Exhibit,Appendix: ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS

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                                , LLP

SUITE Clon
We BUSH STREET

SAN PRANCLECO, CA 94i0g

KEENEY & CORDERY,

LAW ODRICRS

IMAI, TADLOCK,

{4L5] 675-7000

Theodore T. Cordery, Esq. (Bar No. 114730)

Tina Yim, Esq. (Bar No. 232597)

IMAL TADLOCK, KEENEY & CORDERY, LLP

100 BUSH STREET, SUITE 1300
SAN FRANCISCO, CA 94104
Telephone: (415) 675-7000
Facsimile: (415) 675-7008

Attorneys for Defendant
WEBCOR BUILDERS, INC.

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION”

ROBERT ROSS and JEAN ROSS,

Plaintiffs,

C.C. MOORE & CO. ENGINEEERS, et al.,

Defendants.

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

FEB 25 2013

Clerk of the Court
BY: WESLEY G. RAMIREZ-
Deputy Clerk

CASE NO.: CGC-10-275731
(ASBESTOS)

EXHIBITS I, J, K, AND LTO THE

DECLARATION GF TINA YIM IN SUPPORT
| OF WEBCOR BUILDER, INC.’S MOTION
FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY
ADJUDICATION

Date: May 9, 2013

Time: 9:30 a.m.

Dept: 503

Judge: Hon. Teri L. Jackson

Complaint Filed: December 17, 2010
Trial Date: June 10, 2013

Attached are EXHIBITS I, J, K, AND L-THE DECLARATION OF TINA YIM IN
“SUPPORT OF WEBCOR BUILDER, INC.’S MOTION FOR SUMMARY JUDGMENT OR, IN
THE ALTERNATIVE, SUMMARY ADJUDICATION. :

-]-

EXHIBITS I,J, K, AND L TO THE DECLARATION OF TINA YTM IN SUPPORT OF WEBCOR, BUILDER,
INC."S MOTION FOR SUMMARY JUDGMENT GR. iN THE ALTERNATIVE, SUMMARY
ADJUDICATION& CORDERY, LLP

IMAI, TADLOCK,

(4153 675-7000.

PROOF OF SERVICE

I, Heather Cherry, declare:

Tam a resident of the State of California and over the age of eighteen years, and nota
party to the within action; my business address is 100 Bush Street, Suite 1300, San Francisco, CA
94104. On the date of execution below, I served the within documents:

EXHIBITS |, J, K, AND L. TO THE DECLARATION OF TINA YIM IN SUPPORT
OF WEBCOR BUILDER, INC."S MOTION FOR SUMMARY JUDGMENT OR, IN
THE ALTERNATIVE, SUMMARY ADJUDICATION

by transmitting via facsimile the documeni(s) listed ahove to the fax number(s) set
forth below on this date before 5:00 p.m.

by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, in the United States mail at San Francisco, California addressed as set
forth below.

by personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below. .

¥ On the date of execution below, I electronically served the document via File &
ServeXpress on the recipients designated on the Transaction Receipt located on the
File & ServeXpress Web site.

I declare under penalty of perjury under the laws of the State of California that the above

| is true and correct.

Executed on February 22, 2013, at San Francisco, California.

és/ Heather Cherry
Heather Cherry

Ross, Robert and Jean v, C.C. Moore & Co. Engineers, (WB).
SAN FRANCISCO SUPERIOR COURT NO. CGC-10-275731

2.
EXHIBITS I, J, K, ANDL TO THE DECLARATION OF TINA YIM DN SUPPORT OF WEBCOR BUILDER,
INC.’S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
ADIUDICATIONLAW OFFICES

IMAI, TADLOCK, KEENEY & CORDERY, LLP

BUCTE LHI

19
20
21
2
23
24

25]

26
27
28

PROOF OF SERVICE

1, Tina Yim, declare:

lam a resident of the State of California and over the age of eighteen years, and not a
party to the within action, my business address is 100 Bush Street, Suite 1300, San Francisco, CA
94104, On the date of execution below, I served the within documents:

EXHIBITS I, J, K, AND L TO THE DECLARATION OF TINA YIM IN SUPPORT
OF WEBCOR BUILDER, INC.’S MOTION FOR SUMMARY JUDGMENT OR, IN
THE ALTERNATIVE, SUMMARY ADJUDICATION

LL

by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:00 p.m. ,

by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, in the United States mail at San Francisco, California addressed as set-
forth below, ’

by personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below:

Brayton Purcell, LLP
222 Rush Landing Road
Novato, CA 94945-2469

On the date of execution below, I electronically served the document via File &
ServeXpress on the recipients designated on the Transaction Receipt located on the
File & ServeXpress Web site. .

I declare under penalty of perjury under the laws of the State of Califomia that the above
18 }} is true and correct.

Executed on February 22, 2013, at San Francisco, California.

és! Tina Yin
Tina Yim

Ross, Robert and Jean v. C.C. Moore & Co. Engineers, (WB).

SAN FRANCISCO SUPERIOR COURT NO, CGC-10-275731

3.

EXHIBITS J, 1, K, AND L TO THE DECLARATION OF TINA YIM IN SUPPORT OF WEBCOR BUILDER,

INC'S MOTION FOR SUMMARY IUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
ADJUDICATIONEXHIBIT I=

oO om nN D oO BF WwW NM

10

SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
000

ROBERT ROSS and JEAN ROSS,

Plaintiffs,
vs. NO. 275731
C.C. MOORE & CO. ENGINEERS,
et al.,
Dejendants.
I

DISCOVERY DEPOSITION OF ROBERT ROSS
(Volume II!)
(Pages 350 through 581, inclusive)

Taken before RICHARD LENZI
CSR NO. 2564
July 14, 2011Qa.
you belli

A.

was asbestos insulation. Containing asbestos.

Fireproofing that contained asbestos.

Q. Was this fireproofing the spray on kind of
fireproofing?

A. Yes, ma'am.

Q. Do you belleve it contained asbestos

because it looked like the same old type of
firepraofing you had seen in other locations which — - J

we have talked about?

A.
Q.

to get.an understanding of why you believed it

contained ashestes or how you know that.

A.

contained asbestos.

Q.
A

467

Yes.

Do you know how many times you saw them do

No.

~~ Do you believe this ceiling insulation, do

eve the brand was MonoKote?

lam not sure of the brand. But! know if

it contained asbestos, ma‘am:
| understand that, sir. | am just trying
Because | know it was the type that

Did you see this fireproofing installed?

No.

Alken Welch Court Reporters Robert Ross 7/14/2011=

ow wo NN OD oo Ff WwW N

. Wheat Hearts. Basically that's about it.

Q. Do you know who installed it?
A No.
Q. Can you give me any further explanation as

to how you know it contained asbestos?
A Do | have fo repeat myself? | guess | do.

MR. SOLOMON: It's okay. You are using
their time when you repeat yourself.

THE WITNESS: Okay. Because | pointed out
the difference to you between the new and the old.
And | have been around that stuff for many many
years. It would just be like you looking at your

breakfast and fig ure out whether it's oatmeal or

MR. SOLOMON:
THE WITNESS:

Wheat Hearts?
Wheat Hearts. Do you

* remember Wheat Hearts?

MR. ZACHARIN: He is an oatmeal man.
MR. TWU: Is that like Cream of Wheat?
BY. MS. HOFF:
Q. Sir, at the time that you were working at

this building did you know that asbestos was
hazardous toe your health?

A. i knew about asbestos in the late 70's and
80's, in that time frame.

Q. Did you see the Bell Products employees do

468

Aiken Welch Court Reporters RobertRoss 7/14/2011=

521
THE REPORTER: I think it's Exhibit 3.

2 MS. YIM: Exhibit 3? Sorry.
3 THE WITNESS: | don't have that number but
4 Lam going to number it.
5 MR. SOLOMON: 3 was the set of notes you
6 made while you were sitting in the room on
7 Tuesday. Your longer set of notes.
8 (Off record)
9 MR. SOLOMON: Back on the record.
10 BY MS. YIM:
11 Q. Sir, referring te Exhibit 3 which is your
12 longer set of notes. On the top of one of the
13 pages it says Langley Porter Clinic. Do you have
14 that page in front of you?
15 A. Yes, ma'am. That's 3 then? —
16 Q. It says “Webcor Builders, Inc" and it
17 says, "disturbed overhead MonoKoie, sweeping.”
18 A. Yes, ma'am. That's good. Thank you for
19 that. | have it right in my hand here.
20 a Sir, reviewing your prior testimony in —
21 your interrogatory responses, you worked at
22 Langley Porter Clinic sometime between 1967 to
23 1972?
24 A. Yes, ma'am.
25 Q. And this was with Consolidated?

Aiken Welch Court Reporters RobertRoss 7/14/2011522

4 A. Yes, ma’‘am.
2 Q. And this was for approximately one week
3 total off and on?
4 A. For Langley Porter, yes.
5 Qa Sir, do you recall Webcor Builders working
6 around you at any other job sites?
7 A Yes.
8 Q. Do you recall which job sites those are?
9 A. Administration building in Richmond,
10 Kaiser Hospital in San Francisco. UC Berkeley. |
11 don't have that on here but thai's how | remember.
12 Q. Any other sites?
13 A Not at the present moment, no.
44 Qa. Sir, | read your prior transoripté and you
415 didn't mention Webcor af Langley Porter. Did you
16 review any documents or speak fo anyone other than
17 your attorneys that led you to believe you worked
18 around Webcor Builders?
19 MR. SOLOMON: Mave to strike everything
20 before “did you review" as being testimony of
21 counsel.
22 THE WITNESS: Bo you want to repeat that
23 question?
24 MS. YIM: | will have the record read
25 back.

Aiken Welch Court Reporters Robert Ross 7/14/2011526

1 on their harchats?
2 A. No,
3 Q. Do you recall if the hardhats were a
4 particular color?
75 A. No,
6 Q. Do you recall if Webcor used any
7 particular logo or insignia?
& A. No.
9 Qa. Do you know the names of any Webcor
10 employees who worked at the site?
i1 A No, ma'am.
12 Qa. Do you Teall how many Webcor employees
13 you saw at this site?
14 A. A couple of laborers. Looked like the
15 general foreman. | am not sure it was him but it
16 looked like one. Dressed a little better
17 sometimes. Different hardhats.
18 Qa. What duties were the laborers performing
19 on this site?
20 A. Sweeping.
21 Q. Did they remove materials at all, if you
22 recall seeing that?
23 A I don't recall seeing removing any
24 materials.
25 Q. Do you recall if they performed any other

Aiken Welch Court Reporters Robert Ross 7/14/2011>

duties other than sweeping?

, 2 A I didn't see anything else. Or | can't
3 remember seeing anything else.
4 Q. Do you recall what materials they were
5 sweeping off the floor?
6 A. Kaylo, Pabco, all purpose mud.
7 Fireproofing.
8 Q. Anything else?
9 A. No, not that | can remember.
10 Q. Did you clean up any of your scraps on
11 this job site?
12 A. Yes.
13 Q. Sir, do you recall your proximity to
14 Webcor laborers?
15 MR. SOLOMON: Objection. Overbroad. Go
16 ahead.
17 BY MS. YIM:
18 Qa. Strike that. Do you recall how close you
19 were to -- da you recall Webcor laborers sweeping
20 within twenty feet twenty feet of your presence on
21 this job?
22 A. Yes.
23 Q. Did their sweeping work in your presence,
24 did that range again in proximity?
25 A. Yes.

527

Aiken Welch Court Reporters RobertRoss 7/14/2011clarifying question.
EXAMINATION BY MR. ZACHARIN:

Q. When you arrived at the scene was it just
an empty shell that had been gutted?

A. No. It was — it had been an empty shell,
.but they had put some equipment in there. But you
could tell -- | mean | could tell it was just a
remodel. It's like they tore everything out in
here and then they started all over again. This
is not a good example.

Q. When you were there, at anytime when you

were there was there any tear out of any existing

materials going on or was it just putting in new?
A. To the best of my recollection they are

putting in new.
EXAMINATION BY MS. BUCKMAN:
~Q. Okay. Sir, you recall that they were
putting in new materials. Was there fireproofing
instalied at this building at the remodel job at
the Naval Supply Center? /

MR. SOLOMON: By that do you mean was it
in the process of being installed or was it
existing in the building?

MS. BUCKMAN: | believe he said he was

ihere when they were installing new materials.

543

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=

_ BY MS. BUCKMAN:

Q. So was it in the process of being
installed while you were there?
A. - The fireproofing, at least the portions |

saw was already installed.

Q. Did you see the fireproofing installed?
A. No. | can't remember.
Q. Now, you previously testified you thought

they were putting In new materials. To your

knowledge was this fireproofing newly installed

fireproofing?
AL Yes.
a. Do you know the brand or manufacturer —

strike that -- do you know whe installed the

fireproofing?
A "No. /
a Do you know the brand or manufacturer of
the fireproofing?
OA No.
Q. Do you know who supptied the fireproofing?
A No.
Q. Would it be true then since you don't know

the brand or manufacturer or the supplier, that
you do not know if it was asbestos containing

fireproofing?

544

Aiken Welch Court Reporters Robert Ross 7/14/2011ec

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oOo © NN DR HO fk WO NY

545
A. Repeat the question, please?
Qa. Would it be true then because you don't
know the brand or manufacturer or who supplied it
that you wouldn't know if it was asbestos
containing?
MR. SOLOMON: Objection. Absolutely
misleading and argumentative.
THE WITNESS: That's not true,
BY MS. BUCKMAN:

Q. Okay. Did you know if it was asbestos
containing?

A. Yes.

‘a. To your knowledge do you believe it was

~ asbestos containing?

A. Yes.
a What is the basis of this knowledge?
A. When | previously testified about how {

know what is new and what's old in insulation, —
yes. .
Qa. Is that because of the consistency of it
being a little bit finer?
MR. SOLOMON: Objection. The question
implies or responds to only part of his prior
testimony. So it's misleading and argumentative

and intended to mislead the witness. Go ahead,

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oo nt OD oO BR WwW NM

10

sir.
THE WITNESS: Partially because of that.
BY MS. BUCKMAN:
Q.. And what else is the basis of your .

knowledge that this fireproofing was asbestos
containing?

A The main thing is it was -- it’s a lot
different than the new. In fact, back in those
days we didn't know anything about new. There
wasn't any new fireproofing. They didn't know
anything about.this then. They just put in the
old type fireproofing, and that contained

asbestos, on every jab. Nat just one but on every

MR. TWU: Remove to sirike nonresponsive

and speculative portions. ,
BY MS. BUCKMAN:

Q. Moving on just a little bit. You
testified that you saw -- strike that — did you
see the Advance Mechanical contractors disturbing
ihis fireproofing when they were -- strike that --
you testified that you saw them scraping
fireproofing. Is this the same fireproofing that
you saw them scrape, this newly installed

fireproofing?

Aiken Welch Court Reporters Robert Ross 7/14/2011

|EXHIBIT JSUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
—o0o--
ROBERT ROSS and JEAN ROSS,
Plaintiffs,
vs. NO. 275731

C.C. MOORE & CO. ENGINEERS,
et al.,

Defendanis.
i

DISCOVERY DEPOSITION OF ROBERT ROSS
(Volume ¥}
(Pages 616 through 1076, inclusive}

Taken before RICHARD LENZ!
CSR NO. 2564

August 6, 2011=

So om us DOD oO fF WwW NY

San Francisco in the early 60's and again with
Consolidated, at which of your jobs did you see
Webcor?

THE WITNESS: To the best of my
recollection it was ACandS in 1960 to 1966. No.
No. ! am sorry. That's the wrong 1960 -- that's
right. On Geary Street. 1960 fo 1966.

BY MS. YIM:

fee er ee ni oy
Q. Okay, Sir, is this thé Kaiser Hospital

that is located at 2425 Geary?

A. I don't know the exact -- it's on Geary
Street, | know that much.

Q. Because | understand there is a couple of
Kaisers on Geary Street. There was one closer to
6th Street and one that is closer to Masonic.

A. This one was closer with Van Ness.

Q. You have got on here -

MR. SOLOMON: Counsel, for whatever
reason, and | don't Know what you have got, but
when | took notes from his testimony | had him at
the Kaiser Hospital in Oakland. Are you sure it
was the San Francisco one? That is not what!
have got. Which creates problems.

MS. YIM: |! had it as San Francisco.

BY MS. YIM:

1059

Aiken Welch Reporters Robert Ross 08/08/2011eat eas en a

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1061
MR. SOLOMON: Okay, Tina. | am not saying

you did it intentionally, but [ am bringing the
problem to your attention.

MS. YIM: That's fine. | will go back and
review the record in the meantime and we can move
on to the Administration.

BY MS. YIM:
@. Lets move of to the Administration
Building, sir.
A. Yes, ma'am,
Q. This was a Consolidated job between 1967
to 1972?

ey
A. Justa minute. Are we on the record now?

MR. SOLOMON: Yes. She just asked a
question.

THE WITNESS: | know what she said, but !
am trying to find it.

MR. SOLOMON: What are you looking for?

THE WITNESS: Administration Building.

MR. SOLOMON: Right here.

THE WITNESS: I will never find it in that
pile, would I? Here we go. Yes. 1967 to 1972
Consolidated Insulation, right, Webcor Builders,
right. Yes.
BY MS. YIM:

Aiken Welch Reporters Robert Ross 08/08/20111064
4 BY MS. YIM:
2 Q. Sir, your inferrogatory responses indicate
3 that your co-workers were Gene Thompson, Earl
4 Beck, Robert Cantley and Mickey Johnson. Is that
5 correct? Is that your recollection at this time?
6 “AL Yes.
7 Q. Do you recall any other co-workers on this
& job site?
9 A. No.
10 Q, Sir, your interrogatory responses also
41 indicate you worked with Eagle-Picher cement and
12 Pabco 120 blue cement. [s that your recollection
13 at this time?
14 ‘A. Yes, ma‘am.
2 |

15 Q. And do you recall that Webcor Builders was

16 on this job? Were they the general contractor?
17 A. Yes, ma’am.
} 18 Q. Do you recall which trades they employed
i 19 on this site?
20 A. Laborers.
21 Q. Do you recall any other trades they

22| employed?

23 A. That they employed?
24 Q. Yes. Directly employed.
25 A. No.

~Y

Aiken Welch Reporters Robert Ross 08/08/20111066

4 Q. Do you recall if they applied any material
2 to the floors before cleaning up the material?
3 MR. SCLOMON: Objection. Vague. Go
4 ahead.
6 THE WITNESS: No.
6 BY MS. YIM:
7 Q. Co you recall if they wet down any of the
8 materials with water before sweeping up the
9 floors?
10 A. No.
1 Q. And was the range of the Webcor laborers
12 -- do you recall what materials they were sweeping
13 up off the floors?
14 A. They were sweeping up the fireproofing,
| 15 | mud.
16 Q. Mud?
17 MR. SOLOMON: Mud may be vague.
18 THE WITNESS: Pabco 127 blue, Eagle-Picher
19 mud.
| 20 MR. SOLOMON: The insulation muds as
{ 24 opposed to like drywall muds?
| 22 THE WITNESS: Yes.
| 23 MR. SOLOMON: Okay.
|_ 24] ___THEWITNESS: They. swept that up too.
25 | Anyway, just whatever was on the floor they

Aiken Welch Reporters Robert Ross 06/08/20111 A. Yes, ma'am.
2 Q. | believe you testified about this job at
3 Jength in your prior depositions.
4 MR. SOLOMON: So let's go over it all over
5 again.
6 BY MS. YIM:
7\ Q. Sir, do you recall’ Webeor Builders as a
8 general contractor on this job site?
9 MR. SOLOMON: Objection. Misleading.
10 THE WITNESS: Yes.
11 BY MS. YIN:
12 Q. De you recail them as anything else other
13 than a general contractor cn the Steam Plant job?
14 A. James Whitaker. That was a general on the
15 job too.
16 MR. SOLOMON: Wait, wait. Can I have the
VF last question read back?
18 {Record read: Do you recall Webcor
19 Builders as a general contractor on this job
20 site?)
21 BY MS. YIM:
22 ©. Do you recall them being anything other
23 than a general contractor on that site?
24 MR. SOLOMON: She is just asking about
}25 Webcor.

1072

Aiken Welch Reporters Robert Ross 08/08/20111073
1 THE WITNESS: No. They were justa
‘ \2 general contractor.
» 3) BYMS. YIM: .
: 4 Q. Did they employ any cther trades other
5 than laborers on this job that you can recall?
6 A. Not that | know of.
7 Q. Do you recall how many laborers they
8 employed on this job?
9 A. No.
10 Q. And as laborers do you recall they were
11 sweeping up the job site?
12 A. Yes, ma'am.
13 Q. Do you recall them performing any other
14 duties other than sweeping?
: 15 A. I didn't see any. | didn't notice any.
16 Q. And | understand this job was aboui one
17 week in length?
» 18 A. This particular job, yes, ma'am.
/ 49 Q. Did they apply any water to the materials
20 on the floor before they swept? |
/ 24 A. No
| 22 Q. And do you recall what materials they
| 23 swept off the floor? ;
| 24 A. They swept up Pabco insulation. CAFCO.
| - 25 Garlock gaskets. Fiexitallic gaskets.
>

Aiken Welch Reporters Robert Ross 08/08/2011EXHIBIT kSUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SAN FRANCISCO
--o0e--

ROBERT ROSS and JEAN ROSS,

Plaintiffs,
VS. NO. 275731

C.C. MOORE & CO. ENGINEERS,
et al.,

Defendants.

DISCOVERY DEPOSITION OF ROBERT ROSS

(Volume VI}

(Pages 1077 through 1320, inclusive)

Taken before RICHARD LENZI

CSR NO. 2564

August 9, 2011

ly signed by Richard Lanel (20Page 1086

1 ones we haven't discussed. Is that fine, sir?

2 A. That's fine. EK
3. C~™” “oO. “Sirs fee the remaining job sites, the :
4 Uc Berkeley job sites, Warren Hall, the boiler
5 plant and the Kaiser Hospital where you worked for
6 ACandS in the 1960's, was Webcor a general

contractor at each of these job sites?

AL Yes, ma'am.

3 QO. And do you recall if they employed any

a SST ES SEE

0 other trades than laborers?

A. Wo, I don't recall.

©. Bnd you have testified consistently that

the laborers were performing sweeping duties. bid

they perform anything else? Did they perform any

other duties at these job sites?

A. Moving materials and things dike that,

Oo. Do you recall seeing the laborers use
anything other than brooms or shovels to sweep the
floors?

A. Me.

Did you see them ever apply any material
to the floor before sweeping?

No.

As to all of the job sites that we

Aiken Welch Reporters Robert Ross 08/09/2011
Electronically signed by Richard Lenzi (201-178-686-4815) eb894b17-b404-4993-5580-c2ea77bdsdelPage 1087 f

ecm nee amnmines oe

1 discussed, Webcor Builders, boiler plant, that we
2° are going to discuss, boiler plant, Warren Hall
3 steam plant, the Administration Building in
4 Richmond and the Kaiser Hospital in San Francisco
5 when you worked there for ACandS, did Webcor ever
6 provide you any tools or materials?
3 A. Wo, ma‘am.

re Q. Did they provi fe you with any instructions
9 on how to perform your work?
0 A. Wo.

a ere cen

li Q. Sir, going to the University of California
2 Boiler Flant. Your interrogatory responses
3 indicate that you worked there possibly July ta

14 October 1961 or July 1942 to May of 1965. Do you
15 have a recollection which time period that may

16 have been?

17 A. Just during that time period.
8 Q. It was off and on for about three weeks?
2 A. Yes.

20 Q. And your employer for this job was

21 Western Asbestos?

22 A, Yes, ma'am.

23 Oo. And your interrogatory responses indicate
24 that you applied Kaylo block insulation?

25 A. Yes, ma'am.

SSOP FT TT

Aiken Welch Reporters Robert Ross 08/09/2011

Electronically signed by Richard Lenzi (201-778-696-4515) ehBS4b17-bAl4-a933-bee0-c2e377hdsd61Page 1088 |:

1 Q. Sir, do you recall what materials you saw
2 Webcor Builders sweep?
3 A. The block insulation, the mud,
4 Thermobestos. R-Thermobestos. That is what
5 Western MacArthur used to use. It was Western
6 actually at the time. Western Asbestos. They
7 used to use a preduct called Thermobestos.
8 @. Do you recall if they swept up any other
9 materials on this site? :
10 A. The asbestos muds, the blocks, the mag
11 blocks, the powerhouse mud. That's about it,
12 : a. Sir, wore they aWeeping up as you |
13 testified before in the same range of three ta
14 twenty feet?
45 A. Yes, ma'am.
16 Q. Bt times were they also working within
7 twenty feet of your presence?
18 A. Yes, ma'am,
19 Q. Would you be able to estimate the total
20 amount of time they were sweeping within twenty
21 feet of your presence? :
22 A. No, ma’am. :
23 OQ. Do you recall how many Webcor employees E
24 were on this site? :
245 A No, ma'am. :

Aiken Welch Reporters Robert Ross 08/09/2011
Electronically signed by Richard Lanzl (201-178-886-4815} eb894b17-b404-4533-h680-c2e977busd811 en this site?

2 A. Well, without referring to my Exhibit A, I

3 would say a few days.
4 Q. If you want te refer to your Exhibit A

5 that is fine. Your interrogatory responses

6 actually don't indicate a time and that‘s why I

7 was asking.
8 MR. SOLOMON: It says two weeks here.
9 MS, YIM: All right. It didn't say

10 anything in the interrogatory responses.

11 MR. SOLOMON; It says two weeks. Is this

12 eff and on or is it continuous, if you recall?

THE WITNESS: I think I went back once.

BY MS, YIN:

>

QO. Sar, do you recall where in Warren Hall
you worked?
A. All I know it was a building. That's all

I can remember.

QO. When you said you returned there once, did
you see Webcor Builders on both occasions or just
one of the occasions you were at Warren Hall?

A. Both.

QO. Was this a job where you worked there for

some time, left and then came back shortiy

thereafter?

Biken Welch Reporters Robert Ross 08/09/2011
Electronically slyned by Richard Lenzi (201-176-686-4815) eb804b17-b404-4933-b620-026377 bdSd61Page 1091 |
1 A. All I remember is I came back. I don't :
2 remember if it was a week, if it was two weeks, a ;
3 day or two days. I can’t remember. But I know I :
4 went back. :
5 Q. Sir, your interrogatory responses E
6 indicated that you insulated pipes and ducting
7? where you did some tis-in work. Is that your
& recollection today?
9g A. Yes, ma'am.
10 O. Do you recall the brand name, 4
11 manufacturer, suppiier of the insulation you used f
: 12 en this site?
13 A. Insulation that I nsed?
14 QO. Yes.
15 A. Wo, ma‘tam, I don't.
16 Q, Do you recall if you used fiberglass
17 insulation or some other type of insulation?
18 A. Fiberglass. /
19 0. What materials do you recall Webcor
20 Builders sweeping on this site?
21 A. OGver-spray that was on the floor,
: 22 Fireproofing. There is a big difference between
: 23 the old fireproofing and the new fireproofing, you
: 24 know.
i BS OG. You testified about that before, sir. :
Biken Welch Reporters Robert Ross 08/09/2011

Electronically signed by Richard Lenzi (201-178-G86-4815) eb384b17-b404-4929-bés0-