Motion-Secondary: CHARLES HUSBAND VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS

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                                NOVATO, CALIFORNIA 94948-6169

oem NY KD he BY

10

ALAN R. BRAYTON, ESQ., 8.B. #73685
DAVID R. DONADIO, ESQ., 8.B. #154436

JENNIFER C. BENADERET, ESQ., 8.B. #269953 ELECTRONICALLY
BRAYTON&PURCELL LLP
Attorneys at Law sopehr IL ED,
5 Rush Fanding Road County of San Francisco ‘
Novato, California 94948-6169 SEP 29 2011
(415) 898-1555 Clerk of the Court
Tentative Ruling Contest Email: contestasbestasTR@braytonlaw,com BY: WILLIAM TRUPEK
Deputy Clerk

Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

ASBESTOS
No. CGC-09-275098

DECLARATION OF JENNIFER C.
BENADERET IN SUPPORT OF
PLAINTIFF'S OPPOSITION TO
DEFENDANT YORK INTERNATIONAL
CORPORATION’S MOTION FOR
SUMMARY JUDGMENT-PART TWO

CHARLES HUSBAND,
Plaintiff,
vs.

ASBESTOS DEFENDANTS (BP)

eee

Date: October 13, 2011

Time: 9:30 a.m.

Dept: 220, Hon. Harold E. Kahn
Trial Date: November 14, 2011
Action Filed: March 2, 2009

K Ainjuned:tOS815 pido jeb-YORKIN-part 2p 1 JCB
DECLARATION OF JENNIFER. C, BENADERET IN SUPPORT OF PLAINTIFI'S OPPOSITION TO DEFENDANT YORK
INTERNATIONAL CORPORATION’S MOTION FOR SUMMARY JUDGMENTEXHIBIT E000!
t INTHE SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 IN AND FOR THE COUNTY OF SAN FRANCISCO
~--o0g---
CHARLES HUSBAN
Plaintiff,
ys. No. 275098
6

ASBESTOS DEFENDANTS (BP),
7

wr

wok

Defendants.

14 NEWLY SERVED DEPOSITION OF CHARLES HUSBAND

15 VOLUME]
16 (Pages 1 through 180, inclusive)
1?
18
19
20 Taken before Kimberly L. Avery
al CSR No. 5074
22 April 18, 2011
23
24
25
HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 1

EXHIBIT © —00071
1 A. | don't recall.

2 Q. Do you recall the weight of the cardboard boxes
3 of joint compound?

4 A. A lot heavier than the bags, is all I recall.

5 Q. Do you recall the weight of the bags of joint

6 compound?

7 A. 1 don't recall.

8 Q. And do you recall the size, the dimensions of

9 the bags the joint compound came in?

10 A. Well, they could be in little bitty sacks.

1] They had to be in at least a couple pounds, five-pound
12. sacks.

13 I don't recall the weight on them, you know,

14 Q. Do you recall the dimensions, like how long or
15 wide they were?

16 A. No. No.

1? MS. HUTH: | think that's all T have for now.

18 THE WITNESS: Thank you.

19 EXAMINATION BY MR. BURKE:

20 = Q,_Hi, sir, my name is Nick Burke. I'm going to
21 switch gears and ask you about a different arca of your
22 employment history.

23 Do you recall working for a company calied
24 Whalen Engineering? .
25 A, Whalen Engineering, that's my -- Whalen,

HUSBAND, CHARLES 4-18-11 VOL 1 NS. txt

Page 7100072

| W-H-A-L-E-N, that was my father's business.

2 refrigeration enginecring.
Q. Okay. Where was that located?

A, In Emeryville or Oakland. It's right there

3

4

5 glose to the border, off the freeway.

6 ©. Did you ever work at Whalen ~ how do you

7 pronounce that?

8 A. Whalen, like Waylon Jennings. something like

9 that.

10 Q. Whalen Engineering, did you ever work at Whalen
11 Engineering for pay?

12 A, Well, sometimes J cot paid, yeah, It was a

13 family business.

14 Q, Okay. /

1S A, Thad to ~ I'll let you ask the questions and

16 V'ilanswer,

17 Q, Well, twas looking at your Social Security

18 records, and I don't see it listed,

19 A. No, you won't see it listed, I didn't have a

20 Social Security number at that time. You are talking
21 about at the age period of about 14 to. 17, maybe even
22 earlier,

23. Q. So approximately what years did you work for
24 Whalen Engineering?

25 A. Okay. J got to go time machine.

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 7200073
1 Lwould have to say in the late "50s, all the

2 way up in the 'G0s, you know. Some grade schoal,
junior high, aud high school days.

3

4 Q. Do you recall the Jast year that you worked for
5 or you worked at Whalen Engineering?

6 A, Well, Lwent to Vietnam in ‘68, so went in

7 the Army in '67, so it would have to be in '66.

8  Q,_Now, vou mentioned that you were in school at

> the time. Was this work that you performed on the

10 weekends or --

il A. [performed it on the weekends. [went to the

12 shop, and my dad brought the work to the house for me

13 to dg sometimes at night, you know, a couple hours here
14 and there, because he was in rebuilding of the

15 refrigeration industry, you know, take new and make
16 new -- take old and make new, I mean.

12 Q. Sure.
18 What specifically, what kind of work did you
{9 perform?

20 A. Teardown.
21 Q. What's teardown?
22 A. If you rebuild a compressor, you have to fear

23 it down,

24 Q._ And were vou doing this when you were in grade

25 school?

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 7300074
| A. Yes.

2 9. Could you describe what's involved ina

3 Jeardown?

4 MS. ‘TAFISI: Calls for speculation.

5 THE WIENESS: You have kind of --
6 MS. TAFISE Let me finish my objection and vou

7 can go ahead.

8 Calls for a narrative. Vague and ambiguous.

9 THE WITNESS: J can probably go down and take a
10 picture, but the shop is not there.

it Tt was like an assembly line. You bring in the

12 compressors, they tear down the unit that's bad in the

13 component, the compressor or whatever comes down the
14 line, vou wash them, vou clean them, take them apart,
1S and it goes down to the end and vou wash them again,

16 scrape gaskets off of them, clean them out for — to
17 renew them,

{8 BY MR. BURKE:
19 ©. Se vou washed compressors?
20 =A. Yes, in solyent, and scraped gaskets, and

21 cleaned goo off of them with screwdrivers, wire

22 brushes, whatever, you know, get stuff off of there,
23 QO. When did you start -— strike that,

24 Did you start -- did you take apart compressors
25 for the entire time that you worked for Whalen?

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 740075
1 For example, in the 1950s when you were in

2 grade school, were you taking apart compressors?

3 A. Sure. Yeah. I had the money to party with,

4 you know.
5 I would go down on the weekends, every weekend,

6 sometimes half days, but migrated to the house because

7 Teould do more at the house, because some days I had

8 off. I didn't get up early enough to go into my dad’s

9 shop, because I lived in Lafayette and it was in

10 Qakland, Emeryville, so a lot of stuff -- 1 had older

11 brothers and younger brothers, and we all helped out,
12 Q. Can you estimate how many hours per week you

13 worked at your dad's shop?
14 MS. TAFISE Overbroad,

45 THE WITNESS: Well, let's say he worked on the
16 weekend, so, you know, the weekend I would be stuck

17 there for 20 hours, but I'd sneak off sometimes early.
18 Lwould say weekly starting in grade school it would be

19 about a week -- I wouldn't put in more than 20 hours,
20 45 to 20 hours.

21 BY MR. BURKE:

22 = Q. _ Starting in grade school, continuing until high
23 school, you worked, at your dad's shop for 15 to 20

24 hours; is that correct?

25 A. Yeah, all the way up to senior in high school

HUSBAND, CHARLES 4-18-11 VOL 1 NS. txt

Page 7500076
| where I volunteered for the draft so I didn't haye to

2 werk for him.
3 I'm kidding,

4 Q. When you were in schuol, grade school, junior
5 high school, high school, did you engage in any extra-

6 curricular activities, for example, any sports or

7 anything like that?

8 A, Wrestling, yes, track.

9 OQ. Wrestling?

10 A, Track, yeah.

ti - Q,_ "Wrestling and track?

12 A, Yes,

13 Q. When did you start participating?

14 A, Wrestling was only a couple weeks and the track

15 was only a couple weeks, because I didn't get along
i6 with the coach. And wrestling, he put me in too high
17 of a weight class, and I wanted te come out with all my
18 limbs.

i9 =. _So you were only on the wrestling team for a
20 couple weeks?

21 A. Yes, Yes.

22 Q. And you were only on the track team fora

23 couple weeks?

24 AL Yes.

25 Q. Was this junior high school or high school?

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 7600077
i A. No, that's high school. We didn't have any

2 sports like that too much in grade school or

3 intermediate, We had a football team, but, you know.

4 Q._ Were you on the football team?
5 A. Ne.
6

Q. Any other extra-curricular activities after

7 school?

8 MS. TAFISE: Vague and ambiguous,

9 BY MR. BURKE:

10. Q. From grade schgol to high school?

il A. Oh, yeah, after hours, you know, after I come
12 home and do homework or whatever I had to do to get
13 something ready for my dad to rebuild at the shop the
14 next day, because we all helped out, my brothers, but,

15 you know, maybe I'm a little light on the hours, but

16 I'm just trying toe -- vou know, in the long run,
17 because like on the weekends, you know, you only worked

18 in the daytime and you go party at night, you know,
19 that's extra-curricular activities, go to the high

20 schogl dance, you know, go get drunk, go get in
21 trouble, you know.
22 . So most of the work you performed for your dad

23 for Whalen Engineering was on the weekend, correct?

24 A, Yes, Yes,

25 Q, And how much did your father pay you for this

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 7700078
1 work?

2 A. F think three or four dollars an hour, That

3 was a lot of money in them days.

4 Q. When was -- when did he first start paying you
5 for this work?
6 A. When I started.

Q. So --

8 A. Well, it was more like paid in advance, and I

9 had to work it off, so that's how I worked it off. And

10 Lkind of got stuck with it because the cash he'd

11 come -- I didn't particularly like the work because it
12 was really dirty, you know.

13. Can you estimate how many compressors vou

14 worked on during the time you worked for vour dad at

15 Whalen Engincering?
16 MS. TAFISE, Overbroad.

7 THE WITNESS: Per day I can say I tore down

18 about maybe 10, eight to 10, depending on the

19 compressor, you know. Some compressors had bolts you
20 couldn't get off, so I had to heat them or do

something, cut them off or do something, you know, but

nN

22 that's after a crank shaft blows and stuff, you know,
23 you have to get the parts out. ‘The casing is still

24 good.
25 BY MR. BURKE:

HUSBAND, CHARLES 4-18-11 VOL 1 NS. txt

Page 78g0079
tO. You said “per day.” Would this be on the

2 weekend?

3 A. Yes. Yes. On the weekends per day, but at the

4 home, no, maybe two -- two at the most, if 1 did,

5 Q. Ona weekly basis, how many compressors did you

6 take apart?

7 A. 15 to 20. 1 weuldn’t go any higher than 25,

8 26. We had an upper shop area at the house in

9 Lafayette where it was set up the same as his shop but

10 a lot smaller, you know, with air and water,

11 everything, solvent to clean gaskets and all that
12 gtuff,

13° Q. At your house?

14 A. Yes.

15 Q._Do you know the brand name or manufacturer of
16 any of the compressors you took apart when you were
17 working for your dad? .

18 A, _I'd have to think about that, because I

19 testified before about these compressors. We got the
20 ones submersed in cil, We got... There's a York,

21 There was Frigidaire, G -- Electric, what's that
22 Electric - General Electric -- I don't know, General

23 Electric.

24 I'll have to get back to you on those, They'll

25 come to me,

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 7900080
| You know, we did -- because there wasn't any

2 manufacturer that we didn't bust down and fix there.

3. Q. Okay. You mentioned York, so I’m going to ask
4 you questions about York,

5 How do you know that you worked with York
6 compressors?

7 A. Because of the name, York,

8 Here we go with the...

9 Ican't tell you what.color they were. [can't

10 tell you -- I can only tell you that some of them were
11 bigger than the others, two cylinder, ane cylinder, vou
12 know, may have been bigger ones, but as a teenager I
13 never got to tear down the big ones because my dad
14 deemed it too unsafe for me.

15 Q. Can you estimate, as you sit here today, how

16 many York compressors you worked on when you were
17 working for your dad?

18 A. Oh, no, no, I can't tell you. God, that would

19 be -- T would be rich if T could remember all this

20 stuff. I mean, General -- York -- you mean my whele

21 time, you are saying my whole time working, how many
22 Yorks did 1 tear down?
23. Q. The whole time you worked for your dad, so from

24 grade school through high school.
25 MS. TAFIS Overbread.

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 8000081
1 SHE WITNESS: 1 would say York was about 25,

2 30 percent of our -- of our work, so, man, I'd say

3 about one-third.

4 Ican't give you numbers, but I can say about
3 30 percent.

6 BY MR. BURKE:

7 Q. Okay, That's fine,

8 So 30 percent of compressors you worked on when

9 you were working for your dad were York compressors?
10 A, Tecan remember the York because I_had to order

il parts for some of them, and, you know, Frigidaire and

12 all that stuff, They'll come te me, but I just --

13 these were -- Yorks were bigger compressors than most
14 that T remember.

15 Q._Let's stick with York for now.

16 A. Yeah.

17 Q._ Can you tell me what the York compressors that
18 you worked on looked like?

19 MS. TAFISE: Calls for a narrative.

20 BY MR. BURKE:

21 = Q,_For example, size and shape.

22 A. Sizes are different, but the configuration

23 like, looks like a small Harley motor, cylinders come

24 out on each side, you know, with valves on top, but
25 they are not conventional valves, but...

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 8100082
} Q. What type of York compressors did you work on.

2 ifvou know?

3. A. The type that pump to air conditioning, not the

4 York compressors that did air.

§ Q._ Do you reca]]_ how many cylinder heads any of

6 these York compressors had?

7 A. Well, I was saying T was thinking one, but I'm
8 not sure of that, but I remember two and four, but I'm

9 not positive on that because they were bigger than

10 most,

iM Q. Do you recall if you worked on hermetic or
42 semi-hermetic --

13. A, We worked on hermetics, the stuff that's

14 floated in oil, but that was a process that we had to

15 cut -- cut it in two to get the guts out to rebuild
16 them.

17 Q. Were there any distinguishing characteristics

18 of the York compressors that identified them as York
19 compared to the other compressors?

20 MS. TAFISE: Vague and ambiguous. Asked and
21 answered,

22 THE WITNESS: No, just -- just York -- just
23 York stuck with me; that's all,
24 BY MR. BURKE:

25 . Do you recall any logos or markings on the York

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 8200083
| compressors?

2 MS. TAFIST; Vague and ambiguous as to "logos

3 and markings."
4 THE WITNESS: At one point in my testimony I
5 went through this, maybe talking to me now it's

6 changed. [don't know. I mean, T can't seriously -- J

7 mean, T could get serious about it, but, you know, it's

8 going to be really hard for me to pinpoint what you are
9 asking,
10 BY MR. BURKE:

1 . That's okay. I'm just trying to get your best

12 memorv as you sit here today.

13 So as you sit here today, can you recall any
14 logos or markings that you associate with York
15 compressors?

16 A. _Ican't recall at this time,

17 MS. TAFISI: Same objections.
18 BY MR. BURKE:
19  Q. Do you reeall any colors that you associate

20 with York compressors?
21 A. Well, the colors we used were like a black, a

22 gray, and an off red. So if we paint them, it had to

23 be one of those three. And as far as factory color, we
24 usually painted it the same factory color, but I can't

25 distinguish between all those compressors which color

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 8300084

| York was, only the fact is because when they came down

2 the line they were pretty much covered with oil and

3 dirt.

4 Q. Do you recall ever seeing the name "York"

5 stamped anywhere on the compressors?
6 =A. Yeah. Well, there had to be "York" on

7 somewhere. It's probably a little aluminum or brass
8 plate they put on the side of all the compressors.
9 That's the way | identified them, vou know,

10 Q._ Well, when you say "probably," it makes me

1] think that you are guessing.
12 A. No, no, there was -- there is plates.

13 Probably," meaning T was thinking about the metal.
14 That time period it was probably brass or copper,

13 Brass is cheaper than copper, so it was probably brass,
16 And they put aluminum ones on them, too, for the

17 manufacturer's name and specifications on them,
18 Q. Do you recall the style of lettering or of any
19 of the "York" stamps that you saw on the York
20 compressors?

21 A. No, no, it -- that's vague. I could have said,
22 earlier testimony that I did because, you know -- J
23 wish } could remember that stuff,

24 No.

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 8400085
1 MS. TAFISE: Belated objection. Vague and

2 ambiguous as to "style."
3 BY MR. BURKE:

4 Q. Were there gaskets used in conjunction with any

5 of the York compressors that you took apart when you

6 worked for Whaten Engineering?
7 MS. TAFISI:; Overbroad,
8 THE WITNESS: Well, when you take off a head,

9 there's a gasket. When you take off -- some of them

10 have pans with reservoir, the oil, they had gaskets.

11 And then where the cylinders went in to bolt to the

12 block it had gaskets. You know, the only ones that
13 didn't have a lot of gaskets were the hermetic type
14 that were in oil,

iS BY MR. BURKE:
16 = Q._ Of the total number of York compressors that

17 you worked with when you were working for your father,

18 can you estimate in percentage terms how many times vou
19

worked with gaskets associated with York compressors?
| 20 A, Probably every time I worked with them because
21 I~ jin the cleaning process and putting together

22 process I never -- it's vague, too -~ I never -- I tore

23 down. 1 didn't rebuild.
24  Q. But what about with hermetic compressors?
25 A. The only thing I got in with the hermetic

| HUSBAND, CHARLES 4-18-11 VOL 1 NS. txt

Page 85

' i
be A0086
| compressors, yes, [cut a few. And the electric motors

2 inside, 1 had to cut the windings out, and the strips,

3 these insulator strips in between, and get them all

4 cleaned up so we could take it upstairs and rewind the

5 motor, because we did it by hand,

6  Q. Can vou describe the appearance of any of the
7 gaskets that you associate with York compressors?

8 ALNo

9 MS. TAFISI: Vague and ambiguous as to

\0 “appearance,” _Overbroad.
i THE WITNESS: No, I don't.
12 BY MR. BURKE:

13 Q. How about the size of the gaskets that you

14 associate with York compressors, can you describe the
15 size of any of the gaskets?

16 A. ‘The only thing I can say by size is the -- you

17 know, you get the gasket that fits the right spot. I

18 mean, no -- no gaskets are the same size.
19 ). What shapes did the gaskets come in?

20 A, Well, you get square holes, you get round
21 holes.

22 -Q._ Any particular colgrs that you associate with
23 the gaskets?

24 A. Most of the gaskets were grayish.
25 Q. Do you recall their consistency, fer example,

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 8600087
| were they oily or dry?
2 A. Weill, they were oily on one surface when you

3 take them off, but they came dry, | remember about

4 these gaskets, that they would get really hot and they

5 were reatly hard to get off and break down.

6 Q. When you say they came dry, are you referring
7 to the replacement gaskets?

8 A. Yes. Yes.

9 =. And the gaskets that you took out from York

10 compressors, were they oily?

VW A. They wouldn't come out. You had to beat them

12 out. You had to tear them out.

13 Q. How would vou tear them out?
14 A. A sharp object, sharpened files. Just scrape

15 them off, just to get a bite to get them off.

16. I may have asked this, but the compressors, the
17 York compressors that you took apart, what type of

18 equipment were they used in conjunction with?

ig MS. TAFISI: Overbroad. Overbroad. Sorry,

20 THE WITNESS: Air-conditioning units for chain
21 stores, like Safeway for their freezer units, their

22 gpen boxes. They were industrial type of machines, We
23 rarely did any refrigerators. you know, box

24 refrigerators. When we came in it had all the
25 components on them, so the parts that broke down,

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 8700088
1 usually the compressor that run the -- pumped

2 antifreeze,
3 BY MR. BURKE:

4  Q. Do you recall if there was any thermal
5 insulation used in association with these compressors?

6 MS. TAFISI: Vague and ambiguous,
7 THE WITNESS: Some around the return lines
& because they were hot, you know, after the process of

9 the Freon, to take -- get it cool, it turns hot, and

10 I'm pretty sure that the other ones were insulated,
11 too, to keep them cooler.
12 BY MR. BURKE:

13 Q. Se thermal insulation would be wrapped around
14 the lines? :

15 A. Yeah, lines, yeah,

16 Q._ Do you recall what size or shape this thermal

17 insulation came in?

18 A, Well, the size would be no bigger than, you

19 know, like that, you know, with the insulation smaller.
20 =. Can you describe that in terms of dimensions,
21 That doesn't record,

22 A, Inch round, inch-and-a-half round, to about a
23 half inch.

24 I don't think there would be any smaller than a
25 halfinch, more like three-quarters, five-cighths.

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 8800089
1 Q. Going back to the gaskets, did you ever see any

2 logos or markings on any of the gaskets that you

3 removed from York compressors?
4 A._No. It would probably be impossible to see any

5 names or anything on gaskets on teardowns.

6 =Q. Do you know the manufacturer of any of the
7 gaskets that you removed from York compressors?

8 A. Well, only thing lL can say is that 95 percent
9 of all the compressors that came in, York or whatever,

10 were new, and they had failed, and we had -- we didn't
J] go to the place and take them out, the private

12. contractors would do that and bring the unit to us, and

13 we would fix them,

14 MR. BURKE: Could you read that answer back,

5 (Record read.)
16 THE WITNESS: What I was trying to say is these

17 were all manufactured compressors from the factory, and
18 what -- most of the gaskets that were in them came from
19 the factory, where they were manufactured; that's what

20 [was trying to say.
21 BY MR. BURKE:

22 Q, When you say private contractors would take
23 them out, would the compressors come to you already

24 taken apart?
25 A, Well, no, ng, no. Compressors come out in a

HUSBAND, CHARLES 4-18-11 VOL 1 NS.tat

Page 8900090

1 big package unit,

2  Q, Yeah.

3 A, It's all together and you houk up. The

4 contractors would take that whole unit out and bring it
5 tous, because we had -- after we fix the parts in

6 them, we had to run them. I didn't do that, but I know
7 they did,

8 Q. De you know who employed any of these

9 contractors?

10 A, Excuse me?

11 Q. Do you know who employed any of the private
12 contractors?

13. A. No. Some of these contractors were their own
14 contractors, In that part of the field they weren't

15 union. I'm usually a union man. They are just. you
16 know, newer contractors.

1? Q, Okay. Going back to the thermal insulation
18 that you associate with York compressors, can you

19 describe the consistency of that insulation?
20 MS. TAFISE: Vague and ambiguous.

2) THE WITNESS: Consistency, | would say maybe a

22 little bit flaky or rubbery.

23 Well, they had to be flexible because of the

24 movement, Lremember that part, but as far as, you
25 knew, consistency of material, I don't recall that,

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 9000091
| BY MR. BURKE:

2 Q. Do you recail what color the insulation was?

3 A. That, too, varics, because some people paint it

4 to make it look good. I don't — Lwould have to say a

5 darker color, you know,

6 No, that wouldn't work, a darker color with

7 heat. Tt would have -- oh, no.

8 Ican't recall, [just can't recall,

9 Q. Do you recall if there were any logos or

10 markings on the insulation that you associate with York
1] compressors?

12 MS. TAFISI: Vague and ambiguous,

13 THE WITNESS: No, not with teardown. Maybe if
14 Ewas able to get to the unit before I pulled it out,

15 put it on the teardown, maybe I could -- at the time,
16 no,

17 BY MR. BURKE:

18 Q. Well, as you sit here today, dg you recall any

19 logos or markings?

20 MS. TAFISI: Same,

21 THE WITNESS: No, i don't,

22 BY MR. BURKE: :

23 Q. Do you recall brand names or manufacturers of
24 thermal insulation that you_associate with York

25 compressors?

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 9100092
1 A. No,

2

2 Q. Do you know if any of the York compressors you

3 worked on when you were working for your dad contained

4 ashestos?

5 A. Well, at the time, no, Of course, I know now.

6 you know. If it's like all around, working in oil

7 refineries with gaskets, they are asbestos, not all

& gaskets, but some of the gaskets on high-pressure steam

9 lines and -- are asbestos. J didn’t know now, but J

10 know -- 1 know now, but [didn't know then, so...

li Q._And how do you know that now, where did you

12 learn that York compressors had asbestos in them?
13. A. Gaskets.

14 [don't know. J just knew. I mean, the threat

15 was I call null and void, okay. There was no threat to

16 me with asbestos. I knew it was around, you know, but

17 just the way life was in them days.

18 Q. Did you ever work with nonasbestos gaskets?
19 A, Probably,

20 -Q. De you recall, as you sit here today, ever

21 werking with nonasbestos gaskets?

22 A. No, J don't. .

23 Q. Do you know if York compressors used asbestos
24 or nonasbestos gaskets?

25 A, Well, that's your job. I don't know -- 1

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 92dite

00093

1 didn't know at this time, and, to be honest, | didn't

2 know if they were or not,
3. Q, Okay. That's fine,
4 Did you ever see York compressors delivered to

3 Whalen Enginecring's shop?

6 A, Oh, J seen -- I seen _a lot of them come in, but

7 itt had my head out there in the front to see which

8 compressor was which and not doing work, I'd get my ass

9 kicked. :

10 No
11 Q. So the answer is "no"? :
12 A. Ne, ”

13. Q. Okay. Were you ever inyolved in ordering or

14 purchasing compressors when x ou worked for your father

15 at Whalen Engineering? ;

16 A._No, because my dad was smarter than that. I'm
17 just a teenager, young kid. He he had it already

18 setup, you know, when it came in, and if he didn’t

19 haye the parts in stock, then when the stuff came in
20 he'd check it and order it-so it was ready, the parts

21 were all ready before we got to it.

22 =. Was your father the sote person responsible for
23 ordering parts or purchasing York compressors?

24 A, Yeah, most of the time, and then my elder

25 brother, . .

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 930094
t My dad is gone new. He died many years ago,

2  Q. What's your older brother's name?

A. Marshell, . .

Q._Is he still living?

A. As far as the rest of the family, no. We have
6 lest contact in the family because what happened --

7 well, it's so... You don’t need to know.

wom Ww

8 Q. Do you know where he lives today?

9 A. Yeah, but he won't talk to you.

10 ©, Okay. Where does he live?

11 A. Willows,

12 Q. Willows?

13 A. Willows, That's off highway -- what's that

14 highway? Willows,

15 Tcoeme down off 29, so that's 101,

16 Q. How old is Marshell?

17 A. Oh, ['m 63, he's four years older,

18 ©. And when wag the last time you had contact with
19 your brother?

20 A. _F'm the only one in the family who had contact
21 with him, so it's probably a couple years ago.

22 Q. Seq other than Marshell and your father, was

23 there anyone else who was involved in ordering parts or
24 parts --

25 A. Weil, Lhad a younger brother, too, Stewart,

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 9400095
| Stewart Husband, and he worked there. He did the same

2 grunt werk -- excuse me — he did the same work I did,

you know, tear down, clean up.
Q. Where does Stewart live?
A. Richmond. '

Q. How old is Stewart? os
A. Four, five years younger, but he looks older

3
4
5
6 He's younger.
7
8
9

than me.

10 Sorry.
i Q._Do you have any documents in your possession

12 that indicate the types of compressors that were

13 ordered by Whalen Engineering Company?
14 ALN,
1s Q, Haye you ever had any communications with

16 anyone who has held him or herself out to be a

17 representative of York?

18 A. [don't do that.

19 Q, So is your answer "no"?

20 =A, _No, yes, Except right here. 1 mean, lye had

21 adeposition before where Steve Pelz, he worked with us
22 and tried to get us_a settlement with these compressor
23 companies, but, you know, I don't know. [don't even
24 know it's brought up now.

25 I spent a lot of time tearing down compressors,

HUSBAND, CHARLES 4-18-11 VOL 1 NS. txt

Page 9590096
| believe it or not. As far as asbestos contamination, |

2 don't know, like I told you before.

3. Q. Do yeu know the suppliers of any of the gaskets

4 that yeu worked with when vou were working at Whalen
5 Engineering Company? — :
6 A. I did, and it's on that deposition with Steve

7 Pelz that I did, | got to -- because if it wasn't the

8 manutacturer that we didn't get the gaskets and stuff

9 for them, it was the aftermarket stuff from a supply

10 company in Oakland or San Francisco, but 1 don't

ll remember the name now, but it's in testimony way back,
12 so...

13. Q, Do you recall any of the cross streets that

14 these suppliers were located at?

15 A, No. No. No. [think I did at the time

16 because I researched and researched and researched, but

17 it still had no meaning to it, you know, because my dad

18 is dead and my mom took over the business, but she is
19 89, and she's -- she's there, but she's not all there,

20 you know what I'm talking about. It's hard to get a
21 straight question, : ,

22 MS. STERN: Go aliead, Finish your anower.

23 Could I have the question and answer read back.

24 (Record read.)
25 BY B 3

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 9690097 / .
i Q. Earlier you mentioned that you could tear down

2 eight to 10 York compressor’s ina day. How long would

it take to take apart one York compressor?

A, Approximately half an hour, to 45 minutes, to

an hour. My dad had_a thing, you do this many or you

know, I would say average compressor, 45 minutes, you

3
4
3
6 are going to stay here and do without pay. So, you
7
8

know, because we had all the air:tools and everything

9 there to split everything apart, but there was more

10 cleaning than there was tearing them apart physically.
11 Q, So it would take 45 minutes to tear one apart?
12 A,_And clean it, ,

13. Q, And clean it? soos

14 A, Yes. . t
15 Q,_And then would you put it back together?

16 A, No. Ne. No. It would all be cleaned up ina

17 tray, you know, clean, blown off, and then it would go
18 to the next section with the older brother and staff,

19 and they would start getting the gaskets and all the

20 parts and put it together for reassembly.

21 Q, Did you ever put the York compressors together
22 yourself? od

23 A, No. No. I just tore them down.

24 -Q,_You would just take them apart and clean them?
25 A, Yes.

HUSBAND; CHARLES 4-18-11 VOL 1 NS.txt Page 9700098 ,
{ Q. And what did he use to clean them?

2 A. Well, to get the gil and grease off, it was
3 solvent-based stuff, which is bad for you. But,
4 anyhow, we -- that was at the end, but we would tear

5 them down the line, you know. walk them through and

6 take the bolts off, and sometimes the gaskets would
7 come off, and sometimes they were baked on where you

8 had to like almost hammer and chisel -- not hammer and

9 chisel, but a tool like that, and sometimes you had to
10 use air with a wire brush to get ahold of them so you

11 could pop them out, and sometimes they would just be --

12 some of them would be impossible almost to get out,
13 like they were part of the metal, they got se hot,
14 Q._So were there times where the cleaning process,

15 after you took the compressor apart, simply inyolved
16 emersing the compressor in some kind of solvent?

7 A, Yes,
18 And was there another way to clean it, as well.

19 or was that --

20 A,_No. No. No. The solvent and wire brush, and

2 you bring them up and you get most of the filth and

22 dirt out, and then you blow -- you know, air dry them
23 and then you get the rest, and then after that, with

24 gaskets you can't get off, then you start with a hammer
25 and_a chisel-type thing, or wire brush, you know.

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 98

» ,|
|

00099 : {
1 that's the only way we could get them off,

2 ~—Q. So the first step in the process after taking
3 apart the compressor would be to immerse it in the

4 solvent? “

4
5 A. Yes, and clean it, clean everything,

6  Q. And you would clean it while it was still

7 immersed in the solvent? : :

8 A. Yeah, yeah, under the solvent. .
9  Q._When the gaskets were baked on, how long would
10 it take typically to scrape off the gasket?

ll A. A hard one, 15,20 minutes, or longer.

12 Sometimes you had to set ‘them ‘aside and come back to
13 them. oe :

eo EO .
14 Q. And during the entire cleaning process, was the
15 compressor -- were the compressor parts covered in this

16 solvent? . 4
17 A. Well yo

18 MS, TAFISI: Misleading. ‘Misleading,
19 THE WITNESS: Lightly, yes.
20 BY MR. BURKE; sod

21 Q. What kind of solvent was'this?
22 A. Same kind of solyent'we have today, a clean

23 solvent. I don't know the chemical compound of it,
24 but... . ,

25 = Q. Da you know the brand ‘name?

HU! SBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 9900100 i ;
1 A. No. They were like in tanks, like 40-,

2 50-gallon tanks made -- welded up where we set trays
3 with a hoist, you know, and then yeu put the tray on

4 the hoist and vou set it down in there, you let it soak

5 and you come up and brush it off, brush it off under
6 it,
7 Jt was pretty good solvent. Ii would melt

8 pretty good. 1

9 MR. BURKE: Could we go off the record for a

10 minute.

I (Break taken.)
12 BY MR. BURKE:
13. QO. Mr. Husband, are you,ready to continue with

14 your depositiqn?

1S A. Yes. boy

16, I may have asked this, so J apologize if 1

17 have,

18 A, It's okay.

19 Q, But could you tell me what type of York

20 compressors you took apart [when you were working at
21 Whalen Engineering?

22 MS. TAFISE: Asked and answered,

23 THE WITNESS: The compressor that ran the
24 refrigeration for refrigeration units, the York

25 compressors, the one that recycled the Freon.

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 100!
|
|

00101 .
1 York compressors were a refrigeration part, yeah.

2 BY MR, BURKE:
3. Q. So they ran Freon? |
4 A. Yes.

5 = Q._ Did you work on air compressors, York air
6 compressors? : te

7 A, [worked on York air compressors at -- well, T

8 ran them, started them, Maintaining them was part of
9 my job at Phillips 66, started them up and run them for
10 people that needed them.-
11 Q. Phillips 66?
12 A. Weil, it's Phillips 66, it's Avon,
13 MS. STERN: Are vou talking about the Avon
14 refinery?
15 THE WITNESS: Avon retinery,
16 BY MR. BURKE:
17 Q, We're talking about Whalen right now.
18 A, Fine,
19 No. 4
20. So the only York compressors you worked on --
21 A, Was refrigeration. ‘That's all we did there,
22 was refrigeration. :
23 Q,_Were these centrifugal? , ,
24 A, What do you mean -- central?
25 Q. Well, can you -- you earlier mentioned that

HUSBAND, CHARLES 4-18-11 VOL 1 NS. txt

Page 10100102 1 }

| they were either hermetic’or semi-hermetic. Are there

2 any other characteristics of these compressors that you

could tell me?

3
4 A. No, only they were heavy.
5 Q. Okay. At Whalen were there any safety

6 procedures or policies in place regarding employee

7 safety?

8 MS. TAFISE Vague and ambiguous,

9 THE WITNESS: Yeah, no goofing around, no
10 putting the air hoses in somebody's pant: you know,

11 something like that, that's common sense.
12 BY MR. BURKE:

13. Q. Were there any written policies?
14 A. No. We— my dad run the shop, he was usually

15 common sense, and he had people hired, you know, just

16 limited -- I don't know what to say about that. I
17 mean, there was no policy, no, ne.
18 = Q. Did you wear any protective >» eyewear or anvthing

19 like that when you were working on York compressors?
20 A. Sometimes we wore glasses, you know, glasses to
21 shield stuff getting in our eyes when we were blowing
22 them off or using air, and sometimes, you know, I'd

23 wear coyeralls to keep the oil and grease and solvent

24 off my person,

25 Q. How about gloves, would you wear gloves?
poo

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 10200103 "
1 A. Well, it's almost impossible to wear gloves

2 when you are breaking down machinery. 1 guess you can

3 do it, but we never did,
4 Q, Would you wear a respirator or any type of

5 breathing equipment?
6 A, No.

7 Q. Other than your brothers, are there any other

4
8 co-workers that you worked with when you were at Whalen
9 Engineering?

10 A. ‘There was one or two people that popped up, but

11 Tdon't remember them, you know, their names. T just
12 remember my immediate family, and a China man that

13 worked there, he was real fun. I don't remember his

14 name, but... Lwas the guy that always got teaged down
5 there, always got kicked around;

16 Q. Do you have any information or knowledge that

17 you ever worked at any other job site where York

1& equipment was present?

19 MS. TAFISI: Asked and answered,

20 THE WITNESS: Well, no, I'd haye to say on air

21 compressors the only thing that 1 — I don't know about

22 York, but I know Ingersoll-Rand did more -- had most of

23 the industrial air. compressors. °

24 BY MR. BURKE:

25 Q, Let's stick with York, I'm just asking you -—-

‘

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 10300104
| A, No, No. Na.

2 Q. Do you have any information or knowledge that

3 you ever worked at a job site where York employees were

4 present?

5 A, No, No.

6  Q, Do you know the names of any persons who can
7 provide any information as to any of the work you did

8 with or around any York equipment?
9 A. Well, the only thing I can say now is just my

10 family. As far as the other people, you know, hard to

11 get ahold of or impossible to get ahold, just family.

12 I think the easiest one would be my younger

13. brother Stewart which lives in Richmond.

14 Q._ Do vou know of any documents that could provide
15 information as to any of the work you did with or

16 arqund any York equipment?

17 A. Af there were, they are long past Zone,

18 Q. Earlier I asked you if you knew the suppliers

19 of any of their replacement gaskets that you or that

20 Whalen purchased for York compressors, and --
21 A. Like all the aftermarket stuff was done through

22 a job where it had nothing to do with York or anybody

23 else. The only time we couldn't get, the business

24 couldn't get parts from the manufacturer, it would go
25 in the aftermarket.

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 104ae

00105
1 Q. Let me finish my question,

2 You mentioned two locations, Oakland and San

3 Francisco,
4 A. Okay. Go ahead.

5 Is that correct?
6 A._On the business?

7 Q. You testified earlier that the suppliers of

8 replacement gaskets were in Oaldand and San Francisco.
9 A, Oakland or San Francisco, I wasn't sure.
10 . Okay. Okay, 4

i Did you perform any research in preparation of
7

12 your deposition testimony to determine suppliers or
‘ 2G
13 products or anything that you may have worked with and

14 around during your employment history?
15 A. Not ~ not this deposition, but before the
16 first deposition, curiosity, 1 tried to talk tomy

17 brothers about it, my mom, and I couldn't get anything
18 except for my brothers. There's no other way that]

19 could get that information but through them,

20 But the only thing I remember is outside

21 supplier, aftermarket parts, ;

22 . As you sit here today, can you recall the names

23 of any other brands of compressors that you worked with
24 when you worked at Whalen Engineering?

25 MS. TAFISE Qyerbroad. ,

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 10500106 :
| THE WIINESS: [tried to-answer that before,

2 like Frigidaire products. I'm not sure about General

3 Electric, [don't remember... :
w

4 ‘There's about four or five different other

5 brands that ] just can't recall right now. 7 had it

6 allin memory, but J just -- I just’can’t recall,

7 This was the longest period of time that, you

8 know, in that perspective that J was exposed, so-called

9 exposed to anything, and that goes back 50-some-odd

10 years.
11 BY MR. BURKE:

12 Q. Does the name Frick brand compressors, of

13. compressor sound familiar te-you?

14 A, Yes. Yes. Yes.

iS Q,_Did you work on Frick compressors when you

16 worked at Whalen Engineering?

17 A, Well, Frick was part of the ones that, you .
18 know, that we did, you know. There's about — York,

19 Frick, General -- well, there's about five or six

20 different manufacturers. :

a When you said Frick. you it rang a bell.
22 = Q. Did you work on Frick -- as you sit here today,

23 do you know -- strike that,
24 As you sit here today, do you recall whether

25 you worked on Frick compressors when you worked at

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 10600107
} Whalen Engineering?
2 A, Yes. |

3. Q, And how do you know that you worked with Frick

¥

4 compressors? :
5 A, Well, it was the same thing with York or -

6 because sometimes they haye to double-check to see if

7 the part is there.
8 Like I said before, my father was the one that

9 made sure they were there, but he wasn't, you know,

10 there all the time. 4

1] It was kind of -- the nameplate on the side,

12 you know, always gave me what I needed. Most of the

13 time we had ways because we had to take those plates
14 off the compressors ta put new specifications on them
15. because they are rebuilt, with the bigger pistons or

16 something. , : ,

17 Q. Do you recall seeing the Frick nameplate on the
18 side of the compressors that you worked on at Whalen
19 Engineering? : ,

20 =A. Almost.a handred percent of them had

21 identification plates, j :

22 Q._ i'm just talking about Frick.

23 A. Yes. Yes. :

24 Q. As you sit here today, do you recall seeing a
25 Frick nameplate? : '

i HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 107

a eee
ee ree gt00108
| A. Yes.

2  Q, What did that Frick nameplate look like?

3 A. Brass or tin plate with the manufacturer's name

4 and specifications, what it was. That’ 's the only way I

3 identified the com, pressors Iwas. working on.

6 «Q. Well, it sounds to me like you are recalling in

7 general a manufacturer's nameplate on the side of a
8 compressor, :
9 What I'm asking you is whether you recall

10 seeing a Frick nameplate on a compressor?
i A. Sure,

12 Q, What did that Frick nam: eplate Jook like?

13. A, Manufacturer, :

14. OQ. When you say “manufactirer" are you referring
15 to--

16 A. Manufacturer is Frick, the person who

17 manufactured the product. Most of the -- everything
18 that came in that shop had a plate, identification

19 plate,
20 There's no place on a a compressor anywhere where

21 they could write that dawn without being knocked off.

I vi
22 The plate was put on a square plate, inch-and-a-half by

23 maybe three or two inches, and they had brass pins

24 drove into the metal, brass or aluminum, you know, they

25 would smash, and we had to knock them off with a

HUSBAND, CHARLES 4-18-11 VOL 1 NS, txt

Page 10800109
| serewdriver to replace them because they were rebuilt.

2 MS. TAFISL: Belated objection to the question,

3 asked and answered. Asked and answered, harassing,

4 oppressive. t
5 I'l try to speak up, Kim.
6 THE WITNESS: Like if you come up with another

7 name of a compressor and | recognize if, then we're

8 going to go through the same thing, so I just...
9 Sorry.
10 BY MR, BURKE: {

i }
11 Q. Are you finished?

12 A. Yes, I'm finished.

13 Q. Do you know how many Frick compressors you

14 worked on when you were working at Whalen Engineering?
15 A, No, it's -- you have to have a number, Okay,

16 10, 15 percent, + ‘

17 . Okay. Yeah, Percentage is fine.

18 Earlier you testified that 25 to 30 percent of

19 the air compressors were York,

20 =A. Yorkis a big brand name, like Frigidaire, you
21 know. .

22 Q. What do the Frick compressors look like?

23° A. Well --

24 = Q._ For example, size and shape, can you describe
25 that to me?

4

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

'

Page 10900110 poo
1 A. I'm -- I'm not -- I. don't think that Frick is

2 the hermetic-seal type, I think it is a piston type,

3 you know, because the seal type have electric windings
4 and everything contained, where the other type

\
5 compressors, there's a compressor and you have an

6 electric motor that runs them, that's ail I'm trying to

7 get back, thinking about this stuff. The Frick air

8 compressors are -- they have cylinders, two cylinders,

9 ‘There's no one that I know that has three evlinders.
10 Qne cylinder, two cylinders, maybe, and they could go

11 to four, Some of them I remember went to eight, six or
1
12 eight, and [don't think Frick or York was the

¥

13 manufacturer of that one. va |
14 You know, it's hearsay. I better just shet up.

15 Q. We're not talking about York, we're talking
16 about Frick now. :
17 A. Frick, ves. | .

| a
18 Q._You mentioned air compressors.

19 A. Tdon't mean air compressors, 1 mean pump

20 compressors for Freon, I'm sorry.

21 = Q._So were the Frick compressors for Freon?

22 A, Yeah, 4

23 Q, Okay. Were there any Frick air compressors?
24 A. No. They just compressed the gases, you know,
25 the Freon gases.

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt Page 110

4|

OO111 : :
1 Q. Were these semi-hetmetic compressors?

2 A. No, not that I can recall.

Q. Were they reciprocal?
4 A. Yes. :
5

us

Q. How many cylinder heads did they have?

a

A. I remember two. On that application with

7 commercial, the stuff that came in were usually two or

8 four. :
9 Q. Did the Frick compressors look different from
10 the York compressors? i. 4

ll A. Yes. Different color, J think, or different

12 configuration, Nobody is the same. |

13. O. What color were the Frick compressors?

14 A. don't know. They go through the same thing,
15 we had black, gray, and reddish-type paint that we
16 painted all compressors. with, so it's hard for mg to

17 give you a color, because, as 1 mentioned before, with

18 that compressor coming down the line, there's no color
19 onit. me

20 Q. But they look different from the York

21 compressors, correct?

22 A. Yes. Yes. i i
23 Q. How did vou distinguish a Frick compressor from
24 a York compressor other than the nameplate?

25 MS. TAFISI: Vague and ambiguous.

i

HUSBIAND, CHARLES 4-18-11 VOL 1 NS. txt

Page 11100112
1 THE WITNESS: Well, same thing with Chevy and

2 Ford, one is a Chevy, one!is a Ford nameplate, By

3 looks, configuration, they look different,
4 Lcan't tell you how.
5 BY MR, BURKE: :
6 Q. Did Frick compressors come in different

7 dimensions than the York compressors?

8 A. All of them did. 7

9  Q. Can you describe the dimensions of the Frick

10 compressors? a
11 A. Here we go again, | :,
12 Well, you know, this high, this wide.
13 You want inches?

'
14 QO. When you do that, that doesn't translate for

15 the record. .
16 A. You could be a foot-and-a:half to two-foot tall

17 with two cylinders, width, maybe the same way stretched
18 out, and some are stretched out more than the others,

19 some are longer, some are fatter,'some are taller.

20 Q. Okay. I’m just trying to get as much detail as

21 possible with your memory. If you can't recall, that's

22 fine, as well. .

23 A. Well, I_ know that they were all different.

24 =. And were your duties the same with regards to

25 your handling of the Frick compressors, did you just
rn

HUSBAND, CHARLES 4-18-11 VOL 1 NS.txt

Page 11200113
1 take them apart? oS :

2 A, Yes, and cleaned. | :

3 Q. And the process was the same, where you'd have
4 itsubmerged ina solvent? it

5 A. Yes, after it was all broke down

6 Q. And how long would it take to break down a

7 Frick compressor? '

8 A. Most of them were 45 minutes to an hour,

9 depending upon the gaskets. If they really got hot and
10 burned out, the gasket gets so hot, they are hard —

11 they are like stone, you know, and you got to chip them
1 ,
12 off. The solvent doesn't really de anything to them,

13 it just takes the dirt off of them, It doesn't even
14 penetrate them, you know, and that's why these ones

15 take longer, because you are there with a chisel. You

16 can't get a chisel, so you get_a wire brush and try to

17 get a groove in it so you can try and pop it off.

18 . How often would the gasket material be baked

19 onte the compressors? ‘ :

20 =A. _ 30 percent, because most of those things were

21 burned out from the heat," ' uw

22 -Q._ So 50 percent of the time that-you were

23 cleaning compressors, the gasket material was baked on?
24 A. Qh, yeah, yeah. Lo

25 Q, Were the appearance of the gaskets on the Frick
1 —

HUSBAND, CHARLES 4-18-11 VOL 1 NS.tat

Page 113oor . 4
] compressors the same ag the appearance of the gaskets
2 on the York compressors? '

3. A. Yeah, you couldn't distinguish name brand for

4 the shape of the heat gaskets, but as far as being

5 different sizes, yes, it's a different machine. Nobody

6 uses the same gaskets for two different manufacturers,
7 Q. Well, earlier you testified that the York
8 compressors were new. 4

9 A. They were new when they were put in service.
16 They were new burned out when we got them.

1 Q. So my question is, were the Frick compressors

12 new or old? Was there any difference between the Frick
13 compressors and the York compkéssors in that regard?
14 A. No,_90 percent of all the‘co inpressors that

15 came in were new at one time, 10 or so percent were

16 already rebuilt and