Party Discovery: LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al

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                                Co em IN DR A ke WN

Bath kh at
BRRRERREREBE SERRE ERE EES

Douglas G. Wah, Esq. SBN 64692
Khaled Taqi-Eddin, Esq. SBN 220923

Janell M. Alberto, Esq. SBN 239508 ELECTRONICALLY

Lisa H. Mahl, Esq. SBN 248911 FILED

Foley & Mansfield P.L.L.P. Superior Court of California,

1111 Broadway, 10" Floor County of San Francisco

Oakland, CA_ 94607

Telephone: (510) 590-9500 coke 162909. on

Facsimile: (310) 590-9595 BY: WILLIAM TRUPEK
Deputy Clerk

Attorneys for Defendant
THE WILLIAM POWELL COMPANY

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

LOUIS CASTAGNA, Case No. CGC-07-274230

Plaintiff, “Asbestos-Related Case”

DECLARATION OF LISA H. MAHL IN
SUPPORT OF DEFENDANT THE WILLIAM
POWELL COMPANY’S MOTION FOR
PROTECTIVE ORDER RE: PLAINTIFF'S
DEPOSITION

vs.
ASBESTOS DEFENDANTS (BéP),

Defendants.

DATE: May 11, 2009

TIME: 10:30 a.m.

DEPT.: 610

JUDGE: Comm. Bruce E. Chan

Complaint Filed: June 6, 2007
Trial Date: None Set

Ne ae ae a Se! Na et ee ee et! et

I, Lisa H. Mahl, hereby declare:

1. lam an attorney at law duly licensed to practice in the State of California and am an
associate at the firm of Foley & Mansfield, P.L.L.P., attorneys of record for defendant THE WILLIAM
POWELL COMPANY (hereinafter “William Powell”) in this action. Our office has personal
knowledge of the matters stated in this declaration, and, if called upon, could and would competently
testify thereto.

Mt

I
DECLARATION OF LISA H. MAHL IN SUPPORT OF DEFENDANT THE WILLIAM POWELL COMPANY'S MOTION FOR PROTECTIVE ORDER,_

2. Plaintiff Louis Castagna’s deposition was held on June 17, 2008, September 10-12, 2008
and September 24-25, 2008. Plaintiffs deposition continued on March 2, 3, and 5, 2008, and on April 7
and April 9, 2009.

3. After the first six sessions, only Plaintiff's employment history from 1967 to 1970 had
been covered.

4. Tn sessions seven and eight, Plaintiff was only able to testify regarding nine employers.
Session eight concluded having only examined Plaintiff on his employment up to 1971.

5. Defense counsel duly attempted to meet and confer with Plaintiff's counsel to request

ee SF DBD A kk WD NY

that Plaintiff extend the thirty (30) hours to allow the examination of Plaintiff to be completed.

-
oS

6. Plaintiff's counsel declined to extend the time for Plaintiff's examination. At this point,
11 || defendants were left no choice but to move on to client identification, which comprised sessions 9

12 || through 11. William Powell was allotted a mere 13 minutes in which to complete its examination.

13 7. During these 13 minutes, Plaintiff blind sighted William Powell by identifying eight

14 || additional jobsites and four vessels- none of which were identified during prior testimony or in

15 || Plaintiff's responses to discovery.

16 8. In an effort to avoid Court intervention, on both April 7, 2009 and April 9, 2009, William
17 || Powell attempted to meet and confer with Plaintiffs counsel in the hopes of obtaining additional hours
18 || on the record. Despite these attempts, additional time was not provided. (See Exhibit A, attached hereto,
19 || a true and correct copy of Louis Castagna’s deposition taken on April 7, 2009. See Exhibit B, attached
20 || hereto, a true and correct copy of Louis Castagna’s deposition taken on April 9, 2009 )

21 9. Defendants have placed a statement on the record to confirm Defendants’ basis for

22 || suspending Plaintiffs deposition and in bringing forth this motion. (Attached hereto as Exhibit B is a
23 || true and correct copy of Louis Castagna’s deposition taken on April 9, 2009.)

24 10. Defense counsel determined that at least 20 hours, in addition to the 3 hours remaining on

25 || the record, was warranted to complete the deposition of the Plaintiff.

26 | ///
27 |
28 | ///

2
DECLARATION OF LISA H, MAHL IN SUPPORT OF DEFENDANT THE WILLIAM POWELL COMPANY’S MOTION FOR PROTECTIVE ORDERee YN DH HW F Ww Y

em BM N NN NO NR NR Se SEO SO See
BOR RR BRE BS e PRA ETB RE S

ll. Plaintiff is not incapable of continuing with his deposition should additional time be
granted. He is not suffering from a terminal illness and he does not require the administration of
supplemental oxygen.

1 declare under penalty of perjury under the laws of the State of California that the foregoing is

Kode Wult

Lisa H. Mahl

true and correct.

Executed on April 16, 2009 in Oakland, California.

3
DECLARATION OF LISA H, MAHL IN SUPPORT OF DEFENDANT THE WILLIAM POWELL COMPANY'S MOTION FOR PROTECTIVE ORDEREXHIBIT Ai (Pages 985 to 988)

987
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA (1) DEPOSITION OF LOUIS CASTAGNA,
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO (2)
--000--- 3} BE IT REMEMBERED, that pursuant to Notice, and on
4) the 7th day of Apri! 2008, commencing at the hour of
LOUIS CASTAGNA, 5} 9:10 a.m., in the Comfort Suites, 5549 Bridgehead Road,
Plaintiff, 6} Oakley, California, before me, KIMBERLY L. AVERY, a
vs. No. 274230 7} Certified Shorthand Reporter, personally appeared LOUIS
SBESTOS DEFENDANTS 8) CASTAGNA, produced as a witness in said action, and
A 9} being previously duly sworn, was thereupon examined as
Defendants, (10) awitness in said cause.
I an
(h2) ~-000—
(13) APPEARANCES:
(14) For the Plaintiff:
as) Mathew Da Vega
DEPOSITION OF LOUIS CASTAGNA Brayton Purcell
VOLUME X (6) 222 Rush Landing Road
Novato, California 94948
(Pages 985 through 1085, inclusive) an
For the Defendant, Albay Construction Company:
18)
Elien Lockridge
(29) Archer Norris
Taken before KIMBERLY L. AVERY 2033 N. Main Street, Suite 800
CSR No. 5074 (20) Walnut Creek, California 94596
(21) For the Defendant, Kaiser Gypsum Company, Inc.:
April 7, 2009 (22) Myles B. Solomon
Bassi, Edlin, Huie & Blum
(23) 351 California Street, Suite 200
San Francisco, California 94104
(24)
(25)
Aiken Welch Court Reporters L, Castagna, V.10 A-T-O9 Aiken Welch Court Reporters L. Castegna, v.10 4-7-09
986 988
INDEX <1} For the Defendants, CSK Auto, Inc ; Dillingham
Construction NA., 1 ng Joie Controis, |
PAGE a fon NA., Ino; and Johnson Controfs, Ine
EXAMINATION BY MS. KUO 993 a ven
EXAMINATION BY MR. MARTINEZ 4001 Becheret, Kennett & Schweitzer
EXAMINATION BY MS, LOCKRIDGE 1012? 1265 Powel Street
EXAMINATION BY MR. TAQLEDDIN NO17 181 Forthe Delerdons Foster Wheeler Corporation ans
EXAMINATION BY MR, STEVENS 1036 NIBCO, Ine.: , ‘
EXAMINATION BY MS. BURCH 1044 o Ken Hoang
EXAMINATION BY MR, SACK 1057 Brydon, Huge & Raker
135 Main Street,
EXAMINATION BY MS. WAID 1066 ‘3 San Franisco, California 34108
EXAMINATION BY MR. SOLOMON 4067) HH For the Defendants, Oaldabco, Inc.; and Tosco Refining
EXAMINATION BY MR. LATHRAM 1073, fy ee
Michelle Towle
12) Fifice, Brown, Eassa & McLeod
1989 Harrison Street, 18th Floor
13) Oakland, Calfornia 94612
14) Forthe Defendants, Lindstrom 8 King Company, and
Republic Supply Company:
EXHIBIT 15) Ralph Andina
. u
DEFENDANTS’ PAGE 8 tot oredr oth Fioor
D Handwritten document 993 in Cakland, California $4607
uy ” 18) For the Defendants, Red-White Valve Cor tion;
List of Trades win nc See aN ea
19)
E Handwritten document 993 20) Aoeva Mena
4117 Broadway, 10th Floor
24) ‘Oakland, Califomia 94607
22) For the Defendant, Performance Mechanical, Inc.
2 ‘Bob Clevenger
Gordon & Rees:
24) 275 Battery Street, 20th Floor
San Francisco, Caiifomia 94111
25)
Aiken Welch Court Reperters L. Castagna, V.10 4-73-08 Aiken Welch Court, Reporters bL, Castagna, ¥.10 4-7-092 (Pages 389 to 992)

989 991
For the Defendant, Sequoia Ventures, ine.: (2) For the Defendant, Douglass Insulation:
Mark C. Davis a denice Man
Hassard Bonnington LLP ‘
Two Embarcadero Center, Suite 1800 eo SS Now Mentoomery Street, Sith Flocr
San Francisco, California 94111 mw San Francisco, California 94105
(8) For the Defendants, Pacific Gas & Electric; and
For the Defendants, IMO Industries, inc.; and Eaten Caterpitian, fc.:
Electrical, Inc.: ser
Christina Helwig Reynold Martinez,
(By phone) m Sedgwick, Detert, Moran & Arnold
‘One Market Plaza, Stevart Tower
Howard, Rome, Martin & Ridley we Btn Floor
1775 Woodside Road, Suite 200 ‘San Francisco, California 94405.
Redwood City, California 94061-7715 3)
For the Defendant, Elliott Company, fka Elliot For the Defendant, TIMEC Company.
: lao
Tursomachinery Company, Inc.: las Selemen
Ruby Steinbrecher an By shone!
nun Brum LP.
Imai, Tadlock, Keeney & Cordery azD 333 Pine Street, Suite 400
100 Bush Street, Suite 1300 San Francisco, Cetifornia 94106
San Francisco, California $4104 kaa
For the Defendant, Durametaitic Corporation: For the Defendant, Kelly: Moore Paint Gampany
Michael Keith aay
(via phone) Frank M. Stovens
kas ‘Stevens, Drummond & Gifford
vackson & Wallace 4910 Olympic Boulevard, Suite 250
55 Francisco Street, Suite 600 Rist Walnut Creek, California 94596
San Francisco, California 94133 07) For the Defendants, Scott Company of California; end
For the Defendant, Crane Co. Lemons Gesket Company:
Stacey Lee ee Robart J. Bugatlo
fag Rhone) ae Vasquez, Estiada & Dumont
Courthouse Square
Four Embarcadero Center, Suite 1200 2a) $000 Fourth Street, Suite 700
San Francisco, California 94111 San Rafee!, California 94901
For the Defendant, Advocate Mines, Inc.: ken
Alisha Lee For the Defendants, Thomas Des Engineering Company. and
Pe hon Hs mae
Lewis, Brisbois, Bisgaard & Smith Walsworth, Franklin, Bevins & McCatt
221 N, Figueroa Street, Suite 1200 aay 601 Montgomery Street, Ninth Fioar
Los Angeles, California 94104 San Francisco, California 94111
kes)
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990 992
For the Defendant, Piant insulation Company: (2) For the Defendant, PACCAR, Inc.
Susan M. French @ Bil Edgar
Lewis, Brisbois, Sisgaard & Smith Buty & Curliano
‘One Sansome Street, Suite 1400 ao 585 - 12th Street, Suite 1280
San Francisco, Califomia 94104 uy Oaktand, California 94807
For the Defendant, Pacific Mechanical Corporation: sy Por the Defendant, Rockwell Automation, ine:
Sally Waid Timothy Connor
Low, Ball & Lynch ‘sl (a phone) West
805 Montgomery Street, 7th Floor oy 135 Min Street, ‘Sule 700
San Francisco, California 94111 San Francisco, California 94105
For the Defendant, Swinerton Builders: (1
Steven M. Lathram For the Defendant, Contre Costa Electric:
Parton Sell Rhoades
750 Lindaro Street, Suite 140 Steve Harrington
San Rafael, Caiifornia 94904 40} (by phone}
Clapp, Moroney, Beliagamba Vusinich
For the Defendant, Temporary Plant Cleaners, Inc.2 ay 1111 Bayhill Drive, Suite 300
San Bruno, California 94086
Amy Y. Kuo ah
Pond North LLP For the Defendants, Fisher Controls International, LLG;
505 Montgomery Street, 13th Floor 13 and Copeland Corporation
San Francisco, Cafifornia 94104 aah Danie! J. Noonan
For the Defendants, Trane U.S.,tnc., formerly American Von Briesen & Roper, S.C
Standard; Consolidated Insulation, inc.; and Triple A 35) 411 East Wisconsin Avenue, Suite 700
Machine Shop: te Milwaukee, Wisconsin 53202
homas Nolan aro For the Defendants, Ford Motor Company; General Motors
369 Pine Street, Suite 800 17} Corporation, Chrysler, and Honeywell Intarnational,
San Francisco, California 84104 m
For the Defendant, Chicago Bridge & Iron: toy wee
Bowman & Brooke
Dane Sack 2a 879 Wost 190th Street, Suite 700
Sack Rosendin Gardena, California 90248-1019.
One Kaiser Plaza, Suite 340 21
Oakland, California 04612 12
23)
24)
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993 995
LOUIS CASTAGNA, Lb fm trying to think what trade these are. They
previously sworn as a witness, 2} set up the pumps and everything. I'm at a loss.
testified as follows: 3) That's why | wrote down a lot of this stuff,
EXAMINATION BY MS. KUO: 4) because when it comes to mind | think...

Q. Good morning, Mr. Castagna. How you feeling S} BY MS. KUO:
today? 6) Q. Absolutely.

A. |'m okay. 7) So just to be clear, | have here you have them

Q. Have you reviewed any additional documents in 8) down for pipefitting work, electrical, labor,
preparation of your continued deposition for today? a) carpentry, and setting up pumps; is that an accurate

A. Other than Exhibit A and my steamship listand = (10) list?
my dispatches, | have not. (1i} A. There's probably more.

MS. KUO: Okay. | understand you produced two {12} Q. Hit comes to you, let me know.
additional handwritten iists of notes. I'm going to 3) A. Iwill
attach them next. (44) Q. And what years do you recall working with or
(Defendants' Exhibits D and E a around the Plant Maintenance employees?
Marked for Identification.} (16) A. From 1967 or '68 until, all the way through
BY MS. KUO: (17} until 1995.

Q. With respect to the ones entitled "List of (18) Q. [s that intermittent or is that consecutively?
Trades," | understand this is specific to your Lake (19) A. It's all intermittently throughout when we were
Merritt Plaza job in Oakland; is that correct? (20) on shutdowns and things of that nature, they were

A. Yes, ma'am. (41) always there.

Q. I'll attach these next. (42) @. Okay. And can you tell me what locations you

A. The short list, that's refinery product heaters (23) recall seeing Plant Maintenance employees working at?
and such. (34) A. Tosco refinery.

Q. And | see you've indicated a brand name with (25) Q. Okay.

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994 996
the ~ I) A. Shell Oil and Chevron, Unocal.

A. Right. And there's some compressors, air 2) [can't recat if they were Pacific refinery.
compressors that are on there. 3) Q. This might be a little tougher of a question,

Q. I'll let anyone who wants to ask you questions 4) but maybe you can help me out.
about those do so. 5) With respect to Tosco, do you recall what years

I'm going to start off today, sir, I'm going to 6) you associate Plant Maintenance being at Tosco?
ask you a little bit about my client. 7) A. | worked many shutdowns in there, in the alky
Have you ever heard of a company by the name of (8) plant and in the -- in the arsenic ptant and on the
Plant Maintenance, Incorporated? 9) coker burn.
A. Yes, (yo) There was two different burns at Tosco, and |
MR. Da VEGA: Go ahead. (a1) recall them at alt of these sites, and Chevron also.
BY MS. KUO: (2) Q. Right. Can you recall the year specific to

Q. And what do you associate with that company? = (13) Tosco?

A. | associate working in the refineries and (44) A. I'd have to refer to my -- to some of my work
working around dust at times in many locations andin (15) list in order to give you an accurate year,
several refineries in the Bay Area. (16) Q. Before we do that --

Q. More specifically, can you tell me what you (q7} A. 1983, 1981, 1982, 197 -- 1972, 19 -- 1984.
believe that Plant Maintenance, Incorporated, didasa (18) Okay.
company? (49) I'm thinking now this is at -- these are most

MR. Da VEGA: Lacks foundation. Vague. (40} of the refineries I'm thinking of now. So are we just
Overbroad. (4l} talking about Tosco or --
Go ahead. (42) Q. I'm talking about Tosco, but the years you gave
THE WITNESS: They did much of the same as (43) me, that's with respect to all of the refineries?
pipefitting and electrical, and they had laborers. (44) A. Right, a variety of refineries, And Unocal
They had carpenters. { think they had some -- {45} also.
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997 399

(4) Q. We can leave it at that. That's fine. 1} Lacks foundation. Calls for speculation.

(2) Now, with respect to what you saw the Plant 2) BYMS. KUO:

(3) Maintenance employees doing, was it the same for every {3} Q. Sir, let me ask you a question while you are

(4) refinery that you were working at? 4} doing that: How did you identify Plant Maintenance

(5) A. Primarily, yes. 5} employees to be Plant Maintenance employees?

(6} Q. Okay. Then I'll take it as a lump sum instead 6} A. With their hard hat, had their logo on it and

(Th of breaking it up. TY it said “Plant Maintenance."

(8) is that fair? 8) Q. Do you identify any particular color with that

(9) A. Okay. 3} hard hat?

(10) Q. Now, when you saw them working at the 0} A. [can't recall at this time.

(11) refineries what did you see the Plant Maintenance ql} Q. Okay.

(12) employees doing? (42) A. There's so many hard hat colors.

(13) A. | seen them taking and once the boilermakers (L3} Q. No, that's fair enough. | know it's a long

(14) pulled the bundles out of some of the heat exchangers, (/4} time ago, but you identify it because it said "Plant

(15) they'd take it and bring it down and steam out -- steam CLS} Maintenance” on the hard hat?

(16) off the tubes and things of that nature. And I've seen (16) A. Yes, and ihe trucks they drove around in.

(17) them doing pipefitting, much of the same as what | did, (EF) . Can you identify any colors for the trucks?

(18) and the other -- and some electricians that | seen Ley A. | believe they were white, I've seen a variely

(19) doing, they did much of the same. Lo} of different colored trucks, so they had some rental

{20) Q. Okay. And this is again a general question, {£0} trucks also.

{21) but how far away in feet can you estimate you were (Ply Q. Do you remember the names of anyone who worked

{22) standing or working when you saw the Plant Maintenance, (22) for Plant Maintenance?

(23) Incorporated, employees doing their jobs? (23) A. No, I don't.

{24) A. 10 feet. Sometimes they'd be above us, (BA) Chicago Bridge & tron was another company.

(25) sometimes they'd be below us, would be right alongside 25} — Altec Construction is another company. Parsons, C.F.
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998 1000

(1) ofus. They'd have systems that were assigned to them, 4) Braun, Bechtel at the TKC project.

(2) and then we had systems that were assigned to us, and 2) Q. Sir, fm going to ask you another question.

(3} so we'd be working kind of like commingled side by 3) MR. SACK: Excuse me. What list were you

(4} side. 4) reading from?

(5) Q. Okay. 5) THE WITNESS: My union dispatches, sir.

(6) And do you recall any of the names of your 6) MR. SACK: And do we have an exhibit number for

(7) employers that you were employed by when you saw Plant [7} that?

(8) Maintenance also on the job? 8) MS. BURCH: It's been attached previously.

(9) A. Albay Construction, Pacific Mechanical 3) MR. Da VEGA: They were attached previously.
(16) Corporation, Bechte! Power or Bechtel Petroleum, (403 MR. SACK:So it should have an exhibit number
(11) Swinerton & Walberg, Epic Instruments, Ehrhart. (dl) on it.

(12) I'd have to look at my list of dispatches to (42) MR. Da VEGA:His copy doesn''t, but whatever it
(13) refresh my memory a little more, if you'd like. (43) was attached as.

(14) MS. LOCKRIDGE: Could | have that list read (44) BY MS. KUO:

(15) back, please. (5) Q. Sir, you mentioned working around -- I'm sorry.
(16) MR. LATHRAM: Read back the question, as well, (46) I guess my time is up, so | have to pass my seat.

(17) please. (ET) MS. HART: This is Robin Hart. I'm sorry ('m

(18) (Record read.) (48) not there, but | wonder if anybody else on the phone is
(19) THE WITNESS: Dillingham Construction. (E9} having problems hearing? There's some kind of drone
(20) BY MS. KUO: (20) MR. TAQI-EDDIN: Do you want to go off the
(21) Q. And this is upon reflection of what's contained (41) record?

(22) in your dispatch records? (32) MS. KUO: Before we go off the record, | want
(23) A. On my union dispatches. (23) to reserve — before we go off the record, | had just
(24) MR. LATHRAM: I'm going to object to the (24) wanted to make a record that I'd like to reserve my
(25) initial question as overbroad. Vague and ambiguous. (35) rights to ask further questions for my client.5 (Pages 1001 to 1004)

1001 1003
THE WITNESS: Yes, ma'am. 1) in some capacity other than to work there?
(Discussion off the record.) 2) A. Yes.
EXAMINATION BY MR. MARTINEZ: 3} Q. What are those other facilities?
Q. Sir, my name is Reynold Martinez. We met 4) A. There's one right down the street here. It's
earlier during some of the first sessions of your 5} on Wilbur Avenue.
deposition 6} Q. Let me back up a little bit.
A. Irecall. 7) Do you remember visiting any other facilities
Q. I'm here today for a different entity. 1 had &} other than perhaps -- other than San Onofre where you
asked you some questions about Caterpillar. Today I'm 9) recall seeing others doing work at the facility while
going to ask you some questions about PG&E, Pacific Gas (10) you were there?
& Electric. (4h) A. Yes, | do.
A. Yes. (42) Q. And is one of those facilities on Wilbur
Q. You are familiar with the company, correct? (43) Avenue?
A. Absolutely. (44) A. Yes.
Q. Allright. Have you ever worked at a Pacific (45) Q. What type of facility is on Wilbur Avenue?
Gas & Electric site or facility? (16) A. it's a steam-generation plant.
A. No, but they worked on the facilities that | (i?) Q. Do you know the name of this plant?
worked at. (48) A. I don't recall it at this time.
Q. All right. (49) Q. Do you recall when it was that you visited?
But just so the record is clear, you never (40) A. 19— around 1984,
worked, though, at a Pacific Gas & Electric facility, (3h) Q. And how long were you there?
correct? (42) A. Probably two or three hours, | would say.
l'll ask you about the second part in a moment. (43) Q. And what was the occasion that brought you to
A. I'm not sure if working at some of the nuclear (44) this facility on Wilbur Avenue?
powerhouses that were servicing PG&E classifies that (25) A. | had a friend that was a machinist, and he
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1002 1004
as.. 2) brought me in as a guest.
Q. Well, let's do it this way, which nuclear 2) Q. And is that here in town, on Wilbur Avenue?
powerhouses did you think of? 3) A. Yes, itis, sir.
A. San Onofre. 4) Q. And just for the record, we're in ~
Q. Any others? 5) A. Antioch, | believe it's Antioch.
A. | can't recall -- not in the State of 6) Q. While you were in the Wilbur Avenue facility
California. 7) what work was your friend doing?
Q. All right. 8) A. He was doing machine work, and he showed me
Are you familiar with there being any Pacific $) some sump pump work fhat he was doing down in the
Gas & Electric facilities out of California where you (10) basement, and some turbine work.
worked? qi) Q. This wasn't a turbine overhaul, was it?
A. No, just that they contracted, that was. (hey A. It was.
contracted power from them. (hay Q. Itwas.
Q. That is other places where PG&E bought the (44) Was the casing off of the turbine?
power coming from the power stations? (15) A. It was.
A. That's correct. (46) Q. Was any work done to install or remove any
Q. But not another PG&E facility where you worked, ({7) thermal insulation at the time you were at this
true? (48) powerhouse or this steam-generating plant?
A. That's correct. 9) A. | don't recall that at this time.
Q,. Other than San Onofre, are you familiar with (20) Q. And | know we're on the tenth day of your
any other facilities that you understand were Pacific (21) deposition or so, perhaps more, perhaps less, but
Gas & Electric facilities? (22) you've been asked a lot of questions about different
A. Not working at them, no, | do not. (23) products and probably some questions about whether you
Q. When you say, "not working al them," are there (24) believe you were expased to asbestos; is that true?
other PG&E facilities that you recall visiting, either (25) A. That's correct.
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1005 1007
Q. Allright. Do you believe that you were i) A. Pacific Gas & Electric.
exposed to asbestos while at this steam-generating 2) Q. He worked directly for Pacific Gas & Electric,
facility? 3) as you understand it?
MR. Da VEGA: Calls for expert testimony. a) A. Yes, sir.
Go ahead 5) Q. Was he wearing a Pacific Gas & Electric uniform
THE WITNESS: Yes, | do. 6) when you went to the facility?
BY MR. MARTINEZ: 7) A. Yes. He was wearing his coveralls and
Q. And what do you think was the source of that 8) everything, but he had his PG&E hat on, his hard hat.
exposure? 9} Q. Was it your friend who blew -- used the
A. Air compressor that was blowing down a {20} compressed air?
particular area that | thought it was pretty poor (41) A. No.
practice. 12} Q. It was somebody else?
Q. Is that to say someone used compressed air to (ig A. No, it was somebody else. It was another,
clean an area? (143 like -- they have a crew that | guess they are kind of
A. Yes. (i5) more like swampers.
Q. What was the compressed air used to clean? (16) Q. I see.
A. It was down in the lower sump area in the (HT) Who employed that crew, do you know?
basement. (18) A. To my best knowledge, it would be PG&E.
Q. And was this -- what was the compressed air (19) Q. Was there -- do you remember what that crew was
cleaning, that is what was the material that had to be {20} wearing?
removed? (21) A. They also had the PG&E logo on their hard hats.
A. It was blowing out the room. (22) Q. Anything else at this facility that leads you
Q. Do you remember how jong the compressed air was (23) to believe you were exposed to asbestos while you were
used? (24) there other than the compressed air that we've been
A. We moved through pretty fast when | seen that (49) talking about?
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1006 1008
happen, we moved on. 1) A. No.
Q. About how long were you there while compressed (2) Q. Are there -- strike that.
air was being used? 3) I've taken the liberty of looking up San
A. Five, ten minutes at the most. 4) Onofre, and if looks to me like it was operated by
Q. Do you know what the source of the dirt in the 5) Southern California Edison and San Diego Gas.
room was, like where did that dirt come from? 6) Bees that refresh your recollection?
A. I'd say it came from the top, ail the way down 7) A. Yes, it does.
to the bottom of the facility. 8} Okay. So Fm standing corrected.
Q. Were the floors in between -- a) Q. Okay. Do you recall other than this steam-
A. Grated, (10} generating plant, steam-generation plant ever being at
Q. That's what | was going to ask you, it was a (11) any other Pacific Gas & Electric facility while work
catwalk? (12) was taking place in the facility?
A. Yes, sir. (13) A. No, but | was at places where PG&E was working
Q. Your friend who was there with you, what was - (14) on and tying in and doing their work.
what was that person's name? (45) Q. And what type of facilities were those; that
A. | can't think of his name now. It's been a few (16) is, were they refineries?
years, (47) A. Refineries, sir.
If you give me a few minutes, I'll think of it (78) Q. Anything other than refineries?
before we get to the end of this. (19) A. The Oakland modules, and they built pump
Q. Allright. Well, I've got six, so lll try. (20) stations that went to Alaska.
A. Six minutes? (21) @. Are these sometimes called the skids?
Q. It's all right. If you think of it later, I'm (32) A. Exactly.
sort of making a joke here. (43) Q. And is it your understanding that those modules
Do you recall who employed your friend, whe you (24) were being built for PG&E?
came out to see doing work? (25) A. No, they weren't, but PG&E was in -- they were
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1009 1011
doing -- they were supplying power to the facility and 1) Q. Okay. Just a couple questions.
they were doing work on their -- on their equipment. 2) Do you recall ever being paid, yourself, by
Q. Do you recall ever seeing someone who you 3) PG&E?
understand now or understood then was a PG&E employee (4) A. No, I've never been paid by PG&E.
do any work removing or installing any thermal 5} Q. Do you recall ever having any work instructions
insulation? 6} given to you by PG&E employees?
A. Jacketing on the wire and what have you, that's Th MR. Da VEGA: Vague.
what | recall. 8) THE WITNESS: Other than being at home, no
Q. So other than insulation on wiring, do you o) BY MR. MARTINEZ:
recail seeing any PG&E employee or someone who you 6) Q. Do you recall ever getting any supplies from
understood or now understand worked for PG&E disturb or (11) PG&E for you to use at your work?
remove or install any sort of insulation other than 2) A. I did not.
wiring insulation? 3) Q. Do you recall — do you recall ever seeing PG&E
A. Ido not. 4) employees give instructions to any of their workers
Q. Do you recall ever having a job yourself where 5) while you were present?

(
(
(
(
¢
(
in doing that job you had to, say, follow or work (46) A. | did, but | didn’t pay attention to what they
closely with a PG&E employee while that employee was (37) were alluding to.
doing his work? (38) Q. And, finally, were you ever supplied any tools,
A. Iwas within 50 feet of the project. (98) yourself, by PG&E?
Q. Do you recall ever having your job assignment (40) A. No.
(
{

be a job assignment where you had to work -- i'm irying 1) MR. MARTINEZ: Thank you, sir.
to separate out just passing by a PG&E employee. 2) At this point I see I've run out of my allotted
A. Right, | understand what you are saying. (43) time, so | may -- I'd have further questions I'd ask
You mean working like as a ~ (34) you if we had more time, but at this time I've got to
Q. - a helper to him. (45) cede my questioning.

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1010 1012
A. Right. 1) Thank you, sir.
No, no, { never worked as a combination, you 2) THE WITNESS: I'm trying to think of that man's
know, crew. 3) name. It's William -- his last name will come to me.
Q. Sois it correct to say you don't recail a job 4) MR. MARTINEZ: Thank you.
where you and the PG&E employee were assigned to work {5} BY MR. MARTINEZ:
‘on the same piece of equipment, for example? 6) Q. That's the man at the --
A. | don't recali that happening. 7} A. That works for PG&E, and still does,
Q. Do you recall a job where your job and the PG&E 8} Q. At the steam-generation facilities?
person's job were located, say, within 15 feet of each oy A. Yes, he does.
other while you each did your work? o) MR. MARTINEZ: Thank you, sir.
A. I'm having a hard time recalling the procedure 1) MS. WAID: I'm waiting for information for the
that they had when we did the -- when | was working for 2) office, so I'm going to pass.
Foster & Wheeler out at Tosco and putting in a 3) MS. KUO: | already went.
co-generation plant, whether or not | was within 15 4) MS. LOCKRIDGE: Are we on the record?
feet of their service. 5) EXAMINATION BY MS. LOCKRIDGE:
Q. Just a few more questions. 6} Q. [think | have six minutes remaining, so I'd
Can you tell me in about what year thal was, 7} like to use some of that time, if | can.

your work where you saw PG&E employees at Tosco and
they were installing their service?

A. Fd have to look through my work history.

Q. How about without doing thal, do you -- is it
‘80s; can you give me a decade?

Sir, I'm here on behalf of Albay Construction

9) today, and | know you were asked questions about that
0} in prior sessions. | just have a couple of follow-up.

1) questions with regard to the questions that were asked
2) of you regarding Albay.

oe

A. Yeah, it would be in the ‘80s. 3) A. Yes.
Q. 1980s? 4) Q. It's my understanding that you observed Albay
A. Yes. 5) employees welding with Lincoln welding rods; is that

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Q. Okay, All right.
Sir, | don't know that we were on the record

2) those individuals working so that they wouldn't hurt
3) your eyes or you wouldn't be affected by their work?

1013 1015
correct? 1) Q. Sir, how would you know that that's where they
A. Yes, ma'am. 2) were obtained from if you didn't order them?
Q. Okay. Do you know what years you saw that work [3) A. | just know what | ordered when..
performed, and this is when you were employed by 4) Q. So you wouldn't know where they were obtained
someone other than Albay. 5) from?
Are you referring to something? 8) A. No, I wouldn't.
A. I'm looking at my dispatches. 7) Q. And what were you doing when you saw these
ts that okay? 8) employees of Albay welding, when you were working for
Q. Yeah, that’s fine. $9} other employers?
Let me go off the record so | don't use up my (Lo) A. Working alongside of them on another system.
six minutes. (11) Q. Were you wearing eye protection at the time?
(Discussion off the record.} (Lay A. Yes.
BY MS. LOCKRIDGE: (43) Q. Were you wearing a welding mask or hood like
Q. Sir, do you recall the year? (44) the welders?
A. 1976. (15) A. No, | wasn't.
Q. 1976. Okay. (te) Q. Were you concemed about looking directly at
Is that the only time? (47) the welders when they were doing their work?
A. No. cf) A. I never looked at the arc.
Q. Okay. But that's the first year? (19) Q. It would hurt your eyes, right?
A. That's one | see in front of me right new. If (20} A. Yes.
| rifle through these, !'d probably find more. (21) Q. Is there a distance that you would keep from
C
C
(
C

when you said C.F. Braun. 4) A. Well, sometimes it was impossible to get away
Is that the first employer that you recall 5} from them because they'd be working above me or
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1014 1016
seeing Albay workers -- 1) alongside of me, because we were working on different
A. That was the one that was in front of me. 2) systems in the same facility, in the same area of the
Q. Okay. All right. That's fine. 3) refinery.
How did you know that the rods that the Albay 4) @,. Let me ask you this, understanding that that
workers were working with were Lincoln? 5) could occur, is there a distance that you would try to
A. It said on the boxes, on the 50-pound boxes. 6) keep from welders doing their work in order to not get
Q. Did you provide those Albay workers with any 7h sparks on you or to see their sparks?
materials that they were working with? By A. If they were working directly above me | would
A, Not while | was working with another company, 2} get out of the shower of sparks, but if they were

no, ma’am.

Q. How about -- did you ever order any of the rods
thai those Albay employees were working with when you
were working for other employers? 3) flash.

A. i couldn't say that those rods went to Albay. 4) Q. How about sparks?

{40} working along -- like from me to the court reporter, |
{
{
{
(
| couldn't -- 1 couldn't testify that the reds that | (15} A. Sparks were just right there. It was just like
(
(
{
(

1) would just -- I'd have side shields on my safety
2) glasses and it would keep me from getting welder's

had acquired went to Albay. 6} the welder that I'd be working with right next to me.

Q. Okay. Do you know where Albay obtained any of 7} ld have to stand there and I'd be fitting and the
the tools and materials that they were working with, 18} welder would be welding, my hands would be right in the
including the welding rods, when you saw them working o) same spark spray, and so -- | wouldn't move out of the
with those materials when you were working for another (20) way from the welder, the Albay worker that was working

employer? (21) three or four feet away from me because | was doing my
MR. Da VEGA: Vague. Overbroad. (42) Job.
THE WITNESS: The supply company is eluding my (23) MS. LOCKRIDGE: Thank you. Those are actually
thought right now. (24) all my questions, and I think I've used up my six
BY MS, LOCKRIDGE: (25) minutes.

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1017 1019
GQ) Thank you, sir. 1) working on while you were out there.
(2) THE WITNESS: You're welcome. 2) Let's de this a little more generally. Where
(3) EXAMINATION BY MR. TAQI-EDDIN: 3) do you recall working with and around William Powell
(4) Q. Good morning, Mr. Castagna. 4) valves? If you could just give me a listing of where
(5) A. Good morning. 5) in your work history you would have encountered William
(6) Q. How you doing today? 6) Powell valves, that’s a good starting point.
(7) A. So far so good, a) A. Okay. In the ballasting system and in some of
(8) Q. Okay. We spoke very early on in your 8) the lube oil systems on the ships, on some of the
(9) deposition. 3) feedwater system.
(10) A. | recall. (40) We're talking about new at this time or just in
{11} Q. My name is Khaled Taqi-Edgin, and I'm here on (41) general all of them?
(12) behalf of two clients, it's Red & White Valves (sic)as_ {32} Q. I'm talking in general. And |'m not limiting
(13) well as the Wiliam Powell Company. (43) it to only your time on vessels. I'm talking any time
(14) We had previously spoken about them before in (44) in your career, whether it be by employer or work site,
(15) one of your earlier sessions, but I'm going to go more (45) I want to know where it is you encountered William
(16) general since we're limited in regards to time. Sol’m (16) Powell valves?
(47) going to start off with the William Powell Company. (47) A. In Chevron refinery and out at Tosco,
(18) One of the things we discussed earlier is you (78) definitely out at Unocal in Rodeo.
(19) recalled working on William Powell valves during the (39) Did | mention Chevron?
(20) time you were aboard some vessels while you were at (20) Q. You did.
(21) Taconite Harbor. (41) A. Shell, Shell Oil in Martinez. And there's one
(22) Do you remember that? (42) other -- there's one other place, Fibreboard in, |
(23) A. | don't recall Taconite Harbor, but | recall (43) believe il's somewhere over in Pacheco or Port Chicago
(24) working on the Powell valves. { could have been ata (44) or somewhere in that vicinity. | can't recall now.
(25) variety of ports or at -- out on a run on some of these (25) And also at the — we did an annealing plant at U.S
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1018 1020
a) valves. Some of them we couldn't work on while we were {1} POSCO in Pittsburg at the steel mill, that was new
(2) in port due to the fact that they were, a lot of them 2) construction, so those were new valves,
(3) were ballast. 3) Q. Pittsburg, California?
(4) Q. But it would have been during that time period 4) A. Yes, sir.
(5) where you would have been working in and around 5) Q. So far we've got Chevron refinery; Tosco;
(6) Taconite Harbor; is that correct? 6) Unocal; Shell Oil, Martinez; Fibreboard facility in
(7) A. If lwas on Lake Superior, yes. 7) Pacheco, as well as the U.S. POSCO is what you said?
(8) Q. And from what | recail from our discussions 8) A. Yes.
(8) back then, you did not remember the maintenance history (9) Q. US. POSCO Stee! over in Pittsburg, California?
(10) of any of those valves; is that correct? (40) A. That's correct.
(11) MR. Da VEGA: Vague. (hh) Q. Any other places?
(12) THE WITNESS:No, there was nothing written (ey A. Out at -- in Alameda at the glass company
(13) down, sir. (43) there. f'm trying to think of the name of the glass
(14) BY MR. TAQI-EDDIN: (hay company.
(15) Q. Do you remember whether or not at any time (5) In fact, worked on some at the Glass.
(16) while you were working in Lake Superior, whether or not (16) Container that is defunct now. It was in Antioch, did
(17) you had installed a brand-new William Powell valve? G7) @ shutdown there, and worked on some Powell valves
(18) A. | don't know if it was Lake Superior or not, (18) there, as well.
(19) bul we -- | did replace some new Powell valves, andif, = (49) Q. Now, in regards to the time period where we
{20) might not have been on Lake Superior and it might not (20) talked about when you were working aboard vessels, when
{21) have been on the ship that you are alluding to. £ (21) you were aboard vessels and working on Powell valves,
{22) don't know which ship you are referencing. (22) associated ballasting systems, lube oil systems and
(23) Q. When we were discussing It you couldn't (23) feedwater systems, do you remember the names or -- do
(24) remember which ship back then, as weil, you justsaid (24) you remember the names of any of the ships that you
425) it was one of the ships that you would have been (25) would have seen a William Powell valve aboard?
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i021 1023
a) A, GOVERNOR MILLER. i} you've worked throughout your lifetime, and | believe
(2) Q. Did you say the GOVERNOR MILLER? 2) we discussed some of these sites already during your
(3) A. GOVERNOR MILLER, sir. 3) deposition; is that correct?
(4) Q. Okay. 4) A. Yes. Yes, sir.
(5) A. HENRY G. DALTON; SNYDER, JR.; WILLIAM P, 5} Q. And during your testimony with regards to your
(6) SNYDER, JR.; THOMAS WILSON; ARTHUR M. ANDERSON. [6) work at these various sites, | don't believe you've
(1) Q. Are those all of them? 7) mentioned NIBCO or working with NIBCO ai any of these
(a A, That's all that | can recall at this time. 8} sites before that we've talked about.
() MR. TAQI-EDDIN: Counsel, | just came up with a 9) A. That's right.
(ig) fairly enormous list that I'm not going to be able to (40) Q. ts there something that jogs your memory now or
(11) cover in #3 minutes, and at this point I'm just going (1) ~- when you worked with NIBCO at these sites at a later
(12) to make the representation thal i'm going to open it up (42) time that we haven't discussed?
(13) for the room to foliow up, but upon the conclusion of (43) A. Once you -- once - you refreshed my memory by
(14) everyone else I'm probably going to have to suspend the (44) virtue of saying it.
{15} deposition to seek more time because there's going to (45) Q. With regard to the NIBCO valves, what was your
(les be no way I'm going to be able to cover this much time, (16) work?
(17) this many sites in the detail that would be necessary (47) A. Iwas a fitter.
(1g) to be able to effectively represent my clients al (18) Q. And did you install NIBCO valves?
(13) trial. (49) A. Yes, I did.
(205 So i'm going to pass the witness on, and I'm (20) Q. Did you do anything else besides installing
(24) making the record that you might want to contact your (41) NIBCO valves?
(225 office to see whether or not they want to move off the (42) A. I did some packing, change gaskets
(23) 30-hour point; if net, I'm going to be left with no (43) Q. Sir, what type of NIBCO valves did you work
(24) other choice but to suspend. (44) with?
(25) MR. Da VEGA: t've already done that. We are (25) A. | worked with welded, buck-joint welded and
en Welch Court Reporters L. Castagna, V.1G 9 4-7-09 Aiken Welch Court Reporters L. Castagna, V.i0 9 d=7-0%
1022 1024
ql) going to enforce the 30 hours, which is 10 extra hours 1) screwed, bath, and flanged. I've worked with all three
(2) more than the 20-hour rule already in place by the 2} styles. | worked with globe style and gate. I've
(3) General Orders. 3) worked with check valves, also.
(4) MR. TAQI-EDDIN: j understand. | stated my 4) Q. Now, with regards to the globe valves, can you
(5) position. Hopefully you understand mine. 5} give me a range of sizes?
(6) MR. Da VEGA:Right. Sure. 6) A. Six-inch down to half-inch, three-quarter-inch.
(7) We've been going an hour. Take five minutes. 7} Q. With regards fo the gate valves, can you give
(8) {Break taken.) 8} mea range of sizes?
(9) EXAMINATION BY MR. HOANG: 9} A. I can't recall at this time exactly what size
(10) Q. Good morning, sir. | have two clients that 1 (19) they were, sir.
(21) need to ask you about, and the first one is NIBCO, (1h) Q. How about the check valves, do you have a range
(12) Do you associate the name NIBCO, inc., with any (12) of sizes that you worked with?
(13) products or services? (43) A. There was some smaller ones, some three-
(14) MR. Da VEGA: Vague. Overbroad. Lacks (14) quarter, one-inch, and there was some, | believe, four-
(25) foundation (15) and six-inch.
(16) THE WITNESS: NIBCO is a vaive. (16) Q. And, sir, how much of your work was installing
(17) BY MR. HOANG: (47) versus doing packing work or changing gaskets?
(18) Q. Did you work with NIBCO throughout your career? (48) A. Weil, on the new construction | would be
(19) A. Yes, | did (49) installing, of course, and in the shutdowns | either
(20) Q. Where? (40) change out a valve that was -- if it was to the point
(21) A. At Standard Oil, at Shell and Tosco, at Glass (41) of where the face of the -- the gasket face was
(22) Container in Antioch, at General Motors in Fremont, (42) scarred, we'd change it out, put a new valve in, or we
(23) that was on the dipping tanks and on the paint booths, (73) would just repack, put in packing rounds, or the check
(24) yes. (44) valves, we would put new -- new flappers in or whatever
(25) Q. And, sir, you've listed various sites where (45) was required.

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1027

A, Let's see. On the compressor deck at the alky

i repacked probably 40 to 50 at the 300 area at

can give me a number, an estimate of how many brand-new

THE WITNESS: That's what I'm trying to recall.

MR. Da VEGA: Do you want to go off the record?
THE WITNESS: At Parsons, at Shell Oil on the

L. Castagna, ¥.10  4-7-09

1028

If you want to spend five minutes, think of all
the locations and approximately how many numbers and

THE WITNESS: Right. | don't want to eat his

MR. Da VEGA: Why don't we take a five minute

A. That | could say that were new and the packing

Q. So your testimony that you worked or repacked

packings’ appearance that it wasn't tampered with, the
way the valves leaked and the time frame, one to two

1025
(1) Q. Okay. Now, with regards to your packing work 1) Q. Okay. And, sir, can you provide me with an
(2) on NIBCO vaives, can you add up and provide me with an 2) estimate on how many NIBCO valves you believe you
(3) estimate of how many NIBCO valves you repacked? 3) repacked that contained original packing material?
(4) And this is to cover your entire lifetime, sir. 4)
(5) A. From 1967 to 1995 I'd say between 150 to 200, 5) unit, E think | packed about 20 there that | had
(6) if not more. 6) installed two years prior to that, and in other
(7) Q. And what was that time frame, 1967 to 19 when? 7) locations.
(8) A. To 1995 8) Out at Chevron..., Shell in the 300 area...
(gy Q. Can you estimaie how many? 9)
(10} A. 150 to 200, sir. (16) Shell on Pacheco, that's the main line on Pacheco
(14} Q. With regards to any of the NIBCO valves that (Lh) Boulevard in Martinez, and at Tosco, once again, at
(12) you did repacking work on, did you knew the maintenance {12) the -- at the coker burn we had to change out valves.
(13} history to any of those valves? (13) Q. I'm asking throughout your entire career if you
(14) MR. Da VEGA: Vague. Overbroad. Lacks (hay
(15) foundation. (45) NIBCO valves you replaced packing on?
(16) THE WITNESS: To the majority of the vaives | (hey MR. Da VEGA: And that's what he's doing.
(17) did nol, but there was some valves that] knew as to tL7)
(18) being new, and when | went back on a shutdown | would (hed I's really hard for me to -- I'm trying to think back
(19) repack the vaives, I'd work on them again. {hop ‘on this and try to give my best testimony.
(20) I've worked on many of the shutdowns over and (20) I'm trying not to eat your time up.
(21) over again that these valves were al. Like I say, at (2p
(22) Tosco in the alky plant and at Chevron in the dewax, (22)
(23) and in the RLOP, which was a new construction, | did a (#3) tie-ins of the new unit, the new coker unit that | put
(24) lot of work on those valves, and then on shutdowns come {24} — in when | was working prior.
(25) back and do maintenance on them. 125} MR. HOANG: Counsel, could we go off the
Aiken Welch Couxt Reporters _L. Castagna, V.10  4-7-08 Biken Welch Court Reporters
1026
a) BY MR. HOANG: LL} record?
(2) Q. And, sir, in between the time frame where you 2) MR. Da VEGA:Sure.
(3) performed shut-down work and when you came back te do 3)
(4) further work on valves, do you have any documents or 4)
(5) any facts that support your statement or testimony that 5} ihen come back, that would be fine.
(6) no one has ever worked on these valves prior to you 6)
(Ty going back and working on them? 7) time up.
(8) MR. Da VEGA: Vague. Compound. Overbroad. a)
(3) THE WITNESS: | have no personal documents or 9) break and he'll have an answer for you.
(10) records referring to any of the valves that I'm talking (10) (Break taken.)
(11) about other than -- other than what | installed { couid cay (Record read.)
(12) safely say that there wasn't any maintenance done to (12) THE WITNESS: !'d say 50.
(13} them because of the way they were leaking, the stems (43) BY MR. HOANG:
(14) were leaking, and I'd have to extract ail of the old (hay Q. 50 total, correct, sir?
(15} packing out of it and repack. (15)
(16} BY MR. HOANG: (Le) appeared not to be tampered with and that | had to
(17} Q. So you base your testimony that you repacked LT} repack,
(18) new valves based on the fact that they were leaking, (18)
(19) correct’? {19} 50 new NIBCO valves -- valves are based on the
(20} A. Right. And the time frame that | went back to (20}
(21) them, which would be like a year, year and a half. (21)
(22} Q. Okay. But in between that interval you have no (22) years that you'd come back and work on that valve
(23} information that that valve was changed out by somebody (23) again, correct