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IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS JOHN C. EVANS, SR., Individually and as Special Administrator of the Estate of JOHN EVANS, Deceased, Plaintiff, ) ) ) ) ) ) -vs- A.W. CHESTERTON, INC., et al., Defendants. ) ) ) ) ) Case No.1-100-L77 VOLUME II DISCOVERY DEPOSITION OF THOMAS LANG Taken on behalf of the Defendants August 16, 2011 Reported by Maria E. Shockey, CSR Illinois License No. 084-004411 1 INDEX 2 THE WITNESS: THOMAS LANG 3 4 Examination by Mr. Mauller 5 Examination by Mr. Hayes 6 Examination by Mr. Ludolph 7 Examination by Ms. Felkins 8 Examination by Mr. Cohn 9 10 11 12 13 14 PAGE 8 12, 54 39 46 48 15 *** NO EXHIBITS MARKED *** 16 17 18 19 20 21 22 23 24 Page 2 PohlmanUSAC ourt Reporting (877) 421-0099 1 IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT 2 MADISON COUNTY, ILLINOIS 3 JOHN C. EVANS, SR., ) 4 Individually and as ) Special Administrator of ) 5 the Estate of JOHN EVANS, ) Deceased, 6 Plaintiff, ) ) ) 7 -vs8 A.W. CHESTERTON, INC., 9 et al., ) ) Case No. 10-L-1077 ) ) ) ) 10 Defendants. ) ) 11 Page 3 12 CONTINUED DISCOVERY DEPOSITION OF 13 THOMAS LANG produced, sworn, and examined on behalf 14 of the Defendants, August 16, 2011, between the 15 hours of 10:56 a.m. in the morning and 11:26 a.m. 16 in the morning on that day at 200 East 3rd Street, 17 Davenport, Iowa, before Maria E. Shockey, CSR and 18 Notary Public. 19 20 21 22 23 24 PohlmanUSAC ourt Reporting (877) 421-0099 1 A P P E A R A N C E S: 2 SIMMONS, BROWDER, GIANARIS, ANGELIDES & BARNERD, 3 L.L. C., One Court Street 4 Alton, Illinois 62002 TEL: (618) 259-2222 FAX: (618) 259-2251 5 BY: MR. RANDY S. COHN Page 4 6 Appeared on behalf of the Plaintiff; 7 HEPLERBROOM, L.L.C., 8 130 North Main Street Edwardsville, Illinois 62025 9 TEL: (618) 656-0184 FAX: (618) 656-1364 BY: MR. THOMAS P. BRIDDICK 10 Appeared telephonically on behalf of 11 Defendants Ameren Missouri Company f/k/a Union Electric Company d/b/a AmerenUE; 12 13 HERZOG CREBS, L.L.P., 100 North Broadway, 14th Floor 14 St. Louis, Missouri 63102 TEL: (314) 231-6700 FAX: (314) 231-4656 15 BY: MR. CALEB D. HAWKINS 16 Appeared telephonically on behalf of 17 Defendants Borg-Warner Corporation by its Successor-in-Interest, Borg-Warner Morse 18 TEC, Inc., and J-M Manufacturing Company, Inc.; 19 20 HEYL, ROYSTER, VOELKER & ALLEN, P.C., 124 S.W. Adams Street, Suite 600 21 Peoria, Illinois 61602 TEL: (309) 676-0400 FAX: (309) 676-3374 22 BY: MR. MARK A. LUDOLPH 23 Appeared on behalf of Defendants Kraft Foods Global, Inc., IMO Industries, Inc., and 24 Riley Stoker Corporation; PohlmanUSAC ourt Reporting (877) 421-0099 1 APPEARANCES: (Continued) Page 5 2 HUSCH BLACKWELL, L.L.P., 3 190 Carondelet Plaza, Suite 600 St. Louis, Missouri 63105 4 TEL: (314) 480-1500 FAX: (314) 480-1505 BY: MS. CATHERINE M. DICKENSON 5 Appeared telephonically on behalf of Defendant 6 Pharmacia Corporation f/k/a Monsanto Company; 7 8 LANE & WATERMAN, L.L.P., 220 North Main Street, Suite 600 9 Davenport, Iowa 52801 TEL: (563) 324-3246 FAX: (563) 324-1616 10 BY: MR. ROBERT B. McMONAGLE 11 Appeared on behalf of Defendant Crane Co.; 12 13 LEWIS, RICE & FINGERSH, L.C., 600 Washington Avenue, Suite 2500 14 St. Louis, Missouri 63101 TEL: (314) 444-7600 FAX: (314) 241-6065 15 BY: MR. COREY M. SCHAECHER 16 Appeared telephonically on behalf of Defendant 17 E.I. du Pont de Nemours and Company; 18 McKENNA STORER, 19 33 North LaSalle Street, Suite 1400 Chicago, Illinois 60602 20 TEL: (312) 558-3900 FAX: (312) 558-8348 BY: MR. THOMAS W. HAYES 21 22 Appeared on behalf of Defendants Iowa-Illinois Taylor Insulation, Inc., and Iowa-Illinois 23 Taylor Insulation Contracting, Inc.; 24 PohlmanUSAC ourt Reporting (877) 421-0099 1 APPEARANCES: (Continued) 2 NELSEN & LEE, P.C., 3 1010 Market Street, Suite 500 St. Louis, Missouri 63101 4 TEL: (314) 621-9800 FAX: (314) 621-9802 BY: MR. PETER M. MAGINOT 5 Page 6 6 Appeared telephonically on behalf of Defendant Lamons Gasket Company; 7 8 O'CONNELL, TIVIN, MILLER & BURNS, L.L.C., 135 South LaSalle Street, Suite 2300 9 Chicago, Illinois 60603 TEL: (312) 256-8800 FAX: (312) 741-4692 10 BY: MS. HELEN FANNING 11 Appeared telephonically on behalf of 12 Defendants John Crane, Inc., Cleaver-Brooks, and SEPCO Corporation; 14 POLSINELLI, SHUGHART, P.C., 100 South Fourth Street, Suite 1000 15 St. Louis, Missouri 63102 TEL: (314) 889-8000 FAX: (314) 231-1776 16 BY: MS. NICOLE c. BEHNEN 17 Appeared telephonically on behalf of 18 Defendant, Grain Processing Company; 19 SCHIFF HARDIN, L.L.P., 20 233 South Wacker Drive, Suite 6600 Chicago, Illinois 60606 21 TEL: (312) 258-5784 FAX: (312) 258-5600 BY: MS. RENEE C. KELLEY 23 Appeared telephonically on behalf of Defendant Deere & Company; 24 PohlmanUSAC ourt Reporting (877) 421-0099 1 APPEARANCES: (Continued) 2 SEGAL, McCAMBRIDGE, SINGER & MAHONEY, LTD., 3 233 South Wacker Drive, Suite 5500 Chicago, Illinois 60606 4 TEL: (312) 627-4109 FAX: (312) 627-1717 BY: MS. JILL M. FELKINS 5 Page 7 6 Appeared on behalf of Defendants Alcoa, Inc., MidAmerican Energy Company, and 7 H.J. Heinz Company; 8 SEGAL, McCAMBRIDGE, SINGER & MAHONEY, LTD., 9 233 South Wacker Drive, Suite 5500 Chicago, Illinois 60606 10 TEL: (312) 627-4109 FAX: (312) 627-1717 BY: MS. LESLIE C. McCOY 11 12 Appeared on behalf of Defendants Kentile Floors, Inc., Greene, Tweed & Company, Young 13 Group, Ltd., and Young Insulation Group of St. Louis, Inc.; 15 WILLIAMS, VENKER & SANDERS, L.L.C., Bank of America Tower 16 100 North Broadway, 21st Floor St. Louis, Missouri 63102 17 TEL: (314) 345-5000 FAX: (314) 345-5055 BY: MR. BRYAN K. MAULLER 19 Appeared telephonically on behalf of Defendant, Caterpillar, Inc. 20 21 23 24 PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by ^lr. Mauller] Page 8 1 THOMAS LANG, 2 called as a witness herein, having been previously 3 duly sworn, deposeth and saith as follows: 4 EXAMINATION 5 BY MR. MAULLER: 6 Q. Mr. Lang, my name is Bryan Mauller, and I 7 represent a company called Caterpillar 8 Incorporated. 9 Can you hear me okay? 10 A. Sure. Yes. 11 Q. Okay. I should be fairly brief. I've 12 just got some questions for you. 13 Has anything changed about your testimony 14 with regard to Cat from today as opposed to what 15 you testified to last week? 16 A. No. Now, Cat -- for some reason, Cat is 17 pretty big for me. 18 Q. Okay. And is it fair to say that other 19 than these weekly time sheets, you don't have any 20 recollection of working with Mr. Evans at any 21 Caterpillar facility? 22 A. No. I remember the new Cat -- well, when 23 it was newly built here -- that we did some work 24 out there. But I can't tell you exactly what we PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by ^lr. Mauller] Page 9 1 did on it, I'm thinking, because I believe that's 2 after I was out of the Service or a little later. 3 It was more of a fiberglass-type thing then. 4 But like I said, at that time, we were 5 still mudding elbows and stuff, so that would 6 probably be about all that would have happened 7 there that I can recollect. 8 Q. Okay. And just to be clear, I don't want 9 you to guess. I only want you to tell me what you 10 specifically recall, okay? 11 A. Yeah. 12 Q. Okay. Do you specifically recall mudding 13 any joints or elbows at the Cat Davenport, Iowa, 14 facility with Mr. Evans? 15 A. Well, I can't specifically recall it. But 16 if we had done elbows, that's pretty much how we 17 would have done them at that time. 18 Q. Okay. And, again, as you sit here today, 19 you don't have any specific recollection of the 20 names or brands of any of the compound you would 21 have used on any of those joints and elbows 22 possibly at this Caterpillar facility; is that 23 correct? 24 A. Well, it would have been the 301 mud, PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by ^^r. Mauller] Page 10 1 which I don't know if -- I think Manville put the 2 301 out, because that's primarily the mud we were 3 using in those days for One-Coat. And I don't 4 recall any type of blue mud. 5 Q. Okay. So is it fair to say that during 6 that time period, that was the brand of mud you 7 would have used, but specifically with regard to 8 Caterpillar, you don't know what brand you would 9 have used; is that a fair statement? 10 A. Well, if I was with Iowa-Illinois, that's 11 the brand we would have been using. They were 12 never short of that. 13 Q. Okay. And Iowa-Illinois would have 14 provided you that mud, correct? 15 A. Correct. 16 Q. And Iowa-Illinois would have also provided 17 you your tools, correct? 18 A. No. We had our own tools. 19 Q. You had your own tools. Okay. 20 And Iowa-Illinois would have given you 21 directions as far as what work to do and where to 22 do it, correct? 23 MR. COHN: Objection. Asked and answered. 24 Mischaracterizes prior testimony. PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by ^lr. Mauller] Page 11 1 THE WITNESS: I couldn't answer you that 2 because I wasn't in that position to -- that would 3 have been John's position, and I wasn't really 4 privy to sit in on that type of thing. 5 BY MR. MAULLER: 6 Q. Okay. Well, from your personal knowledge, 7 you got your instructions from an employee of 8 Iowa-Illinois, correct? 9 A. Are you talking years later when I would 10 have been doing jobs? 11 Q. I'm just talking about when you worked 12 possibly at any Caterpillar facility. 13 An employee from Iowa-Illinois told you 14 what jobs to do, correct? 15 A. Yeah. Whoever I was working for there, 16 whoever the foreman of that job was, yes. 17 Q. Okay. And I know you said you don't 18 really remember. 19 Do you have any inkling as to whether the 20 work you might have done at Caterpillar with 21 Mr. Evans, would that have been new construction, 22 or would that have been repair work? 23 A. I believe that would have been new. 24 Q. Okay. And I believe you had testified PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 12 1 that in order to get paid, you had to fill out a 2 weekly timesheet, correct? 3 A. Well, yes. 4 But at that time, the foreman was doing 5 all the time sheets. 6 Q. Okay. What I'm trying to ask is, we've 7 got a list of time sheets here. 8 That would have been inclusive of all the 9 time that you would have possibly worked at any 10 Caterpillar facility with Mr. Evans; is that fair? 11 A. Yes. With John Evans, yes. 12 MR. MAULLER: Okay. Sir, I believe those 13 are all the questions I have for you right now. 14 Thank you for your patience. 15 Thanks, Randy. 16 MR. COHN: Yep. 17 Anyone else on the phone have questions? 18 EXAMINATION 19 BY MR. HAYES: 20 Q. Mr. Lang, I'm going to come down here so I 21 don't have to yell across the table at you. 22 Again, my name is Tom Hayes, and I do 23 represent the Iowa-Illinois entities, so I have a 24 number of questions to ask you about Iowa-Illinois PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by iM!r. Hayes] 1 and your work for them. Page 13 2 The first thing I want to clarify is that 3 when you say "Iowa-Illinois," do you mean 4 Iowa-Illinois Thermal Insulation? 5 A. Yes. 6 Q. And during that time frame when you worked 7 with Mr. Evans, 1965 to 1970, you were working for 8 Iowa-Illinois Thermal Insulation; is that right? 9 A. Yes. 10 Q. And to the best of your knowledge, 11 Mr. Evans was always working for Iowa-Illinois 12 Thermal Insulation during that time period; is that 13 right? 14 A. Yes. 15 Q. Was there a distinction with Iowa-Illinois 16 Thermal at that time between permanent employees 17 and insulators that were hired out of the union 18 hall like yourself? 19 Was John Evans in a different category 20 than you as a foreman? 21 A. No. He was actually out of the hall, but 22 he just always worked with me. He just -- they 23 always had work for him, so he just continued on 24 all the time. At that time, they weren't real PohlmanUSACourt Reporting (877) 421-0099 [Examination by ^4r. Hayes] huge. There were guys that stayed with them for Page 14 quite some time. But when they needed help, they'd get people out of the hall. I was probably a 4 permanent -- considered -- on the apprentice part 5 until I got transferred to Taylor. 6 Q. But to the best of your knowledge, 7 John Evans, you would consider him a permanent 8 employee of Iowa-Illinois Thermal during that time 9 frame; is that right? 10 A. Yes. 11 MR. COHN: Objection. Calls for a legal 12 conclusion and speculation. 13 BY MR. HAYES: 14 Q. Well, to the best of your knowledge. 15 A. Yes. But he was out of Local 81. He was 16 under Local 81' s jurisdiction. 17 Q. Right. And as a foreman, he was still in 18 the union? 19 A. Oh, yeah. 20 Q. He was not in management, right? 21 A. No. 22 Q. Okay. You've talked a little bit about 23 your experience with the union. I wonder if you 24 know how active Mr. Evans was in the union. PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by iM!r. Hayes] Page 15 1 During the time frame that you worked with 2 him, did he attend union meetings? 3 A. Yes. They used to be on Friday nights at 4 that time -- wait a minute -- Saturdays at that 5 time. They switched it to Friday and they'd go to 6 them. They were pretty regular going to them. 7 Q. Okay. And when you say "they," you 8 mean John Evans and -9 A. And the guys in the shop. He would go up 10 with people from the Quad Cities, other journeymen. 11 Q. Okay. And were those meetings in 12 Cedar Rapids? 13 A. Yeah. At that time, they were always 14 there, yeah. 15 Q. Okay. Do you know if Mr. Evans ever was, 16 during that time or later, an officer in the union? 17 A. I don't believe so, no. 18 Q. On some of the job sites that you and 19 Mr. Evans worked together, did you ever drive in a 20 car together? 21 A. Sure. 22 Q. What were some of the job sites that you 23 would drive together to? 24 A. Well, up to Clinton Corn, we'd drive PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 16 1 together there, anyplace out of town, like if we 2 went to Muscatine or up to Dubuque to the Deere 3 plant there. To Waterloo, we went to a Deere plant 4 there, mainly the out-of-town jobs. The in-town, 5 we'd just meet at those. 6 Q. And, generally, were those jobs where it 7 was just you and him working together? 8 A. Sometimes. There might be some other 9 people. 10 Q. Okay. On any of those occasions when you 11 were riding in the car with him or any other 12 occasion on a job site, do you recall Mr. Evans 13 telling you anything that he learned at any of the 14 union meetings that he attended? 15 A. Well, he may have discussed some things 16 that they talked about, but not really, no. 17 Q. And just to try to refresh your 18 recollection, if there was anything that he might 19 have said about, boy, they really taught us 20 something interesting on this particular meeting, 21 you don't recall anything like that? 22 A. No. And that only would have been the 23 first six months of -- you have to wait six months 24 to apply to get in the union. And from that point PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 17 1 on, I got in the union. I rode up to meetings with 2 him and stuff and so there would have been no 3 reason to. 4 Q. And you talked a little bit about it last 5 time with respect to your own experience. 6 And just to see if your memory has been 7 refreshed over the last couple of weeks, do you 8 remember anything that the union discussed at any 9 of the meetings that you personally attended 10 regarding safety hazards on job sites generally? 11 A. Just, you know, they always talked about 12 pushing for safety, you know. There was no 13 specific things. It was more along the lines of 14 they wanted people to demand better scaffolding, 15 things like that at that time. 16 Like I said, there wasn't any OSHA to 17 oversee people or -- so there really wasn't other 18 than the plant safety people themselves not wanting 19 problems. That's the type of thing they would 20 discuss about safety. If you don't think it's 21 safe, by God, don't go on it and call us up here 22 and we'll see what we can get done about it, things 23 like that. 24 Q. Right. And I wanted to focus your PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by ^^r. Hayes] 1 attention on that '65 to 1970 time period. P, ge 18 2 So I'm specifically asking if you recall 3 anything about safety from that time period? 4 I'm assuming that's what you're answering. 5 A. Yeah. That's the only type of things I 6 can recall that people would bring. And it was 7 more instead of the union bringing it up, it would 8 be more somebody in the meeting saying something 9 like, well, we're working out here at so-and-so 10 and, boy, this thing looks like it's ready to fall 11 down. 12 And the business agent would tell him, 13 well, use common sense. Don't go on it, call me, 14 or things like that. That's the type of safety 15 things back in those days, and then they'd have to 16 go argue it out for you. 17 Q. Okay. And you testified last time, and I 18 just wanted to clarify that it is still accurate 19 today that you don't recall the union discussing 20 anything about the potential hazards of asbestos 21 during any of those union meetings that you 22 attended; is that right? 23 A. Nothing in the early years, no. 24 Q. And, again, we're trying to focus on the PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 '65 to 1970 time period. Page 19 2 A. Right. During that time period, I don't 3 recall anything in those eras, no. 4 Q. Okay. Iowa-Illinois Thermal insulators 5 that worked for them out of the union hall, did 6 they wear any type of uniform? 7 A. No. 8 Q. So what would you wear to a job site while 9 you were working for Iowa-Illinois Thermal? 10 A. Just some type of work boots and a pair of 11 blue jeans and either a T-shirt or a corduroy shirt 12 or whatever the weather dictated at that time. 13 Q. Okay. Iowa-Illinois Thermal, during that 14 time, did not issue any T-shirts with logos on them 15 or anything like that? 16 A. Well, yeah. I think back in those days - 17 I don't remember back in '65. See, they were 18 notorious for the hats, I think. Everybody in town 19 had an IIT hat, which was Iowa-Illinois Thermal 20 back in those days, but I can't remember if it was 21 a T-shirt so much. That may have been later on. 22 Q. Did you ever wear a hat with a logo on it 23 on any of the job sites from '65 to '70? 24 A. No. I've never been a hat wearer. PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 20 1 Q. Do you recall Mr. Evans ever wearing one 2 of those hats? 3 A. I'm not sure if it was in that actual era. 4 I just remember Iowa-Illinois being kind of famous 5 for that. And that may have been like when I came 6 back from the Service that that type of thing was 7 going on. Just like I said, when I first started, 8 they were still -- it was pretty early in there. 9 They had an office building up on 10 Main Street. They had a warehouse over in 11 Rock Island. They were just getting off the floor 12 back then. 13 Q. Do you have a specific recollection, as 14 you sit here today, of any Iowa-Illinois Thermal 15 employee wearing any of those hats or T-shirts with 16 logos or the company name on them during that '65 17 to 1970 time period on a job site? 18 A. Well, I'd be lying if I said it was 19 definitely there in that time period. I remember 20 it happening, but to actually give you the year 21 that they really started doing that, it might have 22 been the later part of that, probably really not 23 the real early part. 24 But I might be lying there, too. I just PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 21 1 recall that being a big thing. Everybody wanted 2 one of their hats. 3 Q. To the best of your knowledge, that would 4 have been a voluntary thing - 5 A. Oh, yes. 6 Q. -- on the part of the insulator? 7 A. Sure. 8 Q. It was not a uniform that was required? 9 A. No. No. 10 Q. With respect toequipment, specifically 11 vehicles that Iowa-Illinois Thermal had during that 12 time period, '65 to 1970, did they have any trucks 13 that might have been driven to these job sites? 14 A. Yes, they did. They had -- well, one 15 specific I can remember was a Volkswagen. It looks 16 like the Volkswagen Bus deal, but it was a truck, 17 the back end of that. That took a pretty good 18 beating over the years. 19 And I can't recall the exact year, but it 20 was during that period sometime. I won't say '65, 21 but somewhere in that era. That's about the main 22 one I remember. They didn't get into the trucking 23 deal for quite sometime before, all of a sudden, 24 everybody had a truck then. PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by iM!r. Hayes] Page 22 1 Q. Okay. Did that VW bus or truck have any 2 kind of writing or logos on it that identified the 3 company? 4 A. I don't think so back in that time. It 5 wasn't even required, I think, by state law back 6 then. I think later on Illinois had it where you 7 had to have the names on them and stuff. 8 Q. You've talked about a lot of different job 9 sites on day one of your deposition that you worked 10 at with Mr. Evans and I know there were some that 11 were in Illinois. 12 But would it be fair to say that most of 13 the job sites that you worked at with Mr. Evans 14 were in the state of Iowa? 15 A. Yeah. It seemed like we were over here. 16 Q. Can you give me a percentage? And I don't 17 want you to guess, but just a -18 A. It'd be a guess, it really would. But 19 from what I can remember for us having to go to 20 Illinois , the percentage would be much higher on 21 the Illinois side -- I mean, on the Iowa side. 22 Q. Iowa side. Okay. 23 A. It might be as high as 80/20 or maybe even 24 higher. PohlmanUSACourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 23 1 Q. Now, you talked last time, Mr. Lang, about 2 using both materials that you thought were 3 asbestos-containing and fiberglass materials on 4 these various job sites. 5 And at one point, you thought the 6 percentage was about 50/50 in terms of the pipe 7 covering and block; is that right? 8 A. Well, I think when I was first starting 9 out, it might have been a little heavier the other 10 way because fiberglass was just -- fiberglass had 11 been around, but I think they were getting to where 12 they can use it on higher temperature stuff. They 13 were progressing that way on it. 14 So probably that '65 part might have been 15 even 60/40, 70/30. But every year it got a little 16 more to where it was down to a 50/50-type thing. 17 Q. Towards the end of the '60s? 18 A. Oh, yeah. And then fiberglass was coming 19 on real strong. 20 Q. All right. And would it be more than 21 50 percent fiberglass at that time? 22 A. Well, I don't think so. I mean, it just 23 depended. I think it got down to the point where 24 if it was hot, you were still going to go with your PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 24 1 block and your Thermobestos and stuff. But things 2 that they put that on, it wasn't really necessary. 3 But because they didn't trust the fiberglass or 4 whatever, the fiberglass started to pick up and be 5 used more. 6 Q. You mentioned last time and I think you 7 just mentioned just now that they were pushing 8 fiberglass at that time, that they were really 9 starting to push it. 10 Who do you mean by "they"? 11 A. Well, I mean, the industry, I'm thinking. 12 It was -- you know, you're going from something 13 that probably weighed -- I don't even know if it's 14 a quarter of the weight versus your block-type 15 insulation and it just goes on so much faster. It 16 was just a speedier process. So when they could 17 use it and it would do the job and once industry 18 was convinced it was an effective thing, I think 19 that's why it kept going more that way. 20 Q. Is it fair to say that you as an insulator 21 would certainly prefer to have used fiberglass 22 during that time? 23 A. Oh, without a doubt other than to itch. 24 They didn't have the no-itch back then. PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 25 1 Q. Okay. And if you know, would it be fair 2 to say that Iowa-Illinois Thermal as a company 3 would have preferred to use fiberglass if they had 4 the choice? 5 MR. COHN: Objection. Calls for 6 speculation. 7 BY MR. HAYES: 8 Q. You can answer, if you know. 9 A. Well, I would assume because they could - 10 it made your profit -- I mean, speed-wise, it was 11 always -- you know, but now that is assumption on 12 my part, you know. I don't know. They may have 13 lost money on the price of the product. I just 14 don't know. 15 Q. Sure. 16 Now, you talked about using mud or 17 cements, various different kinds and you've talked 18 about Johns Manville 301. 19 Is that insulating cement? 20 A. Yeah. You could -- yeah, 301, you could 21 use on the whole -- you could do the whole elbow 22 with it, I mean, from start to finish on these 23 smaller elbows. They just put that on there and it 24 would be adequate to hold the heat or cold or PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 26 1 whatever they were trying to do on that. If it got 2 extremely warm, you might go with -- it was a 3 high-temp mud. I can't come up with the name right 4 now. I should start writing this stuff down. 5 But you might put a layer of that on and 6 then finish it out in One-Coat because it would 7 take more extreme heat that way. 8 Q. Okay. Now, I want to clarify, you just 9 mentioned One-Coat again. 10 Are those two different products, the 301 11 and One-Coat? They're two different products? 12 A. Well, 301 is supposedly a One-Coat, you 13 know. One-Coat, they're talking about you can put 14 it on, but, you know, that's if you're planning 15 on -- not that thick, you know. If you've got a 16 two- or three-inch elbow thickness here, it would 17 probably behoove you not to try to put two or three 18 inches of mud on there because you're going to come 19 back the next day and it's all going to be shrunk 20 up and you're going to have to go over it again 21 anyway. 22 Q. Okay. I was just a little confused 23 because you were always saying Johns Manville 24 One-Coat -- Johns Manville 301 One-Coat, and I'm PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 trying to find out if there were two different 2 products, if 301 came out of one bag and the Page 27 3 One-Coat came out of another? 4 A. I think it's just the name that came up 5 that the insulators just started using all the 6 time, One-Coat. You could actually mud some 7 surfaces with One-Coat and smooth it out enough 8 where you can get by with it where with other muds 9 you couldn't necessarily do that, like blue mud. 10 Blue mud is finish coat. It would go over 11 that One-Coat and that would be something that they 12 were trying to make it look extra nice. And there 13 was a good insulation value on it, too. So a lot 14 of times it would be used on your real high-temp, 15 big steam lines or something that they -- it would 16 give it an added insulation, plus it looked much 17 nicer. You can smooth it out to look like that 18 glass (indicating). 19 Q. Okay. I just want to finish up with this 20 point, and I hate to belabor it, but do you 21 remember those two products coming out of different 22 bags, the one that said "301" and one that said 23 "One-Coat" or in your mind, is it all coming out of 24 one bag? PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 28 1 A. Well, we used 301 pretty much all the 2 time, so I'm -3 Q. And you just referred to it as One-Coat? 4 A. Yeah. It's just -- you know, somebody 5 might call a piece of Thermobestos and it might be 6 a piece of Kaylo. But to them, it's basically the 7 same thing. 8 Q. Okay. I understand. 9 Now, at that time from 1965 to 1970, were 10 you aware that there were also cements that were 11 insulating and finishing that did not contain 12 asbestos? 13 A. I believe the one I was trying to tell you 14 about, there was a mineral wool mud. I may be 15 wrong there. I don't think -- I never heard down 16 the road that there was any asbestos in it. That's 17 like mineral wool blanket. There's no asbestos in 18 that that I ever heard. 19 So that's about the only one I can think 20 of during that era. There may have been some. I'm 21 not saying there weren't. But from what we were 22 told later on, the One-Coats and the blue muds, the 23 finish muds and stuff had it in them. 24 Q. Did you use any of that mineral wool mud PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 on any of these job sites? Page 29 2 A. Oh, you would use them on -- when you'd 3 get into this real high-temp stuff. But now, there 4 again, you might have some block on there. 5 Q. Right. That's a separate issue. I'm just 6 talking about the muds or cements right now. 7 A. Yeah. But you never had it on by itself. 8 If you put it on, there was going to be a one9 coat -- more than likely a One-Coat and then if you 10 were going to blue mud it. But you never just put 11 it on -- if you did, it better be down in a tunnel 12 or something because it was going to be pretty 13 ugly. 14 Q. Now, there were times during day one of 15 your deposition that you mentioned that you 16 installed fiberglass pipe covering or block and 17 then put the 301 or One-Coat over that; is that 18 right? 19 A. Yeah. That would be -- you're talking 20 look on the ends of tanks or something? 21 Q. Well, that was your testimony. You said 22 that there were some times when you used fiberglass 23 pipe covering and then put a 301 One-Coat over 24 that. PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 A. Not over the pipe covering. Page 30 2 Q. What would that be over? 3 A. I said when we were doing tanks, you might 4 be mudding the top of a tank or even the bottom 5 sometimes. You might have -- more likely there's 6 going to be block, but you might have a fiberglass. 7 But you still mudded. You had to finish it with 8 something. But you wouldn't do the pipe -- unless 9 you were seaming and it wouldn't even be the 10 fiberglass, so there would be no reason to seam 11 fiberglass. 12 But on block, you would seam that pipe. 13 You would have cracks where they wouldn't come 14 together and you'd have to fill that with mud, 15 otherwise, that would be a hot spot coming through 16 there. 17 Q. Right. 18 Do you remember using any of the other 19 Johns Manville 300 series of muds besides the 301? 20 A. If it was out at that time, I probably 21 did. But for some reason, 301 is the one that 22 pretty much sticks in my mind. 23 Q. Okay. You also mentioned at some point 24 you started going to metal instead of muds, and I PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 assume by that, you mean metal jacketing? Page 31 2 A. Yeah. 3 Q. When do you recall first starting to use 4 that? 5 A. That would have been after I came out of 6 the Service, so we're talking -- and it may have 7 been going on while I was in the Service. I don't 8 mean to say that it wasn't. But for me to get 9 involved in it, it would have been '69 when I got 10 out of the Service. 11 So that's when I started running into the 12 metal versus -- and there was still some canvas and 13 stuff going on, but it was -- you could see that 14 was the wave of the future coming on. They were 15 going to go to the metal. 16 Q. Right. And so at that time when they 17 started using the metal jacketing, there was less 18 and less mud that was used? 19 A. As time went on, yeah, just continually. 20 Q. Now, you mentioned just a minute ago and 21 last time about using the hard pipe covering and 22 block because it was easier to walk on. 23 Do you remember that testimony? 24 A. Well, you could walk on it versus PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 fiberglass. 2 Q. But I wanted to just clarify with you P age 32 3 today in terms of what you meant by that. 4 Were there times when the premises owner 5 wanted you to put on the hard pipe covering or 6 block for that purpose so individuals or their 7 employees could walk on it on those sites? 8 A. Well, I can't say for sure who was 9 dictating that you do it, but you'd get in these 10 pipe cracks, for instance, in these chemical plants 11 and places, and to get at valves and stuff, they 12 have to walk through there. 13 So probably through experience they 14 learned that it was in their best interest to have 15 the hard-type insulation that was -- especially 16 once they went to the metal and that where you can 17 walk down them without ruining it. 18 If it was fiberglass, four or five trips 19 down there and you're probably going to end up 20 redoing the line or lines because there would be 21 several lines if you're going to walk up. 22 But otherwise, it would be -- like I had 23 stated before -- the tops of the tanks. Today they 24 still do it that way. PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 33 1 Q. And with respect to the tops of these 2 tanks, was the hard pipe covering and block used so 3 people could walk on it because the material might 4 contain asbestos, if you know? 5 A. Well, I mean, if it was really hot, they 6 were going to have that regardless whether you were 7 going to walk on it or not because that's what took 8 care of the heat in those days. But it could have 9 been a twofold deal, too. 10 Q. Okay. So to the best of your knowledge, 11 at least one of the reasons why the hard pipe 12 covering or block was used on some of these tanks 13 and other jobs was so that employees could walk on 14 it without damaging it? 15 A. Right. 16 Q. Okay. Now, you talked a little bit last 17 week -- or a couple of weeks ago about 18 specifications and whose job it was to specify the 19 use of materials on a particular job site and you 20 did mention that everyone was kind of involved in 21 that, providing input. 22 But is it fair to say -- would you agree 23 that the ultimate decision in terms of what product 24 was installed or applied on a job site was on the PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 owner of the job site? 2 MR. LUDOLPH: Objection. Calls for Page 34 3 speculation. 4 MS. FELKINS: Join. 5 DEFENSE ATTORNEY: Join. 6 THE WITNESS: Well, that wouldn't be fair 7 for me to say because I was -- especially at that 8 time, I wasn't involved in any of that. In fact, I 9 could say through most of my career when I was 10 running jobs, it was -- the worker himself didn't 11 sit in. Those jobs were cut and dry before we ever 12 got to that point. 13 There might be a spec on the job. I don't 14 know if there was back in those days, but -- that 15 you can see -- to see that you were doing it right. 16 BY MR. HAYES: 17 Q. When you became a foreman, you followed 18 the specs, right? 19 A. If you had a spec. That would be 20 depending on -- we tried over the years to have 21 that put in our contract, that they'd have to give 22 you a set of specs with the job to know that we 23 were given the right product and what they wanted. 24 I don't know that we ever got that in. I can't PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 remember it being put in there. Page 35 2 More than likely over the years of what I 3 ran into, that set of specs was sitting in the 4 office and they just sent you out the material. 5 And somebody might tell you, this line is getting a 6 two-inch thick, that line is getting a four-inch 7 thick. 8 Q. Sure. 9 Now, it's been established many times both 10 this morning and a couple of weeks ago that you 11 took all of your directions from either Mr. Evans 12 as your foreman or another Iowa-Illinois Thermal 13 employee or foreman on your job sites from 1965 to 14 1970; is that right? 15 A. Right. 16 Q. And you talked two weeks ago about the 17 fact when you guys arrived on site, Mr. Evans or 18 another Iowa-Illinois foreman would go off with a 19 representative from -- the premises owner and walk 20 the job; is that right? 21 MS. FELKINS: Objection. Mischaracterizes 22 the testimony. 23 DEFENSE ATTORNEY: I'll join. 24 THE WITNESS: I mean, not necessarily. PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by ^lr. Hayes] 1 Sometimes we just went on the job and started Page 36 2 working. But I assumed they had already went 3 through that process and didn't drag me along for 4 that. I just showed up when they were going to 5 start doing the work. 6 BY MR. HAYES: 7 Q. All right. And you were not privy to any 8 discussions that Mr. Evans or any of your other 9 Iowa-Illinois Thermal foreman had with 10 representatives from the owners of these buildings; 11 is that right? 12 A. No. 13 Q. So you don't know what the owners of the 14 premises or their representatives told Mr. Evans; 15 is that right? 16 A. No. I have no idea what was being 17 discussed on any of those things. 18 Q. Now, you mentioned two weeks ago that part 19 of your work with Mr. Evans involved removing old 20 insulation when you arrived on a job site, but a 21 lot of that work was already done by -- it was 22 already done when you arrived; is that right? 23 A. More times than not, yes. 24 Q. Can you give me a percentage of the time PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes Page 37 1 when the old insulation had already been removed? 2 A. Oh, I'd say, from my recollection at 3 least, 75 percent of the time it was already off. 4 Q. Okay. And to the best of your knowledge, 5 that wasn't torn off by anyone at Iowa-Illinois 6 Thermal; is that right? 7 A. Yeah, to the best of my knowledge, it 8 wasn't. 9 Q. Okay. Do you recall, as you sit here 10 today, any specific occasion when you saw 11 John Evans actually tear off or remove old 12 insulation at the job site? 13 A. No, not really. 14 Q. Do you recall him ever being around the 15 removal of old insulation on any job site? 16 A. Well, I mean, I recall us maybe having to 17 take more off than what they had taken because - 18 to repair it right. And we would have done it 19 then. And whether he had me take it off or he took 20 it off, I can't really recall for sure. 21 But I know it was -- there I can tell you 22 90 percent of the time if the plumbers and fitters 23 took it off, we were going to have to take a little 24 more off because they weren't going to take it off PohlmanUSAC ourt Reporting (877) 421-0099 xamination by Mr. Hayes 1 just right to where we could patch it right. 2 Q. Sure. Page 38 3 A. But it wouldn't necessarily be a lot. It 4 would just be enough to where we can patch it and 5 make it look all right. 6 Q. Okay. And you have no personal knowledge 7 who would have installed or applied that old 8 material before - 9 A. No. 10 Q. -- you removed it; is that right? 11 A. No. 12 Q. And do you have any personal knowledge 13 that any of the old insulation that Mr. Evans was 14 around being removed contained asbestos? 15 A. Well, I mean, there's no way -- I mean, 16 today you can't tell without testing it, so I mean, 17 there's no way I can know for sure. 18 Q. Okay. Do you recall ever attending an 19 asbestos screening program? 20 A. Asbestos screening program as -- what do 21 you mean? 22 Q. A medical evaluation or screening to 23 determine if you had suffered any adverse results 24 or -- PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^Ir. Ludo Page 39 1 A. Well, why would you be asking what I did? 2 I'm not suing you. 3 Q. I'm just asking if you ever attended it. 4 A. Well, I'm just wondering why you would ask 5 that question. 6 Q. I'm just trying to find out if the union 7 ever sponsored anything like that? 8 A. Our union, no. 9 MR. HAYES: Okay. I'm almost done, 10 Mr. Lang. Just give me one second. 11 (Brief pause.) 12 Okay. That's all I have, Mr. Lang. Thank 13 you. 14 THE WITNESS: Okay. 15 EXAMINATION 16 BY MR. LUDOLPH: 17 Q. Mr. Lang, I'm Mark Ludolph. 18 A. Yeah. 19 Q. I questioned you a little bit at your 20 prior deposition. I have one other client I was 21 going to ask you about. You've testified quite a 22 bit about some work that you did with Mr. Evans at 23 Clinton Corn and I just want to make sure I've got 24 the time frames correct. PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^4r. Ludo Page 40 1 I think that, according to the records 2 that were produced and your testimony, you worked 3 with him as a helper in '65 and '66? 4 A. Right. 5 Q. And then in '69 and '70? 6 A. Uh-huh. 7 Q. Does that sound right? 8 A. We had a couple of weeks in, too, but I 9 don't think there was anything with Clinton when I 10 came back. 11 MR. COHN: Are you asking Clinton 12 specifically? 13 MR. LUDOLPH: Clinton specifically, yes. 14 THE WITNESS: I don't think there was 15 anything -- when I had come home on leave, I don't 16 believe there was anything going on at Clinton Corn 17 any of those times. So I think that would be the 18 time frames that -- and, actually, after I got out 19 of the Service, it seemed that was the biggest on 20 the time sheets where we had the most -- where we 21 were there for such a long period of time. 22 BY MR. LUDOLPH: 23 Q. And is it correct that you were a helper 24 for Mr. Evans the entire time you worked with him PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^4r. Ludo 1 at Clinton Corn? Page 41 2 A. Well, you know, that's what they called 3 them when you first started out. Like I just 4 testified, it took six months before you could 5 apply to get into the union, and at that time, you 6 became an apprentice, then they gave you credit for 7 the time. So I was an apprentice -- the first six 8 months I was a helper, then I was an apprentice. 9 But I was an apprentice during all that time, yes. 10 Q. You were never with Mr. Evans at Clinton 11 Corn once you became a journeyman; is that correct? 12 A. I sure don't remember being back there. 13 No, I don't think so. 14 Q. And all the times that you worked -- you 15 recall working with Mr. Evans at Clinton Corn, you 16 were working for Iowa-Illinois Insulation? 17 A. Right. 18 Q. And when you were working on those jobs at 19 Clinton Corn, were the insulating materials used on 20 that supplied by your employer? 21 A. To the best of my recollection -- I tried 22 to remember if we had, because when we really were 23 up there for a long period of time, I vaguely 24 remember they had like a maintenance shop there and PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^4r. Ludo Page 42 1 it seemed like we had material stored over there, 2 but I'm sure the material came from us, that we 3 brought it in. 4 Q. You had mentioned, I think, in your last 5 testimony that sometimes on maintenance jobs you 6 might use material that was kept at the various job 7 sites? 8 A. Yeah, if you had a place that they would 9 let you keep your materials, you know. 10 Q. But those insulation materials, to your 11 knowledge, were those originally supplied to those 12 job sites by Iowa-Illinois? 13 A. I would assume, yeah, because if they had 14 the contract, they're going to want to save the 15 materials. 16 Q. Okay. You talked a little about the 17 different plants that were out at Clinton Corn and 18 I think you identified a sugar plant? 19 A. Well, I'm not positive of a sugar plant. 20 I remember syrup and I remember the alcohol. I 21 remember the -- that's the one I told you blew up 22 there on -23 Q. I think you said a starch plant. 24 A. Yeah. That was nasty, the starch plant. PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^4r. Ludo 1 I'll never forget it. Page 43 2 Q. Do you know which one of those plants you 3 would have spent most of your time in with 4 Mr. Evans? 5 A. I know we did a pretty good little job in 6 that alcohol plant -- I can't remember the exact 7 amount of time and a lot in that syrup -- because I 8 always had syrup on the bottom of the feet and too 9 much time in that starch -- I came home with a 10 brand-new jacket and a guy came along and cleaned 11 one of the conveyor belts and a hundred pounds of 12 starch was on my coat. 13 Q. You also talked a little about the types 14 of insulation you used. You defined pipe covering, 15 block insulation, and muds at Clinton Corn. 16 Were there any other types of insulation 17 materials you used at Clinton Corn? 18 A. Not that I really recollect. It was 19 almost always -- we might have done a gilsonite job 20 out there. But that wouldn't have had anything to 21 do with -- that's just some stuff you throw on the 22 ground --on the pipes in the ground. 23 Q. Well, with respect to the pipe covering, 24 you testified that not all the pipe covering you PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^4r. Ludo Page 44 1 used was asbestos-containing, that some of it might 2 have been fiberglass. 3 A. Some was fiberglass definitely. 4 Q. Did you testify that you used some - 5 well, let me ask you, did you also use some rubber 6 insulation on cold water lines and things like 7 that? 8 A. Well, back in that time, I know Armaflex 9 became a big thing. But I don't recall doing any 10 Armaflex back in the early days up there. To tell 11 you the truth, I didn't. I'm not saying it wasn't 12 around and that, but I just don't recall it in the 13 early days. I wish it would have been. Nice 14 insulation. 15 Q. And is it fair to say that generally if it 16 wasn't a hot application, that the insulation - 17 the insulation used wouldn't have contained 18 asbestos? 19 MR. COHN: Objection. Mischaracterizes 20 prior testimony. 21 BY MR. LUDOLPH: 22 Q. It's a bad question anyway. Let me 23 rephrase. Let's talk about piping at the facility. 24 If it wasn't steam or if it wasn't hot PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by iM!r. Ludolph] 1 water flowing through there, would you use 2 non-asbestos-containing insulation? Page 45 3 A. It probably would have been fiberglass, 4 then. 5 Q. And at Clinton Corn, not all the piping 6 was hot water or steam, was it? 7 A. No. 8 Q. Can you give a breakdown of what 9 percentage might have been -10 A. No. I wouldn't have -- that's way too far 11 back on that. 12 Q. Is it fair to say that you and Mr. Evans 13 would have worked on both types of piping in the 14 facility ? 15 A. Right. 16 Q. Earlier you were talking about using 17 mineral wool on certain jobs. 18 Do you recall using any mineral wool 19 products at Clinton Corn? 20 A. I don't. And I can't think of a reason 21 why we would have. 22 Q. During the time you were on the job with 23 Mr. Evans, you would have taken your direction from 24 Mr. Evans, correct? PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by iM!s. Felkins] 1 A. Uh-huh. Yes. Page 46 2 Q. All right. Do you recall the names of any 3 of the -- I think you testified that sometimes 4 Mr. Evans would deal with the engineers from 5 Clinton Corn about various projects? 6 A. I mean, I recall him talking to people 7 from Clinton Corn, but I couldn't give you any 8 names or anything like that. 9 Q. That was the next question. 10 Do you ever recall seeing any 11 specifications for any of the insulation work that 12 you did at Clinton Corn with Mr. Evans? 13 A. No. 14 MR. LUDOLPH: I think that's all the 15 questions I have for you. Thank you very much. 16 MR. COHN: Anyone else? 17 EXAMINATION 18 BY MS. FELKINS: 19 Q. Hi, Mr. Lang. 20 A. Hi. 21 Q. My name is Jill Felkins. We spoke a 22 couple of weeks ago about your work with Mr. Evans 23 at the Riverside and Alcoa facilities. 24 A. Uh-huh. PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by ^4s. Felkins] Page 47 1 Q. You mentioned, after I had already spoken 2 with you, that you may have worked on a Riley 3 Stoker boiler at the Riverside facility. 4 Do you remember that testimony? 5 A. I said it could have been a Riley Stoker. 6 I mean, I'm not accusing it of being a Riley 7 Stoker. 8 Q. Okay. Do you remember where in the 9 Riverside facility that boiler would have been 10 located? 11 A. No. 12 Q. Okay. Do you know when it would have been 13 installed? 14 A. Before I was born, probably. 15 Q. Okay. And you testified that you had been 16 doing some patching work on that boiler, I think? 17 A. Yeah, the things I recall doing out there. 18 And one time on a turbine deal, I was with John 19 there and - 20 Q. I just want to focus on the boiler work 21 for today. 22 No one at Riverside would have been 23 instructing you how to do that patching work on 24 that boiler; is that correct? PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^4r. Cohn 1 A. Not me. And John had been around long 2 enough by then that I'm assuming they wouldn't 3 have had at that time -4 Q. You don't recall anyone - Page 48 5 A. No. John would tell me how to do it and 6 what to do. 7 Q. You don't recall anyone from Riverside 8 standing over or supervising, watching you guys do 9 that work? 10 A. No. 11 MS. FELKINS: Okay. That's all I have. 12 Thank you. 13 THE WITNESS: Okay. 14 EXAMINATION 15 BY MR. COHN: 16 Q. Tom, real quick I want to ask you a couple 17 of follow-up questions, if that's okay, and then 18 we'll get you out of here. 19 Mr. Hayes, counsel for Iowa-Illinois, was 20 asking you some questions about union safety 21 meetings, and I may have asked you this last week 22 and I just want to clarify it for the record. 23 Do you ever recall any safety meetings at 24 Iowa-Illinois, employee safety meetings? PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by iM!r. Cohn] Page 49 1 MR. HAYES: I would object to asked and 2 answered. 3 BY MR. COHN: 4 Q. You can answer. 5 A. (Back in those days, no. 6 Q. When you say "back in those days," we' re 7 talking about '65 to '70 time frame? 8 A. Right. I'm talking in that era there, 9 yeah. 10 Q. Okay. You were asked a couple of 11 questions a while ago about steam lines and high 12 heat lines at these chemical plants or corn 13 by-product plants, Clinton Corn, Monsanto, any of 14 those types of facilities. 15 Were there also chemical lines or highly 16 corrosive material lines that needed to be 17 insulated by Iowa-Illinois insulators? 18 A. Oh, yeah. 19 Q. When you've got a highly corrosive 20 material running through a line, do you recall what 21 type of insulation would generally go on those 22 types of lines? 23 A. I'm trying to think. 24 At that time -- I'm trying to think. The PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by iM!r. Cohn] 1 insulations had changed so much that I couldn't Page 50 2 really tell you back in those days what they were 3 putting on them. Later on, they came up with 4 sugar. 5 Q. Do you have any recollection on, for 6 example , an acid line what type of insulation you 7 would generally put on in that time frame? 8 A. Not really. Not really. And I remember 9 doing an acid tank with John, and I can't recall 10 what we were putting on. The only reason I know it 11 was an acid tank, there happened to be a bubble on 12 the side of the tank and he decided to hit it with 13 his hand and he went -- it was acid and there was a 14 leak in the tank. 15 Q. Do you remember where that tank was? 16 A. Truthfully, no. I'm not going to accuse 17 anybody of that one. I'd be trying to guess. 18 Q. No problem. 19 Going back to -- Mr. Hayes was asking you 20 about the JM cements. He asked you about the 301 21 cement. 22 Do you remember another JM cement, 352? 23 A. Now that you mention it, I recall that 24 number, but I can't recall what that cement was PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^^r. Cohn 1 supposed to do. 2 Was that along the blue mud side? 3 Q. I'm not sure. I'm just wondering if Page 51 4 you're familiar with the 352 and whether that was a 5 cement that you used during your time in working 6 with John? 7 A. Well, I'm just trying to remember if maybe 8 that's what we called blue mud -- with the blue mud 9 number, because the number is familiar when you say 10 it. But, you know, like I told him, we got so used 11 to saying one-coat -- oh, we're going to one-coat 12 this or we're going to blue-mud this or we're going 13 to -- you know. 14 Q. Okay. I understand, but I'm just asking 15 what you remember. 16 You mentioned earlier something along the 17 lines of you used a lot of 301 with Illinois-Iowa 18 and that you recall that 301 would have come 19 from -- would have been supplied by II. 20 Was the JM asbestos cements that were 21 used, were those generally during your time frame 22 working with John Evans supplied by Illinois-Iowa? 23 A. Well, I mean, yeah, they would come out of 24 our warehouse, yeah. PohlmanUSAC ourt Reporting (877) 421-0099 xamination by ^^r. Cohn Page 52 1 Q. Do you know whether Iowa-Illinois was a 2 distributor for the area of Johns Manville asbestos 3 cement products? 4 A. (i think they were the distributor for all 5 of Johns Manville in this area at that time. 6 Q. Do you know whether that distribution 7 included the Illinois side of the river as well? 8 A. Oh, i'm sure whatever their jurisdiction 9 area was, because i think Taylor had the 10 Owens Corning distribution. 11 Q. So is it your recollection that during 12 that time period -- well, strike that. 13 When you say Iowa-Illinois had the JM or 14 Johns Manville distribution for the entire area, do 15 you know how long that lasted or into what time 16 period they had that distribution? 17 A. (A long time. But I couldn't tell you when 18 that -- they still may have some type of franchise 19 with them. I don't know. I don't think they do, 20 but I'm not sure. I couldn't tell you when that 21 would have ended. 22 Q. Sure. 23 Is it your belief that based on that 24 agreement, if a JM or Johns Mansville asbestos PohlmanUSAC ourt Reporting (877) 421-0099 [Examination by ^lr. Cohn] 1 cement product was sold in this area for a Page 53 2 project -- a large insulation project, would it 3 have come from Iowa-Illinois? 4 MR. HAYES: Let me just object to the 5 characterization of whatever he's talking about as 6 an agreement. 7 BY MR. COHN: 8 Q. You just testified, Tom, that you believe 9 that there was some sort of franchise agreement, 10 right? 11 A. Well, I think they had the franchise in 12 the area where you could buy the product out of the 13 warehouse. But I mean, I would have to think - 14 but now that's speculation on my part -- on big 15 jobs. 16 Q. And I don't want you to speculate. 17 A. It would probably be shipped directly to 18 that job rather than -- you know, they had a big 19 warehouse, but it was only so big. 20 Q. And then you indicated that Taylor 21 Insulation, you said, had what you believe was an 22 agreement with Owens Corning? 23 A. If you wanted Owens Corning, you went to 24 Taylor. If you wanted Johns Manville, you went to PohlmanUSAC ourt Reporting (877) 421-0099 urther Examination by Mr. Hayes 1 Iowa-Illinois back in those days. Page 54 2 MR. COHN: Okay. I don't have anything 3 else, Tom. Thanks. 4 FURTHER EXAMINATION 5 BY MR. HAYES: 6 Q. Mr. Lang, just a couple of questions 7 following up on that. 8 There were other insulation contractors in 9 the Quad Cities besides Iowa-Illinois and Taylor; 10 is that right? 11 A. Yeah. But they didn't get much of the 12 action back in those days. Those two had it pretty 13 well cut up between the two of them. 14 Q. All right. What were some of the other 15 insulation contractors that worked in the area? 16 A. I think it was still -- Economy Roofing 17 still had a -- in those days had a small shop. 18 Tom Taylor actually came from Economy Roofing. He 19 ran their insulation and then he went on his own. 20 Actually, at that time -- it's hard for me 21 to say. It would probably have to be -- I don't 22 know if AC&S was in existence back then, out of 23 Peoria, or -- I'm telling you, them two really had 24 this area chopped up for a long time. That's when PohlmanUSAC ourt Reporting (877) 421-0099 urther Examination by Mr. Hayes 1 it was busy around here. Page 55 2 Q. And if someone wanted to buy insulation 3 materials for whatever reason, they could go 4 elsewhere besides Iowa-Illinois or Taylor, though, 5 in the Quad Cities area; is that right? 6 A. Oh, I'm sure there's places they can go, 7 yeah. 8 MR. HAYES: All right. That's all I have. 9 Thank you. 10 MR. COHN: I don't have anything else. 11 Anyone else? Anyone on the phone? 12 (No verbal response.) 13 All right. I guess that will conclude 14 your deposition, Tom. We appreciate your time. 15 THE REPORTER: Signature? 16 MR. COHN: Tom, you have an opportunity to 17 read and review the transcript, or you can waive 18 your right and say you'll waive signature. Really, 19 when you read and review, it's just for spelling 20 and that type of information. We can't change the 21 substance of your testimony. But it's your choice. 22 THE WITNESS: I'll waive reading it. 23 AND FURTHER, DEPONENT SAITH NOT... 24 PohlmanUSAC ourt Reporting (877) 421-0099 1 STATEOFILLINOIS ) Page 56 2 3 COUNTYOF KANE 4 5 ) ) 6 CERTIFICATE 7 8 I, Maria E. Shockey, Certified Shorthand 9 Reporter for the State of Illinois, do hereby 10 certify that there came before me at 200 East 11 3rd Street, Davenport, Iowa. 12 13 THOMAS LANG 14 15 who was by me first duly sworn to testify to the 16 truth and nothing but the truth of all knowledge 17 touching and concerning the matters in controversy 18 in cause; that the witness was thereupon carefully 19 examined under oath and said examination was 20 reduced to writing by me; and that this deposition 21 is a true and correct record of the testimony given 22 by the witness. 23 I further certify that I am neither 24 attorney nor counsel for nor related nor employed PohlmanUSAC ourt Reporting (877) 421-0099 Page 57 1 by any of the parties to the action in which this 2 deposition is taken; further, that I am not a 3 relative or employee of any attorney or counsel 4 employed by the parties hereto or financially 5 interested in this action. 6 7 Signed this 23rd of August 2011. 8 9 10 [CERTIFIED SHORTHAND REPORTER] 11 12 13 14 15 16 17 18 19 20 21 22 23 24 PohlmanUSAC ourt Reporting (877) 421-0099 Page 58 A accurate 18:18 accuse 50:16 accusing 47:6 acid 50:6,9 50:11,13 action 54:12 57:1,5 active 14:24 actual 20:3 AC&S54:22 Adams 4:20 added 2 7:16 adequate 25:24 Administrator 1:4 3:4 adverse 38:23 agent 18:12 ago 31:20 33:17 35:10 35:16 36:18 46:22 49:11 agree 33:22 agreement 52:24 53:6 53:9,22 al 1:9 3:9 Alcoa 7:6 46:23 alcohol 42:20 43:6 ALLEN 4:20 Alton 4:4 Ameren 4:11 AmerenUE 4:11 America 7:15 amount 43:7 ANGELIDES 4:2 answer 11:1 25:8 49:4 answered 10:23 49:2 answering 18:4 anybody 50:17 anyplace 16:1 anyway 26:21 44:22 Appeared 4:6 4:10,16,23 5:5,11,16 5:22 6:6,11 6:17,23 7:6 7:12,19 application 44:16 applied 33:24 38:7 apply 16:24 41:5 appreciate 55:14 apprentice 14:4 41:6,7 41:8,9 area 52:2,5,9 52:14 53:1 53:12 54:15 54:24 55:5 argue 18:16 Armaflex 44:8 44:10 arrived 35:17 36:20,22 asbestos 18:20 28:12 28:16,17 33:4 38:14 38:19,20 44:18 51:20 52:2,24 asbestos-c... 23:3 44:1 asked 10:23 48:21 49:1 49:10 50:20 asking 18:2 39:1,3 40:11 48:20 50:19 51:14 assume 25:9 31:1 42:13 assumed 36:2 as4s8u:2ming 1188::44 assumption 25:11 attend 15:2 attended 16:14 17:9 18:22 39:3 attending 38:18 attention 18:1 attorney 34:5 35:23 56:24 57:3 August 1:16 3:14 57:7 Avenue 5:13 aware 28:10 a.m3:15,15 A.W1:83:8 B B 5:10 back 18:15 19:16,17,20 20:6,12 21:17 22:4 22:5 24:24 26:19 34:14 40:10 41:12 44:8,10 45:11 49:5 49:6 50:2 50:19 54:1 54:12,22 bad 44:22 bag 27:2,24 bags 27:22 Bank 7:15 BARNERD 4:2 based 52:23 basically 28:6 beating 21:18 behalf 1:15 3:13 4:6,10 4:16,23 5:5 5:11,16,22 6:6,11,17 6:23 7:6,12 7:19 BEHNEN 6:16 behoove 26:17 belabor 27:20 belief 52:23 believe 9:1 11:23,24 12:12 15:17 28:13 40:16 53:8,21 belts 43:11 best 13:10 14:6,14 21:3 32:14 33:10 37:4 37:7 41:21 better 17:14 29:11 big 8:17 21:1 27:15 44:9 53:14,18,19 biggest 40:19 bit 14:22 17:4 33:16 39:19,22 BLACKWELL 5:2 blanket 28:17 blew 42:21 block 23:7 24:1 29:4 29:16 30:6 30:12 31:22 32:6 33:2 33:12 43:15 block-type 24:14 blue 10:4 19:11 27:9 27:10 28:22 29:10 51:2 51:8,8 blue-mud 51:12 boiler 47:3,9 47:16,20,24 boots 19:10 Borg-Warner 4:17,17 born 47:14 bottom 30:4 43:8 boy 16:19 18:10 brand 10:6,8 10:11 brands 9:20 brand-new 43:10 breakdown 45:8 BRIDDICK 4:9 brief 8:11 39:11 bring 18:6 bringing 18:7 Broadway 4:13 7:16 brought 42:3 BROWDER 4:2 Bryan 7:17 8:6 bubble 50:11 building 20:9 buildings 36:10 built 8:23 BURNS 6:8 bus 21:16 22:1 business 18:12 busy 55:1 buy 53:12 55:2 by-product 49:13 C c1:3 3:3 4:1 5:1 6:1,16 6:21 7:1,10 CALEB 4:15 call 17:21 18:13 28:5 called 8:2,7 41:2 51:8 Calls 14:11 25:5 34:2 canvas 31:12 car 15:20 16:11 care 33:8 career 34:9 carefully 56:18 Carondelet 5:3 Case 1:7 3:7 Cat 8:14,16 8:16,22 9:13 category 13 : 19 Caterpillar Page 59 7:19 8:7,21 9:22 10:8 11:12,20 12:10 CATHERINE 5:4 cause 56:18 Cedar 15:12 cement 25:19 50:21,22,24 51:5 52:3 53:1 cements 25:17 28:10 29:6 50:20 51:20 certain 45:17 certainly 24:21 CERTIFICATE 56:6 Certified 56:8 57:10 certify 56:10 56:23 change 55:20 changed 8:13 50 : 1 characteri... 53:5 chemical 32:10 49:12 49:15 CHESTERTON 1:8 3:8 Chicago 5:19 6:9,20 7:3 7:9 choice 25:4 55:21 chopped 54:24 CIRCUIT 1:1,1 3:1,1 Cities 15:10 54:9 55:5 clarify 13:2 18:18 26:8 32:2 48:22 cleaned 43:10 clear 9:8 Cleaver-Br... 6:12 client 39:20 Clinton 15:24 39:23 40:9 40:11,13,16 41:1,10,15 41:19 42:17 43:15,17 45:5,19 46:5,7,12 49:13 coat 27:10 29:9 43:12 Cohn 2:8 4:5 10:23 12:16 14:11 25:5 40:11 44:19 46:16 48:15 49:3 53:7 54:2 55:10 55:16 cold 25:24 44:6 come 12:20 26:3,18 30:13 40:15 51:18,23 53:3 coming 23:18 27:21,23 30:15 31:14 common 18:13 company 4:11 4:11,18 5:6 5:17 6:6,18 6:23 7:6,7 7:12 8:7 20:16 22:3 25:2 compound 9:20 concerning 56:17 conclude 55:13 conclusion 14:12 confused 26:22 consider 14:7 considered 14:4 construction 11:21 contain 28:11 33:4 contained 38:14 44:17 continually 31:19 continued 3:12 5:1 6:1 7:1 13:23 contract 34:21 42:14 Contracting 5:23 contractors 54:8,15 controversy 56:17 conveyor 43:11 convinced 24:18 corduroy 19:11 COREY 5:15 corn 15:24 39:23 40:16 41:1,11,15 41:19 42:17 43:15,17 45:5,19 46:5,7,12 49:12,13 Corning 52:10 53:22,23 Corporation 4:17,24 5:6 6:12 correct 9:23 10:14,15,17 10:22 11:8 11:14 12:2 39:24 40:23 41:11 45:24 47:24 56:21 corrosive 49:16,19 counsel 48:19 56:24 57:3 COUNTY 1:2 3:2 56:3 couple 17:7 33:17 35:10 40:8 46:22 48:16 49:10 54:6 Court 1:1 3:1 4:3 covering 23:7 29:16,23 30:1 31:21 32:5 33:2 33:12 43:14 43:23,24 cracks 30:13 32:10 Crane 5:11 6:12 CREBS4:13 credit 41:6 CSR1:18 3:17 cut 34:11 54:13 D D 2:1 4:15 damaging 33:14 Davenport 3:17 5:9 9:13 56:11 day3:16 22:9 26:19 29:14 days 10:3 18:15 19:16 19:20 33:8 34:14 44:10 44:13 49:5 49:6 50:2 54:1,12,17 de 5:17 deal 21:16,23 33:9 46:4 47:18 Deceased 1:5 3:5 decided 50:12 decision 33:23 Deere 6:23 16:2,3 Defendant 5:5 5:11,16 6:6 6:18,23 7:19 Defendants 1:10,15 3:10,14 4:11,17,23 5:22 6:12 7:6,12 DEFENSE 34:5 35:23 defined 43:14 definitely 20:19 44:3 demand 17:14 depended 23:23 depending 34:20 DEPONENT 55:23 deposeth 8:3 deposition 1:13 3:12 22:9 29:15 39:20 55:14 56:20 57:2 determine 38:23 DICKENSON 5:4 dictated 19:12 dictating 32 : 9 different 13:19 22:8 25:17 26:10 26:11 27:1 27:21 42:17 direction 45:23 directions 10:21 35:11 directly 53:17 DISCOVERY 1:13 3:12 discuss 17:20 discussed 16:15 17:8 36:17 discussing 18:19 discussions 36:8 distinction Page 60 13:15 distribution 52:6,10,14 52:16 distributor 52:2,4 doing 11:10 12:4 20:21 30:3 34:15 36:5 44:9 47:16,17 50:9 doubt 24:23 drag 3 6:3 drive 6:20 7:3,9 15:19 15:23,24 driven 21:13 dry 34:11 du5:17 Dubuque 16:2 duly 8:3 56:15 d/b/a 4:11 E E1:18 2:1 3:17 4:1,1 5:1,1 6:1,1 7:1,1 56:8 earlier 45:16 51:16 early 18:23 20:8,23 44:10,13 easier 31:22 East 3:16 56:10 Economy 54:16 54:18 Edwardsville 4:8 effective 24:18 either 19:11 35:11 elbow 25:21 26:16 elbows 9:5,13 9:16,21 25:23 Electric 4:11 employed 56:24 57:4 employee 11:7 11:13 14:8 20:15 35:13 48:24 57:3 employees 13:16 32:7 33:13 employer 41:20 ended 52:21 ends 29:20 Energy 7:6 engineers 46:4 entire 40:24 52:14 entities 12:23 equipment 21:10 era 20:3 21:21 28:20 49:8 eras 19:3 especially 32:15 34:7 established 35:9 Estate 1:5 3:5 et1:9 3:9 evaluation 38:22 Evans 1:3,5 3:3,5 8:20 9:14 11:21 12:10,11 13:7,11,19 14:7,24 15:8,15,19 16:12 20:1 22:10,13 35:11,17 36:8,14,19 37:11 38:13 39:22 40:24 41:10,15 43:4 45:12 45:23,24 46:4,12,22 51:22 everybody 19:18 21:1 21:24 exact 21:19 43:6 exactly 8:24 examination 2:4,5,6,7,8 8:4 12:18 39:15 46:17 48:14 54:4 56:19 examined 3:13 56:19 example 50:6 EXHIBITS 2:15 existence 54:22 experience 14:23 17:5 32:13 extra 27:12 extreme 26:7 extremely 26:2 E.I 5:17 F facilities 46:23 49:14 facility 8:21 9:14,22 11:12 12:10 44:23 45:14 47:3,9 fact 34:8 35:17 fair 8:18 10:5,9 12:10 22:12 24:20 25:1 33:22 34:6 44:15 45:12 fairly 8:11 fall 18:10 familiar 51:4 51:9 famous 20:4 FANNING 6:10 far 10:21 45:10 faster 24:15 FAX 4:4,9,14 4:21 5:4,9 5:14,20 6:4 6:9,15,21 7:4,10,17 feet 43:8 Felkins 2:7 7:4 34:4 35:21 46:18 46:21 48:11 fiberglass 23:3,10,10 23:18,21 24:3,4,8,21 25:3 29:16 29:22 30:6 30:10,11 32:1,18 44:2,3 45:3 fiberglass... 9:3 fill 12:1 30:14 financially 57:4 find 27:1 39:6 FINGERSH5:13 finish 25:22 26:6 27:10 27:19 28:23 30:7 finishing 28:11 first 13:2 16:23 20:7 23:8 31:3 41:3,7 56:15 fitters 37:22 five 32:18 floor 4:13 7:16 20:11 Floors 7:12 flowing 45:1 focus 17:24 18:24 47:20 followed 34:17 following 54:7 follows 8:3 follow-up 48:17 Foods 4:23 foreman 11:16 12:4 13:20 14:17 34:17 35:12,13,18 36:9 forget 43:1 four 32:18 Fourth 6:14 four-inch 35:6 frame 13:6 14:9 15:1 49:7 50:7 51:21 frames 39:24 40:18 franchise 52:18 53:9 53:11 Friday 15:3,5 further 54:4 55:23 56:23 57:2 future 31:14 f/k/a 4:11 5:6 G Gasket 6:6 generally 16:6 17:10 44:15 49:21 50:7 51:21 getting 20:11 23:11 35:5 35:6 GIANARIS 4:2 gilsonite 43:19 give 20:20 22:16 27:16 34:21 36:24 39:10 45:8 46:7 given 10:20 34:23 56:21 glass 27:18 Global 4:23 Page 61 17:21 18:13 18:16 22:19 23:24 26:2 26:20 27:10 31:15 35:18 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45:6 hours 3:15 huge 14:1 hundred 43:11 HUSCH 5:2 H.J7:7 I idea 36:16 identified 22:2 42:18 II 1:12 51:19 IIT19:19 Illinois 1:2 1:19 3:2 4:4,8,21 5:19 6:9,20 7:3,9 22:6 22:11,20,21 52:7 56:1,9 Illinois-Iowa 51:17,22 IMO4:23 inches 26:18 included 52:7 inclusive 12:8 Incorporated 8:8 indicated 53:20 indicating 27:18 Individually 1:4 3:4 individuals 32:6 Industries 4:23 industry 24:11,17 information 55:20 inkling 11:19 input 33:21 installed 29:16 33:24 38:7 47:13 instance 32:10 instructing 47:23 instructions 11:7 insulated 49:17 insulating 25:19 28:11 41:19 insulation 5:22,23 7:13 13:4,8 13:12 24:15 27:13,16 32:15 36:20 37:1,12,15 38:13 41:16 42:10 43:14 43:15,16 44:6,14,16 44:17 45:2 46:11 49:21 50:6 53:2 53:21 54:8 54:15,19 55:2 insulations 50:1 insulator 21:6 24:20 insulators 13:17 19:4 27:5 49:17 interest 32:14 interested 57:5 interesting 16:20 involved 31:9 33:20 34:8 36:19 in-town 16:4 Iowa 3:17 5:9 9:13 22:14 22:21,22 56:11 Iowa-Illinois 5:22,22 10:10,13,16 10:20 11:8 11:13 12:23 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10:24 29:21 31:23 35:22 40:2 42:5 44:20 47:4 55:21 56:21 testing 38:16 Thank 12:14 39:12 46:15 48:12 55:9 Thanks 12:15 54:3 Thermal 13:4 13:8,12,16 14:8 19:4,9 19:13,19 20:14 21:11 25:2 35:12 36:9 37:6 Thermobestos 24:1 28:5 they'd 14:2 Page 66 15:5 18:15 34:21 thick 26:15 35:6,7 thickness 26:16 thing 9:3 11:4 13:2 17:19 18:10 20:6 21:1,4 23:16 24:18 28:7 44:9 things 16:15 17:13,15,22 18:5,14,15 24:1 36:17 44:6 47:17 think 10:1 17:20 19:16 19:18 22:4 22:5,6 23:8 23:11,22,23 24:6,18 27:4 28:15 28:19 40:1 40:9,14,17 41:13 42:4 42:18,23 45:20 46:3 46:14 47:16 49:23,24 52:4,9,19 53:11,13 54:16 thinking 9:1 24:11 THIRD 1:1 3:1 THOMAS 1:14 2:2 3:13 4:9 5:20 8:1 56:13 thought 23:2 23:5 three 26:17 three-inch 26:16 throw 43:21 time 8:19 9:4 9:17 10:6 12:4,5,7,9 13:6,12,16 13:24,24 14:2,8 15:1 15:4,5,13 15:16 17:5 17:15 18:1 18:3,17 19:1,2,12 19:14 20:17 20:19 21:12 22:4 23:1 23:21 24:6 24:8,22 27:6 28:2,9 30:20 31:16 31:19,21 34:8 36:24 37:3,22 39:24 40:18 40:20,21,24 41:5,7,9,23 43:3,7,9 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40:8 46:22 weighed 24:13 weight 24:14 went 16:2,3 31:19 32:16 36:1,2 50:13 53:23 53:24 54:19 weren't 13:24 28:21 37:24 we'll 17:22 48:18 we're 18:9,24 31:6 49:6 51:11,12,12 we've 12:6 WILLIAMS 7:15 wish 44:13 witness 2:2 8:2 11:1 34:6 35:24 39:14 40:14 48:13 55:22 56:18,22 wonder 14:23 wondering 39:4 51:3 wool 28:14,17 28:24 45:17 45:18 work 8:23 10:21 11:20 11:22 13:1 13:23 19:10 36:5,19,21 39:22 46:11 46:22 47:16 47:20,23 48:9 worked 11:11 12:9 13:6 13:22 15:1 15:19 19:5 22:9,13 40:2,24 41:14 45:13 47:2 54:15 worker 34:10 working 8:20 11:15 13:7 13:11 16:7 18:9 19:9 36:2 41:15 41:16,18 51:5,22 wouldn't 30:8 30:9,13 34:6 38:3 43:20 44:17 45:10 48:2 writing 22:2 26:4 56:20 wrong 28:15 _________X X 2:1 Y yeah 9:11 11:15 14:19 15:13,14 18:5 19:16 22:15 23:18 25:20,20 28:4 29:7 29:19 31:2 31:19 37:7 39:18 42:8 42:13,24 47:17 49:9 49:18 51:23 51:24 54:11 55:7 year 20:20 21:19 23:15 years 11:9 18:23 21:18 34:20 35:2 yell 12:21 Yep 12:16 Young 7:12,13 __________0 084-004411 1:19 1 10-L-10771:7 3:7 10:56 3:15 100 4:13 6:14 7:16 1000 6:14 1010 6:3 11:26 3:15 12 2:5 124 4:20 1304:8 135 6:8 14th4:13 1400 5:19 16 1:16 3:14 190 5:3 196513:7 28:9 35:13 1970 13:7 18:1 19:1 20:17 21:12 28:9 35:14 2 200 3:16 56:10 2011 1:16 3:14 57:7 21st 7:16 220 5:8 23rd57:7 2300 6:8 231-1776 6:15 231-4656 4:14 231-6700 4:14 233 6:20 7:3 7:9 241-6065 5:14 2500 5:13 256-8800 6:9 258-5600 6:21 258- 5784 6:21 259- 2222 4:4 259-22514:4 _________3 3rd 3:16 56:11 300 30:19 301 9:24 10:2 25:18,20 26:10,12,24 27:2,22 28:1 29:17 29:23 30:19 30:21 50:20 51:17,18 309 4:21,21 312 5:20,20 6:9,9,21,21 7:4,4,10,10 314 4:14,14 5:4,4,14,14 6:4,4,15,15 7:17,17 324-1616 5:9 324-3246 5:9 33 5:19 345-5000 7:17 345-5055 7:17 352 50:22 51:4 39 2:6 4 444-7600 5:14 46 2:7 48 2:8 480-1500 5:4 480-1505 5:4 5 50 23:21 50/50 23:6 50/50-type 23:16 500 6:3 528015:9 54 2:5 5500 7:3,9 558-3900 5:20 558-8348 5:20 563 5:9,9 __________6 60s 23:17 60/40 23:15 600 4:20 5:3 5:8,13 60602 5:19 60603 6:9 60606 6:20 7:3,9 61602 4:21 618 4:4,4,9,9 62002 4:4 62025 4:8 621-9800 6:4 621-9802 6:4 627-1717 7:4 7:10 627-4109 7:4 7:10 63101 5:14 6:3 63102 4:14 6:15 7:16 63105 5:3 6518:1 19:1 19:17,23 20:16 21:12 21:20 23:14 40:3 49:7 656-0184 4:9 656-1364 4:9 66 40:3 6600 6:20 676-0400 4:21 676-3374 4:21 69 31:9 40:5 7 7019:23 40:5 49:7 70/30 23:15 741-4692 6:9 75 37:3 8 8 2:4 80/20 22:23 81 14:15 81's14:16 889-8000 6:15 __________9 90 37:22