Motion-Secondary: HAROLD KOEPKE et al VS. FORD MOTOR COMPANY et al

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                                Kazan, McClain, Satterley & Greenwood

A Professional Law Corporation

* Oakland, California 94607

* www. kazanlaw.com

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+ 55 Harrisos

Jack London Market

+ Fax: (610) 835-4913

(510) 302-1000

Joseph Satterley, Esq. (C.S.B. # 286890)
Ted W. Pelletier, Esq. (C.S.B. # 172938) ELECTRONICALLY
tpelletier@kazanlaw.com

PAZAN MaCLAIN, SATTERLEY & GREENWOOD FILED
A Professional Law Corporation
Jack London Market

55 Harrison Street, Suite 400
Oakland, California 94607

Superior Court of California,
County of San Francisco

JUN 26 2014
Clerk of the Court

Telephone: (510) 302-1000 BY: VANESSA WU
Facsimile: (510) 835-4913 Deputy Clerk
Attorneys for Plaintiffs
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

HAROLD KOEPKE and NANCY KARIDIS- | Case No. CGC-13-276217

KOEPKE,

DECLARATION OF TED W. PELLETIER

Plaintiffs, IN SUPPORT OF AMENDED EXPERT

MIL 1: PLAINTIFFS’ MOTION IN

vs. LIMINE TO EXCLUDE EXPERT

OPINIONS REGARDING EXPOSURE TO

FORD MOTOR COMPANY, ef dl., ASBESTOS DURING SHEET-METAL

WORK

Defendants.

Dept: 624 (Hon. Richard B. Ulmer, Jr.)

Action Filed: December 3, 2013

Trial Date: June 16, 2014

1, Ted W. Pelletier, declare as follows:

1. lam an attorney duly admitted to practice before this Court. I am of counsel at
Kazan, McClain, Satterley & Greenwood, attorneys of record for Plaintiffs. | have personal
knowledge of the facts set forth herein, except as to those stated on information and belief and, as
to those, I am informed and believe them to be true. If called as a witness, I could and would
competently testify to the matters stated herein.

2, Attached hereto as Exhibit A is a true and correct copy of the cover page, reporter-
certification page, and all cited excerpts of the transcript of Harold Koepke’s deposition testimony

on the following dates: January 23, 2014; January 28, 2014; and January 31, 2014.

“TPELLETIER/13 17075. I

PELLETIER DECL. ISO PLAINTIFFS’ EXPERT MIL 1 RE: SHEET-METAL EXPOSURESKazan, McClain, Satterley & Greenwood

A Professional Law Corporation
+ 55 Harrison Steet, Suite 400 + Oakland, California 94607

(510) 302-1000 + Fax: ($10) 835-4913 = www-kavanlaw.com

Jack London Market

3.

Attached.

ereto as Exhibit B is a true and correct copy of the cover page, reporter-

certification page, and all cited excerpts of the transcript of Manfred Boehnke’s May 6, 2014

deposition testimony.

4,

Attached

certification page, and all

deposition testimony.

5.

Trayer in this matter,

6.

certification page, and al

deposition testimony.

7.

certification page, and al

deposition testimony.

8.

signature page.

, and alll 4

Attached

Attache:

Attache

Attache

hereto as Exhibit C is a true and correct copy of the cover page, reporter-

cited excerpts of the transcript of Barry Green’s May 19, 2014

hereto as Exhibit D is a true and correct copy of the Declaration of Frank

, executed on April 17, 2014.

ereto as Exhibit E is a true and correct copy of the cover page, reporter-

cited excerpts of the transcript of Dr. Mary Jane Teta’s June 4, 2014

hereto as Exhibit F is a true and correct copy of the cover page, reporter-

cited excerpts of the transcript of Dr. Coreen Robbins’ June 4, 2014

ercio as Exhibit G is a true and correct copy of the cover page, the

e cited excerpts from the Declaration of Coreen A. Robbins filed in this

matter in support of defendant Bell Industries, Inc.’s motion for summary judgment, executed

May 14, 2014.
9.

Attached

certification page, and al:

deposition testimony.

10.

Attached

certification page, and al

deposition testimony.

il.

ereto as Exhibit H is a true and correct copy of the cover page, reporter-

cited excerpts of the transcript of Dr. Andrew Churg’s May 29, 2014

hereto as Exhibit I is a true and correct copy of the cover page, reporter-

cited excerpts of the transcript of Dr. Allan Feingold’s May 28, 2014

Attached hereto as Exhibit J is a true and correct copy of the cover page, reporter-

certification page, and al

deposition testimony.

TPELLETIER/1317075.1

cited excerpts of the transcript of Dr. Samuel Spivack’s June 5, 2014

2

PELLETIER DECL. ISO PLAINTIFFS’ EXPERT MIL 1 RE: SHEET-METAL EXPOSURES9
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deposition testimony.

certification page, and all cited excerpts of t

deposition testimony.

certification page, and all cited excerpts of

deposition testimony.

certification page, and all cited excerpts of tl

deposition testimony.

certification page, and all cite

deposition testimony.

17, Attached hereto as Ex!

certification page, and all cite

deposition testimony.

6. Attached hereto as Ex!

excerpts of tl

excerpts of tl

2. Attached hereto as Exhibit K is a true and correct copy of the cover page, reporter-

e transcript of Dr. David Garabrant’s June 2, 2014

3. Attached hereto as Exhibit L is a true and correct copy of the cover page, reporter-

¢ transcript of Dr. Dennis Paustenbach’s June 6, 2014

4. Attached hereto as Exhibit M is a true and correct copy of the cover page, reporter-

e transcript of Dr. Jeffrey Birkner’s June 9, 2014

5. Attached hereto as Exhibit N is a true and correct copy of the cover page, reporter-

¢ transcript of Dr. Patrick Hessel’s June 6, 2014

hibit O is a true and correct copy of the cover page, reporter-

transcript of Dr. William Krebs’ June 9, 2014

hibit P is a true and correct copy of the cover page, reporter-

je transcript of Kyle Dotson’s June 11, 2014

18. Attached hereto as Exhibit Q is a true and correct copy of the cover page, reporter-

certification page, and all cite

deposition testimony.

excerpts of t

transcript of Dr. Dennis O’Brien’s June 9, 2014

19. Attached hereto as Exhibit R is a true and correct copy of the cover page, reporter-

certification page, and all cited

excerpts of t

¢ transeript of Dr. Michelle Minikel’s March 13,

2014 deposition testimony, attaching the cover page and relevant excerpt of Exhibit 2 to that

deposition.

20. Attached hereto as Exhibit S is a true and correct copy of the cover page, reporter-

certification page, and all cited excerpts of the transcript of Patricia Hall’s June 9, 2014 deposition

testimony.

TPELLETIER/1317075.1

3

PELLETIER DECL, ISO PLAINTIFFS’ EXPERT MIL 1 RE: SHEET-METAL EXPOSURESKazan, McClain, Satterley & Greenwood

A, Professional Law Corporation

+ Oakland, California 94607

x: (510} 835-4913 + waww.kazanlaw.com

Jack Londen Market + 55 Harrison Street, Suite 400

(610) 302-1000 +

21. Attached hereto as Exhibit T is a true and correct copy of the cover page, reporter-
certification page, and all cited excerpts of the transcript of Alan Rogers’ May 30, 2014 deposition
testimony.

22. Attached hereto as Exhibit U is a true and correct copy of the cover page, reporter-
certification page, and ail cited excerpts of the transcript of Dr. Tim Oury’s June 3, 2014

deposition testimony.

23, Attached hereto as Exhibit V is a true and correct copy of the cover page, signature

page, and all cited excerpts of the Declaration of Dr. Samuel Spivack filed in this matter in support
of defendant Bell Industries, Inc.’s motion for summary judgment, executed May 14, 2014.
I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct and that this declaration was executed on June 26, 2014, at Oakland,

California.
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TPELLETIER/1317075.1 4

PELLETIER DECL. ISO PLAINTIFFS’ EXPERT MIL | RE: SHEET-METAL EXPOSURESExhibit A=

oo ON DOD ON FR WO N

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
=~ 000--—
HAROLD KOEPKE AND NANCY KARIDIS-KOEBPKE,
Plaintiffs,
vs. No. CGC13 276217
FORD MOTOR COMPANY, et al.,

Defendants.

VIDEOTAPED
DEPOSITION OF HAROLD KOEPKE

VOLUME I, Pages 1 to 235

Taken before EARLY LANGLEY, CLR, RSA, RMR
CSR No. 3537

January 23, 2014

Aiken Welch Court Reporters
One Kaiser Plaza, Suite 250
Oakland, California 94612
(510) 451-1586/(877) 451-1580
Fax: (510) 451-3797

www.aikenwelch.com10 (Pages 37 to 40)

37 39
(4) Q. When did you speak to them? qq) A. Mother's. =
(2) A. Three, four weeks ago. (2) Q. What was his name?
(3) Q. Was -- how tong was the conversation? (3) A. Kurt Bleick.
(4) A. 30 minutes. 4) Q. Where did Kurt work as a sheet metal
(5) Q. How frequently have you spoken with your 14:13 (5) worker? 4416
(6) sister, Angela, over the years? {6} A. In the same place | started working.
(7) A. About every other week. (7) Q. Where was that?
(8) Q. Was this conversation with her and her Py (8) A. At Metelmann.
(2) husband one of your regular calls or was it : i9} Q. Metelmann. ts Metelmann an employer?
(10) specific to the deposition today? 4414 £4(10) A. Yes. 11:16
(41) A. Regular calls. Ql) Q. And what did Metelmann make?
(12) Q. Is it correct that you went to a trade (12) A. A lot of cabinets, sheet metal cabinets,
(13) school? (13) some duct work.
(44) A. Yes. (14) Q. Before -
(15) Q. In Hamburg? 4nt4 (15) A. Switchboard -- 11:16
(26) A. Yes. (16) Q. I'm sorry.
(Ay) Q@. Do you understand how the -- most American | (17) A. Switchboards.
(48) high schools and junior high schools work, having (1a) Q. Anything else?
(19) lived in the United States for many years? {19) A. {can't think of it right now as | sit
(20) A. Excuse me. Yes. 4414 (20) here. V7
(21) @. When you were a youth in Germany, did (21) Q. As what age did you get put on the track
(22) _ students all go through high schoo! together like {22} to become a sheet metal worker?
(23) they do in the United States? {23} A. | went to apprenticeship. | was 18. Yes.
(24) A. It's a different systern. {24} Q. And did you complete your apprenticeship
(28) Q. How so? 4445 (25) _ by the time you left Germany? 4 1A7
38°" 40
A. Elementary school, middle school, high Ca A. Yes. 4
school. Actually, one schooling from first grade {2} Q. How fong was your apprenticeship?
to tenth grade. (3) A. Three years.
Q. And then some students go on a track to (4) Q. And did you perform that apprenticeship at
university? qe {5} Meteimann? VAT
A. That's right. (6) A. Yes,
Q. Other students go into various trades or : (7) Q. fs Metelmann, the location where you
professions? (8) worked, visible on Exhibit 47
A. Yes. (2) A. Just about, yes.
Q. And get very specific training? 115 10) Q. Can you, with a -- just make a red box at 11:17
A. Yes. Li} the spot where that was located?
Q. | gather from the information you have 12) A. (Witness complies.)
given us so far that you went into a trade; is 13} Q. Fm going to show you what I've marked for
that right? 24) purposes of identification as Exhibit 5 and ask
A. Yes. 44016 15) you if you recognize what's depicted in that 14:18
Q. And what was that trade? K16) photograph.
A. Sheet metal trade. 7) A. No, | don't recognize it.
Q. How did you come to select or be selected {38} G. I'm going to hand you what I've marked for
for the sheet metal trade? (19) purposes of identification as Exhibit 6.
A. Because | wanted to be a sheet metal VW ts (20) (Whereupon, Exhibits 5, 6 marked 11:19
worker. (213 for identification.)
Q. Did you know anyone that was a sheet metal | (22) BY MR. MARKS:
worker at -- (23) Q@. You can just put that down. Thank you.
A. My uncle. 24} And ask you if you recognize what's
Q. This was your father's brother? 4416 | k2 5} depicted in Exhibit 6. 44:19 —
te

Aiken Welch Court Reporters

Harold Koepke

01/23/201411 (Pages 41 to 44)

4 1 43
(1) A. Yes. Pa us the time spent in the classroom versus time ~
(2) Q. What is depicted in Exhibit 67 {2} spent at Metelmann at your apprenticeship, like on
(3) A. That's the second school I went to. {3} aweekly basis.
(4) Q. Was that before your apprenticeship? {4} A. Two days schooling and four days work. We
(5) A. That's the school | went to when | had to 11:19 {5} had six days work at the time. 44:21
(6) present my apprenticeship. / 16) Q. in ierms of sheet metal, the trade, is
(7) Q. Was your apprenticeship in sheet metal? | (7) there specialization within sheet metal workers?
(8) A. Yes. 8} AL I wouid say so, yes.
(9) @. And what is the German word for sheet (9) Q. And whai is the specialization that you
{10} metal worker? 44g (20) understood? 44:24
11) A. Blech Schlosser. (it) A. You can work with stainless steel and
(12) Q. And that was your uncle's trade? {12} regular sheet metal work. That's about it.
(13) A. Yes. (13) Q. And did you follow a particular path as a
(14) Q. Had you had a chance to see him al work (14) sheet metal worker?
(15) before you became an apprentice? 41:20 (18) A. | liked stainiess steel. 14:22
(16) A. He died in about 1920 something. (16) Q. Why was that?
(17) Q. So you ended up working at the location (27) A. ifs a very clean work.
{18} where he had worked? 2) 48) Q. Was~
(19) A. Yes. (19) A. You have to be specialized to do it.
(20) Q. Yes. Did you test to become a sheet metal 11:20) (20) Q. Isee. Does that involve welding? 44:22
(21) worker? (21) A. Yes.
(22) A. Test? (22) Q. Did you learn how to weld in the
(23) Q. Did you have to test into it fo become a (23) classroom?
(24) sheet metal worker? / (24) A. [went to special schoo! for it,
(25) A, No -+ 44:20 (25) Q. What was the name of the school where you 11:22|
_ 42 44
(1) MR. SATTERLEY: Object to the form of the | Ma did the welding training? a
(2) question. (2) A. Don't remember,
(3) Go ahead. If you understand, you can Pog 03) @. Did you get to use the welding training at
(4) answer. |) Meteimann?
(5) THE WITNESS: Yes. 44:20 tS} A. Yes. That's right. 44:22
(6} No. (6) Q. Meteimann, was that a single focation
(7) BY MR. MARKS: {7} where all your work was performed, or did you
(8) Q. How were you then selected to go into that {8} do -- work for Metelmann at other locations?
(9) trade? (3) A. No other locations.
(40) MR. SATTERLEY: Objection. Calls for-- 14: 20/(10) Q. Was it a factory setling? 14:23
(2a) assumes facts not in evidence. (ay A. Yes.
(12) BY MR. MARKS: (123 @. And they made various metal cabinets and
(13) Q. You may answer if you understand. {13} you said switchboards?
(14) MR. SATTERLEY: ff you understand. (24) A. Right.
(15) THE WITNESS: Yes. 40:20 (4S) @. Could you describe for me what you mean by 11:23)
(16) My parents taught me. (16) a switchboard?
(17) BY MR. MARKS: a} A. Something like if you go to a PGRE
(18) Q. Did you enjoy your apprenticeship as a K18) substation, you see big cabinets that are
(19) sheet metal worker? (193 switchboards, | would call them.
(20) A. Yes. 44:24 Ao) {Cell phone interruption.) 41:23
(21) Q. Did you do any type of ~ the (2a) MR. SATTERLEY: I'd swear | had my phone
{22} apprenticeship, did that coincide with classroom (223 on mute. | apologize. Let me turn it off.
{23} instruction? (23) BY MR. MARKS:
(24) A. Yes. (24) Q. So you've goi a metal cabinet like you're
(25) Q. How did that work in that could you tell 11:27 es) describing at Pacific Gas & Electric? 44:23 A

Aiken Welch Court Reporters

Harold Koepke

01/23/201412 (Pages 45 to 48)

45

A. Yeah.

Q. PG&E?

A. Uh-huh.

Q. You've got a metal cabinet and then you've
got electrical components inside? 44:23

A. Right.

Q. Meteimann made the cabinets?

A. Yes.

Q. Did they make any of the internai
components? 44:24

A. No.

Q. How many people were employed at Metelmanfif/ |
making cabinets when you were apprenticing at that
location?

A. 40 people, about. 4124

Q. Were they all working in the same area?

A. Yes.

Q. Could you describe the size of the room
for us?

A. Eight to 10,000 square feet. 14:24

Q. Did all of those 40 peopie working there
building cabinets, did they use welding equipment?

A. Not every one had to be welder. Not
everyone could weld. Some did.

a7

@. Would others be using welding equipment at
some point on any day that you were there?

A. We had two people that were specialized in
welding, they did weld every day.

@. When you did your welding, did you weld in 11:26
an area adjacent to where they worked?

A. No.

Q. The welders?

A. No.

. Did you wear any type of protective
equipment when you were welding?

A. Yes.

Q. What did you wear?

A. Leather gloves, a shield, and then call it
apron, leather apron. 14:26

@. And what type of welding equipment did you
use, if you know?

A. We did a lot of acetylene working at the
time, some arc welding.

Q. Did either of those methods of welding use 11:26
welding rods?

A. Yes.
Q. Both or one of them?
A. One of thern.
Q

44:26

A. They only were not only specialized in
welding.

Q. So they did other work?

A. Yes.

Q. Including welding?

A. Yes.

Q. Was the welding done in a particular
location?

A. Yes.

Q. Did that location have a name?

A. Awelding location.

Q. How did you say that in German? Did it
have a name? |

44:25

44:25)

A. Itjust came to me now. | don’t know.

Q. When you welded -- and you did weld-- 71:25

A. Yes.

Q, -- at Meteimann?

A. Yes.

Q. How frequently did you use welding t
equipment? 14:25 \

A. Not very often. |

Q. So, on the four-day weeks where you were!
working as an apprentice, would you use welding |
equipment every day?

A. No.

14:25

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. Which one? 44:26
48
A. The arc welding. 4
Q. Did you perform arc welding yourself?
A. Some.
Q. And did you use welding rods to do that
arc welding? 44:27

A. Yes.

Q. Did you wear a type of face mask at all --

A. Yes.

Q. ~ for the welding?

How about respiratory protection, like a 11:27

mask or respirator?

A. No.

. Did anyone wear respiratory protection
that you saw at Metelmann performing their work?

A. No. 49:27

@. Do you know who made the welding rods that
you used?

A, No, i don’t.

. Can you describe what they looked like?

A. | would say about a foot long and maybe an 11:2
eighth inch, one of an eighth of an inch thick.

@. And how was a welding rod used by a welder
such as yourself in relation to the torch?

A. Weil, you had the welding clamp that you
cail it. You put the stick into it, the welding 11:28

Aiken Welch Court Reporters

Harold Koepke

01/23/201413 (Pages 49 to 52)

ao)

stick, and then we started weiding (indicating). ~
Q. And the rod, the flame of the torch is ]
placed onto the rod?
A. There was no torch. No. That's
different. That's acetylene welding.
Q. | see.
A. The arc welding has oniy the stick, the
welding stick.
. And that welding stick burns?
. Yes. The end of it.
. And does that create smoke?
. A little bit.
|. Does it have a particular smell?
. [don't know. | don't know anymore.

14:28

11:28

PrOrors

welding after your work at Meteimann?

A. We did more acetylene weiding than arc
welding.

Q. When you were in Hamburg at Meteimann --

MR. SATTERLEY: Bless you. 44:29

BY MR. MARKS:

Q. Your trade school, was it called
Rosenallee?

A. That was the -- yes.
Q. Did I pronounce that close?

A. Yes.

Q. And that was the name of the trade schoo!?
A. Yes.

Q. Following the end of the war, was there an

effort to rebuild Hamburg while you were there? = 11:8

. How frequently have you performed arc 142

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A. Yes. (6)
Q. Fairly significant construction? 7)

A. Yes. Alot. {8}
Q. Did you, as part of your work in trade (93
school -- or your apprenticeship, participate in 1 139 (10)
any of that construction? (ily
A. No. (12)
Q. Were buildings built around you, where you 1 023)
worked or where you lived? (44)
MR. SATTERLEY: Object. Object to the 4730115)

form of the question. Vague. Ambiguous. (16)
But if you understand the question, you (27)

can answer. (18)
THE WITNESS: Yes. (19)

BY MR. MARKS: 41:30 (20)
Q. Would it be fair to say that the (21)
rebuilding of Hamburg took piace across the entire (22)
city? (23)
A. Right. | (24)

Q. Some areas were bombed heavily, but no~~4430/25)

51

neighborhoods escaped cornpietely?

A. Yes.

@. How would you get from home to school? On
foot or bike?

A. Bicycle.

@. Through the streets?

A. Yes.

Q. How tong would that take you?

A, 20 minutes.

Q. And to get to Metelmann, how iong would
thal take?

A. 20 minutes.

@. f see. And the trade schoo!?

A. That took half an hour.

@. And you would also go to trade school on 11:31
bicycle?

A. Yes.

Q. And the trade school, where was that
located?

A. That was on -- close to the main train
station in downtown Hamburg.

Q. Could you use this blue pen to circie that
on Exhibit 4 for us, please.

A. (Witness complies.)

dea circle or?

14:31

11:31

41:34

Q. Sure. Why den't you do a blue circle?

A. Oh, blue.

Q. Biue.

A. Okay.

@. Thank you. So you had to cross over the 11:32
Au Ben Alster?

A. Yes.

Q. To get fo the trade school?

A, Right.

Q, see. 14:32

I'm circling an area on Exhibit 4 with a

yellow highlighter at the bottom.

A. Yes.

Q. Of the page.

Do you see that?

A. Uh-huh.

@. De you recognize that area of Hamburg?
Yes.
. What is that area?
. That's the harbor.
That's where ships were built?
Yes.
. Did you ever visit the shipyard?
A, No.
@, Did you have anyone in your trade school 11:33

41:32

44:33

PPOPOP

Aiken Welch Court Reporters

Harold Koepke

Q1/23/201417 (Pages 65 to 68)

65
rm

the local engineering trades committee; is that ay
right? (2)
A. Uh-huh. Yes. (3)
Q. Andis that your signature to the left? {A}

A. Yes. 41:47 {5}
Q. And you were given the trade as fitter? {6}

A. That's what they called it over there, (7)
yes. ae)
Q. Okay. Las

A. At the time. 14:47 (10)
Q. What are the Snowy Mountains? (21)

A. The Snowy Mountains is a section like the (12)
Sierra Nevada. (43)
Q. How is it similar to Nevada? (a4)
MR. SATTERLEY: Objection. Vague, 44:48 (15)
ambiguous. (16)
BY MR. MARKS: (173
Q. It's a region? (18}
A. Yes. £ (19)
Q. |see. Okay. Andit's amountainous 14:48 (20)
region? {21}
A. Yes. {22}
Q. Did you work in the Snowy Mountains? {23}

A. Yes. (24)
Q. Was that part of the hydroelectric project 14:48; (25)

67

A. Five months. ”

Q. And that was five consecutive months?

A. Yes.

@. And then you went fo work elsewhere in
Australia? 11:49

A. Yes.

@. Did you ever return back to the Snowy
Mountains to do work?

A. No.

G. And did the work commence in Augustof 11:49
1860 in the Snowy Mountains?

A. Just about, yes.

MR. MARKS: Why don’t we take a morning
break and we'll resume in, say, ten minutes?

MR. SATTERLEY: That's fine. Let's go off 11:50
the video. Do we have an agreement by everybody
to go off the record?

MR. MARKS: Yes.

MR. SATTERLEY: We're going off the
record. 14:50

THE VIDEOGRAPHER: Off the record. Time
is now 11:56 a.m.

{Recess taken.)
THE VIDEOGRAPHER: On the record at 12:08
12:08

66
that was built there? i (hy Counsel, you may continue.
A. That's right. (2) BY MR. MARKS:
Q. And what was your role as a fitter in the (3) Q. Mr. Koepke?
hydroelectric project in the Snowy Mountains? (4) A. Yes.

MR. SATTERLEY: Objection. Assumes facts 71:485) Q. We're back from a brief break. | know you 12:08
not in evidence and mischaracterizes prior (6) had the opportunity to be with your attorney
testimony. | think he said that was a description CH during the break and | don't want to ask you any
somebody else gave him for the sheet metal work, (8) questions about anything you discussed, but did
so to the extent that mischaracterizes his £9) you look at any documents during the break to
testimony, | would object. 11:48 (10) refresh your recollection? 42:08
BY MR. MARKS: (aay A. No.

Q. Let me just ask it this way: You worked “Ty ea2y Q. Did you speak fo anyone other than your
as a sheet metal worker for the hydroelectric (413) wife or your atterney during the break?
project in the Snowy Mountains; is that right? 4) A. No.
A. Yes. 11:49 (15) Q. We were looking, when we took the break, 12:08
Q. Which part of that project were you (16) at what's been marked as Exhibit 7, which is a
associated with? (17) supplemental response to a request No. 8. | may
A. Well, if you see the other picture? (18) have misspoke at some point and referred to it as
Q. Yeah. (19) being Exhibit 8, but this is the collection of
A. There was a hall attached fo it and that's 11:49 {20} documents that you located in aboxinacrawl 12:09
where we had our machineries, bent machines for (21) space.
sheet metal and we did, again, smaller projects (223 A. Right.
for the underground facilities. {23} MR. SATTERLEY: We'll stipulate it's
Q. How long did you work on the Snowy (24) Exhibit 7.
Mountains hydroelectric project? 44 ao {25} MR. MARKS: Thank you. 12:09

Aiken Welch Court Reporters Harold Koepke 01/23/201420 (Pages 77 to 80)

77 79
BY MR. MARKS: (2) turbines.
Q. Were there other — (2) Q. You're looking at Bates No. 33 of
A. Atleast -- I'm sorry. ; @ Exhibit...
Q. Were there other camps where people were {4} AA
housed other than the one where you slept? 42: (5) Q. 7. And it's the photograph with the 12:19
A. No. Camp Camurro -- Camamaro (phonetic) {6} letter A circled next to it?
was the only camp. i?) A. Yes. Right.
Q. What kind of housing did you have at i (8) Q. People that worked in a room like the one
Camp Camarara (phonetic)? | {9} depicted there where there are turbines?
A. Well, we had a cottage we were sleeping 42:47 (10) A. Yes. 12:20
in. (ih) Q. Did you see people working with concrete?
Q. Like a prefabricated home? (42) A. No, because we were in an area which was
A. Yeah. Right. Yeah. (13) already pretty much done.
Q. Were these like bunk beds inside? (14) Q. What do you mean “pretty much done"?
A. Each of us had his own room. 4218 (15) A. Construction was done and only some minor 12:20
Q. And how many people lived in this / (16) work had fo be finished, and that's what | did.
prefabricated house? (17) Q. in the turbine room?
A. in the small room, one person. (18) A, It was attached to the turbine room, not
Q. How many rooms in the house or the (19) only in the turbine room.
building? 12418 (20) Q. Did you take the photograph that's 12:20
A. 15, 20. (24) Exhibit ~ that's letter A on page 33 of Exhibit
Q. For the other individuals living in your (22) 7?
building, were they all sheet meta! workers? (23) A. No.
A. No, | (243 Q Who did?
Q. There were other tradesmen? 1218 {25} A. Itwas a postcard.
78
A. Yes, (1) Q. But that postcard accurately depicts what
Q. What other trades were housed in the {2) you observed?
building where you slept? (3) A. Yes.
A. | don't remember. | don't remember. (4) Q. And do you remember the name of the
Q. Well, there were other trades working on 12:1. {5} facility where you observed these turbines? 12:20
this project other than sheet meta! workers -- (6) A. T-1, which meant Tunnel 1, | guess.
A. Oh, yes. 7) Q. And Tunnel 1 from where to where? Do you
Q. Right? (8) know?
A. Oh, yes. (9) A. The tunnel went deep into the mountain
Q. There were trades that worked with cement? 121410}  abouta mile long and then we came into this hail, 12:21
A. Yeah. (11) what you see there, which was about the size of a
MR. SATTERLEY: Objection. Calls for (12) football fieid. It was blown out of a mountain.
speculation. (133 Q. Do you know which river this tunnel was
THE WITNESS: I'm sorry. {14} attached to?
MR. SATTERLEY: Let me -- objection. 12:79 (15) A. River? 12:24
Calls for speculation. Foundation. (16) @. The river. The water.
BY MR. MARKS: {17} A. No.
Q. Did you see other tradesmen in the five (18) @. But the tunnel came into this power
months you were warking in the Snowy Mountains for, (19) station?
the Snowy Mountain Authority? 42:19 (29) A. Yes. 12:21
A. Yes. (24) @. And you performed your work in the power
Q. What other trades did you see? (22) station?
A. Machinists, people which worked on other (23) A. Arcom next to it.
projects, other tunnels or places like you see i24) Q. What was the room next to it used for?
here on the first pictures where they installed 12:19 25} A. For us sheet metal workers. 12:21

Aiken Welch Court Reporters

Harold Koepke

01/23/201421 {Pages 81 to 84)

81
Q. Okay. What were you building? 4 (1)
A. Atone time | build three outhouses out of (2)
metal. Some of the little items like smail (3)
cabinets, some sheet metal for coverings, whatever (4)
had to be covered. | never installed it myself. 1224 (3)
I just manufactured it. (6)
Q. So you manufactured metal in a room (Fy
adjacent to the turbine room at the T-1 -- (8)
A. Yes. Pow
Q. -- power plant? 42:22 | (10)
A. Right. (2)
Q. Who installed the work that you -- the (12)
metal structures you made? (13)
A. I wouldn't know. (44)
Q. Did you ever affix any of the metalin 12:22 (15)
place? (16)
A. No. {17}
Q. Was that a trade that the metal workers (1a)
performed, or was that a different trade? (29)
A. Those were the installers. 42:23 (20)
Q. And the installers were different than the (24)
sheet metal workers? (22)
A. Yes. (23)
Q. The turbine room off of the T-1 tunnel, = 7 (24)
how many turbines were located in there? 12:23 (25)
82
A. Well, as itis right now, it's four. (2)
Q. Were the turbines operational? {2}
A. No. @)
Q. How do you know that? (4)
A. I never see them operating. The project 12:23 (5)
wasn't done yet. (6)
Q. Okay. Do you know if the turbines were (7)
installed? (8)
A. Yes, they were installed. (9)

Q. What other trades were working in either 12:24 (10)

the turbine room or the room adjacent to it where {11}
you were performing your metal work? (12)
A. People which would do pipe work, {13}
heavy-duty pipe work, machinists, certified (14)
welders. 42:24 (15)
Q. Sounds like a busy place. (16)
A. itwas, Q7)
Q. Did you work seven days a week during this: (18)
five-month period? (19)
A. No. Six days. 12:24 (20)
Q. So six days out of every week you reported (24)
to work at the power station at T-1? (22)
A. Yes. (23)
Q. How did you get from your camp to the (24)
power station? 42:25 (25)

83
A. By truck.
Q. By truck?
A. Yes.
Q. Oras the Australians might say, a lorry?
A, Yes. 12:25

. Like an open truck, you just jump in the
back?
A. Yes. Open truck.
Q. And how long would it take you to get from
the camp to the power station? 42:25
A. About 20 minutes.
Q. Do you understand that there were seven
power stations associated with --
MR. SATTERLEY: Objection.
BY MR. MARKS:
Q. The Snowy Mountains facility?
MR. SATTERLEY: Object to the form of the
question as assumes facts not in evidence.
THE WITNESS: i don't remember anymore.
BY MR. MARKS: 12:25
@. Do you know how many dams were associated
with the facility?
A. Don't remember anymore.
. Did ait the peopte that were in your home
report fo work at your home, where you slept?

12:25

A. Yes.

Q. For the five months. Did everyone
siseping in that same building, did they all go to
work every day into the same turbine room where
you were working? 12:25

A. Yes. Atleast in that one section where |
was living.

Q. So the entire household worked in that one
space?

. | would say so, yes. 12:26

. How many buildings were in your camp?

. [don't know. | don't know.
. Dozens?

Dozens.

}. Hundreds?

. Dozens.

MR. SATTERLEY: Objection. Object to the
form of the question. Also asked and answered.
He said he doesn’t know.

BY MR. MARKS: 12:26

Q. In the five months that you lived at this
camp, did you ever have the opportunity to walk
around it?

A. Yes.

Q. How big of a space did it occupy?

12:26

POPD POP

12:26

Aiken Welch Court Reporters

Harold Koepke

01/23/201427 {Pages 105 to 108)

(2)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
{10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(223
(23)
(24)
(25)

@
(2)
(3)
(4a)
(5)
(6)
(7)
(8)
(9)

(10)
(11)
(22)
a3)

4)

(15)

(16)

(17)

{18)

{19}

(20)

(21)

(22)

(23)

(24)

(25)

105
. . rm
Q. What type of welding was that? Was it h)
stick welding? | {2)
A. That was arc welding. 3)
Q. What type of protective gear did you use {4}
for that welding? 12:47 {5}
A. (used a mask. | used leather gloves and (6)
a leather apron. (Ty
Q. For any of your weiding, did you ever wear iB)
gloves that were made of something other than {9}
leather? 12:47 10}
A. No. ead)
Q. Have you ever seen welding gloves made of} (12)
anything but leather? (33)
A. Never. 14)
Q. Not even in the United States? 12:47, 115)
A. No. Kis}
Q. Did you ever wear an apron when you iv}
welded? 18)
A. Yes. 4 is)
Q. What was the apron made of? 42:47 120)
A. Leather. (21)
Q. Have you ever used an apron in the {22}
United States that was made of something other {23}
than leather? (24)
A. No. . _ 12:48 pest
106

MR. SATTERLEY: You're talking about work, m™ 1}
right, as opposed to cooking? (23
Right, Chris? Loo
MR. MARKS: Sorry? (Al
MR. SATTERLEY: Youre talking about work 12:4 5)
aprons, right, not cooking aprons? (6)
MR. MARKS: Welding. CF)
MR. SATTERLEY: Welding, okay. {8}
BY MR. MARKS: (9)
Q. Do you understand the aprons to be welding 12:48 (10)
aprons? (il)
A. Yes, (12)
Q. So Athertons, where was Athertons located? ~] (23)
A. At Newtown in Sydney. thd}
Q. And was this a work site that you reported 42:48) (15)
to or did they send you off to perform work (16)
elsewhere? (173
A. Itwas a work site. {18}
Q. And it's in Sydney? {13}
A. Yes. 12:48 (20)
Q. Where in Sydney? {21}
A. Newtown, {22}
Q. Do you remember the address? (23)

A.

. Yeah. It's right here. I think. No. (24)
Can't see it. No. I'm sorry. 12:49 {25}

107

@. The address is for Melbourne, Adelaide and
Brisbane?

A. Yeah. Right.

Q. Bo you remember the street address?

A. No. 12:49

Q. Where did you live when you were working
for Athertons?

A. In Newtown.

Q. And do you remember the street address?

A No. 12:48

Q. Was it a house or an apartment?

A. Apartment.

Q. Did you live with anyone?

A. Yes.

Q. Who? 12:49

A. A friend of mine, Manford.

Q. The one you did the four-week trip with?

A. Right.

Q. What was your job at Athertons?

A. Sheet metal worker. 12:49

Q. And what did you do as a sheet metal
worker at Athertons?

A. | was, again, specialized in stainless
stesi. It says right here, too.

Q. What kind of items were you making out of 14:49
108

stainiess steel?
A. Kitchen supply, kitchen cabinets, sinks

for commercial outfits.
@. How many people were employed at Athertons
in the area where you performed your work? 42:50
A. itwas just all one hail, and we ail
pretty much did the same work, so | think 30.
@. And did this work include welding work?
A. Not much.
. How were the -- how were the pieces of 12:50
stainless steel connected?
A. Those were small places, small items.
They were welded, yes.
. Okay. And did you do that welding?
Yes. 12:50
. Did others do thal welding?
Yes.
. And what type of welding was that?
. With special electronic sticks.
}. Who made those sticks? 12:50
A. Don't know.
Q. Did they have a name?
A. No. idon't know. They might have hada
name but...
Q. Did you ever wear any type of respiratory 12:51

pPPOrOPO

Aiken Welch Court Reporters Harold Koepke 01/23/201429 {Pages 113 to 116)

113
where they installed it. | don't know. As soon iy
as they manufactured it, it got shipped out fo the (2)
high-rise buildings. (3)
MR. MARKS: The tape is over. We need to {4}
switch tapes. 12:54 (8)
MR. SATTERLEY: Let's take another break, {6}
then, while we're switching tapes. (7)
THE VIDEOGRAPHER: This marks the end of| {8}
Video Media No. 4 in the deposition of Harold {9}
Koepke. Off the record at 12:55. 42:55 (210)
(Off the record.) (2h)
THE VIDEOGRAPHER: We are on the record at (12)
12:59 p.m. This marks the beginning of Video (13)
Media No. 2 in the deposition of Mr. Koepke. Pothdy
Counsel -- excuse me. Counsel, you may 5815}
continue. (16)
BY MR. MARKS: (17)
Q. Going back to the Snowy Mountains, which 418}
trade was responsible for digging the tunneis? {19}
A. i wasn't even there when they started = 12:59 | (20)
digging the tunnels, so | wouidn't be able to } (221)
answer that question. (22)
Q. Were there any trades that you associated (23)
with digging or excavating -- {24}

12:59

A. No.

4114
Q. -- while you were there?
A. Absolutely not, no.
Q. Did you ever install any of the fabricated
metal that you built at Athertons?
A. No. 42:59
Q. Did you ever deliver it to any location?
A. No.
Q. Were there any trades employed at
Athertons other than sheet meta! workers?
A. Not in my area. 12:59
Q. Well, I'm tatking about the whole --
A. The whole shop?
Q. -- shop.
A. No. They ail were sheet metal workers.
Q. What do you mean by "not in your area"? 13:40
Was there another area?
A. In the whole shop | meant. i'm sorry.
Q. So the whole -- Athertons only employed
sheet metal workers?

A. Yes. 13:00
Q. Okay. No other trades; true?
A. Yeah.

Q. Why did you stop working at Atherlons?
A. | had a plan to go and emigrate to the
United States. 13:00

115

. But you worked ata third +
Yes.
. ~ business?
. Yes. { actually wanted to be promoted at
Atherton doing stainless steel work only, because 13:00
i really enjoyed working with stainiess steel, and
they promoted someone else, and then | left.

@. So at Athertons, on a daily basis, how
rnuch time did you spend welding stainless steel?

A. Very litte. 13:00

@. How much time did you spend welding any
metal?

A. Actually, very litte because that wasn't
my main profession.

@. When you say "very little,” can you
quantify that?

MR. SATTERLEY: Objection. Calls for
speculation.

THE WITNESS: Very little. That's all
what I can say. 43:01
BY MR. MARKS:

Q. Did you weid every day?

A. No.

Q. Which pieces were welded?

A. At Atherton?

Pere

13:04

116
Q. Yes.
A. Well, the ductwork we did was never
weided.
GQ. Okay,
A. And the ductwork was usually about six 13.01

feel long apiece, and we had special machines

fo -- we ran them, the material, the sheet metal

through a machine. The machine was folding the

sheat metal into a certain way, and then we had

another piece of sheet metal which had a bend and 13:04
it was sliding into this special bend, and then we

were hammering it over, so it didn't need any weld

at ali,

Q. The kitchen --

A. Yes,

Q. - and cafeteria equipment --

A. Uh-huh.

Q. -- and hospital sterilizing equipment, was
this standard equipment that was made again and
again, or -- 13:02

A. No.

Q. -- was every piece different?

A. Different.

Q. And it was done from drawings?

A. Yes. Blueprints.

13:02

13:02

Aiken Welch Court Reporters

Harold Koepke

01/23/201432 (Pages 125 to 128)

125 127

(1) States? {1} seeking?

(2) A. Actually, | left pretty -- it was pretty (2) A. Sheet metal.

(3) much right away [ eft, yes. (3) Q. Did you -- how did you go about that?

(4) Q. And you took a ship? ta) A. | went to the unemployment office and

(5) A. Yes. 41340 (5) found a job right away. 13:13

(6) Q. And what was the name of that ship? {6} Q. And what type of job was that?

7) A. Only can tell you the finer. It was a P&O | (7) A. Sheet metal.

(8) liner. Still in business. (8) Q. And where did you work?

(9) Q. Peninsula and Oriental Steamship, P&O? pote A. | worked for about five, six months at 7
(20) A. P&O, P&O, what's it stand for? 43:11 (10) Fred Meyer of California. 4313
(11) British -- it's a British finer. (12) Q. This is before you went to Germany?

(12) Q. Passenger liner? (125 A. Yes.
(13) A. Yes. 13} Q. Fred Meyer of California?
(14) Q. And you left Sydney and arrived in C14} A. Yes.
(15) San Francisca? 43014 (15) Q. The store, Fred Meyer? 13:13
(16) A. Yes. {16} A. He manufactured certain items.
(17) Q. And when did you arrive in San Francisco? (17) @. Which certain items?
(18) 19627 {18} A. He was specialized in fireplace equipment,
(19) A. Yes. (19) fools, and so forth, whatever belongs to
(20) Q. How tong were you in San Francisco before 13: 44120) fireplaces. 43:14
(21) you went to Germany? Qi} Q. Like fireplace inserts?
(22) A. | was about six, seven months in San {22} A. Well, you have a certain container, |
(23) Francisco, | got homesick, and I left. (23) guess you cail it, where you put your -- your wood
(24) Q. You retumed to Germany in 19637 {24a} in there you burn, Nota container, but... and
(25) A. Yes. 43:14 2s)
126

Q) Q. How did you get to Germany? (i) @. So these are metal fireplaces?

(2) A. | traveled through the United States with {2) A. No. Regular fireplace. Screen. The

(3) a friend by car and trom New York -- to New York. {3) screen for the fireplace he manufactures.

(4} And from New York, | went on the Queen Elizabeth {4} @. Have you ever seen a fireplace made of

{5} to South Hampton. From there i took the ferry to 13:12 (5} brick? 13:14

{6) Germany. {6} A, Yeah, all the time. It’s all over,

(7) Q. In the time you were in San Francisco (73 @. Sure. That's not what you were making at

(8) before you drove across country to catch the Queen (8) Fred Meyer?

(9) Elizabeth, did you work? {9) A. No, no, no.

(19) A. No, 13:12 {10} Q. Have you seen what people call like a “pot 13:14
(11) Q. Where did you live? (44) belly stove"?

(42) A. Hotels, motels. (12) A. Yes. We have one.

(13) Q. Did you have any type of income? (23) Q. ifs --

(14) A. No, not at the time, no. ql4y A. Yeah.

(15) Q. And where did you stay? in the city? = 13:12 (45) Q. ~ self-contained on legs? 13:14
(16) San Francisco? (16) A. Yeah,

(173 A. Yes. (17) Q. Is that what you were making?

(18) Q. And where in San Francisco? Which (18) A. No, no.

(19) district? (19) Q. Were you making a metal structure that
(20) A, In the Castro. 43:12 (20) would fit into a brick -- 13:45
(21) Q. Did you live with anyone in particular? (21) A. Around -- around a fireplace, yes, yeah.
(22) A. No. By myself. I had a room. (22) Q. So it was an insert?

(23) Q. Did you seek employment? {23} A. Yes. You could call it that, yes.

(24) A. Yes. (2ay Q. So it was a metal box that would fit into
(25) Q. And what type of employment were you 13:13 (25) a space in a home? 13:15

Aiken Welch Court Reporters

Harold Koepke

01/23/201433 (Pages 129 to 132)

129 131
(1) A. The frame around the fireplace. ih} Q. Per piece?
(2) Q. Just the frame itself? (2) A. Yeah.
(3) A, Yes. {3) Q. Was anyone else making these pieces?
(4) Q. Was there a door? (4) A. No.
(5) A. No. Screen. 43415 (5) Q. dust you? 1317
(6) Q. And how was that frame attached to the (6) A. Yes.
(7) home or house? (7) @. Where was this shop located?
(8) A. By bolting it against the -- the bricks. f (8) A. In San Francisco close to the -- the
(9) Q. Did you ever install any of those? i (3) hospital. The general hospital. Little further
(10) A. No. Never. ‘oas_| | 120) south. It's not there anymore. 1817
(21) Q. You made them in the shop? fad) Q. Which street was Fred Meyer's shop located
(42) A. Yes. | fabricated it. (12) on?
(13) No. He gave me a blueprint, Fred Meyer, {13} A. Whatever the street is called where the
(14) and he wanted me to manufacture this, this one (14) hospital is on. | don’t know the name anymore.
(15) time, which he has never done before. | was 13:15 (15) Q. Where did you live -- you were living in 13:18
(16) actually a pattern maker. So he gave me this {16} the Castro?
(17) blueprint and he said, this is what } want, make {17} A. Yes.
(18) it, and then | look at it, and if | like it, F (18) Q. How did you get from the Castro to the
(19) manufacture it. {19} shop?
(20) Q. And did he like it? 1316 (20) A. By bus. 13:18
(21) A. Not always. (21) @. And you did this for five months?
(22) Q. But you made more than one? (22) A. Yes.
(23) A. Yes. (23) Q. Did anyone else work with you at this
(24) Q. For about five months? (24) shop?
(25) A. Yes. 13:16 (25) A. Yes. 13:18
130 132
(1) Q. And how were the pieces of metal attached j {L) Q. Who?
(2) that would make this frame? Were they welded? (2) A, One welder and one foreman.
(3) A. Yeah. (3) Q. So the welder's job was to weld?
(4) Q. How many frames did you make during the {4} A. Yeah. He did only welding.
(5) five months that you were with him? 73:16 (3} Q. And did he work the same shiftas you? 13:18
(6) A. | don't know. Many. (6) A. Yes.
(7) Q. Was it like one a day? 7 Q@. And was that an eight-hour job that you
(8) A. No. No. it wasn't that fast to make (8) had?
(9) something out of nothing. That teok time. (3) A. Yes.
(10) Q. How long would it take to make a single 13:16) (10) Q. And what was the name of the welder? 43:18
(11) unit? (il) A. i don't know.
(12) A. More than single units because they belong (12) @. How about the foreman?
(13) more than just a screen to a fireplace. It could (13) A. Manfred was his first name. | don't know
(14) take a week. (14) his last name anymore.
(15) Q. How much time was spent welding those = 13:17(15) @. This is a different Manford? 43:18
(16) pieces on one piece? (16) A. Yes.
(1?) A. Not much at all because there was not much QT} Q. Than the one in Australia?
(18) welding to do. (18) A. Yes.
(19) Q. Are we talking something measured in {19} Q. Were these frames made of anything other
(20) — minutes? 43:47 (20) than metal? 13:19
(21) A. Yeah. {24} A. No.
(22) Q. Or hours? (22) Q. And what kind of metal?
(23) A. Hours. Hours. Hours. Yeah. (23) A. Regular sheet metal.
(24) Q. Can you be more specific? (24y Q. What kind of welding was used?
(25) A. 30 minutes. 4347 {25} A. Alot of -- oh, acetylene. 13:19

Aiken Welch Court Reporters

Harold Koepke

01/23/201434 {Pages 133 to 136)

133

Q. Did you do any acetylene welding yourself?

A. Yes.

Q. And the welder that was employed as a
welder full time, did he use the acetylene torch?

A. He most of the time used the -- the stick, 13:1
the stick welding.

Q. Where you worked and did your work and
where the welder spent his day doing his work, how
close were you?

A. He was completely in a different area,
maybe 35 feet away.

. Was it in the same room?

. twas divided.

How?

. By a curtain.

. What was the curtain made of?
. don't know.

. Did it hang -- it hung from the ceiling?

Yes.

. So there were just the four of you at this 13:2!
shop, the welder, the foreman, Fred Meyer, and
yourself?

A. No. Fred Meyer never was in the shop.

Q. Oh.

43:20

PPOPOPOrD

UA Fred Meyer was the owner. 13:20

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134
Q, So just the three of you there? (ay
A. Yes. (2)
Q. So you got homesick and returned to (3)
Germany? (4)
A. Yes. 13:20 (8)
Q. When did you go to Germany? (6)
A. | stayed altogether six months and then | Cy
went back to Germany. (8)
Q. Did you go back ta Hamburg? (9)
A. Yes. 43:21 (1a)
Q. Did you live with your parenis? (14)
A. Yes. (22y
Q, And they were at the second home? (433
A. Yes. (14)
Q. Apartment? 13:24 (15)
A. Uh-huh. {16}
Q. I'm sorry. Is that a "yes"? (LF)
A. Yes. (18)
Q. How long did you stay in Hamburg? (19)
A. From two months, once we stay itwentup 13:21 (20)
to two years. (21)
Q. So you stayed in Germany for two years?’ (22)
A. Yes. (23)
Q. And then what did you do after that? (24)
A. | had to reapply for my green card. | 13:2! {25)

135

went back to the States.
Q. During the two years you spent In Germany
after leaving the United States, did you work?
A. | worked for Struver.
Q, What kind of business was Struver? 13:21
A. Same.
Q. Sheet metal work?
A. Sheet metal work, yes.
Q. And where was Struver located?
A. in Hamburg. 13:22
Q. Was this a shop?
A. Itwas a manufacturer of -- manufacturer
gasoline transportation.
Q. Tanks?
A. Tanks. | couldn't think of it. Yes.
Q. Tanks used in vehicles?
A. Yeah. Yeah.
Q. Now, I noticed -- and we're looking at
page -- Bates No. 37?

13:22

A. Yeah. 43:22
Q. Your name is spelled K-o, umlaut --
A. Yes.

Q. -p-k-e?

A. Yes.

a Which is a different spelling than you use 13:22

136

today?

A. Right

Q. Did you change that?

A. When | went to the American Embassy, the
first time they told me since -- with an umlaut in 13:23
English is OE, to do it that way.

Q. In German is your name pronounced Képke?

A. Yes.

Q. Can you translate the rest of this letter
for us into English? 43:23

A. {As translated) "Mr. Koepke, born
7-18-1938, Hamburg. He was in the time from
15-8-63 this -- until 9-7-65, a sheet metal worker
working here. Mr. Koepke was working with sheet
metal, also with switchboards. All sorts of sheet 13:23
metal which were covering agregarten (phonetic)”
-- | can’t think of that word, “agregarten,”
something -- "a machine which creates
electricity.”

Can you think of the name? A machine
which creates -~
MR. SATTERLEY: No. You can't ask -- I

can't speak German, personally, | can't read
German. So, okay, just do your best to answer the
question. 13:24

13:24

Aiken Welch Court Reporters

Harold Koepke

01/23/201435 (Pages 137 to 140)

137

If you don't know, just say “I don't
know."

THE WITNESS: Weill, | can't translate it
exactly, but it's a machine which creates

electricity. 13:24
BY MR. MARKS:

Q. What -- okay. Is that at the end of that
paragraph?

A. Just shortly before.
And then the last paragraph is that | left 13:24
on my own and that | was a good worker.
That's about it.
Q. What type of work did you perform on this
machine that makes electricity?

A. Well, some of the area is open and ithad 13:45

to be covered with sheet metai, so they gave me a
blueprint and they told me what size and what
shape it has to be, and that was it.

Q. So you made covers for this machine?

A. Yes. 13:25

Q. That made electricity?

A. Right.

Q. Were the machines in your shop that you
were -- that you were covering?

. You just made the covers?

Right.

And the covers were taken elsewhere?
Yes.

And put on machines?
Right.

And the switchboards?
Yes.

These are cabinets?
Yes.

Made of metal?

Right.

. Anything internal?

No.

.. And what were the switchboards used for? 14:
. 1 don't know.

Q. Did you ever install any of the sheet
metal at a location outside of the Struver
facility?

A. Never did. 13:26

Q. Have you ever done sheet metal work in
Germany at a location other than a shop, a
fabrication shop?

A. No.

Q. Are there sheet metal workers who install 13:21

43:25

43:25

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,

139

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