Document gEJ9MLDBxqJ8LQdNa6p21y6GJ
FILE NAME: Mahoning Valley Supply (MVS) DATE: 2004 Apr 30 DOC#: MVS002 DOCUMENT DESCRIPTION: Legal - Deposition of EG Matuscak
IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO
2 3 4 Edward Matuscak,
Page 1
Plaintiffs, vs . A-Best Products Co., et al.,
)
) Case No. CV 475289
)
) Judge Hanna
8
Defendants
9
10
Videotape deposition of Edward G. Matuscak,
11 a Plaintiff herein, taken by the Plaintiff as
12 upon direct examination and pursuant to the Ohio
13 Rules of Civil Procedure and Notice as to time
14 and place and stipulations hereinafter set forth,
15 at the Best Western Motel, 870 N. Canfield-Niles
16 Road, Austintown, Ohio, on Friday, April 30, 2004,
17 at 9:30 a.m., before George J. Staiduhar, a Notary
18 Public within and for the State of Ohio.
19
20
21
22
23
.24
25
FITCH REPORTING, INC. (800) 569-7888
d41f3692-bdd6-4659-a1bb-c7e50359601d
FRANCES CONTINUED:
For the Defendant, Owens-Illinois:
Barbara Machin, Esq.
of
Bunda. Stutz & DeWitt PLL
5 One SeaGaie, Suite 650 Toledo. OH 43604
76
For the Defendant, Fidelity Builders:
8
Jennifer Riester, Esq.
of
9
Weston, Hurd, Fallon, Paisley &
Howley
10
2500 Terminal Tower
Cleveland, OH 44113
11 12
For the Defendant, Welding Industry:
13 Henry Billingsley, Esq.
14
of
Tucker Ellis & West, LLP
13
925 Euclid Avenue
Eleventh Floor
16
Cleveland, OH 44115
17 For the Defendant, The Will-Butt
18
Company:
19
Lorraine Debose, Esq.
of
20
Buckley King & BIuso
1400 Bank One Center
21
Cleveland, OH 44114
22
23
24
23
V
Page 6
Page 8
1
THE V1DEOGRAPHER: We are on the
2 record.
3
MR. MONEY: First of aH,i want to .......
4 put some stipulations on the record. I believe all
5 defense counsel have agreed to these stipulations.
6 First stipulation is that the video camera will be
7 focused on the witness' face and upper torso. Attorneys
8 are not to be videoed.
9
Second stipulation: The audio level
10 is to be kept at a constant volume.
11
Third, an objection by one defense
12 counsel will be deemed an objection by all defense
13 counsel present.
14
Fourth, all objections are reserved
15 except as to the form of the question and responsiveness
16 of the answer.
17
Fifth, the possession of the video
18 tape will remain with the court reporter.
19
And then, finally, we will abide by
20 all standard stenographic stipulations.
21
MR. KADLEC: Excuse me. Objections
22 for all should be for all Defendants present as opposed
23 to attorneys so somebody can't raise a concern if we
24 were at trial that that attorney was not here, but that
25 the Defendant reserves all the objections.
Page 7
1
STIPULATIONS
2
It is stipulated by and between counsel
3 for the respective parties that the deposition of
4 Edward G. Matuscak,, a Plaintiff herein, called
5 as upon direct examination by the Plaintiff may be
6 taken at this time and place pursuant to the Ohio
7 Rules of Civil Procedure and Notice and agreement
8 of counsel as to time and place of taking said
9 deposition; and to be filed in the trial of this
10 cause; that the deposition was recorded in stenotype
U by the court reporter, George J. Staiduhar, and
12 transcribed out of the presence of the witness;
13 and that said deposition and is not to be submitted
14 to the witness for his examination and signature.
15
16
17
18
19
20
21
22
23
24
25
Page 9
1
MR. MONEY: All Defendants that are
2 represented here by an attorney which is present. AH
3 right? Kevin, is that all right.
4
MR. KADLEC: Yes.
5
MR. MONEY: Are you ready,
6 Mr. Matuscak?
7
MR. MATUSCAK: Yes witness swom.
8
EDWARD G. MATUSCAK
9 of lawful age, being first duly swom, as hereinafter
10 certified, was examined and testified as follows:
11
DIRECT EXAMINATION
12 BY MR. MONEY:
13
Q Good morning, Mr. Matuscak.
14
A Good morning.
15
Q As you know, my name is Carl Money.
16 1am one of the attorneys who is representing you in
17 your claim against various manufacturers, suppliers,
18 distributors, and installers of asbestos-containing
19 products. I would like to ask you some questions today
20 about your background, your work history, and your
21 medical condition.
22
Are you ready to begin?
23
A Yes.
24
Q Sir, could you please introduce
25 yourselfto the jury?
FITCH REPORTING, INC. (800) 569-7888
3 (Pages 6 to 9)
d41f3692-bdd6-4659-a1bb-c7e50359601d
/
Page 10
/ A My name is Edward George Matuscak.
/
Q Sir, as the jury sees you today,
they are going to see yob giving a video tape `
4 deposition.
/ 5
Can you tell the jury why we are
6 making a video tape of your testimony?
7
MR. KADLEC: Objection.
8
A We are making this video tape in
9 case 1become ill or happen to die before you go to
10 trial.
11
Q Do you have an asbestos-related
12 disease that might prevent you from appearing at trial.
13
(Chorus of objections by several
14 counsel.)
15
A True, yes.
16
Q
17 have?
What asbestos-related disease do you
18
A Lung cancer.
19
Q Do you also have asbestosis?
20
(Chorus of objections by several
21 counsel.)
22
A Yes.
23
Q What is your date of birth?
24
A 9-7-32.
25
Q And how old are you today?
Page 12
1 to Betsy?
2
A 37 years.
|
3 ' ........Q .... HdWdidyou meetyour wife?..... ' " 1
4
A At a dance hall.
5
Q Here in Austintown or Youngstown?
6
A Actually, it was in Girard, a little
7 town outside of Youngstown.
8
Q Have you ever been separated or
9 divorced?
10
A No.
11
Q Have you ever had any prior
12 marriages?
13
A No.
14
Q
15 home?
Does your wife work outside the
16
A No.
17
Q Sir, you said you had a son. What
18 is his name?
19
A David.
20
Q When was David bom?
21
A 1968.
22
Q And how old is he today?
23
A 35.
24
Q And he lives with you, correct?
25
A Yes.
Page 11
A 71.
2
Q Where do you live presently?
3
A Austintown, Ohio.
4
Q What address is that?
5
A 207 Parkade Avenue.
6
Q And the zip?
7
A 44515.
8
Q Sir, where were you bom?
9
A Youngstown, Ohio.
10
Q And how long did you live there?
11
A About 34 years.
12
Q And where did you live next?
13
A Austintown, Ohio.
14
Q At your present address?
15
A Yes.
16
Q Is anyone living with you presently?
17
A Yes.
18
Q Who is that?
19
A My wife and my son.
20
Q So you are married. What is your
21 wife's name?
22
A Betsy.
23
Q When did you get married to Betsy?
24
A February of 1967.
25
Q How many years have you been married
Page 13
1
Q Did you graduate from high school?
2
A Yes.
3
Q
4 school?
When did you graduate from high
5
A 1950.
6
Q And where did you go to school?
7
A Youngstown, Ohio.
8
Q Which high school was that in
9 Youngstown?
10
A Cheney High School.
11
Q Since high school, have you had any
12 vocational training, apprenticeships, certifications, or
13 post high school education of any sort?
14
A I had a boilermaker apprenticeship.
15
Q Did you serve in the military?
16
A Yes.
17
Q
18 serve?
What branch of the military did you
19
A United States Army.
20
Q When did you serve in the
21 United States Army?
22
A From 1953 till 1955.
23
Q And where did you serve in the
24 United States Army?
25
A Korea.
# 4 (Pages 10 to 13)
FITCH REPORTING, INC. (800) 569-7888
...........................................
d41 f3692-bdd6-4659-a1 bb-c7e50359601 d
Page 14
Q What were your duties in the
united States Army?
'"`A" Twas'a cook and'amess
sergeant.
5
Q And how many years did you serve?
6
A Two years.
7
Q Did you sustain any injuries when
8 you were in the Army?
9
A No.
10
Q Did you receive any medals or honors
11 when you were in the United States Army?
12
A Good conduct metal, overseas metal,
13 Korean metal.
14
Q What was your highest rank in the
15 U.S. Army?
16
A E-5, sergeant.
17
Q And were you honorably discharged?
18
A Yes.
19
Q Sir, please tell the jury all the
20 jobs you've had where you think you were exposed to
21 asbestos-containing products.
22
A US Steel.
23
Q And which US Steel facility was
24 this?
25
A
It was in Youngstown, Ohio.
Page 16
1 second helper, third helper, cranemen, laborers.
2
Q How often did you work around these
3' other tradesmen? ~
" "'
4
A At least once a month.
5
Q And how close did you work to these
6 other tradesmen?
7
MR. KADLEC: Objection.
8
A Within a couple feet.
9
Q Did you work with or around any
10 asbestos-containing products while you were working at
11 US Steel?
12
A Yes.
13
MS. JAMES: Objection.
14
Q What types of asbestos-containing
15 products did you work with or around at US Steel?
16
MS. JAMES: Objection.
17
A Pipe insulation, block insulation,
18 patch material, and spray-on material.
19
Q What was the brand name or
20 manufacturer's name of the pipe insulation you worked
21 with or around at US Steel?
22
A Kaylo and Johns Manville.
23
Q What was the brand name or
24 manufacturer's name of the block insulation you worked
25 with or around at US Steel?
Page 15
1
Q Is this the Ohio Works facility?
2
A Yes, US Steel.
3
Q When did you first work at US
4 Steel?
5
A 1950.
6
Q When did you last work at US Steel?
.7
A 1980.
8
Q Except for your time in the
9 United States Army, did you work there continuously
10 throughout that time frame?
11
A Yes.
12
Q Where did you work at within the
13 plant?
14
A I worked plant wide.
15
Q Can you list some of the locations
16 for the jury?
17
A Open hearth, blast furnace, 40-inch
18 rolling mill, 43-inch rolling mill, cinder plant, boiler
19 house, power house, machine shop, carpenter shop.
20
Q When you worked at US Steel, did you
21 work around other tradesmen?
22
A Yes. v
23
Q Which trades did you work around?
24
A Almost all of them, bricklayers,
25 millwrights, pipefitters, machinists, first helper,
Page 17
1
A Kaylo and Johns Manville.
2
Q What was the brand name or
3 manufacturer's name of the spray-on material you worked
4 with or around at US Steel?
5
A Narcolite.
6
Q What was the brand name or
7 manufacturer's name of the patch material you worked
8 with or around at US Steel?
9
A KN.
10
Q Sir, how do you associate the name
11 Kaylo with pipe insulation?
12
A 1seen the name written on a box in
13 the work area.
14
Q Did you work with or around Kaylo
15 pipe insulation?
16
MS. JAMES: Objection.
17
A Both.
18
Q Both?
19
A Yes.
20
Q When did you work with or around
21 Kaylo pipe insulation?
22
A Between 1950 and the '70s.
23
Q Where did you work with or around
24 Kaylo pipe insulation?
25
A Plant wide.
--
FITCH REPORTING, INC. (800) 569-7888
5 (Pages 14 to 17)
d41f3692-bdd6-4659-a1bb-c7e50359601d
Page 18
Q How often did you work with or
around Kaylo pipe insulation?
/ '' A~- Onceaweek.
4
Q And how close were you working
5 around Kaylo pipe insulation?
6
MS. MACHIN: Objection.
7
A Within a couple feet.
8
Q Can you describe Kaylo pipe
9 insulation?
10
A Well, it was round, came in two
11 halves, had a hole down the center of it. It was sort
12 of off white in color. It was about three foot long.
13
Q Can you describe how Kaylo pipe
14 insulation was installed?
15
A Yes. They would have the two
16 halves, put it on a pipe, and they would wire the two
17 halves together with wire.
18
Q And which tradesmen installed Kaylo
19 pipe insulation?
20
A Pipefitters and millwrights.
21
Q Did Kaylo pipe insulation have to be
22 cut to be installed?
23
MS. MACHIN: Objection.
24
A Yes.
25
Q What did the air look like when
Page 20
m 1 be hazardous to your health?
2
A No.
3
Q * Did you eversee-a warning,orwere v
4 you ever told that you should wear a mask or respirator
5 when working with or around Kaylo pipe insulation?
6
A No.
7
Q How do you associate the name Johns
8 Manville with pipe insulation?
9
A I seen the name on the box in the
10 work area.
11
Q Did you work with or around
12 Johns Manville pipe insulation?
13
A Yes.
14
Q Both?
15
A Yes.
16
Q When did you work with or around
17 Johns Manville pipe insulation?
18
A From 1950s to th e'70s.
19
Q Is that from 1950?
20
A Yes.
21
Q Where did you work with or around
22 Johns Manville pipe insulation?
23
A Plant wide.
24
Q And how often did you work with or
25 around Johns Manyille pipe insulation?
Page 19
1 Kaylo pipe insulation was cut?
2
A Dusty.
3
Q Did you work close enough to breathe
4 the Kaylo pipe insulation dust?
5
MR. KADLEC: Objection.
6
A Yes.
7
Q Your answer, sir?
8
A Yes.
9
Q Did you breathe the Kaylo pipe
10 insulation dust?
11
MS. MACHIN: Objection.
12
A Yes.
13
Q Did you try to get away from the
14 Kaylo pipe insulation dust?
15
MS. MACHIN: Objection.
16
A No.
17
Q Did you get the Kaylo pipe
18 insulation dust on you?
19
A Yes.
20
MS. MACHIN: Objection.
21
Q How did you get the Kaylo pipe
22 insulation dust off you?
23
A I brushed it off with my hand.
24
Q Did you ever see a warning on the
25 boxes of Kaylo pipe insulation indicating that it could
Page 21
1
A About once a week.
2
Q And how close did you work around
3 Johns Manville pipe insulation?
4
A Within two or three feet.
5
Q Can you describe Johns Manville pipe
6 insulation for the jury?
7
A It was round. It came in two
8 halves. It had a hole down the center length wise, and
9 it was sort of off white in color.
10
Q And how long was the Johns Manville
11 pipe insulation?
12
A About three foot long.
13
Q Can you describe how Johns Manville
14 pipe insulation was installed?
15
A They would take two halves, put it
16 around the pipe, and they would get a piece of wire and
17 wire it together, fasten it to hold it on a pipe.
18
Q And which trades installed
19 Johns Manville pipe insulation?
20
A The pipefitters and the millwrights.
21
Q Did Johns Manville pipe insulation
22 have to be cut to be installed?
23
A Yes.
24
Q What did the air look like when
25 Johns Manville pipe insulation was cut?
m6 (Pages 18 to 21)
FITCH REPORTING, INC. (800) 569-7888
d41f3692-bdd6-4659-a1bb-c7e50359601d
Page 22
A Dusty.
Q Did you work close enough to breathe
3 tnrJofiiis Manvilfd pipe insulatldn d t i s t ? " "
4
MS. MACHIN: Objection.
5
MR. KADLEC: Objection.
6
A Yes.
7
Q Did you breathe the Johns Manville
8 pipe insulation dust?
9
MS. MACHIN; Objection.
10
MR. KADLEC: Objection.
11
A Yes.
12
Q Did you try to get away from the
13 Johns Manville pipe insulation dust?
14
A No.
15
Q Did you get the Johns Manville pipe
16 insulation dust on you?
17
A Yes.
18
Q How did you get the Johns Manville
19 pipe insulation dust off you?
20
A I brushed it off with my hand.
21
Q Did you ever see a warning on the
22 boxes of Johns Manville pipe insulation indicating that
23 it could be hazardous to your health?
24
A No.
25
Q Did you ever see a warning, or were
Page 24
1
A Yes.
2
Q Where did you work with or around
3 Kayio btdckifisutatioh?'" ` "
" -
4
A In the open hearth.
5
Q How often did you work with or
6 around Kaylo block insulation?
7
A Once a week.
8
Q And how close did you work around
9 Kaylo block insulation?
10
A Within two or three feet.
11
Q Can you describe Kaylo block
12 insulation for the jury?
13
A It was about two feet by three feet,
14 inch and-a-half thick and off white in color.
15
Q Can you describe how Kaylo block
16 insulation was installed?
17
MS. MACHIN: Objection.
18
A They had these flanges on the
19 boilers with holes in them. They would fasten them with
20 wire. They put the wire through the holes and fastened
21 the block insulation on to the boilers.
22
Q How many boilers were in the open
23 hearth?
24
A Fifteen.
25
Q And where on the boilers was the
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
f
Page 23
you ever told that you should wear a mask or respirator when working with or around Johns Manville pipe insulation?
A No. Q Sir, how do you associate the name Kaylo with block insulation? A 1seen the letters on a box or name on a box. Q The name Kaylo on a box? A Yes. Q Did you work with or around Kaylo block insulation? A Yes. Q Both? A Both. Q When did you work with or around Kaylo block insulation? A About 1955 to the '70s. Q Did you see Kaylo block insulation when you first started at the mill? A Yes.
MS. JAMES: Objection. Q So from 1950 through the '70s?
MS. JAMES: Objection. MS. MACHIN: Objection.
Page 25
1 Kaylo block insulation installed?
2
A On the outside.
,
3
Q Which trades installed Kaylo block
;
4 insulation on the boilers?
5
A The pipefitters, millwrights.
;
6
Q Did Kaylo block insulation have to
7 be cut to be installed?
8
MS. MACHIN: Objection.
'
9
A Yes.
10
Q Your answer, sir?
11
A Yes.
12
Q What did the air look like when
13 Kaylo block insulation was cut?
'
14
A Dusty.
15
Q Did you work close enough to breathe
16 the Kaylo block insulation dust?
17
MS. JAMES: Objection.
18
MS. MACHIN: Objection.
19
A Yes.
j
20
Q Did you breathe the Kaylo block
21 insulation dust?
22
MS. MACHIN: Objection.
23
A Yes.
24
Q Did you try to get away from the
25 Kaylo block insulation dust?
FITCH REPORTING, INC. (800) 569-7888
7 (Pages 22 to 25)
d41f3692-bdd6-4659-a1 bb-c7e50359601 d
Page 34
We had a plate underneath the brick,
gnd we had to weld on this plate, and if it was in our
2
y
- way, w6"wbuld khock it bfFwith a hammerand brush it "
4 away with our hands, the material.
5
Q When you picked up these KN patching
6 material cans and lids or knocked them out of your way,
7 did that create any dust?
8
A Yes.
9
Q Did you work close enough to breathe
10 the KN patching material dust from this activity?
U
A Yes.
12
MR. HENDERSON: Objection.
13
Q When you knocked off the KN patching
14 material with the hammers and brushed it off with your
15 hands, did that create any dust?
16
A Yes.
17
Q Did you work close enough to breathe
18 the KN patching material dust that was created by this
19 activity?
20
A Yes.
21
MS. MACHIN: Objection.
22
MR. HENDERSON: Objection.
23
Q Did you breathe the KN patching
24 material dust created by removing the cans or kicking
25 the cans or knocking off the can patching material with
..................... ...... .... ..................................................... !
Page 36
1
A Yes.
2
Q Did you work with or around metal
%
- - y - . Encased brKwhen you worked t US'Sfeel?... .. ' !' 1
4
A Yes.
1
5
Q
6 tops --
Did you work with or around hot
7
A Yes.
8
Q -- when you worked at US Steel?
9
A Yes.
s
10
MR. KADLEC: Objection.
11
Q Your answer, sir?
12
A Yes.
13
Q Sir, what did your clothes look like
!
14 at the end of the day when you worked at US Steel?
i
15
A They were filthy, dirty.
16
Q Were they dusty?
17
A Yes.
18
Q Was there any ventilation at
19 US Steel to suck out the dust?
;
20
MR. KADLEC: Objection.
21
MS. MACHIN: Objection.
22
A No.
23
Q Sir, would you like to take a break?
24
A Yes.
1
25
THE VIDEOGRAPHER: One second,
Page 35
1 a hammer?
2
MS. MACHIN: Objection.
3
A Yes.
4
MR. HENDERSON: Objection.
5
Q Your answer, sir?
6
A Yes.
7
Q Did you try to get away from the KN
8 patch material dust?
9
A No.
10
Q Did you get the KN patch material
11 d u st on y ou?
12
A Yes.
13
Q How did you get the KN patch
14 material off you?
15
A 1brushed it off withmy hand.
16
Q Did you ever see a warning on the
17 cans of KN patch material indicating that it could be
18 hazardous to your health?
19
A No.
20
Q Did you ever see a warning, or were
21 you ever told that you should wear a mask or respirator
22 when working with or around KN patch material?
23
A No.
24
Q Sir, did you work with or around
25 welding rods when you worked at US Steel?
Page 37 j|
1 please.
2
(Recess had.)
3
MR. MONEY: Everybody ready?
4
THE VIDEOGRAPHER: Back on the
5 record.
6 BY MR. MONEY:
7
Q Sir, has anyone associated with any
8 asbestos company, manufacturer, distributor, supplier,
9 or contractor ever advised you that exposure to
10 asbestos-containing products could be harmful to your
11 health?
12
A No.
13
(Chorus of objections by several
14 counsel.)
15
Q Has anyone associated with any
16 asbestos company, manufacturer, distributor, supplier,
17 or contractor ever advised you that exposure to
18 asbestos-containing products could cause asbestosis?
19
(Chorus o f objections by several
20 counsel.)
21
A No.
22
Q Has anyone associated with any
23 asbestos company, manufacturer, distributor, supplier,
24 or contractor ever advised you that exposure to
25 asbestos-containing products could cause lung cancer? '
10 (Pages 34 to 37)
FITCH REPORTING, INC. (800) 569-7888
d41 f3692-bdd6-4659-a 1bb-c7e50359601d
f
/
Page 42
Page 44
/
A Boilermaker.
Q Did you work with or around
J Mr. Chismai?--' .......... .............- ............. ................
4
A Both.
5
Q How often did you work around
6 Mr. Chismar?
7
A Couple times a month.
8
Q And how close did you work around
9 Mr. Chismar?
10
A Right next to him or within a couple
11 feet of him.
12
Q And Mr. Carfolo, what was his trade?
13
A Boilermaker.
14
Q Did you work with or around
15 Mr. Carfolo?
16
A Both.
17
Q And how often did you work with or
18 around Mr. Carfolo?
19
A Couple times a month.
20
Q And then how close did you work
21 around Mr. Carfolo?
22
A Right next to him or within a couple
23 feet of him.
24
Q Did you see any suppliers at
25 US Steel?
1
Q How did you know Mahoning Valley
2 Supply was at the mill?
3 A- I saw their name off a door; bn*d '" '
4 truck.
5
Q What sort of trucks did Mahoning
6 Valley Supply have at the mill?
7
A Flatbed.
8
Q Did you see Mahoning Valley Supply
9 Company supplying asbestos-containing products to the
10 mill?
11
A Yes.
12
MR. KADLEC: Objection.
13
Q Your answer, sir?
14
A Yes.
15
Q What types of products did you
16 see Mahoning Valley Supply Company supplying to the
17 mill?
18
A Pipe insulation and block
19 insulation.
20
Q When did you see American
21 Refractories at the mill?
22
A 1950s to the '70s.
23
Q Did you see American Refractories
24 when you started at the mill in 1950?
25
A Yes.
Page 43
1
2
3
4
5
6
7
8
Q When did you see Mahoning Valley
9 Supply Company at the mill?
10
A From the '50s to the '70s.
11
Q Did you see Mahoning Valley Supply
12 when you started in 1950?
13
A Yes.
14
Q So from 1950 to the '70s?
15
A Right.
16
Q How often did you see Mahoning
17 Valley Supply at the mill during that time frame?
18
A Couple times a month.
19
Q Where did you see Mahoning Valley
20 Supply at the mill?
21
A Well, on the roadways leading to the
22 storage area and at the storage area.
23
Q Which storage area is this?
24
A Lot of storage area behind the open
25 hearth building.
1 2 '70s?
Page 45
So did you see them from 1950 to the
m
3
A Yes.
4
Q How often did you see
5 American Refractories at the mill during that time
6 frame?
7
A At least twice a month.
8
Q Where did you see American
9 Refractories at the mill?
10
A In the storage area and on the
11 roadways leading to the storage area.
12
Q Is this the open hearth area?
13
A Yes.
14
Q How did you know American
15 Refractories was at the mill?
16
A They had their name written on the
17 side of the doors.
18
Q Doors of what?
19
A Of their truck.
20
Q What sort of trucks did American
21 Refractories have at the mill?
22
A Flatbeds.
23
Q Did you see American Refractories
24 supplying asbestos-containing products to the mill?
25
A Yes.
12 (Pages 42 to 45)
FITCH REPORTING, INC. (800) 569-7888
(J41f3692-bdd6-4659-a1bb-c7e503596Q1 d