Document v1ODNZz8aJ0nwmOXaDNw8pj0Z

1 IN THE COURT OF COMMON LAKE COUNTY, OHIO i 2 Case No. 91CV001653 3 RUTS H. BURNHEIMER. etc., ) 4) Plaintiffs, ) S vs- iORIGINAL 6 UNIROYAL CHEMICAL CO., INC., ) FOR COURT C. 7 et al.( ) ) e Defendants. ) 9 10 11 Jack Besoner 6 Assocs. 255 S.E. 14th Street 1 2 Suite 2-B Fort Lauderdale, Florida 1 3 November 12, 1992 10:00 - 12:40 p.m. 14 15 16 1 7 DEP0SITION OF JACK H. WOLFSIE 16 1 9 Taken before Jeffrey M. Goldstein, 20 Certified Shorthand Reporter and Notary Public in 2 1 and for the State of Florida at Large, pursuant to 2 2 Notice of Taking Deposition filed in the above 23 cause. 24 25 JACK BESONER & ASSOCIATES FORT LAUDERDALE. FL. (305)763-1608 URL 23196 21 1 library with current and available materials? 2 A. Well, first of all. I suI bscribe to all 3 the worthwhile scientific journals that had all of 4 this material. Also too. don't forget -- And I S joined any number of organizations. For example, 6 I was an active member of the American Academy of 7 Chemical Toxicology. So if they had any, in any 8 of their programs they dealt with, let's say, 9 whether It was vinyl chloride or A.B.C substance. 10 It didn't matter, then that would become part of 11 my package of information. 1 2 Q. Where is the greatest exposure to vinyl 1 3 chloride? Is It in the creation of the monomer, 14 or Is it In the creation of the polymer, or is it 1 5 in processing and fabricating? 1 6 A. You mean, where the greatest likelihood 1 7 of where somebody could become exposed. 1 8 Q. Yes, sir . 1 9 A. 1 would say maintenance people that 20 tear apart equipment. I would also say two people 2 1 taking samples, if they weren't careful, far more 22 than in ordinary day-to-day operating. 23 Q. Do you understand what I mean when 1 24 say creation of the monomer versus polymerization, 25 versus processing and fabricating? JACK BESONER 6 ASSOCIATES FDRT LAUDERDALE, FL. (305)763-1608 *