Document om4bnqkdVGr9RwKam1vqXpjoo

It: Re: Asbestos IV IN THE CIRCUIT COURT OF KANAWHA COUNTY WEST VIRGINIA IN RE: ASBESTOS IV CIVIL ACTION NO; 95-8888 The deposition of TERRY K. LINDQUIST, taken upon oral examination, pursuant to notice and pursuant to the West Virginia Ruies 0f Civil Procedure, before Monique Christiansen, Court Reporter and Notary Public in and for the State of West Virginia, Friday, June 9,1995, at the offices of Goldberg, Persky, Jennings, White & Hostler, Suite 1400, 910 Fourth Avenue, Huntington, West Virginia. JOHNNY JACKSON & ASSOCIATES, INC. 606 Virginia Street, East Charleston, WV 25301 (304) 346-8340 |APPEARANCES: GOLDBERG, PERSKY, JENNINGS & WHITE, P.C. (Bruce Carter appearing) 1030 Fifth Avenue, Pittsburgh, Pennsylvania, 15219, (412) 471-3980, Counsel for Plaintiffs. PIETRAGALLO, BOSICK & GORDON (Eric K. Falk appearing) One Oxford Center, Thirty-Eighth Floor, Pittsburgh, ennsylvania, 15219, (412) 263-2000, Counsel for Allied Signal. BAKER & Marsteller (Roy D. Baker appearing) 1108 Third Avenue, Suite 300, Huntington, West Virginia, 25701 (304) 522-6906, Counsel for Borg-Warner. BARNARD AND GANNON (Timothy B. Barnard appearing) The Williamson House, 218 West Front Street, P.O. Box 289, Media, Pennsylvania, 19063-0289, (610) 565-4055, Counsel for Borg-Wamer. INDEX DEPONENT: TERRY K LINDQUIST JUNE 9,1995 EXAMINATION BY: PAGE: Mr. Carter.............. 4 EXHIBIT IDENTIFICATION: Exhibit No. 1............. 4 Exhibit No. 2............. 4 Exhibit. No 3 ......... 10 Exhibit No. 4............. 57 Exhibit No. 5............. 73 [Exhibit No. 6............. 73 Exhibit No. 7.............88 Terry K. Lindquist; 6/9/95 Page 4 TERRY K. LINDQUIST, DEPONENT, SWORN EXAMINATION BY MR. CARTER: Q. My name is Bruce Carter. I represent some of the plaintiffs in this case. Ifyou would, please state your name for the record? A* My full name is Terry K. Lindquist, L-I-N-D-Q-U-I-S-T. Terry is the proper name. Q. Where do you presently reside? A. Presently reside in a suburb of the City of Chicago. The name of the suburb is Winfield, W-I-N-F-I-E-L-D, Illinois. Q. How old are you today? A. I am 56 years old. Q. I am going to hand you, after the court reporter marks this, a copy of the notice of deposition. (Exhibit Nos. 1 and 2 were marked for identification.) BY MR. CARTER: Q. Take a look at that. Have you ever seen this notice of deposition before or a copy of it? Page 5* I 1 A. Yes. 2 Q. The first thing I would like to do is go 3 through each of the items on there. There are some 4 eight areas to be covered. 5 I would like for you to go through each 6 one and tell me whether you feel that you are the 7 most knowledgeable person for that area, or ifyou 8 feel competent to testify on the subject matter on 9 each of the numbered paragraphs. 10 MR. BAKER: While he's doing that let me 11 just state generally for the record. Don Baker, on 12 behalf of Borg-Warner, the first part ofyour 13 question I am not sure that he's technically in a 14 position to answer, I can tell you that we believe 15 that Mr. Lindquist is the person who has the most 16 knowledge about most of these areas that we are aware 17 of at the present time. That's why we have produced 18 him here today. 19 As far as the second part of your 20 question, I am quite comfortable with him going 21 through each point and telling you what he knows 22 about those points. 23 BY MR. CARTER: 24 Q. Let's go through the different areas. ECOSCRIPTTM Page 1 - Pr Terry K. Lindquist; 6/9/95 Page 6 The first area essentially talks about an overview of the corporation with respect to asbestos and asbestos products, do you feel that that s an area that you have sufficient knowledge to answer questions? lAIdo. ,, , q The second one has to deal with sales and marketing of asbestos products. Do you feel that you have knowledge 10 sufficient to answer questions about the sales and 11 marketing of the asbestos products of Borg-Warner? 12 I A- With one minor discussion point, and 13 that is I see in the next to the last line, Produced 14 or sold by the defendant to West Virginia. 15 I don't have personal knowledge of sales 16 into West Virginia. 17 Q. But as far as an overview of the sales 18 activities of Borg-Warner with relation to asbestos 19 Iproducts? 20 A. Yes. 1 21 Q. No. 3, general record keeping. Do you 22 feel comfortable in answering questions about the 23 record keeping of Borg-Warner? 24 A. I do. In Re: Asbestos TV Page 8 1 A- No. I have no knowledge of insurance 2 coverage. 3 Q. Finally, No. 8 is any knowledge of the 4 threshold limit value? 5 A. Again, I have no knowledge of threshold 6 limit value. 7 Q. You provided for me a document that's 8 been marked as Exhibit No. 2 which is essentially 9 your resume or CV; is that correct? 10 A, That's correct. 11 Q. At the beginning before we begin the 12 deposition, there was mentioned there may be an error 13 in this document that you wanted to correct? 14 A. Yes. There is just a minor 15 typographical error under the second page, the period 16 of 1960 to 1963 the city in Japan is Iwakuni, 17 I-W-A-K-U-N-I, Japan. 18 Q. Have you ever been deposed before? 19 A. Yes, once before. 20 Q. Where was that? 21 A That was in Chicago, Illinois. 22 Q. Can you tell me the subject matter of 23 the deposition? 24 A It was a deposition on asbestos in the I Page 7 1 Q. No. 4 as an investigation into asbestos 2 products. 3 Do you feel comfortable in discussing or 4 knowledgeable in discussing any investigations that 5 may have been made into the asbestos products of 6 Borg-Warner? 7 A The products of Borg-Warner that I am 8 familiar with are clutches. I have no knowledge that 9 there has been any concern expressed on those 10 products; and, therefore, I don't have any knowledge 11 of any investigations that were made. 12 Q. No. 5, it's any steps that may have been 13 taken to provide warnings to any person with regards 14 to asbestos products of Borg-Warner. 15 A The products of Borg-Warner at one point 16 in time did carry a label. Other than that our 17 workplace practices were certainly according to 18 requirements, and I can testify to that extent. 19 Q. Any knowledge that Borg-Warner may have 20 had regarding the January 1946 article that's listed 21 therein? 22 AI have no knowledge ofthat article. 23 Q. I think I skipped 6. No. 6 is insurance 24 issues. Page 9 1 products. 2 Q. When was that deposition taken? 3 A Three weeks ago, I believe. 4 MR. CARTER: At this time I would like 5 to request a copy of tlie transcript. 6 MR. BAKER: To my knowledge it has not 7 been transcribed. 8 MR. CARTER: At such a time that it is 9 transcribed I am requesting a copy. 10 MR. BAKER: I will give you the name of 11 the court reporter. I personally feel that it's the 12 court reporter's right to distribute those. 13 I will give you her name and you can 14 contact her. 15 I am not trying to be difficult, it's 16 just that I represent that right of hers to 17 transcribe and sell her own transcripts. 18 BY MR. CARTER: 19 Q. Have you ever signed any affidavits or 20 statements under oath with regards to asbestos 21 activities? 22 A. Not to my knowledge. 23 Q. What did you do to prepare yourself for 24 the deposition today? Page 6 - Page 9 ECOSCRIPTTM In Re: Asbestos IV Page 10 1 A. I had a meeting earlier today to read 2 the notice. 3 Q. Have you read any other documents to 4 prepare yourself for the deposition? 5 A. No, I have not. 6 Q. Did you participate at all in the 7 preparation of discovery responses, interrogatories, 8 productions of documents or requests for admissions 9 in this case? 10 A. I did not. 11 Q. When were you informed that you were 12 going to be named as a witness in this litigation? 13 A. I don't have knowledge that I have been 14 informed that I have been assigned as a witness in 15 this litigation if that's different than being here 16 today as a person to be deposed. 17 MR. CARTER: At this time I am going to 18 ask the court reporter to mark the final witness list 19 of Borg-Warner as the next deposition Exhibit. 20 (Exhibit No. 3 was marked for 21 identification.) 22 BY MR. CARTER: 23 Q. I am showing you now Exhibit No. 3, 24 which is the witness list of Borg-Warner. You notice Terry K. Lindquist; 6/9 Page 12 1 Q. Let's go through the Borg-Warner 2 positions starting from '63 to get an idea ofwhat 3 your responsibilities were. 4 Ifyou can, give me an idea ofwhat was 5 entailed as an engineering management trainee from 6 1963 to '64. 7 A. Between 1963 and 19641 was the first 8 engineering management trainee on a management 9 training program that Borg-Warner Corporation had at 10 that time. It was specifically for engineers who had 11 little experience in engineering but an engineering 12 degree, and were then going to get a management 13 degree through an MBA. 14 The program had three stops. Six months 15 at the corporate research center where, in effect, we 16 worked side by side with the researchers at the 17 center learning about the types of products which 18 were being developed. 19 Then two stops of three months each at 20 two divisions of Borg-Warner that were arbitrarily 21 chosen. 22 Q. With regard to the research center, is 23 that the Roy Ingersoll Center? 24 A. At the time it was called the Roy C. Page 11 1 on page one under the heading, Lay Witnesses, No. 2 1-C, I believe that's you; is that not correct? 3 A. I believe that is. 4 Q. You have been named as a witness for 5 trial in this case? 6 MR. BAKER: We will stipulate that we, 7 on behalf on Borg-Warner, have named Mr. Lindquist as 8 a witness for trial. He may be called, I think it 9 says, with information concerning the products 10 manufactured and distributed by Borg-Warner 11 Automotive. 12 Q. Let's go through your background. It's 13 easier to start from the back forward. 14 It says here that you received a 15 bachelors in mechanical engineering? 16 A. Yes. 17 Q. From the Illinois Institute of 18 Technology in 1960, and an MBA from the University of 19 Chicago in 1965. 20 At some point, looking at page 2, it 21 appears that while you were working on your masters 22 you were working for Borg-Warner also; is that 23 correct? 24 A. That's correct. Page 13 1 Ingersoll Research Center. 2 Q. Where is that located? 3 A. It's located in Des Plaines, Illinois. 4 Q. The two divisions that you stopped at 5 during this position, can you tell me what divisions 6 they were? 7 A. Yes. The first one was the Spring 8 division in Bellwood, Illinois, where I learned about 9 mechanical clutches, one-way clutches in particular. 10 The second was the Borg & Beck division 11 in the south side of Chicago. 12 Q. Borg & Beck made what at this time? 13 A. At that time they had three primary 14 products. One was manual transmission clutches, the 15 second was automatic transmission torque converters, 16 the third was damper assembly. 17 Q. During your education for your bachelors 18 degree did you take any courses that dealt with 19 mineralogy? 20 A. No. 21 Q. Were there any courses that mentioned 22 asbestos that you can recall, I know it's going back 23 aways? 24 A. I cannot recall any course that I had ECOSCRIPTTM Page 10 - Page 13 Terry K. Lindquist; 6/9/95 Page 14 1 that mentioned asbestos. 2 Q. While you were working at the research 3 center, can you give me an idea what you did? 4 A Yes. I remember in particular that 5 during those six months we were trying to develop a 6 new type of hydraulic control valve. 7 I was working with a project engineer 8 who had been at the research center for longer than 9 me, and we were working side by side. I was doing 10 the calibrations on pressure and flow and he was 11 doing the design. 12 Q. Were all the products that we mentioned 13 so far automotive or truck products as opposed to 14 industrial or piping products? 15 A. All ofthem were automotive or truck. 16 Q. How big was the research center? 17 AI don't recall the exact number at that 18 point in time. 19 Q. Was it one building, part of a building? 20 A It was one self-contained building in 21 Des Plaines, Illinois. 22 Q. Was it a single-floor building or 23 multi-floor building? 24 A It was a single-floor building. In Re: Asbestos IV ______________________________ Page 16 1 Was that the nature of that library? 2 A As I recall it was a room that had 3 shelves mainly for current design literature, like 4 magazines. 5 Q. Would most of these be professional 6 publications? 7 A Yes. 8 Q. Were there any, as opposed to 9 professional publications, any trade publications 10 such as Automotive Weekly, or something like that? 11 A Yes. 12 Q. Were there any publications that you 13 recall that dealt with asbestos? 14 AI don't recall. 15 Q. After you completed this program you 16 became a project manager at the Borg & Beck division? 17 A Yes. 18 Q. You spent approximately two years there? 19 A Yes. 20 Q. As project manager was that for a single 21 project? 22 A Yes. It was for a single project. 23 Q. What was the project? 24 A The project was in an area that we Page 15 1 Q. Do you have an idea of how big the 2 building was? 3 I don't expect you to give me the exact 4 floor space in square feet, but just an estimate 5 would be good. 6 AI would estimate it at about 100,000 7 square feet. That was laboratories and offices. 8 Q. Were there any parts of this research 9 center where there were materials kept that you could 10 read about different aspects of the engineering 11 requirements for products? I know that's a vague 12 question. Let me just get to the point. 13 Was there a library there? 14 A There was a library. 15 Q. Can you give me an idea of how big the 16 library was? 17 A If I recall correctly it was about as 18 big as this room. 19 Q. 10 by 14, something like that? 20 A Yes. 21 Q. Did you spend much time in the library? 22 A No. 23 Q. My concept of a library is a lot of 24 shelves with books or magazines on them. Page 17 1 called advanced engineering. We were trying to use a 2 wet clutch to affect a variable speed drive 3 mechanism. 4 Q. Was this for an automotive transmission 5 or was it designed for heavier applications? 6 A For heavier applications. At that point 7 in time it was for pumps, trying to drive a 8 centrifugal pump at a varying speed. 9 Q. For the next nine years you were sales 10 manager and engineering manager at Borg & Beck? 11 A Yes. 12 Q. You moved from Chicago to Detroit? 13 A Yes. 14 Q. Was this a manufacturing facility in 15 Detroit? 16 A Yes. The one in Detroit was a 17 manufacturing facility. 18 Q. I con imagine since it was Detroit it 19 was almost all automotive because that's the 20 automotive industry, but is that correct? 21 A All the products from that facility were 22 automotive products. 23 Q. Then your next position was the 24 vice-president of engineering for Borg & Beck in Page 14 - Page 17 ECOSCRIPTTM ja Re; Asbestos IV Page 18 1 Sterling Heights? 2 A. Yes. 3 Q. Can you give me an idea of what your job 4 responsibilities were as vice-president of 5 engineering? 6 A. Yes. I have to go back to the previous 7 one because it's indicative. 8 In the previous nine years I was in 9 charge of a project, both through sales and 10 engineering, in controls of electronic systems for 11 automobiles. That was dependant upon a government 12 requirement which was withdrawn. 13 Therefore, one of the tasks I had as 14 vice-president of engineering was to dose that whole 15 area. That was one of the first tasks I had. 16 The rest of the time, which was much 17 shorter, was to oversee an administrative overview, 18 the engineering department and design and development 19 of automotive products. ' 20 Q. Can you give me an idea of the scope of 21 automotive products that were being made by Borg 22 & Beck during this first 10 or so years that were 23 there? 24 A. The scope of automotive products? Terry K. Lindquist; 6/9/95 Page 20 1 Q. The automotive components group of 2 Borg-Warner, were there more aspects of automotive 3 products, or more types of automotive products that 4 you were working with here than you were working with 5 at Borg & Beck? 6 A. Yes, on an oversight but not a direct7 responsibility position. 8 Q. Can you give me an idea of the products 9 that were being made through the automotive 10 components group? 11 A. Yes. They were components for automatic 12 transmissions like the one-way clutch that I learned 13 about during my training program. They were 14 four-wheel drive transfer cases. They were manual 15 transmissions, and there were controls such as 16 electrohydraulic selenoid valves. 17 Q, At the time that you were with Borg & 18 Beck, were you aware that any of the products that 19 Borg & beck was working with contained asbestos? 20 A. Yes. 21 Q. Can you give me an idea of the products 22 that you were aware of at that time that contained 23 asbestos? 24 MR. BAKER: At what time? Page 19 1 Q. Essentially the types of products. 2 A. At these locations? 3 Q. Right. 4 A. They were the same type that I redted 5 the earlier. That is manual transmission dutches, 6 automatic transmission torque convertors, and damper 7 assemblies. 8 Q. As so often happens in asbestos 9 litigation we tend to focus on one product and we 10 never take a look at the entire scope of the 11 corporation. Frequently I am just going to keep 12 saying that this was such a small part ofwhat we 13 did, this is a single asbestos product and that was 14 the idea, is to get an idea of the range of products 15 that were being made by Borg & Beck. I sun not 16 focusing on one small product. 17 After your position as vice-president of 18 engineering you went into research sind engineering as 19 vice-president in Troy, Michigsm? 20 A. Yes. Troy, Michigsm, was the 21 headquarters of a group within Borg-Wsumer, the 22 automotive components group. I was asked to be the 23 vice-president of research and engineering for that 24 group. Page 21 1 MR. CARTER: At the time he was with 2 Borg & Beck. 3 A. The only product that I was aware of 4 that contained asbestos was the friction material 5 that we purchased from outside and attached to our 6 manual transmission clutches. 7 Q. When you went to the BW auto components 8 group, were there any asbestos-containing products 9 that were coming out of the BrW automotive components 10 group? 11 A. With the exception of the one I just 12 mentioned I have no knowledge of any other. 13 Q. Your next stint took you to Brazil? 14 A. Yes. 15 Q. You were with Borg-Warner, I guess, "do" 16 meaning "of Brazil?" 17 A. Yes. 18 Q. What did you do in Brazil? 19 A. I was the president and general manager 20 of a manufacturing facility in Brazil. More 21 particularly, I was an interface with governmental 22 agencies in Brazil in such things as economics and 23 trade. 24 Q. Were any of the products that were made ECOSCRIPTTM Page 18 - Page 21 Terry K. Lindquist; 6/9/95 Page 22 1 in Brazil shipped to the United States? 2 A. Yes. 3 Q. What products were made at the Brazil 4 facility? 5 A- We made in Brazil manual transmission 6 clutches. 7 Q. Are these similar to the ones that were 8 made by Borg & Beck? 9 A. Yes. 10 Q. At the facility in Brazil, was it still 11 the same in that you would purchase the asbestos12 containing part of the clutch assembly from outside 13 source, or did you actually manufacture that segment 14 there in Brazil? 15 A. There were two types. Those that we 16 shipped to the OEM, the original equipment 17 manufacturers in the United States, we purchased frum 18 a vendor in the United States. 19 Those that we produced and sold in 20 Brazil we manufactured in Brazil. 21 Q, Would that mean that for the products 22 that you were selling in Brazil, as opposed to those 23 that were being shipped back to the United States, 24 that you were actually working with the raw asbestos In Re: Asbestos rv Page 24 1 correct? 2 A Yes. I don't know what the coating was. 3 All I know is that we did cure it as if it was a 4 rubber. 5 Q. I may be misunderstanding how this is 6 put together, but essentially ifyou had a circular 7 disc that you were trying to make would that mean you 8 would simply try to make a spiral from the center out 9 and then as you applied the heat and the pressure 10 when you were curing it it would kind of merge into a 11 single solid disc? 12 A That's one description, yes. 13 Q. Is that fairly accurate from a layman's 14 point of view? 15 A Yes. 16 Q. You were at the Brazil facility for 17 about four years? 18 A That's correct. 19 Q. How long had that plant been in 20 operation, if it had been in operation before you got 21 there? 22 A It had been in operation before I got 23 there, and approximately 25 years. 24 Q. When the clutch was being made in Brazil 1 Page 23 1 to create the product? 2 A. No, because at that point we would buy 3 the incapsulated yarn. The only thing we were doing 4 is pressing it into shape. 5 Q. I guess at this point it would be a good 6 idea to give me an idea of what the asbestos in a 7 clutch is comprised of or is made up of. 8 A. I am not sure that I can answer that 9 question accurately for you. 10 Q. Can you give me an idea of how the 11 asbestos is put into the clutch friction material 12 that you discussed. 13 You just mentioned that you would buy an 14 encapsulated yarn and then press it into something to 15 make the plate? 16 A Yes. The encapsulated yam, which would 17 have the rubber materials around it, was purchased 18 and shaped in the shape of the clutch disc. 19 It was then put into a hot platen that 20 came down and closed and cured the rubber product. 21 That made the clutch disc. 22 Q. You mentioned that the yarn was 23 encapsulated. From your description it sounds like 24 the yarn itself came with a rubber coating; is that Page 25 1 from the asbestos yam, was there anything that was 2 put on the yam or above or below the yam when you 3 were pressing it in the platen to keep it from 4 sticking? 5 AI don't know. 6 Q. The reason I ask is it goes back to some 7 things I have done before. I am familiar with the 8 way tires are made. 9 I have heard many a tire maker talk 10 about that in order to keep the raw rubber from 11 sticking to a press they had to coat it with 12 essentially talc powder to keep it from sticking. 13 Was that something that was required to 14 be done? 15 AI really don't know. I can't give you 16 an answer on that. 17 Q. Were you aware at the time that you were 18 in Brazil of any problems with the workforce as far 19 respiratory injuries? 20 A No. I was aware of no respiratory 21 injuries and problems in Brazil. 22 Q. Was the workforce at that plant fairly 23 stable at that time? 24 A At that time it was fairly stable. Page 22 - Page 25 ECOSCRIPTTM In Re; Asbestos IV Page 26 1 MR. BAKER; Show my objection. What do 2 you mean by stable? In length or duration. 3 MR. CARTER; I will be a little bit more 4 specific. 6 BY MR. CARTER: 6 Q. When I am asking about the stability of 7 the workforce, would that plant have a large number 8 of long-term production workers? 9 A. The answer to that is yes. 10 Q. In terms of giving an estimate of the 11 percentage of products that were being made for 12 Brazilian consumption as opposed to being shipped 13 back to the United States for OEM use, can you give 14 me some kind of an estimate of the production, how 15 much was being used in Brazil and how much was being 16 shipped back? 17 A. It changed over time because of the 18 economics of the country of Brazil. Between the 19 period of 1983 and '87 they weiit through horrendous 20 inflation. The percentage would have increased 21 coming into the United States but the total numbers 22 would not have. 23 Q. How much of the production would have 24 been devoted to producing things to be shipped to the Terry K. Lindquist; 6/9/95 Page 28 1 Q. You were the director for about two 2 years, between '87 and '89? 3 A. Yes. 4 Q. Is that research center still in 5 operation today? 6 A. No, it's not. It was closed in 1989. 7 Q. Was that during your tenure there? 8 A. Yes. 9 Q. In '89 you went to Michigan to work as a 10 vice-president of technology and marketing for 11 Borg-Warner Automotive? 12 A. That's correct. 13 Q. What were the products being marketed by 14 Borg-Warner Automotive at this time? 15 A. At that point in time I had two major 16 functions. The one was an oversight of the various 17 advanced technologies that were going on at our 18 operating units. 19 The second thing was to develop a new 20 type of automatic transmission. It's called a 21 continuously variable transmission. 22 Q. Your next position from April of '92 to 23 May of '94 was as president and general manager for 24 Borg-Warner Automotive Transmission Engine Page 27 1 United States? 2 A. I would think that at one time it got up 3 to approximately 25 percent ofwhat was being 4 manufactured. 5 Q. So the majority of the products that 6 were made at that plant were for domestic use in 7 Brazil? 8 A. That's correct. 9 Q. When you returned to the United States 10 you went back to the research center in Des Plains? 11 A. Yes. 12 Q. You were the director there for about 13 two years? 14 A. Yes. 15 Q. This is the same Ingersoll Research 16 Center? 17 A. It was the same building. 18 Q. They may somewhere changed the 19 designation or the name or something. 20 By the way, who was Roy Ingersoll? 21 A. Roy Ingersoll was a family. Roy and his 22 son Bob were chairmen of Borg-Wamer in the periods 23 after the war. I am not sure exactly what years. 24 After World War II, that is. Page 29 1 Components, and Borg & Beck torque Systems in 2 Sterling Heights? 3 A. Yes. 4 Q. Was Borg & Beck at that time a division 5 of Borg-Warner? 6 A. Borg & Beck torque Systems manufactured 7 torque converters for the automotive industry. We 8 reported to a unit of Borg-Warner Automotive called 9 Borg-Wamer Automotive Transmission and Engine 10 Components Corporation. 11 Q. The products that were being sold 12 through Borg-Wamer Automotive were just the torque 13 convertors from Borg & Beck, or were there other 14 products? 15 A. No. There were other products that the 16 Transmission and Engine Components Corporation 17 manufactured and sold. 18 Q. What other products were being sold? 19 A. There were components for automatic 20 transmissions, there were of three different types. 21 MR. BAKER: Have we attached a specific 22 time frame to this discussion? 23 MR. CARTER: During this position. 24 MR. BAKER: Only during that position ECOSCRIPTTM Page 26 - Page 29 Terry K. Lindquist; 6/9/95 Page 30 1 time? 2 MR. CARTER; Yes. 3 MR, BAKER; I just wanted to make sure 4 we weren't switching back and forth. 5 BY MR. CARTER: 6 Q. Are those the only two things, the 7 torque converter and the component parts for 8 automatic transmissions? 9 A. There were torque converters, there were 10 damper assemblies and there were components for 11 automatic transmission. 12 Q. Currently you are the vice-president for 13 business development of Borg-Warner Automotive 14 Automatic Transmission Systems out of Lombard? 15 A. That's correct. 16 Q. I take it from this that the main 17 production is either automatic transmissions or parts 18 for automatic transmission? 19 A. Parts therefor. 20 Q. Are there any parts in an automatic 21 transmission that would contain asbestos, to your 22 knowledge? 23 A. Not to my knowledge. 24 Q. So if my understanding is correct, and In Re: Asbestos tv Page 32 1 automotive market. 2 When you first began with Borg-Warner 3 and Borg & Beck I would imagine that, just with the 4 knowledge of history and talking with my dad, that 5 more often than not the transmissions being made at 6 that time were the manual transmissions? 7 A That's correct. 8 Q. Has that segment of the automotive 9 market decreased over time? 10 A Without a doubt. 11 Q. For the manual transmissions that are 12 being made now for the dry clutches, is there a 13 different product that has replaced the asbestos as a 14 component part of the clutch assembly? 15 A Yes. 16 Q. What has been used as a replacement for 17 the asbestos? 18 A I can't give you an accurate description 19 of what's being used now. I can only tell you that 20 back many years ago the replacement was fiberglass. 21 Q. Can you give me an idea ofwhy asbestos 22 was used in a clutch assembly? 23 A Again, I can't tell you the history as 24 to why it was initially selected. I can only tell Page 31 1 please correct me if I am wrong, the products that we 2 have been talking about thus far are simply parts of 3 a clutch for a manual transmission? 4 A. There are two types of manual 5 transmissions. One that uses a wet clutch and one 6 that uses a dry clutch. With that amplification, 7 yes, that's correct. 8 Q. The asbestos products would be used in a 9 dry clutch as opposed to a wet clutch, or vice-versa? 10 A. Back at that time, yes. 11 Q. Is there a time when Borg-Warner ceased 12 to make asbestos-containing clutch products? 13 A Yes. 14 Q. That was when? 15 A It started, the transition started 16 somewhere, and I'm sorry, I don't know the exact 17 date. Somewhere in the early 1980s. I believe the 18 transition was completed somewhere in the mid 19 eighties. 20 Q. Do you have an idea of anything more 21 specific than the "mid eighties?" 22 AI really can't tell you exactly when 23 that was completed. 24 Q. I mentioned earlier the changing Page 33 1 you that when I first became involved asbestos had 2 very good functional characteristics which made it a 3 material of choice. 4 Q. I have talked to a lot of different 5 people about many asbestos products. Some people 6 have told me that the asbestos was a component part 7 simply because it kept the product from bouncing off 8 the wall on sprayed mastics and cements. 9 Others have said it's used for a fire 10 retardant. Some people use it for an acid resistant. 11 It is the durability ofthe fiber that 12 would have made it an attractive component to a 13 clutch as opposed to some other esoteric thing like 14 it keeps things from bouncing offthe wall? 15 A Again, this goes back several years, but 16 as I recall, one of the main reasons was its 17 capability to provide a material that had heat 18 resistance. 19 Q. I see on some literature about the heat 20 that is generated during the operation of a dry 21 clutch, but I have never seen anybody estimate the 22 maximum temperature that would be generated through 23 that friction process. 24 Do you have any idea ofwhat Page 30 - Page 33 ECOSCRIPTTM ISjte: Page 34 1 temperas are looking at in terms of the clutch 2 ^craaon9 .T 3 a. I don t W the maximum. I am sure it 4 Spends on the application. I do recall that there 5 was a number of ver 400 degrees faluenhelt'but 6 can't be mnre accurate than that. 7 Q. I would like to switch gears at this 8 Point andtake a look at the corporate history of 9 10 Can you give roe an idea, going from the 11 beginning how Borg-Warner was formed? 12 A. I recall reading that Borg-Warner was 13 formed in 1928 during the period of time in the 14 automotive industry when there was a lot of 15 consolidation going on. There were four independent 16 companies that were brought together to form 17 Borg-Warner at that time. 18 Q. Do you know the names of the four 19 companies? 20 A. You are really taxing me. 21 One of them was Borg & Beck, and that's 22 where the Borg comes from in Borg-Warner. 23 Another one was Warner Gear, and that's 24 where the Warner in Borg-Warner comes from. Terry K. Lindquist; 6/9/95 Page 36 1 appears to be five divisions or subparts of 2 Borg-Warner th&t at on tim or anotlisr dealt in 3 asbestos products. The first being Borg & Beck. 4 They made clutch assemblies that contained asbestos; 5 is that correct? 6 A. Yes. 7 Q. The second one is Rockford division, out 8 of Rockford, Illinois. 9 Are you aware of any asbestos products 10 that they made? 11 A. Rockford division in Rockford, Illinois, 12 was outside of any of the responsibility that I had. 13 I do know that they made clutches as well. 14 Q. From the answers to interrogatories the 15 definition was uff-liighway and heavy duty vehicles? 16 A. Yes. 17 Q. Can you give me an idea of what "off18 highway" and "heavy duty vehicles" means? 19 A. Yes, I can, because that's why it was 20 not part of my responsibility which was OEM in 21 automotive. 22 They were making clutches for large 23 vehicles like tractors, Caterpillars. I don't know 24 their customer base, but that's why they were Page 35 1 I believe the third was Mechanics 2 Universal Joint. 3 The fourth was Marvel Carburetor. 4 Q. Do you know what product lines were 5 contributed by these four companies that went 6 together to make Borg-Warner or what product line 7 came out ofthe consolidation of these four 8 companies? 9 A. The companies really did not consolidate 10 in that they didn't then all produce a single 11 product. They continued to manufacture products that 12 they were manufacturing when they were brought 13 together under the Borg-Warner umbrella. 14 Q. So if I understand correctly there may 15 have been a division out of Borg-Warner that would at 16 that time continued to make universal joints from the 17 Mechanics Corporation and carburetors from Marvel 18 Carburetor and, I guess, gears from Warner Gear? 19 A. To my knowledge that's true. 20 Q. Just assuming from names things from the 21 name. At Borg & Beck we talked about it being a 22 clutch company. 23 A. Yes, sir. 24 Q. From answers to interrogatories there Page 37 1 classified as off-highway as opposed to on-highway, 2 being automobile and truck. 3 Q. If I understand this correctly, the 4 off-highway and large vehicle would be essentially 5 construction equipment? 6 A. I believe that that could include 7 construction equipment since I do know that it did 8 tractors. 9 Q. It would not include something like a 10 tractor for a semi? Would that be a highway under 11 the OEM or automotive section? 12 A. I believe that they did have some 13 clutches that went to some sectors of the on-highway 14 large vehicle, but that was not their major market. 15 MR. BAKER: Do you know that? Do you 16 actually know that? 17 THE DEPONENT: Yes, I actually know. 18 BY MR. CARTER: 19 Q. Would the Rockford division also be 20 selling to manufacturers of large farm equipment? 21 A- I don't know. 22 Q. Another division that you had mentioned 23 briefly was the Spring/Brummer division? 24 A. Yes. ! ECOSCRIPTTM Page 34 - Page 37 Terry K. Lindquist; 6/9/95___________________ In a , ------ ---------------------------- ------------ ------------- _Page38 __________________________ . _Sa? 1 Q. What I was been able to glean frnm 2 answers to interrogatories it appears that sometime 3 in the early seventies from approximately '71 to '75 4 they went into the disc brake market? 5 A-1 don't have any knowledge of that. 6 Q. At the time that you spent, what three 7 months at Spring/Brummer, what were they making? 8 A-1 can only tell you that the product 9 that I was involved in was a mechanical one-way 10 clutch for automatic transmissions. That was the 11 project that I was working on. 12 Q. From your history with Borg-Warner, can 13 you give me an idea of what the product line of 14 Spring/Brummer would have been traditionally? 15 A. It initiated out of springs, which is 16 why the name was developed. l were a company that supplied parts to the 2 aftermarket. 3 Q. Do you know what kind of parts they 4 distributed? 5 A. I don't know their entire range, 6 however, I do know that they distributed parts like 7 ignition components at the time when cars used p0in 8 and distributor caps and things. 9 That's typical of the kinds of parts 10 that they distributed. 11 Q. Do you know if the automotive parts 12 division manufactured their own parts, or did they 13 simply resell something that they purchased from 14 other manufacturers? 15 A- I'm afraid I can't tell you. I don't 16 know. 17 Early in the development of automatic 18 transmissions and prior to the KC lngersoll Research 19 Center being developed the research on automatic 20 transmissions was done at the Spring division. 17 Q. There also were documents that were 18 provided earlier this week from counsel regarding a 19 company called Unit Parts out of Oklahoma City. 20 Do you know anything at all about that? 21 Coming from that, then, was the wet 22 clutches for automatic transmissions and the one-way 23 clutches for automatic transmissions. 24 Q. Do you know if they ever got into the 21 A. No knowledge of that. 22 Q. I could not glean from the documents how 23 large Unit Parts was when it was purchased in '72. 24 For some reason the answers to Page 39 1 dry clutches for manual transmissions? 2 A. Not to my knowledge. 3 Q. From what you have said before, if I am 4 correct, you didn't have anything to do with this 5 division at the time when they would have been making 6 disc brakes? 7 A, If they made disc brakes I didn't know 8 about it. 9 Q. The next one is the automotive parts 10 division. 11 Are you aware of that division? 12 A. The automotive parts division that I 13 recall, which was many years ago, was a distributor 14 of aftermarket components. 15 Q. Can you tell me what "aftermarket 16 components" are? 17 A. I don't know what their entire line up 18 was, but these were parts that were sold for 19 replacement of original parts that failed. 20 Q. So, essentially, these would be parts 21 that someone would buy from a parts company like NAPA 22 if they were doing some repairs on their car? 23 A. Again, I don't know what their 24 distribution methods were. I just know that they Page 41 1 interrogatories there was that some point in '76 it 2 may have been discontinued or it got out of the 3 asbestos product line. 4 But you have no knowledge at all about 5 Unit Parts Company? 6 A. I don't know anything about Unit Parts. 7 Q. Is there someone who might be more 8 knowledgeable about that part of the corporate 9 operations of Borg-Wamer? 10 A. I have no idea where it was. I don't 11 know anything about Unit Parts. 12 Q. Can you give me an idea of how big 13 Borg-Warner is today as far as subsidiaries and 14 products that get into even beyond the automotive 15 end? 16 A. Borg-Wamer Automotive is by its name 17 strictly automotive. It is a worldwide company that 18 has sales of about $1.2 billion a year. 19 Q. Is there a parent corporation for 20 Borg-Warner Automotive? 21 A. No. Borg-Warner Automotive, 22 Incorporated, is a public company. 23 Q. There is no other Borg-Warner 24 Corporation? Page 38 - Page 41 ECOSCRIPTTM In Re: Asbestos IV Page 42 1 A. No. 2 Q. Would Borg-Warner have always been 3 automotive? 4 As far as you know, all the products 5 that they made were designed for, for lack of a 6 better word, transportation? 7 A. No. At one point in time Borg-Warner 8 was a corporation that had units in other than 9 automotive. 10 Q. Are you aware of any of the other units 11 that Borg-Warner had historically? 12 A. Yes, I am. There was a finance services 13 company, there was an air conditioning company, there 14 was a company that sold pumps to municipalities, and 15 another one that sold components to control systems 16 for hydraulics like in aircraft controls. Finally 17 there was a Borg-Warner Chemicals company. 18 (Break.) 19 BY MR. CARTER: 20 Q. Before the break we were talking about 21 other units of the Borg-Warner corporation that you 22 were aware of. You had mentioned five units that you 23 were aware of; financial services, the air 24 conditioning, pumps for municipalities, component Terry K. Lindquist; 6/9/95 Page 44 1 Q. It's not something where they were just 2 closed down? 3 A No. 4 Q. Is there a reason why Borg-Warner chose 5 to sell off these five units? 6 A Yes, a very definitive reason. 7 During the mid-eighties we were a target 8 for two different, company writers who were going to 9 be usingjunk bonds to buy our corporation and to 10 dissolve it. 11 So, to my knowledge, the corporation 12 decided to take the corporation private themselves 13 and sold these areas of the corporation to pay for 14 the debt that was taken on to take the company 15 private. 16 Q. Are you aware of any asbestos products 17 that would have been made by any of the five units at 18 a time when they were part of Borg-Warner? 19 AI have no knowledge of that. 20 Q. Was the air conditioning unit the York? 21 A It was the York unit, yes. 22 Q. If they made an asbestos product it's 23 not something that you are aware of? 24 AI would not know. i Page 43 1 hydraulics for aircraft systems, essentially, and the 2 chemical division. 3 Are there any other units that you are 4 aware of? 5 A. Not that I can call to mind right now. 6 Q. During your history with Borg-Warner 7 have you ever had any interaction with any of the 8 other aspects of Borg-Warner? 9 A. The only interaction I have goes way 10 back to that first program that we talked about back 11 in 1964 where I was trying to make a variable speed 12 drive for one of the pumps. Subsequent to that, no. 13 Q. Do you know if these units are still 14 part of Borg-Warner? 15 A. I know that they are not still part of 16 Borg-Warner. 17 Q. Do you have an idea as to the time 18 frames when Borg-Warner either sold them or got rid 19 of them or closed them down or whatever they did? 20 A. Yes. In the period of the mid-eighties 21 terminating in about 1987. 22 Q. Did Borg-Warner generally sell off these 23 divisions? 24 A Yes, generally we did. Page 45 1 Q. At this time is Borg-Warner public or 2 private? 3 A It's a public company now in the New 4 York Stock Exchange. 5 Q. Did they go private in '87? 6 A Yes. 7 Q. Sometime between '87 and now they 8 decided to go back public? 9 A That's correct. 10 Q. Do you know when they went public? 11 AI believe it was two years ago. 12 Q. When Borg-Warner was first created from 13 the four companies have you ever looked or seen or 14 been told about the articles of incorporation for 15 Borg-Warner? 16 A No. 17 Q. So you wouldn't know what the statement 18 of the corporate purpose would be? 19 A No, I am afraid I don't 20 Q. As a public corporation you are required 21 to generate annual reports for the stockholders and 22 annual reports for the IRS? 23 A That's correct. 24 Q. Do you have an idea of how many ECOSCRIPTTM Page 42 - Page 45 Terry K. Lindquist; 6/9/95 Page 46 1 employees Borg-Warner employs now? 2 A. Approximately it's between 9 and 3 10,000 people. 4 Q. You mentioned that Borg-Warner is an 6 international corporation. 6 Can you tell me what countries 7 Borg-Warner does business in or has facilities in 8 besides the United States? 9 A. What countries? 10 Q. Yes. 11 A. Yes, I can. 12 Besides the United States we have 13 companies in Canada and Mexico, Japan, South Korea, 14 Germany, Italy, and Wales. 15 Q. Do you know if any of the historical 16 documents relating to Borg minutes are available for 17 Borg-Warner? 18 A. I have no knowledge about that. 19 Q. Does Borg-Warner have a record keeping 20 policy at this time? 1 21 A. A record keeping - 22 Q. A record retention policy? 23 A. I believe we do, but I am not familiar 24 with what it is. Page 48 1 of sales of the Borg-Warner automotive parts 2 restricted to the United States? 3 A. Primarily we are a designer, developer 4 and manufacturer of components that go to the 5 original equipment manufacturers. More particularly 6 for Borg-Warner Automotive that would be the large 7 automotive companies. 8 Q. If I understand correctly, back to the 9 very early days, Borg-Warner would have been selling 10 to the manufacturers of automobiles and then the 11 parts that Borg-Warner made would have gone wherever 12 the autos went? 13 A. That's true. 14 Q. The automotive parts division, the 15 distributor division, do you know if that unit 16 distributed parts nationwide or were they limited by l7 some geographic scope? 18 AI am sorry. I really don't know what 19 their market was. 20 Q. Is there someone still around that would 21 have familiarity with the automotive parts division 22 that you know of? 23 A That area, the aftermarket, the 24 automotive parts division was completely separate Page 47 1 Q. Is there any place where Borg-Warner 2 would keep historical reference documents? 3 I know some companies keep engineering 4 documents so they can see the cycle of a particular 5 product. If they want to take a look at if this 6 formulation works then why doesn't this one now 7 work. 8 Is there any facility where the 9 engineering records would be kept for different 10 product lines? 11 A. If there is such a place it would be the 12 responsibility of the operating unit to keep those 13 records. There is no central. 14 Q. So, if I understand you correctly, the 15 record keeping function would be essentially 16 delegated to the operating unit and they would keep 17 them on-sight at the production facility? 18 A. To the best of my knowledge that's 19 correct. 20 Q. Do you know if any of the documents have 21 been cither microfilmed or converted to a computer 22 medium for storage? 23 A. That's beyond my knowledge. 24 Q. What is the traditional geographic area Page 49 1 from anything that I came up through. I don't know 2 anybody in that area. 3 Q. Do you know if there was ever a warning 4 put on any of the asbestos-containing products made 5 by Borg-Warner? 6 A. I know that we put a label on some 7 shipping containers that were shipped to General 8 Motors. 9 Q. Was this done at a time when 10 asbestos-containing products were being shipped to 11 other OEMs besides GM? 12 AI really don't know whether we were or 13 not. 14 At the time and to this date I don't 15 know of any problems with the kind of products that 16 we were making. I do know that we were requested by 17 General Motors to put that label on their shipping 18 containers. 19 Q. So if some other company, such as Ford 20 or Chryslerjust to make up a name, did not request a 21 warning label then you would not have put one on? 22 AI don't know firsthand whether there was 23 or was not. 24 Q. At the production facilities that you Page 46 - Page 49 ECOSCRIPTTM In Re; Asbestos IV Page 50 1 had worked at, were there at any of these production 2 facilities any persons who were in charge of, or as 3 part of their duties, would have done air sampling 4 for quality? 5 A Again, I was in engineering. I don't 6 know whether that was the case or not. 7 Q. At any of the facilities do you know if 8 any of the plants had a doctor or a medical 9 department? 10 A. I don't know. 11 Q. I think you said earlier that you don't 12 know really anything about the Unit Parts? 13 A. No. 14 Q. Is there anybody who would know anything 15 about Unit Parts? 16 A. I really have no idea where they were or 17 if they were in the corporation, so I don't know who 18 would know anything about it. 19 Q. I have been provided by counsel a number 20 of catalogs of parts that were made by Borg-Warner 21 divisions. The first one -1 am not going to have 22 these marked as an exhibit so they are not 23 redundant - is a catalog that is entitled Disc 24 Brakes DB-71.1 will try to see if there is a Terry K. Lindquist; 6/9/95 Page 52 1 I want to see ifyou would agree, being 2 more an expert in the field of automotive 3 applications, if that would be a correct description 4 of the contents. 5 A. There is certainly applications here for 6 all the major manufacturers that I recall at the 7 time, all four of them. 8 Q. It appears, and correct me if I am 9 wrong, this looks like these were only made for 10 automobiles. I don't see any trucks listed. 11 Actually counsel can correct me if I am 12 wrong, these were just made for automobiles? 13 AI don't see any trucks listed on these 14 papers. 15 Q. Is there any person who would have been 16 better situated to discuss the operations of the 17 Spring/Brummer division during the early seventies 18 that you know of from your history with Borg-Warner? 19 AI don't even know that these came from 20 the Spring/Brummer division. This mentions 21 automotive parts division Franklin Park, Illinois. 22 That's the division that you and I have discussed 23 already that I have really no knowledge of. 24 Q. That's a mistake on my part. Page 51 1 publication date on the document itself. No. 2 MR. RAKER: What number is that? 3 MR. CARTER: This would be, I think, No. 4 50.1 am not going to be doing a lot with this. I 5 am going to be looking at the scope of the 6 applications of the disc brakes that were made by 7 Borg-Warner at this time. 8 BY MR. CARTER: 9 Q. I am going to ask you to kind of glance 10 through this to take a look at the manufacturers that 11 are listed in terms of applications for the disc 12 brakes. 13 A May I state first of all that I have 14 absolutely no knowledge of any disc brakes by 15 Borg-Wariier. 16 Q. Okay. 17 A You said particularly the United States? 18 Q. Right. Just the car makers that they 19 show listed. 20 It appears from my looking through this 21 that the disc brakes that were made by Borg-Warner 22 appear to be applicable to virtually every 23 manufacturer in the United States of automobiles, and 24 multiple models of those vehicles. Page 53 1 MR. BAKER: It's on page 2. 2 Q. I was making an assumption without 3 looking at it carefully. 4 So this is more of a catalog of 5 distribution from that distributing division of 6 Borg-Warner and not some things necessarily that 7 were made by Borg-Warner? 8 A The fact that it's listed under 9 automotive parts division I believe what you just 10 said is correct. 11 Q. Some ofthe documents that were produced 12 this week showed or demonstrated sales, I would 13 guess - have you seen the stack of documents that is 14 sitting next to counsel before today? 15 AI saw a listing ofthe documents that 16 were listed here. 17 Q. There are a couple of sections of 18 documents that I just wanted to ask if I was reading 19 them correctly. 20 MR. BAKER: You understand that that 21 table of contents was put together by our office 22 just to make looking through the documents easier. 23 It in and of itself is not a document produced by 24 Borg-Warner. ECOSCRIPTTM Page 50 - Page 53 Terry K. Lindquist; 6/9/95 Page 54 1 MR. CARTER; I will agree to that. 2 BY MR. CARTER: 3 Q. There were a number of documents 4 contained in that set that appeared to be invoices. 5 I am just trying to find out whether it was sold from 6 someone to Borg-Warner or purchased by someone from 7 Borg-Warner. 8 I am going to ask you to take a look at 9 the documents that had been tabbed as 48 by counsel. 10 The first one appears to be to HK 11 Porter. 12 Do you have one like that? 13 A. Yes. 14 Q. I am asking, is this a sale of a product 15 from Borg & Beck to HK Porter or is it a purchase 16 from HK Porter by Borg & Beck? 17 A. It's a purchase from HK Porter by Borg & 18 Beck. 19 Q. That makes sense. 1 20 There were a number of companies who 21 supplied the clutch materials that contained asbestos 22 to Borg & Beck; is that correct? 23 A. Yes. 24 Q. Did you have any dealings with the In Re: Asbestos jy Page 56 1 A. Abex I know the name, but I don't know 2 of them as being a supplier. 3 Q. Johns-Manville? 4 A. Again, I know the name. I don't know 5 that they supplied any product to Borg-Warner. 6 Q. National Friction Products? 7 A. I don't know of them. 8 Q. Then there's a company called Russe, 9 R-U-S-S-E? 10 A. I don't know that company. 11 Q. At any time did any of the suppliers, 12 such as HK Porter or Raymark, ever mention, to your 13 knowledge, anything about potential hazards from 14 asbestos? 15 A Not to my knowledge. 16 Q. If I understand you correctly from your 17 prior testimony the vast majority of sales of 18 asbestos-containing products would have been directly 19 from Borg-Warner to the manufacturer of automobiles 20 or other vehicles? 21 A Absolutely true. 22 Q. And not distributed to the general 23 public through parts stores or whatever? 24 A That's true. Page 55 1 suppliers when you were dealing with Borg & Beck or 2 the clutch aspects of Borg-Warner? 3 A. No direct dealings, no. 4 Q. Would you be generally familiar with who 5 were the suppliers? 6 A. I could recall that the two main 7 suppliers, as a matter of fact the only two that come 8 to mind, is HK Porter and Raymark or it was Raybeetos 9 at that point in time. 10 Q. There are a number of other companies 11 that were suppliers, and I would take it or a list 12 of suppliers in answers to interrogatories, I would 13 take it from your comment that they would be minor 14 suppliers compared to these two? 15 A. Only in that my knowledge and my 16 recollection was that I knew about these two. 17 Q. I am going to go through a list of 18 suppliers and see ifyou are familiar with the 19 companies. You mentioned Raymark. What about the 20 Gatke Company, G-A-T-K-E? 21 A. No, sir. 22 Q. Austo, A-U-S-T-O? 23 A. No, sir. 24 Q. American Brake Shoe, or Abex? Page 57 1 Q. Other than anything that may have been 2 distributed through automotive parts, of which you 3 are pretty much unaware? 4 A Yes. 5 Q. Are you aware of any sales offices that 6 Borg-Warner may have had in the West Virginia region, 7 Ohio, Pennsylvania? 8 AI am not aware of any in the West 9 Virginia region. 10 Q. There was at one time an answer to 11 interrogatories by Borg-Warner regarding the warning 12 that you mentioned. I want to find that and see if 13 that goes with your recollection. 14 MR. BAKER: For the record, when you 15 find it could you mention what set it is you are 16 pointing at? 17 MR. CARTER: Sure, I will. Actually I 18 will probably have it marked. 19 I am going ask the court reporter to 20 mark this as the next exhibit in order. 21 (Exhibit No. 4 was marked for 22 identification.) 23 BY MR. CARTER: 24 Q. These are interrogatories from Page 54 - Page 57 ECOSCRIPTTM Re: Asbestos IV Page 58 1 Borg-Warner in a case captioned Parker Thayer versus 2 AP Green Refractories in the State of Michigan, 3 County of Wayne. These were time stamped by the 4 court on July 14,1993,1 believe, before Judge 5 Robert Colombo. I will hand these to you and I am 6 going to ask you a few questions about these. 7 First of all, have you ever seen these 8 before? 9 A. No, I have never seen these before. 10 Q. There is an exhibit to that which is 11 noted as Exhibit B. That's probably two or three 12 pages from the back. 13 That Exhibit B is referenced in the 14 interrogatories at page 43, interrogatory number 70. 15 I will let you go ahead and read the 16 question and answer and I will ask you some questions 17 about that. 18 MR. BAKER: Before you ask any questions 19 I would like a chance to look through the rest of the 20 set here for a second since I have never seen those 21 questions before. 22 (Break.) 23 MR. BAKER: Just for the record I notice 24 that these are not apparently signed by anybody. Terry K. Lindquist; 6/9/9; Page 60 1 It states in this one that the 2 defendant, Borg-Warner, states that it placed warning 3 labels on its asbestos-bearing clutch products in 4 accordance with the requirements of the Hazard 5 Communication Rule of 1986. 6 In your earlier testimony you stated 7 that, and correct me if I misstate your testimony. 8 that the only warning that you are aware of was a 9 warning that was produced and placed on shipments to 10 General Motors, and it was done at the request of 11 General Motors; is that correct? 12 A Yes. The use of our products, to my 13 knowledge at that point in time all the way up 14 through now, has never shown a problem as far as 15 health effects. 16 At the time my testimony has to do with 17 the fact that I was producing products in Brazil for 18 a shipment, to General Motors. General Motors 19 indicated that they wanted to have this label put on. 20 Out of courtesy to our customer we did put that on. 21 I can't tell you exactly when that date 22 was. 23 Q. You being the person designated as most 24 knowledgable in a number of areas that we have gone Page 59 1 Do you have a signed set? 2 MR. CARTER: I don't know if I have a 3 signed set with me. These were time stamped and 4 filed with the court in that case, as noted from page 5 1 on the time stamp. I don't know if I have one 6 signed by Mr. Wentz. Was it Wentz that was signing 7 these then? 8 MR. BAKER: I am just looking at the page 9 which apparently has listed in type Horiszney, but it 10 is neither signed with his signature nor is it dated 11 nor is it verified. All those blanks remain empty. 12 I offer that as an observation in the 13 sense that I am not disputing your representation 14 here on the record that these were filed. I am 15 simply offering it as an observation that apparently 16 we are looking at a document titled Exhibit No. 4 to 17 this deposition which is not signed by anybody from 18 Borg-Warner. I would like to place that on the 19 record before Mr. Lindquist answers any questions. 20 BY MR. CARTER: 21 Q. Going to interrogatory No. 70 and 22 Exhibit B, which is referenced in the answer to 23 interrogatory No. 70, and excluding the part in the 24 answer gives standard objections. Page 61 1 over and another area, one ofwhich being warnings. 2 which statement - there appears to be, from my 3 reading of this list, a conflict between what you 4 have said and what was given as an answer by counsel 5 for Borg-Warner. 6 I am just trying to see which one is the 7 more accurate. Whether it was simply warnings that 8 were placed at the request of General Motors or 9 whether it was warnings placed as a response to a 10 requirement? 11 MR. BAKER: Show my objection to the 12 form of the question. I don't believe that there is 13 an inconsistency here. 14 If you are going to characterize it as 15 an inconsistency I am going to further object on the 16 grounds that, number one, you have pulled out here a 17 set that purports to be answers to interrogatories 18 numbering 64 pages and directed as simply to one 19 question, showing us one exhibit attached. I have 20 already mentioned that this set that you have shown 21 to us is not signed by anybody from Borg-Warner. 22 Secondly, I think Mr. Lindquist has 23 already testified that he has not participated in the 24 preparation in the answers to interrogatories on ECOSCRIPTTM Page 58 - Page 61 Terry K. Lindquist; 6/9/95 Page 62 1 behalf of Borg-Warner, so he does not have knowledge 2 of the exact thought processes that went into 3 answering question No. 70, if, in fact, this is an 4 answer on behalf of Borg-Warner. 5 I would object to the characterization 6 of your question in the sense that there may be 7 inconsistencies here. 8 But to the extent that he has knowledge 9 of the general area ofwarnings he's certainly 10 qualified to testify on those points. 11 BY MR. CARTER: 12 Q. All of that aside, does it appear to you 13 from your reading of the answer, the reading of the 14 warning and your knowledge of the operations of 15 Borg-Warner at this particular time, that the 16 response of Borg-Warner in putting a warning on just 17 those products that were shipped to General Motors at 18 their request was not a response to the Hazardous 19 Communication Rule, but simply a response to a 20 request by a specific purchaser? 1 21 A. Again, T have no knowledge of the 22 Hazardous Communication Rule of 1986.1 don't know 23 what that is. 24 I do know that I was in Brazil at the . In Re: Asbestos ry Page 64 1 we were on the same page. 2 BY MR. CARTER: 3 Q. Where was Spring/Brummer's manufacturing 4 facility or facilities? 5 A. In Bellwood, Illinois. 6 Q. Not being from Illinois I am going to 7 ask you where that is. 8 A. Bellwood, Illinois, is a western suburb 9 of the City of Chicago. 10 Q. Did you ever have an opportunity, other 11 than the one time that you mentioned earlier in your 12 career, to get out to that manufacturing facility? 13 A. I am sure I did get there because I 14 continued to work on that mechanical one-way clutch. 15 I am sure I had been there more than just that one 16 three-month period. 17 Q. Can you give me an idea, just your best 18 recollection, not holding you to photographic memory, 19 the last time you were there? 20 A. Probably last week. 21 Q. Have you visited that facility on a 22 relatively regular basis? 23 A. No, I can't say regularly relatively 24 because I did visit it early in my career. They are Page 63 1 time when we were making clutch products at the 2 request and to sell to General Motors. I do know 3 that on those products we were asked to put this 4 label on it and we did. 5 Q. I want to go through the interrogatories 6 and ask a few other questions. 7 Ifyou go to page 8, actually the 8 question starts, I believe, on page 7, it's question 9 No. 12.1 am looking at particularly answer No. 10 12-C. 11 You stated before that you are not aware 12 of any of the disc brakes that were made or sold? 13 A. No, sir I am not. 14 Q. So you wouldn't know whether or not disc 15 brake pads were sold to Kelsey Hayes or Bendix? 16 A. I really don't know. 17 MR. BAKER: Back up a second. Are you 18 asking him to review interrogatory No. 12 and you 19 were going to ask a question? 20 MR. CARTER: No. I was just confirming 21 that asking a question about the disc brakes would 22 probably be useless because he doesn't know anything 23 about the disc brakes. 24 MR. BAKER: I just wanted to make sure Page 65 1 now part of the group for which I am the 2 vice-president of business development. So I have 3 visited in both those times. 4 Q. Weis there a period of time that you 5 essentially did not visit that facility? 6 A. Sure. That period would be probably in 7 the seventies through when I was down in Brazil, '87. 8 Q. Is there any company that would have 9 resold a Borg-Warner clutch under their own name or 10 in their own box? 11 A. I don't know. Again, that's aftermarket 12 resales, and that's outside of my original equipment 13 knowledge. 14 Q. I want to go back to one of the early 15 exhibits, which is the witness list. There are two 16 people mentioned on the witness list that I want to 17 ask you a couple questions about. 18 The first one, of course, being Mr. 19 James Grady. He's the first lay witness listed. 20 Do you know who Mr. Grady is? 21 A. Yes, I have known Mr. Grady as being 22 part of Borg-Warner. 23 Q. Can you give me an idea of how long you 24 have known Mr. Grady? Page 62 Page 65 ECOSCRIPTTM Ip Re: Asbestos IV Page 66 1 A. Mr. Grady came to Borg-Warner in the 2 Detroit area, so my earliest recollection would have 3 been when I moved to Detroit, which would have been 4 in the late sixties. Somewhere in that time period. 5 Q. Do you know what area of the operations 6 of Borg-Warner in which he would be the most 7 knowledgeable? 8 A. I can only give you the kinds of 9 positions that he's held. 10 Q. That's probably a better question. 11 A. Those positions were, at least that I 12 recall, were in sales. 13 Q. Going to the Thayer interrogatories, on 14 page 22 it mentions in there that at the time that 15 these were filed Mr. Grady was vice-president of 16 marketing and involved in the sale of Borg-Warner's 17 clutch products. 18 Dues that seem col l ect with your memory 19 and knowledge of Mr. Grady? 20 A. I can't give you an exact statement that 21 that was the correct title I know that he was in 22 sales. 23 Q. Was he involved, to the extent of your 24 knowledge of Mr. Grady and his history with Terry K. Lindquist; 6/9/95 Page 68 1 A. To the best of my knowledge that's true. 2 Q. What is his training? Do you know if 3 he's an engineer? 4 A. I am afraid I don't know. 5 Q. Du yuu have an idea of how old he is, 6 best guess? 7 A-1 can only tell you that I think he's 8 older than I am. So I don't know exactly how much. 9 Q. Through your career with Borg-Warner 10 have you ever worked with him at any of the positions 11 that you have held? 12 A. It would only have been on an oversight. 13 but not on any direct reporting relationship. Such 14 as when I had the research center and Spring/Brummer 15 may have had a program that they were having done at 16 the research center. 17 Q. To the extent that I wanted to find 18 something out about the operations of the 19 Spring/Brummer division he would probably be a 20 hetter source than you? 21 A. Yes. 22 Q. Probably better than Mr. Grady from what 23 you have told me about Mr. Grady being pretty much 24 the clutch transmission line? Page 67 1 Borg-Warner, has he been involved with the Borg & 2 Beck clutch line, or would he have been involved in 3 the Spring/Brummer or the automotive parts division 4 or some other division? 5 A. He would have been involved in Borg & 6 Beck products. 7 Q. Which would have been essentially the 8 transmission line, clutches, and that sort of thing? 9 A. Yes. 10 Q. The second person listed on the lay 11 witness list is Robert Hornick. 12 Can you tell me anything about Mr. 13 Hornick? 14 A. Mr. Hornick I knew much less than I know 15 about Mr. Grady. I know that he was an employee of 16 the Spring division. 17 Q. Do you have an idea, to the best of your 18 knowledge, the first time you met him through 19 Borg-Warner, or an estimation? 20 A. I really can't recall the first time. I 21 du know that I've kiiuwn him since I came back from 22 Brazil, which was '87. 23 Q. To the best of your knowledge has most 24 of his work been with the Spring/Brummer division? Page 69 1 A. I assume that's true. 2 Q. In your visit or work with any of the 3 production facilities are you aware of any 4 measurements of asbestos levels in any of the plants? 5 A. No, I am not aware. Again, I was in 6 engineering. 7 Q. Are you aware of any medical exams of 8 any workers fur occupational lung diseases? 9 A. I am not aware. 10 Q. I am going to ask you about a few people 11 to see ifyou have met or know these people. 12 We have talked about Mr. Hornick and Mr. 13 Grady. 14 Have you ever met a person by the name 15 of Edward Fuller? 16 A. That name doesn't ring a bell with me. 17 Q. How about Richard Rosenberg? 18 A. No. 19 Q. Have you ever had any dealings with 20 someone who would have been the manager of regulatory 21 affairs and safety? 22 A. No. 23 Q. How about Jack Wentz, W-E-N-T-Z? 24 A. Jack Wentz was, yes, I've heard that ECOSCRIPTTM Page 66 - Page 69 Terry K. Lindquist; 6/9/95 Page 70 1 name in downtown Chicago, corporate headquarters. 2 Exactly what job, I don't know. 3 Q. Have you ever met Mr. Wentz? 4 A. I probably met him at a Borg-Warner 5 gathering, but, again, not on a working and reporting 6 relationship. 7 Q. Have you ever met an attorney with 8 Borg-Warner by the same of Scott Boylan, B-O-Y-L-A-N? 9 A. No. 10 Q. Or anybody by the name of Thomas 11 Wolowicz, W-O-L-O-W-I-C-Z? 12 A. No. 13 Q. Victor McCloskey? 14 A. No. 15 Q. A lady by the name of Joyce D-R-A-V-K, 16 Dravk? 17 A. No. 18 Q. Are you aware of any person who might 19 have had responsibility for safety in any of the 20 facilities where you worked? 21 A. I believe the safety reported to the 22 plant managers in any of the facilities at 23 Borg-Warner, but I can't give you any names for 24 those. In Re; Asbestng ry _____________________________Page 72 1 different organizations that Borg-Warner was a member 2 of. It lists The American Society of Metals, The 3 American Association of Mechanical Engineers, 4 Friction Subcommittee, Transmission and drive train 5 technical committee and the National Safety Council. 6 Then continuing on the next page it says 7 that Richard Rosenberg, formerly of the Borg-Warner 8 Research Center attended meetings of the Asbestos 9 Information Association. 10 Are you aware of any information or any 11 membership in any of the organizations that have been 12 mentioned? 13 A. No. 14 MR. BAKER: I would like to put, since 15 we keep going on and on about this set of answers to 16 interrogatories, I would like to put a continuing 17 objection on the record that until we are shown a 18 signed copy of these that we are objecting to this 19 entire line of questioning. 20 MR. CARTER: Okay. I am going to ask 21 counsel to investigate the mention of Richard 22 Rosenberg attending meetings of the Asbestos 23 Information Association. To the extent that they may 24 exist, any notes taken or memoranda relating to the Page 71 1 Q. On page 58 of the Thayer 2 interrogatories, it would be answer to question No. 3 104. 4 It lists a deposition by Jack Wentz, who 5 was at that time assist general counsel of 6 Borg-Warner on September 28,1988, in regard to a 7 case called Becker versus Barron Brothers. 8 Were you ever aware of this case? 9 A. No. 10 Q. It also mentions that a copy of this 11 deposition is kept by Borg-Warner Automotive's law 12 department in Sterling Heights. 13 MR. CARTER: At this time I would like 14 to request a copy of that deposition. 15 MR. BAKER: I will make an inquiry to 16 see, first of all, if they still have it. Secondly, 17 what my client's position is on releasing it directly 18 as opposed to through a court reporter. I think 19 there is some ethical considerations there, for 20 example, the court reporter's copyright of the work. 21 BY MR. CARTER: 22 Q. Ifyou will go back to page 48 in the 23 answer to interrogatory No. 82 at the very bottom. 24 It's essentially a question about Page 73 1 ALA. 2 MR. BAKER: May I suggest you put the 3 request in writing and we will respond. 4 (Exhibit Nos. 5 and 6 were marked for 5 identification.) 6 (Break.) 7 BY MR. CARTER: 8 Q. Going to the next set, which is a set of 9 interrogatories in the case captioned Helen M. Webb 10 versus Borg-Warner, State of Michigan, again the 11 Circuit Court of Wayne County. 12 MR. CARTER: Just for the record, there 13 is an affidavit duly signed and notarized by Jack 14 Wentz. 15 Q. I will hand these to you. 16 MR. CARTER: For the record, also, they 17 are dated July 3,1986. 18 Q. I would first like to direct 19 your attention to No. 71, which is on page 68. 20 This question, to summarize it if my 21 interpretation is incorrect, essentially asks ahout 22 warnings. The answer to this one is not applicable 23 in 1986 when they were signed by Mr. Wentz. 24 MR. BAKER: Can we have a moment to read Page 70 - Page 73 ECOSCRIPTTM jn Re; Asbestos IV Page 74 1 the question? 2 MR. CARTER: Sure. 3 MR. BAKER: Before he answers let me 4 just state on the record that I object to the 5 question in the sense that we, sitting here today, 6 are unfamiliar with the set of interrogatories not 7 knowing whether these questions were tailored toward 8 a specific type of usage, products, or a specific 9 genre of products. In other words, the specific 10 context in which these questions were asked. 11 Also, we are being asked to look at one 12 question out of a total of 113 questions stretched 13 over 100 pages, ofwhich we have not had an 14 opportunity to look at. 15 I am going to object to the manner in 16 which the question is being posed and also to the 17 form of it on the basis that we are not familiar with 18 the context in which this question, No. 71, was posed 19 in this particular set of interrogatories. 20 MR. CARTER: But you are not stating 21 that Jack Wentz does not have authority to answer 22 interrogatories on behalf of the corporation, are 23 you? 24 MR. BAKER: I am taking no position in Terry K. Lindquist; 6/9/95 Page 76 1 answered by Borg-Warner, of which you haven't 2 seen but Borg-Warner should be aware if they signed 3 them. 4 MR. BAKER: Understand that I am counsel 5 for Borg-Warner in the State of West Virginia. My 6 representation of Borg-Warner does not date back to 7 the time frame of these discovery questions nor was I 8 counsel in those cases. 9 So I am taking no position at all under 10 authenticity. 11 MR. CARTER: The other counsel that came 12 with you today is counsel for Borg-Warner nationwide 13 or corporate counsel? 14 MR. BARNARD: Not corporate counsel. 15 MR. CARTER: Nationwide counsel? 16 MR. BARNARD: Counsel outside. 17 MR. CARTER: It definitely would cover 18 the scope of Michigan, I would guess, if it's 19 nationwide? 20 MR. BARNARD: I don't represent them in 21 all states. 22 BY MR. CARTER: 23 Q. Anyway, going back to the answer on page 24 81.1 am going to summarize the questions as simply Page 75 1 that regard because I do not know who Jack Wentz is. 2 MR. CARTER: I will go from there. 3 BY MR. CARTER; 4 Q. Again, going back to question 71. The 5 answer at this point, which was signed July 3,1986, 6 would that have been a correct answer on July 3, 7 1986? 8 You appear to be one of the most 9 knowledgeable people about when those warnings were 10 applied to those products that were shipped to GM. 11 A. Again, as I said earlier, T was in 12 Brazil at the time. I know that we were requested to 13 put a warning label on, but I cannot give you an 14 exact date as to when that was. 15 Q. You left Brazil in 1987? 16 A. I left Brazil in the spring of '87. 17 Q. I am going to ask you also to go to page 18 80, and interrogatory No. 88. Please read through it 19 and the answer. 20 MR. BAKER: I simply renew my objections 21 as stated earlier. 22 MR. CARTER: Ifyou want you can have a 23 continuing objection on any questions based on 24 interrogatories answered by or purported to be Page 77 1 one that's asking about a library. 2 Does Borg-Warner have a library or did 3 they have a library? 4 A. Ifyou recall I indicated that I 5 remember that there was a library. I remember that 6 it was about the size of this room. I mentioned that 7 before. It was my understanding that that was a 8 general library that had trade journals in it. 9 Q. That's correct I am not saying that 10 you haven't testified about a library. I just want 11 to ask you some questions about this particular 12 answer. 13 It notes in this answer that Richard 14 Rosenberg established a small library on July 21, 15 1976, but no longer maintains it You have stated 16 that you don't know Mr. Rosenberg? 17 A. No. 18 Q. At this point in time in 1986 it states 19 that there was a publication called Asbestos 20 Magazine, ofwhich, those of us who do asbestos work 21 are well aware as being a trade journal for asbestos 22 manufacturers or people who deal in asbestos, but it 23 does not state when the articles existed. 24 MR. BAKER: Excuse me, was there a ECOSCRIPTTM Page 74 - Page 77 Terry K. Lindquist; 6/9/95 Page 78 1 question? 2 Q. I want to ask you, at any time that you 3 have been at the Ingersoll Research Center have you 4 ever run across any magazines entitled Asbestos? 5 A. Not to my knowledge. 6 Q. If you will go to page 50 of the Thayer 7 interrogatories, I will show you, beginning on page 8 50, question No. 88, and the answer to question No. 9 88,1 would like for you to read that. 10 MR. BAKER: Same objections as before. 11 Q. Remembering that these interrogatories 12 were answered in 1993 as opposed to 1986, which the 13 Webb interrogatories were answered, the question that 14 I pointed you to is, again, a question about 15 libraries. 16 There is a note on the answer in 1993 17 that the research center was closed in 1988, which is 18 somewhat consistent with what you said. 19 Was it 1988 or '89? 20 A It was either at the end of '88 21 or early '89. 22 Q. It states there, And the then remaining 23 contents of the library were sold or disposed of. 24 Were you aware of the disposition of the In Re: Asbestna Page 80 1 don't know what was in the library. I don't know 2 where it weal. 3 Q. I think we are done with Thayer. 4 I want to put in front ofyou a set of 5 interrogatories that are marked as Exhibit No. 6. 6 These are in a case, again, in Wayne 7 County, Michigan, which seems that Borg-Warner had a 8 lot of history in Wayne County, entitled Jack 9 Bruening, B-R-U-E-N-I-N-G, versus Borg-Warner. 10 These are answers to interrogatories 11 that were signed by Jack Wentz, again, in 1986, 12 although the date is somewhat hard to read. 21st day 13 of something. 14 MR. BAKER: I note there is no 15 certificate of service on any of these. Do you know 16 the name of the firm that was counsel for the 17 plaintiff in each of these cases? 18 MR. CARTER: Honestly, no. I know in 19 Thayer, it says on the front, that Michael Serling's 20 office is counsel for the plaintiffs. 21 The rest of them I can't tell you. 22 BY MR. CARTER: 23 Q. This set of interrogatories is answered 24 on page 2, interrogatory No. 3, with regards to Page 79 1 materials of the library at the Ingersoll Research 2 Center? 3 A Not in particular. I was involved in 4 the closure of the research center, but I was more 5 involved In the distribution of equipment and 6 unfortunately the distribution of people, too. 7 Q. To the extent that between the time they 8 were sued in 1986 and the case of 1993, that any of 9 the materials in the library may have had anything to 10 do with asbestos or harms or anything that we wanted 11 to find out they were disposed of during that time 12 period; is that correct? 13 MR. BAKER: Show my objection. First of 14 all, I don't agree with your assessment of the 15 interpretation of those two interrogatory answers by 16 your question. I would object on those grounds. 17 Secondly, it calls for speculation on 18 his part. I think he's already told you that that's 19 not something that he is very familiar with. So I 20 think it calls for speculation on his part, and I 21 object on that ground. 22 You can certainly answer to the extent 23 you know. 24 AI really have no information to give. I Page 81 1 Borg-Warner Corporation. Particularly, the things 2 that sire mentioned here are applicable to the York 3 division, which we mentioned before but you said you 4 didn't have siny dealing with York, which is with sur 5 conditioning; right? 6 A Yes. 7 Q. If we turn to page 5, question No. 8, it 8 simply asks the question about asbestos products. 9 Bsisically, what did you make? The 10 response appears to be a steam grid humidifier 11 containing sisbestos from 1959-1979. 12 That's a product, of course, that you are 13 not aware of; right? 14 A No. I don't even know what a steam grid 15 humidifier is, to tell you the truth. 16 MR. BAKER: Once again, I object on the 17 grounds sis I did earlier in the sense that we 18 certainly don't know the context in which these 19 questions were asked, whether they were case specific 20 dealing with alleged exposure of a particular plant, 21 and the other grounds as I stated earlier. 22 Q. If you will, turn this one to page 47, 23 question No. 79. Go sihead smd read that and the 24 answer on the next page. Page 78 - Page 81 ECOSCRIPTTM In Re; Asbestos IV Page 82 1 A. The question asks in essence, correct me 2 ifyou disagree, that the defendant or defendant's 3 subsidiary in this case, prepared material safety 4 data sheet, or an MSDS, and asked, When? 5 In this case the response was that the 6 defendant prepared an MSDS in approximately 1970. 7 Are you aware of any MSDSs that were 8 ever prepared by the automotive end of Borg-Warner 9 relating to asbestos? 10 MR. BAKER: Show my objection. Did your 11 question say "prepared" or "received?" 12 MR. CARTER: At this point, prepared by 13 Borg-Warner Automotive section. 14 MR. BAKER: Do you want to look at the 15 question yourself? I would rather have him read the 16 question. 17 A. First of all, I am not aware ofwhat an 18 MSDS is. I have never seen one, so therefore, I 19 can't tell you whether, other than the York unit as 20 stated in this question and answer, whether anything 21 of Borg-Warner had ever been received or prepared in 22 response to an MSDS. 23 Q. Sort of anticipating the next question 24 let me ask it as a compound question ifyou don't Terry K. Lindquist; 6/9/95 Page 84 1 that you've held, or would that be someone else's 2 area of responsibility? 3 A. Again, my field of responsibility 4 generally has been engineering and research. I have 5 not had that kind of data come across my desk. 6 Q. Do you have any information about any 7 lawsuits that Borg-Warner has been involved in 8 regarding allegations of exposure to asbestos from 9 their automotive parts, the ones we have been 10 discussing today, the clutches? You are not aware of 11 the brakes, but if you have seen any allegations? 12 A. I have seen no allegations. 13 Q. Are you aware of, other than the lawsuit 14 we are involved in today and the one that you gave a 15 deposition in approximately weeks ago, were you aware 16 before that time of any lawsuits regarding asbestos 17 exposure allegations? 18 A. No, sir. 19 Q. Do you know whether Borg-Warner has been 20 involved in any insurance litigation regarding 21 coverage for asbestos exposure? 22 A. No, I have no knowledge of any insurance 23 coverage. 24 Q. Do you know whether Borg-Warner in any Page 83 1 mind, to summarize what you just said. 2 The automotive end, to the best of 3 your knowledge, neither prepared nor received, again, 4 to the best of your knowledge, any material safety 5 data sheet which is {in OSHA form that discusses the 6 hazards of particular products that are used in the 7 workplace? 8 A. To the best of my knowledge, I have no 9 knowledge of an MSDS. 10 Q. I think that's it for this set. 11 Just for your information, a lot of the 12 names that you didn't understand came actually out of 13 the Bruening interrogatories. If they were in the 14 York division you probably didn't have any dealing 15 with them? 16 A. I had no dealings with the York 17 division; that's correct. 18 Q. Are you aware of any Workers' 19 Compensation claims that have been made by any 20 employees of Borg-Warner relating to either an 21 occupational lung disease or cancer? 22 A. I am not aware of any. 23 Q. Would that be something that you would 24 be aware of in the normal course of the positions Page 85 1 of the facilities where you have worked ever abated 2 any asbestos that may have been in the buildings in 3 which you worked? 4 A. Could you explain "abate," please? 5 Q. Did anybody come in and sample for 6 asbestos and remove any asbestos from ceding tiles, 7 wall boards, anything like that? 8 A. If they did I don't know about it. 9 Q. Earlier in the interrogatories that we 10 have been talking about I asked about organizations 11 ofwhich Borg-Warner was a member. 12 My question is were you ever a member of 13 any of those organizations, the American Society of 14 Metals, the American Association of Mechanical 15 Engineers, the National Safety Council or the 16 Asbestos Information Association? 17 A. No, I was never a member of any of 18 those. I recall that 1 attended one meeting of the 19 Asbestos Institute at the point in time where we were 20 to open a program to find a friction material without 21 asbestos. I found that the discussion did not entail 22 any discussions of alternate fibers and never went 23 back to any more. 24 Q. The Asbestos Institute, is that the ECOSCRIPTTM Page 82 - Page 85 Terry K. Lindquist; 6/9/95 Page 86 1 Asbestos Information Association? 2 A. I believe it was. That was a long time 3 ago. I believe that it was the Asbestos Information 4 Institute. 5 Q. Approximately, when was the time that 6 you attended that meeting? 7 A. Approximately in the late seventies. 8 Q. Can you give me an idea ofwhat was 9 being discussed at that meeting which you attended? 10 A. I really can't. I don't really know 11 what the agenda or what was being discussed. I know 12 that I went specifically to find out about alternate 13 materials like fiberglass. 14 I recall that there was no discussion at 15 all about alternate materials. I can't tell you what 16 the agenda was or what was discussed. 17 Q. Did you keep any materials, notes, 18 memos, records from that meeting? 19 A. I don't believe I did because I was 20 disappointed that it didn't meet my goals ofwhy I 21 went. 22 Q. Have you seen any publications from any 23 of the other agencies or groups of which Borg-Warner 24 was a member; the National Safety Council or the In Re; Asbestos jy Page 88 1 (Exhibit No. 7 was marked for 2 identification). 3 BY MR. CARTER: 4 Q. The last exhibit is Exhibit No. 7. This 5 is a witness list. Just to get it on the record, 6 earlier I had asked you some questions about some 7 individuals who were listed on the witness list for 8 this case, and this one that you have in front ofyou 9 is from the Thayer case in Michigan, and were signed 10 by Richard Brennen on behalf of Borg-Warner, December 11 23,1994. 12 It lists under witnesses Mr. Grady, Mr. 13 Homick, and instead ofyou it listed Mr. Fuller. 14 Did you know Mr. Fuller? 15 A. I don't believe I did. I don't believe 16 so. 17 Q. I want to ask you just a couple of 18 questions about some of the witnesses that they had 19 listed here. Ifyou will go to page 5.1 am at a 20 loss as to who these people are. 21 Witnesses No. 52 through 56,1 want to 22 make sure they are not a Borg-Warner person. 23 Dan Foster, Americus Crawford, Donald 24 McCullum, John McCallum and Dan Mead? Page 87 1 American Society of Metals or the American 2 Association of Mechanical Engineers? 3 A. No. 4 Q. One last question. 5 We were talking earlier about hazards of 6 exposure, or allegations of hazards of exposure of 7 brakes and clutches. 8 I want to ask you a question whether you 9 ever read any paper by DuCharme Somers on the brake 10 and clutch emmisions generated during vehicle 11 operations? 12 A. No. 13 Q. Have you ever been aware of any 14 literature where anybody has ever tried to study 15 whether or not brakes or clutches had any 16 asbestos residue after their lifespan? 17 A. No. 18 Q. I will go through my notes one time. 19 MR. BAKER: In regard to the last 20 question you posed was that another set of 21 interrogatories? 22 MR. CARTER: No. That was something I 23 came across elsewhere. 24 (Break.) Page 89 1 A. I don't know any of those. 2 Q. They listed as experts a number of 3 people at the bottom of page 5, No. 60 through 65. 4 I want to ask you ifyou ever dealt with 5 or heard anything about the individuals that are 6 listed. 7 Dr. John Craighead? 8 A. No. 9 Q. Arnold Anderson? 10 A. There was an Arnold Anderson at Ford 11 Motor Company. I know his name, but I don't know 12 what he does or what he would be expert in. 13 Q. William Krebs? 14 A* No. 15 Q. Otto Wong? 16 A. No. 17 Q. Dr. Churg? 18 A. No. 19 Q. Mark Wick? 20 A. No. 21 Q. Going back to the witness list, for this 22 case, I am going to ask you some similar questions 23 about the experts that have been listed. 24 In this case Borg-Warner has listed Otto Page 86 - Page 89 ECOSCRIPTTM InRerAsbestos IV_______________________ Terry K. Lindquist; 6/9/95 Page 90 Page 92 1 Wong. You have already said that you don't know Mr. 2 Wong. 3 How about Sheldon Rabinovitz? 4 A. No. 5 Q. Amuld Anderson? 6 A- Maybe I was wrong, because that listed 7 him as with a different company. So that may be 8 someone else. 9 Q. That may be a different Arnold Anderson 10 than the one you know. 11 Do you know anything about the field of 12 tribology? It's listed there. 13 A. I know only that tribology is the study 14 of friction, wear and lubrication. Those are the 15 three "ologies" in Iribulogy. 16 Q. Have you seen any of the reports from 17 any of the experts that we have gone through so far? 18 Any reports saying that they find that there is or is 19 not asbestos or any potential harm from clutch 20 or brake materials? 21 A. No, not that I am aware of. 22 Q. I will ask you, is there anything in any 23 of the questions that I have asked and the answers 24 that you have given that you want to clarify 1 1985, which certainly predates our involvement here 2 in the State of West Virginia on behalf of 3 Borg-Warner. If, in fact, Mr. Wentz filed those 4 answers, then certainly they are valid as attachments 5 to the record here today. 6 But not having personal knowledge of his 7 role in those cases those were the reasons for my 8 grounds for objecting earlier. 9 That's all that I have. 10 We would like to read and sign. If you 11 would send it to me I will see that Mr. Lindquist 12 gets a copy and reviews a copy. 13 (The deposition of TERRY K. LINDQUIST 14 was concluded.) Page 91 1 or at this point think that something may have come 2 across incorrectly? 3 A. I can't think of anything. 4 Q. I just want to give you an opportunity 5 if something came to mind to correct the record now 6 rather than try and do it later. 7 The object here is to get the best and 8 most complete record and exhaust as much knowledge as 9 we can today. 10 MR. CARTER: At this point I have no 11 further questions. Thank you very much for 12 your time. 13 MR. BAKER: I just have one matter I 14 would like to clarify on the record. 15 We have looked at a number of sets of 16 answers to interrogatories today dealing with cases, 17 I believe, mainly in the State of Michigan. 18 As I understand it we are getting 19 copies of those made before we leave today. 20 In regard to Mr. Wentz. I made a 21 statement earlier on the record that I was not 22 personally familiar with his role in these answers to 23 interrogatories. I want the record to reflect that 24 the answers that we were looking at date back to Page 93 1 STATE OF WEST VIRGINIA, To-wit: 2 I, Monique Christiansen, a Notary Public and 3 Court Reporter within and for the State aforesaid, 4 duly commissioned and qualified, do hereby certify 5 that the deposition of TERRY K. LINDQUIST was duly 6 taken by me and before me at the time and place 7 specified in the caption hereof. 8 I do further certify that said proceedings were 9 correctly taken by me in stenolype notes, that the 10 same were accurately transcribed out in full and 11 true record of the testimony given by said witness. 12 I further certify that I am neither attorney or 13 counsel for, nor related to or employed by, any of 14 the parties to the action in which these proceedings 15 were had, and further I am not a relative or employee 16 of any attorney or counsel employed by the parties 17 hereto or financially interested in the action. 18 My commission expires the 24 day of August 19 2004. 20 Given under my hand and seal this 16th day of 21 June 1995. 22 22 23 Monique Christiansen 23 CourtReporter 24 Notary Public ECOSCRIPTTM Page 90 - Page 93 Terry K. Lindquist; 6/9/95 In Re: Asbestn ry Page 94 - Page 94 ECOSCRIPTTM In Re; Asbestos IV Terry K. Lindquist; 6/9/95 ============== A =============== abate (85:4) abated (85:1) abex (55:24) (56:1) able (38:1) above (25:2) absolutely (51:14) (56:21) accordance (60:4) according (7:17) accurate (24:13) (32:18) (34:6) (61:7) accurately (23:9) (93:10) acid (33:10) across (78:4) (84:5) (87:23) (91:2) action (1:5) (93:14) (93:17) activities (6:18) (9:21) actually (22:13) (22:24) (37:16) (37:17) (52:11) (57:17) (63:7) (83:12) administrative (18:17) admissions (10:8) advanced (17:1) (28:17) . affairs (69:21) affect (17:2) affidavit (73:13) affidavits (9:19) aforesaid (93:3) afraid (40:15) (45:19) (68:4) after (4:16) (16:15) (19:17) (27:23) (27:24) (87:16) aftermarket (39:14) (39:15) (40:2) (48:23) (65:11) agencies (21:22) (86:23) agenda (86:11) (86:16) agree (52:1) (54:1) (79:14) ahead (58:15) (81:23) aia (73:1) air (42:13) (42:23) (44:20) (50:3) (81:4) aircraft (42:16) (43:1) allegations (84:8) (84:11) (84:12) (84:17) (87:6) alleged (81:20) allied (2:6) almost (17:19) already (52:23) (61:20) (61:23) (79:18) (90:1) alternate (85:22) (86:12) (86:15) although (80:12) always (42:2) american (55:24) (72:2) (72:3) (85:13) (85:14) (87:1) (87:1) americus (88:23) amplification (31:6) anderson (89:9) (89:10) (90:5) (90:9) annual (45:21) (45:22) another (34:23) (36:2) (37:22) (42:15) (61:1) (87:20) answer (5:14) (6:4) (6:10) (23:8) (25:16) (26:9) (57:10) (58:16) (59:22) (59:24) (61:4) (62:4) (62:13) (63:9) (71:2) (71:23) (73:22) (74:21) (75:5) (75:6) (75:19) (76:23) (77:12) (77:13) (78:8) (78:16) (79:22) (81:24) (82:20) answered (75:24) (76:1) (78:12) (78:13) (80:23) answering (6:22) (62:3) answers (35:24) (36:14) (38:2) (40:24) (55:12) (59:19) (61:17) (61:24) (72:15) (74:3) (79:15) (80:10) (90:23) (91:16) (91:22) (91:24) (92:4) anticipating (82:23) anyway (76:23) apparently (58:24) (59:9) (59:15) appear (51:22) (62:12) (75:8) appearances (2:1) appeared (54:4) appearing (2:2) (2:5) (2:8) (2:10) appears (11:21) (36:1) (38:2) (51:20) (52:8) (54:10) (61:2) (81:10) applicable (51:22) (73:22) (81:2) application (34:4) applications (17:5) (17:6) (51:6) (51:11) (52:3) (52:5) applied (24:9) (75:10) approximately (16:18) (24:23) (27:3) (38:3) (46:2) (82:6) (84:15) (86:5) (86:7) april (28:22) arbitrarily (12:20) area (5:7) (6:1) (6:4) (16:24) (18:15) (47:24) (48:23) (49:2) (61:1) (62:9) (66:2) (66:0) (84:2) areas (5:4) (5:16) (5:24) (44:13) (60:24) arnold (89:9) (89:10) (90:5) (90:9) around (23:17) (48:20) article (7:20) (7:22) articles (45:14) (77:23) asbestos (1:5) (6:2) (6:3) (6:8) (6:11) (6:18) (7:1) (7:5) (7:14) (8:24) (9:20) (13:22) (14:1) (16:13) (19:8) (19:13) (20:19) (20:23) (21:4) (22:24) (23:6) (23:11) (25:1) (30:21) (31:8) (32:13) (32:17) (32:21) (33:1) (33:5) (33:6) (36:3) (36:4) (36:9) (41:3) (44:16) (44:22) (54:21) (56:14) (69:4) (72:8) (72:22) (77:19) (77:20) (77:21) (77:22) (78:4) (79:10) (81:8) (81:11) (82:9) (84:8) (84:16) (84:21) (85:2) (85:6) (85:6) (85:16) (85:19) (85:21) (85:24) (86:1) (86:3) (87:16) (90:19) asbestos* (22:11) asbestos-bearing (60:3) asbestos-containing (21:8) (31:12) (49:4) (49:10) (56:18) aside (62:12) asking (26:6) (54:14) (63:18) (63:21) (77:1) asks (73:21) (81:8) (82:1) aspects (15:10) (20:2) (43:8) (55:2) assemblies (19:7) (30:10) (36:4) assembly (13:16) (22:12) (32:14) (32:22) assessment (79:14) assigned (10:14) assist (71:5) associates (1:22) association (72:3) (72:9) (72:23) (85:14) (85:16) (86:1) (87:2) assume (69:1) assuming (35:20) assumption (53:2) attached (21:5) (29:21) (61:19) attachments (92:4) WORD INDEX ABATE - ATTACHMENTS Terry K. Lindquist; 6/9/95 In Re: Asbestnn ry attended (72:8) (85:18) (86:6) (86:9) attending (72:22) attention (73:19) attorney (70:7) (93:12) (93:16) attractive (33:12) august (93:18) austo (55:22) authenticity (76:10) authority (74:21) auto (21:7) automatic (13:15) (19:6) (20:11) (28:20) (29:19) (30:8) (30:11) (30:14) (30:17) (30:18) (30:20) (38:10) (38:17) (38:19) (38:22) (38:23) automobile (37:2) automobiles (18:11) (48:10) (51:23) (52:10) (52:12) (56:19) automotive (11:11) (14:13) (14:15) (16:10) (17:4) (17:19) (17:20) (17:22) (18:19) (18:21) (18:24) (19:22) (20:1) (20:2) (20:3) (20:9) (21:9) (28:11) (28:14) (28:24) (29:7) (29:8) (29:9) (29:12),(30:13) (32:1) (32:8) (34:14) (36:21) (37:11) (39:9) (39:12) (40:11) (41:14) (41:16) (41:17) (41:20) (41:21) (42:3) (42:9) (48:1) (48:6) (48:7) (48:14) (48:21) (48:24) (52:2) (52:21) (53:9) (57:2) (67:3) (82:8) (82:13) (83:2) (84:9) automotive's (71:11) autos (48:12) available (46:16) avenue (1:18) (2:2) (2:8) aware (5:16) (20:18) (20:22) (21:3) (25:17) (25:20) (36:9) (39:11) (42:10) (42:22) (42:23) (43:4) (44:16) (44:23) (57:5) (57:8) (60:8) (63:11) (69:3) (69:5) (69:7) (69:9) (70:18) (71:8) (72:10) (76:2) (77:21) (78:24) (81:13) (82:7) (82:17) (83:18) (83:22) (83:24) (84:10) (84:13) (84:15) (87:13) (90:21) aways (13:23) ============== B============== bachelors (11:15) (13:17) back (11:13) (13:22) (18:6) (22:23) (25:6) (26:13) (26:16) (27:10) (30:4) (31:10) (32:20) (33:15) (43:10) (43:10) (45:8) (48:8) (58:12) (63:17) (65:14) (67:21) (71:22) (75:4) (76:6) (76:23) (85:23) (89:21) (91:24) background (11:12) baker (2:8) (2:8) (5:10) (5:11) (9:6) (9:10) (11:6) (20:24) (26:1) (29:21) (29:24) (30:3) (37:15) (51:2) (53:1) (53:20) (57:14) (58:18) (58:23) (59:8) (61:11) (63:17) (63:24) (71:15) (72:14) (73:2) (73:24) (74:3) (74:24) (75:20) (76:4) (77:24) (78:10) (79:13) (80:14) i (81:16) (82:10) (82:14) (87:19) (91:13) barnard (2:10) (2:10) (76:14) (76:16) (76:20) barron (71:7) base (36:24) based (75:23) basically (81:9) basis (64:22) (74:17) became (16:16) (33:1) beck (13:10) (13:12) (16:16) (17:10) (17:24) (18:22) (19:15) (20:5) (20:18) (20:19) (21:2) (22:8) (29:1) (29:4) (29:6) (29:13) (32:3) (34:21) (35:21) (36:3) (54:15) (54:16) (54:18) (54:22) (55:1) (67:2) (67:6) becker (71:7) began (32:2) begin (8:11) beginning (8:11) (34:11) (78:7) behalf (5:12) (11:7) (62:1) (62:4) (74:22) (88:10) (92:2) believe (5:14) (9:3) (11:2) (11:3) (31:17) (35:1) (37:6) (37:12) (45:11) (46:23) (53:9) (58:4) (61:12) (63:8) (70:21) (86:2) (86:3) (86:19) (88:15) (88:15) (91:17) bell (69:16) bellwood (13:8) (64:5) (64:8) below (25:2) bendix (63:15) besides (46:8) (46:12) (49:11) best (47:18) (64:17) (67:17) (67:23) (68:1) (68:6) (83:2) (83:4) (83:8) (91:7) better (42:6) (52:16) (66:10) (68:20) (68:22) beyond (41:14) (47:23) big (14:16) (15:1) (15:15) (15:18) (41:12) billion (41:18) bit (26:3) blanks (59:11) boards (85:7) bob (27:22) bonds (44:9) books (15:24) borg (13:10) (13:12) (16:16) (17:10) (17:24) (18:21) (19:15) (20:5) (20:17) (20:19) (21:2) (22:8) (29:1) (29:4) (29:6) (29:13) (32:3) (34:21) (34:22) (35:21) (36:3) (46:16) (54:15) (54:16) (54:17) (54:22) (55:1) (67:1) (67:5) borg-wamer (2:9) (2:12) (5:12) (6:11) (6:18) (6:23) (7:6) (7:7) (7:14) (7:15) (7:19) (10:19) (10:24) (11:7) (11:10) (11:22) (12:1) (12:9) (12:20) (19:21) (20:2) (21:15) (27:22) (28:11) (28:14) (28:24) (29:5) (29:8) (29:9) (29:12) (30:13) (31:11) (32:2) (34:9) (34:11) (34:12) (34:17) (34:22) (34:24) (35:6) (35:13) (35:15) (36:2) (38:12) (41:9) (41:13) (41:16) (41:20) (41:21) (41:23) (42:2) (42:7) (42:11) (42:17) (42:21) (43:6) (43:8) (43:14) (43:16) (43:18) (43:22) (44:4) (44:18) (45:1) (45:12) (45:15) (46:1) (46:4) (46:7) (46:17) (46:19) (47:1) (48:1) (48:6) (48:9) (48:11) (49:5) (50:20) (51:7) (51:15) (51:21) (52:18) (53:6) (53:7) (53:24) (54:6) (54:7) (55:2) (56:5) (56:19) (57:6) (57:11) (58:1) (59:18) (60:2) (61:5) (61:21) (62:1) (62:4) (62:15) (62:16) (65:9) (65:22) (66:1) (66:6) (67:1) (67:19) (68:9) (70:4) (70:8) (70:23) (71:6) (71:11) (72:1) (72:7) (73:10) (76:1) (76:2) (76:5) (76:6) (76:12) (77:2) (80:7) (80:9) (81:1) (82:8) (82:13) (82:21) (83:20) (84:7) (84:19) (84:24) (85:11) (86:23) (88:10) (88:22) (89:24) (92:3) borg-Warner's (66:16) bosick (2:5) bottom (71:23) (89:3) bouncing (33:7) (33:14) box (2:11) (65:10) ATTENDED - BOX WORDINDEX In Re; Asbestos IV Terry K. Lindquist; 6/9/95 boylan (70:8) brake (38:4) (56:24) (63:15) (87:9) (90:20) brakes (39:6) (39:7) (50:24) (51:6) (51:12) (51:14) (51:21) (63:12) (63:21) (63:23) (84:11) (87:7) (87:15) brazil (21:13) (21:16) (21:18) (21:20) (21:22) (22:1) (22:3) (22:5) (22:10) (22:14) (22:20) (22:20) (22:22) (24:16) (24:24) (25:18) (25:21) (26:15) (26:18) (27:7) (60:17) (62:24) (65:7) (67:22) (75:12) (75:15) (75:16) brazilian (26:12) break (42:18) (42:20) (58:22) (73:6) (87:24) brennen (88:10) briefly (37:23) brothers (71:7) brought (34:16) (35:12) hruce (2:2) (4:4) bruening (80:9) (83:13) brummer (37:23) (38:7) (38:14) (52:17) (52:20) (67:3) (67:24) (68:14) (68:19) brummer's (64:3) brw (21:9) t building (14:19) (14:19) (14:520) (14:22) (14:23) (14:24) (15:2) (27:17) buildings (85:2) buy (23:2) (23:13) (39:21) (44:9) calibrations (14:10) call (43:5) called (11:8) (12:24) (17:1) (28:20) (29:8) (40:19) (56:8) (71:7) (77:19) calls (79:17) (79:20) came (23:20) (23:24) (35:7) (49:1) (52:19) (66:1) (67:21) (76:11) (83:12) (87:23) (91:5) Canada (46:13) cancer (83:21) cannot (13:24) (75:13) capability (33:17) caps (40:8) caption (93:7) captioned (58:1) (73:9) car (39:22) (51:18) carburetor (35:3) (35:18) carburetors (35:17) career (64:12) (64:24) (68:9) carefully (53:3) carry (7:16) cars (40:7) carter (2:2) (3:8) (4:3) (4:4) (4:21) (5:23) (9:4) (9:8) (9:18) (10:17) (10:22) (21:1) (26:3) (26:5) (29:23) (30:2) (30:5) (37:18) (42:19) (51:3) (51:8) (54:1) (54:2) (57:17) (57:23) (59:2) (59:20) (62:11) (63:20) (64:2) (71:13) (71:21) (72:20) (73:7) (73:12) (73:16) (74:2) (74:20) (75:2) (75:3) (75:22) (76:11) (76:15) (76:17) (76:22) (80:18) (80:22) (82:12) (87:22) (88:3) (91:10) case (4:5) (10:9) (11:5) (50:6) (58:1) (59:4) (71:7) (71:8) (73:9) (79:8) (80:6) (81:19) (82:3) (82:5) (88:8) (88:9) (89:22) (89:24) cases (20:14) (76:8) (80:17) (91:16) (92:7) catalog (50:23) (53:4) catalogs (50:20) caterpillars (36:23) ceased (31:11) ceiling (85:6) cements (33:8) center (2:5) (12:15) (12:17) (12:22) (12:23) (13:1) (14:3) (14:8) (14:16) (15:9) (24:8) (27:10) (27:16) (28:4) (38:19) (68:14) (68:16) (72:8) (78:3) (78:17) (79:2) (79:4) central (47:13) centrifugal (17:8) certainly (7:17) (52:5) (62:9) (79:22) (81:18) (92:1) (92:4) certificate (80:15) certify (93:4) (93:8) (93:12) chairmen (27:22) chance (58:19) changed (26:17) (27:18) changing (31:24) characteristics (33:2) characterization (62:5) characterize (61:14) charge (18:9) (50:2) charleston (1:23) chemical (43:2) chemicals (42:17) Chicago (4:12) (8:21) (11:19) (13:11) (17:12) (64:9) (70:1) choice (33:3) chose (44:4) chosen (12:21) Christiansen (1:16) (93:2) (93:23) Chrysler (49:20) churg (89:17) circuit (1:1) (73:11) circular (24:6) city (4:11) (8:16) (40:19) (64:9) civil (1:5) (1:16) claims (83:19) clarify (90:24) (91:14) classified (37:1) client's (71:17) close (18:14) closed (23:20) (28:6) (43:19) (44:2) (78:17) closure (79:4) clutch (17:2) (20:12) (22:12) (23:7) (23:11) (23:18) (23:21) (24:24) (31:3) (31:5) (31:6) (31:9) (31:9) (31:12) (32:14) (32:22) (33:13) (33:21) (34:1) (35:22) (36:4) (38:10) (54:21) (55:2) (60:3) (63:1) (64:14) (65:9) (66:17) (67:2) (68:24) (87:10) (90:19) clutches (7:8) (13:9) (13:9) (13:14) (19:5) (21:6) (22:6) (32:12) (36:13) (36:22) (37:13) (38:22) (38:23) (39:1) (67:8) (84:10) (87:7) (87:15) coat (25:11) coating (23:24) (24:2) Colombo (58:5) WORD INDEX BOYLAN - COLOMBO Terry K. Lindquist; 6/9/95 In Re; Asbestos rv/ come (55:7) (84:5) (85:5) (91:1) comes (34:22) (34:24) comfortable (5:20) (6:22) (7:3) coming (21:9) (26:21) (38:21) . comment (55:13) commission (93:18) commissioned (93:4) committee (72:5) communication (60:5) (62:19) (62:22) companies (34:16) (34:19) (35:5) (35:8) (35:9) (45:13) (46:13) (47:3) (48:7) (54:20) (55:10) (55:19) company (35:22) (39:21) (40:1) (40:19) (41:5) (41:17) (41:22) (42:13) (42:13) (42:14) (42:17) (44:8) (44:14) (45:3) (49:19) (55:20) (56:8) (56:10) (65:8) (89:11) (90:7) compared (55:14) compensation (83:19) competent (5:8) complete (91:8) completed (16:15) (31:18) (31:23) completely (48:24) component (30:7) (32:14) (33:6) (33:12) (42:24) components (19:22) (20:1) (20:10) (20:11) (21:7) (21:9) (29:1) (29:10) (29:16) (29:19) (30:10) (39:14) (39:10) (40:7) (42:15) (48:4) compound (82:24) comprised (23:7) computer (47:21) concept (15:23) concern (7:9) concerning (11:9) concluded (92:14) conditioning (42:13) (42:24) (44:20) (81:5) confirming (63:20) conflict (61:3) considerations (71:19) consistent (78:18) consolidate (35:9) consolidation (34:15) (35:7) construction (37:5) (37:7) consumption (26:12) contact (9:14) contain (30:21) contained (20:19) (20:22) (21:4) (36:4) (54:4) (54:21) containers (49:7) (49:18) containing (22:12) (81:11) contents (52:4) (53:21) (78:23) context (74:10) (74:18) (81:18) continued (35:11) (35:16) (64:14) continuing (72:6) (72:16) (75:23) continuously (28:21) contributed (35:5) control (14:6) (42:15) controls (18:10) (20:15) (42:16) converted (47:21) converter (30:7) converters (13:15) (29:7) (30:9) convertors (19:6) (29:13) copies (91:19) copy (4:17) (4:24) (9:5) (9:9) (71:10) (71:14) (72:18) (92:12) (92:12) copyright (71:20) corporate (12:15) (34:8) (41:8) (45:18) (70:1) (76:13) (76:14) corporation (6:2) (12:9) (19:11) (29:10) (29:16) (35:17) (41:19) (41:24) (42:8) (42:21) (44:9) (44:11) (44:12) (44:13) (45:20) (46:5) (50:17) (74:22) (81:1) correct (8:9) (8:10) (8:13) (11:2) (11:23) (11:24) (17:20) (24:1) (24:18) (27:8) (28:12) (30:15) (30:24) (31:1) (31:7) (32:7) (36:5) (39:4) (45:9) (45:23) (47:19) (52:3) (52:8) (52:11) (53:10) (54:22) (60:7) (60:11) (66:18) (66:21) (75:6) (77:9) (79:12) (82:1) (83:17) (91:5) correctly (15:17) (35:14) (37:3) (47:14) (48:8) (53:19) (56:16) (93:9) council (72:5) (85:15) (86:24) counsel (2:3) (2:6) (2:9) (2:12) (40:18) (50:19) (52:11) (53:14) (54:9) (61:4) (71:5) (72:21) (76:4) (76:8) (76:11) (76:12) (76:13) (76:14) (76:15) (76:16) (80:16) (80:20) (93:13) (93:16) countries (46:6) (46:9) country (26:18) county (1:1) (58:3) (73:11) (80:7) (80:8) couple (53:17) (65:17) (88:17) course (13:24) (65:18) (81:12) (83:24) courses (13:18) (13:21) court (1:1) (1:16) (4:16) (9:11) (9:12) (10:18) (57:19) (58:4) (59:4) (71:18) (71:20) (73:11) (93:3) courtesy (60:20) courtreporter (93:23) cover (76:17) coverage (8:2) (84:21) (84:23) covered (5:4) craighead (89:7) crawford (88:23) create (23:1) created (45:12) cure (24:3) cured (23:20) curing (24:10) current (16:3) currently (30:12) customer (36:24) (60:20) cycle (47:4) dad (32:4) damper (13:16) (19:6) (30:10) dan (88:23) (88:24) data (82:4) (83:5) (84:5) date (31:17) (49:14) (51:1) (60:21) (75:14) (76:6) (80:12) (91:24) dated (59:10) (73:17) day (80:12) (93:18) (93:20) days (48:9) COME - DAYS WORD INDEX In Re: Asbestos IV Terry K. Lindquist; 6/9/95 db-71 (50:24) deal (6:7) (77:22) dealing (55:1) (81:4) (81:20) (83:14) (91:16) dealings (54:24) (55:3) (69:19) (83:16) dealt (13:18) (16:13) (36:2) (89:4) debt (44:14) december (88:10) decided (44:12) (45:8) decreased (32:9) defendant (6:14) (60:2) (82:2) (82:6) defendant's (82:2) definitely (76:17) definition (36:15) definitive (44:6) degree (12:12) (12:13) (13:18) degrees (34:5) delegated (47:16) demonstrated (53:12) department (18:18) (50:9) (71:12) dependant (18:11) depends (34:4) deponent (3:3) (4:1) (37:17) deposed (8:18) (10:16) deposition (1:15) (4:18) (4:24) (8:12) (8:23) (8:24) (9:2) (9:24) (10:4) (10:19) (59:17) (71:4) (71:11) (71:14) (84:15) (92:13) (93:5) des (13:3) (14:21) (27:10) description (23:23) (24:12) (32:18) (52:3) design (14:11) (16:3) (18:18) designated (60:23) designation (27:19) designed (17:5) (42:5) designer (48:3) desk (84:5) detrolt (17:12) (17:15) (17:16) (17:18) (66:2) (66:3) develop (14:5) (28:19) developed (12:18) (38:16) (38:19) developer (48:3) development (18:18) (30:13) (38:17) (65:2) devoted (26:24) different (5:24) (10:15) (15:10) (29:20) (32:13) (33:4) (44:8) (47:9) (72:1) (90:7) (90:9) difficult (9:15) direct (55:3) (68:13) (73:18) direct- (20:6) directed (61:18) directly (56:18) (71:17) director (27:12) (28:1) disagree (82:2) disappointed (86:20) disc (23:18) (23:21) (24:7) (24:11) (38:4) (39:6) (39:7) (50:23) (51:6) (51:11) (51:14) (51:21) (63:12) (63:14) (63:21) (63:23) discontinued (41:2) discovery (10:7) (76:7) discuss (52:16) discussed (23:12) (52:22) (86:9) (86:11) (86:16) discusses (83:5) discussing (7:3) (7:4) (84:10) discussion (6:12) (29:22) (85:21) (86:14) discussions (85:22) disease (83:21) diseases (69:8) disposed (78:23) (79:11) disposition (78:24) disputing (59:13) dissolve (44:10) distribute (9:12) distributed (11:10) (40:4) (40:6) (40:10) (48:16) (56:22) (57:2) distributing (53:5) distribution (39:24) (53:5) (79:5) (79:6) distributor (39:13) (40:8) (48:15) division (13:8) (13:10) (16:16) (29:4) (35:15) (36:7) (36:11) (37:19) (37:22) (37:23) (38:20) (39:5) (39:10) (39:11) (39:12) (40:12) (43:2) (48:14) (48:15) (48:21) (48:24) (52:17) (52:20) (52:21) (52:22) (53:5) (53:9) (67:3) (67:4) (67:16) (67:24) (68:19) (81:3) (83:14) (83:17) divisions (12:20) (13:4) (13:5) (36:1) (43:23) (50:21) doctor (50:8) document (8:7) (8:13) (51:1) (53:23) (59:16) documents (10:3) (10:8) (40:17) (40:22) (46:16) (47:2) (47:4) (47:20) (53:11) (53:13) (53:15) (53:18) (53:22) (54:3) (54:9) doesn't (47:6) (63:22) (69:16) doing (5:10) (14:9) (14:11) (23:3) (39:22) (51:4) domestic (27:6) don (5:11) donald (88:23) done (25:7) (25:14) (38:20) (49:9) (50:3) (60:10) (68:15) (80:3) doubt (32:10) down (23:20) (43:19) (44:2) (65:7) downtown (70:1) dravk (70:16) drive (17:2) (17:7) (20:14) (43:12) (72:4) dry (31:6) (31:9) (32:12) (33:20) (39:1) ducharme (87:9) duly (73:13) (93:4) (93:5) durability (33:11) duration (26:2) during (13:5) (13:17) (14:5) (18:22) (20:13) (28:7) (29:23) (29:24) (33:20) (34:13) (43:6) (44:7) (52:17) (79:11) (87:10) duties (50:3) duty (36:15) (36:18) earlier (10:1) (19:5) (31:24) (40:18) (50:11) (60:6) (64:11) (75:11) (75:21) (81:17) (81:21) (85:9) (87:5) (88:6) (91:21) (92:8) earliest (66:2) early (31:17) (38:3) (38:17) (48:9) (52:17) (64:24) (65:14) (78:21) WORD INDEX DB-71 - EARL" Terry K. Lindquist; 6/9/95 easier (11:13) (53:22) east (1:22) economics (21:22) (26:18) education (13:17) . edward (69:15) effect (12:15) effects (60:15) eight (5:4) eighties (31:19) (31:21) either (30:17) (43:18) (47:21) (78:20) (83:20) electrohydraulic (20:16) electronic (18:10) else's (84:1) elsewhere (87:23) emmisions (87:10) employed (93:13) (93:16) employee (67:15) (93:15) employees (46:1) (83:20) employs (46:1) empty (59:11) , encapsulated (23:14) (23:16) (23:23) end (41:15) (78:20) (82:8) (83:2) engine (28:24) (29:9) (29:16) engineer (14:7) (68:3) engineering (11:15) (12:5) (12:8) (12:11) (12:11) (15:10) (17:1) (17:10) (17:24) (18:5) (18:10) (18:14) (18:18) (19:18) (19:18) (19:23) (47:3) (47:9) (50:5) (69:6) (84:4) engineers (12:10) (72:3) (85:15) (87:2) entail (85:21) entailed (12:5) entire (19:10) (39:17) (40:5) (72:19) entitled (50:23) (78:4) (80:8) equipment (22:16) (37:5) (37:7) (37:20) (48:5) (65:12) (79:5) eric (2:5) error (8:12) (8:15) esoteric (30:13) essence (82:1) essentially (6:1) (8:8) (19:1) (24:6) (25:12) (37:4) (39:20) (43:1) (47:15) (65:5) (67:7) (71:24) (73:21) established (77:14) estimate (15:4) (15:6) (26:10) (26:14) (33:21) estimation (67:19) ethical (71:19) exact (14:17) (15:3) (31:16) (62:2) (66:20) (75:14) exactly (27:23) (31:22) (60:21) (68:8) (70:2) examination (1:15) (3:7) (4:2) example (71:20) exams (69:7) exception (21:11) exchange (45:4) excluding (59:23) excuse (77:24) exhaust (91:8) exhibit (3:10) (3:11) (3:12) (3:13) (3:14) (3:15) (3:16) (3:17) (4:19) (8:8) (10:19) (10:20) (10:23) (50:22) (57:20) (57:21) (58:10) (58:11) (58:13) (59:16) (59^22) 1 (61:19) (73:4) (80:5) (88:1) (88:4) (88:4) exhibits (65:15) exist (72:24) existed (77:23) expect (15:3) experience (12:11) expert (52:2) (89:12) experts (89:2) (89:23) (90:17) expires (93:18) explain (85:4) exposure (81:20) (84:8) (84:17) (84:21) (87:6) (87:6) expressed (7:9) extent (7:18) (62:8) (66:23) (68:17) (72:23) (79:7) (79:22) ============== F=============== facilities (46:7) (49:24) (50:2) (50:7) (64:4) (69:3) (70:20) (70:22) (85:1) facility (17:14) (17:17) (17:21) (21:20) (22:4) (22:10) (24:16) (47:8) (47:17) (64:4) (64:12) (64:21) (65:5) fact (53:8) (55:7) (60:17) (62:3) (92:3) fiahrenheit (34:5) failed (39:19) fairly (24:13) (25:22) (25:24) falk (2:5) familiar (7:8) (25:7) (46:23) (55:4) (55:18) (74:17) (79:19) (91:22) familiarity (48:21) family (27:21) far (5:19) (6:17) (14:13) (25:18) (31:2) (41:13) (42:4) (60:14) (90:17) farm (37:20) feel (5:6) (5:8) (6:3) (6:9) (6:22) (7:3) (9:11) feet (15:4) (15:7) few (58:6) (63:6) (69:10) fiber (33:11) fiberglass (32:20) (86:13) fibers (85:22) field (52:2) (84:3) (90:11) fifth (2:2) filed (59:4) (59:14) (66:15) (92:3) final (10:18) finally (8:3) (42:16) finance (42:12) financial (42:23) financially (93:17) find (54:5) (57:12) (57:15) (68:17) (79:11) (85:20) (86:12) (90:18) fire (33:9) firm (80:16) first (5:2) (5:12) (6:1) (12:7) (13:7) (18:15) (18:22) (32:2) (33:1) (36:3) (43:10) (45:12) (50:21) (51:13) (54:10) (58:7) (65:18) (65:19) (67:18) (67:20) (71:16) (73:18) (79:13) (82:17) firsthand (49:22) five (36:1) (42:22) (44:5) (44:17) floor (2:5) (15:4) EASIER-FLOOR WORD INDEX In Re; Asbestos IV Terry K. Lindquist; 6/9/9 flow (14:10) focus (19:9) focusing (19:16) ford (49:19) (89:10) . form (34:16) (61:12) (74:17) (83:5) formed (34:11) (34:13) formerly (72:7) formulation (47:6) forth (30:4) forward (11:13) foster (88:23) found (85:21) four (24:17) (34:15) (34:18) (35:5) (35:7) (45:13) (52:7) four-wheel (20:14) fourth (1:18) (35:3) frame (29:22) (76:7) frames (43:18) franklin (52:21) frequently (19:11) friction (21:4) (23:11) (33:23) (56:6) (72:4) (85:20) (90:14) friday (1:17) front (2:11) (80:4) (80:19) (88:8) frill (4:8) (93:10) fuller (69:15) (88:13) (88:14) function (47:15) functional (33:2) functions (28:16) further (61:15) (91:11) (93:8) (93:12) (93:15) gannon (2:10) gathering (70:5) gatke (55:20) gave (84:14) gear (34:23) (35:18) gears (34:7) (35:18) general (6:21) (21:19) (28:23) (49:7) (49:17) (56:22) (60:10) (60:11) (60:18) (60:18) (61:8) (62:9) (62:17) (63:2) (71:5) (77:8) generally (5:11) (43:22) (43:24) (55:4) (84:4) generate (45:21) generated (33:20) (33:22) (87:10) genre (74:9) geographic (47:24) (48:17) germany (46:14) gets (92:12) given (61:4) (90:24) (93:11) (93:20) gives (59:24) giving (26:10) glance (51:9) glean (38:1) (40:22) goals (86:20) goldberg (1:18) (2:2) gone (48:11) (60:24) (90:17) good (15:5) (23:5) (33:2) gordon (2:5) government (18:11) governmental (21:21) grady (65:19) (65:20) (65:21) (65:24) (66:1) (66:15) (66:19) (66:24) (67:15) (68:22) (68:23) (69:13) (88:12) green (58:2) grid (81:10) (81:14) ground (79:21) grounds (61:16) (79:16) (81:17) (81:21) (92:8) group (19:21) (19:22) (19:24) (20:1) (20:10) (21:8) (21:10) (65:1) groups (86:23) guess (21:15) (23:5) (35:18) (53:13) (68:6) (76:18) hand (4:16) (58:5) (73:15) (93:20) happens (19:8) hard (80:12) harm (90:19) harms (79:10) hayes (63:15) hazard (60:4) hazardous (62:18) (62:22) hazards (56:13) (83:6) (87:5) (87:6) he's (5:10) (5:13) (62:9) (65:19) (66:9) (68:3) (68:7) (79:18) heading (11:1) headquarters (19:21) (70:1) health (60:15) heard (25:9) (69:24) (89:5) heat (24:9) (33:17) (33:19) heavier (17:5) (17:6) heavy (36:15) (36:18) heights (18:1) (29:2) (71:12) held (66:9) (68:11) (84:1) helen (73:9) her (9:13) (9:14) (9:17) hereby (93:4) hereof (93:7) hereto (93:17) hers (9:16) highway (36:18) (37:10) historical (46:15) (47:2) historically (42:11) history (32:4) (32:23) (34:8) (38:12) (43:6) (52:18) (66:24) (80:8) holding (64:18) honestly (80:18) horiszney (59:9) hornick (67:11) (67:13) (67:14) (69:12) (88:13) horrendous (26:19) hostler (1:18) hot (23:19) house (2:11) however (40:6) humidifier (81:10) (81:15) huntington (1:18) (2:8) hydraulic (14:6) hydraulics (42:16) (43:1) WORD INDEX FLOW-HYDRAULIC! Terry K. Lindquist; 6/9/95 In Re; Aabeat^, jy idea (12:2) (12:4) (14:3) 05:1) (15:15) (18:3) (18:20) (19:14) (19:14) (20:8) (20:21) (23:6) (23:6) (23:10) (31:20) (32:21) (33:24) (34:10) (36:17) (38:13) (41:10) (41:12) (43:17) (45:24) (50:16) (64:17) (65:23) (67:17) (68:5) (86:8) identification (3:10) (4:20) (10:21) (57:22) (73:5) (88:2) ignition (40:7) illinois (4:13) (8:21) (11:17) (13:3) (13:8) (14:21) (36:8) (36:11) (52:21) (64:5) (64:6) (64:8) imagine (17:18) (32:3) inc (1:22) incapsulated (23:3) include (37:6) (37:9) inconsistencies (62:7) inconsistency (61:13) (61:15) incorporated (41:22) incorporation (45:14) incorrect (73:21) , incorrectly (91:2) increased (26:20) independent (34:15) indicated (60:19) (77:4) indicative (18:7) individuals (88:7) (89:5) industrial (14:14) industry (17:20) (29:7) (34:14) inflation (26:20) information (11:9) (72:9) (72:10) (72:23) (79:24) (83:11) (84:6) (85:16) (86:1) (86:3) informed (10:11) (10:14) ingersoll (12:23) (13:1) (27:15) (27:20) (27:21) (38:18) (78:3) (79:1) initially (32:24) initiated (38:15) injuries (25:19) (25:21) inquiry (71:16) instead (88:13) institute (11:17) (85:19) (85:24) (86:4) insurance (7:23) (8:1) (84:20) (84:22) interaction (43:7) (43:9) interested (93:17) interface (21:21) international (46:5) interpretation (73:21) (79:15) interrogatories (10:7) (35:24) (36:14) (38:2) (41:1) (55:12) (57:11) (57:24) (58:14) (61:17) (61:24) (63:5) (66:13) (71:2) (72:16) (73:9) (74:6) (74:19) (74:22) (75:24) (78:7) (78:11) (78:13) (80:5) (80:10) (80:23) (83:13) (85:9) (87:21) (91:16) (91:23) interrogatory (58:14) (59:21) (59:23) (63:18) (71:23) (75:18) (79:15) (80:24) investigate (72:21) investigation (7:1) investigations (7:4) (7:11) invoices (54:4) involved (33:1) (38:9) (66:16) (66:23) (67:1) (67:2) (67:5) (79:3) (79:5) (84:7) (84:14) (84:20) involvement (92:1) irs (45:22) issues (7:24) italy (46:14) items (5:3) its (33:16) (41:16) (60:3) itself (23:24) (51:1) (53:23) iwakuni (8:16) ============== J =============== jack (69:23) (69:24) (71:4) (73:13) (74:21) (75.1) (80:8) (80:11) jackson (1:22) james (65:19) january (7:20) japan (8:16) (8:17) (46:13) jennings (1:18) (2:2) job (18:3) (70:2) john (88:24) (89:7) johnny (1:22) johns-manville (56:3) joint (35:2) joints (35:16) journal (77:21) journals (77:8) joyce (70:15) judge (58:4) july (58:4) (73:17) (75:5) (75:6) (77:14) june (1:17) (3:5) (93:21) junk (44:9) kanawha (1:1) keep (19:11) (25:3) (25:10) (25:12) (47:2) (47:3) (47:12) (47:16) (72:15) (86:17) keeping (6:21) (6:23) (46:19) (46:21) (47:15) keeps (33:14) kelsey (63:15) kept (15:9) (33:7) (47:9) (71:11) kinds (40:9) (66:8) knew (55:16) (67:14) knowing (74:7) knowledgable (60:24) knowledge (5:16) (6:4) (6:9) (6:15) (7:8) (7:10) (7:19) (7:22) (8:1) (8:3) (8:5) (9:6) (9:22) (10:13) (21:12) (30:22) (30:23) (32:4) (35:19) (38:5) (39:2) (40:21) (41:4) (44:11) (44:19) (46:18) (47:18) (47:23) (51:14) (52:23) (55:15) (56:13) (56:15) (60:13) (62:1) (62:8) (62:14) (62:21) (65:13) (66:19) (66:24) (67:18) (67:23) (68:1) (78:5) (83:3) (83:4) (83:8) (83:9) (84:22) (91:8) (92:6) knowledgeable (5:7) (7:4) (41:8) (66:7) (75:9) known (65:21) (65:24) (67:21) knows (5:21) korea (46:13) krebs (89:13) IDEA-KREBS WORD INDEX In Re: Asbestos IV Terry K. Lindquist; 6/9/95 label (7:16) (49:6) (49:17) (49:21) (60:19) (63:4) (75:13) labels (60:3) laboratories (15:7) lack (42:5) lady (70:15) large (26:7) (36:22) (37:4) (37:14) (37:20) (40:23) (48:6) last (6:13) (64:19) (64:20) (87:4) (87:19) (88:4) late (66:4) (86:7) later (91:6) law (71:11) lawsuit (84:13) lawsuits (84:7) (84:16) lay (11:1) (65:19) (67:10) layman's (24:13) learned (13:8) (20:12) learning (12:17) least (66:11) leave (91:19) left (75:15) (75:16) length (26:2) less (67:14) levels (69:4) libraries (78:15) library (15:13) (15:14) (15:16) (15:21) (15:23) (16:1) (77:1) (77:2) (77:3) (77:5) (77:8) (77:10) (77:14) (78:23) (79:1) (79:9) (80:1) lifespan (87:16) limit (8:4) (8:6) limited (48:16) lindquist (1:15) (3:3) (4:1) (4:8) (5:15) (11:7) (59:19) (61:22) (92:11) (92:13) (93:5) line (6:13) (35:6) (38:13) (39:17) (41:3) (67:2) (67:8) (68:24) (72:19) lines (35:4) (47:10) list (10:18) (10:24) (55:11) (55:17) (61:3) (65:15) (65:16) (67:11) (88:5) (88:7) (89:21) listed (7:20) (51:11) (51:19) (52:10) (52:13) (53:8) (53:16) (59:9) (65:19) (67:10) (88:7) (88:13) (88:19) (89:2) (89:6) (89:23) (89:24) (90:6) (90:12) listing (53:15) lists (71:4) (72:2) (88:12) literature (16:3) (33:19) (87:14) litigation (10:12) (10:15) (19:9) (84:20) little (12:11) (26:3) located (13:2) (13:3) locations (19:2) lombard (30:14) long (24:19) (65:23) (86:2) long-term (26:8) longer (14:8) (77:15) look (4:22) (19:10) (34:8) (47:5) (51:10) (54:8) (58:19) (74:11) (74:14) (82:14) looked (45:13) (91:15) looks (52:9) loss (88:20) lubrication (90:14) lung (69:8) (83:21) magazine (77:20) magazines (15:24) (16:4) (78:4) main (30:16) (33:16) (55:6) mainly (16:3) (91:17) maintains (77:15) major (28:15) (37:14) (52:6) majority (27:5) (56:17) make (23:15) (24:7) (24:8) (30:3) (31:12) (35:6) (35:16) (43:11) (49:20) (53:22) (63:24) (71:15) (81:9) (88:22) maker (25:9) makers (51:18) makes (54:19) management (12:5) (12:8) (12:8) (12:12) manager (16:16) (16:20) (17:10) (17:10) (21:19) (28:23) (69:20) managers (70:22) manner (74:15) manual (13:14) (19:5) (20:14) (21:6) (22:5) (31:3) (31:4) (32:6) (32:11) (39:1) manufacture (22:13) (35:11) manufactured (11:10) (22:20) (27:4) (29:6) (29:17) (40:12) manufacturer (48:4) (51:23) (56:19) manufacturers (22:17) (37:20) (40:14) (48:5) (48:10) (51:10) (52:6) (77:22) manufacturing (17:14) (17:17) (21:20) (35:12) (64:3) (64:12) mark (10:18) (57:20) (89:19) marked (4:19) (8:8) (10:20) (50:22) (57:18) (57:21) (73:4) (80:5) (88:1) market (32:1) (32:9) (37:14) (38:4) (48:19) marketed (28:13) marketing (6:8) (6:11) (28:10) (66:16) marks (4:17) marsteller (2:8) marvel (35:3) (35:17) masters (11:21) mastics (33:8) material (21:4) (23:11) (33:3) (33:17) (82:3) (83:4) (85:20) materials (15:9) (23:17) (54:21) (79:1) (79:9) (86:13) (86:15) (86:17) (90:20) matter (5:8) (8:22) (55:7) (91:13) maximum (33:22) (34:3) mba (11:18) (12:13) mccallum (88:24) mccloskey (70:13) mccullum (88:24) mead (88:24) mean (22:21) (24:7) (26:2) meaning (21:16) means (36:18) measurements (69:4) WORD INDEX LABEL - MEASUREMENTS Terry K. Lindquist; 6/9/95 In Re: Asbestos ry mechanical (11:15) (13:9) (38:9) (64:14) (72:3) (85:14) (87:2) mechanics (35:1) (35:17) mechanism (17:3) media (2:11) medical (50:8) (69:7) medium (47:22) meet (86:20) meeting (10:1) (85:18) (86:6) (86:9) (86:18) meetings (72:8) (72:22) member (72:1) (85:11) (85:12) (85:17) (86:24) membership (72:11) memoranda (72:24) memory (64:18) (66:18) memos (86:18) mention (56:12) (57:15) (72:21) mentioned (8:12) (13:21) (14:1) (14:12) (21:12) (23:13) (23:22) (31:24) (37:22) (42:22) (46:4) (55:19) (57:12) (61:20) (64:11) (65:16) (72:12) (77:6) (81:2) (81:3) , mentions (52:20) (66:14) (71:10) merge (24:10) met (67:18) (69:11) (69:14) (70:3) (70:4) (70:7) metals (72:2) (85:14) (87:1) methods (39:24) mexico (46:13) michael (80:19) michigan (19:19) (19:20) (28:9) (58:2) (73:10) (76:18) (80:7) (88:9) (91:17) microfilmed (47:21) mid (31:18) (31:21) mid-eighties (43:20) (44:7) might (41:7) (70:18) mind (43:5) (55:8) (83:1) (91:5) mineralogy (13:19) minor (6:12) (8:14) (55:13) minutes (46:16) misstate (60:7) mistake (52:24) misunderstanding (24:5) models (51:24) moment (73:24) monique (1:16) (93:2) (93:23) months (12:14) (12:19) (14:5) (38:7) more (20:2) (20:3) (21:20) (26:3) (31:20) (32:5) (34:6) (41:7) (48:5) (52:2) (53:4) (61:7) (64:15) (79:4) (85:23) most (5:7) (5:15) (5:16) (16:5) (60:23) (66:6) (67:23) (76:8) (91:8) motor (89:11) motors (49:8) (49:17) (60:10) (60:11) (60:18) (60:18) (61:8) (62:17) (63:2) moved (17:12) (66:3) msds (82:4) (82:6) (82:18) (82:22) (83:9) msdss (82:7) multi-floor (14:23) multiple (51:24) municipalities (42:14) (42:24) name (4:4) (4:6) (4:8) (4:9) (4:12) (9:10) (9:13) (27:19) (35:21) (38:16) (41:16) (49:20) (56:1) (56:4) (65:9) (69:14) (69:16) (70:1) (70:10) (70:15) (80:16) (89:11) named (10:12) (11:4) (11:7) names (34:18) (35:20) (70:23) (83:12) napa (39:21) national (56:6) (72:5) (85:15) (86:24) nationwide (48:16) (76:12) (76:15) (76:19) nature (16:1) necessarily (53:6) neither (59:10) (83:3) (93:12) never (19:10) (33:21) (58:9) (58:20) (60:14) (82:18) (85:17) (85:22) new (14:6) (28:19) (45:3) next (6:13) (10:19) (17:9) (17:23) (21:13) (28:22) (39:9) (53:14) (57:20) (72:6) (73:8) (81:24) (82:23) nine (17:9) (18:8) nor (59:10) (59:11) (76:7) (83:3) (93:13) normal (83:24) nos (4:19) (73:4) notarized (73:13) notary (1:17) (93:2) (93:24) note (78:16) (80:14) noted (58:11) (59:4) notes (72:24) (77:13) (86:17) (87:18) (93:9) notice (1:15) (4:17) (4:23) (10:2) (10:24) (58:23) number (14:17) (26:7) (34:5) (50:19) (51:2) (54:3) (54:20) (55:10) (58:14) (60:24) (61:16) (89:2) (91:15) numbered (5:9) numbering (61:18) numbers (26:21) oath (9:20) object (61:15) (62:5) (74:4) (74:15) (79:16) (79:21) (81:16) (91:7) objecting (72:18) (92:8) objection (26:1) (61:11) (72:17) (75:23) (79:13) (82:10) objections (59:24) (75:20) (78:10) observation (59:12) (59:15) occupational (69:8) (83:21) oem (22:16) (26:13) (36:20) (37:11) oems (49:11) off (33:7) (33:14) (43:22) (44:5) off- (36:17) off-highway (36:15) (37:1) (37:4) offer (59:12) offering (59:15) office (53:21) (80:20) offices (1:17) (15:7) (57:5) often (19:8) (32:5) Ohio (57:7) Oklahoma (40:19) old (4:14) (4:15) (68:5) older (68:8) ologies (90:15) on-highway (37:1) (37:13) MECHANICAL - ON-HIGHWAY WORD INDEX In Re: Asbestos IV Terry K. Lindquist; 6/9/95 on-sight (47:17) one-way (13:9) (20:12) (38:9) (38:22) (64:14) open (85:20) operating (28:18) (47:12) (47:16) operation (24:20) (24:20) (24:22) (28:5) (33:20) (34:2) operations (41:9) (52:16) (62:14) (66:5) (68:18) (87:11) opportunity (64:10) (74:14) (91:4) opposed (14:13) (16:8) (22:22) (26:12) (31:9) (33:13) (37:1) (71:18) (78:12) oral (1:15) order (25:10) (57:20) organizations (72:1) (72:11) (85:10) (85:13) original (22:16) (39:19) (48:5) (65:12) osha (83:5) others (33:9) otto (89:15) (89:24) our (7:16) (21:5) (28:17) (44:9) (53:21) (60:12) (60:20) (92:1) outside (21:5) (22:12) (36:12) (65:12) (76:16) over (26:17) (32:9) (34:5) (61:1) (74:13) oversee (18:17) oversight (20:6) (28:16) (68:12) overview (6:2) (6:17) (18:17) own (9:17) (40:12) (65:9) (65:10) oxford (2:5) pads (63:15) page (3:7) (8:15) (11:1) (11:20) (53:1) (58:14) (59:4) (59:8) (63:7) (63:8) (64:1) (66:14) (71:1) (71:22) (72:6) (73:19) (75:17) (76:23) (78:6) (78:7) (80:24) (81:7) (81:22) (81:24) (88:19) (89:3) pages (58:12) (61:18) (74:13) paper (87:9) papers (52:14) paragraphs (5:9) parent (41:19) park (52:21) parker (58:1) part (5:12) (5:19) (14:19) (19:12) (22:12) (32:14) (33:6) (36:20) (41:8) (43:14) (43:15) (44:18) (50:3) (52:24) (59:23) (65:1) (65:22) (79:18) (79:20) participate (10:6) participated (61:23) particular (13:9) (14:4) (47:4) (62:15) (74:19) (77:11) (79:3) (81:20) (83:6) particularly (21:21) (48:5) (51:17) (63:9) (81:1) parties (93:14) (93:16) parts (15:8) (30:7) (30:17) (30:19) (30:20) (31:2) (39:9) (39:12) (39:18) (39:19) (39:20) (39:21) (40:1) (40:3) (40:6) (40:9) (40:11) (40:12) (40:19) (40:23) (41:5) (41:6) (41:11) (48:1) (48:11) (48:14) (48:16) (48:21) (48:24) (50:12) (50:15) (50:20) (52:21) (53:9) (56:23) (57:2) (67:3) (84:9) pay (44:13) Pennsylvania (2:3) (2:6) (2:11) (57:7) people (33:5) (33:5) (33:10) (46:3) (65:16) (69:10) (69:11) (75:9) (77:22) (79:6) (88:20) (89:3) percent (27:3) percentage (26:11) (26:20) period (8:15) (26:19) (34:13) (43:20) (64:16) (65:4) (65:6) (66:4) (79:12) periods (27:22) persky (1:18) (2:2) person (5:7) (5:15) (7:13) (10:16) (52:15) (60:23) (67:10) (69:14) (70:18) (88:22) personal (6:15) (92:6) personally (9:11) (91:22) persons (50:2) photographic (64:18) pietragallo (2:5) piping (14:14) Pittsburgh (2:2) (2:5) place (47:1) (47:11) (59:18) (93:6) placed (60:2) (60:9) (61:8) (61:9) plaines (13:3) (14:21) plains (27:10) plaintiff (80:17) plaintiffs (2:3) (4:5) (80:20) plant (24:19) (25:22) (26:7) (27:6) (70:22) (81:20) plants (50:8) (69:4) plate (23:15) platen (23:19) (25:3) please (4:6) (31:1) (75:18) (85:4) point (5:21) (6:12) (7:15) (11:20) (14:18) (15:12) (17:6) (23:2) (23:5) (24:14) (28:15) (34:8) (41:1) (42:7) (55:9) (60:13) (75:5) (77:18) (82:12) (85:19) (91:1) (91:10) pointed (78:14) pointing (57:16) points (5:22) (40:7) (62:10) policy (46:20) (46:22) porter (54:11) (54:15) (54:16) (54:17) (55:8) (56:12) posed (74:16) (74:18) (87:20) position (5:14) (13:5) (17:23) (19:17) (20:7) (28:22) (29:23) (29:24) (71:17) (74:24) (76:9) positions (12:2) (66:9) (66:11) (68:10) (83:24) potential (56:13) (90:19) powder (25:12) practices (7:17) predates (92:1) preparation (10:7) (61:24) prepare (9:23) (10:4) prepared (82:3) (82:6) (82:8) (82:11) (82:12) (82:21) (83:3) present (5:17) presently (4:10) (4:11) president (21:19) (28:23) press (23:14) (25:11) pressing (23:4) (25:3) pressure (14:10) (24:9) pretty (57:3) (68:23) previous (18:6) (18:8) primarily (48:3) primary (13:13) WORD INDEX ON-SIGHT - PRIMARY Terry K. Lindquist; 6/9/95 Ig_Re: Asbesto, ry prior (38:18) (56:17) private (44:12) (44:15) (45:2) (45:5) probably (57:18) (58:11) (63:22) (64:20) (65:6) (66:10) (68:19) (68:22) (70:4) (83:14) problem (60:14) problems (25:18) (25:21) (49:15) procedure (1:16) proceedings (93:8) (93:14) process (33:23) processes(62:2) produce (35:10) produced (5:17) (6:13) (22:19) (53:11) (53:23) (60:9) producing (26:24) (60:17) product (19:9) (19:13) (19:16) (21:3) (23:1) (23:20) (32:13) (33:7) (35:4) (35:6) (35:11) (38:8) (38:13) (41:3) (44:22) (47:5) (47:10) (54:14) (56:5) (81:12) production (26:8) (26:14) (26:23) (30:17) (47:17) (49:24) (50:1) (69:3) productions (10:8) products (6:3) (6:8) (6:11) (6:19) (7:2) (7:5) (7:7) (7:10) (7:14) (7:15) (9:1) (11:9) (12:17) (13:14) (14:12) (14:13) (14:14) (15:11) (17:21) (17:22) (18:19) (18:21) (18:24) (19:1) (19:14) (20:3) (20:3) (20:8) (20:18) (20:21) (21:8) (21:24) (22:3) (22:21) (26:11) (27:5) (28:13) (29:11) (29:14) (29:15) (29:18) (31:1) (31:8) (31:12) (33:5) (35:11) (36:3) (36:9) (41:14) (42:4) (44:16) (49:4) (49:10) (49:15) (56:6) (56:18) (60:3) (60:12) (60:17) (62:17) (63:1) (63:3) (66:17) (67:6) (74:8) (74:9) (75:10) (81:8) (83:6) professional (16:5) (16:9) program (12:9) (12:14) (16:15) (20:13) (43:10) (68:15) (85:20) project (14:7) (16:16) (16:20) (16:21) (16:22) (16:23) (16:24) (18:9) (38:11) proper (4:9) provide (7:13) (33:17) provided (8:7) (40:18) (50:19) public (1:17) (41:22) (45:1) (45:3) (45:8) (45:10) (45:20) (56:23) (93:2) (93:24) publication (51:1) (77:19) publications (16:6) (16:9) (16:9) (16:12) (86:22) pulled (61:16) pump (17:8) pumps (17:7) (42:14) (42:24) (43:12) purchase (22:11) (54:15) (54:17) purchased (21:5) (22:17) (23:17) (40:13) (40:23) (54:6) purchaser (62:20) purported (75:24) purports (61:17) purpose (45:18) pursuant (1:15) (1:16) putting (62:16) = = = = = = = = = = = = = = Q == = = =.................. = = = = = qualified (62:10) (93:4) quality (50:4) question (5:13) (5:20) (15:12) (23:9) (58:16) (61:12) (61:19) (62:3) (62:6) (63:8) (63:8) (63:19) (63:21) (66:10) (71:2) (71:24) (73:20) (74:1) (74:5) (74:12) (74:16) (74:18) (75:4) (78:1) (78:8) (78:8) (78:13) (78:14) (79:16) (81:7) (81:8) (81:23) (82:1) (82:11) (82:15) (82:16) (82:20) (82:23) (82:24) (85:12) (87:4) (87:8) (87:20) questioning (72:19) questions (6:5) (6:10) (6:22) (58:6) (58:16) (58:18) (58:21) (59:19) (63:6) (65:17) (74:7) (74:10) (74:12) (75:23) (76:7) (76:24) (77:11) (81:19) (88:6) (88:18) (89:22) (90:23) (91:11) quite (5:20) rabinovitz (90:3) range (19:14) (40:5) rather (82:15) (91:6) raw (22:24) (25:10) raybestos (55:8) raymark (55:8) (55:19) (56:12) read (10:1) (10:3) (15:10) (58:15) (73:24) (75:18) (78:9) (80:12) (81:23) (82:15) (87:9) (92:10) reading (34:12) (53:18) (61:3) (62:13) (62:13) really (25:15) (31:22) (34:20) (35:9) (48:18) (49:12) (50:12) (50:16) (52:23) (63:16) (67:20) (79:24) (86:10) (86:10) reason (25:6) (40:24) (44:4) (44:6) reasons (33:16) (92:7) recall (13:22) (13:24) (14:17) (15:17) (16:2) (16:13) (16:14) (33:16) (34:4) (34:12) (39:13) (52:6) (55:6) (66:12) (67:20) (77:4) (85:18) (86:14) received (11:14) (82:11) (82:21) (83:3) recited (19:4) recollection (55:16) (57:13) (64:18) (66:2) record (4:7) (5:11) (6:21) (6:23) (46:19) (46:21) (46:22) (47:15) (57:14) (58:23) (59:14) (59:19) (72:17) (73:12) (73:16) (74:4) (88:5) (91:5) (91:8) (91:14) (91:21) (91:23) (92:5) (93:11) records (47:9) (47:13) (86:18) redundant (50:23) reference (47:2) referenced (58:13) (59:22) reflect (91:23) refractories (58:2) regard (12:22) (71:6) (75:1) (87:19) (91:20) regarding (7:20) (40:18) (57:11) (84:8) (84:16) (84:20) regards (7:13) (9:20) (80:24) region (57:6) (57:9) regular (64:22) regularly (64:23) regulatory (69:20) related (93:13) relating (46:16) (72:24) (82:9) (83:20) relation (6:18) relationship (68:13) (70:6) relative (93:15) relatively (64:22) (64:23) releasing (71:17) remain (59:11) PRIOR - REMAIN WORD INDEX In Re: Asbestos TV Terry K. Lindquist; 6/9/95 remaining (78:22) remember (14:4) (77:5) (77:5) remembering (78:11) remove (85:6) renew (75:20) repairs (39:22) replaced (32:13) replacement (32:16) (32:20) (39:19) reported (29:8) (70:21) reporter (1:17) (4:17) (9:11) (10:18) (57:19) (71:18) (93:3) reporter's (9:12) (71:20) reporting (68:13) (70:5) reports (45:21) (45:22) (90:16) (90:18) represent (4:4) (9:16) (76:20) representation (59:13) (76:6) request (9:5) (49:20) (60:10) (61:8) (62:18) (62:20) (63:2) (71:14) (73:3) requested (49:16) (75:12) requesting (9:9) .. requests (10:8) required (25:13) (45:20) requirement (18:12) (61:10) requirements (7:18) (15:11) (60:4) resales (65:12) research (12:15) (12:22) (13:1) (14:2) (14:8) (14:16) (15:8) (19:18) (19:23) (27:10) (27:15) (28:4) (38:18) (38:19) (68:14) (68:16) (72:8) (78:3) (78:17) (79:1) (79:4) (84:4) researchers (12:16) resell (40:13) reside (4:10) (4:11) residue (87:16) resistance (33:18) resistant (33:10) resold (65:9) respect (6:2) respiratory (25:19) (25:20) respond (73:3) response (61:9) (62:16) (62:18) (62:19) (81:10) (82:5) (82:22) responses (10:7) responsibilities (12:3) (18:4) responsibility (20:7) (36:12) (36:20) (47:12) (70:19) (84:2) (84:3) rest (18:16) (58:19) (80:21) restricted (48:2) resume (8:9) retardant (33:10) retention (46:22) returned (27:9) review (63:18) reviews (92:12) richard (69:17) (72:7) (72:21) (77:13) (88:10) rid (43:18) ring (69:16) robert (58:5) (67:11) rockford (36:7) (36:8) (36:11) (36:11) (37:19) role (91:22) (92:7) room (15:18) (16:2) (77:6) rosenberg (69:17) (72:7) (72:22) (77:14) (77:16) roy (2:8) (12:23) (12:24) (27:20) (27-21) (27:21) rubber (23:17) (23:20) (23:24) (24:4) (25:10) rule (60:5) (62:19) (62:22) rules (1:16) run (78:4) russe (56:8) safety (69:21) (70:19) (70:21) (72:5) (82:3) (83:4) (85:15) (86:24) sale (54:14) (66:16) sales (6:7) (6:10) (6:15) (6:17) (17:9) (18:9) (41:18) (48:1) (53:12) (56:17) (57:5) (66:12) (66:22) sample (85:5) sampling (50:3) saw (53:15) saying (19:12) (77:9) (90:18) says (11:9) (11:14) (72:6) (80:19) scope (18:20) (18:24) (19:10) (48:17) (51:5) (76:18) scott (70:8) seal (93:20) second (5:19) (6:7) (8:15) (13:10) (13:15) (28:19) (36:7) (58:20) (63:17) (67:10) secondly (61:22) (71:16) (79:17) section (37:11) (82:13) sections (53:17) sectors (37:13) seem (66:18) seems (80:7) segment (22:13) (32:8) selected (32:24) solenoid (20:16) self-contained (14:20) seU (9:17) (43:22) (44:5) (63:2) selling (22:22) (37:20) (48:9) semi (37:10) send (92:11) sense (54:19) (59:13) (62:6) (74:5) (81:17) separate (48:24) September (71:6) serling's (80:19) service (80:15) services (42:12) (42:23) set (54:4) (57:15) (58:20) (59:1) (59:3) (61:17) (61:20) (72:15) (73:8) (73:8) (74:6) (74:19) (80:4) (80:23) (83:10) (87:20) sets (91:15) seventies (38:3) (52:17) (65:7) (86:7) several (33:15) shape (23:4) (23:18) shaped (23:18) sheet (82:4) (83:5) sheldon (90:3) shelves (15:24) (16:3) WORD INDEX REMAINING SHELVES Terry K Lindquist; 6/9/95 jn Re: Asbestos tv | shipment (60:18) shipments (60:9) shipped (22:1) (22:16) (22:23) (26:12) (26:16) (26:24) (49:7) (49:10) (62:17) (75:10) , shipping (49:7) (49:17) shoe (55:24) shorter (18:17) should (76:2) show (26:1) (51:19) (61:11) (78:7) (79:13) (82:10) showed (53:12) showing (10:23) (61:19) shown (60:14) (61:20) (72:17) side (12:16) (12:16) (13:11) (14:9) (14:9) sign (92:10) signal (2:6) signature (59:10) signed (9:19) (58:24) (59:1) (59:3) (59:6) (59:10) (59:17) (61:21) (72:18) (73:13) (73:23) (75:5) (76:2) (80:11) (88:9) signing (59:6) . similar (22:7) (89:22) simply (24:8) (31:2) (33:7) (40:13) (59:15) (61:7) (61:18) (62:19) (75:20) (76:24) (81:8) single (16:20) (16:22) (19:13) (24:11) (35:10) single-floor (14:22) (14:24) sitting (53:14) (74:5) situated (52:16) six (12:14) (14:5) sixties (66:4) size (77:6) skipped (7:23) small (19:12) (19:16) (77:14) society (72:2) (85:13) (87:1) sold (6:14) (22:19) (29:11) (29:17) (29:18) (39:18) (42:14) (42:15) (43:18) (44:13) (54:5) (63:12) (63:15) (78:23) solid (24:11) somers (87:9) sometime (38:2) (45:7) somewhat (78:18) (80:12) somewhere (27:18) (31:16) (31:17) (31:18) (66:4) son (27:22) sorry (31:16) (48:18) sort (67:8) (82:23) sounds (23:23) source (22:13) (68:20) south (13:11) (46:13) space (15:4) specific (26:4) (29:21) (31:21) (62:20) (74:8) (74:8) (74:9) (81:19) specifically (12:10) (86:12) specified (93:7) speculation (79:17) (79:20) speed (17:2) (17:8) (43:11) spend (15:21) spent (16:18) (38:6) spiral (24:8) sprayed (33:8) spring (13:7) (38:20) (67-16) (75:16) springs (38:15) square (15:4) (15:7) stability (26:6) stable (25:23) (25:24) (26:2) stack (53:13) stamp (59:5) stamped (58:3) (59:3) standard (59:24) start (11:13) started (31:15) (31:15) starting (12:2) starts (63:8) state (1:17) (4:6) (5:11) (51:13) (58:2) (73:10) (74:4) (76:5) (77:23) (91:17) (92:2) (93:1) (93:3) stated (60:6) (63:11) (75:21) (77:15) (81:21) (82:20) statement (45:17) (61:2) (66:20) (91:21) statements (9:20) states (22:1) (22:17) (22:18) (22:23) (26:13) (26:21) (27:1) (27:9) (46:8) (46:12) (48:2) (51:17) (51:23) (60:1) (60:2) (76:21) (77:18) (78:22) stating (74:20) steam (81:10) (81:14) stenotype (93:9) steps (7:12) sterling (18:1) (29:2) (71:12) sticking (25:4) (25:11) (25:12) still (22:10) (28:4) (43:13) (43:15) (48:20) (71:16) stint (21:13) stipulate (11:6) stock (45:4) stockholders (45:21) stopped (13:4) stops (12:14) (12:19) storage (47:22) stores (56:23) street (1:22) (2:11) stretched (74:12) strictly (41:17) study (87:14) (90:13) subcommittee (72:4) subject (5:8) (8:22) subparts (36:1) subsequent (43:12) subsidiaries (41:13) subsidiary (82:3) suburb (4:11) (4:12) (64:8) such (9:8) (16:10) (19:12) (20:15) (21:22) (47:11) (49:19) (56:12) (68:13) sued (79:8) sufficient (6:4) (6:10) suggest (73:2) suite (1:18) (2:8) summarize (73:20) (76:24) (83:1) supplied (40:1) (54:21) (56:5) supplier (56:2) SHIPMENT - SUPPLIER WORD INDEX In Re; Asbestos IV Terry K. Lindquist; 6/9/95 suppliers (55:1) (55:5) (55:7) (55:11) (55:12) (55:14) (55:18) (56:11) sure (5:13) (23:8) (27:23) (30:3) (34:3) (57:17) (63:24) (64:13) (64:15) (65:6) (74:2) (88:22) switch (34:7) switching (30:4) sworn (4:1) systems (18:10) (29:1) (29:6) (30:14) (42:15) (43:1) tabbed (54:9) table (53:21) tailored (74:7) taken (1:15) (7:13) (9:2) (44:14) (72:24) (93:6) (93:9) taking (74:24) (76:9) talc (25:12) talk (25:9) talked (33:4) (35:21) (43:10) (69:12) talking (31:2) (32:4) (42:20) (85:10) (87:5) talks (6:1) target (44:7) . tasks (18:13) (18:15) taxing (34:20) technical (72:5) technically (5:13) technologies (28:17) technology (11:18) (28:10) telling (5:21) temperature (33:22) temperatures (34:1) tend (19:9) tenure (28:7) terminating (43:21) terms (26:10) (34:1) (51:11) terry (1:15) (3:3) (4:1) (4:8) (4:9) (92:13) (93:5) testified (61:23) (77:10) testify (5:8) (7:18) (62:10) testimony (56:17) (60:6) (60:7) (60:16) (93:11) thank (91:11) thayer (58:1) (66:13) (71:1) (78:6) (80:3) (80:19) (88:9) themselves (44:12) therefor (30:19) therefore (7:10) (18:13) (82:18) therein (7:21) third (2:8) (13:16) (35:1) thirty-eighth (2:5) thomas (70:10) thought (62:2) three (9:3) (12:14) (12:19) (13:13) (29:20) (38:6) (58:11) (90:15) three-month (64:16) threshold (8:4) (8:5) thus (31:2) tiles (85:6) times (65:3) timothy (2:10) tire (25:9) tires (25:8) title (66:21) titled (59:16) to-wit (93:1) today (4:14) (5:18) (9:24) (10:1) (10:16) (28:5) (41:13) (53:14) (74:5) (76:12) (84:10) (84:14) (91:9) (91:16) (91:19) (92:5) together (24:6) (34:16) (35:6) (35:13) (53:21) took (21:13) torque (13:15) (19:6) (29:1) (29:6) (29:7) (29:12) (30:7) (30:9) total (26:21) (74:12) toward (74:7) tractor (37:10) tractors (36:23) (37:8) trade (16:9) (21:23) (77:8) (77:21) traditional (47:24) traditionally (38:14) train (72:4) trainee (12:5) (12:8) training (12:9) (20:13) (68:2) transcribe (9:17) transcribed (9:7) (9:9) (93:10) transcript (9:5) transcripts (9:17) transfer (20:14) transition (31:15) (31:18) transmission (13:14) (13:15) (17:4) (19:5) (19:6) (21:6) (22:5) (28:20) (28:21) (28:24) (29:9) (29:16) (30:11) (30:14) (30:18) (30:21) (31:3) (67:8) (68:24) (72:4) transmissions (20:12) (20:15) (29:20) (30:8) (30:17) (31:5) (32:5) (32:6) (32:11) (38:10) (38:18) (38:20) (38:22) (38:23) (39:1) transportation (42:6) trial (11:5) (11:8) tribology (90:12) (90:13) (90:15) tried (87:14) troy (19:19) (19:20) truck (14:13) (14:15) (37:2) trucks (52:10) (52:13) true (35:19) (48:13) (56:21) (56:24) (68:1) (69:1) (93:11) truth (81:15) turn (81:7) (81:22) two (12:19) (12:20) (13:4) (16:18) (22:15) (27:13) (28:1) (28:15) (30:6) (31:4) (44:8) (45:11) (55:6) (55:7) (55:14) (55:16) (58:11) (65:15) (79:15) types (12:17) (19:1) (20:3) (22:15) (29:20) (31:4) typical (40:9) typographical (8:15) ============== u============== umbrella (35:13) unaware (57:3) under (8:15) (9:20) (11:1) (35:13) (37:10) (53:8) (65:9) (76:9) (88:12) (93:20) understand (35:14) (37:3) (47:14) (48:8) (53:20) (56:16) (76:4) (83:12) (91:18) WORD INDEX SUPPLIERS - UNDERSTAND Terry K. Lindquist; 6/9/95 In Re; Asbestna jy understanding (30:24) (77:7) unfamiliar (74:6) unfortunately (79:6) unit (29:8) (40:19) (40:23) (41:5) (41:6) (41:11) (44:20) (44:21) (47:12) (47:16) (48:15) (50:12) (50:15) (82:19) united (22:1) (22:17) (22:18) (22:23) (26:13) (26:21) (27:1) (27:9) (46:8) (46:12) (48:2) (51:17) (51:23) units (28:18) (42:8) (42:10) (42:21) (42:22) (43:3) (43:13) (44:5) (44:17) universal (35:2) (35:16) university (11:18) until (72:17) upon (1:15) (18:11) usage (74:8) use (17:1) (26:13) (27:6) (33:10) (60:12) useless (63:22) uses (31:5) (31:6) using (44:9) ============== V ============= vague (15:11) valid (92:4) value (8:4) (8:6) valve (14:6) valves (20:16) variable (17:2) (28:21) (43:11) various (28:16) varying (17:8) vast (56:17) vehicle (37:4) (37:14) (87:10) vehicles (36:15) (36:18) (36:23) (51:24) (56:20) vendor (22:18) verified (59:11) versus (58:1) (71:7) (73:10) (80:9) very (33:2) (44:6) (48:9) (71:23) (79:19) (91:11) vice-president (17:24) (18:4) (18:14) (19:17) (19:19) (19:23) (28:10) (30:12) (65:2) (66:15) vice-versa (31:9) victor (70:13) view (24:14) Virginia (1:1) (1:16) (1:17) (1:18) (1:22) (2:8) (6:14) (6:16) (57:6) (57:9) (76:5) (92:2) (93:1) virtually (51:22) visit (64:24) (65:5) (69:2) visited (64:21) (65:3) ============== W ============= wales (46:14) wall (33:8) (33:14) (85:7) wanted (8:13) (30:3) (53:18) (60:19) (63:24) (68:17) (79:10) war (27:23) (27:24) Warner (34:23) (34:24) (35:18) warning (49:3) (49:21) (57:11) (60:2) (60:8) (60:9) (62:14) (62:16) (75:13) warnings (7:13) (61:1) (61:7) (61:9) (62:9) (73:22) (75:9) wayne (58:3) (73:11) (80:6) (80:8) wear (90:14) webb (73:9) (78:13) week (40:18) (53:12) (64-20) weekly (16:10) weeks (9:3) (84:15) wentz (59:6) (59:6) (69:23) (69:24) (70:3) (71:4) (73:14) (73:23) (74:21) (75:1) (80:11) (91:20) (92:3) west (1:1) (1:16) (1:17) (1:18) (2:8) (2:11) (6:14) (6:16) (57:6) (57:8) (76:5) (92:2) (93:1) western (64:8) wet (17:2) (31:5) (31:9) (38:21) whatever (43:19) (56:23) wherever (48.11) whether (5:6) (49:12) (49:22) (50:6) (54:5) (61:7) (61:9) (63:14) (74:7) (81:19) (82:19) (82:20) (84:19) (84:24) (87:8) (87:15) white (1:18) (2:2) whole (18:14) wick (89:19) william (89:13) Williamson (2:11) winfield (4:12) withdrawn (18:12) without (32:10) (53:2) (85:20) witness (10:12) (10:14) (10:18) (10:24) (11:4) (11:8) (65:15) (65:16) (65:19) (67:11) (88:5) (88:7) (89:21) (93:11) witnesses (11:1) (88:12) (88:18) (88:21) wolowicz (70:11) wong (89:15) (90:1) (90:2) word (42:6) words (74:9) work (28:9) (47:7) (64:14) (67:24) (69:2) (71:20) (77:20) worked (12:16) (50:1) (68:10) (70:20) (85:1) (85:3) workers (26:8) (69:8) workers' (83:18) workforce (25:18) (25:22) (26:7) working (11:21) (11:22) (14:2) (14:7) (14:9) (20:4) (20:4) (20:19) (22:24) (38:11) (70:5) workplace (7:17) (83:7) works (47:6) world (27:24) worldwide (41:17) wouldn't (45:17) (63:14) writers (44:8) writing (73:3) wrong (31:1) (52:9) (52:12) (90:6) yarn (23:3) (23:14) (23:16) (23:22) (23:24) (25:1) (25:2) (25:2) year (41:18) years (4:15) (16:18) (17:9) (18:8) (18:22) (24:17) (24:23) (27:13) (27:23) (28:2) (32:20) (33:15) (39:13) (45:11) york (44:20) (44:21) (45:4) (81:2) (81:4) (82:19) (83:14) (83:16) yourself (9:23) (10:4) (82:15) UNDERSTANDING - YOURSELF WORD INDEX