Document aBDQnJordggZbOk9q1Kp13r9R

1 between 1978 and 1985. Page 64 2 A Okay. 3 MR. LANKFORD: Objection to form. 4 THE WITNESS: Okay. 1978 to 1985. 5 BY MR. RUCKDESCHEL: 6 Q Is there a potential for exposure to airborne 7 asbestos in opening a box of brake pads? 8 A If they are asbestos-containing brake pads 9 there is a possibility for exposure. I don't know if 10 it's quantifiable but there is a potentialfor 11 exposure. 12 Q Are you aware of anybody attempting to 13 quantify the potential exposure of opening a box of 14 asbestos-containing brake pads? 15 MR. LANKFORD: Let me object to the question in 16 terms of form and with respect to privilege. And 17 specifically with respect to form, you know, what you 18 mean by quantity and, you know, asbestos, either talk 19 about the different types or the issue with respect to 20 what is asbestos, and with respect to privilege, you 21 know, and any work he may have done in a consulting 22 fashion in that regard. To the extent he's not relying 23 up on it again -- 24 JUDGE KLINE: Well, can we have the question 25 again? ESQUIRE DEPOSITION SERVICES (415) 288-4280