Document xjLp99wrrEreM9k6zko4Mznmm

FILE NAME Pratt & Whitney PW DATE 1992 DOC PW004 DOCUMENT DESCRIPTION Legal - Deposition of Newton Ketcham CARUISIDE CARUISIDE _ a i \ RUSSELL ALLEN ET AL 126,986 IN THE DISTRICT COURT VS. OF JEFFERSON COUNTY TEXAS AMERICAN PETROFINA ET FRENCH HICKS ET AL AL 60TH JUDICIAL DISTRICT 134,614 IN THE DISTRICT COURT VS. : JEFFERSON COUNTY TEXAS : BETHLEHEM STEEL CORP ET AL 58TH JUDICIAL DISTRICT | | ROOSEVELT SCOTT H 141 4 IN THE DISTRICT COURT VS. : JEFFERSON COUNTY TEXAS AMERICAN MARGARET OPTICAL CORP ET AL 138,633 138,633 FAULKNER ET AL ; 60TH JUDICIAL DISTRICT IN THE DISTRICT COURT VS. JEFFERSON COUNTY TEXAS AKRON CHEMICAL CO ET AL : 58TH JUDICIAL DISTRICT 136,143 KEITH GIBLIN ET AL ee IN THE DISTRICT COURT VS. : JEFFERSON COUNTY TEXAS MOBIL OIL CORPORATION ET AL : 58TH JUDICIAL DISTRICT | 141,216 | JOSEPH E. BARNARD ET UX IN THE DISTRICT COURT VS. SIGNAL INC ET JOYCE A. BORNE ET AL AL : 140,498 JEFFERSON COUNTY TEXAS 172ND JUDICIAL DISTRICT IN THE DISTRICT COURT VS. ' \ \ SIGNAL \ \ NN _ ET AL JEFFERSON COUNTY TEXAS H 58TH JUDICIAL DISTRICT / a Action Court Reporting LEGAL PLAINTIFF'S LEGAL EXHIBIT M. K. Comer _ Post OffBi ox c 44e 49 EWK Charleston WV25364 ALL 340-1020 / 1-800-752-7064 ) Page 2 The deposition of NEWTON KETCHAM in the above- styled suits was taken pursuant to notice before M. K. Comer a Notary Public within and for the State of West Virginia at Larger pursuant to the West Virginia Rules of Civil Procedure commencing at 9:00 a.m. on December 8 and 9 1992 in the Heart of Town Holiday Inn 100 Washington Street East Charleston Kanawha County West Virginia APPEARANCES Appearing on behalf of the Plaintiffs Allen Hicks and Scott 10 JOSEPH C. BLANKS ESQUIRE 11 Reaud Morgan & Quinn 801 Laurel Street 12 Beaumont Texas 77701 13 Appearing on behalf of the Plaintiffs Allen & Faulkner Giblin 14 HERSCHEL L. HOBSON ESQUIRE 15 Hobson & Ferguson 2190 Harrison 16 Beaumont Texas 77701 ' 17 Appearing on behalf of the Defendant 3M 18 MICHAEL J. TRUNCALE ESQUIRE Orgain Bell & Tucker L.L.P. 19 470 Orleans Street Beaumont Texas 77701 20 Appearing on behalf of the Defendant Harwick 23 Chemical Company 22 D. CRAIG SHEW ESQUIRE Smith Shew & Scrivner 120 East 14th Street P.C. P. O. Box 1373 24 Ada Oklahoma 74821-1373 25 we alae oe L L Tetes St DASA.CR Seren 6 ; "so PARTIES NOTICED TO DEPOSITION CONTINUED 2 WOODARD HALL & PRIMM Monsanto Company Edward Carstarphen Douglas Dougherty Page 11 INDEX Plaintiffs Witness December 8 1992 Direct Direct Cross Cross Redirect Recross Redirect Redirect Redirect Recross Newton Ketcham 13 H December 9 1992 10 Newton Ketcham 11 168 289 348 . 12 Plaintiffs 347 oo Exhibits 356 359 B 361 359 Identified 13 KetNewH001 List of Texts and References 14 921208KetNewH002 Subpoena Duces Tecum 15 37 316 491001KetNewH Harvard Notes 16 347 161004KetNewH Curriculum Vitae 17 347 18 9 Defendants Exhibit 20 No. 1 Subpoena Duces Tecum 22 261 22 23 224 25 Reporter's Certificate Pages 364-366 Ketcham - Direct Hobson Page 14 We represent -- myself and Mr. Blanks represent a number of parties that brought some lawsuits so we are on the opposite side of your employers in the past Do you understand that sir A I do Q Thank you Would you give us a brief sketch of your educational background sir A Okay I attende thde University of Michigan 10 graduated from there in 1939 with a degree of B.S. in 11 Chemistry Then I worked for a while and took a leave of 12 absence went back and spent a year at Harvard University's 13 Graduate School of Public Health and got a Master's Degree 14 in Industrial Hygiene there 15 And after that I have been involved in 16 continuing education activities which are characteristic of 17 the industrial hygiene profession but no more formal 18 schooling 19 Q You finished at Harvard in '49 I believe , 20 A '49 21 Q Where do you currently reside please sir 22 A I reside in South Charleston West Virginia 23 Q And may I ask your date of birth please 24 A October 4 1916 25 0 You were kind enough to provide us a Curriculum A.C.R. Ketcham 1 Direct Blanks contract read Page 347 Q All right sir A Would Carbide be responsible for that or would the contractor be responsible MR BLANKS All right I'm going to have to quit I am hoarse I'm going to pass the witness MR STANTON Let's take a minute break WHEREUPON a brief recess was taken after which the following proceedings 10 were had 11 MR BLANKS Back on the record DIRECT EXAMINATION 13 BY MR HOBSON 14 Q Mr. Ketcham you were good enough to bring with you your notes from Harvard that I requested in yesterday's 16 deposition and we have a copy that has been made and that 17 has been checked as a true and authentic copy and it has 18 been marked as 491001 19 This is a copy of your notes from Harvard that you took that you still have in your possession is that 21 right sir 22 A Yes just thumbing through it I would say this 23 is a copy of my notes 24 WHEREUPON the document referred to was marked as Plaintiffs Exhibit ACR Ketcham - Direct Hobson Number 491001 and Page 348 161004KetNewH for purposes of BY MR HOBSON identification 5 Q And that includes at least some of the notes that you actually took while you were a student of Professor ' Phillip Drinker A. Yes MR HOBSON We will attach these to the 10 deposition transcript so everyone will have copies of it 11 MR MARTIN I would like to ask also that the copy attached to the transcript be Bates numbered so that 13 each of the pages will have a unique number other than just 14 the exhibit number that is on top MR BLANKS We will ask the reporter then to 16 -- well that's fine just start from one and go , - 17 MR MARTIN All right 18 EXAMINATION 19 BY MR MARTIN Q Mr. Ketcham my name is Kirk Martin I have just a few questions for you today to clear up some of the things that I think you tried to talk about during the course of your deposition but may not have gotten a chance to The first is is that a lot of questions have A.C.R.