Document zb371aNO7zaoZpaenDeOoZMR3
TF-5520
1 IN THE DISTRICT COURT
2 CAMERON COUNTY, TEXAS
3 138TH JUDICIAL DISTRICT
4 --oOo-- I
5 SAMUEL OLIPHANT WOOLEY, JR. , et al. ,
6 Plaintiffs,
7 -vs-
No. 94-09-04823 B
8 OWENS-CORNING FIBERGLAS
9 CORPORATION, et al..
10 Defendants.
/
11
12
13
14 Deposition of
15 DOUGLAS WAYNE MERRILL
16 Monday, November 20, 1995
17 By Allen M. Stewart, Attorney at Law
18 DUPLICATE
19 FILE COPY
20
21 Reported by
22 TERI DARRENOUGUE, CM, CRR CSR NO. 5106
23
PLAINTIFF'S EXHIBIT
UC-5166.
24
PENINSULA REPORTING 25 CERTIFIED SHORTHAND REPORTERS
147 WINDSOR DRIVE, SAN CARLOS, CALIFORNIA 94070 26 (415) 594-0677
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ORIGINAL
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1 A. Approximately, yeah.
2 q. Do you recall having any> specific conversations with
3 someone from Carey Canada regarding the health effects of
4 asbestos in 1972?
5 A.
I don't recall anything specific.
6 q.
And what about the Union Carbide Company? Do you
7 recall any specific conversations you had with anyone at
8 Union carbide regarding the health effects of asbestos in
9 1972?
10 A.
I don't recall.
11 Q. What about any year? Do. you recall any
12 conversations you had with Union Carbide in any year
13 regarding the health effects of asbestos?
14 A.
I don't recall any, no. .
i
15 Q. Let me ask that question with regard to Carey
16 Canada. Do you recall having any specific conversations
17 with anyone at Carey Canada at any time about the health
18 effects of asbestos?
19 A. No.
;
20 Q. Johns-Manville. Do you recall having a specific
21 conversation with anyone at any time from Johns-Manville
22 regarding the health effects of asbestos?
23 A.
I vaguely recall having a -- them putting on a
24 seminar or something, but I don't recall anything
25 specific about it.
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26 Q. Where was the -- You're saying Johns-Manville? Do
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PENINSULA REPORTING (415) 594-0677 !i I
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1 THE WITNESS: Nothing specific. It was just
2 generally that the asbestos wasn't a hazardous risk.
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3 Q.
(BY MR. STEWART): So your testimony today is people
4 from Johns-Manville, Carey Canada and Union Carbide told
5 you that there was no risk from asbestos?
6 MR. CHURCHILL: Object to the form of the 7 question. 8 THE WITNESS: The communication from the
9 asbestos companies were that'there was not a hazardous
10 use by using asbestos the way we were using it, small
11 amounts.
i
12 Q.
(BY MR. STEWART): And did you do anything to either
t
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13 confirm or contradict those alleged representations to
1
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14 you?
*
15 A. Well, there would have been some confirmation having
16 come from three different companies. Other than that,
it
17 no.
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18 Q. But you can't tell me as you sit here today who from
19 those three companies told you that information; correct?
20 A. It seems to me they had a representative out of
21 Denver, Colorado for Union -- for Johns-Manville. His
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22 name might have been McCarthy or McCormick or something
23 like that.
24 Q. And it's true as you sit here today you can't tell
25 me what the substance of the conversations that you had
26 with him were; correct?
PENINSULA REPORTING (415) 594-0677
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