Document d2YwxVx2ypvp0mrB7bXoymxb
FILE NAME Kaiser Gypsum KG
DATE 1998 DOC KG051
DOCUMENT DESCRIPTION Legal - Deposition of John E. Crum
VIDEO DEPOSITION OF JOHN CRUM 11/6/98
Case No. 98-2-24915-3 SEA
SUPERIOR COURT OF WASHINGTON FOR KING COUNTY
--000--
JOHN E. CRUM and MARILYN
J. CRUM a married couple Plaintiffs
-VS-
THE E.J. BARTELLS COMPANY
CORNING AMERICAN
CORPORATION GAF CORPORATION individually and as successor to
THE RUBEROID COMPANY ARMSTRONG
COMPANY CORK COMPANY KAISER GYPSUM
;
UNITES STATES GYPSUM COMPANY THE
ASBESTOS CLAIMS MANAGEMENT
CORPORATION fka NEW NATIONAL GYPSUM
COMPANY - CERTAINTEED CORPORATION
and W.R.
GRACE & CO - CONN
Defendants
/
DEPOSITION OF JOHN E. CRUM
called for examination by counsel for Plaintiff pursuant to
Notice at 1200 Chance Lane Reno Nevada on Friday
November 6 1998 before Karen Yates a Notary Public
APPEARANCES See separate page
REPORTED BY
VIDEOGRAPHER :
KAREN TATES AER
Nevada CCR No. 195
BILL STEPHENS
SIERRA NEVADA REPORTERS
702 329-6560
EXAMINATION By Mr. Bergman
INDEX
iii
PAGE 1
DEPOSITION EXHIBITS
No. 1
family photo
PAGE 8
No. 2
photo of house
6
No. 3
photo of Alaska warehouse
16
No. 4
photo of Alaska truck
20
No. 5
photo of Carey product
26
No. 6
photo of Kaylo product
26
No. 7
commendation
39
No. 8
commendation
39
No. 9
commendation
39
No. 10
commendation
39
No. 11
Salesman of the Year award
40
No. 12
photo of award ceremony
40
No. 13
Kaiser Answers to Interrogatories
41
No. 14
warning
42
All original exhibits kept in possession of Mr. Bergman
SIERRA NEVADA REPORTERS 329-6560
: APPEARANCES
For the Plaintiffs
For the Defendant Kaiser Gypsum
For the Defendant American
For the Defendant W.R. Grace For the Defendant E.J. Bartells
For the Defendant CCR
For the Defendant
Corning
ii
WEINSTEIN & BERGMAN
2
By MATTHEW P. BERGMAN ESQ
1201 Third Avenue Suite 5300 Seattle WA 98101-3000
4
6NE WILLIAMS KASTNER & GIBBS PLLC
By
Two 601
KENNETH E. PETTY ESQ Union Square Union Street Suite 4100
Seatle WA 98101-2380
-and-
JACKSON & WALLACE
By BRUCE A. FICHELSON ESQ
1 580 California Street 15th Floor Floor
at,
San Francisco CA 94104
12 BONNETT FAIRBOURN & BALINT
FRIEDMAN
By ANTHONY J. FERNANDEZ ESQ 4041 North Central Avenue Suite 1100 15
Phoenix AZ 85012
GORDON & REES By PAUL CLARK ESQ San Francisco CA
STEELE & SALES P.S. CHERYL A. ZAKRZEWSKI ESQ 700 Fifth Avenue Suite 5511 Seattle WA 98104
GORDON THOMAS HONEYWELL MALANCA PETERSON & DAHEIM
By HENRY WINDER WEBB III 600 University Suite 2101 Seattle WA 98101
17
20
121
23ESC
JONES VARGAS
By ANNE J. WILLIAMS ESQ 201 West Liberty Street Reno NV 89504-0281
RENO NEVADA FRIDAY NOVEMBER 6 1998 10:05 A.M.
--000--
Also present in the deposition room were Marilyn crum John Dean crum and Brandon Crum
MR BERGMAN We are on the record now This is
Matthew Bergman appearing on behalf of plaintiffs John and Marlboro Crum This will be the perpetuation deposition of plaintiff John crum
Plaintiffs agree and stipulate that an objection from one defendant during the course of the examination will be deemed an objection for all defendants whether or not the objecting party is still in the case at the time of
trial
If any of the other counsel have statements they would like to make on the record this would be a good time to do that Okay In that case why don't we begin Just
a moment
MR STEPHENS This deposition of John crum is being held on November 6 1998 at 1200 chance Lane Reno Nevada The caption of the case is John Crum and Marilyn crum versus the E.J. Bartells Company et al The deposition is being taken on behalf of the plaintiffs
Time on record is 10:06 a.m. The videographer's name is Bill Stephens of Bill Stephens Productions
would all attorneys present please identify
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS (702)329-5560 (702)329-5560
SIERRA NEVADA REPORTERS 702 329-6560
:
Pages i - 1
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
_
2
l themselves and state the parties they represent
2
r 3
MR BERGMAN Matthew Bergman for the plaintiff MR PETTY I am Ken Petty representing Kaiser
__-4
S
Gypsum Company
MS ZAKRZEWSKI Cheryl zakrzewski I represent
6
E.J. Bartells
7
MR FICHELSON Bruce Fichelson representing
8
Kaiser Gypsum Inc.
9
MR CLARK Paul Clark W.R. Grace
10
MR WEBB Henry webb C.C.R.
11
MR FERNANDEZ Anthony Fernandez for
12 American Corp.
13
MS WILLIAMS Anne williams Corning
14
MR STEPHENS The reporter's name is Karen Yates
15
from Sierra Nevada Reporters who will now administer the
16
oath to the plaintiff
17
JOHN E. CRUM
18
called as a witness by plaintiffs
19
having been first duly sworn
20
was examined and testified as follows
21
22
EXAMINATION
23
BY MR BERGMAN
24
Q Good morning
25
A Good morning
SIERRA NEVADA REPORTERS (702)329-6560
1
Q And what does your eldest son do for a living
2
sir
3
A He works for he works for -- can't recall the
4
name of the company
5
Q Okay Is one of your sons a doctor sir
6
A Yes he is
7
Q And what son is that
8
A That's Donald Ray Crum
9
Q
10
A
11
Q
12
A
13
Q.
14 ' sir
15
A
And what kind of medicine does Donald practice He's an emergency room physician
Do you have any grandchildren
have 11 grandchildren Do you have a close relationship with your sons
Yes I do
16
Q what are some of the things that you and your sons
17 do together
18
A well we have a boat we use that quite often
19
we go chukar hunting and fishing when we're not working
20
Q Do you work with your sons
21
A Yes do
22
Q How about relationship with your grandkids DO
23
you see a lot of them
24
A see a them lot Enjoy them very much And they
25
stay in this house with me quite a bit
SIERRA NEVADA REPORTERS (702)329-6560
12
2 ~~
3 4 5 6 7
Q. Could you please tell the jury your full name
sir
A My name is John E. Crum m Q Mr. Crum where do you live
A live in this home right here
Q where is that located sir A The location is 1200 chance Lane Reno Nevada
8
Q And how long have you lived in this home here
9
sir
10
A have lived here since 11/15 of '88
11
Q '98 sir you think
12
A of '88
13
Q sir are you married
14
A Yes am
15
Q And what is your wife's name
16
A Marilyn J. Crum
17
Q Is she here with us today
18
A she's here
19
Q How long have you and Marilyn been married
20
A we have been married for 53 years
21
Q Do you and Marilyn have any kids
22
A We
23
Q what are their names and their ages
24
A They are John Dean Crum age 38. And Robert Lee
25
crum he's 43. And Donald Ray Crum is 42
.
a
SIERRA NEVADA REPORTERS (702)329-6560
123
Q Do you have a special room in this house that is
123 used by your grandkids
123
A Yes have three -- I have two bedrooms that they
4
occupy
5
Q sir you indicated a little earlier that you
6
worked with your sons Are you still working
7
A Yes you bet
8
Q And what business are you in
9
A I'm in the building business until I got this
10
11 12
13
mesothelioma
Q could you tell me a little bit about the building
business that you used to be in before you got sick A well we built houses like this one This is the
14
last house we finished
15
Q Now when you say the building business do you
16
mean that you hire contractors to build homes for you
17
A No we do all our own work all our own work
18
Q By we who else works with you
19
A My sons John Dean primarily My oldest son has
20 a_nother job with another company
21
Q How many houses have you and John Dean built
22 ~ together
222
A Probably about 35 or 40
222
Q And do you sell the houses that you build
222
A No.
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
Pages 2 - 5
_ VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
6
1
Q or do you rent them
2
A well we keep the houses and rent them
_
3
on
---
we
build
the
house
we
rent
it
we hold
wit
Q You said that you built these houses yourself
S
sir what are the kinds of things that you and John Dean
6
did when you put these houses together
7
A on this particular house here we did everything
8 but the roofing the drywall and the carpeting
9
Q You did the concrete work
10
A we did the concrete work we do the -- everything
11
this house Electrical plumbing the boiler work We
12
do the entire job and we don't have any we don't hire it
13
out We don't let subcontracts
14 15 16 17 18 19 20 21
22 ~~
23 24 25
Q sir I'm handing you what has been marked as
Exhibit Two Can you tell me what that photograph shows A This is this house right here
Q Is that the house that you built with John Dean
A That's right we did everything on this house but the roofing We do the stucco work we do everything on here but the roofing and the drywall
Q sir
could you show Exhibit Two to the jury please
A The witness complies S sir is this home something that you are proud of A I'm very proud of this home
SIERRA NEVADA REPORTERS (702)329-6560
1
know find a good spot where we can catch one
2
Q Do you go with the grandchildren fishing
3
A we go
4
Q okay sir I'm handing you Exhibit one I ask
5
you if you can tell me what that is
6
A Yeah that's a family picture of --- that's the
7
grandkids my daughter and my -- and my
8
daughter parents are there we are all a pretty
9
close group
10
Q sir before you started having your current health
11
problems how were you feeling
12
A was feeling great I was feeling great up until
13 about the eighth month I and got this tightness feeling
14
across my chest and I went to the doctor And my right lung
15
was full of this liquid The lung was clear up at the top
16 collapsed The right lung was full of liquid so they
17
drew over two quarts of liquid off of it
18
Q And before August of 1998 sir had you ever had
19
any serious health problems
20
A was never sick I had a hernia operation and
21
that's about it That's the worst thing that I had ever
22
had had never been to the doctor
23
Q Have you ever smoked cigarettes sir
04
A Never Never smoked a cigarette in my life
25
Q sir in August of 1998 when the doctor drained the
SIERRA NEVADA REPORTERS (702)329-6560
i.
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
won
7
Q Before you became ill sir did you and John Dean have plans to build additional homes
A Yes We bought this piece of land right here and
there were five lots here and we have two houses built on
the property now And our next step was to go right next door and build another one just like this we never build two houses the same but the same footage and all that same quality that's in this house we were going to have next
door
Q when you and John Dean are building houses together sir how many hours a day would you work on average
A would say we work about nine hours a day average Some days we if one of us are sick why we just take off you know Take off a couple days two or three days if we want to But usually it's the other way around we just keep going you know we work steady
Q sir before your current problems did you have any plans to slow down
A never thought about slowing down Q what are some of the things that you and your family do together when you are not building houses A well we go out in the boat We have a Bayliner boat And we go up to - we go chukar hunting up near winnemucca we go fishing when we get a chance to You
SIERRA NEVADA REPORTERS (702)329-6560
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
fluid off of your lungs what did he tell you was the probable diagnosis
A Well have an incurable lung cancer called mesothelioma It wasn't in the lung It was in the lung cavity on the outside of the lung
Q And who was with you sir when your doctor told you about your diagnosis
A son was with me and my doctor son Don and John Dean was with me
Q Did you and your sons and your doctor discuss
treatment options
A Yes
Q And what kind of treatment is available for your mesothelioma
A There no treatment They did the biopsy thing and that was pretty serious Then they just buttoned me up They have no treatment for this
Q what do you understand to be your prognosis A well I won't be here in a few months Q sir are you experiencing any physical pain as a
result of your mesothelioma A hurts bad
Q can you tell us where you are hurting A well from half my body the right half to the back to the spine around to right down there This right
SIERRA NEVADA Reporters (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
Pages 6 - 9
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
10
12
there
12
Q Are you taking anything for your pain
~
A oh yeah They've got the pain under control If
_ didn't have these patches they put on me they put these
S
patches on and it's an opium patch It makes it so can't
6
feel it see But have side effects see from it
7
Q Are you having any trouble breathing
8
A have a hard time breathing I'm short of
9
breath If I walk 25 feet I'm breathless
10
Q sir in the last two weeks would you say that your
11
condition has gotten better or gotten worse
12
A I'm getting worse every day Every daya little
13
bit worse
14
Q Today is Friday sir On Monday are you going to
15
have any specialist come out and talk about your care needs
16
A Yes I'm going to have a group here in town that
17 __ tend to people like me
18
Q Is that hospice
19
A Yes
20
Q sir what is your understanding as to what caused
21
your mesothelioma
22
A They told me it's caused from asbestos only
222
Q Have you been exposed to asbestos over your life
222
sir
25
A Yes have been
|
\
12
12
Q were you working -
2
A was a carpenter see So I a became joiner
3
And ajoiner puts in -- I worked up in the captain's
4 quarters installing furniture
5
Q were there any other trades working around you
6
when you were working inside the Liberty ships at Kaiser
7 shipyard in 1942
8
A welders plumbers pipefitters asbestos workers
9
There were pipes If you've ever been in a ship there's
10
thousands and thousands of feet of pipe
11
Q what kind of work were the asbestos workers doing
12
aboard the Liberty ships at Kaiser Number Two in 1942
13
A They were covering all these pipes They covered
14
steam pipes
15
Q can you describe for us sir how the asbestos
16
workers went about covering steam pipes on board those
17 Liberty ships at Kaiser shipyard in 1942
18
A well they open up the piece of pipe covering put
19
it on the pipe and they wrap it Of course they have to
20 ~ msake the joints where the pipe makes a bend They have to
21
hand fit that wrap it Coat it they coat it with a paste
22
and finish it off
23
Q when the pipe coverers would miter the pipe to get
24
it around the bend was it necessary to saw it saw the
25 material the pipe covering
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS (702)329-6560
;
11
1
Q when was the first time you were exposed to
2
asbestos
3
A In my opinion the first time is when I went to
4
Alaska
5
Q Before you went to Alaska sir did you ever work
6 in shipyard
7
A Yeah I worked in Kaiser Number Two for a short
8
time Kaiser Number Two
9
Q was that in Richmond California
10
A Yes huh
11
Q And was that in 1942 that you worked there
12
A Just before I went in the service
13
Q And what kind of work was going on at Kaiser
14
Number Two in Richmond in 1942
15 16 17 18 19 20 21 22 23
24 ~~
25
A They were building Liberty ships Q For those of us who didn't live through world war II can you tell us what Liberty ships were A They were a powered small freighter designed to carry war products to the British
Q And were there a lot of Liberty ships that were
being built in those war years A well one out every other day I think Q And what kind of work were you doing on those
Liberty ships A was a joiner
SIERRA NEVADA REPORTERS (702)329-6560
13
123
A To size it
123
Q saw it
123 4 S 6 7 8 9 10 11
A don't know what you mean
Q when you were working around asbestos workers at Kaiser shipyard in 1942 did the asbestos workers ever have to saw the pipe covering
A Oh saw it Yes of course they did There was dust Sure they had to saw it to make the joints and so on and the bends that are required These pipes take different bends They go up run along a ways and make a
left turn and so on
12 13 14 15 16
17 ~
18
Q what was the air like inside the Liberty ships at the Kaiser shipyard in 1942
A Now I worked the night shift They had lights there you know And you could see the dust and the debris in the air Although they had blowers on the ship to get
asll that out At night you could really tell what was in
the air
19
Q sir after serving at working at Kaiser shipyard
20
did you go into the service yourself
21
A Yes did I went in the Air Force
22
Q And did you serve in the Air Force during world
323
War
24
A Yes did
323
Q After world war II did you get some
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
Pages 10-13 10-13 10-13
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
1 2
._
3
I
"
S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
14 education
secondary education
A went to the University of California at Davis
Q And what did you pursue there what course of
study A Oh I was pursuing animal husbandry
Q Have you worked with animals since then sir
A well came from wyoming originally and I always dreamt of having a big sheep ranch And it was a crazy idea I know
Q Mr. Crum I've seen your dog outside the size of a sheep isn't it
A Yeah he's about that big
It's about
Q sir you testified a little earlier that you
worked up in Alaska there
what company were you working for up
A worked for Fiberglass Engineering and supply
Company
Q when did you first go to work for Fiberglass Engineering and supply company
A well I first joined Corning at santa clara
And then --
Q was that in 1943 Excuse me 1953 sir
A Yes
o okay
A And then I moved north to Alaska
SIERRA NEVADA REPORTERS (702)329-6560
16
1
Q what was your job up in Alaska
2
A My job was to keep the branch operating do the
3 __ payroll all the -- keep track of the jobs keep track of
4 the inventory the cash box
5
Q were you the highest ranking person working for
6
FENCO in Alaska
7
A well the top man was a man named wally Muncie and
8
he was in seattle I got well acquainted with him on the
9
way up there
10
Q But in Alaska you were the number one guy
11
A Yeah yes
12
Q sir can you describe a little bit more what this
13
warehouse was like that you operated in ~
14
A It was a building about as big as this house It
15
had a small office on the front with -- had a desk in there
16
and filing cabinets we had a little adjoining room where
17
there was a bathroom and then another door that went out
18
into the warehouse
19
Q sir I'm handing you what has been marked as
20 = Exhibit Three can you identify that photograph for us
21
A That's it That's the warehouse
22
Q Is that what the warehouse looked like in 1953 to
1956
24
A Yes
25
Q Did you take that photograph
SIERRA NEVADA REPORTERS (702)329-6560
15
1
Q Okay Is FENCO an abbreviation for Fiberglass
2 Engineering and supply
3
A Yes is
4
Q As you were moving north to Alaska when you were
S
working for FENCO sir did you happen to stop in seattle
6
A did I stopped in seattle
7
Q Did you work for FENCO in Seattle before you went
8
up to Alaska
9
A Yes I did
10
Q what kind of work were you doing for FENCO in
11
Seattle in 1953
12
A I did I was kind of kind of in training I was
13 doing inventory learning their accounting procedures
14
payroll and all the company records that had to be kept you
15
know in the process of operating the branch up there
16
Q what building were you working in when you were in
17
FENCO's seattle operation
18
A was working in the warehouse and in the office
19
Q what was the warehouse like sir
20
A well just like all warehouses It was a dusty
21
place you know I mean all warehouses you go in there
22
and the dust is an inch thick That's the way it was in
23 Anchorage also
24
Q when did you get up to Anchorage sir
25
A got up there in winter of '53
J
SIERRA NEVADA REPORTERS (702)329-6560
17
1
A Yes did It's a cold place
2
Q How many people were working for FENCO up in
3
Alaska during the 1953 to 1956 period
4
A well we had had a warehouse man named John
5
Colgan and myself Then we had these crews these asbestos
6
workers who did the -- the contracts were figured in seattle
7
and then they were sent up there and we were in charge of
8 the doing the job
9
Q And approximately how many asbestos workers did
10
FENCO employ in Alaska in the '53 to '56 period
"fi A well if varied but about 30. we had about 30
12 people
13
Q what were some of the major insulation contracts
14
that FENCO had in Alaska during the period that you worked
15
up there
16
A we had jobs all over Alaska Some of them lasted
17
quite awhile Some were short lived you know It didn't
18
take us long to finish them They would be building new
19
ones and sending them up to us and so on you see
20
Q what were some of the major jobs that you recall
21
A we had jobs in the Elmendorf
22
Q Elmendorf Air Force Base
23
A Fort Richardson we had -- let's see we had the
24 DEW warning
25
Q what was the DEW warning system sir
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
Pages 1417 1417 1417
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
L
2
_w
5 6 7
A That was during the cold war when we were a little
bit afraid of the Russians There was radar it was a radar setup that they placed these domes across the Arctic Circle some jobs we had to fly the material out there to get it out there to the job site
Q was it difficult to keep FENCO's crews supplied
with insulation material
8
A very very difficult because it was particularly
9
we were busy then Material was in short supply There was
10
lots of work and people were hard to hire then They were
11
scarce
12
Even though somebody didn't do their job you
13
didn't go out and fire them because you would have nobody
14
then to do anything You had to put up with their the
15 things that you didn't like about them
16
Q As result of some of those problems sir did
17
you have to conduct inspections and trouble shooting on some
18 of these major jobs
19
A I went out to these different places and you do
20
what you can you know You send six men out there to do
21 job and they won't do anything for a whole week They'll be
2222 ~~ partying out there
2222
Q well sir --
2222
A Instead working on the job
2222
Q when you would --
SIERRA NEVADA REPORTERS (702)329-6560
20
1
it with material that looks like cheese cloth Then they
2
coat it and they have these stiff brush They put the
3
adhesive on there and so on That's the way they covered
4
the whole thing when they get done it looks all white
5
Q How would the insulators form the block insulation
6 7
8_
9 10
to size when they were putting it around a boiler A To size Oh they cut it they cut it with a saw
in the field
Q what would happen when they would cut it with a
saw
11
A They get dust they get lot of dust They get
12
dust when they mix the adhesive
13
Q sir you testified that FENCO would sometimes have
14
to fly supplies in Would FENCO also use a truck to supply
15
its crews with product
16
A Yeah Well we had a lot of building insulation
17
there that we sold to the local people It was a pretty
18
good market we sold a lot of insulation that way And we
19
had we have a delivery truck That's it right there
20
Q I'm handing you Exhibit Four
21
A This is the delivery truck that our man colgan
22
delivered around town you know In Anchorage 43 years ago
322
doesn't look like it looks today
322
12 sir, in addition to doing trouble shooting on the
322
job sites would you do any fabrication of insulation
SIERRA NEVADA REPORTERS (702)329-6560
with
Eskimo
19
12
A Having a big party with these Eskimo women
12
Q well sir when you would go up to the job sites
3
and break up the party would you try to get them back to
4
work
5
A Oh yes sure but you don't fire them because
6 then you get absolutely nothing done
7
Q And can you describe for us sir once they get
8
back to work the kind of work that you would observe the
9
insulation crews doing on these job sites
10
A well sometimes you would go out and everything
11
would be going fine you know
12
Q can you describe for me the kind of work process
13
they were going through
14
A Oh yes well you mean how they did the job
15
Q Yes sir
16
A Okay well they -- there was probably a pipe
17
covering job and could be a boiler room
18
Q Let's take a boiler sir How would the
19
insulators cover a boiler typically
20
A well what they do is they cover the boiler with
21
flat plate insulation They would put they mix this
22
_adhesive up in gallon can you know They put the
23
water in They put in the powder to make the adhesive And
24
they stick the insulation on there
25
Then of course they have to they usually wrap
SIERRA NEVADA REPORTERS (702)329-6560
1 2 3 4 5 6
7 ~~
8 9 10
11
12 13 14 15 16 17 18
21
components yourself
A when we had a special job they occurred pretty
often inch pipes or so And they are these these lines come down They make bends why I could -- I would make these segmented fittings in the warehouse so the asbestos worker he just drops those in and then finishes right over it
Q why would you A Expediates the work for them Q can you describe for the jury sir how you would go about manufacturing these fittings A well I saw those right in the warehouse
Q what kind of a saw would you use
A we had a big table saw there so I would segment
them up with that And it went along pretty good The dust the dust was every place though But there was dust
out there anyway you know There was dust there when I got there
19
Q what would happen when you would hit the asbestos
20
with the power saw then
21
A The dust would fly
22
Q And would that dust be cleaned up or would it just
23
add to the pile
24
A No we just leave it there Hey I only had John
25
Colgan and I. And he was out of commission most of the
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
.
Pages 18 - 21
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
22 1 time ;
~~ 2
~*~
cones S
Q could you enlighten us what would cause Mr. Colgan
to be out of commission from time to time
A He had a tendency to drink a little bit and spend
too much at the Last Chance
6
Q what was the Last Chance sir
7
A The Last Chance was it was a -- it's a topless
8
club All the girls came up from seattle you know And
9
the boys would spend most of their time And old John
10
would he'd spend all of his time down there And then when
he came back to the warehouse his little room back there
12
where the bathroom was And that's where he spent the day
13
And I'm filling his orders Local delivery orders
14
a_nd other things that needed to be done So I didn't have
15
much time to sweep the floor
16
Q sir
17
A The dust just laid
18
Q sir you talked about maintaining the inventory
19
can you describe for us the system that you used to maintain
20
the inventory at the FENCO warehouse in Anchorage between
21 = '53 and '56
22
A well when I got up there I took an inventory we
323
had a big cardex file It was all checked out you know I
25
started then we started Orders coming in I posted to --
24
12
A One of them was named Bartell and the other one
2
was Boron or something like that
3
Q - was that Brower
4
A Brower of course
5
Q sir would Bartells and Brower ever purchase
6 supplies from you
7
A Absolutely That was the thing when we were
8
out when we were out of material why we could buy from
9
them You know it was a vice versa thing you see
10
Reciprocal agreement we could buy from each other
11
Q Sir did FENCO's Alaska warehouse have one
12
particular type of asbestos product or many different
13
manufacturers products
14
A Oh they had different products because when we
15
would buy from Bartells and the job was over we had to
16
bring that back into our warehouse We couldn't take it
17 __ back over there and give it to them So we kept it
18
Q And as the manager in FENCO was it your
19 responsibility to maintain the inventory
20
A Yes I was not supposed to let the inventory run
21
down to where we couldn't keep our jobs going
22
Q was it your responsibility sir to know what
23 __ products were present in the warehouse
25
Q sir do you recall the manufacturers of the
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS (702)329-6560
23
1
and when I placed an order I made a reference so on when
2
it came in why it often came in short
3
Q on these card files that you had sir or these
4
note cards would you indicate the manufacturer of these
S particular insulation products
6
believe so believe did yeah
7
Q was the seattle office always able to supply you
8
with the insulation products you needed to satisfy your
9
contracts
10
A No they were short a lot of times That's what
11
made big problems We had to pick up the materials that we
12
couldn't get Took about three weeks to get the product up
13 _ from Seattle
14
Q was it -
15
A Unless we flew it up That was a big premium
16 thing
17
Q So sir were there times when you didn't have
18
three weeks to wait for the product and had to get it right
19
away
20
A That's right yes
21
Q How would you get it
22
A we would buy it from the local our local
23 competitors
23
Q who were some of your local competitors from whom
25
you would buy insulation products
SIERRA NEVADA REPORTERS (702)329-6560
1
asbestos products that FENCO used between 1953 and 1956 in
2 Anchorage in Alaska
3
A They used Kaylo They used Pabco carey and
4
Armstrong We had to keep those we had to keep those
5
products We couldn't take them back over
6
Q Let me ask you a few questions about these
7
products Did you ever see any warnings on the boxes well
8
the boxes of Kaylo that breathing asbestos was dangerous
9
A Never
10
Q Did you ever see any warnings on the boxes of
11
carey that breathing asbestos dust could cause mesothelioma
12
A No never did
13
Q Did you ever see any warnings on the boxes of
14
Pabco
15
A NO
16
Q How about Armstrong sir
17
A No.
18
MR WEBB object to form
19
Q Did you ever see any warnings on the boxes of
20
Armstrong that breathing asbestos could cause a hazard to
21
human health
22
MR WEBB Same objection
222
A NO
222
THE REPORTER I'm sorry I didn't see who made the
222
objection
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
.
Pages 22 - 25
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
1 2
car
S
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
26 BY MR BERGMAN
Q sir I'm handing you what has been marked as
_
Exhibit
Five
Ask you if you can identify that for me
please
A Yeah
Q what is that A That's a Carey box Q Does that look like the boxes of Carey that you
used in Alaska when you were working for FENCO A That's right They had that logo on the side
Typical
Q could you show the jury Exhibit Five
A Typical cardboard box All the boxes looked the
same
Qcould you identify Exhibit six A That's a Kaylo That's a Kaylo box Q Does Exhibit six look like the Kaylo product that
you used A Yes it did
Q sir what caused you to leave FENCO stop working
for them
A well my wife didn't like Alaska she didn't like 50 below zero Every time I went home at night why Let's go back let's go back
Q so did you go back to sunny California in 1956
SIERRA NEVADA REPORTERS (702)329-6560
28
123
A They sold Pabco and U.S.G.
123
Q What is U.S.G.
123
A That's United States Gypsum Company
4
Q As a sales representative sir was it ever
S
necessary for you to conduct demonstrations on the
6 application of drywall
7
A Yes did that quite often The dealer would
8
buy from us of course and then he would tell his
9
contractors well John Crum will be by next week and we're
10
going to tape this board They would nail up some sheets of
11 _ wall board on the side of the building
12
Q sir a lot of us don't really know how to do
13
taping can you walk us through the product through the
14
process of how you would go about doing one of these
15
demonstrations and what steps you would take
16
A Well we -- first of all you have to have the
17
board nailed up And the dealer would do that He would
18
have it all ready to go We would take this gallon
19
bucket Put the joint compound in there We would put
20
water in it Put the joint compound in It's a powder
21
Then we would havea drill electric drill we
22
would mix it all up
23
Q what would happen when you mix the powder in the
22 ~~ water
25
A Dust would come out of there We never had any
SIERRA NEVADA REPORTERS (702)329-6560
7
1 2 3 4 5 6 7 8
27 A Yes I did Q Then what did you do when you went back to
california for a living A went to work for Fiberglass Engineering and
supply in sacramento as the office manager Q Okay How long did you continue as office
manager
A worked there for about three months and then I
9
found a lot better job
10
Q what job was that sir
11
A went to work for Norco Distributing company in
12
Sacramento
13
Q what kind of -- go ahead
14
A As the -- I was the sales representative for
15
northern California And my territory was from -- well it
16
was from chico to Yreka California
17
Q what kind of a company was Norco
18
A Norco was a great company It was a full line
19
building material distributor we had plywood molding
20 ~~ doors full line of electrical and plumbing paint And we
21
had the thing we had was the local the delivery delivery
22 ~~ of the product we delivered every week to the dealer we
23
sold only to dealers
24
Q can you tell me whether or not Norco sold any
25
drywall products
SIERRA NEVADA REPORTERS (702)329-6560
29
1
respirators or anything like that
2
Q Then what was - after you had mixed up the U.S.G.
3 joint compound what was the next step
4
MR WEBB Object to form
5
A We would tape the board
6
Q can you describe how you would go about taping the
7 ~~ board
8
A You get a taping knife You fill in the joint if
9
it's a horizontal joint or a vertical joint Fill it with
10
mud and you press the tape into the joint And then you
11 knife it down That's the first course
12
Q okay Then would you --
13
A Then the next week
14
Q what would you do the next week
15
A The next week we put on the topping
16
Q what is the topping coat
17
A well it's mostly clay And it's real smooth
18
Then the next week we sanded it
19
Q can you describe how you would go about sanding
20
the material
21
A Used a sanding pole and work back and forth on it
2223
And then of course it sands down all the imperfections and
2223
then you can start thinking about priming the putting
2223 primer and finishing the wall
2223
Q what happens when you sand dried -
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
Pages 26 - 29
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
30
1
A or you can texture it you see People who want
2
texture they have to have the spray texture shot on it
Q what happened when you sand drywall compound
_
A The dust comes off of it naturally
S
Q sir in addition to your demonstrations of drywall
6 application did you ever have to conduct inspections orjob
7
visits while drywall work was going on
g
A Yeah
9
Q while you were with Norco
10
A when the dealer sells a consumer and he does the
11
job wrong he lets the job freeze or he finishes a house and
12
doesn't keep heat in it and the house expands and cracks
13
develop and the consumer wonders well what's wrong here
14
what's wrong It's the mud It's the way he did the job
15
Q what would you have to do
16
A In most cases -
17
Q what would you -
18
A well they want to be compensated for that for
19
that cracking and so on I had a beautiful house up in
20 = Susanville And this builder finished the house and he
21 ~~ couldn't sell it so he let it sit there
22
And winter came along and the house he would come
23
in maybe on the weekends and turn on the heater And the
24
house would go like this joints all opened up from
25
expansion and contraction
32
1
Norco for about ten years and I decided I didn't like chico
2
anymore and I wanted to move to Nevada And so I moved to
3
Nevada with Kaiser
4
Q How were you contacted by Kaiser about this job
5 o_pportunity
6
A well the Kaiser regional sales manager approached
7
me and asked me ifI wanted to go to work for them
8
Q So what were your duties when you were moved to
9
Nevada and worked for Kaiser
10
A had northern california and Nevada excluding
11
Las vegas
12
Q what kind of products did Kaiser Gypsum sell
13
A They sold gypsum wall board of course all kinds
14
all types of gypsum wall board They had a line of drywall
15
accessories
16
Q What are accessories sir
17
A Accessories are the items that finish the wall
18 = board
19
Q could you tell us what some of them are
20
A Like joint cement and they had all kinds of
21
textures Textures for the wall you know and acoustic
22 ceilings They had tape to tape the joints And they had
23 ~~ adhesives for dual ply insulation That was an accessory
21
2 pid YOU in addition to selling Kaiser Gypsum
25
products sir in your region did you have any
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS (702)329-6560
31
1
Q Did you have any special clothes you would wear
2
when you would do these demonstrations or work around ---
3 just a minute just a minute
4
A Okay
S
Q when you would work around drywall contractors
6
A Yes had overalls in my car and would slip it
7
over my suit could go on any job you know without
8
getting all messed up you see
9
Q what were the brands of joint compounds that Norco
10
sold and that you used to conduct your demonstrations
11
A well Norco bought U.S.G. mostly and pabco
12
Q How did the U.S.G. product come packaged
13
A It came in pound bags
14
Q Did you ever see any warnings on the bags of U.S.
15
Gypsum product that breathing the asbestos dust could be
16
hazardous
17
A Never have never seen any bag warning tabs
18
like that or printing on the box or the bag you know that
19
would say something like that
20
Q Mr. Crum in 1964 did you go to work for Kaiser
21
Gypsum Company
22
A Yes did
23
Q How was it that you came to work for Kaiser Gypsum
23 = company
;
25
A well I was living in chico I had worked for
SIERRA NEVADA REPORTERS (702)329-6560
33
1 _ responsibilities for demonstrating the use of those
2 products
3
A Yes we had a school up in seattle to teach the
4
salesmen how to demonstrate these products how to finish
5
the wall board and so on And often did this out in the
6 7 8 9
10
11
12 13 14 15 16 17 18 19 20 21 22 23 24 25
field had drywall contractors here in town have
apprentices start you know And they a want
help we gave them what they wanted
little bit of
Q And was the process that you would use to apply Kaiser Gypsum drywall compound similar to the process that you just described earlier with respect to United States
Gypsum A Yes all drywall is finished the same
Q And did you have any responsibilities to inspect major jobs that where you were supplying product
A Absolutely
Q why was that
A well because sometimes the company puts out a
wall board that -- they have cockles on the back and they
would have when the finishing was started the blistering
took place calcined wall board So they want
compensation when the wall board doesn't work perfect the customer wants to be compensated for it
Q Beyond kind of trouble shooting sir did you have a more positive reason to go visit some of your job sites
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
<
Pages 30-33 30-33 30-33
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
1
,y2.__
st
5 6
34
A Yes One of the main reasons was to keep on top of the job and not let some competitor get in on and out sell you Get the next load in other words
Q when you were regional sales manager for Kaiser Gypsum sir did you sell for home construction or
commercial construction or both
7
A we sold both had tract jobs I had the circus
8
Circus Hotel down here
9
Q I'll ask about specific job sites in a minute
10
sir But before do that what were some of your major
11
customers when you were sales manager for Kaiser Gypsum
12
A well solari was one of my main customers Of
13
course he's no longer around had Atlas Drywall had
14
numerous smaller drywall contractors solari was probably
15 __ the biggest drywall contractor that I sold
16
Q sir are you familiar with a product called
17 Spray
18
A of course
19
Q what is Spray sir
20
A It's an acoustic spray It's fallen from -
21
people don't desire it anymore They usually go for
2222 __ finished like this smooth wall
2222
Q Did you sell --
2222
A Textured ceiling
25
Q Did you sell Spray while you were sales manager
36
1
some of the commercial sites you worked on My first
2
question to you sir is was there a lot of hotel
3 _ construction in Reno in the late 60s and early 70s
4
A Not too much
5
Q when did the --
6
A we had Harrah's and we had the circus circus The
7
first circus circus Had the Ponderosa on South virginia
8
Ponderosa Hotel
9
But the hotel the hotel construction has
10 _ blossomed since those days
11
Q Okay I want to try to first of all determine
12
some of your work on some of these construction sites was
13
there a reason for you to go on a construction site before
14
the drywall was put on
15
A Yes
16
Q why was that sir
17
A To make sure that I got my wall board on there
18
If you hang out in the house and don't get out on the job
19
sites to find out well what's the drywall contractor going
20 to do on this job He might order a competitor's product
21
Q Are you familiar with a process called
22 ~~ fireproofing
23
A oh yes
21
Q. Can you describe for the jury what fireproofing
25
is
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS (702)329-6560
35
1
for Kaiser Gypsum
2
A Yes
3
Q what kind of buildings would Spray typically be
4
used in
S
A oh that's strictly for home construction you
6
know And the reason is that they can finish the job
7 ~~ cheaper You know they don't have to spend the time
8
sanding the ceiling to get it smooth If you have a job
9
like this and you don't want to spend so much time on it
10 just do a rough job you can cover it up with Spray
11
Q How does Spray come packaged sir
12
A It comes in bag It comes in I believe it's a
13
pound bag They put it in hopper and mix it up And
14
that's a dusty job too
15
Q why is it dusty sir
16
A well because it's a powder They put it in the
17
spray rig and mix it up They mix it up and they shoot it
18
on the ceiling
19
Q sir do you recall any of the job sites where you
20
supplied Spray while you were working for Kaiser Gypsum
21
A Oh yes Lewis Homes out here had Lewis Homes
22 ~~ for years
23
Q Any other entities besides Lewis Homes
24
A well we had Barker we had so many jobs
25
Q am going to ask you now some questions about
SIERRA NEVADA REPORTERS (702)329-6560
37
123
A Yeah that's a material probably the most
2
probably the best known one is Zonelite It has to be
3 sprayed on all these steel buildings before any covering
4
goes on the wall
5
Q why is that sir
6
A well because if a major fire starts in there it
7
melts the steel and down comes the building
8
Q And -
9
A so they put it on there They spray it on there
10 just like they do wall texture They mix it up in a big vat ,
11
and they run the hose up in the building and they spray
12
every square inch of steel steel frame that is
13
Q Have you worked on buildings where zonelite was
14 being sprayed |
15
A Yes have been on them It's a messy it's a
16 = messy thing
17
Q want to now ask you some questions After the
18
fireproofing goes on what is the next step in terms of your
19
work as a sales representative for Kaiser Gypsum
20
A Next step for me is as soon as it's cleaned up
21
then they are going to start stocking they are going to
22
start putting the metal on and then the wall board is going
23
to go there You better be there and find out whose
24 ~~ material is going where
25
Q I'm going to ask you now if you can recall the
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
:
Pages 34-37 34-37 34-37
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
1 2
oo. 3 4
5 6 7
hotels in Reno and carson city and Lake Tahoe where you sold
Kaiser Gypsum joint compound A Okay On Harvey's wagon wheel on Harvey's wagon
wheel In Reno was Harrah's Harrah's first phase And then circus Circus first phase And Ponderosa that wasn't too large job small hotel
That's about it
8
Q could you tell me whether or not you sold Kaiser
9
Gypsum joint compound on the MGM Grand
10
MR PETTY Object to form leading
11
A On the MGM Grand Isold 50 percent of the wall
12
board and I can't recall how much drywall accessories we
13
sold there
14
Q Are you familiar with a hotel in Carson City
15
called the Ormsby House
16
MR PETTY same objection
17
A The Ormsby House Yes And solari had that job
18
solari was buying from me
19
Q Did Mr. Solari --
20
A He bought Kaiser
21
Q Did Mr. - do you know whether Mr. Solari
22 ~~ bought -- what products did Mr. Solari buy from you on the
23 ~~ Ormsby House project
28
He bought joint cement Joint cement and spray
28
texture And that's it think Tape tape he bought
SIERRA NEVADA REPORTERS (702)329-6560
40
1
haven't seen these before the deposition
2
MR BERGMAN Just got them today counsel or
3 yesterday
4
MR PETTY Other than the fact I was here 45
S minutes before the deposition
6
BY MR BERGMAN
7
Q Mr. Crum in 1972 on account of your efforts did
8
you receive any awards
9
A Yes I did
10
Q what award was that sir
11
A was salesman of the year
12
Q was that a proud time for you sir
13
A Pretty it was a pretty good time
14
Q Could you hand me Exhibit 11
15
A Yeah that's it
16 -
Q what is that sir
17
A That's the salesman of the year award
18
Q when you received your salesman of the year award
19
sir was there a ceremony associated with that honor
20
A Yeah we had a big dinner in Oakland
21
Q who was present at that dinner sir
2223
A The C.E.O. the company was there
2223
Q who was the C.E.O.
2223
A The gentleman right here
2223
MR PETTY what is this Mr. Bergman
SIERRA NEVADA REPORTERS (702)329-6560
39
I
tape
2
Q sir from your testimony it sounds like you sold
3
an awful lot of Kaiser Gypsum products
4
MR PETTY Object to the form of the question
5 _ Leading
6
A did sold a lot of wall board and product
7
Q Did you receive any recognition from your company
8
for your sales efforts
9
A Yeah Yes I did
10
Q Handing you what has been marked as Exhibit seven
11
is this one of the ~
12
A Yeah that's one
13
Q And in March 1965 did you receive another
14
commendation
15
A Yes that's another one
16
Q was 1972 a good year for you as a Kaiser Gypsum
17 sales representative
18
A very pretty good year
19
Q Handing you what has been marked as Exhibit Nine
20
is that the commendation that you received
21
A Yes absolutely
22
Q And Exhibit Ten is that also a commendation you
222
received in 1972
222
A You bet
25
MR PETTY counsel is there any reason we
oo.
SIERRA NEVADA REPORTERS (702)329-6560
41
1
MR BERGMAN That is Exhibit 12
2
Q who is the individual in the blue suit standing
3
next to you sir
4
A That was Mr. Costa
5
Q what was his role in Kaiser Gypsum
6
A He was chief executive officer of Kaiser
7
Q Mr. Crum in 1972 did you sell a small amount or a
8
large amount of Kaiser Gypsum joint compound
9
A would say my volume was fairly large
10
Q How many can you give us some idea of how much
11 Kaiser Gypsum joint compound you sold in 1972
12
A No I couldn't guess even without -- it tells in
13
one of these letters here
14
Q Between 1972 and say 1975 sir did you continue
15 to sell Kaiser Gypsum joint compound
16
A Absolutely as much as I could
17
Q How many bags would you estimate you sold during
18
that time period
19
A Oh that's a difficult question I would say
20 10,000 bags maybe
21
Q sir I'm handing you what has been marked as
22 ~~ Exhibit 13 which are Kaiser Gypsum's Answers to
23
Interrogatories in another case I would ask you sir to
24
read the response to that interrogatory
25
A right It says here Beginning in 1972
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
Pages 38 - 41
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
;
1 2
_
3
4 _. S 6 7 8 9 10 11 12 13
Kaiser Gypsum affixed caution labels to the packages and
containers of its asbestos containing products The warning label as prescribed by OSHA read Caution contains asbestos fibers Avoid creating dust Breathing asbestos dust may cause serious bodily injury
Q sir did you ever see a warning in 1972 on any bag of Kaiser Gypsum joint compound
A Never saw I never saw a thing like that at all on any bag
Q How about in 1973 sir Did you ever see any warnings on any Kaiser Gypsum bags --
A No I never have seen a warning like that
Q How about in 1974
14
A No I never seen one
15
Q How about in 1975
16
A Never
17
Q sir I'm handing you Exhibit 14. Have you ever
18
seen a warning such as that depicted in Exhibit 14 prior to
19 today
20
A Never a saw thing like that before in my life
21
Q sir did you ever receive any oral notification
2222 ~~ from anybody at Kaiser Gypsum --
2222
A NO
2222
Q -- that asbestos containing inint compounds had
25
asbestos in them
SIERRA NEVADA REPORTERS (702)329-6560
44
1
A These are these are my friends
2
Q sir who is does it make you feel today to know
3 that Kaiser Gypsum joint compound had asbestos in it
4
A well it's bad If it causes this it's bad
S
Q I want to ask you a few more questions sir about
6
your mesothelioma Can you describe for us I think you've
7
described to us some of the physical symptoms you've
8
experienced as a result of your illness How about some of
9
the emotion and spiritual symptoms that you have had
10
A They are deep They are deep I don't know what
11
can tell you but this is going to kill me
12
MR BERGMAN That's all the questions I have
13
THE WITNESS That's hard to take
14
MR BERGMAN That's all I have at the present
15
time Thank you
16
MR PETTY Let's go off the record
17
There was a discussion off the record
18
The deposition concluded at 11:10 a.m.
19
20
21
2222
2222
2222
25
SIERRA NEVADA REPORTERS (702)329-6560
r~
43
1
A No I never have
2
Q Did you ever receive any oral warnings or oral
3 __ notification from anybody at Kaiser Gypsum that --
4
A NO
5
Q - that breathing asbestos from the joint compound
6 could be dangerous
7
A No never did I never did see a label like
8
that at all on any product
9
Q sir did you value your relationship with your
10 _cs ustomers
11
A Absolutely
12
Q Did you communicate product information to your
13
customers
:
14
A Yes I did everything I could Part of my job
15
Q Did you ever have an opportunity to tell your
16
customers that the Kaiser Gypsum joint compound you were
17
selling them was hazardous to their health
18
A Never I never did that I never knew anything
19
about this Never saw it
20
Q As sales representative would it have been your
21 responsibility to
22
A should have known that If saw it I should
23 ~~ have told my customer And I wouldn't have sold him the
22 ~~ product
25
Q How does ---
SIERRA NEVADA REPORTERS (702)329-6560
45
1 JOHN E. CRUM do hereby swear or affirm under penalty of perjury that the assertions and answers of this deposition are true
DATED at Reno Nevada this
1998
day of
JOHN E. CRUM
*
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
Pages 42 - 45
VIDEO DEPOSITION OF JOHN E. CRUM 11/6/98
46
STATE OF NEVADA
COUNTY OFDOUGLAS )
:
I KAREN YATES a Notary Public for the county
of Douglas State of Nevada do hereby certify That on Friday November 6 1998 10:05 a.m. at
the home of John E. Crum 1200 chance Lane Reno Nevada
I was personally present and took verbatim stenotype notes of the deposition of JOHN E. CRUM who personally appeared and was duly sworn by me and was deposed in the matter entitled herein and thereafter transcribed the same into typewriting as herein appears
That the foregoing transcript is a full true and correct transcription of my stenotype notes of said deposition
DATED at Reno Nevada this 12th day of November 1998
KAREN YATES RPR Nevada CCR No. 195
SIERRA NEVADA REPORTERS (702)329-6560
SIERRA NEVADA REPORTERS 702 329-6560
<
Pages 46 - 46