The following is a portion of a deposition of an insulator who worked throughout New Jersey.
7 SUPERIOR COURT OF NEW JERSEY
8 LAW DIVISION:MIDDLESEX COUNTY
9 DOCKET NO.L-1114-95
10 JOSEPH JACQUEMOT, Individually
11
12 Plaintiff DEPOSITION UNDER
13 ORAL EXAMINATION
14 vs OF
15 JOSEPH JACQUEMOT
16 ANCHOR PACKING CO.; (VOLUME III)
17 AMERICAN HARDWARE, as successor
18 in interest to Elgen Co.;
19 AMERICAN METAL;
20 BABCOCK & WILCOX;
21 BRIDGE SUPPLY COMPANY, a/k/a
22 Raritan Supply;
23 BURNS & ROE ENTERPRISES, INC.;
24 COMBUSTION ENGINEERING, INC.;
25 CSR LTD., as successor to
2: 1 Colonial Sugar Refining;
2 DeLAVAL COMPANY, a successor
3 in interest to Imo Industries;
4 DELTA MAID;
5 DURODYNE CORP.;
6 FOSTER WHEELER CORP.;
7 GAF CORP., in its own name and
8 as a successor in interest to
9 Ruberoid Corp.;
10 GARLOCK INC.;
11 GENERAL ELECTRIC;
12 HEAT EXCHANGER SERVICES, as
13 successor in interest to
14 Condenser Sepcialists;
15 H. H. ROBERTSON CO.;
16 MADSEN & HOWELL, INC.;
17 NOTTE SAFETY APPLICANCE;
18 PORTER HAYDEN COMPANY, in its own
19 name and as a successor in
20 interest to H. W. Porter and
21 Co. and Reid Hayden Co.;
22 PULMOSAN SAFETY EQUIPMENT CO.;
23 RAPID AMERICAN CORP.,
24 individually and as successor
25 to the Celotex Corporation,
3: 1 Philip Carey Corporation,
2 Philip Carey Mfg. Co., Philip
3 Carey Company, Inc., XPRU
4 Corporation, Briggs
5 Manufacturing Company,
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6 237
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8 Panacon Corporation, Smith &
9 Kanzler, Inc. and Quebec
10 Asbestos Corp., Ltd.;
11 RUTLAND FIRE CLAY COMPANY;
12 STANDARD INSULATION CO.;
13 STATE INSULATION CORP.;
14 SUPERIOR WELDING and BOILER
15 COMPANY;
16 W. R. GRACE & COMPANY;
17 YORK INDUSTRIES, INC.;
18 and JOHN DOE and JOHN DOE
19 CORPORATIONS 1-20 (fictitious
20 name representing one or more
21 companies or corporations
22 engaged in the business of
23 manufacturing and/or distributing
24 finished or unfinished asbestos
25 products),
6: 1
2 Defendants
3 ______________________________
4
5 TRANSCRIPT of the deposition of the witness,
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7 called for Oral Examination in the above-captioned
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9 matter, said deposition being taken pursuant to
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11 Superior Court Rules of Practice and Procedure by and
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13 before KERRY ANN CIGAS, a Notary Public and Certified
14
15 Shorthand Reporter of the State of New Jersey, at the
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17 EVERGREEN WOODS PARK ASSOCIATION, 107 Miranda Court,
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19 Lakewood, New Jersey, on Monday, May 1, 1995,
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21 commencing at approximately 10:10 in the forenoon.
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24
25 BRODY & GEISER
7: 1CERTIFIED SHORTHAND REPORTERS
2 77 Hamilton Avenue
3 Fords, New Jersey 08863
4 (908) 738-8555
5 JOB #505013
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9 238
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11 A P P E A R A N C E S:
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13 WYSOKER, GLASSNER & WEINGARTNER, ESQS.
14 BY:ROBERT KRIEGER, ESQ.
15 Attorneys for Plaintiff
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17 ENRIGHT, LENNEY & McGRATH, ESQS.
18 BY:VINCENT D. ENRIGHT, ESQ.
19 Attorneys for Defendant State Insulation
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21 McGIVNEY & REYNOLDS, ESQS.
22 BY:BRENDA C. MOSES, ESQ.
23 Attorneys for Defendant Durodyne
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25 WATERS, McPHERSON & McNEILL, ESQS.
10: 1 BY:JOHN OSHAUGHNESSY, ESQ.
2 Attorneys for Defendant Garlock
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4 CARTON, WITT, ARVANITIS & BARISCILLO, ESQ.
5 BY:DAVID LEAHY, ESQ.
6 Attorneys for Defendant Flintkote
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8 BORRUS, GOLDIN & FOLEY, ESQS.
9 BY:APHRODITE C. KOSCELANSKY, ESQ.
10 Attorneys for Defendant Burns & Roe
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12 EVANS, OSBORNE, KREIZMAN & BONNEY, ESQS.
13 BY:MARIE H. ACCARDI, ESQ.
14 Attorneys for Defendant Rutland Fire Clay
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16 LAW OFFICES OF R. PATRICK WHITE
17 BY:ANN M. McHALE, ESQ.
18 Attorneys for Defendant Woolsulate
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20 DANAHER, TEDFORD, LAGNESE & NEAL, ESQS.
21 BY:MARISSA BANEZ, ESQ.
22 Attorneys for Defendant Pittsburgh Corning
23 and U. S. Mineral
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25 TUCKER, BIEGEL & GOLDSTEIN, ESQS.
11: 1 BY:PERRY GANDELMAN, ESQ.
2 Attorneys for Defendant Owens-Corning
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4 GOLDEN, ROTHSCHILD, SPAGNOLA & DiFAZIO, P.C.
5 BY:RICHARD BOYLAN, ESQ.
6 Attorneys for Defendant CSR Limited
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12 239
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14 A P P E A R A N C E S:(Contd.)
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16 DELANY & OBRIEN, ESQS.
17 BY:PATRICK C. REEDER, ESQ.
18 Attorneys for Defendant Notte Safety Appliance
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20 NOWELL & AMOROSO, ESQS.
21 BY:JOEL R. CLARK, ESQ.
22 Attorneys for Defendant Madsen & Howell, I-R, E&B
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24 RUBIN, BAUM, LEVIN, CONSTANT & FRIEDMAN, ESQS.
25 BY:MATTHEW E. PRZYWOZNY, ESQ.
14: 1 Attorneys for Defendant Rapid American
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3 BENJAMIN S. BUCCA, JR., ESQ.
4 BY:DIANE PINCUS, ESQ.
5 Attorneys for Defendant Imo Industries
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7 TOMPKINS, McGUIRE, WACHENFELD, ESQS.
8 BY:PAUL RYAN, ESQ.
9 Attorneys for Defendant General Electric
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11 COLEMAN & DEMBER, ESQS.
12 BY:JOHN DEMBER, ESQ.
13 Attorneys for Defendant Rock Wool Manufacturing
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15 HOAGLAND, LONGO, MORAN, DUNST & DOUKAS, ESQS.
16 BY:HANY S. BROLLESY, ESQ.
17 Attorneys for Defendant Superior Boilers
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19 PICILLO & CARUSO, ESQS.
20 BY:DENNIS MANESIS, ESQ.
21 Attorneys for Defendants, Dana, A. P. Green,
22 Flexitallic, Armstrong, GAF, Certainteed, National
23 Gypsum, Quigley, Turner & Newall, Union Carbide, U. S.
24 Gypsum, Sherwin Williams
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15: 1 MAURO, SAVO, CAMERINO & GRANT, ESQS.
2 BY:ALAN B. GRANT, ESQ.
3 Attorneys for Defendant Porter Hayden
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5 YOUNGBLOOD, CORCORAN, ALELI, LAFFERTY & STACKHOUSE,
6 ESQS.
7 BY:THOMAS M. OLEARY, ESQ.
8 Attorneys for Defendant J. H. Robertson
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17 A P P E A R A N C E S:(Contd.)
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19 RONCA, McDONALD & HANLEY, ESQ.
20 BY:JOHN RONCA, JR., ESQ.
21 Attorneys for Defendants York Industries and Standard
22 Insulation
23
24 ALSO PRESENT:
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18: 1 Joseph Jacquemot, Jr.
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4 I N D E X
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6 WITNESS NAME PAGE NO.
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8 JOSEPH JACQUEMOT (Volume III)
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10 Direct by Mr. Boylan 241
11 Cross by Mr. OShaughnessy 343
12 Cross by Ms. Koscelansky 347
13Cross by Mr. Gandelman 349
14 Cross by Ms. Banez 366
15 Cross by Mr. Grant 374
16 Cross by Mr. Przywozny 382
17 Recross by Mr. Gandelman 383
18 Recross by Mr. OShaughnessy 387
19 Cross by Ms. McHale 389
20 Cross by Mr. Ryan 390
21 Cross by Mr. OLeary 393
22 Cross by Mr. Enright 393
23 Recross by Mr. Gandelman 395
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18 241
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20 J O S E P H J A C Q U E M O T,
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22 644 Denise Court, Lakewood, New Jersey,
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24 called as a witness, having been first
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22: 1 duly sworn according to law, testifies as
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3 follows:
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5 DIRECT EXAMINATION BY MR. BOYLAN:
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7 Q Mr. Jacquemot –
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9 A Yes.
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11 Q — my name is Rich Boylan.Were here on
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13 the return date on the continuation date of your
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15 deposition.Weve been going through this for some
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17 time now and hopefully well move along as quickly as
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19 possibly.I know you are not feeling well.
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21 You are still under oath and if you have
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23 any questions, please stop.Dont answer the question.
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25 Ask your attorney and well work out whatever your
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2 problems are.Okay?
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4 A Okay.
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6 Q When we left off last time — first of
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8 all, are you on any medication today?
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10 A Yes.
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12 Q What are you taking, do you know?
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14 A Percocet right now.Pain pill.
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16 Q Does Percocet, do you know, have any
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19 JACQUEMOT – Direct
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21 242
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23 affect your memory or anything?
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25 A I — I — not 100 percent sure.Certain times
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2 it does and I was on another medication which was
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6 Q Okay.
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8 A But –
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10 Q All you are taking today is Percocet?
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12 A Yes.I — pardon me.I am taking other pills,
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14 but theyre not pain pills, for something else.
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16 Q Weve gone through that in the past, your
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18 medical history?
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20 A Yeah.
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22 Q If at any point you need a break, just
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24 stop me and let me know.Okay?
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27: 1 A Okay.
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3 Q When we left off, we were talking about
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5 your work at powerhouses specifically for JCP&L.We
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7 talked about your JCP&L in Forked River and Holland
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9 Township.Did you also work for JCP&L in Lakewood?
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11 A No.
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13 MR. OSHAUGHNESSY:Counsel, just based on
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15 your initial questioning, Id just like to ask
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17 the witness a couple questions if you dont
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19 mind, concerning the medication.
20 MR. BOYLAN:You can ask him all the
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22 JACQUEMOT – Direct
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30: 1 questions you want.
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3 MR. OSHAUGHNESSY:I think its important
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5 at this point.
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7 Mr. Jacquemot, do you feel any different
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9 than you did the last time you were here when we
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11 were asking you questions in terms of ability to
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13 recall and so on?Do you feel any different?
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15 THE WITNESS:Im a lot weaker.I just
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17 was in the hospital for another five days and
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19 Im a lot weaker and I — like I said, I started
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21 on this one medicine and really was doing me in
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23 a little bit.
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25 MR. OSHAUGHNESSY:All right.
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2 THE WITNESS:So Im trying to use this
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4 Percocet which is a little better but, you know.
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6 MR. OSHAUGHNESSY:So if at any time you
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8 feel that you need to either take a break or to
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12 Will you let us know that?
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14 THE WITNESS:Yes.
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16 MR. OSHAUGHNESSY:I appreciate it.
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18 Thank you.
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20 BY MR. BOYLAN:
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22 Q You dont recall working at JCP&L in
23 Lakewood; is that correct?
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25 JACQUEMOT – Direct
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4 A No, I dont recall.
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6 Q Do you recall working for — working at
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8 JCP&L in Morristown?
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10 A I dont recall.
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12 Q Do you ever recall working at the
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14 Johns-Manville plant in Manville, New Jersey?
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16 A Yes.
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18 Q Do you recall who you worked there for?
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20 A Keasbey.
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22 Q How about a time frame?Do you recall
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24 when you worked there?First of all, let me ask, was
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3 A Well, I was there for about three weeks.
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5 Q Do you recall the decade at all?
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7 A Probably in mid 60s.
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9 Q Can you be any more specific?Do you know
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11 the year?
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13 A No, I dont remember.I can remember the job
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15 because it run right along the road there.It was a
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17 steam line, thats all I remember.
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19 Q Was this indoor work or outdoor work?
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21 A Outdoor.
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23 Q Was this steam line located under ground
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25 or above ground?
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3 JACQUEMOT – Direct
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5 245
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7 Q What was that line made out of?Was that
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9 a metal pipe, the steam line?
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11 A Yeah.
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13 Q What was your job with respect to that
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15 specific job?
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17 A Putting insulation on it.Insulate it.
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19 Q How many men were working there for
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21 Keasbey with you?
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23 A I had a helper, one person.
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25 Q Do you recall — do you believe you were
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4 job?
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6 AYes.
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8 Q What products were those?
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10 A Kaylo.
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12 Q What form did Kaylo come in?
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14 A Pipe covering form.Its three-foot sections,
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16 split in half, round.
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18 Q So is this the same Kaylo product you
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22 A Yes.
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24 Q — when you referred to Kaylo pipe
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3 A Right.
4 Q Did you use or were you exposed to any
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6 JACQUEMOT – Direct
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8 246
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10 other asbestos-containing products on that job, if you
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12 recall?
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14 A Some cement.Ruberoid.
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16 Q Did you personally handle the Ruberoid
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20 A Yes.
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22 Q What did you do with it?
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24 A Trowled it on the fittings.
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3 covering?
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5 A Yes.
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7 Q What did you do with it?
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9 A We wired — wired it on the pipe.
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11 Q Did you work with any other products
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13 besides those two we just mentioned at this job?
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15 A Thats basically it, that I can remember.
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17 Q Aside from that one period for three weeks
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19 in the mid 1960s, were you ever back at Johns-Manville?
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21 A I think I was, but I cant be sure.
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23 Q Did you ever work inside any of the
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2 A Not that I recall.
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4 Q Did you ever work at a company called
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6 Johnson & Johnson in New Brunswick?
7 A Yes.
