Document em06wBzQqeBxdgyrOwYN5eMoG
FILE NAME Owens Illinois OWILL DATE 1979 July 11
DOC OWILL020
DOCUMENT DESCRIPTION Legal - Deposition of William Justice
a
_ Mari Cen
Dav_i_ d W ye
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con Cowles
David Griffith Conard Metcalf
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WilliamWilliam
A.
Trine
Trine
Charles E. Williams
Michael A. Patrick
Law Offices
WILLIAMS TRINE GREENSTEIN & GRIFFITH
Professional Corporation 1435 Arapahoe
Boulder CO 80302-6390
TEL 303 442-0173 FAX 303 443-7677
Joel H. Greenstein 1933-1984
11/3/89
Barry Castleman Sc.D.
1722 Linden Ave
Baltimore MD 21217
Dear Barry -
Enclosed are copies of pages from the 1979 deposition of William Justice a long time employee of Owens Illinois and Owens Corning
Two matters discussed One the 1958 OI Berlin plant dust study I
I sent you and said I couldn't remember where got it The document is
referred to in the Justice deposition as having been produced by Aetna
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
CIVIL ACTION NO 78-2509
DOMINIC FORTE and JOSEPHINE
Ye?
FORTE his wife
Ye
ee
Plaintiffs
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VS
ee
MANVILLE et als
a
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Defendants
Si
7 ... UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF NEW JERSEY
CIVIL ACTION NO 78-2207
HARRY S. COPELAND et al
Plaintiffs
MANVILLE PRODUCTS
CORPORATION et als
Defendants
DEPOSITION OF WILLIAM JUSTICE witness of lawful age taken on behalf of the Defendants in the
entitled cause wherein MORTON J. AUSTIN and others are the Plaintiffs and MANVILLE and
others are the Defendants pending in the United
States District Court for the District of New Jersey
before GERARD J. RICHARDS a Notary Public of the
State of New Jersey on Wednesday July 11 1979 at
the Corning Fiberglas plant Berlin New Jersey
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Justice - direct
6
proceeding and should be treated as though you were
actually testifying in a courtroom
Do you understand all of that
A
Yes
Q
|.
How long have been employed by Owens-
Corning _
A .
I have to go back and
start when I was employed by Illinois
Q
Let me rephrase the question and go
back to the beginning Let's start with Illinois
when were you employed by them
A
I can give it to you within one day it was
either 4/1/1951 or 4/2/1951 I'm not sure of the 4/1
or 4/2
0
Either April Fool's Day or the day after
A
Yes or the day after
Q
Where did you work before you came to
work for Illinois
A
Where did I work before then
Q
If you did
oo
Te
A
Various and sundry places After I got out of
the service I worked for Goodyear for a while in
Akron Ohio and then I went back to Ohio State got my
degree from Ohio State and after I got out of Ohio
State I interviewed with many companies one of which
was Illinois and I went to work for Illinois Illinois
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Justice - direct T
Q
What was your degree from Ohio State
A
Bachelor of Science in Industrial Management
And when you went to work for Owens-
.
Illinois at what facility of that company were you
.
assigned
A
I went
to work
at
-
the
Sayreville plant the Kaylo operation in Sayreville
New Jersey
Q
And you worked at the Sayreville plant *
from approximately April of '51 up to the time that cs
Sayrevillewas closeddown
-
A
Yes approximately two years if I remember
7
right
And the plant manager at that time there
was Mr. Pfeiffer
A
Pie Pfeiffer
Q
And at that point in time he was brought
to Berlin and so were you
A
Yes I came here with Pie Pfeiffer to Berlin
Q ever since
And have you worked here continuously
A
Yes
Q
And when you were working at Sayreville
back in theperiod of '51 to '53 what was your job
A
Let's see I started out in the maintenance
department and I was a maintenance supervisor for a
while approximately a year Then I was warehouse and
coop PMT. we
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Justice - direct 00
shipping manager and right prior to leaving Sayreville
I became the service manager there
here I was a service manager
And when I came
Q
What did service manager mean what does
that mean
-
A
That means incoming orders
shipments out of the plant keeping track of them
making sure they are shipped on the day they are
supposed to go out the mix of goods is right servic-
- ing customers =>
ae
-
-
Q
All right And after you came to Berlin
_
when did your job title next change
A
I don't know whether I can give you exact dates
I can give you approximate dates
Q
Give us your best approximation
A
A year and a half and then I became a production
~
supervisor
Q of -'55
So it would be somewhere in the vicinity
A
That would be
somewhere around '54 it was '54 I became a production supervisor
Q
And how long did you remain production
supervisor
A
about three anda half years
About three years I came back in the
office late '57
Q
As production supervisor what were your
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Justice Q direct.
duties
A
supervisor
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I ran a shift a shift
Q
At the time that you were production
supervisor do you recall what Mr. Grimmie's duties . were what he was doing
A
Yes he was production superintendent
Q
two jobs
|
What was the difference between those
a
A
He was the bossman
oe boss He Yes your Q
-
wort was a
A
|
Q
Would you have had foremen working
beneath you when you were production
A
At that time our organization
supervisor
structure we
did
not have the luxury of having the foremen reporting
to us they do now but we didn't have it then no
I had hourly type foremen crew leaders and this type
of thing but no salary type
Q
And in late '57 your job changed to
what sir ;
A
_ I had productio_n|
planning and purchasing Then there was I am trying to think '58 wasn't it when Corning took over
There was a temporary period where I had three jobs
while they were looking for a personnel director I
had the personnel director's job I think it was for
about seven months
na e Perna Tem oe
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Justice - direct_
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or the personnel department on types of respirators
to buy types of respirators trials and this sort
of thing
belongs to
But the
the processing and purchasing area
the
actual
|
procuremer
Q
Now I am going to show you some documents
which have been furnished to us by Aetna Insurance
Company
_
some of
them involve your name and
am
going
some questions to
ask
you
a emitiedl
about thems
|
- Now first of all let me showyou an exhibit
that was produced for us by Aetna which has been
marked Aetna Exhibit 1 for identification on 6/12/79
It's entitled Dust Survey prepared for Illinois
-Kaylo Division Berlin New Jersey by Messrs Sehl
and Robinson April 28th and May 2nd 158 which I
know were quite close to the dates of the transfer of
the plant from Illinois to Coming
And under contacts it says the following
Mr. F. W. Sehl and the writer that would be Mr.
Robinson contacted Mr. Pfeiffer plant manager Mr
Justice personnel director Mr. Cassiaral personnel
assistant Mr. Grimmie production superintendent
Also present were Mr. Gardner safety director for
Illinois and Mr. Paul Shoe Aetna safety
{ engineering representative who services this plant
~.First of all do you have any recollection of
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Justice - CIOSS
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was '53 I was here a year I went on the floor in '54
and I was on the floor for three years yes '54 to '57
aQ
What
time 7
:
and the facilities
were your specific duties during that
A
I was in charge of a shift
of the factory the production and
processing and so forth during that period of time
Whenever my shift was on I was in charge reporting
to a factory superintendent
Q ve Did I understand you to say that during |
that time you received African asbestos and Canadian
asbestos for use in the manufacturing process
A
Yes
Q
And from what companies during that time
did you receive the African asbestos
A
North American
Q
Only
A
my knowledge at that time
|
Yes to the best of
|
Q
From what companies did you receive
Canadian asbestos
A
.
When I was a shift
supervisor on the floor
Q
Yes
If you know
A
I can't honestly say who the companies that we
were receiving asbestos from at that time was I did
not really get involved in it until I got in the
purchasing area
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Justice - cross
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Q
And that would have been in '57
ee,
ca
A
Yes
namie
I know we were getting short fiber asbestos
chrysolite and we were getting long fiber asbestos the
African the amosite
nom,
Q
' Now did I understand you to say that the
Canadian asbestos was received on railroad cars
A
Railroad cars yes
Q
And in what form of packaging was it
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received
>
~: oa
A
>. The earlier ones and that
didn't last too long after I came into the purchasing
area were in burlap bags and then they went to all
multi Kraft paper bags
Q
Do you know when the change took place
A
No not exactly no
Q
Was it during the time that you were
the production the production field -
17
A
No it was right along before I left the floor
18
and came into the office because the change took place
19
right along in there Because I can remember being
ee
20
on the floor and part of my job responsibility was the
S
pp
21
batch mixing facility and so forth that you could
22 always tell the amosite asbestos because it was in
2
burlap bags and the one grade of Canadian asbestos was
in a burlap and a Kraft paper bag
2
2 Q Did those containers let's take the
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