Document rBexayGO12Xz1OnL5jNjKDVDv

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES DEPARTMENT NO. 56 HON. JANE L. JOHNSON, DENNIS H. WOODARD, ET AL. ) ) PLAINTIFFS, ) ) VS ) NO. BC 387774 ALFA LAVAL, INC. ET AL ) ) DEFENDANTS. ) ) ) JUDGE REPORTER'S TRANSCRIPT OF PROCEEDINGS TUESDAY, JANUARY 13, 2009 (APPEARANCES ON NEXT PAGE.) VOLUME 1 PAGES 1 THROUGH 168 DANA L. SHELLEY, RPR, CSR #10177 OFFICIAL REPORTER APPEARANCES (CONT'D.): FOR DEFENDANT SEPCO CORP.: SELMAN BREITMAN BY: JERRY C. POPOVICH 600 WEST SANTA ANA BLVD. SUITE 501 SANTA ANA, CA 92701 (714) 647-9700 FOR DEFENDANT SQUARE D K & L GATES COMPANY: BY: RAYMOND L. GILL FOUR EMBARCADERO CENTER SUITE 1200 SAN FRANCISCO, CA 94111 (415) 249-1088 FOR DEFENDANT WARREN PUMPS: HAWKINS, PARNELL & THACKSTON BY: EDWARD R. ULLOA (NOT PRESENT) 444 SOUTH FLOWER STREET SUITE 1100 LOS ANGELES, CA 90071 (213) 486-8000 HAWKINS & PARNELL BY: M. ELIZABETH O'NEILL 4000 SUNTRUST PLAZA 303 PEACHTREE STREET NE ATLANTA, GA 30308 (404) 614-7582 APPEARANCES: FOR PLAINTIFFS: WATERS KRAUS BY: GARY M. PAUL KEVIN LOEW PAUL C. COOK (NOT PRESENT) 222 NORTH SEPULVEDA BLVD. SUITE 1900 EL SEGUNDO, CA 90245 (310) 414-8146 FOR DEFENDANT CRANE CO.: K & L GATES BY: GEOFFREY M. DAVIS 10100 SANTA MONICA BLVD. SEVENTH FLOOR LOS ANGELES, CA 90067 (310) 552-5000 FOR DEFENDANT EATON PRINDLE, DECKER & AMARO ELECTRICAL: BY: ROBERT H. BARONIAN (NOT PRESENT) 310 GOLDEN SHORE FOURTH FLOOR LONG BEACH, CA 90802 (562) 436-3946 HOWARD ROME MARTIN & & RIDLEY BY: LISA A. CORMAN SHAWN M. RIDLEY 1775 WOODSIDE ROAD SUITE 200 REDWOOD CITY, CA 94061 (650) 365-7715 GOLDBERG, MILLER & RUBIN BY: CY GOLDBERG 121 SOUTH BROAD STREET SUITE 1500 PHILADELPHIA, PA 19107 FOR ELLIOTT COMPANY: WALSWORTH FRANKLIN BEVINS & MC CALL BY: THOMAS G. SCULLY SEAN P. MARTIN ONE CITY BOULEVARD WEST FIFTH FLOOR ORANGE, CA 92868 (714) 634-2522 INDEX FOR TUESDAY, JANUARY 13, 2009 VOLUME 1 MASTE R I N D EX CHRONOLOGICAL INDEX OF WITNESSES PLAINTIFFS' WITNESSES: PAGE BRODKIN, CARL ANDREW DIRECT EXAMINATION BY MR. PAUL 78 DEFENDANTS' WITNESSES: (NONE.) PAGE ALPHABETICAL INDEX OF WITNESSES WITNESSES: PAGE BRODKIN, CARL ANDREW DIRECT EXAMINATION BY MR. PAUL 78 79 1 COUPLE SMALL JOBS. HE THEN WENT INTO CITY GOVERNMENT. THAT HE -- LET ME GO BACK A STEP. 2 AND FOR OVER 40 YEARS, HE SERVED AS CITY MANAGER OF YOU ARE GOING TO HEAR THAT ON NAVY SHIPS IN 3 TOWNS IN TEXAS. AND IN FACT, HIS LAST JOB THAT HE LEFT THIS PERIOD OF TIME -- THESE SHIPS WERE BUILT IN THE 4 AS A RESULT OF HIS ILLNESS, HE HAD BEEN CITY MANAGER OF '40S, DURING WORLD WAR II. THERE WAS A GREAT DEAL OF 5 THAT CITY FOR OVER 20 YEARS. SHIP-BUILDING, AS YOU CAN IMAGINE, DURING WORLD WAR II. 6 AND YOU'RE GOING TO HEAR THAT HE WAS THEY HAD TO COME UP WITH HUGE FLEETS OF SHIPS TO FIGHT 7 DIAGNOSED WITH MESOTHELIOMA ON JANUARY 16 -- I'M SORRY, THE WAR BOTH IN EUROPE AND IN JAPAN. AND SO THEY BUILT 8 2008. I WAS JUST THINKING, GOSH, THAT'S ALMOST EXACTLY THOUSANDS OF SHIPS DURING THAI PERIOD OF TIME. 9 ONE YEAR AGO. I GUESS TODAY IS THE 13TH OF JANUARY. ONE OF THE THINGS THAT THEY KNEW WAS, THEY 10 NOW, HOW WAS HE EXPOSED TO THIS ASBESTOS IN HAD TO INSULATE OR KEEP THESE AREAS SAFE FOR THESE 11 THE NAVY? WHAT THE EVIDENCE IS GOING TO INDICATE TO YOU WORKERS, THESE SEAMEN WHO WERE DOWN THERE WORKING ON 12 IS THAT HE WAS IN THE NAVY FROM 1961 TO 1965. YOU'LL 12 THIS EQUIPMENT. 13 HEAR HIM TESTIFY ABOUT IT. HE SAID, "I JUST 13 AND IN THESE AREAS WHERE THEY HAVE BOILERS 14 VOLUNTEERED. I THOUGHT IT WOULD BE A GOOD THING TO DO 14 AND STEAM POWER, TWO THINGS HAVE TO BE REQUIRED. NUMBER 15 TO GO INTO THE NAVY." HE VOLUNTEERED AND HE WENT INTO 15 ONE, YOU'VE GOT TO PROTECT THE WORKERS FROM COMING IN 16 THE NAVY. CONTACT WITH THESE PIPES, WHICH ARE CARRYING VERY HOT 17 ONCE HE GOT INTO THE NAVY, THEY ALWAYS TRY OILS AND STEAM, AND TEMPERATURES OF 800 DEGREES IN SOME 18 TO TEACH YOU TO DO SOMETHING. SO WHEN HE GOT INTO THE OF THESE PIPES. 19 NAVY, THEY TAUGHT HIM FIRST TO BE WHAT'S CALLED A SO ONE OF THE THINGS THEY WOULD DO IS PUT 20 FIREMAN APPRENTICE. INSULATION, OF COURSE, AROUND THIS EQUIPMENT AND AROUND 21 LET ME EXPLAIN WHAT THAT TERM MEANS. 21 THESE PIPES SO, IF THE SAILOR CAME IN CONTACT WITH THEM, 22 "FIREMAN" DOESN'T MEAN FIREFIGHTER. IT BASICALLY MEANS 22 HE WOULDN'T BE BURNED. 23 SOMEBODY WHO WORKS IN THE BOILER AREA OR THE MACHINER 23 THE OTHER REASON YOU WOULD INSULATE THEM IS, 24 SPACES OF A SHIP. 24 YOU'D INSULATE THEM SO YOU COULD KEEP THE HEAT IN. IT 25 THOSE OF YOU WHO SAW "TITANIC," YOU REMEMBER 25 MAKES A MORE EFFICIENT SYSTEM; YOU DON'T WANT THE HEAT 26 THEY WERE SHOVELING COAL IN. THOSE WERE PEOPLE STOKING ESCAPING. SO THEY WOULD PUT THIS INSULATION AROUND IT. 27 THE FIRE. THAT'S HOW THEY MAKE THESE SHIPS OPERATE. ONE OF THE THINGS THAT THEY USED A GREAT 28 BASICALLY, THEY'RE STEAM-DRIVEN SHIPS. DEAL OF IN THE NAVY WAS ASBESTOS, FOR INSULATION. 8 10 1 SO THE PEOPLE WHO END UP WORKING IN THOSE 1 FIREPROOF; DIDN'T HAVE TO WORRY ABOUT SHIPS CATCHING (N 2 MACHINERY SPACES -- THE FIRST PLACE THEY START, WHERE 2 FIRE BECAUSE ASBESTOS IS FIREPROOF. IT'S LIGHTWEIGHT, 3 THEY LEARN THE MACHINERY, THEY LEARN WHAT'S IN THOSE 3 GENERALLY. AND SO THE NAVY DID USE A GREAT DEAL OF 4 MACHINERY SPACES ON A SHIPS -- ARE CALLED FIREMEN. AND 4 ASBESTOS ON ITS SHIPS FOR INSULATION. 5 THEY'RE -- THE LOWEST POSITION IS APPRENTICE. YOU 5 AND YOU WILL HEAR THESE PRODUCTS MADE BY 6 BASICALLY GO ONTO A SHIP TO LEARN YOUR JOB, YOUR TASK, 6 THESE DEFENDANTS, AS WELL, USED ASBESTOS. 7 AFTER SOME BASIC TRAINING. 7 MR. LOEW: LET ME GIVE YOU THIS. 8 BUT HE ALSO WAS BEING TRAINED IN ANOTHER 8 (HANDS NOTE TO MR. PAUL.) 9 POSITION, AND THAT IS TO BECOME AN ELECTRICIAN. YOU'LL 9 MR. PAUL: OKAY. THANK YOU. 10 FIND OUT THERE'S A GREAT DEAL OF ELECTRICAL SUPPLY 10 THINGS CHANGE WHILE YOU'RE GIVING YOUR 11 REQUIREMENTS ON BOARD SHIPS. AND AGAIN, IT'S ALL DRIVEN 11 OPENING STATEMENT, YOUR HONOR. 12 BY THIS EQUIPMENT THAT EXISTS IN THE MACHINERY SPACES. 12 WHERE WAS I BEFORE I WAS SO RUDELY 13 THAT'S WHAT HELPS POWER THE SHIP, THROUGH GENERATORS, ET 13 INTERRUPTED. 14 CETERA. AND ONE OF THE THINGS HE WAS REQUIRED TO DO WAS 14 NO, I'M KIDDING. THAT WAS A FACETIOUS 15 TO WORK WITH THE ELECTRICAL EQUIPMENT ON THE SHIP. 15 COMMENT. 16 NOW, IN DOING THIS JOB, YOU'RE GOING TO HEAR 16 (LAUGHTER.) 17 HE HAD TO WORK AROUND THE EQUIPMENT OF THESE DEFENDANTS. 17 MR. PAUL: "JURY LAUGHS." 18 AND BEING AN APPRENTICE, BEING SOMEONE THAT'S IN THE 18 SO - 19 MACHINERY SPACES, IF SOMEBODY NEEDED A HAND ON 19 CAN I HAVE THE LAST THING I SAID BEFORE? 20 WORKING -- IF THEY WERE WORKING ON A PUMP OR THEY WERE 20 I'M SORRY, YOUR HONOR. 21 WORKING ON SOME PIECE OF EQUIPMENT, THEY'D SAY, "YOU, 21 (RECORD READ BY THE REPORTER AS FOLLOWS: 22 WOODARD, COME HERE. I NEED YOUR HELP. HELP ME HOLD 22 "...ASBESTOS IS FIREPROOF. IT'S 23 THIS WRENCH. HELP ME TAKE THIS PART OFF. HELP WORK 23 LIGHTWEIGHT, GENERALLY. AND SO THE NAVY DID 24 WITH ME," AS THEY'RE REPAIRING THIS EQUIPMENT. 24 USE A GREAT DEAL OF ASBESTOS ON ITS SHIPS FOR 25 AND IN DOING THAT, YOU'LL HEAR THAT HE WAS 25 INSULATION. 26 EXPOSED TO ASBESTOS, AS I'LL TALK ABOUT IN A FEW MORE 26 "AND YOU WILL HEARTHESE PRODUCTS MADE 27 MINUTES. YOU'LL HEAR THAT HE WAS ALSO EXPOSED TO 27 BY THESE DEFENDANTS, AS WELL,USED ASBESTOS." 28 ASBESTOS BECAUSE THE EQUIPMENT, THE ELECTRICAL EQUIPMENT 28 MR. PAUL: OKAY. 11 13 1 AND SO YOU'LL HEAR DISCUSSION IN THIS CASE 1 IN POWERING THESE SHIPS, THE VALVES THAT THEY USED WERI 2 ABOUT WHY THEY USED ASBESTOS. DID THE NAVY REQUIRE IT, 2 HUGE VALVES. 3 OR DID THEY KNOW IT WAS GOING TO BE ON THEIR EQUIPMENT? 3 SOMEBODY TALKED ABOUT IT IN ONE OF THEIR - 4 WE BELIEVE THE EVIDENCE IS GOING TO 4 I THINK, IN ONE OF THEIR MINI OPENINGS. IT'S NOT LIKE 5 INDICATE, YES, THE NAVY DID INDICATE THAT ASBESTOS COULD 5 YOUR FAUCET. IT WORKS THE SAME KIND OF WAY. BUT WE'RE 6 BE USED OR SHOULD BE USED; BUT WE ALSO WILL INDICATE 6 TALKING ABOUT VALVES THAT ARE HUGE, HUNDREDS OF POUNDS. 7 THAT THESE DEFENDANTS KNEW THEY WERE USING ASBESTOS AND 7 AND THESE VALVES, YOU'RE GOING TO HEAR, 8 THAT THEY KNEW OR SHOULD HAVE KNOWN WHAT THE RISKS WERE 8 CONTAINED ASBESTOS INTERNALLY IN THE FORM OF GASKETS AND 9 FROM USING THAT ASBESTOS. 9 PACKING. 10 WE'LL INDICATE TO YOU IN THE EVIDENCE THAT 10 AND THE EVIDENCE WILL DEMONSTRATE THAT THEY 11 NOT ONLY DID THESE PRODUCTS CONTAIN ASBESTOS, BUT THAT 11 KNEW THAT ON THE OUTSIDE OF THEIR VALVES -- BECAUSE THEY 12 IT WAS WELL KNOWN AT THAT POINT IN TIME, IN THE MEDICAL 12 HAD TO MOVE THESE HOT LIQUIDS, AND THEY KNEW THEY WERE 13 LITERATURE AND THE SCIENTIFIC LITERATURE, THAT IT CAUSED 13 GOING TO BE AROUND SAILORS, THAT THEY KNEW IT WAS GOING 14 CANCER AND DEATH. 14 TO BE COVERED WITH ASBESTOS MATERIAL, TO INSULATE THEM 15 NOW, WHY DID THE COMPANIES END UP USING 15 FROM THE SAILORS WHO MIGHT BE AROUND THEM. 16 ASBESTOS IN THEIR EQUIPMENT? WHY WOULD THEY DO THAT? 16 CUTLER-HAMMER, OR EATON -- EATON IS THE 17 WELL, YOU'RE GOING TO HEAR THAT ONE OF THE 17 ESSENTIALLY THE NEW NAME OF CUTLER-HAMMER. YOU WILL 18 LARGEST CUSTOMERS THAT YOU CAN HAVE AS A COMPANY IS THE 18 HEAR, THE SAME AS FOR SQUARE D, THAT CUTLER-HAMMER MADE 19 U.S. NAVY. AS I TOLD YOU, THEY WERE BUILDING THOUSANDS 19 ELECTRICAL EQUIPMENT; SAME KIND OF THINGS THAT SQUARE D 20 OF SHIPS, AND IT WAS A CONTINUING PROCESS. SHIPS WOULD 20 DID: THESE BOARDS AND THIS ELECTRICAL EQUIPMENT. AND 21 BE LOST IN THE WAR -- IN WORLD WAR II, IN KOREA -- OR 21 THAT JUST LIKE SQUARE D, IT CONTAINED SIGNIFICANT 22 SHIPS GOT OLD, AND THEY'D HAVE TO BUILD NEW SHIPS. 22 AMOUNTS OF ASBESTOS THAT MY CLIENT ENDED UP WORKING 23 SO THE EVIDENCE IS GOING TO DEMONSTRATE TO 23 AROUND. 24 YOU THAT THESE COMPANIES WERE SUPPLIERS TO THE NAVY. 24 YOU WILL HEAR ABOUT A COMPANY CALLED SEPCO. 25 THEY WANTED THAT BUSINESS. IT WAS GOOD FOR THEIR BOTTOM 25 SEPCO MADE GASKETS AND PACKING, THE KIND OF THINGS THAT 26 LINE. WE'RE GOING TO INDICATE TO YOU THAT THAT WAS 26 WOULD GO IN THESE VALVES. AND WHAT YOU WILL HEAR IN 27 SOMETHING THEY WERE AWARE OF AND KNEW, AND THEY WANTED 27 THIS CASE IS THAT THESE PARTS WOULD WEAR DOWN, THESE 28 TO KEEP THAT BUSINESS, IN SPITE OF THE FACT THAT THEY 28 GASKETS THAT WOULD CONNECT THESE -- 12 14 1 WERE USING ASBESTOS AND THEY KNEW OR SHOULD HAVE 1 LET ME GIVE YOU AN EXAMPLE. YOU HAVE A 2 KNOWN - 2 VALVE, AND IT CONNECTS TO A PIPE. WHAT THEY HAVE TO DO 3 MR. GILL: OBJECTION, YOUR HONOR. THAT'S 3 IS, THEY HAVE TO CONNECT THEM TOGETHER, SORT OF LIKE 4 ARGUMENTATIVE. 4 YOUR GARDEN HOSE. AND YOU KNOW HOW, IN YOUR GARDEN 5 THE COURT: SUSTAINED. 5 HOSE, YOU HAVE THAT LITTLE THING INSIDE, THAT RUBBER 6 MR. PAUL: THE EVIDENCE WILL INDICATE THAT THEY 6 THING, SO THAT IT DOESN'T LEAK? IN THE SAME FASHION, 7 DID AGREE AND CONTINUED TO USE ASBESTOS, EVEN THOUGH 7 THEY USE GASKETS BETWEEN THE PIPE AND THE VALVE TO KEEP 8 THEY KNEW OR SHOULD HAVE KNOWN THAT THIS ASBESTOS WAS 8 IT FROM LEAKING. 9 HARMFUL TO HUMAN HEALTH. 9 THESE GASKETS WERE MADE ESSENTIALLY OUT OF 10 SO LET'S TALK ABOUT THE COMPANIES THAT WE'LL 10 80 TO 90 PERCENT ASBESTOS. 11 BE DISCUSSING WITH YOU IN THIS CASE. 11 SO WHEN YOU SEE A CONNECTION WITH A VALVE OR 12 WE'RE GOING TO BE TALKING TO YOU ABOUT A 12 YOU SEE A CONNECTION WITH A PUMP -- YOU'LL HEAR THAT THE 13 COMPANY CALLED SQUARE D, WHO MADE ELECTRONIC - 13 GASKETS THAT MR. WOODARD RECALLS WORKING WITH ON THAT 14 ELECTRICAL COMPONENTS. THEY MADE BOARDS THAT WENT IN 14 SHIP WERE MADE BY SEPCO, AND THOSE GASKETS CONTAIN 15 CONTROLLERS. THEY ENDED UP MAKING WHAT ARE CALLED ARC 15 ASBESTOS. 16 SHIELDS. YOU'RE GOING TO LEARN A LOT ABOUT ELECTRICAL 16 NOW, LET'S GO TO THE DANGER, JUST FOR A 17 EQUIPMENT IN THIS CASE, AS WELL. 17 SECOND. WHAT IS THE DANGER THAT WE'RE TALKING ABOUT? 18 AND THE EVIDENCE, WE BELIEVE, IS GOING TO 18 THE EVIDENCE IN THIS CASE WILL BE, AS EARLY AS THE 1930S 19 DEMONSTRATE TO YOU THAT SQUARE D PUT INTO THESE BOARDS 19 IN THE UNITED STATES -- AND ACTUALLY, WORLDWIDE, IN THE 20 AND INTO THESE PRODUCTS THAT THEY MADE FOR THE U.S. NAVY 20 MEDICAL LITERATURE; AND I'LL TALK TO YOU A LITTLE MORE 21 A SIGNIFICANT AMOUNT OF ASBESTOS, POTENTIAL EXPOSURE TO 21 ABOUT SOME OF THE DETAIL -- THAT IT WAS KNOWN BY THAT 22 THE PEOPLE USING THEIR PRODUCT. 22 TIME THAT ASBESTOS WAS A KILLER, THAT IT WOULD KILL 23 WE'RE GOING TO BE TALKING TO YOU ABOUT A 23 HUMAN BEINGS, IN SUFFICIENT DOSES. 24 COMPANY CALLED CRANE, CRANE CO. THIS IS A COMPANY THAT 24 YOU'LL HEAR BY THE 1940S THAT STUDIES 25 MADE VALVES, HUNDREDS AND THOUSANDS OF VALVES, FOR THE 25 CONFIRMED THAT ASBESTOS CAUSED CANCER, LUNG CANCER. AND 26 U.S. NAVY. YOU WILL HEAR THAT THESE SHIPS WERE PACKED 26 YOU'LL HEAR AN EXPERT COME IN AND TESTIFY THAT THERE 27 WITH VALVES. BECAUSE IN THESE ENGINE ROOMS, THEY HAD TO 2 7 WERE ALREADY ARTICLES APPEARING IN THE 1940S, TALKING 28 CONTROL THE STEAM, THE OIL, THE WATER THAT WOULD BE USED 28 ABOUT THIS STRANGE DISEASE, CANCER, THAT WAS ATTACKING 23 25 1 THE EQUIPMENT TO MAKE NEW HOLES FOR PUTTING IN PARTS ON 1 WITH IT; YOU JUST NEED TO BE AROUND AND TO BREATHE THESE 2 THESE ELECTRICAL BOARDS. WHEN HE'S DOING THAT, HE'S 2 FIBERS AND THE DANGER THAT IT CAUSES TO THOSE WHO ARE 3 RELEASING THOSE FIBERS. HE'D CLEAN IT UP WITH AIR HOSES 3 AROUND IT. 4 AND BLOW IT OUT, WHICH IS MUCH WORSE, BECAUSE THAT GETS 4 AND YOU'RE GOING TO HEAR ABOUT IT'S NOT JUST 5 ALL THE FIBERS INTO THE AIR. 5 MESOTHELIOMA THAT'S CAUSED BY IT. ASBESTOSIS, WHICH IS 6 THAT IS THE PROCESS THAT GOES ON AND 6 A SCARRING OF THE LUNGS, BASICALLY SHUTS THE LUNGS DOWN; 7 RELEASES THESE PRODUCTS INTO THE AIR. NOW, IS THERE ANY 7 LUNG CANCER, INTERNAL TO THE LUNGS; AND THE EXTERNAL 8 WARNING? NO. ASBESTOS HAS NO ODOR. YOU CAN'T SEE IT. 8 PROBLEM OF MESOTHELIOMA. 9 THESE PARTICLES ARE SMALLER THAN THE HUMAN EYE CAN SEE. 9 SO WE'LL HAVE SOME PEOPLE TO TALK TO YOU 10 SO YOU HAVE NO WAY OF VISUALIZING, OTHER THAN THE FACT 10 ABOUT THIS. ONE OF THE PEOPLE YOU'RE GOING TO HEAR BY 11 THAT YOU SEE THIS BIG DUST CLOUD. 11 VIDEOTAPE, BECAUSE HE'S FROM TEXAS, IS DR. ROY SMYTHE. 12 BUT YOU DON'T KNOW THAT THESE TINY PARTICLES 12 DR. SMYTHE WAS THE TREATING DOCTOR FOR MR. WOODARD. AND 13 ARE GETTING INTO YOUR LUNGS. THERE ARE NO WHAT ARE 13 DR. SMYTHE IS GOING TO TALK TO YOU ABOUT WHAT HE DID. 14 CALLED "ONION PROPERTIES." THERE'S NOTHING TO GIVE YOU 14 A LITTLE BIT OF HIS BACKGROUND: HE'S A 15 A CLUE OR A HINT THAT YOU'RE DOING SOMETHING THAT COULD 15 THORACIC SURGEON, BOARD CERTIFIED. HE'S CHAIRMAN OF THE 16 END UP HARMING YOUR BODY. 16 DEPARTMENT OF SURGERY. HE'S A PROFESSOR IN THE 17 AND AS I'VE SAID, YOU DON'T GET SICK RIGHT 17 DEPARTMENT OF SURGERY. HE'S A PROFESSOR IN MOLECULAR 18 AWAY. IT WOULD BE ONE THING IF YOU BREATHED THAT IN ONE 18 AND CELLULAR MEDICINE. HE'S TREATED PATIENTS WITH 19 DAY AND YOU FELL OVER BECAUSE YOU COULDN'T BREATHE 19 MESOTHELIOMA FOR OVER 20 YEARS. 20 ANYMORE. YOU'RE TALKING 40 YIARS BEFORE YOU ACTUALLY 20 AND ONE OF THE THINGS THAT HE DECIDED THAT 21 KNOW THE EFFECT OF YOU'VE BEEN DOING WITH ASBESTOS. 21 HE WANTED TO DO TO TRY TO HELP OUT MR. WOODARD WAS TO DO 22 SO THE EVIDENCE WILL BE THAT AND MR. WOODARD 22 A SIGNIFICANT SURGERY. IT'S CALLED AN EPP -- AND I'LL 23 WILL TALK TO YOU ABOUT THE KIND OF WORK HE DID IN THOSE 23 LET SOMEBODY ELSE COME IN AND TELL YOU THE TECHNICAL 24 SPACES, THE KIND OF WORK WHERE PEOPLE WOULD SAY TO HIM, 24 WORDS FOR IT -- BUT BASICALLY, THEY TOOK HIS LUNG OUT IN 25 "COME OVER HERE AND HELP ME WORK ON THIS PART. WORK 25 ORDER TO TRY TO GIVE HIM A LITTLE EXTRA TIME. 26 WITH ME ON -- TAKE THAT ASBESTOS OFF OF THERE. GRIND 26 AND HE'S GOING TO SAY THAT HE THINKS IT MAY 27 THAT GASKET OFF THAT PIPE." 27 GIVE HIM A LITTLE EXTRA TIME, BUT THERE'S NO QUESTION 28 THIS IS THE KIND OF THING HE WOULD DO. 28 THAT IT'S NOT GOING TO SAVE HIS LIFE. HE'S GOING TO 24 26 1 "DRILL THAT PART OVER HERE. SCRAPE DOWN THAT ELECTRICAL 1 PASS FROM THIS DISEASE IN A VERY BRIEF PERIOD OF TIME. 2 BOARD." HE WILL TALK TO YOU ABOUT THAT PROCESS, HOW 2 YOU'RE GOING TO HEAR FROM TWO OTHER REALLY 3 DUSTY THAT PROCESS WAS, AND HOW THAT DUST ENDED UP BEING 3 WORLD-RENOWNED EXPERTS IN ASBESTOS MEDICINE. YOU'RE 4 BREATHED BY HIM. HE KNEW HE WAS BREATHING IT; HE JUST 4 GOING TO HEAR FROM A DR. ARNOLD BRODY, WHO IS A CELLULAR 5 DIDN'T KNOW WHAT HE WAS BREATHING WOULD END UP TAKING 5 BIOLOGIST, A PH.D., WHO HAS TESTIFIED BEFORE CONGRESS, 6 HIS LIFE. 6 HAS LECTURED AROUND THE WORLD ABOUT ASBESTOS AND HOW T 7 SO WE'RE GOING TO BRING IN EXPERTS TO TALK 7 CAUSES DISEASES; AND THE TESTING HE'S DONE, AND THE WAY 8 TO YOU ABOUT HOW THAT HAPPENS. HOW DOES IT TAKE 8 HE DEMONSTRATES HOW IT IS THESE FIBERS GET INTO THE 9 SOMEONE'S LIFE, THESE TINY PARTICLES? IT'S STUPID OF ME 9 LUNG -- NOT ONLY GET INTO THE LUNG, BUT THEY GET PAST OF 10 TO TRY TO DRAW IT ON THE BOARD BECAUSE THEY'RE MUCH 10 THE DEFENSES OF THE BODY. 11 SMALLER THAN ANYTHING I COULD DRAW ON THIS BOARD. WE'RE 11 YOU KNOW, THERE ARE WAYS THAT -- I DON'T 12 GOING TO HAVE SOME EXPERTS COME IN AND TALK TO YOU ABOUT 12 WANT TO GET INTO THE GROSSNESS OF IT, BUT SPUTUM AND THE 13 THAT. 13 OTHER KIND OF THINGS ARE WAYS THAT KEEP THESE PARTICLES 14 BUT WHAT HAPPENS IS THAT THESE FIBERS NOT 14 FROM GETTING INTO YOUR LUNGS. YOU'RE GOING TO HEAR 15 ONLY JUST AFFECT THE GUY WHO IS WORKING WITH THESE 15 ABOUT HOW THESE DEFENSES CAN BE OVERWHELMED, HOW IT GE"S 16 PRODUCTS DIRECTLY, BUT ANYBODY STANDING NEARBY. IF 16 DOWN TO THE VERY TINIEST AIR SACS IN THE BODY -- IN THE 17 YOU'RE WITHIN A FEW FEET OF THE PERSON, YOU'LL HEAR 17 LUNG, AND IT GETS FROM THERE TO THE LINING OF THE LUNG. 18 STUDIES THAT THOSE PEOPLE ARE AFFECTED. 18 IT ACTUALLY CROSSES THE BOUNDARY TO GET TO 19 YOU'LL HEAR THAT IT'S SO PERVASIVE -- FOR 19 THE PLEURA, WHICH IS THE LINING OF THE LUNG, WHERE THERE 20 EXAMPLE, SOME OF THE STUDIES THAT THE EXPERTS RELY 20 IT INTERACTS WITH THE CELLS AND ENDS UP AFFECTING THE 21 UPON -- THAT MEN WHO WORKED WITH THIS PRODUCT, WHO WOULD 21 DNA OF THE CELLS AND CAUSES THEM TO BECOME CANCER CELLS. 22 COME HOME WITH THEIR CLOTHES, AND THEIR SPOUSE WOULD THAT'S HOW ASBESTOS CAUSES THE WREAK AND 23 CLEAN THEIR CLOTHES, SHAKE IT OUT, THAT THE SPOUSE WOULD 23 HAVOC OF MESOTHELIOMA. 24 GET MESOTHELIOMA FROM DOING THAT. 24 SO DR. BRODY, JUST TO GIVE YOU A LITTLE BIT 25 YOU'RE GOING TO HEAR STUDIES THAT PEOPLE WHO 25 OF HIS BACKGROUND: PROFESSOR OF THE DEPARTMENT OF 26 CAME HOME FROM WORK WITH ASBESTOS ON THEIR CLOTHES, THAT 26 MOLECULAR BIOMEDICAL SCIENCES AT NORTH CAROLINA STATE, 27 THEIR PETS IN THEIR HOUSE WOULD GET MESOTHELIOMA. 27 FORMER VICE CHAIRMAN OF PATHOLOGY AT TULANE UNIVERSITY. 28 SO YOU DON'T HAVE TO BE THE PERSON WORKING 28 HE'S WRITTEN OVER 145 ARTICLES, PEER REVIEWED, IN 39 41 1 GOING TO HEAR FROM DEFENDANTS. AND WE'RE GOING TO BEG N 1 STEEL FROM SOME COMPANIES. THEY BOUGHT VALVES, LIKE 2 WITH MR. DAVIS, FOR CRANE. 2 CRANE CO. MAKES, FROM SOME COMPANIES. THEY BOUGHT 3 MR. DAVIS: THANK YOU, YOUR HONOR. MAY I GO UP 3 PUMPS. THEY BOUGHT DEAERATING FEED TANKS. THEY BOUGHT 4 FRONT? 4 BOILERS AND TURBINES AND THOUSANDS AND THOUSANDS OF 5 THE COURT: YES, YOU MAY. 5 PARTS TO BUILD THESE MASSIVELY COMPLEX VESSELS TO FIGHT 6 MR. DAVIS: AS YOU MAY HAVE GUESSED, CRANE CO. IS 6 THE WAR. 7 STILL A PARTY IN THIS CASE. AS I SAID, I'M GEOFF DAVIS. 7 SOME WERE SUPPORT VESSELS, LIKE THE SECOND 8 JAMES LEE -- STAND UP -- IS HERE WITH ME FROM CRANE CO., 8 ONE MR. WOODARD SERVED ON, WHICH WAS A SEA PLANE TENDER, 9 AND HE'S GOING TO BE ASSISTING ME AT COUNSEL TABLE 9 AND IT REPAIRED AND SERVICED SEA PLANES THAT WERE ACTIVE 10 THROUGHOUT THE CASE. 10 IN THE WAR EFFORT. OTHERS WERE DIRECT FRONT-LINE 11 AND WE'RE HERE TO TALK TO YOU -- I'M HERE TO 11 FIGHTING SHIPS, LIKE THE DESTROYER HE SERVED ON FIRST. 12 TALK TO YOU THIS MORNING ABOUT HOW WE BELIEVE THE 12 BUT THEY ALL WERE PART OF THE WAR EFFORT. 13 EVIDENCE IS GOING TO COME OUT IN THIS CASE AND WHAT 13 THEY ALL USED THOUSANDS AND THOUSANDS OF DIFFERENT PARTS 14 WE'RE GOING PROVE TO YOU OVER THE NEXT COUPLE OF WEEKS. 14 PROCURED FROM MANY DIFFERENT COMPANIES, AND ALL, AS THE 15 HOPEFULLY, THE TRIAL IS GETTING SHORTER, AS THE JUDGE 15 EVIDENCE WILL SHOW, TO EXACTING MILITARY SPECIFICATIONS. 16 READS THESE INSTRUCTIONS TO YOU. 16 THE GOVERNMENT DIDN'T JUST CALL UP AND SAY, 17 FIRST OF ALL, THERE IS NO DOUBT THAT MR. 17 "SEND US A BUNCH OF VALVES" OR "SEND US SOME STEEL." 18 WOODARD HAS A TERRIBLE DISEASE. THERE'S NO DISPUTE 18 THEY TOLD THE COMPANIES THAT THEY BOUGHT FROM EXACTLY 19 ABOUT THAT. THERE'S NO DISPUTE AS TO WHETHER HE WAS AT 19 WHAT THEY WANTED, EXACTLY HOW IT HAD TO BE MADE, EXACTLY 20 FAULT FOR CAUSING THAT DISEASE. I AND MR. LEE, THE 20 HOW IT HAD TO BE PACKAGED, AND EVEN WHAT THE WRITING ON 21 OTHER DEFENDANTS, WE ALL SYMPATHIZE WITH THE WOODARD 21 THE OUTSIDE OF THE PACKAGE HAD TO SAY. 22 FAMILY. THIS IS NOT OF THEIR DOING. BUT AT THE SAME WE'RE GOING TO PRESENT YOU EVIDENCE OF THAT 23 TIME, WE'RE HERE BECAUSE CRANE CO. NEEDS ITS DAY IN 23 THROUGH WITNESSES, PARTICULARLY EXPERT WITNESSES. WE'RE 24 COURT, BECAUSE THIS IS NOT CRANE CO.'S DOING. 24 GOING TO PRESENT TO YOU A RETIRED ADMIRAL IN THE U.S. 25 PLAINTIFFS SUED A NUMBER OF DEFENDANTS. 25 NAVY WHO WILL TALK A LOT ABOUT THAT. YOU'LL HEAR FROM 26 THEY'RE ALLEGING THAT IT IS THE FAULT OF CRANE CO. AND 26 MR. PAUL'S WITNESSES AND PERHAPS OTHERS ABOUT THIS 27 THE OTHERS WHO ARE HERE, BUT WE'RE GOING TO SHOW YOU 27 ISSUE, AS WELL. 28 THROUGH THE EVIDENCE THAT IT WAS NOT. 28 SO YOU'LL ALSO HEAR, AS MR. PAUL SAID, ABOUT 40 42 1 AND WE NEED TO NOT FORGET THE FACT THAT IT'S 1 SOME OF THE SCIENCE, THE MEDICINE ISSUES. 2 A LOT -- LIFE IS A LOT MORE COMPLICATED NOW THAN IT WAS 2 AND WHAT YOU DIDN'T HEAR FROM MR. PAUL IS 3 65 YEARS AGO OR SO, WHEN THE SHIPS WERE BUILT, OR EVEN 3 WHETHER OR NOT ANYBODY, IN 1943, WHEN THE SHIPS WERE 4 40 YEARS SO AGO, WHEN MR. WOODARD WAS SERVING IN THE 4 BEGINNING TO BE CONSTRUCTED AND WHEN THE VALVES AND 5 NAVY. WE HAVE HUGE CORPORATIONS THAT ARE DESTROYING 5 OTHER PRODUCTS WERE MADE THAT WENT INTO THOSE SHIPS - 6 PEOPLE'S LIVES NOW THROUGH FINANCES AND OTHER 6 THAT NOBODY WAS CONCERNED THAT THE PARTS, THE COMPONENT 7 ACTIVITIES, AND PEOPLE ARE VERY CYNICAL; BUT WE'RE GOING 7 PARTS OF VALVES THAT DID SOMETIMES CONTAIN ASBESTOS, 8 TO SHOW YOU THROUGH THE EVIDENCE THAT IT WAS A LOT 8 WERE HARMFUL TO PEOPLE, THAT THEY CAUSED ANY KIND OF 9 DIFFERENT BACK THEN. 9 CANCER. 10 THERE WAS NO EMAIL; THERE WAS NO INTERNET; 10 THE NAVY WAS WELL AWARE OF CERTAIN RISKS OF 11 NO COMPUTERS, PRACTICALLY. THINGS WERE MUCH SIMPLER. 11 MESOTHELIOMA -- EXCUSE ME, OF ASBESTOS, BUT NOBODY KNEW 12 AND WHEN THE SHIPS THAT ARE AT ISSUE IN THIS CASE -- ONE 12 THE WORD "MESOTHELIOMA," FIRST OF ALL. NOBODY WAS 13 OF WHICH IS CALLED THE USS ROGERS; ONE OF WHICH IS 13 WORRIED ABOUT THE GASKETS AND THE PACKING, THAT YOU 14 CALLED THE USS SALISBURY SOUND -- WHEN THESE SHIPS WERE 14 HEARD MR. PAUL TALK ABOUT, CAUSING ANY DISEASE, LET 15 BUILT, IT WAS STILL THE MIDDLE OF WORLD WAR II. THEY 15 ALONE THE ONE THAT MR. WOODARD GOT. 16 WERE DESIGNED IN WORLD WAR II. THEY NAVY CONTRACTED AND 16 THE NAVY, HOWEVER, WAS CONCERNED, HAD 17 HAD THEM BUILT IN WORLD WAR II. AND THEY WERE ACTUALLY 17 KNOWLEDGE, THAT INSULATION WAS HAZARDOUS. ITS KNOWLEDGE 18 CONSTRUCTED, FOR THE MOST PART, BEFORE THE WAR ENDED. 18 GREW OVER THE YEARS, AND IT WAS WELL AWARE OF INSULATION 19 THE COUNTRY LITERALLY WAS AT WAR. AND ONE 19 HAZARDS BEFORE MR. WOODARD WENT IN THE NAVY. WE'LL 20 OF THE THINGS THAT THE NAVY DECIDED TO DO WAS, 20 PRESENT EVIDENCE OF THAT TO YOU. 21 OBVIOUSLY, TO EXPAND THE SIZE OF THE NAVY GREATLY, 21 SO WHAT WE WANT YOU TO DO IS KEEP AN OPEN 22 BECAUSE IT WAS FIGHTING A WAR ACROSS TWO OCEANS. AND IT MIND. I'M GOING TO EXPAND ON SOME OF THESE TOPICS HERE 23 BUILT UP THE NAVY VERY QUICKLY. MR. PAUL TOLD YOU A 23 OVER THE NEXT FEW MINUTES. AND I'M GOING TO TRY NOT TO 24 LITTLE BIT ABOUT THAT. YOU'LL HEAR MORE ABOUT IT DURING 24 TALK AS LONG AS MR. PAUL. 25 THE TRIAL. 25 BUT WE WANT YOU TO KEEP AN OPEN MIND 26 THE WAY THE NAVY BUILT UP THE NAVY VERY 26 THROUGHOUT THE ENTIRE CASE. THAT'S WHAT YOUR OATH WAS, 27 QUICKLY WAS TO CONTRACT WITH VARIOUS COMPANIES TO SUPPLY 27 AND THAT'S WHAT WE NEED YOU TO DO: HEAR THE EVIDENCE ON 28 THE PARTS THEY NEEDED TO MAKE THE SHIPS. THEY BOUGHT 28 BOTH SIDES. PLAINTIFFS GET TO PRESENT THEIR EVIDENCE 47 49 1 THE NAVY KNEW BACK IN THE 1920S, THE 1930S, THE 1940S. 1 OFFICERS ON THEIR SHIPS, AND NOT TRAINING THEIR 2 THE NAVY -- I THINK YOU HEARD IN MINI OPENINGS, THE NAVY 2 COWORKERS ON THE SHIPS TO AVOID THESE EXPOSURES. 3 IN THE '40S HIRED SOME HARVARD SPECIALISTS TO GO DO 3 AS I SAID, THE NAVY WAS IN BASICALLY 4 RESEARCH FOR THEM AT SHIPYARDS WHERE THEY MADE SHIPS 4 COMPLETE CONTROL OF THE ENTIRE PROCESS OF SHIP 5 NOW, THEY CONCLUDED AT THE TIME THAT EVEN 5 CONSTRUCTION. AND CONTROL IS GOING TO BE A MAJOR THING 6 THE INSULATORS WORKING WITH THE INSULATION PRODUCTS, 6 YOU HEAR ABOUT DURING THIS TRIAL. 7 THAT WERE HIGH EXPOSURES WITH THE AMOSITE-TYPE 7 WE'RE GOING TO PRESENT TO YOU EVIDENCE, 8 INSULATION, WERE NOT AT SERIOUS RISK FOR DISEASE. BUT 8 THROUGH BOTH PLAINTIFFS' WITNESS AND OURS, THAT THE 9 THE NAVY WAS LOOKING INTO IT, AND THAT STUDY CONCLUDED 9 NAVY, AS I SAID, DESIGNED THE SHIPS, CONTRACTED FOR THE 10 THAT EVERYBODY COULD EASILY BE PROTECTED IF THE RIGHT 10 PURCHASE OF THE EQUIPMENT, CONTRACTED FOR OR BUILT THEM 11 PRECAUTIONS WERE TAKEN. 11 THEMSELVES WITH THAT EQUIPMENT THAT THEY BOUGHT. THEY 12 UNFORTUNATELY, THE NAVY DID NOT IMPLEMENT 12 DEVELOPED DETAILED MILITARY SPECIFICATIONS TO TELL THE THOSE PRECAUTIONS -- AT LEAST NOT FOR SERVICEMEN SERVIN 13 PRODUCT SELLERS EXACTLY WHAT THEY WANTED. ON THE SHIPS, LIKE MR. WOODARD. THE NAVY -- DESPITE ITS 14 WE'LL PRESENT TO YOU EVIDENCE THAT THAT WAS RESEARCH AND ITS KNOWLEDGE OF ASBESTOS, THE NAVY 15 DONE FOR VERY SPECIFIC REASONS. THEY DIDN'T WANT ANY CONCLUDED THAT THE PEOPLE LIKE MR. WOODARD SIMPLY 16 COMPLICATIONS. THEY WANTED BOTH SIDES TO BE ABSOLUTELY 17 WEREN'T AT RISK. 17 SURE THEY WERE IN AGREEMENT AS TO WHAT WAS BEING SENT TO 18 WELL, THE NAVY GOT IT WRONG BECAUSE OF THE 18 THE NAVY AND EXACTLY HOW IT WOULD OPERATE AND EXACTLY 19 INSULATION. BUT THE NAVY ALSO CONCLUDED THAT GASKETS 19 WHAT IT WOULD LOOK LIKE AND EXACTLY HOW BIG IT WAS. 20 AND PACKING WERE OF NO RISK. AND THE EVIDENCE IS GOING 20 BECAUSE IF THE NAVY WANTED TO BUY A VALVE TO SHOW YOU THAT THAT IS ACTUALLY TRUE. 21 THAT WAS DESIGNED TO FIT IN A SPACE THIS SIZE, AND THEY THE GASKETS AND PACKING WERE LOW-DOSE 22 WEREN'T SPECIFIC, AND THEY GOT A VALVE FOR THIS BIG, EXPOSURES. MR. PAUL ALSO TOLD YOU ABOUT THAT: IT'S A 23 THEY'VE GOT A PROBLEM. DOSE DISEASE. THE MORE YOU GET, THE MORE LIKELY TO 24 THUS WE'RE GOING TO PRESENT TO YOU EVIDENCE 25 CAUSE INJURY. 25 THAT THE NAVY'S MILITARY SPECIFICATIONS WERE INCREDIBLY 26 BUT THE GASKET AND PACKING EXPOSURES, WE 26 DETAILED. THE NAVY DICTATED BASICALLY EVERY DETAIL OF 27 WILL SHOW YOU, WERE SO LOW, AND WITH THE LOWER POTENC 27 EVERY PRODUCT, AS I SAID, DOWN TO THE WRITING ON THE 28 ASBESTOS TYPE, CHRYSOTILE, THAT THEY DID NOT CAUSE OR 28 PACKAGING ON THE OUTSIDE. 48 50 1 CONTRIBUTE TO MR. WOODARD'S DISEASE. AND IT WAS THE 1 THERE WAS MILITARY SPECIFICATIONS FOR 2 AMOSITE-TYPE INSULATION AND THE AMOSITE-TYPE ASBESTOS 2 PENCILS AND FOR WHAT FOOD WENT IN THE KITCHEN, IN THE 3 THE INSULATION THAT DID. 3 GALLEY, IN THE SHIPS. THEY SAID HOW MANY BAGS OF 4 BY THE 1940S, THE NAVY WAS WELL AWARE THAT 4 MARSHMALLOWS TO KEEP IN THE GALLEY. AND THAT'S HOW 5 SHIPYARD WORKERS WERE AT RISK FOR ASBESTOSIS. THIS IS 5 DETAILED THEY WERE. 6 THROUGH THE RESEARCH THEY HAD DONE. THEIR INDUSTRIAL 6 IN COORDINATION WITH MILITARY 7 HYGIENE AND MEDICAL DEPARTMENTS HAD DETERMINED THIS. 7 SPECIFICATIONS, THE NAVY DEVELOPED QUALIFIED PRODUCTS 8 THEY RECOMMENDED -- THE NAVY RECOMMENDED THE USE OF 8 LISTS. THAT PROVIDED NAVY SUPPLY OFFICERS, THE PEOPLE 9 RESPIRATORS FOR SHIPYARD WORKERS AND INSULATORS BY TH 9 WHO BOUGHT THE EQUIPMENT AND MATERIALS, A LIST OF WHAT 10 '40S. 10 COMPANIES WERE APPROVED TO SELL WHICH PRODUCTS TO TH 11 AS I SAID, THE NAVY HIRED SOME HARVARD 11 NAVY UNDER THOSE SPECIFICATIONS. 12 RESEARCHERS, AND SOME NAVY PERSONNEL PARTICIPATED WIT H 12 THEY HAD GONE THROUGH AND THEY'D FIGURED OUT 13 THIM TO PERFORM A STUDY. YOU'LL HEAR ABOUT THIS, THE 13 IF CERTAIN VALVES, FOR INSTANCE, MET THE SPECIFICATION, 14 FLEISCHER-DRINKER STUDY, WHICH WAS RELEASED IN THE MID 14 YOU COULD CALL CRANE CO. OR ANOTHER VALVE MANUFACTURER 15 '40S. THEY CONCLUDED THAT THE INSULATION WORKERS WERE 15 AND GET THE VALVE THAT WAS LISTED. 16 NOT ENGAGED IN A DANGEROUS OCCUPATION. 16 YOU COULD CALL A GASKET MANUFACTURER, IF YOU 17 THE NAVY RELEASED FURTHER PUBLICATIONS, 17 WERE A NAVY SUPPLY OFFICER, AND YOU COULD GET GASKETS 18 INTERNALLY AND EXTERNALLY, OVER THE NEXT DECADES. IN 18 AND THE NAVY COULD CALL UP INSULATION MANUFACTURERS A 19 1962, THE NAVY CONCLUDED AND WROTE THAT WORKERS SHOU D 19 GET THE INSULATION THAT WAS APPROVED. BECAUSE NOT ALL 20 AVOID CARELESS CREATION OF DUSTY CONDITIONS; THEY SHOU D 20 GASKETS WERE APPROVED, AND NOT ALL INSULATION WAS 21 WET DOWN MATERIALS WHEN POSSIBLE AND USE RESPIRATORY 21 APPROVED, AND NOT ALL VALVES WERE APPROVED, EITHER. 22 MATERIAL. 22 SO THE NAVY HAD THESE DETAILED 23 THAT WAS IN THE FIRST OR SECOND YEAR OF MR. 23 SPECIFICATIONS, AND THEY HAD THE LISTS OF WHO COULD MAKE 24 WOODARD'S NAVY SERVICE, BUT THEY DIDN'T TRAIN MR. 24 PRODUCTS THAT MET THE SPECIFICATIONS. 25 WOODARD TO DO THAT. THE NAVY WAS LOOKING, 25 THE EVIDENCE WILL THEN SHOW YOU THAT WHAT 26 UNFORTUNATELY, IN THE WRONG PLACE AND EXCLUDING PEOP LE 26 THE NAVY DID WAS, THEY WOULD HAVE THE SHIPYARD -- EITHER 27 WHO WERE AT RISK FROM INSULATION EXPOSURES, LIKE MR. 27 A NAVAL SHIPYARD OR A CIVILIAN SHIPYARD THAT CONTRACTED 28 WOODARD, AND NOT TRAINING THEM, NOT TRAINING THEIR 28 WITH THE NAVY -- DO THE FULL DESIGN OF THE SHIP. THEY 51 53 1 WOULD FIGURE OUT EXACTLY HOW MANY VALVES OF WHICH TYPE 1 ITS EXCESS GASKETS OR PACKING FROM CRANE CO. IN FACT, 2 THEY NEEDED AND EXACTLY HOW MANY OF EVERYTHING THEY 2 NOT ONLY DID CRANE CO. NOT SELL THE INSULATION TO THE 3 NEEDED, AND THEN THEY WOULD SEND IT OUT FOR BIDS AND, IN 3 NAVY, THE VALVES DIDN'T REALLY NEED IT. THE NAVY PUT 4 TURN, THE CONTRACTS TO PROCURE THOSE ITEMS. 4 THE INSULATION ON THE VALVES AND THE OTHER EQUIPMENT IN 5 THEY WOULD HAVE DRAWINGS, COMPLEX, THOUSANDS 5 THE ENGINE ROOMS, MOSTLY, BECAUSE IT WAS VERY HOT. THE 6 OF PAGES OF DRAWINGS OF THESE SHIPS, IN ORDER TO MAKE 6 STEAM SYSTEMS, FOR INSTANCE, OPERATED AT AS MUCH AS - 7 SURE THAT EVERYBODY KNEW WHERE EVERYTHING WENT. AND 7 MR. PAUL SAID UP TO 800 DEGREES OR MORE. 8 WHEN THE PEOPLE BUILDING THE SHIP -- WOULD THEY GOT A 8 THAT'S BECAUSE THERE WAS A BOILER THAT 9 VALVE, THEY WOULD KNOW WHERE IT WENT; OR WHEN THEY GOT A 9 GENERATED THAT HEAT, AND IT CREATED STEAM. AND IF THEY 10 PUMP, THEY KNEW EXACTLY WHERE IT WENT AND WHAT IT WAS 10 DIDN'T PUT INSULATION ON IT, A, SAILORS COULD GET BURNED 11 HOOKED UP TO. 11 AND INJURED; AND B, IT'LL BE SO HOT IN THE ENGINE ROOM, 12 THE NAVY TESTED THE PRODUCTS THAT PEOPLE -- 12 THEY COULDN'T WORK. 13 THAT COMPANIES SOLD THEM BEFORE THEY GOT THEM. THEY 13 I THINK YOU'LL HEAR TESTIMONY THAT THE 14 TESTED THEM AFTER THEY RECEIVED THEM. THEY TESTED THE 14 ENGINE ROOM, EVEN WITH THE INSULATION, WOULD BE WELL 15 SHIPS BEFORE THEY RELEASED THEM TO BE USED IN WAR OR 15 OVER 100 DEGREES, JUST ON A ROUTINE BASIS. 16 OTHER NAVAL OPERATIONS. 16 BUT THE VALVES DID NOT NEED INSULATION TO 17 SO THE NAVY WAS INTIMATELY INVOLVED IN ALL 17 OPERATE. THE NAVY ELECTED TO INSULATE THEM IN ORDER TO 18 ASPECTS OF NOT ONLY THE DESIGN AND CONSTRUCTION OF THE 18 MAKE THE AREA MORE HABITABLE AND, IN RELATIVE TERMS, A 19 SHIPS, BUT THE DESIGN AND CONSTRUCTION OF THE PRODUCTS 19 MORE COMFORTABLE TEMPERATURE AND TO PREVENT PEOPLE FROM 20 THEY BOUGHT TO GO IN THE SHIPS. 20 BEING BURNED. 21 THE VALVES THAT THE NAVY PURCHASED -- AND 21 IN ADDITION TO THE NAVY, CRANE CO. MADE 22 IT'S VERY SIMPLE. SOMETIMES WE OVERSIMPLIFY IT AND SAY 22 VALVES TO SELL TO LOTS OF OTHER COMPANIES -- I'M SORRY, 23 A VALVE IS SIMILAR TO YOUR KITCHEN FAUCET. THAT'S A 23 FOR LOTS OF OTHER USES BESIDES NAVY VESSELS. VALVES 24 TYPE OF VALVE. THERE'S ARE LOTS OF TYPES OF VALVES. 24 HAVE A LOT OF PURPOSES. AS I SAID, SOME OF THEM CONTROL 25 MOST PEOPLE -- AND I NEVER HEARD OF THEM 25 THE FLOW. SOME OF THEM JUST ARE AUTOMATIC AND RELEASE 26 BEFORE I STARTED DOING THIS, BUT MOST PEOPLE HAVE NEVER 26 WHEN PRESSURE BUILDS UP. 27 HEARD OF THEM. WE'LL PRESENT TO YOU SOME EVIDENCE ABOUT 27 BUT LOTS OF THINGS FLOW THROUGH VALVES: 28 THEM. YOU'LL HEAR ABOUT AT LEAST A COUPLE TYPES OF 28 AIR, WATER, FUEL. ANYTHING THAT WAS LIQUID OR GAS THAT 52 1 VALVES. 2 SOME VALVES SIMPLY TURN THE FLOW OF A LIQUID 3 OR GAS ON OR OFF. SOME ALLOW IT TO BE CONTROLLED, LIKE 4 A FAUCET, SO THAT YOU CAN HAVE LESS OR MORE FLOW. 5 OTHERS ARE MORE AUTOMATIC AND, IF TOO MUCH PRESSURE 6 BUILDS UP, RELEASES PRESSURE OR CUTS OFF THE FLOW OF A 7 FLUID. YOU'LL HEAR ABOUT THESE. 8 BUT THEY HAVE DIFFERENT FUNCTIONS. THEY'RE 9 CONNECTED TO OTHER EQUIPMENT IN DIFFERENT WAYS. SOME 10 USE GASKETS AND SOME DON'T. 11 THEY ARE ON DIFFERENT SYSTEMS. SOME OF THEM 12 ARE ON THESE HOT SYSTEMS MR. PAUL TALKED ABOUT. WELL, 13 THESE SHIPS HAD COLD WATER TOO. SOME OF THEM WERE ON 14 COLD SYSTEMS; SOME OF THEM WERE ON A SEA WATER SYSTEM 15 WHERE THEY BROUGHT SEA WATER IN TO FIGHT FIRES. 16 AND WE'LL PRESENT TO YOU EVIDENCE ABOUT THE 17 DIFFERENT TYPES OF VALVES. THEY WERE MADE BY LOTS OF 18 MANUFACTURERS, NOT JUST CRANE CO. AND NOT ALL THE 19 VALVES CONTAINED ASBESTOS. SOME DIDN'T CONTAIN ANY AT 20 ALL. SOME CONTAINED ASBESTOS GASKETS, SOME CONTAINED 21 ASBESTOS PACKING, AND SOME CONTAINED BOTH. 22 BUT THE EVIDENCE IS GOING TO SHOW YOU THAT 23 CRANE CO. DIDN'T -- FIRST OF ALL, DIDN'T MAKE THE 24 GASKETS OR THE PACKING. THEY MADE THE METAL VALVE. 25 CRANE CO., IF IT PUT ANY ASBESTOS GASKET OR PACKING IN 26 THE VALVES, BOUGHT IT FROM SOMEONE ELSE. CRANE CO. DID 27 NOT PUT INSULATION ON THE VALVES. 28 AND THE NAVY DID NOT BUY ITS INSULATION OR 54 1 HAD TO BE MOVED FROM ONE PART OF, IN THIS CASE, A NAVY 2 SHIP TO ANOTHER WENT THROUGH VALVES. MANY, MANY OF THEM 3 WERE NOT STEAM OR WERE THESE HOT PRODUCTS THAT MR. PAUL 4 TALKED ABOUT. 5 WE'RE GOING TO PRESENT TO YOU EVIDENCE THAT 6 CRANE CO. IS A COMPANY THAT'S OVER 150 YEARS OLD. 7 STARTED IN THE 1800S, BEEN MAKING VALVES EVER SINCE. 8 AND THE PEOPLE OF CRANE CO. WORKED VERY HARD TO DESIGN 9 AND SELL A SAFE PRODUCT, AND THAT IT WAS IMPORTANT TO 10 THE COMPANY TO SUPPORT THE WAR EFFORT BY MAKING THESE 11 PRODUCTS THAT THE NAVY NEEDED TO KEEP THE SHIPS MOVING. 12 WE'RE GOING TO PRESENT TO YOU EVIDENCE THAT 13 THE ASBESTOS GASKETS AND PACKING USED IN THE VALVES WAS 14 NOT HARMFUL, DID NOT CAUSE OR CONTRIBUTE TO MR. 15 WOODARD'S DISEASE. 16 WE'RE ALSO GOING TO SHOW YOU THAT -- ABOUT 17 ASBESTOS, IN GENERAL, THAT NOT ALL ASBESTOS EXPOSURE 18 CAUSES AN INJURY. 19 WE BELIEVE THE EVIDENCE WILL SHOW THAT THE 20 PLAINTIFFS' VIEW OF THIS IS OVERSIMPLIFIED; THAT WHEN 21 THEY SAY EVERY TIME YOU'RE EXPOSED, IT ADDS TO THE DOSE, 22 AND THAT'S ALL CONTRIBUTORY, THAT'S NOT WHAT THE SCIENCE 23 SHOWS. WE'LL PRESENT THAT THROUGH CROSS-EXAMINATION Ol 24 PLAINTIFFS' WITNESSES AND THROUGH THE WITNESSES THAT WE 25 CALL. 26 BUT EVERYBODY IS EXPOSED TO BACKGROUND 27 LEVELS OF ASBESTOS. YOU'RE GOING TO HEAR THAT FROM, I 28 BELIEVE, THE VERY FIRST WITNESS THAT'S GOING TO TESTIFY,