Document x1ddYb3gewz34K15mJ5jwr0py

1 Mr. Smith, please. Page 582 2 READING OF DEPOSITION OF RONALD W. HILL 3 TAKEN ON AUGUST 25, 1987 4 (Whereupon, the questions were read by Mr. 5 Smith and Mr. McGowan and the answers were read by Mr. 6 Shellenberger.) 7 MR. SMITH: Thank you. 8 Ronald Hill after having been first duly 9 sworn was examined and testified as follows: 10 BY MR. SMITH: . 11 Q Mr. Hill, what is your birth date? 12 A December 13th, *38. 13 Q And so you are 48 years old? 14 A Yes. 15 Q Where were you born? 16 A West Jersey Hospital inCamden. 17 Q What is the first residence that you 18 remember? 19 A 112 Rich Avenue. 20 Q Where is that? 21 A Berlin. 1 Q Mr. Hill, how far did you go in school? 2 A I went to the 8th grade, and then I went a 3 year and a half to vocational. 4 MR. SMITH: Skipping to page 28. 5 BY MR. SMITH: 6 Q After working at American Pulley, you went 7 back to Kelly Carpet? 8 A Yes . 9 Q Do you know the year you left Kelly Carpet? 10 A 1960. 11 Q Where did you go to work then? 12 A Owens-Corning Fiberglas in Berlin. 13 Q Mr. Hill, you mentioned that you went to 14 work at Owens-Corning Fiberglas in 1960. 15 What was the reason that you sought 16 employment there? 17 A Higher pay. 18 Q Than at Kelly Carpet Company? 19 A Yes. 20 Q What was your first job duty at the Owens21 Corning Fiberglas plant? Page 583 1. A I was a stripper. Page 584 2 Q I assume that means you stripped pipe 3 molds? 4 A Yes. Took the wear out of the molds. 5 Q Did you start working there in, what was it, 6 July 1960? j 7 A July the 18th, 1960. 8 Q Was there any ware left over like caked on 9 the inside of the mold after you took the pipecovering 10 out? 11 A Yes. 12 Q Was anybody responsible for getting that 13 leftover ware out of the mold? 14 A No. Just fell on the floor, blew around 15 with the fans. 16 Q Was working as a pipe mold stripper a dusty ; 17 j ob? 18 A Yes. 19 Q How long did you work as a pipe mold 20 stripper 21 A About two years, I believe. 1 Q And the entire time it was on number 2 Page 585 2 production line? 3 A YV es . 4 Q During those two years, did you ever speak 5 to anyone at the Owens-Corning plant about the dangers 6 of asbestos dust? . 7 A No. Nobody knew anything about asbestos 8 dust. 9 Q Did a supervisor ever ask you to wear a 10 respirator during those two years? i 11 A No. 12 Q They never instructed you to wear one? 13 A No. 14 Q During those two years, did you ever see any 15 signs in any areas of the plant instructing that ^ 16 respirators should be used? 17 A No. 18 Q During those two years, did you ever have 19 conversations with any of your co-workers about the 20 dustiness or the conditions? 21 A We didn't like the dust, but there was zsmttmtaias 1 nothing we could do about it. It was just there. Page 586 2 1 Q Do you know if you or any of your co-workers 3 complained to the supervisor at OCF about the dust? 4 A I don't know. 5 Q Did you? 6 A I didn't complain because it was there. I 7 just thought it was the way it was. 8 Q While you were working as a stripper on 9 number 2 production line, were there exhaust vents on 10 that line designed to suck up airborne dust? 11 A No. When I was on there, I believe it was a 12 blower-type thing that blew the dust off. 13 I don't believe it sucked it up because all 14 around it was all piles of the dust that it blew off. 15 Q After you worked as a pipe mold stripper, 16 what were your next duties at the Owens-Corning 17 Fiberglas plant? 18 A I went into finishing. 19 Q What is entailed in finishing? 20 A . I worked on a saw line. They run the ware 21 through a saw and then up a conveyor belt and then 1 packers pack it and it goes on out to the warehouse. Page 587 2 Q So you actually worked on the saw itself? 3 A I worked packing for 10 years. ' 4 Q So you actually put the ware in the boxes? 5 A Right. 6 Q Did you work on any other part of the 7 finishing line other than the packing? 8 A I was a sawsetup manafter that. 9 Q What did you do as a packer? 10 A The ware would come up line, sometimes you 11 will put tape around it, other times put a piece of 12 cloth around it and put it in the box. 13 Q What was the tape or cloth designed to do? 14 A The tape was designed to just hold the ware 15 together, keep it from falling apart, and the cloth 16 was a way of putting it on the pipe. They would 17 somehow glue it, the overlap, and that would hold it 18 on the pipe. 19 Q So thecloth wasglued onto the pipe? 20 A Yes. 21 Q Then you put the ware with the cloth or tape 1 into a box? Page 588 2 A Right. 3 Q And you shut the box? 4 A It went through a conveyor line, through a 5 carton sealer and then onto a pallet. 6 Q Now, how big were these individual boxes 7 that you would put the ware in? 8 A Well, they were all three feet long, not 9 counting the flaps. 10 Q Do you remember the years that you worked as 11 a packer 12 A Must be from '62 to '72, I guess. I can't 13 be sure. 14 Q Mr. Hill, do you know what Kaylo is? 15 A That is the product we are talking about. 16 Q Kaylo is what you put into the boxes? 17 A Yes. 18 Q What did the boxes of Kaylo look like? 19 A Just the box itself? 20 Q Yes. I mean, was there printing on it? 21 What color were they? Was there writing? 1. A The boxes were printed with Owens-Corning Page 589 2 Fiberglas. 3 Q So it said Owens-Corning Fiberglas. 4 Was the printing a certain color? 5 'A Yes, red. 6 Q Were the boxes themselves a cardboard-kind 7 of color? 8 A Yes, corrugated cardboard. 9 Q Then they had red printing that said Owens- 10 Corning Fiberglas? 11 A Yes, Kaylo. 12 Q Kaylo was also on it? 13 A Yes . 14 Q What color printing was that in? 15 A That was in red, also. 16 Q Do you remember other than the OCF label and 17 the Kaylo label whether there was any other printing 18 on the boxes? 19 A Just on the bottom, the manufacturer's 20 number and carton size. 21 Q Those are like lot numbers and that kind of 1 thing? Page 590 2 A Yes. The size of the carton and a carton - 3 excuse me, an A carton, and a D carton. 4 Q Anything else? 5 A No. 6 Q When you were in the finishing department 7 packing boxes, did you see any warnings on the \ 8 boxes - 9 A No. 10 Q -- about the dangers of Kaylo? 11 A No. 12 Q No? 13 A No. 14 MR. SMITH: Move to page 57, please. 15 BY MR. SMITH: 16 Q While you were working in thefinishing 17 department as a packer, did a supervisor ever tell you 18 that you should wear a respirator? 19 A No. 20 Q While you werein the finishing department 21 as a packer, did you ever complain to a supervisor 1 about dusty conditions? Page 591 2 A No. Dust was everywhere, just a way of 3 life. 4 Q Do you know of any co-workers who complained 5 about dusty conditions? 6 A No. 7 Q Can you compare the dustiness of your job as 8 a pipe mold stripper with the dustiness of your job as 9 a packer? 10 Which one was more dusty? Were they the 11 same? 12 A I would say the dust was finer packing 13 because it come through the saw, but as far as one 14 being dustier than the other, it is -- 15 Q It is pretty much the same? 16 A Yes. 17 Q While you were working as a packer, were 18 there any exhaust hoods, exhaust fans in your working 19 area? 20 A No. 21 Q There was nothing to suck the dust up out of 1 the area? Page 592 2 A Nothing whatsoever. 3 Q Was there a time at which OCF installed 4 ventilation fans that would suck dust out of the plant 5 area? 6 A Yes. 7 Q Do you remember when that was? 8 A Not exactly, no. 9 MR. McGOWAN: Page 59, line 2. 10 BY MR. McGOWAN: 11 Q After you worked as a packer, you worked as i 12 a saw setup man? 13 A Yes. 14 Q How long did you do that? 15 A Up until about six months ago. . 16 Q What are the duties of a saw setup man? 17 A A few years ago they took the saw setup away 18 from me and I still drove the truck and did everything 19 I did before, but the crew sets the saw now, but 20 before that, I drove the truck, I brought the ware, I 21 set the new saw, moved the blades in and out to suit Page 593 1 the different sizes of the ware, and so it come out to 2 the right size so it fit on a pipe. 3 Q You mentioned several things and I would 4 like to try and go through them one at a time. 5 You drove a truck? 6 A Yes . 7 Q What type of truck was that? 8 A A forklift truck. 9 Q From where to where did you drive it? 10 A Around the stripping lines. The saw was 11 near the stripping lines at the time. 12 Q Okay. 13 A I would have to run around and get cages and 14 bring them back, set them up to the saw, take the 15 empty cages away, put them over where the strippers 16 were who were taking the ware out of the molds. That 17 is how to rotate them. 18 Q So the forklift picked up a cage full of 19 ware? 20 A Right. 21 Q Took it over to the saw? 1. A Right. Page 594 2 Q You would set up the saw for the proper 3 cut? 4 A Right. 5 Q You would take an empty cage back to the end 6 of the production line so they could fill it with more 7 ware? 8 A Right. 9 Q So the job entailed driving the forklift and 10 setting the saw? 11 A Right. 12 Q In the areas of the production line is where 13 the saws were? 14 A Right. 15 Q You have done that right up to the present 16 except they took the saw adjustment away? 17 .A Setup. 18 Q That was a few years ago that they took the 19 saw away? 20 A A couple of years ago, I guess. 21 Q You testified before that during the entire j 1 time that you worked as a fork truck driver and a saw Page 595 2 setup man, that you wore a respirator every day. 3 A Yes, from '66 or '65 on every day. 4 MR. SMITH: I think I will read the next 5 couple of questions. 6 BY MR. SMITH: 7 Q Was your job as a forklift driver and saw 8 setup man a dusty job? 9 A Yes. 10 Q Do you know the source of the dust in that 11 area of the plant? 12 A Driving the truck, the dust off the cages 13 blew while you were bringing them around to put them 14 up to the saw. 15 Q The cages were in front of you when you were 16 driving? 17 A Yes. You had to take them forward and then 18 there was dust off the saw. 19 20 me? MR. SMITH: Now to page 75. Are you with ! 21 MR. SHELLENBERGER: Yes. 1 BY MR. SMITH: Page 596 2 Q Mr. Hill, do you remember the first time you 3 became aware of asbestos could be dangerous to your 4 health? 5 A In the late '70s. 6 Q Do you remember how that was brought to your 7 attention? 8 A I believe it was an article in the paper. 9 Q In a regular newspaper? 10 A Yes. 11 Q Prior to that time no one at the Owens12 Corning Fiberglas plant had told you that asbestos was I 13 a dangerous substance? 14 A No. 15 MR. McGOWAN: 77, line 3. 16 BY MR. McGOWAN: 17 Q While you were at OCF, did the company have 18 programs under which it would give physical ; 19 examinations to the employees? 20 A Yes . 21 Q When did that program start, do you know? ; 1 A I can't remember specifically when it 2 started. I think they just gave us X-rays. I am not 3 sure how it started. 4 Q When you started working there in 1960, did 5 you receive an X-ray? 6 A I don't recall. I don't know. 7 Q At some point during your time at OCF, did 8 they start having annual X-rays? 9 A Yes. 10 Q Do you recall when that was? 11 A No, not really. 12 Q Was there anything else involved in the 13 physical other than X-rays? 14 A The doctor would give you a checkup at the 15 plant. I believe that started like once a year like 16 the X-ray 17 Q Was that an OCF doctor or someone that they 18 called in from the outside? 19 A No, it was an OCF doctor, the plant doctor. 20 Q Do you recall the names of the plant 21 doctors at the Berlin plant? Page 597 1- A There is a doctor from ACCO, I can't Page 598 2 remember his name. No, I can't remember the name. 3 MR. SMITH: Page 79. 4 BY MR. SMITH: 5 Q When you were given these physicals, did 6 they appear actually at the plant or did you go to a 7 doctor's office for them? ; 8 A We get them at the plant now. We used to go 9 out for X-rays, and I think the plant doctor gave us 10 the physicals. 11 Q Did the doctors ever discuss the results of 12 the X-rays or physicals with you? 13 A No. i 14 MR. McGOWAN: 132. 15 BY MR. McGOWAN: 16 Q Now, when you had these physicals by Owens- 17 Corning doctors, were these doctors that were employed 18 by Owens -Corning? 1 19 A Yes. ! 20 Q Were there any outside doctors that Owens- 21 Corning used or sent to you? 1. A Not for physicals that I recall, no. 2 Q The doctors that were employed by Owens- 3 Corning, did you ever have occasion to ask them any 4 questions about your health after your testimony was 5 done? 6 A Only in the latter years, last four or five 7 years. 8 Q On the occasions that you asked them 9 questions , did they answer the questions that you 10 asked them? 11 A Yes. 12 MR. McGOWAN: I believe that is all, Your 13 Honor. 14 THE COURT: Thank you. 15 Next, please. 16 MR. SMITH: At this time, Your Honor, I 17 would like to publish to the jury discovery responses 18 by Owens- Illinois and Owens-Corning Fiberglas 19 regarding some foundational matters, corporate 20 history, products. 21 THE COURT: Please. Page 599 j I 1. MR. SMITH: Thank you. Page 600 2 As part of the pretrial discovery in this 3 case we have asked the defendants to admit to certain 4 matters or give us some information, and I am going to 5 read some admission requests and some interrogatory 6 answers by the two companies I have just identified. 7 First will be Owens-Illinois, and this will 8 be our admission request number 1. 9 Ms. Tostanoski, if you have any problems, 10 just let me know for following along. 11 MS. TOSTANOSKI: Certainly. 12 PRESENTATION OF DOCUMENTS ' 13 MR. SMITH: The Owens-Illinois Glass 14 Company -- I will start over. I am sorry. 15 Owens-Illinois has admitted that the Owens- 16 Illinois Glass Company was incorporated in 1929 under 17 the laws of Ohio. 18 Owens-Illinois has also admitted that on 19 April 28, 1965, Owens-Illinois Glass Company changed 20 its name to Owens-Illinois, Inc. 21 That was request number 2. Page 601 1 Number 4. We asked them in 1962 -2 Owens-Illinois Glass Company obtained authorization to 3 do business in the State of Maryland. 4 Their response, on May 31, 1962, Owens5 Illinois Glass Company obtained authorization to do 6 business in the State of Maryland. 7 Number 9. In admission response number 9, 8 Owens-Illinois stated, in 1953, this defendant entered 9 into a sales agreement with Owens-Corning Fiberglas 10 Corporation in which it agreed to the sale of 11 asbestos-containing products to that corporation. 12 This defendant believes that it ceased the 13 general marketing and sales of its asbestos-containing 14 thermal insulation products at that time, disbanded 15 its sales force and that thereafter Owens-Corning 16 Fiberglas Corporation was the primary marketer of its 17 product until the sale of the division to 18 Owens-Corning Fiberglas Corporation in 1958. 19 In response to admission request number 10, 20 Owens-Illinois stated that this defendant has found 21 information in its records which indicate that at 1 least in 1956 it placed Owens-Corning Fiberglas Page 602 2 Corporation's logo on some of its boxes. 3 Owens-Illinois has admitted that on April 4 30, 1958, Owens-Corning Fiberglas purchased all 5 properties, products, patents, trademarks, materials 6 and assets of the Kaylo division of the Owens-Illinois 7 Inc. Owens-Illinois stated admitted as set forth in 8 Exhibit I. 9 Exhibit I is the sales agreement between 10 Owens-Illinois and Owens-Corning Fiberglas dated April 11 30th, 1958, which we have marked as our Exhibit 1054. 12 I would just like to read a couple of 13 sentences from the sales agreement between Owens- 14 Corning and Owens-Illinois. 15 O-I hereby sells certain of the properties 16 hereinafter more particularly described as the Kaylo 17 division of O-I under the following terms and 18 conditions. 19 Paragraph 7 it states, O-I will permit OCF 20 to have such access as OCF may desire, the books, 21 records, contracts, orders, files, and properties of Page 603 1 the Kaylo division and as promptly as practicable, O-I 2 will deliver to OCF all books, records, contracts, 3 orders, and files of the Kaylo division except such as 4 0-1 desires to retain and as to these O-I will make 5 and deliver to OCF copies of any OCF desires. 6 Now I would like to read a few discovery 7 responses by Owens-Corning Fiberglas. 8 Number 11. OCF has stated, OCF admits that 9 it was formed as a result of an agreement dated 10 October 28, 1938, between Owens-Illinois and Corning 11 Glass Works. 12 Number 17 it is stated, OCF admits that from 13 1938 until June 29, 1949, some members of the Board of 14 Directors of Owens-Illinois and Corning Glass Works 15 served on the Board of Directors of OCF. 16 In response number 15 it is stated, OCF 17 admits that Harold Boeschenstein was a director of 18 both OCF and Owens-Illinois from 1938 to June 29, 19 1949. B-o-e-s-c-h-e-n-s-t-e-i-n. I think I am 20 pronouncing that correctly. 21 In interrogatory -- supplemental 1 interrogatory answer number 100, OCF has stated the Page 604 2 following: 3 OCF states that Owens-Illinois and Corning 4 Glass Company were parent companies for OCF. From 5 1938 until 1947, various Owens-Illinois and Corning 6 Glass officials served as officers and/or on the Board 7 of Directors of OCF. 8 The initial officers of OCF were Harold 9 Boeschenstein, president and general manager, formerly 10 vice-president and general manager of Owens-Illinois; 11 James Slater, he was the OCF vice-president, formerly 12 director of research glass fiber laboratories of 13 Owens-Illinois; W.P. Zimmerman was the OCF 14 vice-president and formerly general manager of the 15 glass fiber and block division of Owens-Illinois; 16 Harold Boeschenstein, again, he was also the 17 treasurer; and H.R. Winkle was the OCF comptroller and 18 formerly general auditor at Owens-Illinois. 19 The initial Board of Directors of OCF was as 20 follows: 21 Harold Boeschenstein, he was the president rfi! 1 of Owens-Corning; William Levis, vice-president of Page 605 2 Owens-Illinois; C.B. Belknap, executive vice- 3 president of Owens-Illinois; and Urban E. Bowes, 4 B-o-w-e-s, was director of research of Owens- 5 Illinois. 6 After June 29, 1949, no one with any 7 financial interest in or connection to Owens-Illinois 8 or Corning Glass was permitted to serve on the OCF 9 Board of Directors. 10 In OCF's admission response number 16 it is 11 stated, OCF admits that on December 10, 1947, the U.S. 12 Justice Department filed an antitrust suit against 13 OCF, Owens-Illinois, and Corning Glass Works. 14 On June 29, 1949, the parties to the 15 antitrust suit entered into a consent decree whereby 16 the members of OCF's Board of Directors would have no 17 current financial interest in or connection to Owens- 18 Illinois. 19 Accordingly, Harold Boeschenstein resigned 20 from Owens-Illinois Board of Directors. 21 OCF response to our interrogatory number 1, Page 606 1 they stated, OCF states that it was incorporated under 2 the laws of the State of Delaware on October 31, 3 1938. 4 Its principal place of.business is in the 5 State of Ohio, and its currents address is Fiberglas 6 Tower, Toledo, Ohio. 7 OCF has been authorized to transact business 8 in the State of Maryland since August 20, 1964. 9 OCF further states that it purchased the 10 assets of the Kaylo division of Owens-Illinois in May 11 1958, specifically the Berlin, New Jersey 12 manufacturing place. 13 OCF believes that Owens-Illinois ceased 14 distributing and selling Kaylo at that time that it 15 acquired the Berlin plant in 1958. 16 OCF first distributed Kaylo in 1953 and 17 began to manufacture Kaylo in 1958. 18 OCF also purchased the assets of the 19 Chembest division of Unarco in 1970, specifically the 20 Bloomington, Illinois facility. 21 OCF believes that Unarco ceased distributing xMa&at 1 and selling Unarcoboard at the time it acquired the Page 607 j 2 Bloomington facility. OCF began to manufacture and 3 distribute Unarco Fyrcor at the time it acquired 4 Chembest in 1970. 5 In a supplement to the same interrogatory 6 answer number 1, OCF stated on June 27, 1952, OCF 7 purchased certain assets of the marine engineering and j 8 supply company. j 9 OCF operated these assets under the name 10 Fiberglass Engineering and Supply Company which came j 11 to be known as the contracting and supply division and i 12 eventually the contracting division of Owens-Corning j 13 Fiberglas. 14 In response to admission request number 110, 15 OCF admits that it had contracting units which | 16 operated as the contracting division of OCF from ! 17 January 1950 until February 1987 when this division j 18 was sold. j 19 Now I am jumping back to Owens-Illinois. . | 20 This is their response to interrogatory number 5. j 21 In response to our question about what Sa 1 products, asbestos products they sold or used, they Page 608 2 stated as follows: 3 Owens-Illinois Glass Company began a limited 4 pilot plant operations involved in the production of 5 asbestos-containing products in 1943. 6 It began the manufacture of commercial 7 quantities of asbestos-containing products in about 8 1948. It continued such manufacture until about April 9 30, 1958. 10 American Structural Products Company, a 11 wholly-owned subsidiary of Owens-Illinois Glass 12 Company, engaged in the manufacture, sale, 13 distribution of asbestos-containing products from 14 about January 1948 until June 1949 when it became the 15 Kaylo division of Owens-Illinois Glass Company. 16 The Kaylo division of this defendant 17 continued to manufacture such products until about 18 April 30, 1958, when it was purchased by Owens-Corning 19 Fiberglas Corporation from this defendant effective on 20 that date. 21 In interrogatory response number 12, we 1 asked them to identify their manufacturing facilities 2 and Owens-Illinois stated: 3 This defendant's manufacturing plants were 4 located in Berlin, New Jersey, in Sayreville, New 5 Jersey. The Berlin plant was in operation from 6 approximately 1943 until on or about April 30, 1958. 7 The Sayreville plant was in operation from 8 February 1948 until about April 30, 1953. 9 In response to our interrogatory number 8 10 when we asked about asbestos-containing products, 11 Owens-Illinois stated in response to the question 12 about the brand name, it is called Kaylo. 13 . And in response to the composition of the 14 product, Owens-Illinois stated: 15 Its investigation as to the composition of 16 each such product is continuing, although defendant 17 now believes that its asbestos-containing products 18 were hydrous calcium silicates containing between 13 19 percent and 25 percent asbestos. 20 Chrysotile asbestos was the primary type 21 apparently used. Amosite was used to a lesser Page 609 1 extent. Page 610 2 In response to our admission request number 3 15, Owens-Illinois has admitted the following: 4 Owens-Illinois knew that asbestos-containing 5 products it manufactured, sold and/or distributed 6 would be used to insulate equipment, structures, and 7 pipes which generated heat. It has admitted it would 8 be used by asbestos insulators and by pipecoverers. 9 In response to number 16, the question was, 10 you knew that in the normal and expected use of your 11 asbestos-containing products that those products would 12 be, and Owens-Illinois' response was, this defendant's 13 asbestos-containing industrial insulation was 14 manufactured in two forms, block and pipecovering. 15 It was a premolded rigid product which was 16 not intended or required to be molded or mixed in 17 application. 18 It was manufactured in standard premolded 19 shapes and sizes and intended to minimize cutting the 20 pieces in application. 21 It appears the product was applied by 1 methods including gluing, tying, strapping or wiring Page 611 2 it to pipe. 3 It appears that a limited amount of its 4 product was cut during application. 5 We also asked some of the similar questions 6 to Owens-Corning. And this is Owens-Corning's 7 response to our interrogatory number 8 where we asked 8 them about its asbestos-containing products. Their 9 supplemental answer is as follows: 10 OCF further states that Kaylo manufactured 11 by OCF from 1958 through 1972 contained amosite and 12 chrysotile asbestos. 13 The approximate percentage of amosite fibers 14 as compared to chrysotile fibers contained in Kaylo 15 varied between one-half and two-thirds of the total 16 percentage of the asbestos content of Kaylo. 17 Kaylo 10 pipecovering and block contained 18 approximately 15 percent asbestos, and Kaylo 20 19 pipecovering and block contained approximately 20 20 percent asbestos. 21 The amount of amosite in Kaylo 10 and Kaylo 1 .20 varied between one-half and two-thirds of the total Page 612 2 asbestos content of those products. 3 The amount of chrysotile in Kaylo 10 and 4 Kaylo 20 varied between one-third and one-half the 5 total asbestos content of those products. 6 In its response, supplemental response to 7 our interrogatory number 22 where we asked them about 8 the description on the boxes, OCF responded: 9 Both -- excuse me, to the best of OCF's 10 knowledge, both OCF's and Owens-Illinois' names 11 appeared on packages of Kaylo distributed by OCF from 12 1953 to 1958. 13 In a document we have marked as Plaintiff's 14 Exhibit OCF-353, this is an internal OCF memo dated 15 November 8, 1966, and I apologize I didn't put it on 16 the overhead, it is just one sentence. 17 This is a memo from an official in New York, 18 Mr. Johnson to OCF officials in Toledo and New York. 19 The memo states, "Asbestos content of Kaylo 20 is about 15 percent, composed of 12 to 13 percent 21 amosite mined in Africa and 3 percent chrysotile mined 1 .in Canada." Page 613 2 I will move these and other documents into 3 evidence at a later date. 4 Just a couple of more discovery responses 5 here. Thank you for bearing with me. 6 In response to our admission request number 7 16, OCF has stated, it admits that it knew its Kaylo 8 asbestos-containing pipe and block insulation would be 9 handled, moved, removed from its container, cut, 10 sawed, installed, and moved. 11 In its supplemental response to admission 12 request number 23, OCF admits that its asbestos- 13 containing insulation products may have emitted some 14 dust, a small percentage of which contained asbestos 15 when the product was cut or sawed during application. 16 OCF also admits that asbestos-containing 17 cements previously manufactured and/or sold by OCF may 18 have emitted some dust, a small percentage of which 19 was asbestos when the product was mixed during 20 application. 21 In response to our admission request number 1 30 -- this is the last one -- OCF admits that from Page 614 2 1953 to 1973, asbestos-containing Kaylo pipe 3 insulation products were generally distributed 4 throughout the United States, including Baltimore City 5 and/or Baltimore County areas of Maryland. 6 Thank you. 7 THE COURT: Thank you, Mr. Smith. 8 MR. SMITH: At this time we would like to 9 read another deposition, Your Honor. 10 This one will be of Edward Ames an employee 11 of both Owens-Corning and Owens-Illinois at various 12 times. 13 THE COURT: When and where was the 14 deposition taken, please. 15 MR. SMITH: As soon as Mr. Shellenberger 16 hands it to me, I will tell you. 17 , THE COURT: Mr. Smith will do the questions, 18 and Mr. Shellenberger will do the answers; and Mr. 19 McGowan will do the defense designations? 20 MR. McGOWAN: Yes, Your Honor. 21 THE COURT: When and where was it taken,