Document evw1G3DD5KnonDLmZ7zRZ8o7G

1 IN THE DISTRICT COURT 2 CAMERON COUNTY, TEXAS 3 138TH JUDICIAL DISTRICT 4 -- oOo -- 5 SAMUEL OLIPHANT WOOLEY, JR., et al., 6 Plaintiffs, 7 -vs- 8 OWENS-CORNING FIBERGLAS 9 CORPORATION, et al.. No. 94-09-04823 B 10 Defendants. ____ __________________________/ 11 12 13 14 Deposition of 15 DOUGLAS WAYNE MERRILL 16 Monday, November 20, 1995 17 By Allen M. Stewart, Attorney at Law 18 DUPLICATE 19 FILE COPY 20 21 Reported by 22 TERI DARRENOUGUE, CM, CRR CSR NO. 5106 23 24 PENINSULA REPORTING 25 CERTIFIED SHORTHAND REPORTERS 147 WINDSOR DRIVE, SAN CARLOS, CALIFORNIA 94070 26 (415) 594-0677 1 DEPOSITION OF DOUGLAS WAYNE MERRILL 11/20/95 1 Q. Just give me an approximation. 2 A. I don't recall. It could have been back -- We've 3 had safety rules and regulations as long as I can 4 remember. I don't know if we handed everybody, when they 5 first came on board. They've always been posted. 6 Q. And when you say "They've always been posted," are 7 you saying that -- strike that. 8 Tell me what you mean, "They've always been 9 posted." 10 A. They were put on the board, bulletin board, with -- 11 taped on a bulletin board or pinned on a bulletin board. 12 Q. When did Kelly-Moore first pin on a bulletin board 13 that asbestos could be harmful to its workers' health? 14 MR. CHURCHILL: Object to the form of the 15 question. 16 THE WITNESS: We never understood that it was 17 harmful to their health. We told the employees in 1972 18 that -- that -- what the thresholds were and what OSHA 19 was telling us, and that's what we complied with. 20 Q. (BY MR. STEWART): All right. Let me object to the 2 1 responsiveness. I asked when Kelly-Moore posted on this 22 board for its employees that asbestos could be harmful to 23 their health. When did Kelly-Moore do that, if it ever 24 did? 25 MR. CHURCHILL: Same objection. 26 THE WITNESS: The warnings to asbestos came out 94 PENINSULA REPORTING (415) 594-0677