16 A. So I wouldn't know what they -- 17 what they -- you know what they -- if they made it 18 out of a flat sheet If they made it out of a roll 19 = lining 20 Q. Okay 21 But clearly as of September 1983 22 the 1/4 inch RNAW asbestos existed 23 A. Yes 24 Q. Okay 25 So is it your testimony that as of 1 asbestos -- 2 A. Flat -- flat woven sheet 3 Q. Okay All right Page 223 Page 225 1 September 183 the 1/4 inch asbestos lining was no 2 longer being made 3 A. Can't answer that 4 Now this -- this invoice is dated 4 Q. Why not 5 from September 1983 correct 5 A. We don't know We know it wasn't 6 A. Yes 6 being made We don't know if we had it 7 Q. And in this invoice it does 7 Q. Okay 8 expressly use the phrase RNAW asbestos correct 8 A. This particular print had a RNAW on 9 A. Yes 9 it So at that time if there was both they didn't 10 Q. Okay 10 want the other one they wanted this one 11 But you have not seen any -- do you 11 Q. Okay 12 agree with me there are no Reddaway invoices to Abex | 12 But again would you have been 13 from before 1987 that say RNAW or asbestos on 13 using the machines the looms for this 1/4 inch RNAW 14 them 14 asbestos 15 A. I've looked through them as well as 16 you I didn't see any 17 Q. Okay So help me out 18 Can you explain why Reddaway would 19 be using the phrase RNAW asbestos to identify a 20 product that's asbestos in 1983 in this invoice 21 for the East Paterson Machine Company but -- 22 A. Maybe because -- 23 MR HAMILTON Let him finish the 24 question 25 ~-- 15 A. Oh yeah 16 Q. So if it was -- if you were 17 manufacturing that by September 183 you wouldn't be 18 manufacturing the 1/4 inch asbestos 19 Is that correct 20 A. No we would not 21 Q. Okay 22 A. They only changed over once 23 Q. All right 24 Am I correct that Reddaway has never 25 had its own Medical Director correct Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 226..229 1 A. No they have not Page 226 1 Page 228 And down towards the bottom it 2 Q. Okay 2 refers to a wet weaving operation 3 Is it correct that Reddaway was the 3 Do you know what that means 4 first friction material company to -- to completely 4 Does that help you with the water 5 stop manufacturing asbestos friction materials 5 mist that we talked about earlier 6 A. I was told that 6 A. I would assume 7 Q. Who told you that 8 A. Bill Barton Warren Conway 9 Q. Okay 10 Do you have any understanding of 11 when Abex stopped manufacturing asbestos friction 12 products 13 A. I have no idea 14 Q. Okay 15 At any time did Abex ever send 7 Pause 8 A. This was a wet weaving operation 9 and the dust probably came from the nearby -- 10 Q. So and it's okay if the answer is 11 you don't know 12 But when it said wet weaving 13 operation do you know what that's referring to 14 A. I don't -- I don't have any idea on 15 that 16 Reddaway any information about the hazards or dangers | 16 17 of asbestos to your knowledge 17 18 A. I have no documentation on that 18 19 Q. Okay 20 - 19 second 20 222225 At which time a Letter from Ralph 21 222225 L. Lanz to Vincent LaCarrubba dated November | 22 222225 11 1975 was received and marked as 23 222225 Deposition Exhibit 34 for identification by | 24 222225 the court reporter 25 Pause MR HUGHES Okay Let's go off the record for a VIDEO TECHNICIAN The time is 2:28 -- Off the record Discussion held off the record --- VIDEO TECHNICIAN Back on the Page 227 1 see 1 record Page 229 2 CONTINUATION 3 BY MR HUGHES 2 The time is 2:37 3 so 4 Q. You've been handed -- this is a copy 4 5 of a letter from Ralph Lanz dated November 11 1975 5 6 Have you seen this document before 6 7 A. I don't recall it 7 8 Q. Okay 8 9 This was an earlier exhibit from 9 At which time a Reddaway Manufacturing Company Inc. File Copy Invoice dated 8/28/85 was received and marked as Deposition Exhibit 35 for identification by the court reporter --- 10 your old deposition -- 11 MR BOUCH Is this 34 10 = CONTINUATION 11 BY MR HUGHES 12 13 14 15 CONTINUATION COURT REPORTER 34 MR HUGHES - - Yup 12 Q. All right 13 Sir I've handed you -- I just want 14 to get your help on some more of the terms these 15 sales documents 16 BY MR HUGHES 17 Q. Does this appear to reflect the 18 periodic air sampling -- 19 A. Yes 20 Q. -- that -- that Reddaway started 21 doing after OSHA came into place 22 A. Yes 23 After turning the page I recognize 24 some of this yes This was the air sampling 16 So this exhibit first page that's 17 a Reddaway invoice from August 28th 1985 correct 18 A. Yes 19 Q. Okay 20 So customer's order number 21 That's an internal clerical notation 222222 when the order comes in 222222 Is that what that is 222222 A. Yes 25 Q. Okay 222222 Q. Okay Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 230..233 Page 230 1 Page 232 Requisition number 1 says price is based on price list effective 2 Do you know what that means 2 7/1/84 3 A. No I don't 4 Q. Okay 5 Terms those would be shipping 6 payment terms 7 A. Yeah 8 Q. Okay 9 Salesman 1 3 Do you see that -- 4 A. No. 5 Q. -- in the middle of the page 6 A. Price -- okay based Okay 7 Q. So but you -- but Reddaway just 8 doesn't have any copies of these price lists 9 -- anymore 10 A. Looks like an H for house I would 10 A. No. 11 think 12 Q. Okay All right 11 Q. -- those price lists 12 A. No. 13 And on this page the thickness of 14 these linings is 16's of an inch or a 1/4 inch 15 A. Yes 16 Q. So that would be within the 17 category of the industrial lining -- the thinner 13 Q. Okay 14 Sitting here today did you know 15 whether the price list effective July 1st 1984 do 16 you know if that would have listed prices for 17 asbestos or asbestos or -- 18 lining 19 A. 20 Q. Yes Okay 18 A. Couldn't even guess on that one 19 Q. Okay 20 A. I have no idea 21 2222 order 2222 2222 A. 2222 Q. The next page it says short Do you see that Yes Do you know what that means 21 Q. Okay 22 And then Reddaway 1009 a few more 222 pages in on the document -- 222 A. Okay 222 Q. -- once again where it says three 1 A. That means that they didn't shiPpage 231 1 bales of asbestos brake lining what you're tePlalgieng233 2 everything on the first order so they had to back 2 me is that might not be accurate 3 order something 3 A. Yes it's not accurate I don't 4 Q. Okay 4 know if it's accurate or not because I'm sure these 5 A. 75 100 125 5 are expensive forms and I'm sure for years we used 6 MR BOUCH Which page are you on 6 the same ones 7 8 CONTINUATION 9 BY MR HUGHES - +e 7 8 9 have MR HUGHES Okay Those are all of the questions I 10 Q. It's the second page of the 11 document Reddaway 1000 12 So short order might mean that they 13 shipped part of it at one point and part of it at 14 another 15 A. Yes 16 Q. If you go to Reddaway 1005 17 Reddaway 1005 it's an Abex order 18 Do you see that 19 A. Okay Yes 20 Q. Okay 21 So this is a copy of what Abex 22 woven sent to Reddaway right 10 MR BOUCH Okay 11 VIDEO TECHNICIAN Could you give 12 him your microphone 13 MR HAMILTON I'm sorry 14 MR BOUCH Good afternoon 15 Mr. Walker 16 THE WITNESS How are you doing 17 MR BOUCH My name is Tim Bouch 22222222 and I represent Pneumo in this case 22222222 Nice to see you 22222222 I hope I won't jump around too much 22222222 but let me see if I understand something 22222222 -- > 23 A. Yes 24 Q. Okay 22222222 EXAMINATION 22222222 --- 25 And you see towards the middle it 22222222 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 234..237 1 BY MR BOUCH Page 234 1 asbestos correct Page 236 2 Q. Beginning in 1972 Reddaway put 2 A. Yes 3 warning or caution labels on its asbestos containing 3 Q. Okay 4 products that left its facility correct 4 And you started with the smaller 5 A. Yes 5 width or diameter products and moved to the bigger 6 Q. And they went on all the products 6 sizes 7 that contained asbestos regardless of the customer 7 A. Yes 8 A. Yes 8 Q. And the reason that you articulated 9 Q. And one of the reasons you know that 9 that was the larger sizes were used in the oil field 10 is you discussed this with earlier executives of the 10 servicing industry in Canada who had a demand 11 company who had been there prior to your coming to 11 specifically for asbestos 12 work there correct 12 A. Repeat that question 13 A. Correct 13 Q. Okay 14 Q. And another reason you know that is | 14 The reason you started with the 15 you've discussed it with the shipping manager who 15 smaller size material and went to the larger was the 16 predated your first day of employment 16 larger sizes had a specific demand from the oil field 17 A. Yes 17 services industry mostly in Canada 18 Q. And that the method of adding labels | 18 A. That was part of it 19 to the products leaving the company has been the same | 19 The other was the smaller -- they 20 since 1972 until today 20 were smaller machines to change over and get 21 A. Well we -- we quit using burlap at 2222 a certain point -- 21 running -- ~ 222222 Q. Okay 2222 Q. Right 222222 A. -- and learn how to do it 2222 A. -- and that would be -- let me 2222 think So that would be late 90's early 2000 222222 Q. And you discussed this with us that 25 the -- the particular looms were custom built looms 1 Q. Okay Okay Page 235 Page 237 1 for your company that date back to the 1890's -- 2 But -- but the method of attaching 2 A. Yes 3 it to the container -- 3 Q. -- and that these looms had 4 A. Yes 5 Q. -- -- wrapper 4 hundreds if not thousands of individual spools per 5 machine 6 A. Yes 6 A. Yes 7 Q. -- whatever it is and attaching it 8 to product has remained consistent -- 9 A. Yes 10 Q. -- as far as you know -- 11 A. Yes 7 Q. And you discussed the fact that 8 when you changed over from asbestos to asbestos 9 considerable work and adjustments had to be made to 10 those looms to effect that change 11 A. Yes 12 Q. 13 A. 14 15 question 16 -- until at least mid -- The only difference is -- MR HAMILTON Let him finish his MR BOUCH -- at least until 12 Q. And for that reason once they were 13 changed over you did not go back and manufacture 14 asbestos containing materials once the asbestos 15 products were produced 16 A. True 17 1972 correct 18 THE WITNESS Yes 19 -- 20 CONTINUATION 21 BY MR BOUCH 22 Q. Okay 23 Beginning in early 1980's possibly 24 as early or probably as early as 1981 in your 25 woven asbestos linings Reddaway began to phase out 17 Q. Okay 18 I believe you also stated that it 19 was your belief as President of the company and 20 your experience that the inventory manufactured by 21 Reddaway changed over approximately three times a 22 year 23 A. Yes 24 Q. Okay 25 So approximately every four months Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 238..241 Page 238 1 the retained inventory of a particular product plus 1 BY MR BOUCH Page 240 2 or minus a reasonable time would have been 3 exhausted 4 A. Yes 5 Q. Okay Okay Let me see 6 Got that 2 Q. Okay 3 I believe in reviewing your earlier 4 testimony it is your understanding that Reddaway has 5 never had an asbestos related workers compensation 6 claim from any of its workers 7 You were asked certain questions by 7 A. No it has not 8 the plaintiff's counsel concerning the fiber type of 8 9 asbestos utilized by Reddaway when they were 9 Q. Okay Okay Let's see here Let me see here 10 producing asbestos containing products 11 Do you recall that 12 A. Yes 13 Q. Okay 10 I think I just have one -- but let 11 me find out if I've got the -- 12 You were asked certain questions on 13 Exhibit which was the Redco Fact or Facts on 14 Mr. Barton I believe was President 15 of the company prior to your taking over -- 16 A. Yes 17 Q. -- and he had been President for a 18 very long time 19 A. I'm not sure how long 14 Friction Sheet dated July 1986 15 A. Okay 16 Q. Okay 17 And you were asked certain questions 18 as to particular warning labels 19 Pause 20 Q. But he had been with the company a 20 21 very long time -- 21 Q. Here Let me just give you mine Got it 22 A. Yes 23 Q. -- and Mr. -- is it Eggert 24 A. Yes 25 Q. Okay 22 A. Yeah 23 Q. Okay 24 You were asked certain questions on 25 the wording of warning labels contained in that Page 239 1 He was also an executive or Vice 1 exhibit correct Page 241 2 President with the company for a period of time 2 A. Yes 3 A. For a short time 3 Q. And it's your understanding the 4 Q. Okay 4 wording in those warning labels were -- were required 5 During the preparation for this 5 by OSHA 6 deposition had you occasion to review the testimony 6 A. Yes 7 of Mr. Barton and Mr. Eggert previously given in 8 other asbestos suits against Reddaway 9 A. I looked over that yes 10 Q. Okay Okay 11 If Mr. Barton and Mr. Eggert both 7 Q. Okay 8 And it is your testimony that if 9 OSHA required certain warnings that your information 10 is Reddaway complied 11 A. Yes 12 testified that the use of asbestos was restricted to | 12 13 chrysotile asbestos yarn would you have any 13 Q. Okay And that if products did not contain 14 information that could be contrary to that testimony 14 asbestos they would of course not contain an 15 A. No. 15 asbestos caution or warning label 16 Q. If Mr. Barton and Mr. Eggert 16 A. No they would not 17 discussed the fact that amphibole asbestos or 17 Q. All right 18 crocidolite and amosite was too harsh a fiber to 18 And finally ask you about 19 be utilized in the brake -- woven brake lining 19 Exhibit and 33 20 products would you have any information that would 20 21 contradict that information 21 32 is the Industrial Group Listing A. Yes 22 MR HUGHES Objection 22 Q. Okay 222 THE WITNESS I wouldn't 23 Going over it it shows I guess 222 77 24 four manufacturers 25 CONTINUATION 25 It looks like pieces per set Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Pages 242..245 1 A. Yes 2 Q. Okay Page 242 1 A. 2 here Page 244 Whatever that material would be on 3 Size drum diameter make 4 application and model across the top 5 A. Yes 3 Q. So it would have been specifically 4 individually made -- 5 A. Yes 6 Q. The make of these materials and you 7 can look through this I guess pages 7 through 11 8 these are all crane manufacturers 9 Are they not 6 Q. ~~ as opposed to a form that may 7 have been utilized for other standard products that 8 you sell everyday 9 A. Yes 10 Pause 11 A. I don't really know 12 Q. Okay Fair enough 10 Q. 11 12 I have Okay MR BOUCH That's all the questions 13 How about Exhibit 14 A. 33 15 Q. It's this one with the drawing 16 Here Use this one 17 You were asked certain questions on 18 Exhibit which involved not only a product 19 specification sheet that you have in front of you 20 but a particular product that was made for I 21 believe East Paterson Machinery Company . 22 A. Yes 13 14 15 anything 16 17 18 19 20 21 22 Thank you very much sir MR HAMILTON I don't have MR HUGHES Okay Back to Exhibit just a couple -- THE WITNESS Okay MR HUGHES -- follow Let me see that THE WITNESS Okay - > 23 Q. Okay 23 CONTINUATION 24 24 Is this a custom product BY MR HUGHES 25 A. It would have been -- we would have 25 Q. On Exhibit the caution language Page 243 1 been sent a drawing and then we would have made a 1 2 part 2 3 Q. Right 3 4 A. I have no idea what the part looked 4 5 like but it would have been on the print and it 5 6 would have said what material to use for the part 6 7 Q. Exactly 7 8 And that particular product was not 8 9 something you had in inventory or on the shelf , but 9 10 you made specifically for this particular -- 10 11 A. This one person That's it 11 12 Q. Okay All right 12 13 And so it was not necessarily a 13 14 standard shelf product 14 15 A. No it was not 15 16 Q. It would have been a custom made 16 17 A. Yes 17 18 Q. Okay 18 19 And would the invoice likely have 19 20 been in your experience custom type as opposed to a | 20 21 form that you might use for shelf or 21 22 inventory materials 22 23 A. Well it would have listed the exact | 23 24 material that was on the print 24 25 Q. Right 25 Page 245 -- A. Okay Q. -- am I correct that that is the only language of a caution or warning label that you yourself have seen that Reddaway issued for its asbestos products form MR HAMILTON Objection to the THE WITNESS Yes that I have seen MR HUGHES Okay No other questions VIDEO TECHNICIAN Is that it MR HAMILTON That's it VIDEO TECHNICIAN This concludes the deposition of Todd Walker consisting of four tapes The time is 2:53 We are off the record ---- Witness excused) - ee Deposition concluded at 2:53 p.m. ee Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Page 246 Page 246 1 I Debra G. Spallone certify that the 2 foregoing is a true and accurate transcription of the 3 notes taken by me on the date set forth 4 I further certify that I am not an attorney or 5 counsel of any of the parties nor a relative or 6 employee of 7 with the action 8 action attorney or counsel in connection action nor financially interested in the 9 10 11 12 F 13 / 14 DEBRA G. SPALLONE CCR RPR 15 16 17 18 This transcript is not to be copied unless under the 19 direct control and supervision of the certifying 20 reporter 21 22 23 24 25 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index G1688-050..1890 # G1688-050 215 $ 17.30 174 175 4637.62 168 0 3,4,12 38:16 39:20 8,9,17 9,25 47 56:24 59:25 59:257,17 62:13 158 174 175 222 224 225 1063 17 171 173 1066 173 10:13 8:19 10:20 23 10:29 23 10:48 42:25 10:58 43:11 11 102 226 227 242 1298 13,20 12:27 13,19 20,23 12:55 136 13 8:8:18 18 120 121 181 13th 18:13 14 133 15 102 1 1 39:23 40 11: 0 129 186 1/2 3,7 12,17 1/8 20 26:15 6,19 10 92 122 100 18:23 98:24 175 222 231 11/24/86 173 11:40 91:12 11:50 91:20 12 110 18 12.95 13 66 125 231 137 193 15th 122 124 163 16 139 17 141 173 9,13 1/27/88 57:12 1/3 17: 4 1/4 16:16 20 18:22 21:10 17,23 9,15,21 16,17 1009 232 1061 167 23,25 23,25 168 169 1062 171 1294 121 1295 23 65:21 66 123 1296 122 14,19 124 1297 128 180 18: 3 18 46:20 18,22 181 1800's 42 1890 42:15 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index 1890's..21 1890's 237 18th 183 19 125 162 " 1930's 103 1940's 115 204 235 1981 205 235 1982 1983 15:15 1985 28:20 16,22 25 45 11,16 11,16 61:12 62:13 : 229 125 112 27 7 22 3 1988 57:23 59 1989 78 : 1950's 105 1950's 115 1962 5 197 1972 53 94:19 95 108 113 14,20 23 119 120 141 10,19 20,25 1973 211 1975 226 227 1978 111 1980 69 70:22 200 205 1980's 72 203 9,19 21 22 35:13 38 39:24 40 45:21 3,7 61:19 162 172 204 206 5,20 224 18:13 1984 19:18 19:18 21:15 204 29:15 11:21 2 59:15 59:15 20: ,24 62:17 69 70:23 70:23 88:16 166 17,21 17,21 17,21 4,9,18 170 8,23 4,22 174 12,20 1991 176 1993 10 45 43:1697:23 1995 99:14 102 1:07 1:07 14: 9 1:08 149 1st 232 2 2 17:20 2/13/84 11,24 7,18 61 63:17 4,13,15 133 165 166 200 5,7,16 4,13 232 185 194 214 224 : 240 1987 13:23 62:21 63 77:10 114 122 124 10,23 20 163 22 20's 97:13 2000 12 37 234 2010 132 2012 8:19 21 167 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index 22..50's 22 114 19 176 13,14 225 64:19 2:16 215 2:28 228 2:37 2:53 229 30's 97:13 103 4,22 30 b 6 96:16 9 104 113 116 : 117 13 23 178 31 : 4000 32 23r 23rd d 164 2,17 24 80:17 81 1,4 25 17 18:23 98 99:10 103 194 250 18:22 18:22 257-840 169 258 19 169 26 6,11 26 A 212 27 208 25 28 210 , 14,15 14,15 14,15 28th 229 29 212 2:06 215 3 23:14 187 16's 158 : 16's : 3/23/84 3/4 30:23 14,18 19,21 16,23 33 4's 26:15 , 16,18,21 16,18,21 16,18,21 16,18,21 16,18,21 13,18 8's 8's 16:16 16:16 16:16 23 18:24 21:11 36 38:17 158 30 58:22 60 63:17 20,21 99 10,25 176 215 10 32 218 4,5,6 241 33 219 221 241 242 34 226 11,12 34188 11 164 35 98:11 160 229 : 38872 167 168 39131 171 3rd 19:18 4 4 23:15 40 11,25 19 100 40's 103 48 97:24 97:24 98 : 49 111 5 43 186 5,000 31:25 16's 16,21 22 35:19 23 36 38:17 58 50 58:25 60 96:19 23,25 100 1,7 11,20 103 135 140 174 50's 23,24 116 118 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index 5000..Abex 5000 32 51 119 82 46 97 149 7 83 45:25 516 164 7 56 2,11 A 242 60 8:19 519 24 166 168 584 19:11 585 63:18 64 586 64:14 589 18 64:17 593 65 594 18 65:17 6 6 54 : 141 60 98:23 98:23 60's 93:13 601 9 5,7 62 197 65 20,22 : 70 97:15 70's 1,4 107 72 9,25 16,22 72A 115 75 12,18 16,19 7,9 99:10 101 14,21 231 : 8 8 57:13 8/28/85 229 80's 16:18 3,4,12 16 56:25 73 104 1,17 84 134 2017 85 27:18 30 19: 7 8548 1988 1988 86 11:24 20:16 7,10 17,18 28:20 7,16 44:10 44:10 46:20 46:20 89 : 7,18 184 141 , 4,2 2 3 3 87 20:16 62 63 77 125 126 875 8:15 Abex 11:21 13 17:18 4,17 19 20 43 23,25 49 : 24,25 52 8 55:10 67:17 73:24 73:24 13,15 16 77:11 19 78 10,15 16 80 11,14 85 86:13 88:15 8,15 7,13 18,24 95:15 96 9,12 16 161 . 6th 142 197 204 80-30 24:14 81 197 25 9 9 71:20 90's 78 234 25 7,20 163 166 5,9,19 169 : 171 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index abide..appears 7,17 added 219 156 23 70 178 1,13 204 adding 234 ahead 68 74:16 Amended 10:20 208 adequate aid 106 American 223 224 11,15 17,21 abide 187 4,8 adhesive 75:14 86 adjustments 237 air 111 112 18,24 airborne 217 93:10 amosite 18,23 72 239 absolutely 116 127 accommodate 34:19 account 71:12 162 172 203 accounts 172 accurate 233 2,3,4 accurately 179 action 8:15 activity activity 216 actual 49:16 49:16 167 add 99:18 99:18 affidavit 148 5,25 : 9,11 15 affixed affixed 87:12 affordable 177 afternoon 233 afterward 125 agree 20:18 85:13 19,21 1,10 21 12: 2 128 167 196 223 agreed 5 agreement agrement 77:12 Akin 156 Alan 8:20 AlbanyAlbany 8:14 alive 25:24 161 allegation 153 allegations 12:16 alleged 89:24 153 alleges 155 13 alterations 41:10 altered 63:22 Alternates 142 4,17 Amatex 15,21 amount 44:22 97 170 192 4,5,6 4,5,6 4,5,6 amounts 97:11 amphibole 239 Amy 8 and 239 announced 172 annual 119 answers 10:14 10:14 194 208 anymore 69 71:10 183 232 : aapppep arsears Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index application..attended 18:20 57:22 64 134 174 185 196 ap lication application 5,10 11 242 applications 148 153 154 apply 127 approved 187 approximate 170 asbestos 6,23 7,11 8,13,19 21 22 25:14 27 29:13 31 33 34 40 44 13,23 45:13 47 1,16 7,22 19,24 19,24 11,15 21 59:16 11,21 2,11 21,25 . 22 63:20 63:20 5,7,15 7,20 4,9 14 104 9,14 117 118 3,5 10,20 12,21 3,5 135 12,16 141 : 142 5,10 24 159 17 161 8,13 24 171 172 : 232 233 3,7 235 1,11 8,14 9,10 8,12 13,17 240 14,15 245 as asbestos bestro elated s 200 asbestosis 12:14 asks 111 Association Association 195 21,25 April 19:18 39:23 40 58:22 60 61 63:17 : 63:17 area 160 218 aromatic 101 140 arran4 gement articulated 236 4,11 1144,,2323 14,23 67:22 4,6 2,11 70:17 23,24 6,9 84:24 12,14 22,25 88 89 12,18 20 6,8 6,7,25 99:10 174 17: 5 179 4,9,13 181 183 191 193 5,21 14,20 5,10 21 206 208 209 1,18 5,11 assume 14,16 22:19 22:19 16: 0 166 3,5 228 Assuming 193 attaching 2,7 235 2,7 attendance 197 attended 195 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index August..Bill August 6,17 181 165 174 181 97:12 11,18 119 beating 191 began 119 avoid 106 2,3,8 214 : 16,18 228 140 175 186 awareness 116 11: 8 126 awhile 55:21 B 1,13 244 backwards 34 bag 50:20 50:20 17,18 21 73:25 75 76 8 6,9 21: 3 back 13:22 bags 195 20,2320,23 20,23 11,23 235 begin begin 16: 6 226 238 : 7,11 16 Barton's 28:11 28:11 99:13 based 6 232 basically 11 15:15 8:12 63 177 234 : 235 begins 91:17 136 : 215 behalf 10:15 170 belief 237 5,13 30 36 43:10 47:16 49:10 66:18 68 71:15 95 100 3,8 4,22 106 122 135 140 : 149 5,19 153 208 baled 80:23 bales 20 19 67:22 233 : band 145 bands 153 155 Barton 22,24 22,24 22,24 26 : 24,25 : : 36 39:19 53:13 75 1 93:24 95:23 113 205 : basis 26 27:21 29 40 53 72 118 150 192 Bates 12,25 131 134 : 28:21 209 believing 118 big 19 26:13 32 33:14 4,6 11,12,24 158 181 bigger bigger 236 Bill Bill 19:14 222, 2,2424 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index bit..brake 8,11 75 97:12 119 192 226 166 11,21 197 1988 228 bit 182 214 blade 109 110 : Bouch 6 26:16 69:25 : 7,16,19 7,16,19 93:20 95 3,11 171 11,18 173 175 176 3 9,25 18: 1 182 20,21 130 132 18,25 box 839 2,3,19 boxed 80:23 boxes 10,11 22 1,7 19 83 20 218 blocks 82 9,11 22,24,25 219 220 bolt 11 bolted 157 bonded 46 78:10 218 bottom 12,13 18 19:10 44 46 11,15 87 94:23 107 121 131 133 99:17 100 101 102 : 2,4,25 106 116 117 118 1,19 1,19 125 126 127 128 132 134 10,25 14: 5 10,23 148 8,18 , 20,22 20,22 20,22 152 155 158 159 : 160 4,23 3,18 187 1988 brake 13 188 17 20 189 13,19 24 190 : 58 59 2,9 192 6 60 62:12 10,13 21 197 67:22 2,23 199 73:18 20: 1 84:20 8,19 204 93:10 117 96 20: 5 138 207 8 143 213 13,19 216 146 227 147 2316 149 10,14 17 234 153 154 16,21 240 : 155 156 244 158 169 5,9 bought 31 bought 88 19,24 6,11 12,23 12,23 92:18 98 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index brakes..cetera 171 172 3,13 17: 7 15,21 205 218 219 62 built 42:10 236 bulletins bulletins 197 bunch 18 115 177 16,19 208 Calling Calling 100 Calls 104 Canada 26:13 159 193 194 200 201 206 214 233 233 4 239 brakes 149 burlap 50:20 18,21 54 73:25 75 : 76 : 80:24 15,19 22 28:21 29:24 160 184 cases 143 200 categcoatregyory 30 230 11,12 brand 23:13 42 : 50 : , 14,17 51 brass 97:21 99 break 10:10 11 22:23 24 91 214 breath 53 : breathing : bring 112 brings 99:23 brochure 71:19 215 218 building 83 14,22 234 business 1,6,11 131 buy 90:13 156 186 19: 2 219 buying 49 C call 89:19 92:13 called 31:21 42 : 51 : 98 110 156 Canadian 30 cancer 188 carcinogen 106 card 162 167 171 cards 166 cars 146 case 12:12 5,13 43:16 66:23 12,17 110 131 : 143 11,13 154 caution 52:22 53 21,22 4,14 15,25 8,10 15,16 57 1,4,9 12,25 21,25 234 241 : 245 : 25 ceasing 29:12 ceiling 10: 9 certification certification certification 7 cetera 177 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index challenge..compensation challenge 128 chance 86 126 checking 50 cheese 150 clutch 143 149 code 208 172 comp 83 companies 156 change 20:15 25:10 6,24 56:21 94 60:19 60:19 106 : 236 237 changed 17,18 25:15 25:15 26:11 : chests 119 chrysotile 17,24 239 circumstances 176 citation 215 21: 6 217 cited 217 codes 208 collection 115 116 8,11 118 121 123 167 collector 5,6 5,6 117 collectors company 10:22 25:19 28:12 34:10 44 45:20 48 51 52:10 60:17 110 125 : 126 13: 8 148 : : 36:10 40:14 41:13 : 3,17 67:25 79 83 8,22 212 claim 200 240 clarify 175 Clark 156 college 13:25 color 4,5 4,5 141 column 220 14 207 211 21: 4 223 226 229 : 193 205 206 225 8,13 21 check 65:15 115 checuk ps 119 cleaner 109 clear 86:17 clerical . 229 client client 13,18 21,24 12,23 155 98 103 Committee 142 5,10 committees com it e s 1959 1959 committees common 98 com unicated communicated 237 15,20 239 242 compare 1687 58 comparison 132 : 10 compensation 240 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 2011ndex competed..CONTINUATION competed..CONTINUATION competed 132 confusing 43:21 58:15 68:11 70 2,14 148 complete 3,10 completed 182 considerable 237 considered 186 71:23 10,19 1,16 82:14 85:10 1,22 150 151 152 153 completely 14 44 10 71:12 84:21 97:22 224 226 compliance 215 216 complied 193 241 concluded 245 consist 73 consistent 235 consisting 245 consists 182 constantly 53:16 contained 104 234 240 container 88:21 90 92 94:13 95:10 96:25 3,25 102 104 4,15 106 107 110 115 10,20 117 4,17 4,24 155 156 157 158 159 160 6,15 162 1,23 165 167 3,13 22 173 175 176 177 concludes 91 214 245 conditions 48:16 confirm 213 confirms 38:10 conformed 193 235 contention 20:12 21:14 153 contents 201 CONTINUATION 11 17:23 23:18 26:23 43:13 45 54:11 56 57:19 123 126 127 128 9,18 132 8,23 134 136 137 139 141 144 145 5,14 178 179 1,19 181 182 4,15 185 5,22 10,24 9,21 190 191 5,21 194 196 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index continue..court 5,21 4,22 201 1,11 203 204 205 207 209 212 213 214 216 conversations 27:23 conversion's conversion's 35:15 converted 16 Conway 25:23 27:24 28 29 36 39:19 75 119 192 227 229 231 Corporation 8:15 10:16 17:18 162 163 correct 16 12,17 19,20 19,20 50:13 216 217 218 5,8 19,24 25 226 229 4,12 13 235 241 245 correctly 219 220 22: 1 224 2,15 229 Conway's 28:14 28:14 copies 187 10,12 4,12,22 77:10 80:13 81 86:24 101 106 cotton 103 counsel 6 : 24 197 238 235 239 244 continue 77:19 continued 55:15 197 : contract 156 contradict 239 contrary 239 232 copy 57:11 64:15 80:16 102 114 122 136 163 164 186 15,25 191 192 194 199 216 111 128 6,16 147 . 166 167 17,23 171 5,11 18 174 9 194 195 197 198 199 : 2,18 211 couple 92:22 191 244 court 8:16 21,22,25 9:11 10:24 17:21 23:15 43 54 56 14,17 71:21 92 102 16,19 120 133 137 139 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index crane..day 141 19,23 162 19,23 167 10,14 178 2,5 1948 7,11 208 210 20,21 201 custom 236 242 16,20 customer 92:18 93 125 176 177 234 cutting 12,21 116 117 1,8 5,14 19 D daily 26 Dakota 10 127 11,13 136 142 163 17,21 182 188 14,20 200 206 217 11,22 218 219 221 226 227 12 229 : crane 242 cranes customer's 229 customers 22 29:24 30 12,22 17,23 17,22 96 dangers 13,20 23 226 data 91:24 data 11,20 11,20 93 2,25 94:11 95:22 120 dated 17:19 18:13 18:13 19:17 22 57:12 58:22 60 95 127 134 141 crates 6,10 creating 2,3,8 crocidolite crocidolite crocidolite 18,23 18,23 72 239 curiosity 138 current 179 180 183 203 cut 84:14 108 108 109 144 145 157 cutoff 27:12 28:21 123 125 12 126 129 : 3,13 3,13 139 date 8:18 date 15:13 6 44 63 77:21 78 95:23 122 7,9,13 176 185 197 17 200 223 226 227 229 240 dates 164 David 176 day 53:25 75 77 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index deadline..discussed 107 234 deadline 152 deposed 9:23 213 194 196 210 11 diameter 236 242 Debra 8:22 deceased 25:25 28 December 176 : defendant 9 194 212 Defendants 194 degree 14 Delegates 142 4,16 17 7,12 9:22 21,23 4,6,13 12 13:14 17:20 23:14 5,7,16 54 56 57:13 57:13 74:20 16,20 10,18 92 97:23 99:14 11,12 17,22 8,25 10,14 21 216 10 218 221 226 227 229 239 : 15,22 depositions depositions 13:12 96:16 depth 17 describe 109 : differ 169 difference 15,17 25 82:17 141 235 direct 48:19 Director 198 200 225 Directors 12,25 disagree : delivery 67:17 demand 26:13 39:12 10,16 Department 91:23 91:23 120 133: 218 depending 138 133 1,3 136 137 139 141 148 161 : 1629 1629 163 167 176 178 185 describes 220 description 14:10 destroyed 136 detail detail 153 182 development 33:22 Dexter Dexter 4 : 22:16 discarded 199 disclosures disclosures 12,19 discoudnt iscount discount 8,16 discovery 194 discussded iscusseddiscussed 10,15 236 237 239 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index discusses..earlier discusses 182 discussion 23 43 216 228 discussions 201 disease 188 dispute 129 199 72 distributor 24:20 4,8 1,8 distributors 178 133 134 139 20,23 13,24 149 174 176 178 179 10,14 20 186 17 199 : 216 219 227 231 23: 2 documentation 226 229 dot 63:16 doubdoublele 37 : drawing 6,7 224 242 243 drawings 41:16 155 Drayton 8 drill : drilled 84:11 145 drilling drilling 115 5,6 13,16 3,8 11,23 7,8,9 157 1587,13 217 228 duty 18:25 1,21 60 64 78:23 130 132 6,8,9 20,24 170 18,22 23,25 14,17 District 16,17 doctor 129 documents 12 11 21 13,16 13,16 5,16 106 110 2,8 145 driver 39:16 driving 39 drum 242 earlier 37:16 58 102 112 11: 5 22:10 25 29 54:14 57:23 67:12 18,20 6,8 125 130 123 137 175 194 196 197 198 208 dust 106 107 2,3,8 6,12 17 110 9,15 113 114 179 184 204 : 227 24 228 234 : 240 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index earliest..exhibit earliest 134 early 21 16:18 22 2,4,12 16 37:25 42 56:25 107 : 115 effective 179 5,9 232 effects 106 Eggert 124 end 17 26:14 29:24 52 63 69 144 145 156 160 17: 9 evidence 14,24 exact 28 20 77:21 206 224 243 EXAMINATION 116 177 203 9,16 9,16 234 23,24 earth 147 East 176 211 242 Eastern 8:16 easy 75:15 eat 109 EBONY 169 19 170 23 175 13 Ed 124 20 196 edge 208 176 195 196 : 209 238 7,11 16 Eggert's 124 elected 200 elevators 21,22 : 21,22 , 23 emergency 106 147 employee 126 employees 21: 7 ended 130 ending 135 engineer engineer 41:16 66:22 entity 207 entry 174 175 equipment 147 : 148 149 152 Erenstoft 176 Erik 8:13 233 excused excused 245 executive 239 executives 234 exhausted 238 exhibit 10:23 17:20 18 : 43 : 50 : 54 56 57:13 20,25 73:10 92 102 110 120 133 : effect 29:25 108 237 : 16,24 125 employment 234 error 112 et al 8:15 everyday 244 139 : 141 148 162 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index 1..fabricate 163 11,17 10,18 178 : 133 Exhibit 17,25 139 Exhibit 212 Exhibit 23:21 24 8,15 23:14 exist 25 exiesxtie stded 194 20: 8 11,19 : 10,21 216 219 221 226 227 7,16 241 Exhibit 11 Exhibit 92 94:23 3,14 96 3,6 122 140 Exhibit 110 Exhibit 6,19 159 EEx xhh ibi itbit Exhibit 141 142 145 162 165 3,6 7,17 Exhibit 47:16 58:11 63:17 64 Exhibit 16: 5 Exhibit 167 16: 8 171 Exhibit 178 Exhibit 185 : 240 : Exhibit 196 EExxh hiibb it it 209 : 49:11 135 Exhibit 216 Exhibit 218 Exhibit 241 Exhibit 221 13,18 Exhib t Exhibit 50 Exhibit 80:17 97:24 Exhibit 54:13 55:10 2,8 Exhibit 56 Exhibit 57:21 59 Exhibit 85:12 85:12 87 : exhibits 11:12 expect 144 155 : expected : 145 expensive 233 experience experience 243 explain 36:25 138 155 223 exposure 12:17 expressly 223 extent 115 19: 7 F F.W. 25:22 24,25 fabricate 222 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index fabricated..foresee fabricated 224 face 17:13 17:13 20:19 facility 11:20 18 1,4 69:17 234 facings 143 58:25 60 66 117755 fiber fiber 238 Fiberglass Fiberglass 1,21,24 17,21 57 80 Fiction 29:19 field 167 229 filled filled 68 : film 17,22 final 98:19 170 fifnianlallyly 241 find 11:15 12 42:21 fixed 47 flagged 18 flap 22 75:20 85:23 flat 61:20 210 223 224 Flex 139 flexible 87 : 237 : 239 240 factory 42:10 42:10 Facts 29:19 29:19 184 240 fair 15 150 : : 14,15 , 18,20,21 38:25 4,13 16: ,17 16,17 125 18: 1 9,16 fields 28:23 30:11 38:23 184 fifty 104 19: 0 194 240 finfe ine 55:19 55:19 89 : finish finish 88:18 88:18 88:18 223 235 : finished 84:11 99:2: 4 floors 42:10 flying 117 FMSI 142 6,19,25 143 19,21 5,8 7,24 199 200 folder 11:21 184 242 February 18:13 FedFedereal ral Federal 212 feet 17 : 23,24 figure 21,22 24 67 figured 219 figuring figuring 140 file 57:11 16: 3 21 104 183 firm 53 fishing 17,25 fit fit 98:10 98:10 145 fix 145 folks 119 follow 244 foot 18:23 2,7,10 13,19 175 foreseforeseee 154 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index forgive..give forgive 31 form 8 19:21 18,23 44:14 45 55:18 5,13 21,24 1,4,14 69:25 7,8 76:20 77:14 82 6,7 93:20 94:24 95 14,22 23 99:17 20,23 102 2,3,24 105 : 10 106 107 7,18 117 1,15 120 123 125 14,16 127 16,22 12,24 25 145 24 146 25 147 19 148 10 150 17,18 17,18 153 11,24 157 16,17 5, : 8 4,21 161 171 11,18 117735 176 : 177 179: 2,21 2,21 , 22 : 180 181 182 1,2,7 8 3,18 187 1,21 22 190 2,9,20 3,18 19 204 13 205 7,8 213 220 243 244 245 : forms 20:15 21,24 233 formula formula 7,18 7,18 found 166 196 210 219 foundation 89:21 191 193 ffrrame ame 170 friction 12,13 16 71:18 19,22 1,6,7 19 83 22,24,25 12,24 184 Friday 8:18 front 73:10 14 102 113 242 ffuullll 21 : 24:16 25 function 119 future 200 G m 212 G1688-050 G1688-050 21: 6 gave 190 209 general 158 generate generate 157 :16 generated 68:14 158 Genuine 207 Gipp 43 132 133 134 2,20 6,23 7,18 4,5,11 240 give 20:17 66 182 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index giving..handed 233 240 group 30:15 195 76:19 77:13 82 157 158 giving giving 119 179 glued 146 157 good 154 233 goods 12,25 governing 156 218 241 grove 145 Grumble 3,21 23 guess 30:23 112 125 134 183 232 85 88:18 5,12 13,21 100 101 4,7 3,23 105 107 110 114 24 115 116 159 160 14,17 165 176 177 178 179 180 1,7,13 185 187 188 grade 98 103 241 242 graduated 63 green 150 Grey 221 grind grind 169 170 grinder 182 guns 86 guys 11:17 190 H half 23 16:16 38:17 19,20 15,25 8,13 121 123 126 128 129 5,14 133 134 135 137 189 1,23 191 3,18 1938 9,14 1,14 199 6,18 204 207 208 grinding 2,9 13,17 21,23 grooved 145 grooving 2,8 6,7 halfway 80:21 81 164 200 Hamilton 4 18,23 45 18,23 18,23 57:16 58:11 6,13 11,23 145 11,24 9,18 148 10,16 21,24 1,9 2,7,17 2,7,17 155 : 213 220 221 223 233 244 7,13 hand 11 45 handed 18 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index handmade..Hughes 43:15 137 148 194 227 22: 9 handmade head 114 116 heard 97:15 16 132 25 160 : 202 207 holes 145 157 hope 233 hose 20,25 house 230 9,15 8,22 15,17 20,25 3,9 : 116 117 42 hands 151 handwritten 164 hang 18:12 129 happen 82:24 170 happened 25:19 39:23 162 208 209 4,6 212 217 heavy heavy 58:25 58:25 59:21 60 64 78:23 130 132 147 170 Hughes 2 20 11 17:24 16,22 25 23:19 26:24 42:21 43:14 43:14 45 : 54:12 55:20 56 57:20 12,16 68:12 70 71:24 118 5,18 11,14 11,14 , 16,25 16,25 16,25 5,25 125 : 24 5,7 10,19,22 25 127 18,20,23 18,23 6,10 6,10 16,19 happening 86 hard 60 78:14 132 153 206 harsh 239 held 23 43 216 228 helpful 151 historical 136 11,14 20 2,17 10,15 7,11 88:22 8,24 90 91 92 94 6,14 96:15 97 9,24 9,24 7,25 3,6 136 2,11 14 138 139 : 144 hazard 188 :20 hazards 16,25 217 226 15: 2 hold 48:15 189 holhole e 138 : 21,25 4,24 101 1,16 6,9 5,13 16 106 : 147 3,12 15,24 2,5 13,21 2,23 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index huh..identification 13,19 151 17,20 5,16 20 154 3,16,21 14,18 21 3,6 157 21,23 1,9,12 160 1,4,7 23 192 22 193 194 12,17 3,6,22 5,23 8,13 2,12 22,25 203 204 205 10,14 hundreds 237 Huseby 23 8:21 hydraulic 153 hydrocarbons 101 140 hygienist hygienist 112 177 178 199 200 18,22 210 14,17 226 228 232 243 identical 52 13,16 12,22 24 164 16,19,24 165 167 4,14 23 173 175 176 177 3,12 179 2,20 181 182 5,11 16 185 6,23 188 4,11 10,19,22 10,19,22 10,19,22 10,19,22 190 6,15 210 14,18 7,18 213 4,22 215 5,25 217 1,4,9 220 221 224 3,13 16 228 229 231 233 239 16,19 24 245 huh 67:15 2018 hundredhundred 66 I idea 19 50:25 61 65:12 66:16 72:17 87:22 97 2,20 15,21 16,18 23 129 130 131 132 9,11 140 143 148 152 156 6,21 161 162 173 identification 17:21 23:15 43 : 54 56 57:14 71:20 120 22 133 137 139 141 148 10 163 19 167 178 185 196 20: 8 210 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index identify..interested 212 215 218 221 226 229 16,17 23 35:17 23 36 15,22 3,4,7 17 39:21 industrial 14:12 16:10 1,3,9 12 146 12 149 195 206 221 226 14,20 21 241 identify 223 ignorance 31 8,9,17 9,25 4,7 56:24 59:25 153 154 203 218 219 informing 47:25 ingredients 99 II 123 3,5 7,8,17 62:13 230 241 Initial 212 III 123 implement 187 imply 197 important 65:16 impossible 25:15 97:18 127 Inc.'s 110 194 212 158 175 2,3 222 224 1,13 18 230 include 101 18,20 182 included 119 increased 128 inch 16:16 20 26:15 20 27 5 28:17 5,13 19,23 15,18 19,21 indicating 104 130 individual 109 237 individually 244 industries 126 industry 54 98 109 177 10,17 information 23:12 25:21 1,6 40 47:21 48 68:18 69 88 94:21 97 108 126 14,17 159 160 161 6,10 179 inside 109 installed 109 110 112 113 1147 12,23 12,2123 ,23 institute 107 12,24 5,20 208 209 210 insurance 176 177 interact 110 interested 201 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index internal..label internal 48 229 International 8:14 8:14 interpret 5,11 60 63:18 64 6,7,17 8,21 12,13 184 Interrogatories 13,24 194 23 167 23 168 10,16,25 169 208 170 interrogatory 115 203 204 209 introduce 8:25 8:25 introduced 15:17 8,10 6,17 174 222 4,7,20 6,17 24: 3 invoices 14,17 59:14 inventory 16:19 21 181 19,22 204 2,17 206 1,4,5 237 238 9,22 77:25 166 4,18 171 21,25 204 223 224 involved 153 242 invoice 18:11 irrelevant . issued 49:12 122 136 210 245 item item 212 16,17 items 207 IV 1287 J January 165 John 2 153 17,25 3,5 21,25 7,10 221 Johnson 8:22 join 198 216 Judge 89:17 July 184 185 193 200 232 240 jump 233 K kind 43:20 72:24 152 156 200 kinds 180 219 knew 78:13 79 160 knocks 3 99 knowing knowing 117 knowledge 93:17 97 100 105 150 16,18 161 188 189 192 11,14 213 226 L label 54:21 58:22 58:22 issue 107 193 4,6,14 15 56 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index labeled..lining 10,15,16 57 74 162 14,16 late 1,4 42 161 163 15,17,18 19 190 115 168 22,24 13,16 116 197 7,9,23 12,13 204 234 76:17 7,9,11 13,15,18 4,8,22 82 : 83:23 83:23 6,9 14,16 15 218 16 234 18,25 241 Labor 91:24 12: 0 133 234 latest 21,22 21,22 lawsuit 12:13 12:13 213 hand 131 159 leftover 62 : legal 183 86:23 87 137 21,25 21,25 9,18 21 187 23 188 13,24 : 3,25 1937 218 241 245 labeled 213 labeling 5,9 87:21 213 labels 53 20,21 55:25 3,14,18 10,21 80 137 Lacarrubba 22: 6 lack 69:22 Lading 19:14 8,11 Landers 8:14 language 55:15 11,21 23 189 24 190 16 191 25 192 244 245 Lanz 226 227 larger 16:11 54:22 9,15 16 201 lawyer 21:24 65:15 lawyers 11 114 2,9,17 leads 94:16 learn 236 learned 49 20,23 leaves 15: 0 leaving leaving 23: 4 led 176 left 24:21 87 106 123 127 142 143 legitimate legitimate 199 length 17 : 36:18 153 letter 141 6,: 25 177 226 227 liability 176 17: 7 light 20 169 limit 107 lining lining 17 18:25 8,13,19 8,13,19 29:13 44:17 44:17 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index linings..looms 12,21 48 49 50:14 51:16 56:11 58 1,6 8,22 2,11 62:12 67:22 2,23 4,18 10,14 11,19 78:11 79 80 81:24 12,20 5,8,14 16 85:14 13,22 87:25 5,16 8,16 93:10 96 104 8,19 11 109 110 117 126 130 1,20 140 141 7,8 19,21 19 146 147 2,7 151 154 155 20,25 1,2,4 6,14 5,9 20,24 12,23 171 172 175 177 179 4,9,13 10,22 205 206 211 4,17 224 225 17,18 233 239 : linings 14:16 13 5,10 143 11,12 15,21 230 235 list 24:14 16 25 12,17 21 67 3,10 95 13,20 23,24,25 198 200 9,22 6,16 1,15 listed 197 232 243 Listing 218 241 lists 171 197 21,24 25 232 11 litigation litigation 160 202 locate 11:20 166 : located 167 Log 162 logo logo 161 long 27 77:18 108 204 18,19 21 longer 49 225 looked 52 73:18 5,13 90:23 131 141 : 239 : 243 loom : 30:20 2,22 34:17 36:10 37 39 14,16 20,23 10,12 47 18,19 63:22 63:22 206 10,16 10,16 looms 16:17 25:10 33 35:23 11,22 11,22 7,8 42:14 112 225 236 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index loss..marked 3,10 loss 153 lot 34 109 146 low 33 lower 97:12 lubricates 113 237 machinery 30:24 34:17 205 242 machines 32:14 33:24 4,25 145 186 17,18 15,18 21 219 3,6 makes 41:24 making 180 193 manufactures 149 manufacturing 10:22 15:23 23:12 41 57 61:24 87:16 110 17 148 lubrication 113 lunch 135 lung 188 lungs 107 M M2010 130 131 132 machine 30:20 19,20 21,24 7,9,17 20 36:21 38:22 24,25 113 114 155 : 176 8 211 223 225 : 22 236 made 24 30:20 31:19 35:16 42 90:11 150 181 4,9 10,12 13,17,18 2,6 237 242 1,10 16 244 maintained 34:14 major 69:15 make 34:23 11,20 63:14 86:17 6,10 213 234 manila 78:14 3,22 manufacture 15:10 90:16 98:20 4,5,6 237 manufactured 12:18 13 13,17 20,24 47 94 206 237 manufacturer 14:11 90:12 155 manufacturers 241 242 194 21: 2 215 17,18 5,11 229 March 133 134 1,2,3 4,5,17 marked 11 10:23 17:20 14,21 43 54 56 57:13 71:19 91:25 96 : 12 120 : 133 137 139 5,14 148 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index market..mining 162 123 measurements met 11 167 176 : 178 196 = 208 133 3,12 133 3,12 139 182 196 Medical 225 meeting 197 158 method 235 Mexico 69:18 10,20 215 10,20 10,20 215 : 221 226 229 market 38:23 38:23 mask 106 107 masks 107 Master 194 : material 22 57 69 71 91:24 11,20 2,24 94:10 95:22 11,17 97 7,19 7,19 20,21 104 109 120 121 243 6,24 6,24 243 : materials materials 12,13 141 195 196 4 226 : 242 :14 24: 3 matter 8:13 8:13 MDL 8:15 meaning 19 means 89:11 17,21 143 145 181 14,15 205 3,16 3,16 228 2,25 231 meant 47 meetings 13,21 member 1,6 18,20,21 143 5,8 19,24 197 198 208 209 members 14,19 memorized 77:23 mention 30 mentioned mentioned 28:17 31 35:19 37:16 102 mentions 125 mesothelioma 128 120 133 139 208 microphone microphone 221 233 mid 235 1972 2,20 2,20 235 middle middle 10,11 143 174 203 231 232 mine 69:17 79 240 minimum minimum 33 : mining 148 149 150 152 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index minus..non minus 238 minute 66 90 129 minutes minutes 91 23 : 191 192 206 237 move 11:,24 11,24 nature 103 108 109 nearby 228 necessarily 15,16 25 45 10,12,16 20 46 17,19 47 : 17,19 1,14,22 49:23 53 12:24 mist 110 5 112 18 113 17,25 228 model 242 modern modify 42:17 moldmeoldded 15,20 15 82:22 4,19,25 5,15 7,12 16,18 3,419,24 19,24 140 155 210 mover 147 MSDS 17 92:13 93:19 18 3,13,14 1,6 15,18 13,14 17 101 102 7,15 19,20 124124 7 125 127 134 : 11,14 11,14 19,23 10,16 4,8 159 1,12 170 1,2 N monitor 8:19 needed 34:14 126 News 178 197 1987 199 200 newsl newsleter etter 29 Nice 233 night night 196 nods 142 204 asbestos 14:11 15:14 2,6,9 17 20:14 24 5,15 22 24 3,10 32:25 33 56:14 58 16,17 60 1,12,18 1,12,18 63:21 65 5,11 66:15 6,15 : 6,15 88 89 125 2,6 170 171 1782,16 8,16 173 2,4 17: 5 176 . 177 180 181 204 205 1,8 13,19,20 111 : NAPA 207 19,24 6,10 22 225 232 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index normal..objection normal 146 North 111 not notaattioi n on 229 noted 149 notice 11 10:21 123 noticed 34:23 November 27:10 2,10 : 20,23 62:17 122 110 111 114 119 131 13: 2 136 163 : 164 12,14 21,22 2,23 1,23 24 168 11,16 171 187 189 Number - 9 73:11 numbered 114 131 : numbers 3,6 4,8 16: 4 11,12 16 219 20 0 O.S.H.A. 215 192 10,24 25 199 20 201 220 objection 45 : 18,21 72 76:19 77:13 77:13 82 : 89 93:20 13,21 23 99:17 100 22,23 4,6 2,3,23 2,3,23 105 125 12,23 127 141 142 164 173 174 179 5,9,13 10,24 214 226 227 number 8:15 203 209 214 216 219 229 230 Number 15 137 Number 2 18 : Number 21 167 Number - 22 69:23 100 object 55:20 69:25 72 85 89 95 115 116 118 145 14: 6 154 171 177 179 1,2 107 116 24,25 120 121 123 125 14,15 127 13:,15 129 132 133 4,21 10,11 2,7 57:16 Number - 28 210 189 : 16 145 10,23 ; Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index objections..packaged 18 148 10 150 10,16,18 15: 2 153 10,24 157 15,17 5,8 245 objections 8 occasion occasion 239 : October 171 173 9,16 older 152 page 50 : operation 2,8,13 operations 144 originally 12:17 42 OSHA 53 84:15 112 118 4,7 125 133 4,20 17: 2 shelf 14,21 opposed 243 186 8,18 2,15 175 176 9,25 178 2,21 180 181 182 184 4,9,16 4,9,16 28:20 306,16 6,16 office 41 17,18 Officer Officer Officer : Officers order 16:18 17:19 16,20 68 145 15: 7 229 230 2,3 193 216 6,13 218 227 5,9 OSHA'S 94 : OSHA 94:24 24,25 188 1,3 9,19 3,18 8,10 2,14 20: 1 202 18,19 11,13 205 6,8 213 : officially 17: 9 180 oil 16:11 14,15 18,19,21 28:23 28:23 30:11 30:11 23,25 39 4,13 4,13 83:16 125 145 ordered 22,: 23 22,23 22,23 ordering 18:21 52 70:11 71 orders 52:10 59:19 71:13 ore 69:17 69:17 organic 99:10 98 103 111 overexposure 106 P p.m. 245 package 170 171 packaged 54:17 843 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index packages..personal packages 20 packaging 87:21 packet 92:19 179 182 183 193 213 19,22 162 176 181 6,13 17 189 17,21 11,23,24 25 99 10,19 10,15 1,7 11,20 | packing 93 54 3,9,18 224 194 203 14,15 21 104 pages 19 pages 43:20 64:18 67 137 231 236 2,4,6 particulars 207 208 272,816 135 140 percentage 73 97:13 140 209 240 10 5,7 13,17,18 221 232 242 Paller 8:20 panic 183 paper 153 155 paperwork 19:15 paragraph 8,25 207 219 222 party 201 pass 28 passed 26 past 11:12 63:11 93 211 Paterson 176 211 Payable 162 payment 230 PEMCO 9 156 pending 177 Pennsylvania 8:17 people 50:16 92:13 140 percentages 100 104 performed 144 period 38 16 40 61:19 698,24 8,24 7,22 78:20 88:16 89 189 part 14:25 112 169 68:24 119 120 149 151 200 percent periodic 227 19 97:20 21 7,9 11 personal Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index personally..price 161 picture 233 122 188 189 192 73:17 13,20 18,20 point 26 27:12 33:11 10,14 160 187 personally 12,20 21 personnel piece 156 158 pieces 144 56:19 21,22 23 109 110 presence 72 present 12 217 pertinent 241 place 75:19 : 196 199 167 : preserve phase 23: 5 phased 30:18 phenolic 101 158 Phillips Phillips 8:13 13 phone 9 : 13,14 216 photo 54:20 phrase 182 8,19 224 physical 119 227 plaintiff plaintiff 13 plaintiff's 110 114 194 20: 8 238 plaintiffs 3 plant 12 44:13 67:18 76:24 79 87:23 90:18 108 162 21: 9 231 234 pointing pointing pointing 164 points points 78:25 policy 96 : 92:92:17 17 107 : position position 13:19 11,14 11: 8 possibly 235 post 12,15 powder 31 President 13:20 : 13,15 148 237 14,17 14,17 239 press 216 pretty 115 : previous 13:14 previously previously 239 price 21:19 24:16 25 12,16 21 51:24 65:10 66 75:10 79 : 76 pick 14 70:13 156 pneumatic 86 Pneum abex o 7 93 234 preparation 239 prepared 16: 8 12,19 7,12 13,24 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index prices..products 177 23:13 50 190 213 210 6,16 20,24,25 1,6,8 11,15 prices 24:12 49:22 210 232 problem 34:22 143 problems 33:14 Procedure 54 212 191 195 209 210 237 producing 69 179 180 10,21 223 224 235 238 : 18,20 24 243 14 production pricing 21:20 procedures 106 238 product 21 19,21 2,5 8,9 51:23 66:18 primary 73 print 225 proceed 66:23 9:16 process process 2,5 44:15 54 181 15:20 23:12 31:16 40 47:20 48 73 55 : 5 7 76:16 84:11 29:13 14,25: 14,25 14,25 114 179 4,8 18: 3 208 5,24 printed 51:20 prior 15:23 21:15 39:23 183 processed 181 produce 16,18 9,15 93:25 96 19,23 : 20,24 100 101 products 12:17 44:13 49:23 49:23 21,25 71:18 73 11,25 13,18 20,24 59:18 74:20 77 94:20 131 206 234 238 private 115 137 produced 11:24 22:17 44:25 63:22 77:25 114 4,25 13: 7 160 2,6 1,4,7 17,18 136 13: 9 141 144 154 176 22 177 : 207 20208 87 7 83:17 1519,1 9,14 4 16 169 17: 3 182 193 15 211 5 9 226 4,6,19 236 21 375 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index prospect..quote 238 175 6,14 125 239 241 244 245 purchased 88:17 132 159 128 137 138 145 140 149 3,13 177 prospect 160 2,25 179 20: 2 protect 125 purchasing purchasing 88:15 purging 187 191 207 13,16 184 5,15 17 191 14 210 protected 75:24 protection 10: 7 108 > 44:11 purported 72 purpose 107 234 puts 97:22 214 putting 89:20 53 217 235 : 24 236 questioning questioning provide 69 113 161 1548 provided 192 providing providing 92:17 publicize 48:21 publicized 172 published 118 pull 22:20 33 pulmonary 114 purposes 2147 Pursuant 212 put 51:22 52:25 52:25 6,21,23 54 56:11 10,25 3,4,22 76 80:24 82 19,24 21,22 182 Q qualities 34:11 question 9 10 : 12:24 12:24 13 45 14 46:12 50:11 70 80:22 81:18 82 88:19 89:13 questions 10 19: 1 193 213 233 238 12,17 24 242 245 quit 234 quote 112 128 : 143 10,13 purchase 87:17 88:24 23 3,5 94:18 102 105 3,7 13,21 115 121 203 209 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index 2..recess R 0 2 219 raise 221 Ralph 226 227 ran 26:14 2,3 109 randomly 156 : range 27:18 153 154 ranges 37:13 129 : 11,15 4,17 13: 9 140 RBW 25 46 48:16 59:22 69 944,18 944,18 96 98:19 10: 1 3,15 14,25 134 135 138 8,16 183 reading 96:15 6 127 149 184 195 ready 12 11 35:13 40 84:11 85:18 213 real 42:17 reason 21 30:10 38:20 115 17:19 23:14 23:14 43 : 54 56 57:12 57:12 71:19 91:25 110 14 120 : 133 137 : 139 14: 1 142 161 163 18 167 : raw 31 69 71 11,17 Raybestos 17,20 88 130 139 140 219 221 Raybestos 219 Raylon 207 Raymark 146 147 2,6 18,23 152 159 11,20 4,8,12 182 218 ask 105 branding 77:1277:12 76:15 : read 82 83 : 95 : 96:17 174 179 199 209 234 8,14 8,14 237 reasonable 155 238 reasons 177 234 recall 227 238 received received 10:22 178 1946 195 196 : : 20: 8 21: 0 21: 2 291,5 20 218 221 226 229 recess 135 136 215 : Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index recognize..Reddaway recognize 227 110 3,15 57:11 17,21 20,23 126 record 23 5,8 42:24 2,11 47:18 127 134 135 21,23 20,24 62:11 63:18 5,7,13 127 3,11 13,20 6,25 86:17 140 14,17,18 4,12 13,21 159 2,17 15 132 21,24 136 16,20 3,17 18,20 23 229 245 recordreecd orded 166 records 184 210 215 218 220 1,10 240 Reddaway 5 15,21 15,21 11:20 16 5,9 68:14 1,2,10 23 70:11 22 1,5 4,15,22 73 76 12,18 11,18 8,18 8,18 79:12 134 18,22 5,19 2,13 15,19,24 1,18 24 143 6,20 148 14: 9 9,14 23 18 41:15 58 4,5 6,9,14 7,23 91:24 9,12 15,20 69:22 9,14 90:24 12,15 163 rectangular rectangular 138 Redco 19:24 23:13 46 54 71:19 76 18,22 18,22 2,17 21,22 21,22 21:14 23:11 25 26 27 29 31 32:22 35 4,20 40 47:25 47:25 : 21,24 : 14,16 24 52:11 52:11 14,24 18 96:16 98:19 107 108 110 112 116 12,23 2,15 2,20 121 10,14 18 124 2,19 7,17 9,18 22 163 15 164 165 10,16 21,24 18,25 1,16 170 3,17 6,7 15,16 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index Reddaway's..reporter 3,14 21 177 178 180 185 3,15 227 4,17 11,16 17,22 7,22 234 6,17 referencing 151 refrefere ed rred referred 184 related 172 240 released 18 22 188 18 189 23 190 7,16 235 237 238 239 referring 112 115 151 relevant 154 remained 235 4 8,16 8,16 19,24 : 19,24 197 : 12,18 13,17 14: ,18 21 201 16,20 4,13 203 204 15,18 21 208 9,14,18 209 210 211 10,20 215 217 218 219 2,17 2,17 12,18 12,18 225 3,16 3,16 245 5 245 Reddaway's 14:10 92:16 118 : 19 130 145 123 Reddaway 123 Reddaway580 18 Reddaway584 19:10 reduce 117 reduces 8,9 referenced 49:17 references 212 refers 44:21 56:20 60 184 228 reflect 227 reflected 168 reflecting 18:16 18:16 reflects 98:18 regard 11:19 12:23 26 154 Regional 24:19 regulation 94 186 regulations regulations 84:15 112 193 181 remember 29:11 63 80 84:10 114 216 repeat 12:21 26:17 79:11 236 reprhephraserase 10 replreplacemeant cement replacement 48:19 replacing 22 reporter 2:2,25 22,25 9:11 10:24 17:21 23:16 43 54 : 56 : : 14,17 71:21 71:21 92 : Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index Reporting..roll 102 110 Request 110 respiratory 106 reviewed 13:12 120 208 3,18 194 133 requested 108 reviewing 139 141 15 19:,23 162 20,23 93:22 Requests 110 required 21,22 response : 111 : 119 204 240 revise 189 revised 94:25 167 11,14 178 2,5 194 93 4,7,10 128 3,7,15 190 responses 110 114 115 119 133 RFM 23 139 21 risk 128 7,11 208 210 212 11,22 218 219 218 4,9 requiring requiring 107 : Requisition 230 194 203 11 restricted 239 result 72 riveted 9,12 RNAW 15:18 16 46 : 24 48:15 48:15 49:13 221 226 Research 33:22 results 111 16,22 : Reporting Reporting 8:21 represent 18 131 166 216 233 representing 5 201 resell 186 reserved 9 resin 98:24 99 99::119 9 101 158 resins 97:19 98:15 103 resold 140 respirators 218 238 : retrofit 34:15 retrofitted retrofitted 25:12 Rev 94:24 94:24 reverse 66:22 66:22 review 239 23 141 : 4,19 25 223 13,19 22: 4 10,13 10,13 , 22 225 13 RNAW 24:14 Rock 221 Role 211 2 2 roll 17 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index rolled..sell 15,22 10,13 23 75 10,11,13 19,21 105 125 1,9 144 155 S S.K. 51 221 : Salesman 230 sample 72 samples 4,13 161 sack 80:24 140 77:11 80 81:23 82:11 848,14 16,25 13,17 13,22 206 208 room 32:10 roughly 31:25 73 safeguard 107 safety 91:24 91:24 2,25 94:11 95:22 sampling 111 6,9 6,9 18,24 scraped 85:25 86 150 151 ' 155 156 158 5,6 2,6 13,17 20 224 rolled 11,25 182 rolls 17 18:23 52 54:16 64:20 77:19 78 9,17 8,15 104 214 round 37 rub 75:22 rubbed 86 85:24 rul rule e 66:13 89:17 rules 53:10 193 6,8 , 24 33 35:10 48:23 running running 44:16 121 : 123 125 126 129 3,13 3,13 139 sale 183 sales 11:21 23 18 47:17 557 7: :2 22 2 58 73 90:23 156 20,23 1,21 1,21 167 : 173 sealing 6 searched 12 41:22 sec 135 SECO 11 51 Section Section 107 6,8 11,15 11,15 3,5 128 129 sell 40 21,25 21,25 77:19 77:19 90 : 127 : 15,25 8,16 15,18 21 | 229 : 183 5,6,7 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index selling..show 16,17,18 series 10 12,14 73:23 219 64:20 126 79:12 244 137 127 85:18 selling 15:24 25 40 52:10 13,16 services 236 servicing 129 20,22 3,13 134 138 14 171 14,15 231 93:13 126 169 203 set 40 110 208 : 12,14 19 139 10,17 shipper 197 shipping shipping 222 circular 241 sewn 138 159 160 170 67:12 138 213 send 92:22 160 226 sending sending 93:19 sense 63:14 153 sentence 10,15 183 184 separate 30:20 40:11 223 224 sequentially 37:21 shape 44:14 shear 20,22 : 20,22 sheet 22 23:13 24 38 40 47:21 91:24 48 11,20 11,20 93 94:18 3,13,14 96 1,6 101 120 121 19 123 9,13 11,21 223 11,18 240 242 sheets 19,25 92:17 94:11 94:11 95:22 122 136 140 159 211 shelf 243 230 234 shop 116 short 230 231 239 shovel 149 152 show 41:16 47:13 72 14,16 88:14 137 shipment shipment 2,4,23 143 shipped shipped 1,4 15: 5 : 174 175 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index showed..speculate 196 162 skinnier sort 54:25 212 7,8 55 173 showed 13,22 72 88:24 204 244 sitting 62:10 63:18 slip 93 slip 161 sorts 154 sought 177 showing showing 54:16 67:17 166 180 209 shows 20 66:12 128 151 171 232 inch 109 slitting 182 2,3 2,3 small 88:11 192 smaller 10,14 sound 93:14 155 sounds 188 speaks 106 121 165 3,7 197 209 218 241 side 17 38:25 39 55 62:13 74:18 79:23 6,20 158 236 4,15 19,20 sold 16 14,16 63:20 70:17 77:11 78 spec 24 16,17 special 75:13 86 107 specialist 131 159 164 sign 65:21 signed 149 156 signing similar similar 141 6 sir 9:21 23:20 33 43:15 64 86:18 92 sizes 16 10,11,14 7,9,15 22 : 12,15 18,20 35:11 20,25 5,16,21 9,20 61:17 180 181 204 6,9,16 11,14 85 127 144 14: 7 193 19 200 206 207 somebody's 79 someplsomeplace ace 114 specific 16:15 204 -236 specifically 193 236 243 244 : specification specification 24: 2 speculate 151 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index speculating..submit speculating 82 Standards 12,24 statement 52:22 53 126 206 speculation speculation 74:21 89:20 104 20,21 spell 212 spoken 119 spools 11,16 11,16 , 25 32 187 5,20 stands 153 staple 86 stapled 86 : start 80:21 80:21 120 129 146 80 86:12 116 128 129 180 States 8:16 stating 161 26 stay 207 : 210 stop 61:24 191 226 stopped 179 19: 3 203 204 226 33 183 216 stopping 17,22 24 4,12 38:22 39 99 237 : Spouse 8:14 springs 33:21 33:21 started 13:22 13:22 14 : 22,24 26 35 6,10 36 44:11 53:19 57 83 : 204 steam 149 152 steel 110 7 112 21 Step 187 steps 32:22 94:10 94:10 108 179 4,8 4,8 183 stores 207 strands 113 strike 41 : 27 73:22 73:22 3 2048 stamp 134 Starting 119 187 stickers Study 142 5,: 10 208 stand 16 109 standard 17 67:24 109 24: 3 244 starts 12: 3 166 state 84:15 stated 179 237 stipulated 5 stock 35:13 38 57 7 60:22 2,12 2,12 1,2,12 1,2,12 63:20 63:20 117 2,7 2,7 118 213 219 subcommittees 195 submit submit 112 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index submitted..terms submitted 111 34:10 20,21 tag 8416 138 16 2,7 42:24 subsequent 130 144 subsequently 11:23 18 199 25 38:21 3,10,21 45:20 47 55:16 14,24 80:12 3,7 tags 52 taking 9:21 30:23 238 talk 21:23 119 43:10 68 5,9,17 12,17 136 16,19 214 215 suits 239 supplied supplied 162 supplier 15: ,24 15,24 70 suppliers 69 4,11 4,11 140 support 14,18 29 suppose 206 : swiswtitcchhinig ng 3,10 30:25 35 48:22 sworn 9:14 system 11,13 109 110 112 113 1 16,19 6,13 213 221 228 taltalkkinig ng 17:11 29 32:17 56 81:22 83 97:12 97:12 158 194 Tannish Tannish 141 tatpapee 8:12 233 : 12,14 tell's 55:22 telling 90:22 90:22 138 206 215 233 tension 34:14 tensions 33:15 33:15 41 suspected 136 terms 12:16 swear 11 switch switch 44 37:15 37:15 181 swistwcih tcehded 14,15 h 160 tacked 86 75:15 tacks 75:13 taped 188 tapes 245 technically 8418 8:11 9:10 51:20 74:21 74:21 78 : 115 161 229 230 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index terribly..times terribly 33:20 test 72 tested 23 72 testified Textile 208 209 Thedford 18,24 thick 27 1 thousands 25:11 36:24 throw 200 5,14 13,15 19,23 1,6 139 : 141 2,5 204 211 239 testifying 76:16 testimony 20:22 : 8,9 39:18 59:25 75 78 84:23 87 88 89:20 95 1,10 116 132 15: 8 180 193 2115 218 36:15 thickness 3,4,8 11 21:10 31:19 37 38:16 23: 0 thin 206 thing 39 50 53:24 2,6 75:18 114 193 213 23 things 34:13 10: 3 113 thinking thinking Tim 6 233 time 9 19,24 9:10 10:20 14 : 17:18 22 9,11 35 23 26 37:20 38 40 42:25 43 13,24 54 55:25 57:11 61:19 8,24 7,22 71:18 71:18 78:20 82 88:16 89 12,15 : 12,15 , 149 154 163 167 172 176 178 184 189 194 195 4,19 208 9,23 212 2,5,7 16,19 218 21 221 225 6,14 240 241 tests 111 119 140 thinner 205 230 thought 33:18 13 60:16 154 95:25 95:25 102 : 10 110 119 120 124 133 228 2,4 : 2,18 21 239 245 times 9:25 21 40:25 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index Tina..unbranded 7,8 22,23 204 10,12 13,18 207 23: 7 Tina 8:14 38:11 12,15 61:16 74 75 88:17 119 179 180 : 198 19,21 6,19 211 216 217 220 242 total 73 tradename turning 227 turnover 206 page 185 type 117 132 10:15 13:17 14:11 41:25 62:10 63:18 66:12 : 151 161 : 171 181 190 204 232 234 Today's Today's Today's 8:18 8:18 Todd 9:13 43 : 11,18 136 14: 8 21: 4 215 245 told 11 26:10 36 213 6,7 Tom 153 196 top 13 17:12 18:14 19:2 24:13 24:13 43:21 44 43:21 :8 57:22 58:24 64:18 86 2,6 106 113 114 115 13 123 : 124 127 129 130 139 142 175 179 194 transcript 5,15 transitioned 170 trial 9 10 trucks 146 True 14 80:11 87 237 Trumble 22,25 7,10 214 turn 21 31:15 166 205 : turned 34:10 34:10 96:18 21,23 204 9,11 207 238 243 typed 59:19 106 types 14:16 152 typically 50:21 52:17 55:11 55:11 55:11 typo 112 213 U U.s 120 159 U.S. 91:23 133 139 unable 69:23 unbranded 1,25 5,21 60 5,8,19 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index uncharged..Walker uncharged 105 183 197 variation 157 videotape 8:21 uncommon 126 undated 202 220 226 240 : ventilation 4,9 4,9 Verbally Verbally 10,18 136 215 VII 123 underlying 8,12 underneath 48 55 3 94:24 106 understand unit 66 174 United 8:16 unquote 112 128 144 verified 209 version 48:16 63:20 176 27 versions VIII 107 Vincent 226 violations 217 virtual y virtually 109 13 50:11 86:16 93 187 191 221 233 understanding 11,15 20,22 39:20 90:15 92:10 92:10 97 : 120 122 127 203 209 unrelated 197 updated 23,24 95:23 user 156 users 144 versus 36 8:14 VI 123 Vice 28:15 239 video 8:11 10,16 2,7 42:24 utilized 238 : 23: 9 244 5,9,17 : 12,17 136 16,19 24,25 visible 81:15 VOICE 216 volume 8:12 W wait 46:18 129 waived 7 walk 30:24 82:25 82:25 125 146 154 10,24 vacuum 11,13 20,25 233 12,14 11,19 135 5,11 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index walls..woven 215 245 walls 109 wanted 22:20 40:11 40:11 44:12 94:10 112 225 water 110 5 112 18 113 16,25 228 : ways 6 157 3 wear 11 107 218 winches 149 150 152 Winchester 67:18 67:18 wise 97:13 witnesses witnesses 74:21 working 13:16 26 53:19 117 18: 1 214 worth 137 woven 14:13 16,18 15 Warehouse 24:20 warning warning 52:22 weaving 5,7 14,21 218 96:16 wood 116 117 : 2,6,7 2,6,7 18:25 24 27 : : 4,7 4,7 15,17 50:13 58 wording 85:25 138 162 187 189 11,13 16 193 12 234 24 108,1285,25 4,: 15 warnings 52:25 241 Warren 27:23 28 75 119 192 226 weeks 181 weiwegighhtt 10: 3 Wellman 221 51 240 241 words 61:23 72:14 83 112 183 wet 228 8,12 When's 22 white 54:25 width width 8,10 8,10 : 17 5,6 5,6 236 widths 48:23 183 wife 191 William 43 11,18 work 33:12 34 48:25 113 234 237 worked 13 86:15 126 workers 107 240 workers 240 60 61 62:12 64 : 4,17 10,11 20,23,24 82:22 85:14 90:25 1,2 96 104 7,19 130 1,24 144 : 5,6,8 9,19,24 170 4,18 23 218 222 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889 ERIK ROSS PHILLIPS ET AL vs ALBANY INTERNATIONAL CORP ET AL Todd Walker on 04/13/2012 Index Wow..Yup 223 20,21 222 231 4,6,15 227 235 24 1,3 239 6,9 113 Wow 42:16 wrapper 235 8 114 140 159 18,25 writing 161 156 181 written 156 208 239 wrong wrote 100 37:16 yarn's 96:17 yarns 33:15 year 21 25:10 rays 119 Y yarn 12 25:11 31 11,25 32 3,5,9 12,22 1,2 111 162 195 201 204 10,12 14 2,3 237 11,20 35:10 8,15,17 37 11,15 24 70 11,17,22 71 96:11 7,14 years 15:23 69:14 78 22,25 94 105 125 160 17,23 195 233 Yup 168 Huseby Inc. 1230 West Morehead Street 408 Charlotte NC 28208 www.huseby.com 704 333-9889