Document byYbgRq1YGVzX7Bbz6bYLd1v0

Page 2770 1 You have been deposed on several occasions; 2 is that correct? 3 A Yes. 4 Q How many prior occasions do you think you 5 have been deposed on? 6 A I don't know exactly. I would presume 7 around 10 perhaps or 15 at the most. 8 Q So you are pretty familiar with the process; 9 is that correct? 10 A I would hope so. 11 MR. SMITH: Page 32. 12 BY MR. SMITH: 13 Q During the time that you were employed by 14 Ford, were you aware of files that involved 15 government contracts supplying -- Ford supplying 16 asbestos-containing brakes or friction products during 17 those years? 18 A In a few instances, on friction materials, 19 yes, I was aware of some special military vehicle 20 operations, SMVO. 21 Q Excuse me, special military --