Document gbV7zpjvDMXvQXeKDkv347LeQ

FILE NAME DuPont DUP DATE 2018 July 18 DOC DUP301 DOCUMENT DESCRIPTION Legal - Deposition of Raymond A. Anderson - Day 1 Raymond A. Anderson Jr. 7/18/2018 STATE OF MINNESOTA COUNTY OF RAMSEY DISTRICT COURT SECOND DISTRICT PERSONAL INJURY ASBESTOS Court File No 18-169 ROBERT E. BENSON and SUZANNA BENSON Plaintiffs His Wife 3M COMPANY ET AL Defendants VIDEOTAPED DEPOSITION OF RAYMOND A. ANDERSON JR Pursuant to Minnesota Rule of Civil Procedure 30.02 a for Sporting Goods Properties and E.I. du Pont de Nemours & Company taken at Law Offices of Murtha Cullina CityPlace I 185 Asylum Street Hartford Connecticut July 18 2018 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 2 APPEARANCES Representitnhge Plaintiffs Robert E. Benson and Suzanna Benson 3 KARST von OISTE 19500 State Highway 4 Houston TX 77070 BY ERIK P. KARST ESQ 5 DOUGLAS D. von OISTE ESQ 281 970-9988 6 epk@karstvonoiste.com douglas@vonoiste.com 7 8 _ Representing Defendants E.I. du Pont de Nemours & Company and Sporting Goods Properties 9 GLYNN & FINLEY 10 One Walnut Creek Center Suite Pringle 11 100Walnut CreeAvkenue 94596 T. BY ANDREW MORTL ESQ 12 952 945-1974 amorti@glynnfinley.com 13 CROWELL & MORING Pennsylvania Avenue 14 1001 NW Washington DC 20004-2595 15 BY GLORIA MARTINEZ TRATTLES ESQ 202 624-2601 16 gtrattles@crowell.com gtrattles@crowell.com 17 Following appearances by teleconference 18 Representinthge Defendant Olin Corporation HUSCH BLACKWELL 19 190 Carondelet Plaza Suite 600 St. Louis MO 63105 20 BY JACKSON K. OTTO ESQ 314 480-1835 21 jackson.oto@huschblackwel.com jackson.otto@huschblackwell.com 22 Representitnhge Defendant E.I. du Pont de Nemours 23 -- -- ----.-- 30 E. 7th Street Suite 3200 24 St. Paul MN 55101 BY PETERW WANNING ESQ 25 651 227-9411 2 APPEARANCES Continued Representitnhge Defendant Union Carbide Corporation 3 ELLIOTT LAW OFFICES 2400 West 66th Street 4 Minneapolis MN 55423 PATRICK ESQ 5 612 466-7192 pat@elliottlaw.net 6 pat@eliotlaw.net 7 RepresethenDtefienndagnt Federal Cartridge 8 141 West Front Street Suite 120 Red Bank NJ 07701 9 BY CHRISTINE DELANEY ESQ 10 christine.delaney@lit letonpark.com christine.delaney@lit letonpark.com christine.delaney@litletonpark.com 11 12 RepresentinthgeDefendants and MEAGHER & GEER 13 33 South Sixth Street Suite 4400 Minneapolis MN 55402 14 371-1321 emugaas@meagher.com 15 Appliance 16 RepreLsOGeANntO'iBRnIEgN 8519 Eagle Point Boulevard Suite 100 17 Elmo MN 55042 BY HATLEVIG ESQ 18 651 290-6504 ehatlevig@jlolaw.com ehatlevig@jlolaw.com 28 20 IN ATTENDANCE Rocco Leone videographer 21 22 23 25 2 4 1 INDEX 2 WITNESS 3 DIRECT CROSS REDIRECT RECROSS RayA. Anderson Jr. 7 4 5 EXHIBITS 6 PAGE Plaintiff's Plaintiff's 7 Exhibit 1 handwritten notes of Mr. Anderson 32 8 Exhibit regarding Exhibit 2 2/17/71 document regarding toxicity primer and of projectile in rimfire ammunition ammunition 9 130 eens neee ... REZ Exhibit 3 United States patent ..... 142 REZ Exhibit specifications for shotshell ammunition 147 REZ * Exhibits retained by reporter 13 152222 152222 152222 152222 152222 152222 152222 152222 152222 23 2 25 3 123 123 123 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 223 223 223 24 22 5 VIDEOGRAPHER Good morning Today's date is July 18 2018. We going on the record at is 10:18 10:18 a.m. ThisThis is thethe vivdiedoetoatpaepded dedpeospiotsiiotnion of of being Cullina Murtha Cullina Ray Anderson being taken at 185 Asylum Street Hartford Connecticut in the matter of Robert E. Benson and Suzanna Benson his wife versus 3M Company et al This is the Plaintiff's second amended notice for du Pont is Plaintiff's notice It is also the Plaintiff's second amended notice for Sporting Goods Properties Inc. This deposition is being taken on behalf of the Plaintiffs filed in district court second judicial district personal asbestos Min esota State of Minnesota County of Ramsey docket number CV 62 18-169 18-169 My name is Rocco Leone cameraman and legal video technician from VIP Studios located in Conecticut with Keli McGilton Waterbury Connecticut with Keli McGilton certified court reporter Counsel please state your appearances for the record and whom you represent Then the will in Witness court reporter will swear in the Witness This Erik MR KARST This is Erik Karst for the Plaintiffs MR von OISTE Doug von Oiste for the Doby Professional Reporting Inc. 952-943-1587 2 Pages 2 to 5 Raymond A. Anderson Jr. 7/18/2018 6 8 1 Plaintiffs 2 MR MORTL Andrew Mortl for the 1 these two defendants to produce a witness on is that 2 correct 3 defendants du Pont Sporting Goods and the 4 witness Mr. Anderson 5 MS TRATTLES Gloria Trattles for the 3 A. Yes 4 Q. Are you currently being represented by the two 5 individuals here 6 defendant du Pont and Sporting Goods 6 A. Yes 7 Properties Inc. 7 Q. How long have you been represented by them 8 MR KARST If we can have the record 8 A. Since yesterday reflect everybody else on the phone 9 Q. To prepare for your deposition today what did 10 MR OTTO Jackson Otto appearing for the 1 defendant Olin Corporation 2 MS DELANEY Christine Delaney for Federal 3 Cartridge 4 MR WADDING Pete Wadding for du Pont 15 MR ELLIOTT Pat Elliott for Union Carbide 10 you do 11 A. Well I talked with my counsel looked at a lot 12 of records from Remington including such things as 13 process records meeting minutes of various sorts 14 catalogs price lists a lot of memory refreshers and 15 talked with counsel 16 Corporation 1082 MS MUGAAS Emily Mugaas for Warren Pumps 1082 and IMO Industries Inc. 1082 16 Q. And where did you obtain the meeting minutes 17 the catalogs and the price lists from 18 A. Most of them came from counsel 19 Q. Do you know which specific ones you reviewed 20 1082 RAYMOND ANDERSON Deponent having been first duly | 21 1082 sworn was examined and deposed as follows 22 22 A. series of catalogs from numerous years Q. And whose catalogs were they A. Remington 2 23 Q. Are they on firearms or are they ammunition 24 24 catalogs 25 25 A. Just ammunition catalogs 7 123 DIRECT EXAMINATION BY MR KARST 123 123 Q. By Mr. Karst Good morning Mr. Anderson 4 A. Good morning 5 Q. Before we get started I need to make agreements 6 with your attorneys and then we can begin 7 MR KARST Can we agree that this 8 deposition is being taken pursuant to the 9 Minnesota Rules of Civil Procedure and that an 10 objection by one Defendant is good for all 11 present or on the phone 12 MR MORTL Agreed 13 MR KARST Any other housekeeping before 14 we start 15 MR MORTL No. 16 Q. By Mr. Karst Mr. Anderson can you state your 17 full name for the record 18 A. Raymond A. Anderson Jr. 19 Q. And what is the A What is your middle initial 222222 A. Albert 222222 Q. When were you born 222222 A. April 27 1945 222222 Q. And you're here today as far as I understand 222222 r_epresenting both du Pont and Sporting Goods 222222 Properties Inc. on certain topics that we've asked 9 1 Q. Do you know what the title of those catalogs is 2 A. Generally they're known as Remington 1964 or 5 3 or whatever 4 Q. Is it an annual publication 5 A. Product catalog yes 6 Q. And the price lists what are those 7 A. Those are individuals sheets They go to 8 vendors and sales operations that sort of thing 9 Q. So someone who would be selling either 10 ammunition or Remington products 11 A. huh That's right 12 Q. And you also said you reviewed meeting minutes 13 What meeting minutes are those 14 A. Well the meeting minutes The major one was my 15 deposition in a previous legal matter 16 Q. Is that your deposition from 2014 17 A. That's correct 18 Q. And that was an asbestos matter at that 19 time 20 A. That's right 2 Q. Anything else You said meeting minutes and 22 you mentioned deposition What else 23 A. I read some Remington documents that I have that 24 had to do with various products and processes and so 25 forth Doby Professional Reporting Inc. 952-943-1587 3 Pages 6 to 9 Raymond A. Anderson Jr. 7/18/2018 10 1 Q. You said you had Are these document that you 2 had and not that your attorneys gave you 3 A. My attorney showed me several documents but 4 most of the documents that I recall off the top of my 5 head were in my first deposition same stuff 6 Q. They were attached as exhibits 7 A. I believe they were 8 MR KARST Do you have a copy of the 9 specific ones that he reviewed 10 MR MORTL I do not but I can represent 11 he did not review anything that has not already 12 been produced in the case 13 MR KARST There's 10,000 pages That's 14 kind of voluminous Can you narrow it down a 15 little bit Are they in the du Pont stuff Are 16 they in the Sporting Goods stuff 17 MR MORTL Well I think he just told you 18 it's catalogs it's price list and his prior 28728 deposition exhibits 28728 MR KARST Right But meeting minutes and 28728 formulas and so I'm forth is that stuff that 28728 was in the du Pont docs or is that stuff was in 28728 the Sporting Goods Properties docs 2 MS TRATTLES I would say the majority was 25 in the Sporting Goods documents There might be 12 1 Q. By Mr. Karst How many conversations did you 2 have with your attorneys 3 MR MORTL You can give him a number if 4 you remember 5 THE WITNESS A dozen 6 Q. By Mr. Karst Were these on the phone or were 7 some of them in person 8 A. Some were in person 9 Q. Did they come out to your house or did you come 10 to the law firm 11 A. Both 12 Q. When you would come and meet in person were 13 there documents that you would review 14 A. huh 15 Q. Is that yes 16 A. Yes 17 Q. What documents would you review at that time 18 A. The ones I mentioned before 19 Q. Anything different from what you've mentioned to 20 me already 21 A. No. 22 Q. Do you have a copy of any documents related to 23 shotgun shells and containing products in your 24 possession 25 A. Yes 11 12 some that came from a du Pont source but the 2 overwhelming majority were in the Sporting Goods 3 Properties production to you 4 MR KARST Okay 5 Q. By Mr. Karst Mr. Anderson when did you first 6 learn of the case that we're here today for the Robert 7 Benson case 8 A. Several months ago 9 Q. And were you contacted -- I don't want to know 10 anything that you discussed with an attorney or 11 anything but were you contacted specificalfloyr this 12 case 13 A. Yes 14 Q. And do you know who contacted you 15 A. I believe it was Gloria Attorney Trattles 16 Q. You said they weren't representing you at the 17 time Can you tell me what was the discussion that 18 you had 19 MR MORTL I'm going to instruct you not 222222 to answer that because you were represented by 222222 us at the time 222222 We're going to assert attorney 222222 privilege and instruct him not to answer and 222222 you and I can talk about that line if need 222222 be 13 1 MR MORTL He's asking other than the 2 documents that you got from us 3 THE WITNESS Other than the documents -- 4 Q. By Mr. Karst Correct 5 A. No I don't think so 6 Q. Have you ever looked 7 A. When 8 Q. At any point have you ever looked for any 9 documents 10 A. No none outside of these proceedings 11 Q. The deposition that you gave in 2014 in the 12 Michael Taska case have you ever given a deposition 13 besides that deposition 14 A. No. 15 Q. Have you ever been involved in an 16 asbestos matter outside of this case and the 17 Michael Taska case 18 A. No. 19 Q. Where do you live 20 A. Eastford Connecticut 22222 Q. And you were born in 1945 22222 A. Correct 22222 Q. So 22222 A. 73 22222 Q.Q. I'm assuming you graduated high school -- Doby Professional Reporting Inc. 952-943-1587 4 Pages 10 to 13 Raymond A. Anderson Jr. 7/18/2018 14 123 A. I have it memorized 123 Q. assuming you graduated high school in '63 123 A. Yes 4 Q. Did you work in high school 5 A. Did I work in high school 6 Q. Yes 7 A. I had summer job 8 Q. What did you do Anything in the 9 construction trades or anything like that 10 A. No. 11 Q. Auto mechanic or anything 12 A. I did some auto work but not for pay 13 Q. Just on your own stuff 14 A. Yes 15 Q. You graduated high school in '63 What did you 16 then do 17 A. Went to college 18 Q. Where 19 A. Georgia Tech Q. yeayoru s 22222 Q. Did you graduate graduate '67 ? 23 A. '68 Q. high Did work graduationbetweengraduation 22222 you at Q. fromfrom high school and graduation from Georgia Tech Techin 16 1 A. Mechanical and industrial 2 Q. Did you have any family members who ever worked 3 at Remington 4 A. No. 5 Q. Do you know anybody else who worked there when 6 you applied 7 A. No I didn't 8 Q. Shot in the dark 9 A. It's a big place 10 Q. So you were hired in March of '68 11 A. huh 12 Q. What did you get hired as 13 A. research engineer 14 Q. And what is a research engineer 15 A. It's an engineer that does research 16 Q. On what 17 A. Ammunition There were various other peripheral 18 products product lines that I didn't get involved 19 with 2 Q. Any specific type of ammunition 2 A. Shotshell centerfire 2 Q. There's gointgo be deposition so I'm going to terms the ask - I'm sure a lot of of 2 them are obviously very familiatro you but some us 25 are not -- can you explain what shotshell is 15 1 '68 2 A. Yes Summer jobs again 3 Q. What type of summer jobs did you have 4 A. I worked at the Bullard Company in Bridgeport 5 Connecticut They make machine tools or they used to 6 I did some lawn service type work that kind of thing 7 Q. Any jobs down at Georgia Tech 8 A. That's where the lawn work was It was hot 9 Q. So you graduated in I assuming May of '68 10 A. March 11 Q. March of '68 12 A. huh 13 Q. Is that when you started Remington 14 A. Yes 15 Q. How did you get your job at Remington 16 A. interviewed foritwhen I was on a vacation in 122222 the winter prior early 1968. It was kind of like a 122222 job fair type of thing in Bridgeport 122222 Q. Was there a specific type of job that you were 122222 interviewing for 122222 A. Engineerijnogb 122222 Q. What type of engineer 122222 A. Mechanical 24 Q. Did you graduate with a degree in mechanical 25 engineering 17 1 A. shotshell is ammunition for a shotgun 2 Q. And centerfire 3 A. Centerfire is ammunition for rifles and pistols 4 generally and other sorts of weapon systems in the 5 military 6 Q. And the shotshell is that for both target and 7 for hunting 8 A. Yes 9 Q. Any particular gauge that you worked on 10 A. Well I worked on -- at one time or anotherI 11 worked on all of them 12 Q. We're talking shotshell 13 A. 12 16 20 410 14 Q. Any others 15 A. gauge That's an industrial shotshell 16 Q. What is an industrial shotshell 17 A. It's a big shotshell with -- I believe it was a 18 ~~ 2 ounce slug used for studying vibrations reflected 19 back in the earth when you fire the thing for oil 20 exploration that kind this 21 Q. I've seen it in movies You have a stand and 22 you fire straight down 222 A. Yes 222 Q. Are the 12 16 20 and 410 all operated 25 shotguns Doby Professional Reporting Inc. 952-943-1587 5 Pages 14 to 17 Raymond A. Anderson Jr. 7/18/2018 18 1 A. Yes 2 Q. Any other uses for the 12 16 20 and 410 3 MR MORTL Vague 4 Q. By Mr. Karst Besides use them in a handheld shotgun 6 A. Besides hunting and target shooting 7 Q. Yes 8 A. No. 9 Q. Any particular calibers of centerfire 10 A. .308.306 .308.306 .556 some .44 mag pistol That's 11 about it 12 Q. In regards to the shotshell does Remington make 13 anything besides 12 16 20 410 and ? 14 A. No. 15 MR MORTL Objection to form 16 Q. By Mr. Karst For the period oftime that you 17 worked for Remington did Remington ever make anything 18 _ besides those five 19 A. You know they made gauge 20 Q. Throughout your time period 21 A. Yes I believe we made some out there 22 Q. Does the gauge have the same use as a 12 16 23 20 and 410 24 A. Basically It's known as a goose gun shell 25 They've got a big long barrel long range but it's 20 1 A. Yes Shared one of the buildings yes 2 Q. So you really didn't - 3 A. I was quite familiar with the surroundings 4 Q. How long did you stay at RemGrit 5 A. I was there about five years and then they sold 6 the business 7 Q. What did you do at RemGrit 8 A. I was the vice president of production 9 Q. Let's step back to Remington You were a 10 research engineer in ammunition How long did you have 11 that title 12 A. Now you're gonna tax me I had lot of titles 13 at Remington Research engineer for three years 14 Q. What was your next job after that 15 A. Senior research engineer for two years I 16 believe 17 Q. What is the difference between a research 18 engineer and a senior research engineer in regards to 19 your job 20 A. Complexity 21 Q. What do you mean bythat 22 A. You get different jobs and in some cases you 23 get some supervisory responsibility with research 24 engineers 25 Q. Are you still doing hands on work 19 12 basically the same as a gauge shell as far as 12 operation 3 Q. You started at Remington in March of '68 4 A. Right 5 Q. How long did you work there 6 A. Until 1986. I believe it was May or June 7 Q. And why did you leave 8 A. The plant was closed down and the follow 9 business was something I was familiar with so they 10 hired me 11 Q. Who did 12 A. RemGrit Corporation 13 Q. And what is RemGrit Corporation 14 A. They manufactured abrasive products 15 Q. Saws and so forth 16 A. Yeah Different kinds of saws both hand and 17 machine saws 18 Q. Was that a division of Remington 19 A. Yes 20 Q. So where you worked from '68 until the summer of 22222 '86 that was in Bridgeport Connecticut correct 22222 A. Yes 22222 Q. Was RemGrit also in Bridgeport 22222 A. Yes 25 Q. Was it one of the same buildings 21 1 A. Yes 2 Q. All the same duties that you had before just 3 more 4 A. Yes 5 Q. After your two years as a senior research 6 engineer in ammunition what did you do 7 A. I became a research supervisor 8 Q. What is a research supervisor 9 A. Supervises research engineers and senior 10 research engineers 11 Q. Any other type of engineers you're over 12 A. No. 13 Q. How did you have the title 14 A. I think it was probably a couple years 15 Q. three years 16 A. Yes Probably two 17 Q. What was your next job title 18 A. have to think about this Production 19 supervisor Production chief supervisor actually 20 Q. What is a production chief supervisor 21 A. Supervises the manufacturer of ammunition 2222 products 2222 Q. Both centerfire and shotshell 2222 A. No. Shotshell and rimfire 2222 Q. What is rimfire Doby Professional Reporting Inc. 952-943-1587 6 Pages 18 to 21 Raymond A. Anderson Jr. 7/18/2018 22 1 A. 22s It's a shell that's made with primer 2 that's inserted into the rim of the shell and the fire 3 pin strikes the rim rather than striking the center 4 which would be centerfire 5 Q. Would rimfire be all shotgun related 6 A. No. Rifle and pistol Mostly .22 caliber 7 Everybody says .22s small caliber compared to 8 centerfire 9 MR MORTL It's a little bullet 10 THE WITNESS It's a little bullet yes 11 Q. By Mr. Karst How were you product chief 12 supervisor 13 A. Production chief 15610-222 Q. Production chief supervisor 15610-222 A. I never had anything to do with marketing 15610-222 proudly I was the chief supervisor for two or three 15610-222 years 15610-222 Q. What was your next title 15610-222 A. Chief supervisor of plant engineer 15610-222 Q. What does that entail 15610-222 A. Overseeing the maintenance and business conduct 15610-222 _ basically of the plant the plant operation itself 2 the equipment and the people 2 Q. So longer supervising the engineering of the 2 product itself It's engineering of the building 24 1 mechanical parts There were other numbers assigned to 2 other buildings some of which I don't remember 3 Q. Sure When you were the chief supervisor of 4 plant engineering was that just over 875 or other 5 building numbers 6 A. Other buildings as well The maintenance 7 department was included in it which was pretty big 8 Q. Where manufacturing was performed what building 9 number is that 10 MR MORTL Objection to form 11 Go ahead 12 THE WITNESS There were quite a number of 13 them of buildings 14 Q. By Mr. Karst Does it depend on the product 15 being made 16 A. In part 17 Q. If I asked shotshell what building or buildings 18 is shotshell manufactured I know there's different 2 components 2 A. Primarily 300 series buildings 21 Q. Is there anything else made in the 300 series 22 _ buildings besides shotshell and shotshell components 23 A. Rimfire 2 Q. When you were a chief supervisor of plant 2 e_ngineering was your job over the 300 series 23 1 itself 2 A. The building and the people that maintain the 3 building That's about it really 4 Q. Is it just the maintenance of the building or 5 is it also production workers 6 A. Maintenance and production equipment too 7 Q. That's where I was going 8 MR MORTL Slow it down a little bit for 9 the court reporter She can't type several 10 people speaking You know where he's going with 11 his question but you've got to let him finish 12 his question and then give your answer 13 THE WITNESS Okay 14 Q. By Mr. Karst When you were doing this type of 15 work as a chief supervisor of plant engineering was 16 there a certain plant that you were in in Bridgeport 17 A. The same one was in in all the other jobs 18 Q. Which is which building 19 A. Mostly 875 but in Bridgeport Connecticut 20 Q. I understand the plant is -- there's different 21 sections to the plant itself 22 A. Correct The Barnum Avenue facility would be 23 the property 24 Q. And the building number is 875 25 A. 875 was the office building and part of the 25 1 buildings 2 A. It was more within them The 300 series 3 buildings were production buildings When I was the 4 plant chief supervisor of plant engineering it was 5 maintenance slash engineer employees so my office 6 was not in the 300 series buildings 7 Q. But would your job entail you going into those 8 buildings during that time 9 A. Yes 10 Q. Would that be for production equipment or any 11 maintenance to the building itself 12 A. That's right equipment and facilities 13 Q. After you were chief supervisor of plant 14 engineerin-g- how long did you have that title 15 A. Again about two or three years not specific 16 Q. Sure After that 17 A. I was superintendent of employee relations 18 Q. Where did that have you located out there 19 A. I was in 875 building 875 20 Q. What did that job entail 21 A. Supervision of all employee relations functions 22 Q. Did that entail you actually going out into the 23 facility itself or would employees come to you 24 A. Both 25 Q. The majority of the time one versus the other Doby Professional Reporting Inc. 952-943-1587 7 Pages 22 to 25 Raymond A. Anderson Jr. 7/18/2018 26 1 MR MORTL Objection to form 2 THE WITNESS One or the other 3 - Q. Mr. Karst Okay Not one greater than the 4 other in your mind 5 A. No not really 6 Q. Is this dealing with issues that employees have 7 or 8 A. Yes That was a big issue at that time The 9 plant was going to announce that it was going to be 10 moved 11 Q. How long were you superintendent of employee 12 relations 13 A. Two years 14 Q. And you mentioned that that was the big thing 15 going on that the plant was going to move Do you 16 remember what year this was 17 A. I'm just guessing 1966 18 MR MORTL '66 22222 THE WITNESS I'm sorry '76 '66 is when 22222 I got there 22222 Q. By Mr. Karst Somewhere around 76ish 22222 A. Actually it's later than that too now that 22222 think about it 80s I've had a lot of jobs there 22 Q. So you're thinking mid 80s 22 A. Yes 28 1 THE WITNESS Specifically a safety issue 2 no They would go through the safety 3 supervisor 4 Q. By Mr. Karst And who was that at that time 5 MR MORTL Same objection 6 THE WITNESS I don't recall 7 Q. By Mr. Karst At any of your tenure at 8 Remington from '68 through '86 do you remember any of 9 the people in charge of safety out at the plant 10 whether alive or deceased 11 A. I don't recall the names no 12 Q. When you got there in '68 did Remington have 13 someone in charge of safety 14 A. Oh yeah 15 Q. When everything closed down in '86 did 16 Remington still have somebody in charge of safety at 17 that time 18 A. Yes 19 Q. After your tenure as the superintendent of 20 employee relations -- you said you had that job roughly 21 two years - what was your next job 22 A. I believe that was the job title I had when I 23 left Remington 24 Q. Okay You mentioned that shotshell was made in 25 the 300 series buildings correct 27 12 Q. Any other issues besides the issue with the 2 plant potentially moving that you would deal with the 3 employees 4 A. Well there were always other issues 5 Q. Was safety part of the issues 6 A. Yes But I wasn't responsible for that I was 7 responsible for just the employee relations part We 8 had a separate department that handled safety and 9 security and a few other things 10 Q. When you say you handled the employee relations 11 part of the issues what does that meant 12 A. That means I oversaw the activities involved 13 with people getting paid people's benefits people 14 getting along with each other dealing with the union 15 that represented the people being the between 16 _between the plant manager who was overall responsible 122222 for the plant and the rest of the people and the rest 122222 of the plant staff 122222 Q. If an employee during this period of time had a 122222 safety issue regarding some equipment they were working 122222 on are you the person that they would go to or would 122222 they go to somebody else 122222 A. On safety a issue 24 Q. Yes 25 MR MORTL Objection to form 29 1 A. Nod yes 2 Q. Along with rimfire 3 A. Rimfire shells yes 4 Q. Is the manufacturing of shotshell quite 5 different from rimfire or were they relatively the 6 same 7 MORTL Objection 8 Q. By Mr. Karst I understand one's centerfire 9 and one's fired on the rim but is the manufacturing 10 relatively similar 11 MORTL Objection to form 12 THE WITNESS They're quite different 13 Q. By Mr. Karst Can you explain to me when you 14 got there in '68 what were the component parts for 15 shotshell 16 MORTL Objection to form 17 Go ahead 18 THE WITNESS It would depend on what kind 19 of shotshell it was what gauge 20 Q. By Mr. Karst Let's do gauge 21 A. Okay The major components of the shells that 22 _would be manufactured whenI first got there were the 23 shell body shell cap or head shell basewads internal 24 wads that were in the shell which depended on what 25 load it was lead shot Doby Professional Reporting Inc. 952-943-1587 8 Pages 26 to 29 Raymond A. Anderson Jr. 7/18/2018 30 12 Q. What - 2 A. Lead shot 3 Q. A 4 A. A yes Heavy Depending on the load 5 other types of wads which would have been made out of 6 cardboard orfelt as opposed to shell basewad and the 7 primer which was made up of subcomponents as well 8 Q. What is a primer 9 A. On a shotshell primer a battery cup -- 10 MR MORTL Objection to form 11 THE WITNESS A battery cup an anvil a 12 primer cup and explosive mix 13 Q. By Mr. Karst Outside of the explosive mix 14 are the components metal or plastic 15 A. They're metal all brass 16 Q. Are those individual parts for the primer all 100222222 formed or stamped out or however they're made at the 100222222 Remington facility the Bridgeport 100222222 MR MORTL Form 100222222 THE WITNESS Yes they were 100222222 Q. By Mr. Karst You mentioned the shell body 100222222 Are we talking a paper body or plastic body 100222222 A. It depends on when you're talking In 1968 they 100222222 were plastic bodies period transition 100222222 Q. Was there a period of transition when they were 32 1 Q. By Mr. Karst Is there a reason you needed 2 these notes 3 A. Just because there's kind of a lot of dates and 4 numbers and things on them so it gets confusing so 5 just to keep my thinking straight 6 Q. And this is a page document sided 7 A. Yes 8 MR KARST I'll mark this as Exhibit 1 9 10 Plaintiff's Exhibit 1 handwritten notes 11 of Mr. Anderson marked for identification 12 13 Q. By Mr. Karst On the document it says the last 14 paper shell bodies was 1966. Is that correct 15 A. correct TBhuatt's 16 Q. prior to 1966 they had -- I can see from 17 the line -- '61 to '63 some field loads with top 18 plastic shells A. That's correct 20 Q. So prior to 1961 were all bodies paper is 2222 Q. What field load field load field load A. hunting field purpose hunting primary A 23 A. load is a llooaadd primary 24 Q. Obviously target load just for target shooting 25 A. TargTargeet t shooting shooting 31 123 paper bodies versus plastic 123 A. Yes 123 Q. Roughly when was that transition period 4 A. Early 60s 5 Q. After they transitioned to -- 6 A. have a cheat sheet I should tell you about 7 Q. I was going to ask you about it 8 A. There's some dates and -- 9 MR KARST Do you mind if I see this 10 MR MORTL I've got a copy for you 11 Counsel He made notes also on his depo notice 12 so that he knew what categories he was -- if you 13 want to mark it as an exhibit here's an extra 14 MR KARST We'll mark that one page of 15 handwritten notes 16 Q. By Mr. Karst Mr. Anderson is this your 17 handwriting 18 A. Yes 19 MR MORTL Wait Is this your 20 handwriting 21 THE WITNESS No. In part my 22 handwriting It's my information I believe 23 Gloria did this for me when we were having a 24 meeting I have pretty good arthritis in my 25 hands and I don't write that well anymore 33 1 Q. Can you use a target load to hunt with 2 A. You could 3 Q. And vice versa can you use a field load to 4 target shoot with 5 A. Not really You could but it's typically a 6 heavier shot and heavier load You would be 7 overpowered for target shooting if you're doing target 8 shooting that's sanctioned by a body of sportsmen they 9 themselves There are certain regulations for the 10 gaugesgauges that you can use for certain types of target 11 shooting skeet trap 12 Q. Did those regulations exist in the 1960s 13 A. Yes 14 Q. Do you know what specific regulations those are 15 what body enforces those regulations 16 A. American Skeet Shooting Association American 17 Trap Shooting Association organizations like that 18 Q. But if you're just out messing with friends you 19 can use a field load target shooting 22222 A. Sure 22222 Q. you a have field load and a target load 22222 that's gauge - well I'm making an assumption 22222 Remington made both right 22222 A. Yes 25 Q. If you have a field load and a target load Doby Professional Reporting Inc. 952-943-1587 9 Pages 30 to 33 Raymond A. Anderson Jr. 7/18/2018 34 1 that's gauge what is the difference between the 2 two 3 MR MORTL Objection to form 4 Q. By Mr. Karst And there's other factors 5 that I need to be asking you to know the difference 6 let me know 7 MR MORTL Objection to form 8 If you can answer 9 THE WITNESS The major differences are the 10 weight of the load the lead shot primarily 11 There are also differences in the wad column as 12 it's known which is internal parts of the 13 shell 14 Q. By Mr. Karst And which wads are you referring 15 to 16 A. Well it depends on which load you're talking 17 about but typically -- 1 Q. If we're dealing with gauge 19 A. A gauge would have a basewad an powder 20 wad card wad for the timers power piston wads in 21 the newer shells and H wads which I believe we started 22 making in the 50s well before I got there plastic 23 wads 24 Q. And is the weight difference the wads or is the 25 weight difference the shot 36 1 Q. The main difference is weight What would cause 2 the difference in weight is typically the size of the 3 shot and how much powder you need but you also 4 mentioned that there's some type of difference in the 5 wad itself and that's what I'm asking 6 A. Yes The wad column would be different 7 Depending on the shell you could have a separate 8 basewad as it's known which is the wad that you're 9 interested in here I'm sure or the integral base in 10 the shell a shell all in one piece 11 Q. And that's for -- 12 A. That could be for either target shooting or 13 field shooting 14 Q. What's a separate basewad 15 A. separate basewad is a component that fills the 16 b_ottom of the body of the shell when the shell is a 17 plastic body or before that paper body The body 18 was a tube and the first thing that went into the tube 19 in the manufacturing process was a basewad and that 20 _ formed the base section of the shell Q. I don't want to put words in your mouth but I 22 thought you said a separate basewad That's why I'm - 2 A. Yes it's not an integral body shell or 24 ~ u_nibody shell there's a basewad in it and it could be 25 made out of plastic or dry molding 35 123 A. It's primarily the shot but the shot weight 123 might bring on a different weight in a powder charge as 123 well 4 Q. You might have more or less powder 5 A. Yes 6 Q. The wads that are internal would they 7 differentiate at all -- 8 A. Between the field and -- 9 Q. the target 10 A. Yes 11 MR MORTL Objection to form Slow down a 12 little bit 13 Q. By Mr. Karst What would be that 14 differentiation -- 15 MR MORTL Objection to form 16 Q. By Mr. Karst -- between field and target on a 17 gauge 18 MR MORTL Same objection 19 Q. By Mr. Karst Do you understand my question 222322 A. Repeat the question 222322 Q. You mentioned that a field wad and a target wad 222322 one of the main differences 222322 A. Field load and target load 222322 Q. Field load and target load 25 A. Yes 37 1 Q. So unibody shell or integral shell 2 A. Unibody and integral body is the same thing 3 different nomenclature 4 Q. What is that 5 A. It's a shell made in one piece 6 Q. Does that have a basewad in it 7 A. No not as such It's not a separate component 8 Q. Is that a target shot 9 A. It's primarily target but there are field loads 10 _ using those shells too 11 Q. Has there always been field loads using those 12 or that something newer or a specific type of gauge 13 MR MORTL Objection to form 14 THE WITNESS The whole concept of the 15 unibody shell came into being in the early 60s 16 earlier than 60s and it was preferred 17 construction because it was stronger 18 Q. By Mr. Karst If you had a unibody shell it 19 does not have a basewad in it 20 A. Correct 21 Q. You have to put one in it when you -- 22 A. You don't put one in it It's built into the 23 shell That's why it's an integral body It's a 24 unibody one piece 25 Q. Is it down on the bottom or is it up on the Doby Professional Reporting Inc. 952-943-1587 10 Pages 34 to 37 Raymond A. Anderson Jr. 7/18/2018 38 1 sides 2 A. A section that would be analogous to a basewad 3 in the bottom 4 Q. Is there still a primer that goes into the 5 center 6 A. Yes 7 Q. Is that a rim or a center 8 A. Center All shotshells are centerfire 9 Q. This unibody shell did they make it in certain 10 gauges 12 THE WITNESS Yes but primarily 12 13 Q. By Mr. Karst Outside of the unibody shell 14 did all other shotgun shells have a basewad 15 A. Yes unibody Q. The unibody shell that 17 did have wads didn't have a basewad that - 18 A. Yes Q. go 19 I'll back to that . I know we kind of got off I'll to little track 222222 go babacckk to tthhe e uniunbibooddy y shsehllellin a little I'll track 222222 bit I want to go back to the gauge shell that we 222222 were talking about before We were talking about the shell body and then you also mentioned obviously 222222 they have a basewad in there and a shell cap . 25 A.A. Yes . 40 1 wads The basewad is associated with the shell The 2 powdewr ad is a separate component It's 3 generally made of cardboard or felt composition The 4 shot container sometimes known as shot protector is a 5 wad that the shot goes into and it's made out of 6 plastic and that protects the shot from being formed 7 against the barrel of the shotgun to some extent 8 Q. Is that the power piston you're referring to 9 A. That's Remington's trade name for it Yes 10 Q. Do you either have the internal wads or a power 12 A. You can have both 13 Q. Now you mentioned the other type of wads were 14 cardboard and felt 15 A. huh 16 Q. How do you know that 17 A. That's how our specifications read The 18 catalogs can give you the rundown on what kind of wads 19 are in each particular load 222221 Q. Are there any other component parts of cardboard 222221 wads besides cardboard 222221 MR MORTL ObjectionObjection WITNESS don't 222221 THE : I don't know 222221 Q. By Mr. Karst How about the felt wads any 222221 other component parts 39 1 Q. I think you said cap 2 A. Cap or head Those terms are interchangeable 3 for that 4 Q. I'm looking in a shotgun shell from the 5 outside is that the metal part 6 A. Yes 7 Q. And then the shell basewad where is that 8 located within the shell 9 A. It's on the bottom of the shell 10 Q. Meaning - 11 A. Surrounded by the cap and whatever the body is 12 made out of paper or plastic 13 Q. Are there different sizes of basewads 14 A. Yes 15 Q. And what would the size of the basewad be 16 determinate of 17 A. The gauge the shell We're talking about a 18 gauge It would be the same diameter but it might 19 have a different length depending on what the shell is 20 used for 22222 Q. You mentioned there were internal wads depending 22222 on the load 22222 A. Correct 22222 Q. What do you mean by that 22222 A. Well there were several different kinds of 41 1 A. Yes Felt wads are made up of felt fiber 2 sometimes animal fiber horse hair and it has a 3 binder I believe it's a little butyl rubber That's 4 it for the felt wad 5 Q. What does a felt wad look like 6 A. A disc of varying thickness and diameter which 7 is defined by the inside of the shell That's it 8 Q. An image just popped in my head At times when 9 you have a chair on a hard surface you put that little 10 felt buffer on there so that you don't scratch the 11 floor 12 A. Bingo 13 Q. Is that relatively what it looks like 14 A. Not as big but yeah it looks like that 15 Q. Just the diameter is smaller 16 A. Yes 17 Q. I'm dealing with a cardboard wad what does 18 that look like 19 A. It looks like a piece of fairly thick cardboard 20 without the expansion chambers that cardboard typically 21 has It again depends on the outside diameter of the 22 shell and the amount of body that you want to fill up 23 _ in the shell determines its thickness 24 Q. Would the felt also -- would the thickness vary 25 A. It could yes Doby Professional Reporting Inc. 952-943-1587 11 Pages 38 to 41 Raymond A. Anderson Jr. 7/18/2018 42 1 Q. You also mentioned I believe an H wad 2 A. Yes An wad is a plastic molded wad that was 3 device that Remington invented Quite few other + manufacturers made it too but it's a plastic piece 5 that looks like -- instead of being flat like a 6 cardboard wad or a felt wad it has concave sections in 7 both the front and on the back of it so if you put -- 8 the major use for the H wad is to separate the 9 propellant package whatever it might consist of the 10 shot package originally OriginallyI say because that 11 was used before the power piston came into existence 12 therefore it did not have the shot protection 13 qualities that the power piston had It just sealed 14 _ off the powder chamber from the shot chamber basically 15 Q. Which is what the power piston did when that 16 came in 17 A. The power piston did that as well as protecting 1 the shot from the shotgun barrel 19 Q. When the power piston came into being was the H 20 wadwad used anymore 21 A. No I don't believe so 22 Q. I'm sure there's a transition period 23 A. Yes there is 24 Q. What was an H wad made up of 25 A. Polyethylene plastic 44 1 A. No. 2 Q. What else have you seen besides - 3 A. We had some Union Carbide polyethylene as well 4 Q. Do you know if the polyethylene had any type of 5 a filler or an additive 6 A. The du Pont stuff didn't no It was pure 7 polyethylene 8 Q. Do you know if the Union Carbide stuff did 9 A. I don't know 10 MR KARST Do you wantto take a 11 minute break 12 MORTL Sure 13 VIDEOGRAPHER The time is 11:07 a.m. We 14 are going off the record 15 16 ***** 17 18 VIDEOGRAPHER The time is 11:23 We are 19 back on record 22222 Q. By Mr. Karst Mr. Anderson looking at Exhibit 22222 1 which is the handwritten notes here you mentioned 22222 that you did not write this that your attomey did 22222 correct 22222 A. She mechanically wrote it I told her what to 25 write 43 1 Q. That's it That's the only component 2 A. That's it 3 Q. Were they made by somebody else and then 4 shipped to Remington or did Remington -- 5 A. No. Remington made them 6 Q. Where they molded 7 A. Yes 8 Q. Are they compression molded or injection molded 9 A. Injection molded 10 Q. Injection molded so there would be a hopper on 11 the machine stuff is poured in it's injected into a 12 mold and there comes the end product 13 A. Correct 14 Q. Is just polyethylene that's poured into the 15 hopper or are there other things poured in there 16 A. Just polyethylene 17 Q. And how do you knowit's just polyethylene being 18 put in 19 A. It comes out of Alathon bags 20 Q. What's an Alathon bag 22222 A. It's a brand name from du Pont for polyethylene 22222 Q. So all the polyethylene for the H wad came from 22222 du Pont itself 22222 MR MORTL Objection to form 22222 Q. By Mr. Karst From what you've seen 45 1 Q. The first thing written on there is well I 2 guess in the upper righwte have plastic H wad mid 3 1950s Where is that information coming from 4 A. Do you mean the H wads 5 Q. Yes 6 A. catalog I had to go through catalogs and 7 price lists to remember what these dates were and so 8 forth 9 Q. Do you know which specific catalog you looked 10 at 11 A. Remington's ammunition catalogs 12 Q. Do you know what year catalogs you looked at 13 A. Everything from 1950 or so up to the 80s or so 14 Q. And what were you looking for 15 A. Dates of manufacture make sure we had the right 16 manufacture cutoff dates for things that we were 17 looking at 18 Q. When you say plastic H wads mid 1950s what 19 does that mean 20 A. That means that's when they were used That's 21 when they came into use 22 Q. And are you basing that off of you looked at a 23 catalog and that's the first time they appeared in a 24 catalog How do you come up with the mid 50s from 25 looking at catalogs Doby Professional Reporting Inc. 952-943-1587 12 Pages 42 to 45 Raymond A. Anderson Jr. 7/18/2018 46 1 A. They're good indicators of when something came 2 into being for sale I have all kinds of other dates 3 in my head -- because I was an D guy -- about what 4 the progression of those kinds of things were 5 Q. Right But you said the plastic H wad mid 1950s 6 note came from the catalogs 7 A. Yeah The timing foirt did 8 Q. Right But if you're looking at the catalogs 9 does a catalog not give you a specific year if you're 10 looking at a specific year of a catalog 11 A. Well it gives you the specific year that you're 12 reading but if you come across something for the first 13 time in a string of catalog dates you'll know that's 14 when it was first introduced roughly 15 Q. That's what I was trying to understand Why did 16 you not have your attomey write down the year of that 17 catalog as opposed to putting mid 50s 18 A. I did for several of them or she did 19 Q. know for thatt hat one you didn't 222222 A. No reason I don't know 222222 Q. So is this you looking at the catalogs or is 222222 this your attorney looking at the catalogs and writing 222222 down year 24 A. Both 25 Q. Are you looking at the catalogs together 48 1 would say 2 Q. Were you in this office 3 A. No. 4 Q. Where were you 5 A. Home 6 Q. Who was present with you 7 A. Some of this might have been from my first 8 deposition too which was four years ago 9 Q. Might have been doesn't help me That's why I 10 need to know that facts question I 11 MR MORTL Hold on think there's some 12 confusion on what the is if you're 13 talking about the first deposition I think he 14 means when was this handwritten -- 15 MR KARST Hold 16 Q. By Mr. Karst When this list was generated 17 you said you were at your home 18 A. huh 19 Q. And the attorneys brought documents to you 2322 A. Correct Q. Who was present for that meetmieentigng 2322 A. Both of my attorneys 2322 Q. So it was just the three of you or were there 2322 more people there 25 A. No. Just the three of us No. . 47 123 A. huh 123 Q. Yes 123 A. Yes 4 Q. You have felt wad around 1930tso 1968 or 1969 5 A. Correct 6 Q. What is that information based off of 7 A. Once again I'm sure we got the dates from the 8 catalogs and price lists 9 Q. What catalogs did you look at that are from the 10 1930s I'm unaware of any 11 A. I don't know I can't answer that 12 Q. So where would the date around the 1930s come 13 from 14 A. It might have come from our process records 15 other things that we looked at when we started -- 16 Q. What are process records 17 A. Process records are records of how something is 18 made what equipment is used what materials are used 2222222 that kind of thing 2222222 Q. You said it might have come from that 2222222 A. Yeah I don't recall 2222222 Q. When was this list generated Was this 23 yesterday when you met with your attorneys 24 A. No. It was before that We had this -- I don't 25 know -- a couple months ago A couple months ago I 49 1 Q. And did they literally -- what documents did 2 they have with them 3 A. Well they had some catalogs and they had some 4 price lists and we went through those 5 Q. Are they on a computer or are they hard copies 6 A. Hard copies 7 Q. So are we talking like an inch of documents - 8 5 feet of documents What are we talking about 9 A. I don't know I didn't measure it 10 Q. Give me an idea 11 A. Take a fairly thin catalog for 20 years worth at 12 least between 40s and 60s They're catalogs The 13 price lists are one sheet generally 14 Q. I understand that but in the catalogs that I 15 have I don't see any from the 30s and 40s so that's 16 why I'm trying to understand where this comes from 17 MORTL Objection to form 18 THE WITNESS | told you it might have come 19 from the process records 20 Q. By Mr. Karst I just asked you what documents 21 you looked at and you said your attorney had given you 22 catalogs to look at 23 A. huh 24 Q. Correct 25 A. Yes But not exclusively Doby Professional Reporting Inc. 952-943-1587 13 Pages 46 to 49 Raymond A. Anderson Jr. 7/18/2018 50 1 Q. What else did they give you 2 MR MORTL Objection to form 3 THE WITNESS Catalogs price lists and I 4 don't recall the rest but I worked there for 20 5 year and I remember a lot of process records 6 and I've seen those I know the product very 7 well 8 Q. By Mr. Karst Do you have an independent 9 recollection that felt wads came into existence in 10 around the 1930s 11 MR MORTL Objection to form Vague 12 THE WITNESS Me personally 13 Q. By Mr. Karst Yes 14 A. No. I wasn't born then 15 Q. You have here to 1968 or 1969. Do you have an 16 independent recollection that they were used until '68 17 or '69 18 A. recall them being used until then 19 Q. Pardon 2 A. recall them being used until then 2 Q. On that you have an independent recollection 2 A. I don't understand what you mean by independent 23 recollection 2 Q. Felt wads you have around 1930s to '68 or '69 25 correct 52 1 remember I really don't read them anymore 2 Q. By Mr. Karst But these are catalogs that you 3 personally obtained 4 A. These are magazines 5 Q. Magazines that you personally get 6 A. Yes 7 Q. Do you still have copies of any of those 8 A. Yes 9 Q. What do you still have copies of 10 A. American Rifleman I subscribe to that 11 Q. How far back do your copies go 12 A. It depends which ones I threw away 13 Q. Okay Give me an idea I 14 A. really can't 15 Q. Can you give me a decade 16 A. Two years three years 17 Q. What's the oldest magazine that you have in your 18 house Objection 19 MR MORTL Objection to form 22822 Q. By Mr. Karst Related to shotguns or rifles Q. Anything before 22822 before 2000 ? Probably A. 22822 A. 22822 Q. Probably AnyAtnhyitnhging from thethe 6060ss 25 A. Could be 51 12 A. Yes 12 Q. So I'm assuming this means that felt wads were 3 u_sed around the 1930s until '68 or '69 + A. That's right 5 Q. You do you have an independent recollection that 6 the felt wads were used until '68 or '69 7 MR MORTL Objection to form 8 THE WITNESS I don't know what you mean 9 Q. By Mr. Karst Is this your recollection or is 10 this a recollection from the documents that your 11 attorneys gave you - 12 A. '68 to '69 is my recollection and the early 13 stuff is from literature 14 Q. That your attorneys gave you 15 A. Not necessarily but yes in this case I read 16 catalogs too 12222 Q. What do you mean You said not necessarily from 12222 your attomeys so what other catalogs 12222 A. Remington catalogs gun magazines anything 12222 where you can learn stuff about how ammunition works 12222 and is made 12222 Q. What are those other magazines 12222 MR MORTL Objection to form 12222 THE WITNESS Guns and Ammo American 12222 Rifleman There's a lot of them I don't 53 1 Q. Prior to -- 2 A. I don't really know I don't remember 3 Q. So that's where I'm trying to understand the 4 basis of your knowledge which I still don't have 5 clear So the dates from around the 1930s you said 6 that's not your independent knowledge so that's 7 knowledge from who 8 A. Catalogs process records recollections from my 9 employment at Remington 10 Q. When you say that what does that mean 11 recollection from your employment at Remington 12 MORTL Objection to form 13 THE WITNESS I don't know how to answer 14 you You don't know what that means 15 Q. By Mr. Karst Well there's a lot of things it 16 could be mean I want to know what it means to you 17 A. It means things that I remember from the time 18 that was employed at Remington 19 Q. Documents that you read People you talked to 20 A. Documents process equipment all that kind of 21 stuff 22 Q. So let me ask you the felt wads you're saying 23 started around the 1930s Where is that specific 24 knowledge from 25 MORTL Objection to form Asked and Doby Professional Reporting Inc. 952-943-1587 14 Pages 50 to 53 Raymond A. Anderson Jr. 7/18/2018 54 56 1 answered 1 A. From a vendor 2 THE WITNESS I don't know I can't put my 2 Q. Were they made the sheets 3 finger on where all this stuff comes from 3 A. The sheets were made yes 4 Q. Mr. Karst The felt wads were made as your 5 attorney has written here 1968 or 1969. Where is that 4 Q. Do you know what vendor they came from 5 A. No. 6 specific information from 6 Q. Would they come from one vendor or multiple 7 A. Catalogs price lists 7 vendors 8 Q. Can you give me the specific catalog it is from 8 MORTL Objection to form Foundation 9 A. No. 10 Q. When you have the dates 1968 or 1969 are you 11 specifically looking at a catalog to get that from 12 A. In the case of that particular one I think we looking 13 probably were at a price list 14 Q. Was the price list from '68 or '69 9 THE WITNESS | don't know This was 10 before my experience in the production 11 department at Remington specifically 12 Q. By Mr. Karst I understand but you said your 13 knowledge was based on your experience while working at 14 Remington so that's why I'm asking you that You A. Yes 15 Q. Do you know in the documents that have where 17 been produced that Objection 18 MR MORTL Objection to form 15 first said it was based off of the documents that your 16 attorneys specifically showed you Then you said it 17 was based off of working at the plant 18 A. And I said it was based Mr. Karst Can you show me that document | 19 Q. Right So now I'm trying to understand what at 82282 Q. No.there 20 the plant is any basis for that information 82282 Is a reason that youyou can't show me that 82282 ? Argumentative document 22 MR MORTL Objection Askedanswered 82282 MR MORTL Objection Argumentative WITNESS 24 82282 THE I don't know where is came Q. By Mr. Karst You said it came in sheets A. huh 2 Q. Q. By Mr. Mr. Karst Is this a document that your 25 Q. What was the process They come in sheets 55 1 attorney gave you to review 2 A. It's one that -- yes It's one that she brought 3 with her It's publically available 4 Q. So without seeing that document you have no 5 independent knowledge that that's '68 or '69 or what 6 year that is 7 MORTL Objection Misstates 8 testimony 9 THE WITNESS I have a recollection from my 10 experience That was about the time it was I 11 couldn't be specific as to whether it was date 12 month year or what have you but in the late 13 60s 14 Q. By Mr. Karst So what's the recollection from 15 your experience Were they making ? Was a specific 16 machine making it and stopped making it What's your 17 recollection when you're at the plant 18 MR MORTL Objection to form 19 THE WITNESS My recollection is we stopped 222222 using it in the late 60s 222222 Q. By Mr. Karst How were felt wads made 222222 A. They're punched out of a sheet of material 222222 Q. What building 222222 A. I don't recall 222222 Q. Where did the sheet come from 57 1 What happens to them 2 MR MORTL Objection to form 3 THE WITNESS They're punched out on what's 4 known as a punch press 5 Q. By Mr. Karst One at time Multiple One 6 sheet at time 7 A. row of punches 8 Q. What happens after they're punched out 9 MR MORTL Objection to form 10 THE WITNESS They're collected in a bin 11 Q. By Mr. Karst And then where do they go 12 MR MORTL Objection to form 13 THE WITNESS To wherever they're needed 14 Q. By Mr. Karst Within building 3 series or 15 somewhere else I'm sorry 300 series 16 A. I don't recall specifically on the felt wads 17 but they were made in one of the 300 buildings and 18 they were used in one of the 300 buildings but not 19 necessarily the same one 20 Q. Was there a specific machine that would punch 21 these out 22 A. Yes 23 Q. What happened to that machine in the 1970s 24 MR MORTL Objection to form 25 If you know Doby Professional Reporting Inc. 952-943-1587 15 Pages 54 to 57 Raymond A. Anderson Jr. 7/18/2018 58 123 THE WITNESS It wasn't used for felt wads 123 anymore 123 Q. By Mr. Karst What was it used for 4 A. I don't know 5 Q. Was it used 6 A. I don't know that either 7 Q. Where was the machine located 8 A. In one of the 300 buildings 9 Q. Was there one machine or multiple machines 10 A. No. There were two or three of them 11 Q. Do you know who operated any of those machines 12 A. Do you mean personally who operated them Q. Yes 13 recall A. I don't 15 Q. Was diameter of the felt wad - | the already 16 guess you said the punch presses punched it out 17 A. huh something 18 Q. So they have to have something that they're Was scored punching out it already or anything A. No. It was just a sheet and it was placed over 222222 a punch and die tooling set 222222 Q. So nothing done to the sheet beforehand to score Q. anything 222222 it or anything where the punch had to punch 222222 A. No. 25 MR . MORTL: You just need to slow down a 60 1 A. That's correct 2 Q. Did anyone ever tell you the specific dates for 3 this line 4 A. Other than from the catalogs that we looked at 5 no 6 Q. Is any of this information from catalogs other 7 than what your attorney brought to show you 8 A. I don't know I don't remember when we were 9 compiling the list 10 Q. Next you have 1964 some target loads slash 11 power piston 12 A. huh 13 Q. What does that line mean 14 A. That means that some target loads had plastic 15 body shells and then the power piston was introduced 16 around that time 17 Q. So this is only relating to the outer shell of 18 the shell 19 MR MORTL Objection to form 20 Q. By Mr. Karst The outer body of the shell piston 21 A. The power piston is an internal component 22 Q. But you're talking about as it relates to 23 plastic plastic shells 24 A. Correct 25 Q. So you're saying that some target loads had a 59 12 little bit 2 THE WITNESS Okay 3 Q. By Mr. Karst Next you have on this plastic 4 body shells You have 1961 to 1963 some fieldloads 5 with plastic shells Did I read that correctly 6 A. Yes 7 Q. And again that's in your attorney's 8 handwriting and not yours 9 A. Correct 10 Q. Where did that information come from 11 A. I believe we identified those dates from 12 catalogs 13 Q. Do you know which specific catalogs they came 14 from 15 A. No. 16 Q. Is there any way you could point me right now to 17 those catalogs 18 MR MORTL Objection to form 19 THE WITNESS No. 20 Q. By Mr. Karst Do you have any independent 21 recollection of those dates without looking at the 22 catalogs 23 A. No not really I had a vague recollection of 24 the timing of a lot of these things 25 Q. This is before you even got to the plant 61 1 power piston internally on plastic shells 2 A. Correct 3 Q. Starting in 1964 4 A. Correct Yes 5 Q. Where is that information gleaned from 6 A. Probably from a catalog 7 Q. Do you know which catalog 8 A. No. 9 Q. Is this a catalog that you have independently 10 or this a catalog that your attorney brought to you 11 A. I believe it came with my attorney 12 Q. Without looking at a catalog do you have any 13 independent recollection of the date 1964 as it relates 14 to this 15 A. Only what I've heard from other people that were 16 there at the time since I wasn't 17 Q. What other people 18 A. Coworkers 19 Q. What coworkers 20 A. I don't remember 21 Q. Can you give me any coworkers 22 A. No. 23 Q. Were power pistons manufactured on site 24 A. Yes 25 Q. How were they made Doby Professional Reporting Inc. 952-943-1587 16 Pages 58 to 61 Raymond A. Anderson Jr. 7/18/2018 62 1 A. Injection molding 2 Q. How many injection molding machines were out 3 there that made power pistons 4 MR MORTL Form 5 THE WITNESS Specifically I can't tell 6 you but I would say eight is a good number 7 Q. By Mr. Karst Are these in the 300 series 8 buildings 9 A. Yes 10 Q. Are they located anywhere else besides the 300 11 series buildings 12 A. No. 13 Q. Did they ever add machines while you were there 14 to make these 15 A. Yes 16 Q. Do you know how many machines they added 17 A. don't recall They had other things made on 18 i_njection molding machines besides power pistons 19 Q. What else would be made on injection molding 20 machines besides power piston 21 MR MORTL Objection to form 22 THE WITNESS Different kinds of wads 2 Q. By Mr. Karst What type of wads injection molding machine injection 24 A. H wads are made on an injection molding molding machine injection 25 Q. The same injection molding machines that made 64 1 Q. Okay How long were H wads made 2 A. I don't recall 3 Q. Can you give me a decade 4 A. No. BecauseI don't know for sure 5 Q. Were they still being made when you left in '86 6 A. No. 7 Q. The H wads we're talking about just so the 8 record's clear 9 A. Correct 10 Q. Were power pistons still being made when you 11 left in '86 12 A. Yes 13 Q. 1966 last year paper shell bodies Again this 14 in your attorney's handwriting and not yours Where 15 did that specific date come from 16 A. Once again I believe it came from a catalog 17 Q. Do you know which specific catalog it came from A. point 18 Anything Anything thatthat ? Q. Anything that can point to Anything you me 20 a clue don't mean to be cutecute withwith is I 21 but you Without you 22 Q. Without looking looking atat thathatt catcataaloglog could could you give looking 23 me the date 1966 Would you know that independently? 24 A. I would know around that dateyesyes looking 25 Q. When youyou saysay looking loking at a catalogcatalog 1966 , last 63 1 the power pistons 2 A. Not necessarily 3 Q. That's what I'm asking I thought you said that 4 some injection molding machines that made power pistons 5 could also be used to make other things 6 A. They can You change the mold 7 Q. That's what I'm saying So on injection molding 8 machines power pistons were made H wads were made 9 correct 10 A. I think I recall it that way yes but it really 11 is -- well it's up to you to say whether it's 12 irrelevant or not but to me is 13 Q. It's all relevant What else is made on those 14 _ injection molding machines besides the power pistons 15 and the H wads 16 A. Nothing 17 MR MORTL Objection to form 18 Q. By Mr. Karst Sothere's nothing else that was 19 injected molded out at Remington in the 300 series 222222 _ buildings besides power pistons and H wads 222222 MR MORTL Objection to form 222222 THE WITNESS Ibelieve that's true yes 222222 Q. By Mr. Karst And when power pistons came into 222222 existence the H wads were phased out 222222 A. No. 65 year paper shell bodies what does that mean Does 2 that mean that in 1966 they no longer appeared in the 3 catalog Was does that mean 4 A. That means they were no longer manufactured 5 Q. And how would you know that looking at the 6 catalog 7 A. You wouldn't but you would know that was the 8 last year that they appeared in the catalog 9 Q. That's what I'm saying So 1966 last year 10 _ paper shell bodies were made that's an assumption 11 based off a catalog that you've looked at 12 A. Correct 13 MR MORTL Objection Form 14 Argumentative 15 Q. By Mr. Karst Do you have any independent 16 recollection that 1966 was the last year paper shell 17 bodies were made 18 A. Independent recollection No. I wasn't there 19 then 20 Q. On the next line you have here 1968 AA target 21 shell dash 1972 replaced by - is that RXP 22 A. RXP unibody 23 Q. RXP unibody all other target shells 24 parenthetical gauge and gauge close 25 __ parenthetical plastic basewad Did I read that Doby Professional Reporting Inc. 952-943-1587 17 Pages 62 to 65 Raymond A. Anderson Jr. 7/18/2018 66 1 correctly 2 A. You did 3 - Q. What does that mean 4 A. That means in 1968 the American target shell 5 came out That was a Remington trade name That was 6 characterized by a plastic body and a plastic basewad 7 and in 1972 the RXP unibody shell came out which 8 replaced the American target shell 9 Q. Were all target shells American shells in 10 1968 11 A. No. gauge only 12 Q. And how long was it just gauge only 356110222222 A. Forever 356110222222 Q. Were all gauges the American 356110222222 MR MORTL Objection Vague 356110222222 THE WITNESS Were all gauge target 356110222222 loads American 356110222222 Q. By Mr. Karst Yes The only type that you can 356110222222 buy or there other types 356110222222 MR MORTL Same objection 356110222222 THE WITNESS I don't recall 356110222222 Q. By Mr. Karst But the American target basewad 3561022 had Corect plastic 356110222222 Q. Did the American target shells ever have 68 1 A. I believe we looked at it in a catalog but it's 2 also my knowledge 3 Q. Do you know which catalog 4 A. No not specifically 5 Q. Were there multiple catalogs or one catalog 6 A. Do you mean in any given year 7 Q. To get this information 8 A. Multiple catalogs different years 9 Q. Again are these catalogs that your attorneys 10 gave you or catalogs that you had 11 A. They were ones that my attorneys brought 12 Q. Then you say in 1972 the American target 13 shell was replaced by the RXP unibody Is a separate other all 14 line target shells gauge and gauge 15 I'm tryintgo understand what these notes mean 16 A. All other target shells gauge and gauge 17 had plastic basewad That's what that means were 18 Q. That unibody plastic A. No. Unibody and plastic are 20 basewad You can't have a unibody and a plastic 21 basewiad ndependenttoo existed 2222 Remington what was on the market What existed Objection 24 MR MORTL to form 25 THE WITNESS I don't know what you mean 67 1 anything else besides a plastic basewad 2 A. No. 3 Q. And the American target shells starting in 4 1968 only came in gauge 5 A. Yes 6 Q. And they never -- don't want to put words in 7 your mouth 8 A. I'm sure you don't 9 Q. Did they ever come in any other gauge besides 10 12 the American shells 11 A. Not that I recall no 12 Q. How long were the American target shells 13 made 14 A. Well they were replaced the by RXP unibody 15 shell in 1972 so that's four years 16 Q. Okay So the only year the American target 17 shells were made with a plastic basewad was from '68 to 18 '72 in gauge only 19 A. I believe that's right 222222 Q. Where is that information from 222222 A. Right up here 222222 Q. That comes from you 222222 A. I was there then 222222 Q. So that information is not based of a catalog 25 That's based off of your knowledge 69 1 lot of things were on the market 2 Q. By Mr. Karst It says in 1972 the RXP unibody 3 replaced the American target shell 4 A. Correct 5 Q. The American target shell was only made in 6 gauge 7 A. Correct 8 Q. So the RXP unibody is that only gauge 9 A. Yes 10 Q. And long was the RXP unibody made 11 A. long time I can't give you a date I don't 12 know 13 Q. Was it still made when you left in '86 14 A. Yes 15 Q. Was it only gauge when you left in '86 16 A. I believe so yes 17 Q. Was there a basewad in the RXP unibody 18 A. No. 19 Q. Was there ever 20 A. No. 21 Q. All other target shell Does that mean the only 22 other target shells that Remington made were 12 and 23 gauge 24 A. Correct 25 Q. There's no other target shell -- Doby Professional Reporting Inc. 952-943-1587 18 Pages 66 to 69 Raymond A. Anderson Jr. 7/18/2018 70 1 A. No. I'm sorry It was made in 410 as well 2 Q. So target shells that Remington makes are 3 gauge gauge and 410 4 A. Correct 5 Q. Those are the only type of target shells 6 Remington makes 7 MR MORTL Objection to form 8 Q. By Mr. Karst Made Sorry 9 A. To the best of my recollection yes 10 Q. And the gauge did they have a basewad 11 A. Yes Objection 12 MR MORTL Objection to form 13 Q. 15 Q. Q. 17 By Mr. Karst Did the gauge have a basewad objection THE WITNESSSatmhee 410 a DDiidd ByBy Mr.Mr. KaKrasrtst the Objection havehave a bbaasseewwaadd MR MORTL Objection 18 THE WITNESS Yes Q. By Mr. Karst What was the gauge basewad shells for target A. Plastic made out of Q. What was the gauge target shell basewad made 222222 out of Plastic 222222 A. Plastic 222222 Q. And what was the 410 72 1 basewads 2 A. They're injection molded and then formed 3 when the shell is assembled 4 Q. What molding 5 A. I didn't say molding 6 Q. formed I'm sorry 7 A. formed The temperature of everything is 8 ambient temperature and you slide the basewad in -- 9 I'm going to make this sound simpler than it is but 10 you slide the basewad into the body which is a plastic 11 tube and then it's headed which is a punch and die 12 operation That does a couple things it deforms the 13 basewad so that it flows into the rim of shell along 14 with the bottom of the body of the shell to lock 15 everything together 16 Q. So at that point you have the metal the plastic 17 and basewad 18 A. Correct 19 Q. Are there multiple machines that make this 20 A. There were 21 Q. Are the 12 and gauge and 410 made on the same 22 machine or different machines depdeenpdeinndging on the the ? gauge 23 A. Different machines 24 Q. Q. CoCouulld d you makmakee aa 20gauge andand a 12 gauge 25 machine 71 1 A. Plastic 2 Q. How do you know that the gauge were plastic 3 basewads 4 A. Because I was around when they had the 5 development program I saw them 6 Q. Were you part of the development -- 7 A. I also used them No I was not part of the 8 development program 9 Q. Who was part of the development program 10 A. Other employees 11 Q. And who are they 12 A. I don't recall specifically but the main one is 13 deceased 14 Q. Who is that What was that 15 A. George Eckstein 16 Q. How do spell Eckstein 17 A. N 18 Q. How do you know -- why do you state that the 19 gauge target shell were only plastic basewads How 222222 do you know they were only that How do you know they 222222 were not something else or they didn't make multiple 222222 things 222222 A. Because I knew the product line That's all we 222222 made then 222222 Q. Can you describe the process of making plastic 73 1 A. No. 2 Q. You can't retool it to do that 3 A. No. I guess you could if you wanted to but we 4 didn't do it that way 5 Q. So machine that made gauge target shells 6 with plastic basewad could those machines be used to 7 make anything else 8 A. No. 9 Q. Could they be used to make gauge shells with 10 a different type of wad 11 MR MORTL Vague 12 Q. By Mr. Karst Or is this a specific process 13 for that machine 14 A. It could but we didn't 15 Q. So once the machine had its function that was 16 the function of that machine 17 A. Generally yes 18 Q. The next line you have 1968 gauge shells 19 standardized yellow What does that mean 20 A. That means that from 1968 Remington changed from 21 using a variety of colors for gauge shells to a 22 standardized yellow Every Remington shell that was 23 made in 1968 or later in gauge was yellow 24 Q. So the plastic component part 25 A. The plastic component was yellow correct Doby Professional Reporting Inc. 952-943-1587 19 Pages 70 to 73 Raymond A. Anderson Jr. 7/18/2018 74 1 Q. How about other gauges 2 A. No. They were not single colors They were the 3 classical colors for Remington which is green and 4 blue 5 Q. So on the gauge changed 6 A. Correct 7 Q. And is that for target or for field 8 A. All 9 Q. Regardless of what it's for if it's gauge in 10 1968 it's yellow 11 A. If it was made in 198 or earlier yes 12 Q. Did that color stay on until you left in '86 or 13 did it change again 14 A. No. It was still yellow '86 when I left As 15 far as I know it was still yellow 16 Q. Where is the information that 1968 is when this 17 occurred Where is that gleaned from 18 A. It might be in catalog but I also recall 19 that I recall that year That's when I came there 20 Q. To your recollection not looking at any sheets 22222 in front of you to your recollection did Remington 22222 make containing components in their shotgun 23 shells 22222 A. Yes 25 Q. And what would that component or components be 76 1 knew him at the time 2 Q. By Mr. Karst Do you remember any names of any 3 of the people the 18/19 years you were there who 4 operated that machine 5 A. I wasn't in production for 18 or 19 years but I 6 remember one Curt Simmons 7 Q. Is Mr. Simmons still alive 8 A. No. 9 Q. Can you describe the process of how that machine 10 is operated and how the wad is made 11 MR MORTL Objection to form 12 THE WITNESS There's a couple machines 13 that make the wad One is a mixing machine with 14 the various components of the mix 15 Q. By Mr. Karst What are the various components 16 of the mix 17 A. In addition to the asbestos there's wood flour 18 wax and asbestos 19 Q. Is there a certain percentage of each or does 20 that vary 21 A. There is a certain percentage of each and I 22 don't recall whether it varies according to the gauge 23 of the basewad being made I don't think it did but 24 it was close 25 Q. So those raw components are poured into a mixer 75 1 A. molded basewad 2 Q. And what is a molded basewad that contains 3 asbestos 4 A. It forms the base of a shotshell and it's used 5 just like a plastic basewad except it's made up of 6 other components It's molded in a different process 7 Q. What type of molding is this 8 A. It's compression molding not heated compression 9 molding just ambient temperature other than the 10 temperature that's generated by the process 11 Q. And that molded onsite in Bridgeport 12 A. Yes it was 13 Q. And how many machines did this type of molding 14 MR MORTL Objection to form 15 THE WITNESS Primarily one I think we 67222222 had a spare but it was primarily one machine 67222222 operation 67222222 Q. By Mr. Karst Could it make the asbestos wad 67222222 for multiple gauges of shells 67222222 A. Do you mean the molded basewad 67222222 Q. Yes 67222222 A. Yes 67222222 Q. Do you know who operated that machine 67222222 MR MORTL Objection to form 25 THE WITNESS I don't recall but yeah I 77 1 -- hopper 2 A. They're poured into a mixer to start with and 3 they're blended There was a certain order that they 4 went into which I believe was the wood flour and then 5 the wax -- no The wood flour the asbestos powder and 6 then the wax Then they went from that mixing machine 7 to forming machine 8 Q. Who operated that mixing machine at any time 9 during your 18/19 years there 10 A. Mr. Simmons did 11 Q. Anybody else 12 A. There was another guy but I don't recall his 13 name He wasn't there very long after I was there 14 Q. After the mixing machine what's the next step 15 A. A forming machine which is a machine called a 16 Colton machine That's the company that makes the 17 machine 18 Q. O 22222 A. Yes It's basically a making machine 22222 rotary dial The material comes down and fills the 22222 cavity The platens rotate The punches come down and 22222 _ compress the mixture that's in each cavity real hard 22222 It generates around 15,000 PSI that process The dial 24 continues around and the parts are ejected into a bin 25 That's it It's a simple process Doby Professional Reporting Inc. 952-943-1587 20 Pages 74 to 77 Raymond A. Anderson Jr. 7/18/2018 78 1 Q. So if you're looking in the bin you literally 2 just have -- 3 A. -- hollow cylinder 4 Q. That's it 5 A. Yes 6 Q. So it kind of looks like a small doughnut or is 7 it solid 8 A. Well the proportions a are little different 9 but yes 10 Q. Does it have a hole in the center 11 A. Yes it has a hole in the center 12 Q. So is that part of the mold itself giving it 13 that -- 14 A. There's a punch The punch gives it the hole in 15 the center and the die gives it the outside diameter 16 and the length 17 Q. If punches that means there's excess material 19 A. Generally no It's all compressed It's 20 weighed pretty accurately and dumped into each cavity 21 There were a lot of cavities on the dial I forget how 22 many 28 30 something like that 2 Q. So now you've got all these wads in a bin What 2 happens to them 2 A. They get transported to the making 80 1 send them off loaded 2 A. Yes 3 Q. Does that go to a different machine that does 4 that 5 A. Yes 6 Q. Okay Just keep walking me through the process 7 Now you have a primed shell Where do we go next 8 A. You go to the loading operation next 9 Q. Okay 10 A. The powder and the wads which could be variable 11 depending on the load and the crimp is made That's 12 final -- that's it That's the final operation 13 Q. And packaged up 14 A. Correct 15 Q. Remington sells the component parts 16 A. Some ofthem 17 Q. What component parts does Remington sell of the 18 shotgun shells that you just described 222 MR MORTL Objection to form 222 THE WITNESS Do you mean during this time 222 period that we're talking about or today 22 Q. By Mr. Karst Back then back in the 60s 70s 22 A. The power pistons were sold as components The 2 primers were sold as components The H wads I 2 _ believe were sold as components The cardboard wads 79 1 operation and that's where the shells are assembled 2 Q. Can you describe that process 3 A. The making process 4 Q. Yes With these asbestos wads 5 A. It's also done on a rotary press type operation 6 with multiple tools what's called an assemble head and 7 prime operation because it assembled the shell headed 8 the shell which means it rammed it so its head would 9 be formed to its final dimensions the basewad was 10 formed to its final dimensions and the body was formed 11 to its final dimensions 12 Q. When you're talking the head what are you 13 referring to 14 A. Steel cap or brass cap depending on the shell 15 Q. So when that's conformed there's three parts 16 the metal head plastic body and the asbestos basewad 17 A. And the last step is the primer simple primer 18 Q. But after those three areas then the primer 222 goes in fourth 20 A. Correct But in the same machine It's done in 222 the same machine 22 Q. Once that is done what happens to that shell 22 A. That's now a primed shell and ready to be 24 loaded 2 Q. And do they load the shells at Remington and 81 1 were sold as components although their use was on the 2 wane at this time The felt wads were also sold as 3 components 4 Q. Then the shot and the powder 5 A. Then the shot and the powder right 6 Q. Did you say the primer 7 A. Yes 8 Q. Were the basewads ever sold independently 9 A. No. 10 Q. Why 11 A. Because the end user would not have the 12 wherewithal to use them 13 Q. What do you mean by that 14 A. You need the machine to put it together You 15 need the prime machine or else the basewad is useless 16 Q. Could the basewad be used as the cartridge wad 17 A. The cartridge wad 18 Q. The wad that you talked about before that you 19 described as felt or cardboard could the basewad be 22222 used as that wad 22222 A. No. 22222 Q. Why 22222 A. Too big It's not dimensionally appropriate 22222 Q. The circumference The thickness What do you 2 mean Doby Professional Reporting Inc. 952-943-1587 21 Pages 78 to 81 Raymond A. Anderson Jr. 7/18/2018 82 1 A. The thickness for sure The inside diameter for 2 sure The outside diameter is questionable It's just 3 not dimensionally compatible 4 Q. Have you ever repacked a shotgun shell before 5 A. Repacked 6 Q. Reloaded I'm sorry 7 A. Yes Do you mean personally 8 Q. Yes 9 A. Yes I have 10 Q. When you would do that do you have a machine at 11 your house a reloading machine 12 A. No. I did at Remington actually but I have 13 operated the machines that you're probably talking 14 about did 15 Q. When you say you did it at Remington what do you mean 16 A. We had a loading experimental room for experimental -- | was loading 18 in & at the time and depending upon the project you're to load working on you might need doing that ammunition so had plenty plenty of experience that am unition Was doing 22222 Q. Was for & purposes or for personal this 22222 A. the time no It was & It was 23 business It wasn't personal 22222 Q. Q. OuOtustisdiede ofof worwokrk havehave you relroelaodaedded shsehellllss 25 A. Yes . 84 1 the press You put a powder tube usually fed in a 2 plastic tube There's a primer -- I'm not giving you 3 these in orde-r- and there's a wad like a power 4 piston or depending what you're reloading it might be 5 a cardboard wad a or felt wad although that's rare 6 these days You don't see that anymore You put them 7 in sequentially and the last operation is the crimp 8 and you're done 9 Q. Now the primer goes in from the backside where 10 the metal 11 A. The bottom 12 Q. Everything else is fed through the plastic end 13 A. Correct 14 Q. So seems like most things in the shell either 15 _are ejected from -- when you shoot it -- is ejected 16 from the shell itself when you shoot it or needs to be 17 replaced like the primer correct 18 A. The primer does 19 Q. Needs to be replaced each time 22222 A. The only thing that doesn't -- depending on the 22222 shell you've got -- if it's a unibody that's correct stops 22222 that's where it stops If it's not a unibodyththee is 22222 basewad is still in there and doesn't move 22222 Q. Why is the basewad not replaced 25 A. It doesn't need to be replaced 83 123 Q. For your own personal use 123 A. Yes 123 Q. Target Hunting 4 A. Just target 5 Q. In reloading shells based on your experience 6 is there any big difference between reloading a target 7 shell versus a field shells 8 MR MORTL Objection to form 9 THE WITNESS Not really no 10 Q. By Mr. Karst Before the power pistons were 11 used did you -- strike that 12 Have you reloaded shotgun shells without using 13 the power piston 14 A. Yes 15 Q. Can you describe the process of reloading 16 A. The process of reloading 17 Q. I'm sorry Yes Without the power piston 18 A. Well it's the same with it or without it It's 19 just another component You put shell -- if you're 20 using a press there's a small rotary press that's 21 almost universal in most places It's made by MEC 22 Q. M 23 A. M 24 Q. Do you know what that stands for 25 A. No. Reloading You put shell in one spot in 85 1 Q. Why 2 A. It's not damaged still works holds the shell 3 together 4 Q. Why do you state that it's not damaged the 5 basewad 6 A. Just experience 7 Q. Experience doing what 8 A. Shooting testing at Remington all that kind of 9 stuff Basewads were tough You're talking about the 10 molded basewad 11 Q. Correct 12 A. Yes Very tough 13 Q. How many uses could you get 14 MR MORTL Objection to form 15 THE WITNESS It's not the weak part of the 16 shell if that's what you mean The worst 17 thing when the molded basewad was in use 18 was the crimp of the shell That was the weak 19 spot You might fire a reloaded shell and shoot 20 the crimp right off of it which is part of the 21 body 22 Q. By Mr. Karst Part of the plastic 23 A. Correct 24 Q. But if that didn't fail or wear out could you 25 _ continue to reload the same shell Doby Professional Reporting Inc. 952-943-1587 22 Pages 82 to 85 Raymond A. Anderson Jr. 7/18/2018 86 123 A. Yes 123 MR KARST We've gone almost another hour 123 Why don't we take a break 4 VIDEOGRAPHER The time is 12:10 p.m. We 5 are going off the record 6 7 ***** 8 9 VIDEOGRAPHER The time is 1:15 p.m. This 10 is tape two of the deposition of Ray Anderson 11 We're back on record 12 Q. By Mr. Karst Ready to continue 13 A. Yes 14 Q. Mr. Anderson while we were at lunch did you 15 review any documents 16 A. No. 17 Q. Did you speak to anybody outside of your 18 attorneys over lunch period 19 A. No. 20 Q. Did you review any of the documents that you 2222 have in your folder in front of you over lunch 2222 A. No. 23 Q. The sheet that your attorney wrote for you that 24 we've marked as Exhibit 1 have some other questions 25 on that We were going over that on the break You 88 1 MR MORTL Vague 2 Q. By Mr. Karst How long was your meeting 3 A. It didn't take very long to come up with that 4 I don't remember 5 Q. Can you give me an estimate 6 A. How long was the meeting 7 Q. Yes 8 A. I don't know Three or four hours 9 Q. Who was there for that meeting 10 A. Two attorneys 11 Q. The two attorneys that are here 12 A. huh 13 Q. Yes 14 A. Yes 15 Q. Did the attorneys bring all of these documents 16 with them 17 A. Yes OrI had them already They were mailed 18 Q. Which one is ? 19 A. Catalogs Some were some were the other 20 Q. How many documents did they bring with them 21 A. I don't know 22 Q. How did they bring them Were they in a stack 222 a box 222 A. I think they brought papers They shipped me 25 some documents 87 123 said you put this together a couple months ago is that 123 right 123 MR MORTL Misstates testimony 4 Q. By Mr. Karst When did you put it together 5 sir 6 MR MORTL This sheet 7 Q. By Mr. Karst I'm sorry When did your 8 attorney write this for you 9 A. Yesterday day before yesterday 10 Q. Was this document created when you were looking 11 at catalogs and so forth at your home 12 A. Yes 13 Q. So now you're telling me that you were looking 14 at catalogs yesterday 15 MR MORTL Objection 16 THE WITNESS We had some catalogs 17 yesterday I wasn't studying them no 18 Q. By Mr. Karst But you said this list was 19 created yesterday 22222 A. Yes 22222 Q. At your home 22222 A. Correct 22222 Q. From looking at catalogs and documents 22222 A. huh And from discussing 25 Q. How long did that take 89 1 Q. How many documents did they ship you 2 A. I don't know I didn't count them 3 Q. Hundreds of pages Thousands 4 A. At least hundreds 5 Q. Did it come in a box 6 A. Yes 7 Q. Did they come in a bankers box 8 A. What's a bankers box 9 Q. Your standard normal bankers box 10 A. Yes 11 Q. Was that box full 12 A. One was partially full and the other one was 13 close to full yes Actually one was a lot thinner 14 than bankers box 15 Q. You're making some indications with your hands 16 H_ow tall was that stack of documents 17 A. One was 4 inches high and about the size outside 18 of bankers box I guess and the other one was a 19 bankers box and it was pretty close to full 20 Q. So were documents in the bankers box 22322 horizontally and full that way 22322 A. Yes 22322 Q. And you said the other one was 4 inches high 24 A. Yes They were in manilla folders that were 25 just put in there for shipping I would say there were Doby Professional Reporting Inc. 952-943-1587 23 Pages 86 to 89 Raymond A. Anderson Jr. 7/18/2018 90 1 4 folders in there 2 Q. Okay So one box was full and the other one 3 had about 4 inches of documents 4 A. Yes 5 Q. When were they shipped to you 6 A. I don't remember 7 Q. Could you give me an estimate of when they were 8 shipped to you 9 A. I would say the last one came a few weeks ago 10 Q. So multiple shipments 11 A. The first one I had gotten earlier than that 12 Q. How much earlier 13 A. I don't know 14 Q. Can you give me an estimate of how much time 15 A. No. 16 Q. Are we talking last year -- last month 17 A. Not last year no 18 Q. A couple months ago 19 A. A couple months ago 222222 Q. And so which one came first the box that was 222222 full or the box that had only a couple inches of 222222 documents 222222 A. The box that was just a couple inches of 222222 documents 25 Q. That's the one that came first 92 1 through them with your attorneys yesterday or did you 2 go through them with your attorneys prior to that 3 A. No. Yesterday was the first time that we went 4 through them 5 Q. What documents did you go through yesterday with 6 your attorneys in that three meeting 7 A. We looked at the catalogs and price lists 8 Q. Were there specific ones that you looked at 9 A. Some of the ones with the dates that we have on 10 this list 11 Q. Why those specific ones 12 A. We were looking for which particular loads were 13 made at which particular time that sort of thing 14 refreshing my memory 15 Q. Why 16 A. Because I couldn't remember all this stuff 17 Q. Why would you be looking for this specific 18 information that's on this list that your attorney 19 wrote 20 A. Because that's kind of what this is all about 21 isn't it 22 Q. Some is and some of it's not That's why I'm 23 trying to understand why 24 MR MORTL Argumentative 25 Q. By Mr. Karst I'm trying to understand why 91 1 A. Yes 2 Q. What were those couple inches of documents 3 A. I don't remember specifically They were file 4 folders with -- there were some process records from 5 Remington I don't remember I don't remember I 6 read those awhile back I didn't read them recently 7 Q. Then a couple weeks ago you received the full 8 bankers box 9 A. Yes 10 Q. And what documents were in there 11 A. Catalogs price lists I think there were some 12 process records in there as well That's really all | 13 remember I didn't read them all I looked at the 14 outside folder and rifled through most of them 15 Q. So you didn't actually read all of them 16 A. I didn't commit them to memory that's for sure 17 Q. Did you read all the pages of the documents 18 A. No. 19 Q. Are those the only two shipment of documents 20 that you received from your attomeys 21 A. Yes sir 2222 Q. Have you received documents from any other 2222 source besides those two shipments from your attomeys 2222 A. No. 25 Q. Is the first time that you physically went 93 1 some this is written on here For example when 2 field loads were switched to plastic -- 3 A. I can tell you why they're written on here 4 They're written on here because -- 5 MR MORTL Let him ask you a question 6 THE WITNESS Go ahead 7 Q. By Mr. Karst Why are they written on there 8 A. Because there's too many to remember when you're 9 73 years old that's why 10 Q. But why this specific information Why not 11 other information Why is this specific information 12 here 13 A. Well this is kind of what we're talking about 14 Q. I've never asked anything about paper shell 15 A. I wasn't talking about you 16 Q. I understand but why is this to you relevant 17 when last year they made paper shell bodies 18 A. Because I didn't remember when that was off the 19 top of my head 20 Q. Why is that relevant to this case 21 A. Because it's a different kind of shotshell 2222 _ construction 2222 Q. Why is that relevant to the asbestos case Is 24 there a reason 25 MR MORTL Argumentative Doby Professional Reporting Inc. 952-943-1587 24 Pages 90 to 93 Raymond A. Anderson Jr. 7/18/2018 94 1 If you know 2 THE WITNESS What's your question 3 - Q. Mr. Karst Why is the last year paper shell 4 bodie-s- you listed here 1966 last year paper shell 5 bodies Why is that relevant in an asbestos 6 case 7 A. Because it shows you when a shotshell that had 8 different sort of casualty considerations -- 9 Q. What does that mean 10 A. -- went out of production That means a paper 11 shell you shoot the crimp off if you try to reload it 12 Q. Why is that relevant in an asbestos 13 case 14 A. Because I know you're going to start talking 15 about a molded basewad 16 Q. And how is that relevant to the molded 17 basewad when paper shells were last used 18 MR MORTL If you know 19 THE WITNESS Because you're going to start 222222 talking about -- I'm anticipating that you will 222222 start talking about reloading again and paper 222222 shells were not very reloadable 222222 Q. By Mr. Karst Have you ever read my client's 222222 testimony 25 A. No. 96 1 itself of my client 2 A. No. 3 Q. Do you know anything about what my client Mr. 4 Benson testified to his use of shotgun shells 5 A. Only what came up in discussion 6 MR MORTL And you're not going to get 7 into -- 8 Q. By Mr. Karst Any in a written form 9 A. No. 10 Q. In an email 11 A. No. 12 Q. So you're looking at one full bankers box of 13 documents A bankers box of documents arguably is 14 roughly 5,000 pages of documents and you're looking at 15 inches of other documents in another box and you 16 spent three or four hours going through the documents 17 yesterday How did you choose which information was 18 put on this sheet or did your attorney choose for you 19 MR MORTL Objection to form 20 THE WITNESS When I was doing it by myself prior to my meeting with the attorneys I just 22 read it in a particular order looking at the 23 titles on the folders that they had 24 Q. By Mr. Karst Right But you didn't make the 25 list until -- 95 123 Q. His deposition 123 A. No. 123 Q. Have you ever read a summary of his testimony 4 A. Of your client This client 5 Q. Mr. Benson yes 6 A. No. 7 Q. Your attorneys haven't given you any type of 8 summary of this case that you've read 9 A. No. 10 MR MORTL Objection Argumentative 11 You're also starting to get into 12 attorney 13 MR KARST it's a document that he 14 reviewed then I get to ask that 15 MR MORTL Let's slow it down if you're 16 going to go down this route Is there a 17 question pending 18 Q. By Mr. Karst Did your attorneys ever put 19 together any type of summary shorthand any type of 20 ~ d_ocument related to my client's testimony in this case 22222 that you've read 22222 MR MORTL You can answer that yes or no 23 Have you read a summary of the testimony 24 THE WITNESS No. Of the testimony no 22222 Q. By Mr. Karst Have you ever read the testimony 97 1 A. Well this list is not based on all of that 2 material This is based on a very small amount of 3 material 4 Q. Right And know your attorney put that 5 together 6 A. Yes With some help from me I wasn't just 7 sitting there looking at her 8 Q. Right But why would you say oh hey here's 9 document X we should put that on the piece of paper 10 MR MORTL Objection Asked and answered 11 Harassing 12 THE WITNESS I wouldn't have said that 13 Q. By Mr. Karst How did those specific items get 14 chosen to put on the list by your attorney 15 MR MORTL Same objection Go ahead 16 THE WITNESS It just kind of followed the 17 conversation that we were having and some things 18 that I told the attorneys that I probably 19 wouldn't remember unless I wrote them down 20 Q. By Mr. Karst Well you said this stuff was 21 based off documents not from conversations with your 22 attomey 23 A. That's right It's based on the catalogs and 24 price lists And you are being argumentative I agree 25 with my attorney Doby Professional Reporting Inc. 952-943-1587 25 Pages 94 to 97 Raymond A. Anderson Jr. 7/18/2018 98 1 MR MORTL That's okay We can take a 2 break if you need to Let's slow down 3 MR von OISTE Let's take five minutes 4 MR KARST Sure 5 VIDEOGRAPHER The time is 1:28 p.m. We 6 are going off the record , 8 ***** 9 10 VIDEOGRAPHER The time is 1:32 p.m. We 11 are back on record 12 Q. By Mr. Karst A couple other questions on the 13 topic that we were just on The boxes that were mailed 14 to you do you still have those at your house Are 15 they still in your possession 16 A. Yes I think they are 18022222 MR MORTL You can go with what you 18022222 remember 18022222 THE WITNESS Yes 18022222 Q. By Mr. Karst So your recollection is that the 18022222 full box and the partial box are still in your 18022222 _ possession at your home 18022222 A. You know I had another thought when we were 18022222 out of the room The big big box box belobngeedlonged toto mmyy aatttornety orney 18022222 She sent it because she was coming for a meeting The 100 1 Q. And what is that information based off of 2 A. Some of it is from catalogs and price lists and 3 some of it's from my memory 4 Q. So you're tell me that the catalogs and price 5 lists specifically list containing molded 6 basewads in 1961 7 A. No it doesn't it It says molded basewads 8 Q. So how would you know when they first made an 9 containing molded basewad 10 A. Because I knew what the composition of the 11 material was 12 Q. How do you know the composition of the material 13 A. Because I worked at Remington You 14 Q. weren't working there '61 That's why 15 I'm trying to understand the basis of your knowledge 16 A. That's true I knew when I got there yes stilling making 17 They were them then 18 Q. So what specifically tells you that they started 19 making them in '61 A. advent basewad of dry Thasbeestos the molded asbestos containing make a molded basewad it'sit's 2 always containing 23 A. Yes its 2 Q. Regardless of its use 2 A. huh . 99 123 smaller one was mine and it was copies of some of the 123 stuff that was in the big one 123 MR KARST Objection to the nonresponsive + portion of the question There was no question 5 pending 6 Q. By Mr. Karst But both them are still in 7 your possession to your recollection 8 A. Yes We packed them up but we didn't send them 9 out 10 Q. Was everything in the boxes copies or were some 11 of them the actual catalogs themselves in 19 whatever 12 A. Some were catalogs Some were catalogs 13 Q. When did Remington first make an 14 containing wad 15 A. the early 60s 16 Q. I noticed you're looking down atyour sheet 17 A. Yes I am I noticed there's lot of other 18 things on it too 19 Q. Where are you looking on your sheet here 20 A. I'm looking at 1961 22222 Q. What specifically about what's on your sheet 22222 _ answers that question 22222 A. It's under the section about the molded 24 b_asewad and that tells me that Remington started 25 making molded basewad in 1961 or thereabout 101 1 Q. Is that a yes 2 A. Yes 3 Q. Is there any document that you can point me to 4 that shows hey this is the exact year they started 5 making mold basewads 6 A. I don't know I would suggest you might look at 7 ~~ a 1961 catalog 8 Q. To your recollection -- did you look at a 1961 9 catalog 10 A. Yes I did 11 Q. To your recollection what would that 1961 12 catalog tell me 13 A. SpecificallyI can't tell you but generallyI 14 would say you'd probably be looking at a section 15 of shell 16 Q. And it would say mold basewad 17 A. No. It would show you a basewad that I happened 18 to know is molded because that's the only way they 19 made them at that time 22222 Q. And you're telling me if I looked at a 1960 22222 catalog that would not be there Are you telling me 22222 that 22222 A. Maybe I don't really know 22222 Q. That's why I'm trying to understand why you say 25 '61 Doby Professional Reporting Inc. 952-943-1587 26 Pages 98 to 101 Raymond A. Anderson Jr. 7/18/2018 102 1 A. The molded basewad is noticeably different 2 from what preceded it which was a wound basewad 3 Q. Describe the difference Visually if you're 4 looking at them what's the difference 5 A. Color 6 Q. What's the color difference 7 A. The paper was sort of white looking 8 and molded basewad is sort of tannish looking 9 Q. the paper crumpled Is it stacked 10 A. No. It's wound 11 Q. How the paper wound 12 A. Around a mandril 13 Q. its density different between paper and 14 asbestos 15 MR MORTL Objection to form 16 THE WITNESS I don't really know 17 Q. By Mr. Karst I'm looking in a catalog 18 looking at a basewad what I am looking at in the 19 catalog that will tell me hey that's a mold 20 basewad or hey that's a paper basewad 22222 A. I don't know that they ever differentiated in a 22222 catalog what the basewad was made out of 22222 Q. Then how can you look at the catalog and say 22222 that's -- 22222 A. Because I know they were different colors and 104 1 need to tell you that 2 MR MORTL Sure You can tell him who you 3 recall who worked there in '61 or when you got 4 there in '68 5 Q. By Mr. Karst My question was back in the 6 early 60s 7 A. Spencer Wildman is one He was an & engineer 8 like I was 9 Q. Wildman 10 A. Wildman yes Ed Yacko was one 11 Q. How do you spell Yacko 12 A. A He's deceased Ben Daubenspeck 13 A He's also deceased Most of 14 the names that I would give you are deceased 15 Q. And who are they 16 A. Do still want them 17 Q. First give me the living people and then we'll 18 go with the deceased 19 A. Off the top of my head I don't know of any 222222 living people 222222 Q. Is Mr. Wildman still alive 222222 A. Yes 222222 Q. Where does he live 222222 A. Kentucky 222222 Q. Do you know where in Kentucky 103 123 know what the dimensions were roughly 123 Q. So were these catalogs colored that you're 123 looking at 4 A. Yes some of them were 5 Q. '61 is the year you chose 6 A. huh 7 Q. So the '61 catalog in color 8 A. I don't remember 9 Q. So '61 based on an approximation or is it 10 actually based on a fact that it's '61 11 A. I don't really know that either Once again I 12 wasn't there 13 Q. Who would know the answetro that question as to 14 when Remington started using an containing 15 mold basewad 16 MR MORTL Objection to form 17 THE WITNESS Somebody that was there and 18 that knew something about the process could 19 probably tell you that 222222 Q. By Mr. Karst Can you tell me anybody who was 222222 there 222222 A. I could tell you a lot of people who were there 222222 but I don't know where they are 222222 Q. What are of some their names 222222 A. I don't know I want to tell you that Do 105 1 A. No. 2 Q. When was the last time you had contact with Mr. 3 Wildman 4 A. Probably at work at Remington '86 5 Q. And how do you know Mr. Wildman is still alive 6 A. I don't 7 Q. You're just making the assumption You haven't 8 heard he passed 9 A. I haven't talked to him since then butI 10 haven't heard he passed 11 Q. But Mr. Yacko and Mr. Daubenspeck - 12 A. Mr. Yacko and Mr. Daubenspeck I went to their 13 funerals 14 Q. Who else worked there back in the early 60s 15 who's deceased now 16 A. That come to mind right now I can't think of 17 anybody right now Jack Scanlon A 18 Q. Is Mr. Scanlon living or deceased 19 A. He's deceased Bill Decker K 20 deceased That's all I can think of off the top of my 21 head 22 Q. Did any of these individuals pass away from 23 cancer 24 MR MORTL Objection to form 25 THE WITNESS Not that I know of Doby Professional Reporting Inc. 952-943-1587 27 Pages 102 to 105 Raymond A. Anderson Jr. 7/18/2018 106 1 Q. By Mr. Karst Do you know anybody who's worked 2 at Remington who's passed away from a related 3 disease cancer or any type of related disease 4 MR MORTL Objection to form 5 THE WITNESS No. 6 Q. By Mr. Karst How long were 7 containing basewads made Until what year 8 A. I believe 1971. That's one of the dates on 9 here '81 I'm sorry '61 to '81 20 years 10 Q. And you're again referring to the sheet that 11 your attorney wrote 12 A. Correct 13 Q. And where does the 1981 year come from 14 A. That was the last year I believe of the 15 molded basewad 16 Q. And how do you know that 17 A. Memory 18 Q. So that date comes from your personal memory 19 not a catalog 20 A. I believe so yes It might have come from 22222 catalog as well 22222 Q. During the time when mold basewads contained 22222 asbestos were basewads made out of any other material 22222 besides asbestos 25 A. Plastic 108 1 containing outside of the AA target shells 2 from '68 to '72 which were replaced by the RXP unibody 3 MR MORTL Vague Form 4 THE WITNESS Could you do that again 5 Q. By Mr. Karst I'm trying to understand 6 There's containing basewad and you said there 7 were some things that are made during this time frame 8 '61 to '81 that do not have the containing 9 basewad 10 A. Plastic 11 Q. And there's plastic 12 A. No. That was plastic The ones that were not 13 containing that was plastic 14 Q. So where would those plastic ones specifically 15 be used What shells would they be on 16 A. American 17 Q. Okay 18 A. gauge target I think some gauge field 19 loads 20 Q. What's the basis for your information on the 21 gauge field loads 22 A. My memory or lack thereof 222 Q. And what's that memory based off of 222 A. Experience I worked for a company that made 25 shotshells among other things 107 1 Q. And that's what we discussed earlier 2 A. huh 3 Q. Correct 4 A. Correct 5 Q. And outside of those specific instances that we 6 spoke of earlier all of the other basewads would be 7 containing 8 MR MORTL Objection to form Vague 9 THE WITNESS Earlier than 1961 or 10 thereabouts Is that what you're talking about 11 Q. By Mr. Karst We spoke of the plastic basewads 12 for the AA target shell and then replaced by the RXP 13 unibody correct 14 A. Correct 15 Q. And those were the plastic basewads 16 A. The unibody was not a basewad not a separate 17 basewad It was integral with the shell 18 Q. Besides those two instances are there any other 19 instances where there would be a basewad that was not 20 containing 22222 A. Yes 22222 Q. What would that be 22222 A. Paper before that for years 22222 Q. During the time frame -- I'll use your years of 25 '61 to '81 -- are there any other basewad besides 109 1 Q. Would you see a document that said that 2 A. No I don't think so 3 Q. Were you working in & and experimenting on any 4 of these 5 A. No. I was working in production at that time 6 Q. So can you tell me for a fact that any of the 7 field loads that were gauge had the plastic basewad 8 A. Yes 9 Q. What's that fact based off of 10 MR MORTL Asked and answered 11 Q. By Mr. Karst Can you point me to any 12 document 13 A. No. 14 Q. Was it a specific type of gauge field load 15 MR MORTL Objection 16 THE WITNESS I don't recall 17 Q. By Mr. Karst What do you recall about it 18 A. That's kind of broad isn't it No I don't 19 recall anything else about it 20 Q. So how could I look at a gauge field load 21 that is plastic basewad and a gauge field load 22 that's an asbestos basewad and know the difference 222 How do you tell the difference 222 A. One is a target load and one's a field load 25 Q. But I thought you said of some the field loads Doby Professional Reporting Inc. 952-943-1587 28 Pages 106 to 109 Raymond A. Anderson Jr. 7/18/2018 110 1 that are gauge had the plastic basewad 2 A. I think one or two of them did yes but I don't 3 recall which ones and you can't tell from the outside 4 of the shell You would have to tear it down 5 Q. What would be the purpose of having a couple 6 oddball ones versus everything else that has the 7 asbestos basewad 8 MR MORTL Objection to form 9 THE WITNESS I don't know I didn't 10 design them 11 Q. By Mr. Karst Who did 12 MR MORTL Objection Overbroad 13 THE WITNESS I don't know 14 Q. By Mr. Karst Who would have worked on those 15 oddballs 16 A. Other engineers or production employees 17 MR MORTL Objection 18 Q. By Mr. Karst What years were they made those 19 ~~ gauge field shells 22222 A. Let me look at my list again here I would say 22222 late 60s but I'm not sure about that 22222 Q. What are you basing that on 23 A. Because that's when the change to the yellow 22222 shell across the line was put in place and I believe 25 at least one of those had a plastic basewad 112 1 right 2 A. Sorry 3 Q. So therefore that's the only instance of a 4 gauge field shell that had a plastic basewad which 5 one of them that was yellow 6 MR MORTL Objection to form 7 THE WITNESS That's my belief yes 8 Q. By Mr. Karst Therefore by that standard 9 everything that was green that had a basewad would be 10 containing prior to that 11 MR MORTL Objection to form Misstates 12 testimony 13 THE WITNESS I don't know I couldn't 14 answer that accurately 15 Q. By Mr. Karst What am I misstating here What 16 am I missing 17 MR MORTL Objection Argumentative 18 Q. By Mr. Karst I'm trying to understand 19 You've given me the shells that did not contain 20 asbestos and had a plastic basewad so the AA target 21 shells '68 to '72 You said the RXP unibody from '72 22 on correct 322 A. Correct 322 Q. And you also said target shell that were 322 gauge and gauge correct 111 123 Q. You believe one of the gauge -- 123 A. One of the specifications of the gauge 123 Q. Let me get my whole question out so we're both 4 on the same page 5 Are you saying after 1968 one of the gauge 6 field shells that was yellow had a plastic basewad 7 versus an asbestos basewad 8 A. I believe that's right 9 Q. So therefore any that were green would be 10 containing 11 MR MORTL Objection Misstates 12 testimony Form 13 Q. By Mr. Karst That are gauge-- 14 A. don't know Yellow didn't happen all of 15 sudden It was kind of phased in 16 Q. understand But you just told me that the 17 ~~ gauge field shell - 18 A. A gauge field shell 19 Q. A gauge field shell that had a plastic 20 _basewad versus an asbestos one and that was when there 21 ___ was yellow plastic versus green correct 2222 A. huh 2222 Q. Is that correct 24 A. Yes 25 Q. you say huh it doesn't come on the record 113 1 A. huh Yes 2 Q. And then you also said one gauge field shell 3 after they switched to yellow 4 A. I believe that's right Okay Next question 5 Q. Are there any others or is that it 6 A. That's it to my knowledge 7 Q. If had a gauge field shell that was a 8 plastic basewad versus an asbestos one what would be 9 the difference 10 MR MORTL Objection Vague Form 11 THE WITNESS Just the basewad would be 12 different 13 Q. By Mr. Karst I understand that but wouldI 14 as a consumer notice a difference in using them Is 15 the quality of the shot different 16 A. The size of the shot 17 MR MORTL Objection to form 18 Q. By Mr. Karst Well they're both gauge 19 right 20 A. That's the size of the shell That has nothing 21 to do with the shot 23 Q. Okay That's what I'm trying understand 23 A. You might have a different size shot them A 22 target load had a number 9 shot invariably for 25 gauge A field load could have anywhere from -- a Doby Professional Reporting Inc. 952-943-1587 29 Pages 110 to 113 Raymond A. Anderson Jr. 7/18/2018 114 1 gauge could have anywhere from probably number 6 2 shot on up smaller 3 - Q. So think we've got our world We've got our 4 target shells '68 to '72 replaced by the RXP 5 unibody in '72 We have target shell gauge and 6 gauge and one type of field shot gauge after 7 they switched to yellow and that's it that would have 8 the plastic basewad 9 A. I believe so 10 Q. sorry I don't think I wrote this down If 11 you have - I'm kind of switching topicsa little bit 12 We're done with that one 13 Target shells come in gauge gauge and - 14 A. 410 15 Q. -- 410. And hunting come in 12 16 20 and 410 16 A. Do you mean field loads 1082 Q. Field loads yes I call them hunting but 1082 we're on the same page hunting and field loads 1082 A. Yes pretty much 1082 Q. And then 8 was industrial and then you 1082 mentioned the 10. Yes 22 A. I did yes 2 Q. Outside of work have you -- well let me start 24 with in work Did you ever shoot a shell with an 2 containing basewad 116 1 MORTL Objection to form 2 WITNESS Shot a wad not a basewad a 3 power piston wad in all likelihood possibly a 4 felt wad depending on the load and shot size 5 Q. By Mr. Karst Why do you say possibly a felt 6 wad 7 A. Felt wads were in and out of combinations with H 8 wads and that sort of thing There was lot of 9 combinations 10 Q. You're not saying sometimes a felt wad if they 11 had it might stay in It would always be expelled 12 A. No. Anything in front of the basewad comes out 13 That's loose piece to start with 14 Q. Then what happens to the shell itself with the 15 basewad in it when you shoot 16 A. It gets ejected from the gun 17 Q. Falls on the ground 18 A. Yes if you're outside I did a lot of shooting 19 inside 2 Q. When you shoot inside are you under different 2 conditions 2 MORTL Vague Form 23 THE WITNESS With respect to what 24 Q. By Mr. Karst I said the spent shell would 25 fall on the ground you said yes if I was outside 115 123 A. Yes 123 Q. How do you know that you have shotshells that 123 had an containing basewad 4 A. Say it again please 5 Q. How did you know they were an 6 containing basewad 7 A. Because of the type of shell they were 8 Q. Were they field shells 9 A. Yes 10 Q. And why would you be shooting them at work 11 A. As part of a project I was on 12 Q. & 13 A. Yes D 14 Q. What gauge were you shooting or have you shot 15 A. Probably 12 16 Q. So if you're shooting -- 17 A. I don't recall specifically 18 Q. If you're shooting a gauge field shell at 19 work you pull the trigger what happens 20 A. It goes bang 2222 Q. Yes 2222 A. What do you mean what happens I don't 2222 understand the question 24 Q. What comes out of the end What comes out 2222 A. Shot 117 1 A. Yes If was inside it would fall on the 2 floor 3 Q. Okay There's not any type of collection system 4 when you shoot it 5 A. Generally no 6 Q. What happens with the spent shell then 7 MORTL Overbroad Vague 8 THE WITNESS It depends what you're 9 shooting it in 10 Q. By Mr. Karst Are they tested Are they 11 repacked What happens 12 A. They're not repacked if they're fired if that's 13 what you mean 14 Q. Yes 15 A. What happentos it after you fire it It gets 16 _collected and put in probablya scrap container or 17 possibly goes back to & for inspection of some kind 18 or another 19 Q. It's not used again 20 A. No it's not 1 MORTL You're talking about 20 H field 2 loads 23 THE WITNESS I thought you were talking 2 about gauge 2 Q. By Mr. Karst gauge Doby Professional Reporting Inc. 952-943-1587 30 Pages 114 to 117 Raymond A. Anderson Jr. 7/18/2018 118 1 A. They could be reloaded but generally we did it 2 inside I thought you were talking about the inside 3 shooting that I did because I mentioned that 4 Q. Do you know if Remington - strike that 5 You were taking about people who worked at the 6 plant and I wanted to ask you about a couple different 7 names Do you know an M.W. Kordas 8 A. Yes 9 Q. Who is Mr. Kordas 10 A. An & engineer 11 Q. Did you ever work with Mr. Kordas 12 A. Not directly 13 Q. Do you know roughly the time period Mr. Kordas 14 worked at Remington 15 A. He was there when I got there and I believe he 16 worked for another five years or so and transferred to 17 marketing 18 Q. At Remington 19 A. At Remington yes 222222 Q. Was that still in Bridgeport the marketing 222222 department 222222 A. Yes Different location but Bridgeport still 222222 yes 222222 Q. Not physically but the same building 222222 A. Correct 120 1 prior workers for any asbestos injury or lung 2 disease 3 A. Individually employees I don't believe so but 4 there was a lot of monitoring for asbestos 5 Q. When did that start 6 A. It was underway when I got there 7 Q. When you got there in March of '68 they were 8 already monitoring for asbestos 9 A. Yes they were 10 Q. How were they monitoring for asbestos 11 A. With asbestos monitoring equipment which is 12 some sort of device I'm not all that familiar with 13 the procedure but it's area monitoring or personal 14 monitoring 15 Q. People have like a monitor on themselves 16 A. Correct 17 Q. And there's also one in the general area itself 18 that's not attached to an individual 19 A. An area monitor right 20 Q. And what are they testing 21 MR MORTL Objection to form 22 Speculation 23 THE WITNESS They were testing the air 24 Q. By Mr. Karst And how do you know they were 25 testing the air for asbestos 119 1 Q. Do you know if he stayed in marketing or what 2 happened to him 3 A. I don't beyond the fact that he just worked in 4 marketing because I left not too long after that 5 Q. What would be roughly his job duties 6 MR MORTL Objection to form 7 Speculation 8 If you know 9 THE WITNESS He was in a research group 10 that was known as applied research and he for 11 the most part did not work on ammunition 12 though he did at times He had some projects 13 that were involved in ammunition but they had 14 exploratory research they called They 15 looked at all kind of things You probably 16 wouldn't believe some of the things they looked 17 at 18 Q. By Mr. Karst Did they have an house 19 medical department at Remington 20 A. Yes 21 Q. And what was the purpose of the medical 2222 department 23 A. Physicals injuries you know take care of 24 documentation health records safety 25 Q. Do you know if they ever examined workers or 121 1 A. I think they made that plain There wasn't any 2 secret that we had asbestos in the plant among the 3 employees 4 Q. You mentioned earlier that the asbestos that was 5 used to make the basewad came into the plant correct 6 A. Yes 7 Q. How did that come to the plant 8 A. Either truck or rail car 9 Q. And how was it packaged 10 MR MORTL Objection to form Overbroad 11 THE WITNESS Bag 12 Q. By Mr. Karst Do you know how big the bags 13 were 14 A. I believe they were 50 or 100 pounds 15 Q. Do you know who the asbestos bags came from 16 A. Johns Manville 17 Q. And how do you know they were Johns Manville 18 A. I them 19 Q. And how would -- I know this sounds -- 20 A. I was supervisor of production 22222 Q. How do you know they were Johns Manville bags 22222 A. It said so on the bags 22222 Q. On any of the bags did you ever see any type of 24 warning 25 A. I don't recall specifically Doby Professional Reporting Inc. 952-943-1587 31 Pag1e 18s to 121 Raymond A. Anderson Jr. 7/18/2018 122 1 Q. Were there any other suppliers of the asbestos 2 to Remington besides John Manville 3 MR MORTL Objection to form 4 THE WITNESS I don't know 5 Q. By Mr. Karst How often would asbestos come to 6 the plant 7 MR MORTL Objection to form Broad 8 THE WITNESS As we used to say at 9 Remington all the time that's not my 10 department however it was probably monthly 11 Most of our materials were monthly 12 Q. By Mr. Karst Was it stored then 13 A. Yes 14 Q. Where was it stored 16 MR MORTL Objection to form Go ahead buildings 300 One the 17 THE WITNESS of buildings 18 Q. By Mr. Karst 300 series buildings 19 A. Yes 20 Q. If they were monitoring for asbestos and obviously they knew they were getting in raw asbestos 22 did they issue warnings to employees about asbestos A. Individual warnings to people or handouts no 24 Q. Did they put signs up in the building warning 25 asbestos asbesatsboesstos 124 1 Q. By Mr. Karst Did they make 2 containing basewads in Arkansas at the plant 3 MORTL If you know 4 THE WITNESS I don't know 5 Q. By Mr. Karst When you said they moved the 8 operation down to Arkansas what do you mean 7 A. They moved the manufacturing operation butI 8 don't recall whethethre molded basewad was still 9 in production As a matter of fact I think the RXP 10 shell had taken over by then 11 Q. Do you have any knowledge one way or another 12 whether containing basewads were manufactured 13 at the Arkansas planotr not 14 A. No. 15 Q. Do you know who would know the to answer that 16 question Who would you go to 17 A. I would probably dial up the Arkansas plant 18 Q. still there 19 A. Yes Q. Is still in operation 1 A. Yup 2 Q. When did it start operation Foundation 2 Objection MR MORTL Objection Foundation Form 2 WITNESS '71 I think somewhere 25 around there 123 12 A. There were some signs 12 Q. When were there signs 3 A. Caution asbestos During the time we were using 4 it 5 Q. Was there signs there when you got there in 6 March of '68 7 A. I believe so yes 8 Q. Were they still there when you left in '86 9 A. I don't recall The shotshell operation was 10 removed sequentially from that plant It went down to 11 the Lonoke plant in Arkansas I don't know during what 12 _ period of time the Colton operation might have gone 13 down there They made the basewads During that time 14 we were pretty much out of it 15 Q. That's where I was kind of going When they 16 moved some of the asbestos operation down to 17 Arkansas - and it was eventually completely gone from 18 Bridgeport correct 19 A. huh Yes 20 MR MORTL Objection to form 21 THE WITNESS That's right In fact I 2222 think it might have happened before they moved 2222 to Arkansas 2222 MR MORTL Objection to form Misstates 2222 the record as to Lonoke 125 1 Q. By Mr. Karst Did they make ammunition there 2 A. Yes 3 Q. Did they only make ammunition there 4 A. Yes 5 Q. Did they make ammunition for shotgun and pistol 6 and 7 A. Not at the same time They started at different 8 times The first thing was centerfire rifle The 9 second was centerfire pistol I believe the third was 10 shotshell And the last was rimfire 11 Q. Shotshell was there a specific gauge or gauges 12 they were doing 13 MR MORTL Objection Form Foundation 14 THE WITNESS I really don't know the 15 specific - 16 Q. By Mr. Karst Were they taking -- 17 A. -- schedule 18 Q. Were they taking the business from Bridgewater 19 down there -- 22222 A. Bridgeport 22222 Q. - or were they producing it at both locations 22222 at the same time 22222 A. There was slight overlap but I couldn't tell 22222 ~~ you which specifications were overlapped I was out of 25 that by then Doby Professional Reporting Inc. 952-943-1587 32 Pages 122 to 125 Raymond A. Anderson Jr. 7/18/2018 126 1 MR MORTL You said Bridgewater but he 2 corrected you It was Bridgeport but that's 3 fine 4 MR KARST Sorry 5 Q. By Mr. Karst Do you knowa Dr. John Zapp 6 A 7 A. No not that I recall 8 Q. A Dr. D'Alonzo 9 A. No. 10 Q. C.A. D'Alonzo 11 A. No. 12 Q. The products that were manufactured in 13 Bridgeport the shotshells that had the 14 c_ ontaining basewad when they were packaged up 15 a_nd shipped off to Remington's customers did they ever 16 contain any type of a warning regarding asbestos 17 A. I don't believe so 18 Q. Is there any reason why they would have warning 19 signs and air monitoring in the plant itself but not 8 warn their customers that the product contains 21 asbestos 22 MR MORTL Objection to form 2 THE WITNESS Sure The employees were in 2 the environment where the asbestos was being 25 used and very few by the way could be exposed 128 1 from time to time on the job and they were well 2 trained and equipped and so on and so forth and 3 monitored 4 Q. By Mr. Karst Are you saying in your belief 5 you would have to have been doing that job to have been 8 exposed to asbestos 7 PHONE Calls for expert opinion 8 THE WITNESS I don't know that I would say 9 that but I can't tell you why not 10 Q. By Mr. Karst Because the signs in the plant 11 were warnings for all employees correct 12 A. Generally yes but people in the plant were 13 also assigned to specific areas 14 Q. Sure 15 A. So there would be no reason for them for 16 example to go into the area where the Colton machine 17 was operated 18 Q. But it's there for everybody 19 A. But there The safety program is there for 20 everybody yes 228 Q. Have you ever heard the term friable 228 A. Yes 23 Q. How would you define the word friable 24 A. It's a property of substance which makes it 25 break apart on impact 127 123 to it 123 Q. By Mr. Karst And why do you saythat 123 A. Because there were only two people on the job 4 Q. Two people on what job 5 A. On the molded basewad manufacturijnogb 6 Q. So you gave me one individual's name earlier 7 A. Curt Simmons 8 Q. And who was the other 9 A. I don't recall I tried to think of it when I 10 was out of the room 11 Q. So do you believe that those were the only two 12 that could have been in danger regarding any asbestos 13 MR MORTL Objection Misstates 14 testimony 15 THE WITNESS I don't believe they were in 16 danger There was a very thorough safety 17 program and personal protective equipment and 18 monitoring and the whole nine yards It was 19 very conscientiously done 222222 Q. By Mr. Karst But those are the only two 222222 people that you think could ever be involved with 222222 anything 222222 MR MORTL Objection Overbroad 222222 THE WITNESS I don't know specifically of 222222 other people but I know other people filled in 129 1 Q. Would you consider friable dusty 2 A. Not necessarily 3 Q. What would you consider it 4 A. Friable 5 Q. Yes 6 MORTL Vague Calls for expert 7 opinion 8 Just give your general understanding sir 9 WITNESS Something that breaks up in 10 clean pieces It would not be dusty but it 11 might be friable 12 Q. By Mr. Karst Breaks up in clean pieces but 13 would not be friable 14 A. I said maybe It might be called friable 15 Q. When you shoot a shotshell obviously like you 16 said the projectile comes out as intended the other 17 side of the gun correct The shotgun 18 A. I'd prefer you use the word ejecta 19 Q. But also where you're shooting there's -- some 20 call it gunshot residue and so forth that comes out the 21 other side correct 22 A. small amount yes gunshot residue 23 Q. Is that typical 24 A. Gunpowder residue would be the proper term not 25 gunshot Doby Professional Reporting Inc. 952-943-1587 33 Pages 126 to 129 Raymond A. Anderson Jr. 7/18/2018 130 1 Q. Is that a typical experience that you've had 2 A. Yes 3 Q. going to show you what I'll mark as Exhibit 4 2 5 6 Plaintiff's Exhibit 2 2/17/71 document 7 regarding toxicity of primer and projectile 8 in rimfire ammunition marked for 9 identification 10 11 MR KARST I'll give this to your 12 attorney 13 MR MORTL Is this the only copy 14 MR KARST It's your all's document 15 Q. By Mr. Karst I'll let you read this document 16 but I'm just going ask you have you ever seen this 17 document before Does it look familiar to you 18 MR MORTL Take a minute to -- 19 Q. By Mr. Karst I'll let you read the whole 20 thing but I'm just asking you generally speaking 21 A. No I don't think I've seen it before 22 Q. let you read this document The document 2222 for the record is dated February 17 1971. The upper 2222 left says M.W. Kordas Jr. supervisor applied 25 research Remington Arms Company Inc. Bridgeport 132 1 attention in recent years The American Conference of 2 Governmental Industrial Hygienists now recommends a 3 threshold limit value of 5 fibers per milliliter of 4 air fibers greater than 5 microns in length counted by 5 phase contrast method following collection by a 6 membranefilter technique This low level of 7 concentration reflects the concern that is felt for the 8 health effects of inhaling asbestos fibers In 9 addition to the fibrotic disease called asbestosis 10 which has long been recognized It is now known that 11 persons who acquired the disease asbestosis are more 12 likely to develop lung cancer than rates for the 13 general population would predict It would be well to 14 seek a suitable substitute for asbestos in the friable 15 projectile In the building construction industry 16 where containing insulation has been sprayed 17 on steel structural members it has been necessary to 18 s_eek substitutes for asbestos Various compositions 19 containing asbestos from steel mill slag have been used 20 the insulating of steel members of buildings This 21 might be a starting point in the search for an adequate 22 substitute for asbestos in the friable projectiles 23 My question for you sir is when did Remington 24 begin to look for a substitute for asbestos in their 25 shells 131 123 Connecticut 06602 entitled Toxicity of the Primer and 123 the Projectile in Rim Fryer Ammunition 123 MR MORTL It's rimfire not rim fryer 4 THE WITNESS This is not an easy document 5 to read 6 MR MORTL Take your time 7 THE WITNESS Okay 8 Q. By Mr. Karst It's signed James F. Morgan Do 9 you know Mr. Mortgage 10 A. No. I know Mr. Kordas 11 Q. Okay He's the gentleman you mentioned earlier 12 in applied research 13 A. Correct 14 Q. It talks about here on the first page asbestos 15 in the projectile The weight of the projectile is not 16 given in your letter On the basis of 36 percent by 17 weight of asbestos in the projectile we estimate 18 assuming projectile weight of 1 gram that 250 rounds 19 would probably contain 50 to 100 grams of asbestos at a 222222 ~~ minimum The projectile is described as friable We 222222 judge from this description that the asbestos could be 222222 reduced by friabilittyo discrete fibers and dispersed 222222 at least to a partial extent in the air of the 222222 enclosure in which the firing is done The danger of 25 _ inhaling asbestos fibers has received a lot of 133 1 A. Well let me first comment that -- 2 Q. That's my question sir 3 A. Okay 4 MR MORTL Well he can answer your 5 question however he wants to answer it 6 THE WITNESS I don't know 7 Q. By Mr. Karst Was there ever a program that 8 you're aware of where Remington began a phaseout 9 program of containing wads 10 A. Yes For basewads 11 Q. When was that 12 A. I don't recall specifically In the 60s 13 somewhere 14 Q. They began a phaseout the program in the 60s 15 A. I believe so yes 16 Q. Why did it take until least according to 17 what you told me earlier '81 to phase it out 18 MR MORTL Objection to form 19 Q. By Mr. Karst Why would it have taken that 20 long 22222 MR MORTL Objection to form Foundation 22222 If you know 22222 THE WITNESS Ammunition is a very tricky 22222 thing to manufacture You don't make changes 22222 lightly That would be my short answer You Doby Professional Reporting Inc. 952-943-1587 34 Pages 130 to 133 Raymond A. Anderson Jr. 7/18/2018 134 1 would have to test and test and test make sure 2 that everything's okay with the ammunition from 3 a performance standpoint 4 Q. By Mr. Karst They had a viable substitute 5 before they had asbestos As you said they had paper 6 A. huh 7 Q. Is that correct 8 A. Paper preceded containing yes 9 Q. Why couldn't they just go back to using paper if 10 they're looking for a substitute if they knew asbestos 11 was dangerous 12 MR MORTL Objection to form 13 THE WITNESS The shells were highly 14 reloadable 15 Q. By Mr. Karst Which ones were not 16 A. The based ones 17 Q. You also told me for some specific shells they 18 had plastic basewad 19 A. huh 22222 Q. Why could they not use that as a substitute for 22222 asbestos 22222 MR MORTL Objection to the form 22222 Go ahead 22222 THE WITNESS I would have to speculate a 25 little bit but there's a lot of reasons for 136 1 Q. So you just said the basewad goes out the end of 2 the barrel 3 MR MORTL Objection to form 4 THE WITNESS No. I said I'm surprised you 5 haven't said that yet quite frankly 6 Q. By Mr. Karst You've told me that it didn't 7 A. I did tell you it didn't 8 Q. Right 9 A. Yes 10 MR KARST We've gonea little more than 11 an hour Why don't we take a break 12 VIDEOGRAPHER The time is 2:22 p.m. We're 13 going off the record 14 15 * 16 17 VIDEOGRAPHER The time is 2:38 p.m. We're 18 back on record 19 Q. By Mr. Karst Mr. Anderson the document | 20 read you Exhibit 2 in this letter they're talking 21 about the friability of the projectiles Since this 22 came out '71 which you said they were already 322 testing asbestos or warning about asbestos in '68 when 322 you got there are you aware of any testing that was 25 done to see the amount of asbestos expelled from the 135 123 going to a plastic basewad in a shotshell One 123 of them is that it's very easy to adjust the 123 internal of the shell which bears on what kind 4 of shots you use what kind of other wads you 5 need to use what you're trying to use the shell 6 for and all that takes time to figure out and 7 it's not the same for each shell or each load 8 You might have one set of problems to deal with 9 with a plastic basewad all other things being 10 equal and totally different ones if it was an 11 asbestos or a molded basewad whether it had 12 asbestos in it or not 13 Q. By Mr. Karst Why did they use asbestos in the 14 first place 15 MR MORTL Objection to form 16 THE WITNESS Because it's a perfect 17 material for that kind of application It's 18 very hard It's very a wearable you might say 19 Q. By Mr. Karst Even though it's dangerous 22222 A. It's very strong Yes it is dangerous 22222 Gunpowder's dangerous too It forms well It's very 22222 tough once it's formed I assume that's probably why 22222 you haven't talked about the basewad going out the 22222 barrel yet That's pretty much it It's a good 25 material for that application 137 1 gun when it was fired 2 A. No. 3 Q. Either from what came out the end or as you 4 said from -- 5 A. I would seriously question the assumption that 6 any asbestos came out the end 7 Q. But you're not aware of any testing 8 A. No. 9 Q. In your attorney's handwriting the document 10 that you had given me this morning Exhibit 1 the last 11 line on there has 1964 to 1967. I'm assuming that says 12 some target loads 13 A. Yes it does 14 Q. What does that reference What does that mean 15 A. That means there were target loads that had 16 molded basewad in them 17 Q. Between '64 and '67 18 A. huh That's what it says 19 Q. And what is that based off of 20 A. I'm thinking it's a catalog item that shows that 21 it's the molded basewad shell 22 Q. Why would target shells have a molded 32 basewad 24 MR MORTL Objection to form 25 THE WITNESS It can only be because the Doby Professional Reporting Inc. 952-943-1587 35 Pages 134 to 137 Raymond A. Anderson Jr. 7/18/2018 138 1 molded basewad shell was more suitable for 2 the particular load than the RXP shell was 3 although the RXP shell wasn't available at that 4 time so I can't answer the question 5 Q. By Mr. Karst The notation that's here is 6 SGPI Do you know what that stands for 7 A. Yes That's a code on the bottom of a 8 Remington I think probably a price list but I'm not 9 sure 10 Q. Do you think this is from a price list 11 A. That would be my guess yes 12 Q. Do you know what that code means SGPI 13 A. No not off the top of my head 14 Q. Is that something that the attorney would have 15 written down 16 A. No. I believe that's the form of the codes that 17 appear at the bottom of the catalog and the price 18 lists 19 MR MORTL They're bates numbers 222222 THE WITNESS That's the kind of numbers 222222 that are on there 222222 MR KARST I'm asking him 222222 MR MORTL Sure Just to help you 222222 MR KARST I know what they are I'm just 222222 asking him if he knows since it was he said 140 1 MR MORTL I don't no 2 MR KARST How can you find out 3 MR MORTL Do you have anymore questions 4 for the Witness We can do this off the record 5 MR KARST We can do this off the record 6 but I'm asking you right now do you have them 7 MR MORTL We can do this off the record 8 Do you have anymore questions for the Witness 9 MR KARST Can you look or not 10 MR MORTL Do you have anymore questions 11 for the Witness 12 MR KARST Of course I do 13 MR MORTL Okay Ask them 14 MR KARST Wow You're a piece 15 Q. By Mr. Karst Mr. Anderson are you aware of 16 any patents that Remington possesses or had possessed 17 for containing products 18 A. No. 19 Q. You've never seen any 20 A. Nope 21 Q. Do you know an Edward Rickey 22 A. I knew him yes 23 Q. Who is Mr. Rickey 24 A. I believe he was a production supervisor Ed 25 Rickey probably in the park production unit but I'm 139 123 from him 123 Q. By Mr. Karst Do you know what specific target 123 loads had an containing basewad from '64 to 4 '67 5 A. No I don't 6 Q. Any idea how I would find the answer to that 7 which ones did and which ones did not during that time 8 period 9 A. I don't know You could go look up that code 10 number on the price list and see if you saw any other 11 ones 12 Q. Honestly I'm trying to find if I have been 13 given those documents or not 14 MR KARST Do you guys have those 15 MR MORTL They've been produced 16 MR KARST Do you guys have those 17 MR MORTL I don't have them 18 MR KARST You guys don't have a copy of 19 the documents that you've produced in this case 222322 MR MORTL Counsel ask your questions 222322 MR KARST I understand but you guys 222322 brought this to the deposition I didn't bring 222322 this to the deposition You guys made notations 222322 on here Do you have these documents for those 222322 pages 141 1 guessing 2 Q. In which unit 3 A. Park production 4 Q. What is park production 5 A. Rimfire and explosives 6 Q. Do you know roughly what years he worked for 7 Remington 8 A. No. He was there before I was If I'm not 9 mistaken he's deceased 10 Q. When you arrived in '68 was Mr. Ricky still 11 working there to your knowledge 12 A. Yes 13 Q. And you also mentioned a gentleman Ben 14 Daubenspeck 15 A. Yes 16 Q. What was his job at Remington 17 A. He was a research manager He was my first 18 boss twice removed 19 Q. How did he work at Remington 20 A. long time I would guess 30 40 years 22222 Q. Was he there when you arrived in '68 22222 A. Yes 22222 Q. Was he still there when you left in '86 24 A. No. He retired 22222 Q. Q. Okay He didn't move on to another company or Doby Professional Reporting Inc. 952-943-1587 36 Pages 138 to 141 Raymond A. Anderson Jr. 7/18/2018 142 1 anything 2 A No. 3 - Q. He was pretty much a Remingtonlifer for the 4 most part 5 A. For most part he was yes lot of them 6 were 7 Q. I'll show you a patent In the upper hand 8 corner it says United States Patent Office patented 9 Septembe6r 1666 number 3270671 title of the patent 10 is Cartridge Wad and Process for the Manufacture 11 Thereof by Benjamin Daubenspeck and Edward A. Rickey 12 Stafford Connecticut as signers to Remington Arms 13 Company Inc Bridgeport Connecticut a corporation of 14 Delaware I'll hand this to your attorney and we can 15 mark this as Exhibit 3 16 17 Plaintiff's Exhibit 3 United States 18 patent marked for identification 22222222 22222222 Q. By Mr. Karst I'll give you a couple minutes 22222222 if you want to peruse that It's a page patent 22222222 A. It might be more than a couple minutes 23 Q. Have you had a chance to read this 22222222 It's A. have It's tough to read 22222222 Q. It's patent 144 1 asbestos listed there says 40 percent asbestos If you 2 look right here in the next paragraph it starts with 3 However it must be appreciated that the preferred 4 percentages are not limiting in the exercise of the 5 present invention For example basewads can be 6 produced at 100 percent asbestos plus binder or 100 7 percent wood fiber plus binder If you continue on 8 down that paragraph right there -- 9 A. It has been found 10 Q. Yes has been found that acceptable basewads 11 for most general uses can be produced by varying the 12 asbestos not substantially less than 30 percent and not 13 substantially more than 60 percent 14 However when you look deeper into this patent 15 where I'm point right here on the first page the 16 paragraph that starts the following discussion which 17 is the patent itself The following discussion will 18 refer mostly to the manufacturer of molded basewad 19 however it must be appreciated that the discussion is 20 not intended be limited to basewads only huh 22 Q.Q. Do Do you knowknow what what elels se tthhey ey would would be be refreeferrrirnging 23 to Mr. Anderson 24 A. No I don't 25 Q.Q. Well , we a peruse liltittletle bibit tfafarrttherher iinntoto 143 1 A Yes 2 Q. As you can see from the first page of that as I 3 mentioned the date September 6 1966 in the upper 4 hand comer of page one but as you can see by 5 the writing right in the beginning of the document it 6 says This application is a continuation in part of 7 pending application serial number 211108 filed July 8 19 1962 now abandoned Do you see where I'm reading 9 A. Yes 10 Q. And this is as they call it a patent for a 11 cartridge wad correct 12 A. huh That's what it says yes 13 Q. That's what they're terming it least 14 A. Yes 15 Q. Do you have any disagreements with anything 16 that's in this patent 17 MR MORTL Objection to form 18 THE WITNESS None that I see but I'm 22223 probably not qualified to make such a judgment 22223 in some ofthese things in chemistry in 22223 particular 22223 Q. By Mr. Karst As you can see on the first 22223 page-- I wish each line was numbered I apologize 2 If you look up - I'll point to your copy As you can 25 see right here where I'm pointing the amount of 145 1 this on the second page you'll see the big four up 2 here and then when you get into this column it says 3 what is claimed and it has numbers one through seven 4 listed of what is claimed and when you look at these 5 they talk about basewad the cartridge basewad I'll 6 give you a chance to look at it You can look through 7 Several of them refetro the cartridge basewad Are 8 you okay with that 9 A. Yes 10 Q. Number seven however specifically says a 11 __ cartridge wad consisting essentially of an individually 12 molded mixture of 30 to 60 percent of asbestos 13 fibers 70 to 40 percent of ligneous cellulose fibers 14 and a wax binder present in the amount equal to 15 to 15 20 percent of the weight of the fibers and so forth 16 So this patent is not only for containing 17 basewads but also wads made of asbestos within the 18 cartridge itself 19 MR MORTL Objection to form Mistakes 20 the document Calls for a legal conclusion 2322 If you know 2322 THE WITNESS What is your question 2322 Q. By Mr. Karst Am I correct in reading this 24 that paragraph seven does not relate to basewads and it 2322 _ specifically relatetso a different wad they're calling Doby Professional Reporting Inc. 952-943-1587 37 Pages 142 to 145 Raymond A. Anderson Jr. 7/18/2018 146 1 cartridge wad 2 MR MORTL Same objections 3 THE WITNESS I don't know what a cartridge 4 wad is 5 Q. By Mr. Karst It's not a basewad correct 6 A. Yes 7 Q. Is that fair 8 A. Yes 9 Q. Because throughout the other paragraphs they 10 specifically labeled it cartridge basewad but in 11 paragraph seven it's called a cartridge wad What is 12 the cartridge of a shotgun shell 13 MR MORTL Objection Foundation Form 14 If you know 15 THE WITNESS That's lawyer language 16 That's not ammunition manufacturing language 17 You don't call fat shells cartridges I don't 18 know what that means 19 Q. By Mr. Karst You don't know what a cartridge 20 is 22222 A. I know what a cartridge is 22222 Q. What is a cartridge 23 A. In ammunition 22222 Q. Yes 25 A. It's a brass case usually centerfire or 148 1 are back on the record 2 Q. By Mr. Karst Mr. Anderson I'm going to give 3 you what we're marking as Exhibit 4. This is a 4 document that's bates stamped SGPI 1001353 through 5 bates number SGPI 1001367 6 A. Got it 7 Q. Have you had a chance to review this 8 A. Not in detail no 9 Q. If you want to take a minute or two and look at 10 this document 11 Have you had a chance to review ? 12 A. Yes It's pretty voluminous isn't it 13 Q. This is a document produced by your attorneys 14 I'm asking you -- first of all on Exhibit 1 these are 15 the numbers that were referenced under 196t4o 1967 16 some target loads under mold basewads I'm trying 17 to understand this document First of all what is 18 this 19 A. It looks to me like a list of all specifications 20 for shotshell ammunition By specifications I mean 21 components 2222 Q. All or just some 2222 A. I would have to study it more to say all or 2222 some but there's a lot in there Those are all the 25 gauges 147 1 possibly rimfire Shotshells are called shotshells 2 They're not called cartridges not in the business so 3 to speak or among users I don't know that I've ever 4 heard a shooter call a shotshell a cartridge 5 Q. This patent is written by -- 6 A. Lawyers 7 Q. - the two gentlemen who their names are on it 8 one of them you know Actually the two gentlemen you 9 know Mr. Daubenspeck and Mr. Rickey 10 A. Right 11 Q. Do you have any idea what those two gentlemen 12 were referring to when they talked about a cartridge 13 wad 14 A. No. 15 MR KARST Off the record 16 VIDEOGRAPHER The time is 3:04 p.m. We 17 are going off the record 18 19 **** 222222 222222 Plaintiff's Exhibit 4 specifications for 222222 shotshell ammunition marked for 222222 identification 222222 222222 VIDEOGRAPHER The time is 3:15 p.m. We 149 1 Q. On the first page there's several names lower 2 left corner J.J. Capasso 3 A. Yes Jimmy Capasso 4 Q. Is Mr. Capasso still with us 5 A. No. 6 Q. What washis job 7 A. He was chief supervisor of park production when 8 I was there 9 Q. Parts for 10 A. Park manufacturing facility rimfire 11 explosives That's it firing and explosives 12 Q. the lower right we've got several other 13 names There's R.M. Malcom 14 A. Yes Ralph Malcom 15 Q. What was his job 16 A. I don't really recall I'm not even I sure 17 could point him out in a picture 18 Q. How about W.L. Penn 222 A. Bill Penn I knew him well 222 Q. What did Mr. Penn do 222 A. He was the superintendent of process engineering 22 when I first went to Remington 22 Q. Process engineering of what 2 A. Of the plant 25 Q. Is Mr. Penn still with us Doby Professional Reporting Inc. 952-943-1587 38 Pages 146 to 149 Raymond A. Anderson Jr. 7/18/2018 150 12 A No. 12 Q. Then there's Mr. Capasso again and F.J. 3 Montague 4 A. Frank Montague yes 5 Q. Is Mr. Montague still with us 6 A. I don't believe so I don't know what his 7 specific position was either He was getting up there 8 when there 9 Q. And then there are the letters VRV Do you know 10 what that means 11 A No. 12 Q. Do you know if they're initials or not sure 13 A. No don't know at all 14 Q. Is that department Would that stand for a 15 department 16 A. Not that I can think of Because that 19 Q. I see the date in the lower hand corner of 2 July 12 1968 correct That's 2 A. That's right 2 Q. Looking at this document do you see any other 2 anywhere date on this document A. No. Did I miss one on any page Any dates 25 Q. No. I didn't see one either So where I'm 152 1 on there for different loads 2 Q. But none of that has any data on it prior to 3 July 12 1968 which is why I'm asking On Exhibit 1 4 it says '64 to '67 That's what I'm tryintgo 5 understand They just don't seem to comport to me and 6 I don't know if I'm missing something 7 A. I can't help you 8 Q. Where did this information then for these two 9 lines on this sheet of Exhibit 1 come from then that 10 your attomey wrote down 11 MR MORTL Objection to form 12 THE WITNESS I'm guessing from a catalog 13 or an interpretation of a catalog I don't 14 know I can't say this information 15 Q. By Mr. Karst Could this information be 17 incorrect MORTL Objection to form 18 I THE WITNESS whether it is or not don't know I don't know asking 20 That's I'm Q. By Mr. Karst That's what I'm asking You 21 don't know one way or another whether that's a correct 22 statement or not . 23 A. Yes 24 Q. Let's look at this document so I can understand 25 at least trying to generically read this . If you look 151 123 going with that is on Exhibit 1 there's listed some 123 target loads '64 to '67 and it lists this set of 123 documents under that 4 A. Down here some target loads Okay 5 Q. Right So I'm trying to figure out how this 6 document purports to say '6t4o '67 some target loads 7 mold basewads 8 MR MORTL Objection to form 9 THE WITNESS What is the question 10 Q. By Mr. Karst Exhibit 1 says that from '6t4o 11 '67 some target loads have molded basewads and 12 they're referencing this document 13 A. Down here 14 Q. Right So what I'm asking is how does this 15 document give me any of that information 16 A. I don't see anything on there that would give 17 you that 18 Q. He can't answer 19 A. He can't answer Okay 222222 Q. On Exhibit 1 would that -- is Exhibit 1 correct 222222 or incorrect then Exhibit 1 is the yellow piece of 222222 paper 222222 A. I can't tell you that there's not an error on it 222222 or an omission insofar as you accept those things It 25 _ looks accurate to me There's a lot of specification 153 1 at page two obviously there's line across the top 2 cap body wad product and remarks It's page two of 3 the document It's page one of the chart 4 A. All right 5 Q. So the last four bates numbers are 1354 6 A. Yes 7 Q. The cap would be the metal part of the exterior 8 the shell 9 A. That's right 10 Q. The body would be the plastic part 11 A. Correct 12 Q. The wad the basewad 13 A. Correct Unless is said otherwise 14 Q. If looking at this -- and please correct me 15 _ if I'm wrong because I may be -- it says Remington 16 _industrial number 260 brass Can you tell what gauge 17 that is or what that is for 18 A. Yes It's an gauge 19 Q. And how do you determine that 20 A. It's in the product column SP8 21 Q. Okay What does SP mean 22 A. It usually means plastic shell shell plastic 23 Q. Okay And it has SP8 standard SP and there's 24 magnum standard zinc magnum zinc 25 A. huh Doby Professional Reporting Inc. 952-943-1587 39 Pages 150 to 153 Raymond A. Anderson Jr. 7/18/2018 154 1 Q. What is the different -- standard magnum what 2 does that all mean 3 A. Ordinarily -- I'm not all that familiar with the 4 gauge That was an industrial load basically but 5 generally what those mean -- standard means there's one 6 __ type of powder in it one weight of load and magnum 7 usually is a higher powder charge and a heavier load 8 Q. And says zinc afterwards does that 9 literally mean there's zinc in there 10 A. It could mean there's zinc head on it instead 11 of brass or it could mean that there's a zinc slug in 12 it 13 Q. If we go to the next page bates number 1355 14 this would be gauge 15 A. Yes 16 Q. Now can you tell from this whether this is -- 180222222 strike that 180222222 Is this target or is this field 180222222 A. This would be field There were no gauge 180222222 target loads 180222222 Q. Okay Let's go to the next page That might be 180222222 little easier Bates page last four 1356. This is a 180222222 gauge Is this field or target 180222222 A. There are some of both which 180222222 Q. How can you tell which is which 156 1 next page 2 A. Yes They're all gauge 3 Q. And the body I'm assuming is 2 3/4 inches 4 A. Correct 5 Q. And some are green blue white green blue 6 again 7 A. Yes 8 Q. But all of them have the notation -- I'm sorry 9 Some have different numbers - 58.0GR 10 A. Grain 11 Q. And 45.0GR 12 A. huh 13 Q. Green again 14 MS TRATTLES Grain 15 THE WITNESS Grain It's a weight 16 Q. Mr. Karst Grain Okay Is it grams 17 A. It weighs 58 grains 18 Q. And these all would - on these two pages 1356 would have 19 and 1357 bates numbers all a mold 20 basewad that would contain asbestos is that correct 22 Q. Yetshat Q. So we dodno'nt't have have to go tthhrrouoguhgh eacheach one ofof 23 these anytime it would say DMBW on this that would be 24 drmyolded basewad , which would be containing 25 containing 155 123 A. One says International target 123 Q. Right If it doesn't say International target 123 4 A. If doesn't say target you can assume it's a 5 field load 6 Q. Okay And again SP12 would be shell plastic 7 A. gauge plastic shell yes 8 Q. Under product third one down it has SP12 9 dash 00 dash BK dash 9. What does all that mean 10 A. Buck shot double 00 buck shot 9 pellet 11 Q. Number seven under that SP12 dash RS 12 A. Rifle slug 13 Q. And number ten under that SP12 dash 6 SAAMI 14 - 15 A. Sporting Arms and Ammunition Manufacturers 16 ~ Association standards which means it has all the 17 standard dimensions on the drawing 18 Q. I'm sorry That would be a field because it 19 doesn't say the word target 20 A. Yes But it was used as a standard that was 22222 used from time to time to compare with other types of 22222 ammunition different loads or different 22222 specifications That's the standard that you always 22222 come back to 25 Q. It looks like this one continues on until the 157 1 A. That's right 2 Q. Bates number 1359 here it has a gauge 3 target plastic basewad 52 grains 4 A. Yes 5 Q. What does the -- now obviously this would be a 6 plastic basewad according to this and therefore not 7 asbestos 8 A. Correct 9 Q. Under the product on the first line it says 10 ~~ RPA12L Do you know what that means 11 A. RPA12L It doesn't come back to me There'sa 12 12M No I don't know what that is I don't know what 13 that The answer to your question is no I can't 14 tell you 15 Q. A little further down it says PPA12L Any idea 16 A. No. 17 Q. We'll continue going through the document 18 ~~ Everything is DMBW molded basewad until you get 19 to bates 1365 20 A. Okay Got it 21 Q. So this would be gauge target and again 22 the body as you mentioned yellow at this time period 23 and I assume that would be a plastic basewad 24 A. Correct 25 Q. Do you know what RP20 stands for Doby Professional Reporting Inc. 952-943-1587 40 Pages 154 to 157 Raymond A. Anderson Jr. 7/18/2018 158 1 A. The only thing comes to mind is 2 Remington 3 Q. And PP20 4 A. I don't know what that is 5 Q. And the next page again molded basewad 6 and then the last page of the document 1367 has the 7 gauge that you were talking about and that looks 8 like it has -- it says CONV paper Does that mean it 9 still has a paper wad 10 A. Paper basewad yes 11 Q. So all in all if this document as of July 12 12 1968 purports to show the shotshells that Remington 13 was making as of this date the only two -- I'm sorry 14 The only three that are not listed as molded 15 basewads are the gauge target on page 1359 the 16 target listed on 1365 and the gauge paper gauge listed on 1367 17 A. huh 19 Q. Is that correct is 222222 A. Yes I believe it is 222222 MR MORTL Objection to form 222222 Q. By Mr. Karst Therefore everything else would 222222 be an containing molded basewad correct 222222 MR MORTL Object to the form 25 THE WITNESS I really can't answer that 160 1 Q. That might be on the 1969 one 2 A. Might be or might not be Maybe it got 3 forgotten Do you see how many specifications are on 4 here I know that's happened before I've had 5 personal experience with that That was not with 6 _ shotshell though That was centerfire That was a 7 document like this 8 Q. Do you mean a product was supposed to be in a 9 document and it didn't list ? 10 A. I can't remember which way it went but 11 something was missing or something was superfluous 12 Q. But looking at this there isn't anything that 13 you could think of that's missing off the top of your 14 head 15 A. No. But I wouldn't bet money on it to tell you 16 the truth 17 Q. These are the documents from the company This 18 is all I have to go on 19 A. I understand that 20 Q. Do you have any document that would refute any 2 of this what's in this document No. A. 22 A. 23 MR KARST I know we're at the end of the so going we're 24 tape , to stop for today If questions today 25 have have some other questions I'll pick up in the 159 123 I would have to look at this for a lot longer 1 123 Q. By Mr. Karst Are there any other shotshells 23 123 that you're aware of not listed here in this document 3 4 that existed on September 12 1968 4 5 MR MORTL July 12 5 6 Q. By Mr. Karst I'm sorry July 12 6 7 A. I can't really say We had specifications from 7 8 time to time that went in and out of production Some 8 9 might have made this list that were never even 9 10 produced 10 11 Q. Do you mean there are some that might be on this 11 12 list that were never produced 12 13 A. Or the converse There might have been some 13 14 __ produced that aren't on this list There may be some 14 15 that were not produced that are on this list and there 15 16 may be some that were produced that were not on this 16 17 list 17 18 Q. Why would something be -- if this is showing the 18 19 chart of component products for shotshells why would 19 20 it not list the different shotshells 20 22222 A. The only thing I could say about that -- and 22222 22222 __ this is pure supposition -- is that it's between 22222 22222 publications You might not have a specification on 23 22222 this 12 months of the year if a specification came into 22222 22222 _ being during the year didn't get put on the chart 22222 161 morning so we can be done for the day and the tape easily MR MORTL Agreed VIDEOGRAPHER The time 3:43 p.m. We're suspending the deposition of Ray Anderson for today and going off the record MR KARST For the record guys everyone on the phone we'll start tomorrow at 10:00 eastern time same call same everything I assume Doby Professional Reporting Inc. 952-943-1587 41 Pages 158 to 161 Raymond A. Anderson Jr. 7/18/2018 STATE OF CONNECTICUT , Keli McGilton a Notary Public in and for the State of Connecticut do hereby certify that there came before me on the 18th day of July 2018 at the Law Offices of Murtha Cullina CityPlace , 185 Asylum Street Hartford Connecticut the following named person wit RAYMOND A ANDERSON JR who was by me duly swo to trestn ify to the truth and nothing but the truth as to his knowledge touching and concerning the matters in controversy this cause that he was thereupon examined upon his oath and said examination reduced to writing by me and that the statement is a true record of the testimony given by the witness to the best of my knowledge and ability I further certify that I am not a relative or employee of counsel'attorney for any of the parties nor relative or employee of such parties nor am I 12 financially interested in the outcome of the action 13 WITNESS MY HAND this 22nd day of July 2018 14 15 16 Keli McGilton Notary Public 2222222 2222222 2222222 2222222 2222222 2222222 2222222 My Commission expires 25 July 31 2022 162 Doby Professional Reporting Inc. 952-943-1587 42 Page 162 Raymond A. Anderson Jr. 7/18/2018 Page 163 A a.m 3 44:13 AA 65:20 107 108 112 114 abandoned 143 ability 162 abrasive 19:14 accept 151 acceptable 144 accurate 151 accurately 78:20 112 acquired 132 action 162 activities 27:12 actual 99:11 add 62:13 added 62:16 addition 76:17 132 additive 44 adequate 132 adjust 135 advent 100 ago 11 25,25 48 87 90 9,18,19 91 agree 7 97:24 Agreed 7:12 161 agreements 5 ahead 24:11 29:17 93 97:15 122 134 air 23,25 126 131 132 al 8 7 Alathon 19,20 Albert 7:20 alive 28:10 76 104 105 all's 130 American 4,8,9,14 17,22,25 17,22,25 67 3,10,12 67:16 68:12 3,5 108 ambient 72 75 amended 8,9 American 33:1166 51:24 52:10 132 Ammo 51:24 ammunition 9,11 8:23 8:25 9:10 17,20 17 17 20:10 6,21 45:11 51:20 82:20 11,13 1,3,5 130 131 133 134 16,23 147 148 15,22 amorti@glynnfinley.com 2:12 amount 41:22 97 129 136 143 145 analogous 38 Anderson 1:12 3,7 4 4,20 3,16,18 11 31:16 32:11 44:20 86:10 86:14 136 140 144 148 161 162 Andrew 2:11 6 animal 41 announce 26 annual 4 answer 20,23 23:12 34 47:11 53:13 95:22 103 112 124 4,5,25 138 139 18,19 157 158 answered 54 56:22 97:10 109 answers 99:22 anticipating 94:20 anvil 30:11 anybody 16 77:11 86:17 103 105 106 anymore 31:25 42:20 52 58 84 3,8,10 anytime 156 apart 128 apologize 143 appear 138 appearances 1,17 3 5:20 appeared 45:23 2,8 appearing 6:10 Appliance 3:15 application 17,25 143 applied 16 119 130 131 appreciated 3,19 appropriate 81:23 approximation 103 April 7:22 area 13,17,19 128 areas 79:18 128 arguably 96:13 argumentative 54:23 56:21 65:14 92:24 93:25 95:10 97:24 112 Arkansas 11,17,23 2,6,13,17 Arms 130 142 155 arrived 10,21 arthritis 31:24 asbestos 75 76:17 76:18 77 4,16 93:23 102 23,24 109 110 7,20 112 113 4,8,10 11,25 2,4,15 1,5,20,21,22,25 3,16 126 16,21,24 127 128 14,17 131 19,21,25 8,14 132 18,19,22,24 134 10,21 11,12,13 136 23,23,25 137 1,1,6,12 12,17 156 157 containing 12:23 74:22 99:14 100 9,22 103 106 7,20 1,6,8,13 111 112 114 115 2,12 126 132 133 134 139 140 145 156 158 asbestos 9:18 13:16 5,12 120 asbestosis 9,11 asked 7:25 24:17 49:20 53:25 56:22 93:14 97:10 109 asking 13 34 36 56:14 63 130 22,2252,25 140 148 151 3,20 assemble 79 assembled 72 1,7 assert 11:22 assigned 24 128 associated 40 Association 16,17 155 assume 135 155 157 161 assuming 13:25 14 15 51 131 137 156 assumption 33:22 65:10 105 137 Asylum 1:15 5 162 attached 10 120 ATTENDANCE 3:20 attention 132 attorney 10 10,15 44:22 16,2126,22 49:21 54 55 60 10,11 86:23 87 92:18 96:18 97 4,14,22,25 98:24 106 130 138 142 152 attorney's 59 64:14 137 attorney 11:22 95:12 attorneys 6 10 12 47:23 19,2129,22 11,14 51:18 56:16 9,11 86:18 10,11,15 10,11,15 91:20 91:23 1,2,6 7,18 96:21 97:18 148 auto 11,12 available 55 138 Avenue 10,14 23:22 aware 133 136 137 140 159 awhile 91 back 17:19 20 19,2109,20 38:21 42 44:19 52:11 22,22 86:11 91 98:11 104 105 117 134 136 148 155 157 backside 84 bag 43:20 121 bags 43:19 12,15,21 22,23 bang 115 Bank 8 bankers 7,8,9,14,18,19 7,8,9,14,18,19 89:20 91 12,13 Barnum 23:22 barrel 18:25 40 42:18 135 136 base 9,20 75 based 47 13,15,17,18 65:11 24,2254,25 83 1,2,21,23 100 9,10 108 109 137 basewad 30 34:19 36 14,15,19,22,24 14,15,19,22,24 37 37:19 2,142,,14,116,2462,,14,216,424 7,15 40 65:25 66 66:23 1,17 17,19 68:21 69:17 10,13,110,613,16 19,22 72 8,10,13,17 73 1,2,5,20 76:23 9,196,16 15,16,19 15,16,19 23,24 85 5,10,17 15,17 24,25 100 20,21 16,17 102 1,2,8,18,20,20,22 1,2,8,18,210,2,,8,2180,2,0,2202,22 103 106 107 17,19,25 108 7,21,22 1,7,25 6,7,20 4,9,240,9,20 8,11 8,8,2 25 15 15 115 2,12,15 121 124 126 127 134 1,9,11,23 1,9,11,23 136 16,21,23 138 139 144 5,5,7 5,10 153 20,24 157 157 6,18,23 5,10,23 basewads 29:23 39:13 3,19 72 81 85 100 101 7,22 106 6,11,15 123 2,12 133 144 5,10,20 17,24 148 7,11 158 basically 18:24 19 22:22 42:14 77:19 154 basing 45:22 110 basis 53 56:20 100 108 131 bates 138 148 153 13,22 156 2,19 battery 9,11 bears 135 began 8,14 beginning 143 behalf 5:11 belief 112 128 believe 10 11:15 17:17 18:21 19 20:16 28:22 31:22 34:21 41 42 42:21 59:11 61:11 63:22 64:16 67:19 68 69:16 77 80:25 106 8,14,20 110 111 113 114 118 119 120 121 123 125 126 11,15 133 138 140 150 158 belonged 98:24 Ben 104 141 benefits 27:13 Benjamin 142 Benson 5,6 2,2 6,6 11 95 96 best 70 162 bet 160 beyond 119 big 16 17:17 18:25 24 26 8,14 41:14 81:23 83 98:24 99 121 145 Bill 105 149 bin 57:10 77:24 1,23 binder 41 144 145 Bingo 41:12 bit 10:15 23 35:12 38:21 59 114 134 144 BK 155 BLACKWELL 2:18 blended 77 blue 74 156 bodies 30:24 31 32:14 32:20 64:13 1,10,17 93:17 4,5 body 29:23 21,22,221,222,22 8,15 16,17,17,17 36:23 2,23 38:23 39:11 41:22 59 60:15 60:20 66 10,14 10,16 85:21 2,10 156 157 bom 7:21 13:21 50:14 boss 141 bottom 36:16 37:25 38 39 72:14 84:11 138 138 Boulevard 3:16 box 88:23 89 5,7,8,9,11,14 5,7,8,9,11,14 18,19,20 18,19,20 2,20,221,20,21 90:23 91 12,13,15 21,21,24 boxes 98:13 99:10 brand 43:21 brass 30:15 79:14 146 153 154 break 44:11 3,25 98 128 136 breaks 9,12 Bridgeport 4,18 19:21 19:23 16,19 30:18 75:11 20,22 123 125 2,13 130 142 Bridgewater 125 126 bring 35 15,20,22 15,20,22 139 broad 109 122 brought 48:19 55 60 61:10 68:11 88:24 139 buck 10,10 buffer 41:10 building 22:25 2,3,4,18 24,25 5,8,17 11,19 55:23 57:14 118 122 132 buildings 19:25 20 24 6,13,17,20,22 1,3 3,6,8 28:25 17,18 58 8,11 63:20 17,18 132 built 37:22 Bullard 15 bullet 22 10 business 19 20 22:21 82:23 125 147 butyl 41 buy 66:19 C T 77:18 C.A 126 CA 2:11 caliber 6,7 calibers 18 call 33 114 129 143 146 147 call 161 called 77:15 79 119 129 132 146 147 calling 145 Calls 128 129 145 cameraman 5:16 cancer 105 106 132 cap 29:23 38:24 1,2,11 14,14 153 Capasso 2,3,4 150 car 121 Carbide 2 6:15 3,8 card 34:20 cardboard 30 3,14 20,21 17,19,20 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 Page 164 42 80:25 81:19 84 care 119 Carondelet 2:19 cartridge 7 6:13 81:16 81:17 142 143 5,7,11,18 146 10,11,12,19,21,22 4,12 cartridges 146 147 case 10:12 6,7,12 12,16,17 12,16,17 51:15 54:12 20,23 20,23 6,13 95 95:20 139 146 cases 20:22 casualty 94 catalog 5 6,9,23,24 9,10,13,17 9,10,13,17 49:11 8,11 6,7,9,10,12 16,17,22,25 16,17,22,25 3,6,8 65:11 67:24 1,3,5 74:18 7,9,12,21 17,19,22,217,139,2,23 103 19,21 137 138 12,13 catalogs 14,17,20,21,24 8:25 9 10:18 40:18 6,11,12,25 6,8,6,82,21 61,8,21 22,2252,25 8,9 49 14,22 50 16,18 51:19 52 53 54 12,13,17,22 12,13,17,22 4,6 5,8,9,15,80,9,10 11,14,111,614,16 87:23 88:19 91:11 92 97:23 11,12,12 100 100 103 categories 31:12 cause 36 162 Caution 123 cavities 78:21 cavity 21,22 78:20 CC 150 cellulose 145 center 2:10 22 5,7,8 10,11,15 centerfire 16:21 2,3 18 21:23 4,8 29 38 125 146 160 certain 7:25 23:16 9,10 38 19,21 77 certified 5:19 certify 3,10 chair 41 chamber 14,1144,14 chambers 41:20 chance 142 145 7,11 change 63 74:13 110 changed 73:20 74 changes 133 characterized 66 charge 28 9,13,16 35 154 chart 153 19,25 cheat 31 chemistry 143 chief 19,20 11,13,14 16,19 23:15 3,24 4,13 149 choose 17,18 chose 103 chosen 97:14 Christine 9 6:12 christine.delaney@little christine.delaney@little 3:10 circumference 81:24 CityPlace 1:15 162 Civil 1:12 9 claimed 145 classical 74 clean 10,12 clear 53 64 client 4,4 1,3 client's 94:23 95:20 close 65:24 76:24 89:13 89:19 closed 19 28:15 clue 64:20 pending 143 code 7,12 139 codes 138 formed 2,6,7 molded 145 molding 4,5 collected 57:10 117 collection 117 132 college 14:17 color 74:12 102 103 colored 103 colors 73:21 2,3 102 Colton 77:16 123 128 column 34:11 36 145 153 combinations 116 come 9,9,12 25:23 45:24 46:12 47:12 14,20 49:18 55:25 6,25 59:10 64:15 67 77:21 88 5,7 105 13,20 111 114 15 121 122 152 155 157 comes 12,1192,19 49:16 54 67:22 77:20 106 24,24 116 16,20 158 coming 45 98:25 comment 133 Commission 162 commit 91:16 company 8,13 8 7 15 77:16 108 130 141 142 160 compare 155 compared 22 compatible 82 compiling 60 completely 123 Complexity 20:20 component 29:14 36:15 37 2,20,25 2,20,25 43 60:21 24,25 74:25 15,17 83:19 159 components 19,22 29:21 30:14 22,25 22,25 75 14,15,25 14,15,25 80:23 24,25 1,3 148 comport 152 composition 40 100 100 compositions 132 compress 77:22 compressed 78:19 compression 43 8,8 computer 49 concave 42 concentration 132 concept 37:14 concem 132 concerning 162 conclusion 145 conditions 116 conduct 22:21 Conference 132 conformed 79:15 confusing 32 confusion 48:12 Connecticut 1:16 5,18 13:20 15 19:21 23:19 131 12,13 162 162 conscientiously 127 consider 129 considerations 94 consist 42 consisting 145 construction 37:17 93:22 132 construction 14 consumer 113 contact 105 contacted 9,11,14 contain 112 126 131 156 contained 106 container 40 117 containing 132 contains 75 126 continuation 143 continue 85:25 86:12 144 157 Continued 3 continues 77:24 155 contrast 132 controversy 162 CONV 158 conversation 97:17 conversations 12 97:21 converse 159 copies 5,6 7,9,11 1,10 copy 10 12:22 31:10 130 139 143 comer 142 143 149 150 corporation 2:18 2 6:11 6:16 12,13 142 correct 8:29:17 8:29:17 4,22 19:21 23:22 28:25 32:14 15,19 37:20 39:23 43:13 44:23 47 48:20 49:24 50:25 59 60 60:24 2,4 63 64 65:12 66:24 4,7,24 70 72:18 73:25 74 79:20 80:14 13,17,21 11,23 87:22 106 3,4,13,14 21,23 22,23,25 118 120 121 123 128 17,21 131 134 143 145 146 150 151 152 153 13,14 4,20 8,24 19,23 corrected 126 correctly 59 66 counsel 5:20 11,15,18 31:11 139 attomey 162 count 89 counted 132 County 1:25:14 1:25:14 couple 21:14 25,25 72:12 76:12 87 90:18 19,21,23 19,21,23 2,7 98:12 110 118 20,22 course 140 court 1,4 12,19,22 23 coworkers 18,19,21 18,19,21 created 10,19 Creek 10,11 crimp 80:11 84 18,2108,20 94:11 CROSS 4 section 101 CROWELL 2:13 crumpled 102 Cullina 1:14 4 162 cup 9,11,12 currently 4 Curt 76 127 customers 15,20 cute 64:20 cutoff 45:16 cylinder 78 D D 54 54 D'Alonzo 8,10 8,10 A 104 R 105 damaged 2,4 danger 12,16 131 dangerous 134 135 20,21 dark 16 dash 65:21 9,9,9,19,19,9,11 155 data 152 date 5 47:12 55:11 61:13 15,23,24 15,23,24 69:11 106 143 19,23 158 dated 130 dates 31 32 7,15,16 2,13 47 53 54:10 11,21 60 92 106 150 Daubenspeck 104 11,12 141 142 147 day 87 161 4,13 days 84 DC 2:14 de 1:13 8,22 deal 27 135 dealing 26 27:14 34:18 41:17 decade 52:15 64 deceased 28:10 71:13 12,13,14,18 105 18,19,20 141 Decker 105 deeper 144 defendant 18,2182,22 2,7 3:15 6,11 7:10 defendants 9 8 3:11 38 38 define 128 defined 41 deforms 72:12 degree 15:24 Delaney 9 12,12 Delaware 142 density 102 department 24 27 56:11 118 19,22 122 14,15 depend 24:14 29:18 depended 29:24 depending 30 36 19,21 72:22 79:14 80:11 82:18 4,20 116 depends 30:23 34:16 41:21 52:12 117 depo 31:11 Deponent 6:20 deposed 6:21 deposition 1:12 3,11 8 8 15,16,22 5,19 11,12,13 16:23 48 48:13 86:10 95 139 139 161 describe 71:25 76 79 83:15 102 described 80:18 81:19 131 description 131 design 110 detail 148 determinate 39:16 determine 153 determines 41:23 develop 132 development 5,6,8,9 device 42 120 dial 20,2230,23 78:21 124 diameter 39:18 41 6,15,21 58:15 78:15 1,2 die 58:21 72:11 78:15 difference 20:17 1,5,24 34:25 1,2,4 83 3,4,6 22,23 9,14 differences 9,11 35:22 different 12:19 19:16 20:22 23:20 24:18 29 29:12 35 36 37 13,19,25 13,19,25 62:22 68 22,23 73:10 75 78 80 93:21 94 1,13,25 12,15 113 116 6,22 125 135 145 152 154 22,22 156 159 differentiate 35 differentiated 102 differentiation 35:14 dimensionally 81:23 82 dimensions 79 9,10,11 103 155 DIRECT 2 7 directly 118 disagreements 143 disc 41 discrete 131 discussed 11:10 107 discussing 87:24 discussion 11:17 96 16,17,19 disease 106 120 9,11 dispersed 131 district 1,25 12,13 division 19:18 DMBW 156 157 docket 5:14 docs 22,23 document 4 10 32 32:13 19,22,25 55 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 Page 165 87:10 13,20 97 101 1,12 6,14 15,17,22,22 131 136 137 143 145 148 4,10,13,17 22,23 6,12,15 152 153 157 6,11 159 160 20,21 documentation 119 documents 9:23 3,4,25 13,17,22 2,3,9 48:19 1,7,8,20 51:10 19,2109,20 54:16 56:15 15,2105,20 87:23 15,20 88:25 1,16,20 90 22,2242,24 2,10,17,19 91:22 92 13,13,14 13,13,14 15,1165,16 97:21 139 19,24 151 160 doing 20:25 23:14 33 82:20 85 96:20 125 128 double 155 Doug 5:25 doughnut 78 DOUGLAS 5 douglas@vonoiste.com 6 dozen 12 Dr 126 drawing 155 dry 36:25 mold 5,16 102 103 106 148 151 156 molded 1,2,20 10,17 15,1615,16 99:23 99:25 5,7,9,20,21 5,7,9,20,21 101 102 106 124 127 135 16,21,22 138 151 156 157 158 5,14,23 du 1:13 8,22 8 3,6,14 7:24 15,22 11 21,23 44 duly 6:20 162 dumped 78:20 dusty 1,10 duties 21 119 E E 5 2,23 4 5 K 71:17 E.I 1:13 8,22 Eagle 3:16 earlier 37:16 74:11 90:11 90:12 1,6,9 121 127 131 133 early 15:17 31 37:15 51:12 99:15 104 105 earth 17:19 easier 154 easily 161 eastern 161 Eastford 13:20 easy 131 135 Eckstein 15,16 Ed 104 140 Edward 140 142 effects 132 ehatlevig@jlolaw.com 3:18 eight 62 either 9 36:12 40:10 58 84:14 103 121 137 7,25 ejecta 129 ejected 77:24 15,15 116 ELISA 3:17 ELLIOT 4 Elliott 3 15,15 Elmo 3:17 email 96:10 Emily 6:17 employed 53:18 employee 17,21 26:11 7,10,19 28:20 162 162 employees 25 5,23 26 27 71:10 110 120 121 122 126 128 employment 9,11 emugaas@meagher.com 3:14 enclosure 131 enforces 33:15 engineer 15:22 13,14 16:15 10,13,15,18,18 10,13,15,18,18 21 22:19 25 104 118 engineering 21,25 24,25 23:15 24 4,25 4,14 21,23 engineers 20:24 9,10 21:11 110 entail 22:20 25 7,20,22 entitled 131 environment 126 epk@karstvonoiste.com 2 equal 135 145 equipment 22:23 23 10,12 27:20 47:18 53:20 120 127 equipped 128 Erik 4 5:23 error 151 ESQ 4,5,11,15,20,24 4 9,17 essentially 145 estimate 88 7,14 131 et 8 eventually 123 everybody 9 22 128 18,20 everything's 134 exact 101 examination 7 162 examined 6:21 119 162 example 93 128 144 excess 78:17 exclusively 49:25 exercise 144 exhibit 7,8,10,11 31:13 8,10 44:20 86:24 130 136 137 15,17 147 148 148 1,10,20,20 1,10,20,20 151 152 exhibits 5,12 6,19 exist 33:12 existed 68:22 159 existence 42:11 50 63:24 expansion 41:20 expelled 116 136 experience 10,15 10,13 82:20 83 6,7 108 130 160 experimental 82:17 experimenting 109 expert 128 129 expires 162 explain 16:25 29:13 exploration 17:20 exploratory 119 explosive 12,13 explosives 141 149 149 exposed 126 128 extent 40 131 exterior 153 extra 31:13 F 131 F.J 150 facilities 25:12 facility 23:22 25:23 30:18 149 fact 103 109 119 123 124 factors 34 facts 48:10 fail 85:24 fair 15:18 146 fairly 41:19 49:11 fall 116 117 Falls 116 familiar 16:24 19 20 120 130 154 family 16 far 7:23 19 52:11 74:15 farther 144 fat 146 February 130 fed 1,12 Federal 7 6:12 feet 49 felt 30 40 3,14,24 1,1 4,5,10,24 4,5,10,24 42 47 9,294,24 2,6 53:22 54 55:21 57:16 58 58:15 2,19 84 4,5,7,10 132 fiber 1,2 144 fibers 22,25 3,4,8 13,13,15 fibrotic 132 field 17,22,23 17,22,23 33 19 21,25 35 8,16,21,23 35:24 36:13 9,11 59 74 83 93 18,21 7,14,20 21,24,25 110 6,17,18,16,197,18,19 112 2,7,25 6,16,17 114 8,18 117 18,19,23 5,18 5,18 figure 135 151 file 4 91 filed 5:12 143 fill 41:22 filled 127 filler 44 fills 36:15 77:20 filter 132 final 9,10,11 12,1122,12 financially 162 find 6,12 140 fine 126 finger 54 finish 23:11 FINLEY 9 fire 19,22 22 85:19 117 firearms 8:23 fired 29 117 137 firing 131 149 firm 12:10 first 6:20 10 11 29:22 36:18 1,23 12,14 7,13 56:15 11,20 90:25 91:25 92 99:13 100 104 125 131 133 135 141 2,22 144 14,17 1,22 157 five 18:18 20 98 118 minute 44:11 flat 42 floor 41:11 117 flour 76:17 4,5 flows 72:13 folder 86:21 91:14 folders 89:24 90 91 96:23 follow 19 followed 97:16 following 2:17 132 16,17 162 follows 6:21 Forever 66:13 forget 78:21 forgotten 160 form 18:15 24:10 26 27:25 11,16 10,19 3,7 11,15 37:13 38:11 43:24 49:17 50 50:11 7,23 52:19 12,25 12,25 54:18 55:18 56 2,9,12,24 2,9,12,24 59:18 60:19 4,21 17,21 65:13 68:24 7,12 14,2144,24 76:11 80:19 83 85:14 8,19 102 103 105 106 107 108 110 111 6,11 113 113 1,22 119 120 121 122 122 20,24 124 125 126 18,21 12,22 135 136 137 138 143 145 146 151 11,17 21,24 formed 30:17 36:20 40 9,10,10 135 forming 7,15 forms 75 135 formulas 10:21 forth 9:25 10:21 19:15 45 87:11 128 129 145 found 9,10 Foundation 56 124 125 133 146 four 14:20 48 67:15 88 96:16 145 153 154 fourth 79:19 frame 107 108 Frank 150 frankly 136 friability 131 136 friable 21,23 129 11,13,14 131 14,22 friends 33:18 front 8 42 74:21 86:21 116 fryer 131 full 7:17 11,12,13,19,21 11,12,13,19,21 2,21 91 96:12 98:21 function 15,16 15,16 functions 25:21 funerals 105 further 157 162 G gauge 17 29:19 37:12 39:17 67 72:22 76:22 115 125 153 gauges 33:10 38:10 74 75:19 125 148 GEER 3:12 general 120 129 132 144 generally 2 17 40 49:13 73:17 78:19 101 117 118 128 130 154 generated 47:22 48:16 75:10 generates 77:23 generically 152 gentleman 131 141 gentlemen 7,8,11 George 71:15 Georgia 19,25 15 getting 13,14 13,14 122 150 give 12 23:12 40:18 46 49:10 50 13,15 54 61:21 3,22 69:11 88 7,14 14,17 129 130 142 145 148 15,16 given 13:12 49:21 68 95 112 131 137 139 162 gives 46:11 14,15 giving 78:12 84 gleaned 61 74:17 Gloria 2:15 5 11:15 31:23 GLYNN 2 go 7 24:11 21,22 28 29:17 19,20,21 45 52:11 57:11 3,7,8 2,5 93 95:16 97:15 98:17 104 122 124 128 9,23 139 13,21 156 160 between 27:15 goes 38 40 79:19 84 115 117 136 going 2 19,2129,22 16:22 16:23 23 7,10 7,22 9,9,15,15 31 44:14 72 5,25 14,19 95:16 6,166,16 98 123 3,16 135 135 136 147 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 Page 166 148 151 157 160 161 gonna 20:12 good 5 3,4,10 31:24 46 62 135 Goods 1:13 8 5:10 3,6 7:24 16,23,25 11 goose 18:24 gotten 90:11 Governmental 132 graduate 14:22 15:24 graduated 13:25 2,15 15 graduation 24,25 Grain 10,14,15,110,614,15,16 grains 156 157 gram 131 grams 131 156 greater 26 132 green 74 9,21 112 5,5,13 ground 17,25 group 119 gtrattles@crowell.com 2:16 guess 45 58:16 73 89:18 138 141 guessing 26:17 141 152 gun 18:24 51:19 116 129 137 Gunpowder 129 Gunpowder's 135 Guns 51:24 gunshot 20,22,2205,22,25 guy 46 77:12 guys 14,16,18,21,23 161 H H 4 34:21 1,2,8,19,24 43:22 2,4,18 46 62:24 8,15,20,28,145,20,24 1,7 80:24 116 117 hair 41 hand 19:16 142 162 operated 17:24 handheld 18 handled 8,10 handouts 122 hands 20:25 31:25 89:15 handwriting 17,20,22 59 64:14 137 handwritten 4 31:15 32:10 44:21 48:14 happen 111 happened 57:23 101 119 123 160 happens 1,8 78:24 79:22 19,22 19,22 116 6,11,15 Harassing 97:11 hard 41 5,6 77:22 135 Hartford 1:16 5 162 HATLEVIG 3:17 head 10 29:23 39 41 46 6,8,12,16 6,8,12,16 93:19 104 105 138 154 160 headed 72:11 79 health 119 132 heard 61:15 8,10 128 147 heated 75 heavier 6,6 154 Heavy 30 help 48 97 138 152 hey 97 101 19,20 high 13:25 2,4,5,15,25 17,23 higher 154 highly 134 Highway 3 hired 10,12 19:10 HKM 2:23 Hold 11,15 holds 85 hole 10,11,14 hollow 78 home 5,157,17 11,21 98:22 Honestly 139 hopper 10,15 77 horizontally 89:21 horse 41 hot 15 hour 86 136 hours 88 96:16 house 12 52:18 82:11 98:14 housekeeping 7:13 Houston 4 hundreds 3,4 hunt 33 hunting 17 18 32:23 83 15,17,18 HUSCH 2:18 Hygienists 132 idea 49:10 13,21 139 147 157 identification 32:11 130 142 147 identified 59:11 image 41 IMO 3:11 6:18 impact 128 house 119 inch 49 inches 17,23 17,23 3,21 90:23 91 96:15 156 included 24 including 8:12 incorrect 151 152 independent 50 8,16,21 50:22 51 53 55 59:20 61:13 65:1158 68:20 independently 61 64:23 81 indications 89:15 indicators 46 individual 30:16 120 122 individual's 127 individually 120 145 individuals 8 9 105 industrial 16 15,16 114 132 153 154 Industries 3:11 6:18 industry 132 information 31:22 45 47 54 56:20 59:10 60 61 20,24 68 74:16 92:18 10,11,11 96:17 100 108 151 8,15 inhaling 131 132 initial 7:19 initials 150 injected 43:11 63:19 injection 8,9,10 1,2 18,19,24,25 18,19,24,25 4,7 63:14 72 injuries 119 injury 120 asbestos 3 5:13 inserted 22 inside 41 82 19,20 117 118 insofar 151 inspection 117 instance 112 instances 5,18,19 instruct 19,23 insulating 132 insulation 132 integral 9,23 1,2,23 107 intended 129 144 interchangeable 39 interested 36 162 internal 29:23 34:12 35 39:21 40:10 60:21 135 internally 61 International 155 interpretation 152 interviewed 15:16 interviewing 15:20 introduced 46:14 60:15 invariably 113 invented 42 invention 144 involved 13:15 16:18 27:12 119 127 irrelevant 63:12 issue 26 1,20,23 28 122 issues 26 1,4,5,11,41,5,11 item 137 items 97:13 J.J 149 Jack 105 Jackson 2:20 6:10 jackson.otto@huschbl 2:21 James 131 JARDINE 3:16 Jimmy 149 job 14 15,18,19,21 15,18,19,21 14,19 21:17 24:25 7,270,20 20,21,22 20,21,22 119 3,4,5 128 141 6,15 jobs 2,3,7 20:22 23:17 26:23 John 122 126 Johns 16,17,21 Jr 1:12 4 7:18 130 162 judge 131 judgment 143 judicial 5:13 July 1:16 2 143 150 152 158 159 4,13,25 June 19 K 2:20 Karst 3,4 23,2233,23 8 7 3,7,13,16 8,13,20 4,5 1,6 13 18 18:16 22:11 23:14 24:14 3,21 4,7 8,13 29:20 13,21 9,14 31:16 1,8,13 34 14 13,16,19 13,16,19 37:18 38:13 40:24 43:25 10,20 15,1165,16 49:20 8,13 51 2,220,20 53:15 54 19,2159,25 14,21 56:12 56:23 5,11,14 58 3,20 60:20 7,23 18,2138,23 65:15 18,22 69 70 8,13,16,19 73:12 75:18 2,15 80:22 83:10 85:22 86 86:12 4,7,18 88 92:25 93 3,23 13,18,25 13,18,25 8,284,24 13,2103,20 4,12,20 3,6 102 103 104 106 107 108 11,17 110 14,18 111 112 15,18 13,18 5,24 10,25 119 120 121 5,12,18 124 1,16 126 127 127 4,10 129 11,14,15,19 131 7,19 134 13,19 6,10,19 5,22,24 2,14,16 18,21 2,5,9,12 14,15 142 143 145 5,19 147 148 151 15,20 156 158 159 160 161 keep 32 80 Keli 5:18 3,17 Kentucky 24,25 kind 10:14 6,17 17:20 29:18 32 38:19 40:18 47:19 53:20 78 85 92:20 13,21 97:16 109 111 114 117 119 123 3,4,17 138 kinds 19:16 39:25 2,4 62:22 knew 31:12 71:23 76 10,16 103 122 134 140 149 know 8:19 9 9,14 16 18:19 23:10 24:18 33:14 5,6 38:19 16,2136,23 43:17 4,8,9 9,12 13,19,20 11,25 48:10 49 50 51 2,13,14,12,163,14,16 2,16,24 4,9 57:25 4,6,11 59:13 60 61 62:16 4,17,23 64:24 5,7 3,25 69:12 2,18,20,20 74:15 75:23 83:24 88 88:21 89 90:13 94 94:1148 96 97 98:23 8,12 6,18 101 16,21,25 1,11,1,11,13,233,25 1,,121,313,,223,525 19,25 5,25 5,25 1,16 109 110 110 111 112 115 4,7,13 1,8,23,21,58,23,25 120 12,15,17,19,21 122 123 3,4,15 124 125 126 24,25 128 131 131 6,22 138 12,24 139 140 141 144 145 3,14,18,19 3,14,18,19 146 3,8,9 150 9,12,13,18 9,12,13,18 6,14 152 18,18,21 10,12 12,25 158 160 160 knowledge 4,6,7,24 55 56:13 67:25 68 100 113 124 141 162 known 2 18:24 34:12 36 40 57 119 132 knows 138 Kordas 7,9,11,13 130 131 L A 3,4 labeled 146 lack 108 Lake 3:17 language 15,16 late 12,20 110 law 1:14 3 12:10 162 lawn 6,8 lawyer 146 Lawyers 147 lead 29:25 30 34:10 leam 11 51:20 leave 19 left 28:23 5,11 13,15 12,14 119 123 130 141 149 hand 150 legal 5:16 9:15 145 length 39:19 78:16 132 Leone 3:20 5:16 Let's 20 29:20 95:15 2,3 152 154 letter 131 136 letters 150 level 132 lifer 142 lightly 133 ligneous 145 likelihood 116 limit 132 limited 144 limiting 144 line 11:24 32:17 3,13 65:20 68:14 71:23 73:18 110 137 143 153 157 lines 16:18 152 list 10:18 47:22 48:16 13,14 60 87:18 10,18 96:25 97 100 110 8,10 139 148 9,12 159 14,15,17,20 160 listed 94 144 145 151 14,16,17 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 Page 167 159 lists 14,17 6 45 47 4,13 50 54 91:11 92 97:24 100 138 151 literally 49 78 154 literature 51:13 little 10:15 22 10 23 35:12 38:20 3,9 59 78 114 134 136 144 154 157 LITTLETON 7 live 13:19 104 living 17,20 105 load 29:25 30 22,23 23,2243,24 1,3,6,19,21 21,25,25 21,25,25 10,16 23,23,24,24 23,23,24,24 39:22 40:19 79:25 80:11 82:19 14,20,21,24,24 14,20,21,24,24 24,25 116 135 138 4,6,7 155 loaded 79:24 80 loading 80 82:17 loads 32:17 9,11 59 10,14,25 10,14,25 66:17 92:12 93 19,21 7,25 16,17,18 117 12,15 139 148 2,4,6,11 152 154 155 located 5:17 25:18 39 58 62:10 location 118 locations 125 lock 72:14 LOGAN 3:16 long 7 25,25 19 4,10 21:13 22:11 25:14 26:11 64 66:12 67:12 10,11 77:13 87:25 2,3,6 106 119 132 133 19,20 longer 22:24 2,4 159 Lonoke 11,25 look 5,18 47 49:22 101 102 109 110 130 132 139 140 143 2,14 4,6,6 148 24,25 159 looked 8:11 6,8 45 12,2122,22 47:15 49:21 60 65:11 68 91:13 7,8 101 15,16 looking 39 44:20 45:14 17,2157,25 8,10,21,22 46:25 11,13 59:21 61:12 22,25 65 74:20 78 10,13,23 10,13,23 12,17 12,14,22 12,14,22 97 16,19,20 101 4,8,17,18,18 103 134 150 153 160 looks 13,14,19 13,14,19 42 78 148 151 155 158 loose 116 lot 11,14 22,23 20:12 26:23 32 50 51:25 53:15 59:24 69 78:21 89:13 99:17 103 8,18 8,18 120 131 134 142 148 151 159 Louis 2:19 low 132 lower 1,12 150 lunch 14,18,21 lung 120 132 related 106 M 83:23 M 83:22 M.W 118 130 machine 15 19:17 43:11 55:16 20,23 7,9 62:24 22,25 5,153,13 15,16 16,23 76 9,13 6,7,8,14,15 6,7,8,14,15 15,1615,,16,117,19715,,16,117,919 20,21 80 14,1154,15 10,1110,11 128 machines 9,11 2,13 16,1816,,18,220,25016,,18,220,525 4,8 63:14 19,22,23 73 75:13 76:12 82:13 mag 18:10 magazine 52:17 magazines 19,22 52 52 magnum 24,24 154 154 mailed 88:17 98:13 main 35:22 36 71:12 maintain 23 maintenance 22:21 4,6 24 5,11 major 9:14 29:21 34 42 majority 10:24 11 25:25 making 33:22 34:22 55:15 16,1166,16 71:25 89:15 99:25 17,19 101 105 158 Malcom 13,1143,14 manager 27:16 141 mandril 102 manilla 89:24 manufacture 15,16 133 142 manufactured 19:14 24:18 29:22 61:23 65 124 126 manufacturer 21:21 144 manufacturers 42 155 manufacturing 24 29 29 36:19 124 127 146 149 Manville 16,17,21 122 March 10,11 16:10 19 120 123 mark 13,14 32 130 142 marked 32:11 86:24 130 142 147 market 68:22 69 marketing 22:15 118 118 119 marking 148 MARTINEZ 2:15 material 55:22 77:20 78:18 2,3 11,12 106 17,25 materials 47:18 122 matter 6 15,18 13:16 124 matters 162 McGilton 5:18 3,17 MEAGHER 3:12 mean 20:21 39:24 4,19 50:22 8,17 10,16 58:12 60:13 64:20 65 2,3 66 68 6,15,25 69:21 73:19 75:20 80:20 13,25 7,176,16 85:16 94 114 115 117 124 137 148 153 2,5,9 10,11 155 158 159 160 Meaning 39:10 means 27:12 45:20 48:14 51 14,16,17 60:14 65 66 68:17 73:20 78:17 79 94:10 137 138 146 150 153 154 155 157 meant 27:11 measure 49 MEC 83:21 mechanic 14:11 mechanical 23,24 16 24 mechanically 44:24 medical 19,21 meet 12:12 meeting 8:1136 12,13 14,21 10:20 31:24 48:21 2,6,9 92 96:21 98:25 members 16 17,20 membrane 132 memorized 14 memory 8:14 91:16 92:14 100 17,18 108 108 mentioned 9:22 18,19 26:14 28:24 30:21 35:21 36 38:23 39:21 40:13 42 44:21 114 118 121 131 141 143 157 messing 33:18 met 47:23 metal 14,15 39 72:16 79:16 84:10 153 method 132 Michael 12,17 microns 132 mid 26:24 2,18,24 2,18,24 46 46:17 middle 7:19 military 17 mill 132 milliliter 132 mind 26 31 105 158 mine 3:15 99 minimum 131 Minneapolis 4,13 Minnesota 1,12 5:14 9 minute 130 148 minutes 8:1136 12,13 14,21 10:20 98 20,22 missing 112 152 11,13 Misstates 55 87 111 112 123 127 misstating 112 mistaken 141 Mistakes 145 mix 12,13 14,16 mixer 76:25 77 mixing 76:13 6,8,14 mixture 77:22 145 MN 2:24 4,13,17 MO 2:19 mold 43:12 63 78:12 molded 42 6,8,8,9,10 63:19 72 6,11 144 molding 36:25 1,2,18 19,24,25 19,24,25 63 4,7,14 7,8,9,13 money 160 monitor 15,19 monitored 128 monitoring 4,8,10,11 13,14 122 126 127 Montague 3,4,5 month 55:12 90:16 monthly 10,1110,11 months 11 25,25 87 18,19 159 Morgan 131 MORING 2:13 moming 5 3,4 137 161 Mortgage 131 Mortl 2:11 2,2 12,15 10,17 11:19 12 13 3,135,15 22 23 24:10 1,18 27:25 28 29 7,11,16 30:10 30:19 10,19 3,7 11,15,18 37:13 38:11 40:22 43:24 44:12 48:11 49:17 2,11 51 7,23 52:19 12,25 18,23 7,18 8,21 2,9 12,24 58:25 59:18 60:19 4,21 17,21 65:13 15,20 68:24 7,12,14,17 73:11 14,2144,24 76:11 80:19 83 85:14 3,6,15 88 92:24 5,25 94:18 10,15,22 96 96:19 10,15 1,17 102 103 104 105 106 107 108 10,15 110 12,17 111 112 11,17 10,17 1,22 7,21 119 120 121 122 122 20,24 124 124 125 1,22 13,23 129 130 130 131 4,18 133 12,22 135 136 137 19,23 15,17,20 1,3,7,10,13 143 145 2,13 151 11,17 21,24 159 161 mouth 36:21 67 move 26:15 84:23 141 moved 26:10 16,22 124 movies 17:21 moving 27 Mugaas 17,17 multiple 56 57 58 5,8 71:21 72:19 75:19 79 90:10 Murtha 1:14 4 162 N 4 name 5:16 7:17 40 43:21 66 77:13 127 named 162 names 28:11 76 103 104 118 147 1,13 narrow 10:14 necessarily 15,17 57:19 63 129 necessary 132 need 5 11:24 34 36 48:10 58:25 14,15 82:19 84:25 98 104 135 needed 32 57:13 needs 16,19 Nemours 1:13 8,22 never 22:15 67 93:14 140 9,12 newer 34:21 37:12 nine 127 NJ 8 Nod 29 nomenclature 37 reloadable 134 nonresponsive 99 Nope 140 normal 89 Notary 162 notation 138 156 notations 139 note 46 notes 4 11,15 32 32:10 44:21 68:15 notice 8,9 31:11 113 noticeably 102 noticed 16,1176,17 number 5:15 12 23:24 9,12 62 113 114 139 142 143 145 148 153 154 155 155 157 numbered 143 numbers 1,5 32 19,20 145 148 153 9,19 numerous 8:20 NW 2:14 O'BRIEN 3:16 oath 162 Object 158 objec7:t10i1o 8:n 15 24:10 26 27:25 28 7,11,16 30:10 3,7 11,15,18 37:13 38:11 40:22 43:24 49:17 50 50:11 7,23 52:19 12,25 18,23 55 55:18 8,21 2,9,12 57:24 59:18 60:19 62:21 17,21 65:13 15,20 68:24 7,12,14,17 14,24 76:11 80:19 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 Page 168 83 85:14 87:15 95:10 96:19 10,15 99 102 103 105 106 107 109 8,12,17 111 6,11,17 10,17 116 119 120 121 3,7,15 20,24 124 125 126 127 127 18,21 12,22 135 136 137 143 145 146 151 11,17 158 objections 146 obtain 8:16 obtained 52 obviously 16:24 32:24 38:23 122 129 153 157 occurred 74:17 oddball 110 oddballs 110 office 23:25 25 48 142 Offices 1:14 3 162 oh 28:14 97 oil 17:19 Oiste 3,5 25,25 98 okay 11 23:13 26 28:24 29:21 52:13 59 64 67:16 6,9 90 98 108 4,22 117 7,11 133 134 140 141 145 4,19 153 153 154 155 156 157 old 93 timers 34:20 oldest 52:17 Olin 2:18 6:11 omission 151 once 47 64:16 73:15 79:22 103 135 one's 8,9 109 page 32 sided 32 ones 8:19 10 12:18 52:12 68:11 8,9,11 12,14 110 15,16 135 139 7,11 onsite 75:11 operated 11,12 75:23 4,10 77 82:13 128 operation 19 22:22 72:12 75:17 1,5,7 8,182 ,12 84 9,12 123 6,7,20,22 operations 8 opinion 128 129 opposed 30 46:17 order 77 84 96:22 Ordinarily 154 organizations 33:17 originally 10,10 Otto 2:20 10,10 ounce 17:18 outcome 162 outer 17,20 outside 10,16 30:13 38:13 39 41:21 78:15 2,24 86:17 89:17 91:14 107 108 110 114 18,2158,25 powder 34:19 40 overall 27:16 Overbroad 110 117 121 127 overlap 125 overlapped 125 overpowered 33 oversaw 27:12 Overseeing 22:21 overwhelming 11 P P 4 P.A 2:23 p.m 4,9 5,150,10 136 136 16,2156,25 161 package 9,10 packaged 80:13 121 126 packed 99 page 5 31:14 111 114 131 143 143 144 145 149 150 1,2,3 154 13,21,22 156 5,6,15 pages 10:13 89 91:17 96:14 139 156 paid 27:13 paper 30:22 31 14,20 36:17 39:12 64:13 65 10,16 14,17 94 4,10,17,21 97 7,9,11,13,20 107 5,8,9 151 158 158 9,10,16 paper 134 wound 102 papers 88:24 paragraph 2,8,16 145 146 paragraphs 146 Pardon 50:19 parenthetical 24,25 park 7 140 141 7,10 part 23:25 24:16 5,7,11 31:21 39 6,7,9 73:24 78:12 15,20,22 15,20,22 115 119 142 143 7,10 partial 98:21 131 partially 89:12 particular 17 18 40:19 54:12 12,13 96:22 138 143 parties 11,11 parts 24 29:14 30:16 34:12 20,25 77:24 79:15 15,17 149 pass 105 passed 8,10 106 Pat 6:15 pat@elliottlaw.net 5 patent 4:10 7,8,9,18 21,25 10,16 14,17 145 147 patented 142 patents 140 PATRICK 4 Paul 2:24 pay 14:12 pellet 155 pending 95:17 99 Penn 149 18,19,20,25 Pennsylvania 2:14 people 22:23 2,10 13,13,15,113,173,15,17 28 48:24 53:19 15,17 76 103 17,20 118 120 122 3,4,21,25,25 128 people's 27:13 percent 131 1,6,7 12,13 145 12,13,15 percentage 19,21 percentages 144 perfect 135 performance 134 performed 24 period 16,20 27:19 30:25 31 42:22 80:21 86:18 118 123 139 157 peripheral 16:17 person 7,8,12 27:21 162 personal 3 5:13 82:21 82:23 83 106 120 127 160 personally 50:12 3,5 58:12 82 persons 132 peruse 142 144 Pete 6:14 PETER 2:24 phase 132 133 phased 63:24 111 phaseout 8,14 phone 9 7:11 12 128 161 physically 91:25 118 Physicals 119 pick 160 picture 149 piece 36:10 5,254,24 41:19 42 97 116 140 151 pieces 10,12 making 77:19 pin 22 pistol 18:10 22 125 pistols 17 piston 34:20 8,11 11,13,15,17,19 11,13,15,17,19 60:11 15,21 61 62:20 13,17 84 116 pistons 61:23 62 18 1,4,8,14,20,23 1,4,8,14,20,23 64:10 80:23 83:10 place 16 110 135 placed 58:20 places 83:21 plain 121 Plaintiff's 4 8,9 32:10 130 142 147 Plaintiffs 6 2 12,24 6 plant 19 19,22,22 15,16,20,21 4,24 4,4,14,34,13 9,195,15 27 16,17,18 28 55:17 17,20 59:25 118 2,5,7 122 123 123 2,13,17 126 10,12 149 plastic 14,22,214,422,24 31 32:18 34:22 17,25 39:12 40 2,4,25 2,18 46 3,5 14,2134,23 61 65:25 6,6,23 1,17 68:17 19,2109,20 21,2214,24 71 2,19,25 10,1160,16 6,24,25 75 79:16 2,12 85:22 93 106 11,15 10,11,12,13,14 10,11,12,13,14 7,21 1,25 111 19,21 4,20 113 114 134 135 10,22,22 155 3,6,23 platens 77:21 Plaza 2:19 please 5:20 115 153 plenty 82:20 plus 144 point 3:16 13 59:16 64:19 72:16 101 109 132 143 144 149 pointing 143 polyethylene 42:25 43:14 17,21,22 3,4,7 Pont 1:13 8,28,222 5 3,6 6:14 7:24 15,22 11 21,23 44 popped 41 population 132 portion 99 position 150 possessed 140 possesses 140 possession 12:24 98:15 98:22 99 possibly 116 117 147 potentially 27 pounds 121 poured 11,14,15 76:25 77 powder 2,4 36 42:14 77 80:10 4,5 84 154 power 34:20 8,10 11,13,15,17,11,139,15,17,19 60:11 15,2115,21 1,23 62 18,2108,20 1,4,8,14,20 1,4,8,14,20 63:23 64:10 80:23 83:10 83:13 84 116 PP20 158 PPA12L 157 made 43 2,3 scored 58:19 preceded 102 134 predict 132 prefer 129 preferred 37:16 144 prepare 9 present 7:11 6,21 144 145 president 20 press 57 79 20,20 20,20 84 presses 58:16 pretty 24 31:24 78:20 89:19 114 123 135 142 148 previous 9:15 price 14,17 6 10:18 45 47 4,13 50 7,13,17,413,14 91:11 92 97:24 100 8,10 138 139 primarily 24:20 34:10 35 37 38:12 15,16 primary 32:23 prime 79 81:15 primed 79:23 80 primer 4 22 7,8,9 12,16 38 17,17 79:18 81 2,9,17,18 130 131 primers 80:24 Pringle 2:10 prior 10:18 15:17 16,20 53 92 96:21 112 120 152 privilege 11:23 probably 14,16 52:23 54:13 61 82:13 97:18 101 103 105 114 115 117 119 122 124 131 135 138 140 143 problems 135 procedure 1:12 9 120 proceedings 13:10 process 8:13 36:19 47:14 16,17 49:19 50 8,20 56:25 71:25 73:12 6,160,10 76 23,25 2,3 80 15,16 4,12 103 142 21,23 processes 9:24 produce 8 produced 10:12 54:17 139 19 6,11 148 10,12,14,15 159 producing 125 product 5 16:18 22:11 22:25 24:14 43:12 50 71:23 126 2,20 155 157 160 production 11 20 18,19,218,019,20 22:1134 5,6 3,130,10 56:10 76 94:10 109 110 121 124 24,25 141 149 159 products 10,24 12:23 16:18 19:14 21:22 126 140 159 program 5,8,9 127 128 7,9,14 progression 46 project 82:18 115 projectile 8 129 130 2,15,15,17,18 131 132 projectiles 132 136 projects 119 propellant 42 proper 129 Properties 1:13 8 5:10 6 7:25 10:23 11 property 23:23 128 proportions 78 protecting 42:17 protection 42:12 protective 127 protector 40 protects 40 proudly 22:16 PSI 77:23 Public 3,17 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 Page 169 publically 55 publication 4 publications 159 pull 115 Pumps 3:12 6:17 punch 4,20 16,21 23,2233,23 72:11 14,14 punched 55:22 3,8 58:16 punches 57 77:21 78:17 punching 58:19 pure 44 159 purports 151 158 purpose 32:23 110 119 purposes 82:21 pursuant 1:12 8 put 36:21 21,22 41 42 43:18 54 67 81:14 19,25 1,6 1,4 89:25 95:18 96:18 4,9,14 110 117 122 159 putting 46:17 Q qualified 143 qualities 42:13 quality 113 question 11,12 35:19 35:20 48:12 93 94 95:17 4,4,22 103 104 111 113 115 124 132 133 137 138 145 151 157 questionable 82 questions 86:24 98:12 139 3,8,10 160 quite 20 24:12 4,12 42 136 R & 46 18,2118,,221,222 104 109 12,13 117 118 R.M 149 rail 121 Ralph 149 rammed 79 Ramsey 1:25:14 range 18:25 rare 84 rates 132 raw 76:25 122 Ray 3 4 86:10 161 Raymond 1:12 6:20 7:18 162 read 9:23 40:17 51:15 52 53:19 59 65:25 6,6,13,15,17 94:23 3,8,21,23,25 96:22 15,19,22 131 136 23,24 152 reading 46:12 143 145 ready 79:23 86:12 real 77:22 really 20 23 26 33 53 59:2593 :23 63:10 83 91:12 101 102 103 125 149 158 159 reason 32 46:20 54:21 93:24 126 128 reasons 134 recall 10 6,11 47:21 4,18,20 55:24 57:16 58:14 62:17 63:10 64 66:21 67:11 71:12 74:18 74:19 75:25 76:22 77:12 104 16,17,19 110 115 121 123 124 126 127 133 149 received 7,20,22 131 recognized 132 recollection 9,16,21,23 5,9,10,12 53:11 55 14,17,19 21,23 61:13 16,18 70 20,21 98:20 99 8,11 recollections 53 recommends 132 record 2,21 8 7:17 14,19 5,11 98 98:11 111 123 130 13,1183,18 140 140 15,17 148 161 162 record's 64 records 12,13 14,16 17,17 49:19 50 53 4,12 119 RECROSS 4 Red 8 REDIRECT 2 reduced 131 162 refer 144 145 reference 137 referenced 148 referencing 151 referring 34:14 40 79:13 106 144 147 reflect 9 reflected 17:18 reflects 132 refreshers 8:14 refreshing 92:14 refute 160 regarding 8 27:20 126 127 130 Regardless 74 100 regards 18:12 20:18 regulations 9,12,14,15 relate 145 related 12:22 22 52:20 95:20 relates 60:22 61:13 145 relating 60:17 relations 17,21 26:12 7,10 28:20 relative 10,11 relatively 5,150,10 41:13 relevant 63:13 16,20 93:23 94 5,12,16 reload 85:25 94:11 reloadable 94:22 reloaded 6,24 83:12 85:19 118 reloading 82:11 5,6,15 16,25 84 94:21 remarks 153 remember 12 24 26:16 28 45 50 52 53 53:17 60 61:20 2,6 88 90 3,5,5,13 92:16 8,188,18 97:19 98:18 103 160 RemGrit 12,13,23 20 20 Remington 12,22 2,10 9:23 13,15 16 12,17,17 3,18 9,193,13 8,12,16,23 8,12,16,23 30:18 33:23 42 4,4 43 51:19 53 9,11,18 11,14 63:19 66 68:23 69:22 2,6 20,22 3,21 79:25 15,17 12,15 85 91 13,24 100 103 105 106 4,14,18,19 119 122 130 132 133 138 140 7,16,19 3,12 149 153 158 Remington's 40 45:11 126 Remington 158 removed 123 141 repacked 4,5 117 117 Repeat 35:20 replaced 65:21 66 67:14 68:13 69 17,19,24 84:25 107 108 114 reporter 4:12 19,2192,22 23 represent 5:21 10:10 represented 4,7 11:20 27:15 representing 2,8,18,22 2,8,18,22 2,7,11,15 7:24 11:16 research 13,14,15 13,14,15 10,13,15,17,18,23 5,7,8,9,10 9,10 119 130 131 141 residue 20,22,2204,22,24 respect 116 responsibility 20:23 responsible 6,7,16 rest 17,17 50 retained 4:12 retired 141 retool 73 review 10:11 13,17 55 15,20 7,11 reviewed 8:19 9:12 10 95:14 Rickey 21,23,25 142 147 Ricky 141 rifle 22 125 155 rifled 91:14 Rifleman 51:25 52:10 rifles 17 52:20 right 11,20 10:20 19 25:12 33:23 2,15 5,8 51 56:19 59:16 19,21 81 85:20 87 96:24 4,8,23 16,17 111 112 4,19 120 123 136 140 5,25 2,8,15 147 149 150 5,14 153 155 157 hand 142 143 rim 2,3 29 38 72:13 131 rimfire 8 24,25 22 24:23 2,3,5 125 130 131 141 147 149 Robert 5 2 6 11 Rocco 3:20 5:16 room 82:17 98:24 127 rotary 77:20 79 83:20 rotate 77:21 roughly 28:20 31 46:14 96:14 103 118 119 141 rounds 131 route 95:16 row 57 RP20 157 RPA12L 10,11 RS 155 rubber 41 Rule 1:12 Rules 9 rundown 40:18 RXP 21,22,23 66 67:14 68:13 2,8,12,08,10 69:17 107 108 112 114 124 138 s A 105 SAAMI 155 safety 3:15 5,8,20,23 1,2,9,13,11,2,96,13,16 119 127 128 sale 46 sales 8 sanctioned 33 saw 71 121 139 saws 15,16,17 saying 53:22 60:25 63 65 111 116 128 says 22 32:13 69 100 130 11,18 142 6,12 144 2,10 151 152 153 154 155 9,15 158 Scanlon 17,18 schedule 125 school 13:25 2,4,5,15 14:25 score 58:22 scrap 117 scratch 41:10 sealed 42:13 search 132 second 2 8,9,12 125 145 secret 121 section 36:20 38 99:23 sections 23:21 42 security 27 see 31 32:16 49:15 84 109 121 136 139 2,4,8,18,22 2,4,8,18,22 143 145 19,22 150 151 160 seeing 55 seek 14,18 seen 17:21 43:25 44 50 16,21 140 sell 80:17 selling 9 sells 80:15 send 80 99 senior 15,18 5,9 sent 98:25 separate 27 7,14,15 36:22 37 40 42 68:13 107 September 142 143 159 sequentially 84 123 serial 143 series 8:20 20,21,25 2,6 28:25 14,15 7,11 63:19 122 seriously 137 service 15 set 58:21 135 151 seven 145 3,10,24 146 155 SGPI 6,12 148 Shared 20 sheet 31 49:13 22,25 57 20,2220,22 86:23 87 96:18 16,19,21 106 152 sheets 9 2,3,23,22,35,23,25 74:20 shell 18:24 19 1,2 23,23,23,24 23,23,23,24 6,261,21 32:14 34:13 36 7,10,10 16,16,20,23,24 37 1,5,15,18,23 38 9,13 16,20,21,23,24 16,20,21,23,24 39 7,8,9,17,4190 41 22,23 17,18,20 17,18,20 64:13 1,10,16,21 4,7,8 67:15 68:13 3,5,21,25 70:22 71:19 72 3,13,14 73:22 7,8,14,22,27,8,134,2,23 80 82 7,19,27,519,25 84:14 16,21 2,16,18,19 2,16,18,19 85:25 14,17 3,4 94:11 101 12,17 4,24 111 17,18,19 4,24 2,7,20 5,24 7,18 14,2144,24 117 124 3,5,7 137 138 138 146 8,22 153 155 making 78:25 79 shells 12:23 3,21 32:18 34:21 37:10 38:14 59 59 15,2135,23 61 65:23 9,9,9,92,23,2539,,9,223,525 67 10,12,110,712,17 14,1164,16 69:22 2,5,20 5,9 18,21 74:23 75:19 1,25 80:18 82:24 5,7,12 17,22 96 1,15 110 111 19,21 114 115 132 13,17 137 146 ship 89 shipment 91:19 shipments 90:10 91:23 shipped 43 88:24 5,8 126 shipping 89:25 shoot 33 15,16 85:19 94:11 114 15,20 117 129 shooter 147 shooting 18 24,25 7,8,11,16,17,19 12,13 85 10,14 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 Page 170 16,18 116 117 118 129 short 133 shorthand 95:19 shot 16 29:25 30 33 10,2150,25 1,1 36 37 4,4,5,6 10,12 42:1148 4,5 113 16,21,23,24 114 14,25 116 10,10 shotgun 12:23 17 18 22 38:14 39 40 42:18 74:22 80:18 82 83:12 96 125 129 146 shotguns 17:25 52:20 shots 135 shotshell 4:11 21,25 1,6,12,15,16,17 18:12 23,24 17,18 22,22 22,22 28:24 4,15 29:19 30 75 93:21 94 123 10,11 129 135 4,22 148 160 shotshells 38 108 115 126 147 158 159 2,19,20 show 19,21 60 101 130 142 158 showed 10 56:16 showing 159 shows 94 101 137 side 17,21 sides 38 signed 131 signers 142 signs 122 1,2,5 126 128 similar 29:10 Simmons 6,7 77:10 127 simple 77:25 79:17 simpler 72 single 74 sir 87 91:21 129 132 133 site 61:23 sitting 97 Sixth 3:13 size 36 39:15 89:17 16,20,23 116 sizes 39:13 skeet 11,16 slag 132 slash 25 60:10 slide 8,10 slight 125 slow 23 35:11 58:25 95:15 98 slug 17:18 154 155 small 22 78 83:20 97 129 smaller 41:15 99 114 sold 20 23,24,25 23,24,25 81 2,8 solid 78 somebody 27:22 28:16 43 103 sorry 26:19 57:15 1,8 72 82 83:17 87 106 112 114 126 155 156 158 159 sort 9 92:13 94 102 102 116 120 sorts 8:13 17 sound 72 sounds 121 source 11 91:23 South 3:13 SP 21,23 SP12 6,8,11,13 SP8 20,23 spare 75:16 speak 86:17 147 speaking 23:10 130 specific 8:19 10 15:19 16:20 25:15 33:14 37:12 45 9,10,11 53:23 6,8 11,15 57:20 59:13 60 15,17 73:12 92 8,11,17 93:10 93:11 97:13 107 109 11,15 128 134 139 150 specifically 11:11 28 54:11 11,16 57:16 62 68 71:12 91 99:21 5,18 101 108 115 121 127 133 145 145 146 specification 151 23,24 23,24 specifications 4:11 40:17 111 125 147 19,20 19,20 155 159 160 speculate 134 Speculation 119 120 spell 71:16 104 Spencer 104 spent 96:16 116 117 spoke 6,11 Sporting 1:13 8 5:10 3 6 7:24 16,23,25 16,23,25 11 155 sportsmen 33 spot 83:25 85:19 sprayed 132 St 19,24 stack 88:22 89:16 stacked 102 staff 27:18 Stafford 142 stamped 30:17 148 stand 17:21 150 standard 89 112 23,24 23,24 154 155 17,20,23 standardized 19,22 standards 155 standpoint 134 stands 83:24 138 157 start 7:14 77 94:14 94:21 114 116 120 124 161 started 5 15:13 19 34:21 47:15 53:23 99:24 100 101 103 125 starting 61 67 95:11 132 starts 2,16 state 1 2 14,20 7:16 71:18 85 162 statement 152 162 States 4:10 8,17 stay 20 74:12 116 stayed 119 steel 79:14 132 17,19,20 step 20 77:14 79:17 stilling 100 stop 160 stopped 16,19 stops 84:22 stored 12,1142,14 straight 17:22 32 Street 1:15 2:23 3,8,13 5 162 strike 83:11 118 154 strikes 22 striking 22 string 46:13 strong 135 stronger 37:17 structural 132 Studios 5:17 study 148 studying 17:18 87:17 stuff 10 5,15,16,21,22 14:13 43:11 6,8 13,20 53:21 54 85 92:16 97:20 99 subcomponents 30 subscribe 52:10 substance 128 substantially 12,13 substitute 14,22,24 4,10,20 substitutes 132 sudden 111 suggest 101 suitable 132 138 Suite 10,19,23 8,13,16 8,13,16 summary 3,8,19,23 summer 14 2,3 19:20 superfluous 160 superintendent 25:17 26:11 28:19 149 Supervises 9,21 supervising 22:24 Supervision 25:21 supervisor 7,8,19,19 21:20 12,14,16,19 12,14,16,19 23:15 3,24 4,13 28 121 130 140 149 supervisory 20:23 suppliers 122 supposed 160 supposition 159 sure 16:23 24 25:16 33:20 36 42:22 44:12 45:15 47 64 67 1,2 91:16 98 104 110 126 128 134 9,23 149 150 surface 41 surprised 136 Surrounded 39:11 surroundings 20 suspending 161 Suzanna 6 2 6 swear 5:22 switched 93 113 114 switching 114 sworn 6:21 162 system 117 systems 17 T 2:11 take 44:10 49:11 86 87:25 88 1,3 119 130 131 133 136 148 taken 1:14 4,11 8 124 133 takes 135 talk 11:24 145 talked 11,15 53:19 81:18 105 135 147 talking 17:12 22,23 34:16 22,22 39:17 48:13 7,8 60:22 64 79:12 80:21 82:13 85 90:16 13,15 14,20 94:21 107 21,23 118 136 158 talks 131 tall 89:16 tannish 102 tape 86:10 160 161 target 17 18 24,24 32:25 1,4,7,7,10,19 21,2251,25 9,16,9,16,221,2319,1,6,221,323 35:24 36:12 8,9 10,14,25 10,14,25 20,23 4,8,9,164,8,,9,16,22,2542,8,9,,162,22,525 67 12,16 12,16 12,14,16 12,14,16 3,5,21,22,25 2,5 20,2202,22 71:19 73 74 3,4,6 107 1,18 109 112 112 113 114 114 12,15,22 139 148 2,4,6 151 18,20,23 1,2,4,19 3,21 3,21 15,16 Taska 12,17 tax 20:12 tear 110 Tech 19,25 15 technician 5:17 technique 132 teleconference 2:17 tell 11:17 31 60 62 93 100 12,13 102 19,20,22,219,520,2 ,25 104 6,23 110 125 128 136 151 153 154 154 157 160 telling 87:13 20,21 tells 99:24 100 temperature 7,8 75 75:10 ten 155 tenure 28 term 128 129 terming 143 terms 16:22 39 test 1,1,1 tested 117 testified 96 testify 162 testimony 55 87 94:24 3,20,23,24,25 111 112 127 162 testing 85 20,23,25 23,24 137 thereabout 99:25 thereabouts 107 thereof 108 142 thick 41:19 thickness 6,23,26,423,24 81:24 82 thin 49:11 thing 8 6,18 17:19 26:14 36:18 37 45 47:19 84:20 85:17 92:13 116 125 130 133 158 159 things 8:12 27 32 43:15 45:16 46 47:15 15,17 59:24 62:17 63 69 71:22 72:12 84:14 97:17 99:18 108 108 15,1165,16 135 143 151 think 10:17 13 14,18 26:23 39 11,13 54:12 63:10 75:15 76:23 88:24 91:11 98:16 16,20 108 109 110 3,10 121 123 9,24 127 127 130 8,10 150 160 thinking 26:24 32 137 thinner 89:13 third 125 155 thorough 127 thought 36:22 63 98:23 109 117 118 Thousands 89 three 20:13 22:16 25:15 23,25 52:16 58:10 15,18 88 96:16 158 three 92 threshold 132 threw 52:12 time 9:19 17,21 12:17 17:10 16,20 8,285,25 26 27:19 4,17 13,18 45:23 46:13 53:17 55:10 5,6 60:16 61:16 69:11 76 77 80:20 81 82:18 82:22 84:19 4,9 90:14 91:25 3,13 5,10 101 105 106 107 108 109 118 122 3,12,13,312,13 7,22 128 131 135 12,17 138 139 141 16,25 21,21 157 159 159 161 times 41 119 125 timing 46 59:24 title 9 20:11 13,17 22:18 25:14 28:22 142 titles 20:12 96:23 today 7:23 8 11 80:21 160 161 Today's 5 told 10:17 44:24 49:18 97:18 111 133 134 136 tomorrow 161 tooling 58:21 tools 15 79 top 10 32:17 93:19 104 105 138 153 160 topic 98:13 topics 7:25 114 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 7/18/2018 Page 171 totally 135 touching 162 tough 9,12 135 142 toxicity 8 130 131 track 38:20 trade 40 66 trades 14 trained 128 transferred 118 transition 30:25 31 42:22 transitioned 31 transported 78:25 trap 11,17 Trattles 2:15 5,5 10:24 11:15 156 tricky 133 tried 127 trigger 115 truck 121 true 63:22 100 162 truth 160 162 try 94:11 trying 46:15 49:16 53 56:19 68:15 23,25 100 101 108 112 113 135 139 148 151 4,25 tube 18,18 72:11 84 84 twice 141 two 1,4 20:15 21 5,16 22:16 25:15 26:13 28:21 34 52:16 58:10 86:10 10,11 19,23 107 110 3,4,11 127 7,8,11 148 152 153 156 158 page 142 three 21:15 TX 4 type 3,6,18,19,22 16:20 21:11 9,14 36 37:12 40:13 44 62:23 66:18 70 73:10 75 75:13 79 7,19,19 106 109 114 115 117 121 126 154 types 30 33:10 66:19 155 typical 129 130 typically 33 34:17 36 41:20 U huh 9:11 12:14 14:21 15:12 16:11 40:15 47 48:18 49:23 56:24 58:17 60:12 87:24 88:12 100 103 107 22,25 113 123 6,19 137 143 144 153 156 158 unaware 47:10 understand 7:23 23:20 29 35:19 46:15 49:14 49:16 50:22 53 56:12 56:19 68:15 23,25 93:16 100 101 108 111 112 13,22 115 139 148 5,24 160 understanding 129 underway 120 unibody 36:24 1,2,15 18,24 9,13,16,20 22,23 66 67:14 13,1813,,18,119,20913,,18,219,020 2,8 10,17 21,22 13,1163,16 108 112 114 union 2 6:15 27:14 44 44 unit 140 141 United 4:10 8,17 universal 83:21 upper 45 130 142 143 use 4,22 1,3,10,19 42 45:21 1,12 83 85:17 96 100 107 129 134 4,5,5,13 useless 81:15 user 81:11 users 147 uses 18 85:13 144 usually 84 146 153 154 Vv vacation 15:16 vague 18 50:11 59:23 66:15 73:11 88 107 108 113 116 117 129 value 132 variable 80:10 varies 76:22 variety 73:21 various 8:13 9:24 16:17 14,15 132 vary 41:24 76:20 varying 41 144 vendor 1,4,6 vendors 8 56 versa 33 versus 7 25:25 31 83 110 7,20,21 113 viable 134 vibrations 17:18 vice 20 33 video 5:17 videographer 3:20 5 13,18 4,9 5,10 12,17 16,25 161 videotaped 1:12 3 VIP 5:17 Visually 102 voluminous 10:14 148 von 3,5 25,25 98 VRV 150 W W 2:24 W.L 149 wad 11,20,20 21,21 5,6,8 2,5 4,5 41:17 1,2,2,6,6,8,20 42:24 43:22 45 46 47 58:15 73:10 75:18 10,13 16,17,18,20 3,5,5 99:14 2,3,4 6,10 142 143 11,25 1,4,11 147 2,12 158 Wadding 14,14 wads 29:24 30 14,20 21,23,24 35 38:17 39:21 1,10,13,18,21 40:24 41 45 18 50 50:24 2,6 53:22 54 55:21 57:16 58 62:22 23,24 63 15,20,24 1,7 78:23 79 80:10 24,25 81 116 133 135 145 Wait 31:19 walking 80 Walnut 10,1110,11 wane 81 WANNING 2:24 want 11 31:13 36:21 38:21 41:22 44:10 53:16 67 103 104 142 148 wanted 73 118 wants 133 warn 126 warning 121 122 16,18 136 warnings 22,23 128 Warren 3:12 6:17 Washington 2:14 wasn't 27 50:14 58 61:16 65:18 76 77:13 82:23 87:17 93:15 97 103 121 138 Waterbury 5:18 wax 76:18 5,6 145 way 59:16 63:10 73 89:21 101 124 126 152 160 we'll 31:14 104 157 161 we're 6,22 17:12 34:18 39:17 64 80:21 86:11 93:13 111 12,18 12,17 148 160 160 161 we've 7:25 2,24 114 114 136 149 weak 15,18 weapon 17 wear 85:24 wearable 135 weeks 90 91 weighed 78:20 weighs 156 weight 10,24,25 1,2 1,2 131 15,17,18 145 154 156 went 14:17 36:18 49 4,6 91:25 92 94:10 105 123 149 159 160 weren't 11:16 100 West 3,8 wherewithal 81:12 white 102 156 looking 102 wife 6 7 Wildman 7,9,10,21 105 winter 15:17 wish 143 wit 162 witness 4 5:22 4 8 12 13 22:10 23:13 24:12 2,19 1,6 12,1182,18 11,20 31:21 34 37:14 38:12 40:23 49:18 3,12 8,284,24 53:13 2,24 55 19 56 57 3,10,13 58 2,19 5,22 63:22 16,2116,21 68:25 15,18 15,2155,25 76:12 80:20 83 85:15 87:16 93 2,19 95:24 96:20 12,1162,16 98:19 102 103 105 106 107 108 109 9,13 9,13 7,13 113 2,23 117 117 119 120 121 4,8,17 123 4,24 125 126 15,24 128 129 131 6,23 13,24 135 136 137 138 140 140 143 145 3,15 151 152 152 156 158 8,13 wood 76:17 4,5 144 word 128 129 155 words 36:21 67 work 12,24 6,8 19 20:25 23:15 82:24 105 23,24 115 115 118 119 141 worked 15 2,5 17 10,11 18:17 19:20 50 100 104 105 106 108 110 118 5,14,16 119 141 workers 23 119 120 working 27:20 13,17 82:19 100 109 141 works 51:20 85 world 114 worst 85:16 worth 49:11 wouldn't 65 12,19 119 160 wound 10,11 Wow 140 write 31:25 22,25 22,25 46:16 87 writing 46:22 143 162 written 45 54 1,3,4 93 96 138 147 wrong 153 wrote 44:24 86:23 92:19 97:19 106 114 152 X 4 97 Y A 104 Yacko 10,11 105 105 yards 127 yeah 19:16 28:14 41:14 46 47:21 75:25 year 26:16 45:12 46 9,10 11,16,23 50 55 55:12 64:13 1,8,9,16 67:16 68 74:19 90:16 90:17 93:17 3,4 101 103 106 7,13,14 24,2254,25 years 8:20 14:20 20 5,13 20:15 21 5,14,15 22:17 25:15 26:13 28:21 48 49:11 16,16 67:15 68 3,5 77 93 106 23,24 110 118 132 6,20 yellow 19,22,23,25 19,22,23,25 10,14,15 110 6,14,21 112 113 114 151 157 yesterday 8 47:23 87 9,14,17,19 1,3,5 96:17 Yup 124 Z A 126 Zapp 126 zinc 24,24 8,9,10 154 0 00 9,10 9,10 06602 131 07701 8 1 1 4 8,10 44:21 86:24 131 137 148 1,10,20,20,21 152 152 1:15 86 1:28 98 1:32 98:10 10 114 gauge 19,2129,22 154 154 10,000 10:13 10:00 161 10:18 3 100 2:10 3:16 121 131 144 1001 2:14 1001353 148 1001367 148 11:07 44:13 11:23 44:18 12 13,2143,24 2,13,22 38:12 67:10 69:22 72:21 114 115 150 152 158 4,5,6 159 gauge 19 29:20 33:22 1,18,19 35:17 38:21 39:18 65:24 66:11 12,16 4,18 68:14 68:16 6,8,16,58,15 3,10 70:19 2,19 72:24 5,9 112 5,13 115 24,2254,25 154 155 156 157 158 gauges 66:14 12:10 86 120 3 12M 157 Doby Professional Reporting Inc. 952-943-1587 Raymond A. Anderson Jr. 130 4 1354 153 1355 154 1356 154 156 1357 156 1359 157 158 1365 157 158 1367 6,17 141 8 142 4:10 147 4:11 15 145 15,000 77:23 16 13,24 18 13,22 114 1666 142 17 130 18 1:16 1:16 2 76 3 9 18/19 76 77 20004-2595 2:14 2014 9:16 13:11 2018 1:16 2 4,13 202 2:15 2022 162 211108 143 22 22 227-9411 2:25 22nd 162 22s 1,7 2409 3 250 131 260 153 7:22 27 28 78:22 : 281 290-6504 3:18 3 6 142 : 142 60 144 145 2:19 60s 31 15,16 49:12 52:24 : 52:24 13,20 80:22 : : 99:15 104 105 : : 110 12,14 61 32:17 14,19 101 5,7,9,10 104 106 107 108 5,14 CV 18-169 4 5:15 2:15 624-2601 2:15 63 14 32:17 2:19 63105 2:19 64 137 139 151 : 1:15 : 4 18th 162 19 99:11 143 : 2:19 190 2:19 1930s 53 4,10,12 10,24 | 1945 7:22 13:21 45:13 19500 3 1950s 45 3,18 46 1950s 1960s 33:12 1961 32:20 59 20,25 | : : : | 100 7,8,11 107 1962 143 1963 59 1964 9 60:10 3,13 137 148 1966 26:17 14,16 64:13 | 20,23,25 2,9,16 | 94 143 1967 137 148 1968 15:17 30:23 47 50:15 5,10 65:20 4,10 67 18,2108,20 73:23 10,16 111 150 152 158 3 4:10 57:14 15,17 3/4 156 3:04 147 3:15 147 3:43 161 30 2:23 78:22 141 144 145 30.02 1:12 300 20,21,25 2,6 28:25 15,17,18 58 7,10 63:19 17,18 18:10 306 308 18:10 30s 49:15 31 162 2:20 32 3200 2:23 3270671 142 3:13 131 371-1321 371-1321 3:14 5 3M 5 4 4 4:11 17,23 1,3 651 2:25 3:18 66 18,19 66th 3 67 14:22 137 139 2,6,11 4,16 68 23,24 1,9,11 16:10 3,20 8,12 29:14 16,24 3,6 51:12 54:14 55 67:17 104 108 112 | 114 120 123 136 10,21 69 17,24 3,6,12 54:14 55 54:14 : 7 4 70 145 70s 80:22 71 124 136 72 67:18 108 21,21 114 73 13:24 93 732 9 76 26:19 76ish 26:21 159 1969 50:15 160 96:15 147 148 | 144 145 40s 12,15 77070 4 | 7th 2:23 1970s 57:23 410 13,24 13,23 8 1971 106 130 1972 65:21 66 67:15 12,2122,22 69 198 74:11 1981 106 1986 19 2 24 24 17:18 130 136 156 70 1,3,16,25 72:21 14,15,15 gauge 7,16 44 18:10 4400 3:13 45.0GR 156 466-7192 5 480-1835 2:20 5 8 18:13 114 gauge 17:15 153 154 80s 23,2243,24 45:13 81 106 107 108 133 8519 3:16 86 19:21 8,15 8,15 5,11 13,15 12,14 105 123 141 2/17/71 8 130 5 2 49 132 875 19,24,25 19,24,25 24 2:22 136 5,000 96:14 19,19 2:38 136 50 121 131 20 13,24 18 13,23 49:11 50 106 114 117 145 gauge 65:24 68:1146 69:23 3,13,22 72:21 72:24 18,21,23 74 74 108 18,18,21 109 14,20,21 1,19 1,2,5,13,17,118,2,5,,13,117,198,19 4,25 113 7,18,25 1,6,6,13 157 500 2:10 50s 34:22 45:24 46:17 52 157 530-9108 9 55042 3:17 55101 2:24 55402 3:13 55423 4 556 18:10 58 156 58.0GR 156 9 9 113 9,10 945-1974 2:12 94596 2:11 952 2:12 970-9988 5 158 2000 52:22 Doby Professional Reporting Inc. 952-943-1587 Page 172