Document w4Jd0rqG3R5OeZBB6jONN8v4

' GARY AUSTIN Page 30 Page 32 | 1 A I only know that they were being produced in the 1 compatible with high heat applications, and I wanted 2 1960s. I have no idea whether that was the initial 2 to explore that a little bit more with you. We were j 3 time or not. 3 talking about two types, the beaded steel head gasket 4 Q Okay. I'm with you. Do you know the last year that 4 as well as the steel construction exhaust manifold I 5 Dana Victor manufactured beaded steel head gaskets 5 gasket. And I think that you mentioned that those 6 for high heat applications? 6 were the only two high heat application non-asbestos 7 A We still make beaded steel gaskets. 7 containing Dana Victor gaskets that were manufactured 8 Q For high heat applications? 8 at any time during the '60s and 70s; is that 9 A Cylinder head gaskets, I would consider to be high 9 correct? 10 heat applications. 10 MR. CELBA: Object to form 11 Q During the 1960s and the 1970s, other than the beaded 11 THE WITNESS: I guess the question I would 12 steel head gaskets, was there any other asbestos-- 12 have beyond that, those are what I consider to be the 13 Was there any other non-asbestos gaskets that Dana 13 two highest heat applications in an internal 14 Victor was manufacturing that could be used in a high 14 combustion engine or diesel engine, so beyond that 15 heat application, or was that the only one? 15 I'm unclear as to what other areas of an engine you 16 MR. CELBA: Object to form. 16 would consider to be high heat applications. 17 THE WITNESS: Exhaust manifold gaskets were 17 BY MR. VALLAS: j 18 often steel construction. 18 Q Okay. Well, let me ask you that question because 19 BY MR. VALLAS: 19 you're probably more familiar with internal 20 Q Any others you can think of? 20 combustion engines and where Dana Victor gaskets 21 MR. CELBA: Same objection. 21 might be used inside of an engine than I am Let's, 22 THE WITNESS: No, nothing else I can 22 if we can, run through the different types, the 23 recall. 23 different places within an engine that you are 24 BY MR. VALLAS: 24 familiar with where heat would be a concern. Just 25 Q Okay. Do you know the first year that Dana Victor 25 generically speaking, head gaskets intake gaskets. Page 31 Page 33 1 made an exhaust manifold gasket of steel construction 1 exhaust gaskets, whatever the case may be, if you can 2 that could be used in a high heat application? Do 2 just kind of list them for me, that would be great. 3 you know the first year? 3 IH figure out where I'm going to go from there. 4 A No, sir, I do not. 4 MR. CELBA: I'm going to object to the 5 Q I'm sorry, with steel construction that did not 5 form Go ahead. 6 contain asbestos-- Let me back up and ask the 6 THE WITNESS: In general the head gaskets 7 question again. Do you know the first year that Dana 7 and exhaust gaskets I would consider to be the 1 8 Victor manufactured the exhaust manifold steel 8 highest heat portions of an engine. Many of the 1 9 construction gasket that you just mentioned without 9 gaskets beyond that become more what I would describe | 10 asbestos, do you know the first year? 11 A No, I do not. 10 as secondary or ancillary gaskets. They would be I 11 mounting gaskets, that type of gasket, and that would 1 12 Q Do you know the last year? 12 be strictly dependent upon where on the engine that | 13 A There are still some applications that are 14 manufactured to this date. 13 gasket was being used. 14 BY MR. VALLAS: I 1 15 Q Okay. These-- Why don't we do this, we've been going 15 Q Okay. Let's go through-- let's go through what kind I 16 almost an hour. Why don't we take about a 16 of--I'm going to kind of make a list here. I'm | 17 five-minute break? Is that okay? 17 going to put heat gaskets and exhaust gaskets. I'm j 18 A That's fine. 18 sorry, not heat gaskets, head gaskets and exhaust 19 MR. VALLAS: We'll be back with you in just 19 gaskets kind of in a category by themselves. We'll j 20 a second, all right? Thanks. 20 just kind of refer to them for purposes of this 21 (Off the record.) 21 deposition as high heat gaskets. Let's visit a little 22 BY MR. VALLAS: 22 bit about this second category that you're talking 23 Q Mr. Austin, just prior to the break we were talking 23 about, these mounting gaskets. Where might those be 24 about non-asbestos containing gaskets that Dana 24 used in an internal combustion engine where heat was j 25 Victor made that you're familiar with that were 25 a concern? j Henjum Goucher Reporting Services 1-888-656-DEPO 9 (Pages 30 to 33)