Document kD060KwmaNj6kpz4D1wGm8VeJ

314 1 Sayers 2 BY MR. WILL: 3 Q. Mr. Sayers, 1 have a few questions for 4 you to follow up on some of the things that you 5 were requested by the other lawyers. 6 Mr. Polk asked you some questions about 7 whether you had ever seen a warning on bags of 8 Calidria; do you remember that? 9 A. 1 do. 10 Q. When was the last time that you were II involved with Calidria asbestos where you would 12 have seen a bag? 13 A. In the autumn of'68. 14 Q. Fall of 1968 at some point? 15 A. Yes, that is correct. 16 Q. That would have been in Europe when you 17 would have seen that bag? 18 A. Yes, it would, that's right. 19 Q. How many times a year did you get 20 shipments of asbestos in Europe? 21 A. I'm guessing, but 1 would say around 22 twice a year. 23 Q. About twice a year? 24 A. Yeah. 25 Q. And do you have any knowledge of when it 316 1 Sayers 2 MR. BROWNSON: Objection. 3 MR. POLK: Objection, leading. 4 A. Principally Tom Frangos. 5 Q. Have you ever seen any documents by the 6 people involved about when it was -- let me 7 rephrase the question. 8 1 want to show you a document that was 9 dated Exhibit E to the deposition of John Myers on 10 May 17th of this year. I'm going to ask you to II take a look at that, the part that's highlighted. 12 A. Right. 13 MR. BROWNSON: What deposition is that 14 from? 15 MR. WILL: The deposition of Mr. Myers 16 that was taken about a month, two months 17 ago -- two and a half months ago. 18 MR. BROWNSON: In what case? 19 MR. POLK: In what case? 20 MR. BICKS: 1 think it was taken in 21 all Waters and Krauss Texas and California 22 cases. 23 Q. Did the document 1 just asked you to 24 read say, "Our bags have carried a warning label 25 since 1968, four years before the federal OSHA 315 1 Sayers 2 was that that last bag of asbestos you saw in 3 Europe was packed and shipped out of the United 4 States? 5 A. No, I couldn't tell you that. 6 Q. Now, in terms of knowing whether or 7 not -- let me rephrase the question. 8 In terms of knowing when warnings were 9 put on bags of Calidria in the United States, would 10 you think that you were the authority on that? II A. The reason for it, you mean? 12 Q. No, would you think that you were the 13 person that would know most about that, when 14 warnings were put on in the United States? 15 A. No, 1 wouldn't have thought so. 16 Q. Would you want to talk to somebody in 17 the United States about when that happened? 18 MR. POLK: Objection, leading. 19 A. The people in America would have 20 obviously known. 21 Q. If somebody asked you who would have 22 been the best source for that information, who 23 would that be, in your view? 24 A. 1 would have asked Tom Frangos. 25 0 Or somebody else in the U.S.? 317 1 Sayers 2 standards were promulgated to require this"? A. Yes. 4 MR. BROWNSON: 1 object to the question 5 as leading and reading facts not in 6 evidence. 7 Q. My question is to the -8 MR. POLK: Excuse me. Do you mind I see 9 what you're reading? 10 MR. BROWNSON: 1 further object it's II having him testifying about something the 12 witness has never seen. 13 MR. GOLDMAN: Perhaps we could have a 14 copy of whatever it is that's been 15 distributed so counsel can follow along. 16 MR. WILL: Mr. Goldman, your lawyer 17 didn't do that. I'd be happy to give you 18 one later. 19 MR. POLK: Wait a minute. Wait a 20 minute. 21 MR. GOLDMAN: This is a different case 22 we don't know about. 23 MR. POLK: 1 don't have this 24 transcript. 1 don't have this document at 25 all. I'm just saying if you're going to use SPHERION DEPOSITION SERVICES (212)490-3430 80 (Pages 314 to 317)