Document o9wO1XMe7Ykr1DJ2YG9yNavZr

14. I met Mr. Beers when he came to work at Bob Bell Ford as a mechanic. His service bay was located next to mineTn the service department of Bob Bell Ford. 15. I learned through Mr. Beers and others that he worked at Bob Bell Ford prior to 1984, when I first met him. 16. Mr. Beers worked with me at Bob Bell Ford from approximately 1984 through approximately 1986 and then again from approximately 1992 through approximately 1999, when Mr. Beers retired. 17. Mr. Beers and I were friends. 18. Mr. Beers was an excellent mechanic and I respected him. 19. All of the mechanics performed basically the same type of work in Bob Bell Ford's service department. 20. That work included i) brake repair, service, maintenance and repair; ii) vehicle clutch replacement and service; iii) tune-ups; iv) oil changes; v) engine repair; and, vi) any other type of vehicle repair that was required. 21. Mr. Beers performed all of the same type of work that every other mechanic performed at Bob Bell Ford's service department. In addition to the general type of work described above, Mr. Beers had special skills, expertise and knowledge with regard to maintaining, servicing, rebuilding and replacing Ford automatic transmissions. 22. In addition to Mr. Beers' general mechanic work and specialized skills with respect to Ford automatic transmissions, Mr. Beers was also a Maryland State safety inspector at the dealership. 2 no policy regarding the blowout of clutch bell housings prior to approximately 1988. 57. Clutches, like brakes for Ford Motor Company vehicles serviced at Bob Bell Ford came from the dealership's parts department. 58. Replacement clutches for Ford Motor Company vehicles serviced at Bob Bell Ford came in boxes that indicated the replacement clutch came from Ford Motor Company. 59. During my tenure at Bob Bell Ford, I never saw a warning regarding any danger or work practice standards in connection with Ford Motor Company clutches. 60. The dust created by i) the removal of the brake drum; ii) the blowing out of the brake drum and the brake assembly with compressed air; iii) the sanding of new and existing brake shoes; iv) the chamfering of brake shoes on bench grinders got all over the dealership service area; and, v) the blowing out of the bell housing assembly area with compressed air was a) visible; b) copious; c) respirable; and d) unavoidable by any person in the service department, even those who were not performing the work. 61. Bob Bell Ford never issued respirators or even dust masks to its mechanics during the time I worked at the dealership, including the time I worked with Mr. Beers, or even to this day. 62. During my tenure with Bob Bell Ford, I attended a number of Ford Motor Company training sessions at Ford Motor Company's training offices in Northern Virginia. These trainings were conducted by Ford Motor Company 8 69. Mr. Beers was a Maryland State safety inspector for Bob Bell Ford. 70. When Bob Bell Ford traded-in a low mileage vehicle that it wanted to sell on its used car lot, Mr. Beers would inspect those vehicles. 71. I personally observed Mr. Beers inspect many cars. While I cannot give a precise number of vehicles Mr. Beers inspected, it was in the hundreds. 72. Mr. Beers was not the only inspector of used vehicles at the dealership. 73. In addition to vehicles manufactured by Ford Motor Company, Bob Bell Ford traded many non-Ford Motor Company manufactured vehicles, including vehicles manufactured by Honda, Nissan (Datsun), Toyota, General Motors and Chrysler. 74. In the course of inspecting those vehicles, Mr. Beers would pull the wheels off and inspect the brakes. As with most of the vehicles in production during that time period, brakes on those cars were of the front-disc, rear-drum variety. 75. Inspecting those vehicles' brake systems involved spraying compressed air into the brake drums and onto the brake assemblies to be able to visualize the brake shoes and components free from brake dust. 76. Blowing off the dust from the rear brake drums on those vehicles with compressed air created the same type of dark, visible brake dust that was created when blowing off brake drums on Ford Motor Company vehicles. 77. If work was required to those used vehicles pass the Maryland Safety inspection, that work would be performed by the dealership's mechanics, including by me. 10 78. Based on my training, experience and recollection, most of the vehicles that were traded in by Bob Bell Ford still had their original brakes. 79. On those occasions when brakes needed to be replaced in order that a tradedin vehicle would pass inspection, the replacement brakes would come from an auto supply store and would be brakes manufactured by Wagner and Raybestos, among others. I do not recall many Original Equipment Manufacturer ("OEM") brakes used to replace brakes on the non-Ford Motor Company trade-ins. 80. My best estimate is that approximately 90% of the vehicles worked on in the Bob Bell Ford dealership during my tenure were Ford Motor Company vehicles. The remaining approximately 10% of the vehicles were Toyota, Nissan, Honda, General Motors and Chrysler manufactured vehicles. 81. I cannot provide any further good-faith estimate of the breakdown of the approximately10% non-Ford Motor Company manufactured vehicles, except to say that Bob Bell Ford regularly and frequently inspected and worked on Nissan, Honda and Toyota vehicles, including servicing and replacing brakes on these vehicles. 82. At Bob Bell Ford mechanics were and still are responsible for sweeping up and keeping their work area clean. This was true during the time I worked with Mr. Beers at the dealership. 83. Every mechanic regularly swept up his work area, particularly after performing brake or clutch work. 11