Mesothelioma Deposition

Unfortunately, asbestos exposure does not stop when a family member leaves the workplace. Many construction workers through no fault of their own unwittingly expose family members to asbestos when they bring the asbestos home on their clothing. Unfortunately, asbestos has no onion properties. You cannot taste asbestos, smell asbestos and most of the time you do not even know that it is in your environment. The asbestos that is capable of killing his invisible to the naked eye. Construction workers such as boilermakers, carpenters, sheet metal workers, laborers, pipefitters etc. were constantly exposed to asbestos throughout their working career. Unfortunately both the workers and some family members have innocently been contaminated and developed cancer. The following is a deposition given by the father of a young woman who develop mesothelioma. She never worked with asbestos at her home did not contain any asbestos except for the asbestos brought home on her fathers clothing and other family members.

1
1 SUPERIOR COURT OF NEW JERSEY
2 LAW DIVISION - MIDDLESEX COUNTY
3 DOCKET NO. MID-L-4527-09
4 KAREN SAVARESE and STANLEY
5 SAVARESE, VIDEOTAPE
DEPOSITION UNDER
6 Plaintiffs, ORAL EXAMINATION
OF
7 v. EDWARD SKRABONJA
8 ABB LUMMUS CREST, INC., et al.,
9 Defendants.
10
11 Computer-aided transcript of the videotape
12 deposition testimony of EDWARD SKRABONJA taken
13 stenographically in the above-entitled matter
14 before EDWIN SILVER, Certified Court Reporter and
15 Notary Public of the State of New Jersey, at the
16 offices of Cohen, Placitella & Roth, P.C., Two
17 Commerce Square, 2001 Market Street, Suite 2900,
18 Philadelphia, PA 19103, on Tuesday, December 1,
19 2009, commencing at 10:10 a.m.
20
21 BRODY DEPOSITION SERVICES, INC.
22 Certified Court Reporters and Videographers
23 7 Elm Street
24 Westfield, New Jersey 07090
25 (908) 789-2000

2
1 A P P E A R A N C E S:
2
3
4 COHEN, PLACITELLA & ROTH, P.C.
5 BY: CHRISTOPHER M. PLACITELLA, ESQ.
6 127 Maple Avenue
7 Red Bank, NJ 07701
8 Attorneys for the Plaintiffs
9
10
11 CARUSO, POPE, EDELL & PICINI, PC
12 BY: WOLODYMYR P. TYSHCHENKO, ESQ. and
13 MARCIA DePOLO, ESQ.
14 60 Route 46 East
15 Fairfield, NJ 07004
16 Attorneys for Defendants, JCP&L and Notte
17
18
19 GARRITY, GRAHAM, MURPHY, GAROFALO & FLINN
20 BY: MICHAEL P. McGRATH, ESQ.
21 One Lackawanna Plaza
22 Montclair, NJ 07042
23 Attorneys for Defendants, United Conveyor Corp. and
24 State Insulation Corp.
25

3
1 A P P E A R A N C E S (CONTINUED):
2
3
4 MARKS, ONEILL, OBRIEN & COURTNEY, PC
5 BY: DENNIS C. SCHMIEDER, ESQ.
6 6981 North Park Drive
7 Pennsauken, NJ 08109
8 Attorneys for Defendant, Bayonne Plumbing Supply
9
10
11 SPEZIALI, GREENWALD & HAWKINS, PC
12 BY: MICHAEL P. QUINN, ESQ.
13 1081 Winslow Road
14 Williamstown, NJ 08094
15 Attorneys for Defendants, General Electric and
16 Foster Wheeler
17
18
19 CONNELL FOLEY, LLP
20 BY: MEGAN M. ROBERTS, ESQ.
21 85 Livingston Avenue
22 Roseland, NJ 07068
23 Attorneys for Defendant, Superior Welding Supply
24
25

4
1 A P P E A R A N C E S (CONTINUED):
2
3
4 HOAGLAND, LONGO, MORAN, DUNST & DOUKAS, LLP
5 BY: KRISTY KULINA LYONS, ESQ.
6 40 Paterson Street
7 New Brunswick, NJ 08903
8 Attorneys for Defendants, W.W. Grainger and
9 Goulds Pumps
10
11
12 MORGAN, LEWIS & BOCKIUS, LLP
13 BY: CHRISTOPHER IANNICELLI, ESQ.
14 502 Carnegie Center
15 Princeton, NJ 08540
16 Attorneys for Defendant, Yarway Corporation
17
18
19 MONTGOMERY, CHAPIN & FETTEN, PC
20 BY: CHARONE S. FRANKEL, ESQ.
21 745 Route 202/206, Suite 101
22 Bridgewater, NJ 08807
23 Attorneys for Defendant, J.H. France Refractories
24
25

5
1 A P P E A R A N C E S (CONTINUED):
2
3
4 SEGAL, McCAMBRIDGE, SINGER & MAHONEY, ESQS.
5 BY: THOMAS F. COLEMAN, ESQ.
6 United Plaza
7 30 South 17th Street, Suite 1700
8 Philadelphia, PA 19103
9 Attorneys for Defendant, Garlock
10
11
12 OTOOLE, FERNANDEZ, WEINER & VAN LIEU, LLC
13 BY: ARTHUR LASH, ESQ.
14 60 Pompton Avenue
15 Verona, NJ 07044
16 Attorneys For Defendant, Clark Reliance Corp.
17
18
19 HOLLSTEIN, KEATING, CATTELL, JOHNSON &
20 GOLDSTEIN, PC
21 BY: NANCY D. GREEN, ESQ.
22 Willow Ridge Executive Park
23 750 Route 73 South, Suite 301
24 Marlton, NJ 08053
25 Attorneys for Defendant, Chicago Bridge & Iron

6
1 A P P E A R A N C E S (CONTINUED):
2
3
4 McELROY, DEUTSCH, MULVANEY & CARPENTER, LLP
5 BY: CHAD D. MOUNTAIN, ESQ.
6 1617 JFK Boulevard, Suite 1500
7 Philadelphia, PA 19103
8 and
9 McELROY, DEUTSCH, MULVANEY & CARPENTER, LLP
10 BY: JOSEPH P. LaSALA, ESQ.
11 1300 Mount Kemble Avenue
12 Morristown, NJ 07962
13 Attorneys for Defendants, Rockwell and Exxon
14
15
16 MAGEE & MAGEE, LLP
17 BY: GRANVILLE M. MAGEE, ESQ.
18 1937 Route 35 (At Allaire Road)
19 Wall Township, NJ 07719
20 Attorneys for Defendant, Alltite Gasket Co.
21
22
23
24
25

7
1 A P P E A R A N C E S (CONTINUED):
2
3
4 REILLY, JANICZEK & McDEVITT, PC
5 BY: BRANDY L. HARRIS, ESQ.
6 Kevon Office Center
7 2500 McClellan Boulevard, Suite 240
8 Merchantville, NJ 08109
9 Attorneys for Defendant, Cleaver-Brooks, Inc.
10
11
12 PORZIO, BROMBERG & NEWMAN, PC
13 BY: THOMAS J. COFFEY, ESQ.
14 100 Southgate Parkway
15 Morristown, NJ 07962
16 Attorneys for Defendant, E.I. du Pont de Nemours Co.
17
18
19 MARGOLIS EDELSTEIN, ESQS.
20 BY: JASON T. SCHEETS, ESQ.
21 100 Century Parkway, Suite 200
22 Mount Laurel, NJ 08054
23 Attorneys for Defendants, Industrial Rubber and
24 United Engineers
25

8
1 A P P E A R A N C E S (CONTINUED):
2
3 TIERNEY LAW OFFICES
4 BY: JOHN R. SEREDA, ESQ.
5 1125 Land Title Building
6 100 South Broad Street
7 Philadelphia, PA 19110
8 Attorneys for Defendants, Guyon General Piping and
9 Elizabeth Industrial Supply
10
11
12 MARSHALL, DENNEHEY, WARNER, COLEMAN &
13 GOGGIN
14 BY: NADIRA K. KIRKLAND, ESQ.
15 Woodland Falls Corporate Park
16 200 Lake Drive East, Suite 300
17 Cherry Hill, NJ 08002
18 Attorneys for Defendant, D.B. Riley, Inc.
19
20
21 GOLDFEIN & JOSEPH, PC
22 BY: MADHURIKA JEREMIAH, ESQ.
23 1880 JFK Boulevard, 20th Floor
24 Philadelphia, PA 19103
25 Attorneys for Defendant, ACL

9
1 A P P E A R A N C E S (CONTINUED):
2
3 GIBBONS, PC
4 BY: ALAN R. GRIES, ESQ.
5 1700 Two Logan Square
6 18th and Arch Streets
7 Philadelphia, PA 19103
8 Attorneys for Defendant, Honeywell International, Inc.
9
10
11 ECKERT, SEAMANS, CHERIN & MELLOTT, LLC
12 BY: ELIZABETH A. WEILL, ESQ.
13 Two Liberty Place
14 50 South 16th Street, 22nd Floor
15 Philadelphia, PA 19102
16 Attorneys for Defendant, CBS
17
18
19 KENT & McBRIDE, PC
20 BY: KEVIN E. HOFFMAN, ESQ.
21 Woodbridge Towers
22 555 Route 1 South, Fourth Floor
23 Iselin, NJ 08830
24 Attorneys for Defendant, Alfa Laval
25

10
1 A P P E A R A N C E S (CONTINUED):
2
3 HOFHEIMER, GARTLIR & GROSS, LLP
4 BY: GARY N. SMITH, ESQ.
5 530 Fifth Avenue
6 New York, NY 10036
7 Attorneys for Defendant, Rapid American Corp.
8
9 McGIVNEY & KLUGER, PC
10 BY: DAVID V. BOGDAN, ESQ.
11 Two Penn Center
12 15th Street & JFK Boulevard, Suite 518
13 Philadelphia, PA 19102
14 Attorneys for Defendants, Nutley Heating & Cooling
15 Supply Co., Inc.; Hayes Pump, Inc.; Guardian
16 Protech; and Central Boiler Repair Co. Inc.
17
18 KELLEY, JASONS, McGOWAN, SPINELLI & HANNA, LLP
19 BY: ROBERT W. ROWAN, ESQ.
20 Two Liberty Place
21 50 South 16th Street, Suite 1900
22 Philadelphia, PA 19102
23 Attorneys for Defendant, Trane U.S.
24
25

11
1 A P P E A R A N C E S (CONTINUED):
2
3 WEBER, GALLAGHER, SIMPSON, STAPLETON, FIRES
4 & NEWBY, LLP
5 BY: SYREETA PEAKE, ESQ.
6 2000 Market Street, Suite 1300
7 Philadelphia, PA 19103
8 Attorneys for Defendant, Durabla
9
10
11 SWARTZ CAMPBELL, LLC
12 BY: DAMIAN S. JACKSON, ESQ.
13 115 North Jackson Street
14 Media, PA 19063
15 Attorneys for Defendant, Crane Co.
16
17
18 DELANY & OBRIEN, ESQS.
19 BY: ANISHA S. ABRAHAM, ESQ.
20 The Bourse
21 111 South Independence Mall East
22 Suite 1002
23 Philadelphia, PA 19106
24 Attorneys for Defendant, O.K. Electric
25

12
1 A P P E A R A N C E S (CONTINUED):
2
3
4 HARRIS BEACH, PLLC
5 BY: WILLIAM T. MIEDEL, ESQ.
6 100 Wall Street, 23rd Floor
7 New York, NY 10005
8 Attorneys for Defendant, Kentile Floors, Inc.
9
10
11 Also present:
12 Gerard Genna, Videographer
13
14
15
16
17
18
19
20
21
22
23
24
25

13
1 I N D E X
2 WITNESS PAGE
3 EDWARD SKRABONJA
4 Examination by Mr. Placitella 16
5 Examination by Mr. Lash 57
6 Examination by Mr. Quinn 58
7 Examination by Mr. Scheets 95
8 Examination by Mr. LaSala 113
9 Examination by Mr. McGrath 120
10 Examination by Mr. Jackson 124
11 Examination by Ms. Harris 125
12 Examination by Ms. Lyons 127
13 Examination by Ms. Kirkland 129
14 Examination by Mr. Gries 139
15 Examination by Mr. Coffey 141
16 Examination by Ms. Weill 154
17 Examination by Mr. Coleman 157
18 Examination by Ms. Frankel 184
19 Further examination by Mr. Placitella 191
20 Further examination by Mr. Quinn 196
21 Further examination by Ms. Kirkland 198
22 Further examination by Mr. Coleman 201
23
24
25

14
1 EXHIBITS
2 NUMBER DESCRIPTION IDENT.
3 P-1 Deposition of Edward 19
4 Skrabonja taken on 12/29/98
5 P-2 Sketch of a Foster Wheeler boiler 23
6 at the PSE&G Hudson Generating
7 Station
8 D-1 International Brotherhood of 86
9 Boilermakers, Iron Ship Builders,
10 Blacksmiths, Forgers and Helpers
11 publication dated April 1969
12
13
14 REQUEST FOR PRODUCTION BY MR. PLACITELLA:
15 PAGE LINE
16 86 24
17
18
19
20
21
22
23
24
25

15
1 THE VIDEOGRAPHER: Todays deposition
2 will be video recorded. We are now on the
3 video record in the matter of Karen Savarese
4 versus ABB Lummus Crest, Inc. Todays date
5 is December 1st, 2009. Time is
6 approximately 10:10 a.m.
7 This is Docket No. MID-L-4527-09.
8 This is the video-recorded deposition of
9 Edward Skrabonji--
10 MR. PLACITELLA: Skrabonja.
11 THE VIDEOGRAPHER: --Skrabonja--
12 MR. SKRABONJA: Its good enough.
13 THE VIDEOGRAPHER: --taken at Cohen,
14 Placitella & Roth in Philadelphia,
15 Pennsylvania. Gerard Genna is the camera
16 operator.
17 MR. PLACITELLA: Hes Italian, and he
18 cant figure it out.
19 THE VIDEOGRAPHER: The court reporter
20 is Ed Silver, from Brody Deposition
21 Services.
22 All appearances will be noted in the
23 transcript.
24 Please administer the oath.
25 THE WITNESS: Are we done?

16
1 E D W A R D S K R A B O N J A, duly sworn,
2 testifies as follows:
3 EXAMINATION
4 BY MR. PLACITELLA:
5 Q Good morning, Mr. Skrabonja.
6 How are you?
7 A Fine.
8 Q You know my name is Chris
9 Placitella.
10 You met me yesterday for the first
11 time?
12 A Yes.
13 Q Okay. And you sat yesterday with me
14 for a while and talked to me about the work that
15 you did as a boilermaker in years past. Correct?
16 A Yes.
17 Q You currently live in Bellmawr, New
18 Jersey?
19 A Yes.
20 Q And you were born in what year? Do
21 you remember?
22 How old are you now?
23 A Twenty--22.
24 Q You were born in 22?
25 A No. December 19, 1922.

17
1 Q Okay. So that makes you 88?
2 A Thats--no. It makes me--what the
3 hell am I doing here? Ill be 87 the 19th of this
4 month.
5 Q Okay. And whats--how far did you go
6 in school?
7 A Eighth grade.
8 Q And after you left eighth grade, did
9 you go to trade school?
10 A Yes.
11 Q For what?
12 A For instruction, welding.
13 Q And are you married?
14 A Yes.
15 Q And who are you married to?
16 A Some girl.
17 Q Is--is your wifes name Margaret?
18 A Margaret.
19 Q Okay. And do you have kids?
20 A Yes. I have two.
21 Q What are their names?
22 A Edward and Karen.
23 Q Do you have any grandchildren?
24 A Five.
25 Q Five. Okay.

18
1 And did you have occasion--did you
2 serve in the armed services?
3 A Yes, I did.
4 Q And what did you do?
5 A I was with the Seabees, construction
6 outfit.
7 Q And what branch?
8 A Navy.
9 Q The Navy. All right.
10 A Its a Navy branch.
11 Q Now, do you--did you at some point in
12 time have your own asbestos lawsuit?
13 A Yes.
14 Q All right. And what--what injury
15 were you claiming in that lawsuit? Do you
16 remember? What did you have? What do you have?
17 A I had a little asbestos
18 around--around the edges--
19 Q Okay.
20 A --of my lungs.
21 Q All right. And did you give a
22 deposition in that case?
23 A Yes, I did.
24 Q All right. Im going to show you
25 whats been marked--

19
1 MR. PLACITELLA: Did you mark this
2 already?
3 THE REPORTER: No. I didnt get a
4 chance to.
5 MR. PLACITELLA: All right.
6 THE REPORTER: Want me to mark it
7 now?
8 MR. PLACITELLA: Yeah. Just mark
9 it.
10 (Off the record.)
11 (Deposition of Edward Skrabonja taken
12 on 12/29/98 received and marked Exhibit P-1
13 for identification.)
14 Q Im going to show you whats been
15 marked P-1 for identification and ask you if this
16 is your deposition transcript.
17 A Thats the start of it. Yes.
18 Q And do you remember giving that
19 deposition back in 1998?
20 A Yes.
21 Q Okay. And when you gave that
22 testimony, did you give it as accurately as
23 possible and as truthful as possible?
24 A Yes, I did.
25 Q How is your memory today compared

20
1 to--
2 A Not too good.
3 Q Okay. Was it better when you--
4 A Better than, yeah, Oh, Christ!
5 Q All right.
6 A Youre talking about years.
7 Q Okay. During the course of the
8 deposition, if theres things you cant recall, I
9 may refer back to the transcript, if thats okay.
10 A Good.
11 Q All right. You worked as a
12 boilermaker. Correct?
13 A True.
14 Q All right. Did--were you a member of
15 the boilermakers union?
16 A Yes.
17 Q When did you join the boilermakers
18 union?
19 A Forty--48.
20 Q And how long did you remain a
21 boilermaker?
22 A Up until 86.
23 Q And do you believe--did you work out
24 of a particular local?
25 A Local 28.

21
1 Q And where was that housed out of? Do
2 you remember?
3 A Its in--its in Bayonne now.
4 Q During the time that you worked as a
5 boilermaker, do you believe you were exposed to
6 asbestos?
7 A Definitely, yes.
8 Q When you--when you say definitely--
9 A Yes.
10 Q --how do you believe you were exposed
11 to asbestos when you worked as a boilermaker?
12 A Using the gloves and the blankets and
13 all that--
14 Q Okay.
15 A --from welding.
16 Q During the--during the time that you
17 worked as a boilermaker, did your daughter Karen
18 live with you?
19 A Yes.
20 Q During the time you worked as a
21 boilermaker, did you wear your work clothes home
22 from the job?
23 A Yes.
24 Q During the time you worked as a
25 boilermaker, did your daughter Karen, was she

22
1 involved in washing your clothing?
2 A Yes, she was, definitely.
3 Q Now, as a boilermaker, I take it you
4 worked on boilers.
5 A Sometimes.
6 Q Okay. And was there one type of
7 facility that you worked at more than other kinds
8 of facilities?
9 A No.
10 Q All right. Did you ever work in
11 powerhouses?
12 A Yes.
13 Q All right. And where were the
14 powerhouses that you worked?
15 A All the way up and down the
16 turnpike. There were seven of them.
17 Q Okay. And do you know who owned
18 those powerhouses?
19 A Well, United--Public Service had
20 everything south.
21 Q Okay. Now, when you worked in the
22 powerhouses, what kind of equipment did you work
23 on?
24 A Tubes, repairs, tearing down the
25 boilers.

23
1 MR. PLACITELLA: Okay. Now, Im
2 going to show you whats been--going to be
3 marked P-2, please.
4 (Sketch of a Foster Wheeler boiler at
5 the PSE&G Hudson Generating Station received
6 and marked Exhibit P-2 for identification.)
7 Q Im going to show you whats been
8 marked P-2 for identification and ask if you can
9 tell me what this is.
10 A This a Foster Wheeler boiler--
11 Q All right.
12 A --complete boiler.
13 Q All right. And is that a diagram of
14 a Foster Wheeler boiler?
15 A Yes, when--yes.
16 Q Is that typical of what boilers
17 looked like in terms of their layout that you
18 worked on over the years?
19 A Yes.
20 Q Whether or not--was the--was there
21 more than one kind of manufacturer of boilers?
22 A No. But they all come out to look
23 like something like this.
24 Q Okay. So even, for instance, you
25 worked on a B & W boiler, it was the same basic

24
1 layout.
2 A The same basics.
3 Q All right.
4 A You had the super heaters and the
5 wall tubes and--
6 Q All right. Now, on the boiler,
7 thats a--that comes from the Hudson Generating
8 Station. Did you work on boilers at the Hudson
9 Generating Station?
10 A Yes.
11 Q All right. Would you be so kind as
12 to, if you wouldnt mind, stand up and show us on
13 the screen where you would have worked on the
14 boilers, what kind of work you did, and how you
15 believe your work brought you into contact with
16 asbestos.
17 MR. QUINN: Chris, I just need to
18 object to the use of this document. Theres
19 been no witness or testimony indicating he
20 ever worked on a Foster Wheeler boiler.
21 Q Mr. Skrabonja, did you ever work on a
22 Foster Wheeler boiler?
23 A Yes, I did.
24 Q How many times?
25 A A couple of times--

25
1 Q Okay.
2 A --back and forth, for repairs.
3 Q Okay. And is this typical of what
4 the Foster Wheeler boiler looked like that you
5 work on?
6 A Yes.
7 Q Can you show us where--by the way,
8 how big would this boiler be in actual--in
9 actuality?
10 A Theyre usually about eight to 10
11 stories high.
12 Q Okay. So its not your typical
13 boiler that you see in a home.
14 A No.
15 Q All right.
16 A When you go down the turnpike, youll
17 see them big boilers. Thats what they look like.
18 Q Okay. When you say big boilers--
19 A Huge, huge.
20 Q Huge. Okay.
21 The--you say theyre eight to 10
22 floors?
23 A Oh, yeah.
24 Q And can you explain--whoops! What
25 did I just do here.

26
1 THE VIDEOGRAPHER: I didnt do it.
2 MR. PLACITELLA: No, thats fine. My
3 fault.
4 A Right there, thats where the boiler
5 used to be. Thats a good--
6 Q Okay. Now, can you explain where you
7 worked on the boilers, what you did, and how you
8 believe you came into contact with asbestos?
9 MR. QUINN: Do you mean all boilers
10 or--
11 MR. PLACITELLA: In general, yes.
12 A VOICE: Objection to form.
13 A This here--
14 THE REPORTER: Whoa. Excuse me.
15 A --down the bottom--
16 THE REPORTER: One second.
17 Who--youve got to speak your name.
18 I have no idea who you are.
19 A VOICE: Can you just do objection
20 by one is objection by all?
21 MR. QUINN: Well, lets go off the
22 record a minute.
23 (Off the record.)
24 Q Let me ask you this question, because
25 the lawyers didnt like how I asked you the last

27
1 one.
2 Okay?
3 Did you work on boilers that looked
4 just like this?
5 A Yes.
6 Q All right. Can you show--can--do you
7 believe that you, when you worked on boilers like
8 this, you were exposed to asbestos?
9 A Yes.
10 Q All right. Can you explain, by using
11 this diagram, how you would be exposed to asbestos
12 when working on a boiler that looks like this?
13 A When youre cutting all these tubes
14 out down the bottom, this is a floor, and this is
15 the top tubes, when you go in here, this is all
16 asbestos, you got to--you got to burn them out.
17 When youre burning them out, you get a lot of
18 metal drops down. Or if you go up on top here,
19 youre getting a lot of draft goes up here and
20 blows up.
21 Like I explained to you before, this
22 soot up here, whatever is mixed in with that, its
23 five foot deep. After a few years, you dont
24 realize what--what the dust collects.
25 Q All right. Is there something--did

28
1 you work on something in a boiler known as a
2 tube?
3 A Yeah. These--these here, everything
4 you see here, these little--theyre all tubes.
5 Nothing is going in. Its just blank here.
6 Q Okay. But that--
7 A Thats water wall tubes.
8 Q And what would you do to the--to the
9 tubes?
10 A Well, youd have to--youd have to
11 cut them in a--someplace in a section, right about
12 here, get rid of these bottom, the floor tubes,
13 and then bring in--cut them, get new ones, and
14 youd have to weld them right up in here--
15 Q And did you--
16 A --or if it was the roof tubes, it
17 would be the same thing.
18 Q And when you did that, did you come
19 into contact with asbestos-containing products?
20 A Oh, yeah.
21 Q How?
22 A Well, this is all being burned out.
23 You have to cover up with asbestos blanket,
24 gloves, anything you can wear.
25 Q Was there a casing?

29
1 A Yes, a casing. This is all--this
2 here is all casing, right here.
3 Q And was there insulation on the
4 casing?
5 A It was on the inside of the casing.
6 Q All right.
7 A Youd have to--youd have to cut the
8 casing out, and the--the insulation would come up.
9 Q And then youd have to remove the
10 insulation?
11 A Right.
12 Q All right. And what did the
13 insulation look like?
14 A Blocks.
15 Q What color? Do you remember?
16 A I think it was like a--like a brown,
17 tan, or something.
18 Q Okay.
19 A It was dark.
20 Q And when you--when you took the
21 insulation off, did that create any dust?
22 A Definitely, because you have nothing
23 but draft blowing up. When you worked up there,
24 you have to get out of there, because the draft
25 comes up so bad.

30
1 Q Now, were there--were there floors
2 that separated the sections of the boiler?
3 In other words, you said it was
4 10--it was eight to 10 stories high.
5 A Yeah, thats how high it was. But
6 you had--you had grating so high, so you could
7 work anyplace on the boiler you wanted to.
8 Q All right. So the floors were
9 actually gratings?
10 A Gratings, all the way around.
11 Q So if you were on, say, the ninth
12 floor, could you see down to the bottom?
13 A Yes.
14 Q All right. So if dust was generated
15 on the top, could it fall down to the bottom, or
16 if it was blowing up, blow up through it?
17 MR. QUINN: Objection to form.
18 A Thats where it winds up--
19 Q Okay.
20 A --down the bottom.
21 Q All right. Now, is there something
22 on a boiler known as a firebox?
23 A Firebox--firebox should be
24 right--well, this--this isnt--you cant see too
25 much here. The firebox would be right in this

31
1 area here. All this is firebox.
2 Q All right. And what is a firebox?
3 What was that?
4 Did you work on that?
5 A Yeah. Thats the floor.
6 Q Okay. And do you believe when you
7 were working on the fireboxes, you were exposed to
8 asbestos?
9 A Oh, yeah. Thats where it all comes
10 from. Youve got to burn them blocks out.
11 Theres so much dirt stuff in there, you have to
12 lance, what they call lance out.
13 Q Okay. Now, is there something on a
14 boiler known as a drum?
15 A This is the drum.
16 Q All right. And was there insulation
17 on the drum?
18 A Yes.
19 Q All right. Were you exposed to the
20 insulation on the drum?
21 A Cutting it out, yeah.
22 Q Okay.
23 MR. QUINN: Objection to form.
24 MR. PLACITELLA: Whats wrong with
25 the form?

32
1 MR. QUINN: Leading.
2 MR. PLACITELLA: Leading is, Were you
3 exposed to insulation on the drum? Thats
4 leading?
5 Ill stick with the question.
6 MR. QUINN: Okay.
7 Q Were you exposed to insulation on the
8 drum?
9 A Yes, cutting--cutting--cutting it
10 out, cutting everything out, clean it all up in
11 there.
12 Q What did you cut out on the drum?
13 A Nothing on the drum. You had to take
14 the casing off to get to the drum.
15 Q Okay. And underneath the casing was
16 what?
17 A Underneath the casing was asbestos--
18 Q Okay. Now--
19 A --or insulation, whatever you want to
20 call it.
21 Q Okay. Was there something known as a
22 roof tube?
23 A Roof tube is right here.
24 Q All right.
25 A These are all roof tubes.

33
1 Q Did you work on roof tubes?
2 A Oh, yeah.
3 Q What would you do for roof tubes?
4 A Well, you cut them out, too.
5 They--the boiler gets so hot, they melt and they
6 just hang.
7 Q All right.
8 A And once they hang, youre losing all
9 your water, all your steam, you go in there. Then
10 you have another one here. These are super heated
11 tubes, so hot. Thats what turns the generators.
12 Q Okay. And were the super heated
13 tubes insulated?
14 A No, because theyre all on the inside
15 of the boiler.
16 Q All right. When you had to work on
17 the super heated tubes, did you have to remove
18 insulation to get to them?
19 A No.
20 Q Okay. The--when you worked on the
21 roof tubes, when you did that work, did that
22 expose you to asbestos?
23 A Oh, yeah. Well, to clean it all
24 out. Once its cleaned out, youre okay.
25 Q Okay.

34
1 A Like I say, youve got about six foot
2 of soot up there. If you know what six foot of
3 soot looks like, it takes about a week to clean
4 it.
5 Q Okay. Now, did--you said that you
6 used asbestos blankets.
7 A Right.
8 Q What would you use those for?
9 A Well, when you blow something, youre
10 burning out, you get hot metal drops. So if
11 youre--if youre sitting down or youre welding,
12 youve got to put it on your on--your knees,
13 someplace where--where it drops, you wouldnt get
14 burnt.
15 Q Okay. And would the--would the hot
16 metal actually hit the asbestos blankets?
17 A Oh, yes.
18 Q Okay. And what would happen when
19 that happened?
20 A Well, after a while it would start
21 fraying, burning up.
22 Q All right.
23 A It doesnt catch fire, but it--it
24 melts--
25 Q Okay.

35
1 A --it burns it up.
2 Q And when it--after you used it for a
3 while, would the blankets create dust?
4 A Definitely.
5 Q Would you get that on your clothing?
6 A Yeah. Thats whats--whats on you.
7 Youre wearing it all day long.
8 Q Okay. And you also mentioned
9 asbestos gloves.
10 What will you use those for?
11 A Same thing, burning, burning the
12 floor tubes out when youre lancing.
13 Q Okay. Did you work with a product
14 known as refractory?
15 A Yes.
16 Q Whats refractory?
17 A Well, its when you put the asbestos
18 in down in these corners here, you had a--you had
19 a packet--
20 Q All right.
21 A --with a--with a refractory.
22 Q All right.
23 A Its like a--its like a mud.
24 Q Okay. And how--do you remember where
25 you got that from or how it came packaged, or

36
1 anything like that?
2 A Yeah. It come in drums, 200-pound
3 drums--
4 Q Okay.
5 A --little barrels.
6 Q And is there something known as a
7 fire brick?
8 A Yeah.
9 Q Where was--did you use that in
10 conjunction with a boiler?
11 A Yeah. The fire brick is all down
12 here on the floor, right in around here.
13 Q All right. And how would you--did
14 you remove fire brick?
15 A Everything goes.
16 Q Would you have to reinstall the fire
17 brick?
18 A No. That was another fire brick
19 people.
20 Q All right. That wasnt you. You
21 were the welder.
22 A It was like a--like a bricklayer
23 deal.
24 Q Okay. All right. You can--you can
25 have a--you can sit back down. Thank you for

37
1 teaching us.
2 (Off the record.)
3 Q When you worked for Public Service,
4 do you recall any of the companies that you
5 actually worked for, the names of the companies?
6 A B & W, Babcocks & Wilcox, United.
7 Thats mostly--thats mostly all of them for these
8 boilers in Jersey.
9 Q All right. When you say United, you
10 mean United Engineers?
11 A United Engineers.
12 Q All right. And when you worked for
13 B & W or United Engineers, who supplied the
14 blankets and the gloves that you used?
15 MR. SCHEETS: Objection.
16 MR. PLACITELLA: Basis?
17 MR. SCHEETS: Well, you have both of
18 them together. So Im objecting to your use
19 of the question.
20 Q Who supplied the blankets that you
21 used when you worked for United Engineers?
22 A Well, the company buys them from an
23 outside company that sells welding rods, blankets,
24 everything for welding it.
25 Q Okay. And when you say the

38
1 company, you mean United Engineers?
2 A Yeah, they--that would buy it, you
3 know, or--
4 Q And then you would use it?
5 A Then we would use it. Wed go into
6 our tool room.
7 Q All right. The gloves that you used,
8 who--who purchased those gloves?
9 A Same thing.
10 Q United Engineers?
11 A Well, the company would purchase all
12 the stuff, but we would get it into our tool
13 room.
14 Q All right. And did you also at some
15 point in time work for a comp--a company known as
16 Foster Wheeler?
17 A Yes.
18 Q All right. And when you worked for
19 Foster Wheeler, do you believe you were exposed to
20 asbestos?
21 A Yes.
22 Q When you worked for United Engineers,
23 did you believe you were exposed to asbestos?
24 A Yes.
25 Q When you worked for United Engineers,

39
1 did you wear your work clothing home for your
2 family to wash?
3 A Yes.
4 Q When you worked for Foster Wheeler,
5 did you work--bring your work clothing home for
6 your family to wash?
7 A Yes.
8 Q When you worked on the boilers in the
9 Public Service powerhouses, did you work in the
10 vicinity of other trades?
11 A Yes.
12 Q What other trades?
13 A Fitters, insulators, ironworkers.
14 All crafts.
15 Q And what would the insulators be
16 doing?
17 A Well, theyre--theyre around
18 insulating the piping and stuff that runs through
19 these boilers and on the outside.
20 Q All right. And--
21 A Everything is insulated.
22 Q And do you--do you remember what they
23 were insulating with?
24 A Most of it--most of the time then was
25 asbestos--

40
1 Q Okay.
2 A --material.
3 Q All right. And as part of that
4 process, do you know whether dust was created by
5 the insulators?
6 A Yes.
7 Q Would you be exposed to that dust?
8 A Oh, yes. They were sloppy.
9 Q All right. When you worked for
10 Public Service Electric & Gas, was your daughter
11 Karen--
12 MR. PLACITELLA: Mr. LaSala, I saved
13 you a seat right here for your birthday.
14 Wasnt it Friday?
15 MR. LaSALA: Yesterday. Thank you.
16 MR. PLACITELLA: Yesterday. Okay.
17 Q The--when you worked for Public
18 Service Electric & Gas, was Karen living at home
19 with you?
20 A Yes.
21 Q All right. Did you work at the
22 Bergen Generating Station?
23 A Yes.
24 Q And where was that located?
25 A Bergen. Its in--

41
1 Q Okay.
2 A Where is that near?
3 Newark--
4 Q Okay.
5 A --or something up that way somewhere.
6 Q What kind of work did you do at the
7 Bergen Generating Station?
8 A Same thing.
9 Q That you showed up--
10 A Yeah.
11 Q --on the screen?
12 A Cut the tubes, repair all the tubes,
13 burning out casing.
14 Q All right. Do you have a
15 recollection of who you worked for at Bergen?
16 A Most of it up there was United
17 Engineers.
18 Q Okay. Did you work at the--ever work
19 at the Burlington Generating Station?
20 A Uh-huh.
21 Q What kind of work did you do there?
22 A Same thing.
23 Q Did you ever work in a--at a place
24 known as Deepwater?
25 A Sure did.

42
1 Q Where was Deepwater?
2 A In Deepwater.
3 Q Okay. And--
4 A Its down in Salem.
5 Q All right. And what kind of work did
6 you do there?
7 A Same thing, tore out boilers--
8 Q All right.
9 A --repairs.
10 Q All right. So you--and you did the
11 kind of work you showed us up--
12 A Same--
13 Q --on the screen?
14 A Same thing on all of them.
15 Q Okay. Did you--did you work at the
16 Hudson Station for Public Service?
17 A Yes.
18 Q Okay. Did you work at Public Service
19 Electric & Gas in Linden?
20 A Yes.
21 Q All right. And did you work at
22 Public Service Electric & Gas in Sewaren, New
23 Jersey?
24 A Yes.
25 Q Did you work at Public Service

43
1 Electric & Gas in Trenton, New Jersey?
2 A Yes.
3 Q Is that also known as Duck Island?
4 A Duck Island.
5 Q All right. And did you at some time
6 work in the Salem Generating Station?
7 A Yes.
8 Q Okay. Now, did you work at Public
9 Service facilities in the 1950s?
10 A Yes.
11 Q Did you work at Public Service
12 facilities where you were exposed to asbestos in
13 the 1960s.
14 A Yes.
15 Q Did you work at Public Service
16 facilities in the 1970s?
17 A No. I got out in 68.
18 Q 68 or 86?
19 A 86.
20 Q Okay.
21 A I have it backwards.
22 Q Okay. So did you work in the 70s at
23 Public Service facilities?
24 A Yes.
25 Q Im going to ask you if you know the

44
1 names of any of the following people as people
2 who--who may have worked with you at Public
3 Service. Okay.
4 James DePietro?
5 A Yes--
6 Q And what--
7 A --James DePietro.
8 Q And what did you do with him?
9 A Worked alongside of him--
10 Q Okay.
11 A --like a helper--
12 Q Okay.
13 A --working together, you need--you
14 need help.
15 Q All right. Peter Bobinski?
16 A Yes.
17 Q Who is he?
18 A Hes a welder.
19 Q All right. Did he work with you at
20 Public Service?
21 A Yeah.
22 Q All right. Howard McDonald?
23 A Yes.
24 Q Was he also--what--what was his job?
25 A Mechanic.

45
1 Q Okay. Was he a boilermaker?
2 A Yes, he was a boilermaker.
3 Q He worked at Public Service?
4 A Yes.
5 Q All right. John Tomney?
6 A Yes.
7 Q All right.
8 A Boilermaker.
9 Q Okay. James Walsh?
10 A Walsh, yeah, boilermaker.
11 Q Arthur Crosby?
12 A Boilermaker.
13 Q Frank Pero?
14 A Frankie Pero, yes.
15 Q Somebody named Cookie?
16 A Oh, yeah. Big Cookie. Yeah. You
17 got to know him.
18 Q And where did you work with him?
19 A Well, mostly Sewaren, up North
20 Jersey, the powerhouse in North Jersey.
21 Q Okay.
22 A Hed never come down to South Jersey
23 at my end.
24 Q Okay. And did you ever work with a
25 John Schroeder?

46
1 A Yes.
2 Q Okay. And what--what was his job?
3 What was his job title?
4 A Same thing.
5 Q Okay. Did you ever work for a
6 company known as Atlantic City Electric?
7 A Yes.
8 Q And where was that located?
9 A Down at Salem--
10 Q Okay.
11 A --a powerhouse down there.
12 Q Okay. And what did you do for
13 Atlantic City Electric?
14 A Tearing it out, repaired--
15 Q And did--
16 A --floor tubes, all the repairs, tear
17 everything down, rebuild.
18 Q All right. And do you believe you
19 were exposed to asbestos in doing that work?
20 A Yeah. At that place it was dirty.
21 Q Okay. And did you ever work for a
22 company known as Jersey Central Power & Light,
23 JCP&L?
24 A Yeah. But I never worked for them.
25 Q You didnt work--you dont recall

47
1 working for them?
2 A No.
3 Q Okay. Im going to ask you if--did
4 you ever work in the vicinity of an Allis-Chalmers
5 turbine?
6 A Yes--
7 Q Okay.
8 A --just near them, yes, but never
9 worked on it.
10 Q Okay. Did you ever work in the
11 vicinity of a Westinghouse turbine?
12 A Yes.
13 Q But not on it itself. That wasnt
14 your job. Correct?
15 A (Witness shakes head.)
16 Q Okay. Did you ever work--
17 A Millwrights.
18 Q Excuse me?
19 A Thats a millwright job.
20 Q Okay. Did you ever work in the
21 vicinity of a General Electric turbine?
22 A Yes.
23 Q Okay. Does the name Garlock mean
24 anything to you?
25 MR. COLEMAN: Objection.

48
1 A Insulation, yes.
2 Q Okay. What do you associate with the
3 name Garlock?
4 MR. COLEMAN: Objection.
5 A Well, asbestos springs, seals for
6 manway covers and stuff.
7 Q Okay. When you say a seal for a
8 manway cover, what do you mean by that?
9 A Well, to get into any of these
10 things, you have a--you have a little opening.
11 Q Okay.
12 A Everything is sealed, but you have
13 places where you could take them out and go in--
14 Q All right.
15 A --and work on it.
16 Q And then what was the Garlock used
17 for?
18 MR. COLEMAN: Objection. Leading.
19 A It was a ring around the--
20 MR. PLACITELLA: Excuse me.
21 What was the Garlock used for is
22 leading?
23 MR. COLEMAN: Yeah. It follows up
24 the other two leading questions regarding if
25 you ever worked around Garlock. Hes never

49
1 mentioned anything--
2 Q Do you remember--do you know the name
3 Garlock?
4 A Oh, yeah.
5 Q Do you associate it with your work?
6 MR. COLEMAN: Objection.
7 A Yes.
8 MR. PLACITELLA: Basis for objection,
9 please.
10 MR. COLEMAN: Same thing, leading.
11 MR. PLACITELLA: Do you associate it
12 with your work is a leading question?
13 Okay.
14 Q Im going to ask you some more.
15 Okay?
16 A Okay.
17 Q What did the Garlock look like?
18 A Garlock is a name.
19 Q Right. When you said its used for
20 sealing, what did you--what did it look like?
21 A Well, have you ever put a little ring
22 around your door to keep the air out?
23 Q Right.
24 A Well, thats what it did. It sealed
25 the air from coming out and going in.

50
1 Q All right. When you--
2 A It closed the boiler off is what it
3 does.
4 Q Okay. Did you ever have occasion to
5 remove that Garlock?
6 A Oh, yeah.
7 Q And how would you remove it?
8 A Well, you peel it off, scrape it off,
9 any way it--after so long that it gets hot, burns
10 up, collapses.
11 Q And how would you--would that create
12 dust?
13 A Yeah.
14 Q Would you get that dust on your
15 clothing?
16 A Oh, yeah, you get dust.
17 Q Does the name J.H. France mean
18 anything to you?
19 A No.
20 Q Do you associate the name J.H. France
21 with bricks or cement?
22 A No. Stuff like that was ordered by
23 the company, and we had nothing to do with names
24 or ordering that stuff.
25 Q Okay.

51
1 A We might have.
2 Q Okay. During the course of your
3 career, did you ever work at any refineries?
4 A Paulsboro.
5 Q Okay. And what did you do--do you
6 believe when you worked at the Paulsboro refinery,
7 you were exposed to asbestos?
8 A Definitely.
9 Q And how were you exposed to asbestos?
10 A Well, you--you do a lot of burning
11 out there on the cigarette towers.
12 Q All right.
13 A You have a bunch of trays in there
14 and they have to come out. You have to take
15 asbestos, something that dont burn so you dont
16 get burned.
17 Q Okay. And how would you be exposed
18 to asbestos when working on the cigarette towers
19 on the trays?
20 A Same thing, carry--carry with the
21 gloves and blanket so you dont burn up. Inside
22 them trays are only about two foot apart you have
23 to go through there and work.
24 Q Okay. And were the trays covered
25 with asbestos?

52
1 A No.
2 Q Did you ever work on something known
3 as a hoodray?
4 A A hoodray?
5 Q Yeah.
6 A Yeah.
7 Q What is that?
8 A Its a big tower--a big
9 manufacture--a plant.
10 Q Okay.
11 A Its a--I dont know what--what youd
12 call it.
13 Q Did you--did you associate that with
14 your work at the Paulsboro refinery?
15 A Yeah. I was the one that put the
16 stack up.
17 Q Okay. And when you did that, were
18 you exposed to asbestos?
19 A Yes.
20 Q And--
21 A That was on the hoodray.
22 Q Okay. And did that asbestos get on
23 your clothing?
24 A Yes.
25 Q All right. And did you wear that

53
1 home?
2 A Yes. Whatever you picked up, you
3 wore home.
4 Q Okay. Did you ever work for a
5 company known as du Pont?
6 A Yes.
7 Q Where?
8 A Gibbstown.
9 Q All right. And do you remember what
10 decade?
11 A It was early. It was 60s, I guess.
12 Q All right. Was Karen living with you
13 at the time?
14 A Yeah.
15 Q All right. When you worked at du
16 Pont in Gibbstown, do you believe you were exposed
17 to asbestos?
18 A Yes.
19 Q How were you exposed?
20 A Gloves, blankets, and whatever you
21 burn out. It was all repairs.
22 Q Were you exposed to asbestos
23 insulation when you worked at du Pont in
24 Gibbstown?
25 A Yes.

54
1 Q All right. Did you get that on your
2 clothing?
3 A Yes.
4 Q Do you remember what kind of
5 equipment you worked on when you worked at
6 Gibbstown?
7 A They were all cracking units, they
8 were all vessels, and so on--
9 Q Okay.
10 A --heaters.
11 Q Did you ever work for a company known
12 as Hercules in Gibbstown?
13 A Yes.
14 Q All right. And who were you working
15 for?
16 A Du Ponts.
17 Q All right. When you were working at
18 Hercules, you were working for du Pont, how did
19 that happen?
20 A That was their maintenance. They had
21 their own maintenance people. You were working
22 for them. You were not working for anybody else.
23 Q All right. And did--do you believe
24 you were exposed to asbestos while you were
25 working at Hercules?

55
1 A Yes.
2 Q All right. And how were you exposed?
3 A Cutting out, rebuilding, tearing out.
4 Q Do you associate the name Riley
5 Stoker with any work that you did at Hercules?
6 A Yes.
7 Q What--what--what--whats--how do
8 you--what is--whats Riley Stoker?
9 A Its a boiler outfit.
10 Q All right. And did you--what did you
11 do--was it a boiler?
12 A Yes.
13 Q All right.
14 A Repair them, tearing them out.
15 Q All right. When you worked on the
16 Riley Stoker boiler, do you believe you were
17 exposed to asbestos?
18 A Yes.
19 Q Did you get that on your clothing?
20 A Yes.
21 Q All right. Did you wear that home?
22 A Yes.
23 Q During your working career for Public
24 Service, were--when you were exposed to asbestos,
25 were you ever told that asbestos was dangerous to

56
1 your health?
2 A No.
3 Q Were you ever told not to wear your
4 clothing home for your family?
5 A No.
6 Q When you worked at the Paulsboro
7 refinery, were you ever warned about the dangers
8 of asbestos?
9 A No.
10 Q When you worked at du Pont, were you
11 ever warned about the dangers of asbestos?
12 A No. It was a big secret.
13 Q Okay. There was a time when you also
14 worked at the New York Shipyard. Right?
15 A Yes.
16 Q Okay. But that was before Karen was
17 born?
18 A 40, 41.
19 Q And when you were there, do you also
20 believe you were exposed to asbestos?
21 A Oh, definitely. Thats where it all
22 started.
23 MR. PLACITELLA: Okay. Now, why
24 dont we take a five-minute break.
25 THE VIDEOGRAPHER: Off the video

57
1 record at 10:50 a.m.
2 (A short recess was taken.)
3 MR. PLACITELLA: Just for the record,
4 I have no more questions at this time. I
5 may have some more later on.
6 THE VIDEOGRAPHER: Were back on the
7 record at 10:58.
8 EXAMINATION
9 BY MR. LASH:
10 Q Okay. Let me tell you good morning
11 again.
12 A Dont go low, because I cant hear
13 that good.
14 Q Okay.
15 A Okay?
16 Q Not a problem.
17 My name is Art Lash, and I just have
18 a few questions for you.
19 Do you recognize the name Clark
20 Reliance?
21 A No.
22 Q Do you recognize the name Jacoby Tar
23 Box?
24 A No.
25 Q So I assume you dont associate any

58
1 exposure to asbestos from products from either of
2 those companies?
3 A No, because I wasnt involved in
4 buying.
5 Q Okay.
6 A I dont know the names of some of
7 this equipment.
8 Q I appreciate your candor. Thank
9 you.
10 A Okay.
11 THE VIDEOGRAPHER: Off the video
12 record at 10:59.
13 (Off the record.)
14 THE VIDEOGRAPHER: Back on the video
15 record at 11 oclock.
16 EXAMINATION
17 BY MR. QUINN:
18 Q Good morning, sir. How are you?
19 A Good.
20 Q My name is Mike Quinn.
21 Are you okay to continue?
22 A Good.
23 Q You dont need a--you dont need
24 another break or anything?
25 A No.

59
1 Q Good.
2 Now, I wanted to talk to you about
3 Foster Wheeler.
4 You testified earlier today that you
5 worked on some of their boilers?
6 A Yeah.
7 Q Where did you work on their boilers?
8 A It was--it was Deepwater.
9 Q Anywhere else?
10 A No. Thats all I can remember--
11 Q Okay.
12 A --that I did.
13 Q And Deepwater is in Salem; is that
14 correct?
15 A Yeah.
16 Q How many times did you work at
17 Deepwater?
18 A Oh, half a dozen, in and out,
19 repairs.
20 Q Do you remember the first time you
21 were at Deepwater?
22 A No.
23 Q Do you remember what decade?
24 A 50s.
25 Q Do you remember the last time you

60
1 were at Deepwater?
2 A No. Its been 15, 20 years ago.
3 Q Maybe--maybe even longer.
4 A Since then, yeah.
5 Q Were you ever at Deepwater in the
6 1960s?
7 A I--I dont remember dates.
8 Q So it could have been the 1950s the
9 last time you were there.
10 A It could have been, yeah.
11 Q Okay. Now, of these six times you
12 were at Deepwater, did you work on the Foster
13 Wheeler boiler each time?
14 A Do what?
15 Q Did you work on a Foster Wheeler
16 boiler each time you were at Deepwater?
17 A Yeah.
18 Q How many boilers were at Deepwater?
19 A I think there was five.
20 Q Do you know if they were all Foster
21 Wheeler boilers, or were there other
22 manufacturers?
23 A I think there was other
24 manufacturers. They have some in a row, and then
25 they have du Pont boilers in there, or they did

61
1 then.
2 Q Is du Pont--
3 A Du Pont supplied--they supplied du
4 Pont with their boiler in the powerhouse.
5 Q When you--when youre saying a du
6 Pont boiler, do you mean a boiler that was
7 manufactured by du Pont?
8 A No, no. That was--du Pont owned the
9 boiler, but Deepwater had them on their site
10 sending steam over to them. But du Pont owned
11 them.
12 Q Okay. Now, let me get back to the
13 Foster Wheeler boiler.
14 A Yeah.
15 Q Do you know if it was just one Foster
16 Wheeler boiler out of the five?
17 A No. I think it was three--three of
18 them, three or four of them.
19 Q Okay.
20 A I think that was all of them. It had
21 a beginning and an end of boilers there, all new
22 boilers on this end and all old boilers on that
23 end.
24 Q Now, the--the first time that
25 you--you went to Deepwater, these boilers were

62
1 already installed; is that correct?
2 A Yes. Oh, yeah.
3 Q So you just went there for
4 maintenance.
5 A Repairs, yes.
6 Q Okay.
7 A Air-heated tubes.
8 Q Can you tell me--well, let me back
9 up.
10 Earlier, you testified in general as
11 to--to working on boilers--
12 A Yeah.
13 Q --and what Im interested in is what
14 you remember from working on the Foster Wheeler
15 boilers at Deepwater.
16 Do you understand that?
17 A Yes.
18 Q Okay. Do you believe you were
19 exposed to asbestos from your work on the Foster
20 Wheeler boilers at Deepwater?
21 A Yes.
22 Q Earlier, you gave a list of various
23 products in general that you believe caused you to
24 be exposed to asbestos.
25 Can you tell me what specifically

63
1 related to the Foster Wheeler boilers at Deepwater
2 you believe caused you to be exposed to asbestos?
3 A Out of--no.
4 Q Okay. That--that was kind of long.
5 Earlier, you testified to various
6 products, insulation-type products--
7 A Yeah.
8 Q --that you worked around on boilers.
9 Can you tell me which of those
10 products were on the Foster Wheeler boiler, if
11 any?
12 A Well, mostly I think it was--supply
13 was Garlock. They supplied a lot of--a lot of
14 gaskets, material.
15 Q I want--at this point I just want to
16 know what types of products. Like earlier there
17 was--
18 A Asbestos.
19 Q --testimony about block.
20 A Block, yeah.
21 Q So, you know, for instance, did you
22 work with block on the Foster Wheeler boilers at
23 Deepwater?
24 A I never touched them.
25 Q You never touched the block.

64
1 A The insulators put that in.
2 Q So you--you never had to--
3 A Tear it out, yeah.
4 Q You--you tore it out.
5 A Throw it away. But putting it back,
6 it was insulated.
7 Q Okay. So your work with the block
8 was tearing it out. Correct?
9 A Right.
10 Q Do you know who made the block?
11 A No, I dont.
12 Q Do you know whether or not that block
13 contained asbestos?
14 A It was brown. Thats all I know. In
15 them days I guess it was--asbestos was mixed with
16 almost everything.
17 Q But you--you didnt see the package
18 in that the block that came in--
19 A No, I didnt, no.
20 Q And did you see the--
21 A No, I cant--well, I cant honestly.
22 Q So you have no basis for your belief
23 that its asbestos other than what was generally
24 used in the trade; is that correct?
25 A Yeah.

65
1 MR. PLACITELLA: Objection to the
2 form.
3 He went through in detail where the
4 stuff was used on the Foster Wheeler boilers
5 and how it was used.
6 MR. QUINN: Well, Im trying--
7 MR. PLACITELLA: So for you to say he
8 has no basis I think is not a fair
9 question.
10 MR. QUINN: Well, I think I--I
11 mentioned his basis. Im trying to find out
12 what it is. He did not see the packaging it
13 came in. So Im just trying to find out the
14 basis for his belief that it contained
15 asbestos. So, okay.
16 MR. PLACITELLA: All right.
17 Q Now, other than the block, did you
18 use--work with any other types of insulation with
19 the Foster Wheeler boilers at Deepwater?
20 A Yes. We had all the--all the--all
21 the piping was wrapped with asbestos blankets.
22 Everything we had in the--in the tool room was
23 asbestos blanket, gloves and so on, tearing out
24 the floors.
25 Q The piping, was that part of the

66
1 boiler, or was that connected to it?
2 A Thats pipes, pipe fitters.
3 Q But the pipes themselves, were they
4 part of the boiler, or did they just connect--
5 A They just connected to it.
6 Q And you mentioned that they were
7 covered with pipe covering.
8 Do you know the manufacturer of any
9 of the pipe covering--
10 A No, I dont. Its been a long time.
11 Q I dont mean to interrupt, but let me
12 finish so that the court reporter can get my--I--I
13 know you know where Im going with the question,
14 but I need to get it on the record.
15 Do you know the manufacturer of any
16 of the pipe covering that was used on the pipes
17 connected to the Foster Wheeler boilers?
18 A I had nothing to do with the covering
19 of pipe.
20 Q Did you see any writing on the--on
21 the pipe covering?
22 A I dont have to. I wasnt involved
23 with it.
24 Q Do you believe that that pipe
25 covering contained asbestos?

67
1 A In them days, yes.
2 Q And do you believe that because of
3 just general knowledge or general belief in the
4 trade that it contained asbestos, or did you see
5 any writing on it?
6 A Well, I seen it. And then later on
7 they did away with that, and now they come to a
8 better stuff after that.
9 Q Well, when you were--when you were
10 working around the Foster Wheeler boiler, did you
11 see the words asbestos on the pipe covering?
12 A No.
13 Q Now, you mentioned a few moments ago
14 you believe you were exposed to asbestos through
15 flooring connected with the boiler?
16 A Yes.
17 Q Earlier, you talked about grating,
18 grate floors. So Im--Im not sure what you mean
19 by this--
20 A Its a walkway. If you want to go up
21 to the fifth floor, you took an elevator and go up
22 there. You go up the elevator, and youre on the
23 fifth floor. Thats a walkway.
24 Q But they would be made of--they were
25 made of metal. Correct?

68
1 A Yeah. Theyre steel.
2 Q Okay.
3 MR. PLACITELLA: Youre talking about
4 two different things.
5 MR. QUINN: Well, thats what Im
6 trying to--
7 MR. PLACITELLA: Hes talking about
8 what youre walking around the boiler. When
9 he was talking before, I think, just to help
10 you, he was talking about inside the
11 boiler. Youre talking about two different
12 things totally.
13 Q Are you talk--is that correct what
14 Mr. Placitella just--
15 A Is what?
16 Q With regard to flooring, you
17 mentioned that you were exposed to asbestos from
18 the flooring. We talked about the--
19 A The flooring--the floor is the bottom
20 of the boiler. But the flooring, what were
21 talking about, 10 stories, thats on the outside.
22 Q Well, the flooring of the boiler, do
23 you mean like brick?
24 A No. Corrugated steel.
25 Q Okay. So theres no asbestos

69
1 associated with the flooring?
2 A No.
3 Q Okay.
4 A Where the hell are we going here?
5 Q Well, Im just trying to--you
6 mentioned flooring, and then you mentioned the
7 tool room.
8 A The outside was steel, and now youre
9 coming--youre asking me the--
10 Q Well, Im sorry. I misunderstood
11 what you said, sir.
12 A Most--most of this stuff that youre
13 asking me was supplied by the manufacturer
14 through--through the company. They bought the
15 stuff. We never knew a name. We was given
16 something to work with, and thats what we used.
17 Now, if it was jibip, or whoever it
18 was, thats what we worked with.
19 Q Im just trying to find--
20 A Youre asking me--youre asking me
21 some specifics.
22 Q Im trying to find out what you
23 know. Thats all, sir. I dont mean to prolong
24 this, but just to get as much information as I
25 can.

70
1 A I missed my lunch.
2 Q Would you like to take a break for
3 lunch, sir?
4 A No.
5 Q We can do that.
6 A No, no.
7 Q Okay. A few moments ago you spoke
8 about stuff in the tool room that contains
9 asbestos.
10 A Right. No. Wait now.
11 Q Okay.
12 A That was always stored there. Thats
13 where you went to get the asbestos blankets. You
14 cut a piece off. You took it with you on the
15 job.
16 Q So when you mentioned the tool room,
17 thats where you got the blankets from?
18 A Right.
19 Q Why do you believe the blankets
20 contained asbestos?
21 A Because thats what they were. In
22 them days it was all asbestos blankets, until they
23 stopped it, and then they got--they come out with
24 this nylon blanket. It looks like a roll of tar
25 paper. You go out and you fold it out and cut a

71
1 piece off.
2 Q You--
3 A In the early days there was nothing
4 but asbestos, and that stuff flew.
5 Q Well, let me ask you, when do you
6 believe they switched from asbestos to nonasbestos
7 products in your trade?
8 A I cant--I cant give you that one.
9 Q Okay. Now, these--the--the blankets
10 that you mentioned, did you ever see them
11 packaged?
12 A No.
13 Q So you never saw the word asbestos
14 on the blankets.
15 Would that be fair?
16 A No, but I know it was asbestos
17 because I went in the tool room to get it.
18 Q Why--why do you know it was
19 asbestos?
20 A Well, if you want to look inside of
21 it, then you could tell.
22 Q So you can--so just from looking at a
23 product--
24 A In other words, you go in there, you
25 want a--you want a piece of asbestos blanket,

72
1 thats what you got. If you want a piece of nylon
2 blanket, thats what you got, in later years.
3 Q So is it fair to say when were
4 talking about whether something contained asbestos
5 or not, you could tell from looking at the
6 product?
7 A Definitely.
8 Q Okay. Is there any other way you
9 could tell whether it contained asbestos or not?
10 A Unless you called the manufacturer.
11 Q Okay. But for now, for today,
12 everything were talking about, you could tell
13 from looking at it.
14 A Right.
15 Q Okay. Now, getting back to the
16 Deepwater, the six times that you were at
17 Deepwater--
18 MR. PLACITELLA: Object to the form.
19 He said approximately six times.
20 Q Okay. Ill--fair enough.
21 A Approximately. Ive been--I had 30
22 years in the business, and Im not that old, but
23 Im paid two weeks here, three weeks there, two
24 months here, two months there. It was all repair
25 jobs.

73
1 Q Wasnt--didnt there come a time when
2 you no longer went out to various sites and you
3 strictly worked at the Salem nuclear facility?
4 A Yes.
5 Q Was that around 1966?
6 A Something like that. I went in there
7 for 10 years.
8 Q I think from your--your prior
9 testimony--
10 MR. QUINN: And is this Exhibit 1,
11 the--the deposition?
12 MR. PLACITELLA: Yes, it is.
13 MR. QUINN: Okay.
14 Q For Plaintiffs Exhibit 1, theres
15 been a notation, or I made a notation--
16 A You read a lot.
17 Q Lets see.
18 MR. QUINN: Chris, Im looking at I
19 guess it would be page 90, 89 and 90.
20 Q It looks like page 90 you testified
21 that you worked at the Salem Generating Station
22 for 17 years, until 1984.
23 So, my math, that takes us to about
24 to 1967. Correct?
25 A Yeah.

74
1 Q And also in that--that same--
2 A I retired then from the Salem plant--
3 Q But when you retired--
4 A --in 86.
5 Q --that was around 1986?
6 A 86.
7 Q Okay. So from 1967 to 86, you were
8 strictly at Salem nuclear plant. Correct?
9 A Right.
10 Q And you had testified then that you
11 believed that once you got to Salem, you were no
12 longer being exposed to asbestos.
13 A No, because it was against the
14 nuclear.
15 Q Okay.
16 A Its all nuclear powerhouse.
17 Q Okay. So we can say that as far as
18 your exposure was concerned, your exposure to
19 asbestos ended in 1967; is that correct?
20 A Right. That was the bad years.
21 (Off the record.)
22 Q Okay. And actually page 90, line 14,
23 it said--line 12, you had been there beginning
24 approximately 66, and then you testified 1965.
25 So somewhere in the mid-60s.

75
1 A Yeah.
2 Q Okay.
3 MR. PLACITELLA: Objection to the
4 form of the question.
5 Q So is it, then, according to your
6 prior deposition, you would not have been exposed
7 to asbestos after 1965. Correct?
8 MR. PLACITELLA: Thats not what he
9 said.
10 A Right.
11 MR. PLACITELLA: Just ask him when
12 he--you just asked him, and he said 67.
13 Q Now, the first time--well, let
14 me--let me shorten it up a little bit.
15 The--the times that you were at the
16 Deepwater plant, it would have been somewhere
17 between the late 1950s and 1965, 66, in there?
18 A I was there--
19 Q If you--
20 A --in and out them years.
21 Q Okay. And you anticipated my next
22 question.
23 If you were to add up, you know, the
24 amount of the weeks or days that you were there on
25 those various occasions, would you be able to give

76
1 me a total time that you spent at--at Deepwater,
2 in either days or weeks?
3 A No. Were talking a few months.
4 Q Would that be a few months total?
5 A Total. Most of these jobs are
6 renting out jobs.
7 Q Now, the--the first time that you
8 were at Deepwater, what did you do?
9 Do you remember the--the work that
10 you performed on the Foster Wheeler boiler?
11 A Yeah. Burning out tubes, floor...
12 Q Do you remember how long that job
13 lasted?
14 A A couple of weeks. A job would only
15 last a month or so on the floor.
16 Q So this is burn out tubes and a
17 repair job on the floor?
18 A On the floor, plus replace air tubes,
19 air heater tubes.
20 Q Now, when you replaced--by
21 replacement, that would include installing new
22 ones; is that correct?
23 A Whats this?
24 Q Did you install new tubes?
25 A Yes.

77
1 Q Okay.
2 A Oh, yeah.
3 Q Did any of that installation work
4 cause you to be exposed to asbestos?
5 A No. There was no insulation there at
6 that time.
7 Q Okay. And the rest of the work was
8 tear-out?
9 A (Witness nods head.)
10 Q Okay. Do you recall what work you
11 did your second time at Deepwater on the Foster
12 Wheeler?
13 A Same thing. All repair jobs.
14 Flooring, walls, water walls.
15 Q That second time, was it all tear-out
16 work?
17 A Yeah.
18 Q A--
19 A And the third time, whatever.
20 Q Well, was--can you tell me, other
21 than--other than that first time where you
22 replaced the air tubes, did you ever do any
23 installation of any material onto the boilers?
24 A Replace tubes. Thats all.
25 Q And they did not have insulation--the

78
1 tubes did not involve the use of insulation; is
2 that correct?
3 A No, no.
4 Q So is it fair to say you--you dont
5 believe you were exposed to asbestos when you
6 worked--
7 A Oh, no. Thats wrong.
8 Q I need--if you--I need to finish my
9 question.
10 A I was covered with blankets.
11 Q Well--
12 A I used my own stuff.
13 Q I need to finish my question, so
14 maybe your answer will be different when I
15 finish.
16 MR. PLACITELLA: Objection. The
17 witness is badgering the lawyer.
18 MR. QUINN: At least go off the
19 record on that.
20 Q When you were just replacing the--the
21 air tubes, when you were installing the new air
22 tu--air tubes, that didnt cause you to be exposed
23 to asbestos, did it?
24 A No.
25 Q Okay. So all your work on the Foster

79
1 Wheeler boilers through the years, you believe you
2 were exposed from tearing out insulation
3 materials. Correct?
4 A Right.
5 Q And by using blankets--
6 A Blankets, gloves.
7 Q --and gloves?
8 A And refractory cement. That had
9 asbestos in it.
10 Q And thats all--
11 A Repacking, yeah.
12 Q And this was all tear-out work.
13 A Tear-out and repairs.
14 Q But did you ever see the packaging
15 that the refractory material came in?
16 A No.
17 Q Did you ever see the packaging that
18 the gloves came in?
19 A No.
20 Q Did you ever see the--I believe I
21 asked this. Did you ever see the packaging the
22 blankets came in?
23 A No.
24 Q Okay.
25 THE VIDEOGRAPHER: Three minutes left

80
1 on the tape. If you want me to change now
2 or--
3 MR. QUINN: Why dont you change now.
4 THE VIDEOGRAPHER: Okay. Off the
5 record at 11:20.
6 (A short recess was taken.)
7 THE VIDEOGRAPHER: Okay to continue.
8 BY MR. QUINN:
9 Q When you worked at Deepwater, was
10 that all for the same employer?
11 A B & W I think it was.
12 Q And was that on all approximately--
13 A Most of them.
14 Q --six occasions?
15 A Yeah.
16 Q Do you recall any other employers you
17 worked for at Deepwater?
18 A No.
19 Q Did there come a time when you became
20 aware of the hazards of asbestos?
21 A Never got any information on it.
22 Q Well, at some point in your life you
23 came to believe that asbestos was dangerous; is
24 that true?
25 A No.

81
1 Q As you sit here today, did--
2 A I worked in the shipyard for three
3 years and used asbestos blanket. Nobody ever said
4 a word about asbestos blanket, which thats where
5 I got the most of it. And then go from job to
6 job, they did the same thing.
7 Q So you believe--
8 A Nobody give you anything on asbestos
9 blanket.
10 Q You believe most of your exposure
11 occurred in the--when you worked in the
12 shipyards?
13 A Yeah.
14 Q Okay. But you brought a--a lawsuit
15 for your exposure to asbestos. Correct?
16 A Right.
17 Q So that you believe that your
18 exposure caused your harm. Correct?
19 A Yeah.
20 Q Now, your lawsuit was in the--in the
21 mid-1990s. Correct?
22 A Right.
23 Q So at some point you had to learn
24 that asbestos was dangerous.
25 A Right.

82
1 Q Do you remember when you first
2 learned that asbestos was dangerous?
3 A No.
4 Q Do you remember any decade?
5 A Well, it was a big--it was a big--a
6 big thing to find out what the asbestos was. It
7 got ballooned out that this guy took an x-ray,
8 that guy took an x-ray, the unions put a stand on
9 it.
10 Q Now, when--youre a member of the
11 Local 28 Boilermakers. Correct?
12 A Yeah.
13 Q And you attended some union meetings;
14 is that correct?
15 A Yeah.
16 Q Did you receive a--a publication from
17 the union?
18 A No.
19 Q You never received a magazine
20 quarterly that came out of the union?
21 A No.
22 A magazine or a paper?
23 Q Well, Im not sure if the for--I
24 believe the format was in like a newspaper
25 format.

83
1 Did you ever receive any
2 publications?
3 A No.
4 MR. QUINN: If I may, Id like to
5 show your counsel a document.
6 Q Sir, I want to show you a--what Ill
7 represent is a reproduction of a magazine
8 published by the--lets see, it would be the
9 International Brotherhood of Boilermakers, Iron
10 Ship Builders, Blacksmiths, Forgers and Helpers.
11 Was that the name of your union?
12 A Yeah.
13 Q I want you to have a--have a look at
14 that on the first couple of pages and let me know
15 if you, you know, recognize that.
16 (The witness complies with the
17 request.)
18 A Its a navy ship.
19 What the hell else is there?
20 Q Well, if you go over to page 2, is
21 that the union that you were a member of?
22 If you look down on page 2, it says,
23 PUBLISHED MONTHLY by the International
24 Brotherhood of Boilermakers, Iron Ship Builders,
25 Blacksmiths and Forgers...

84
1 Do you see that?
2 A Where the hell is page 2?
3 Q Here. Maybe I can help you here.
4 Ill tell you what. Let me see. Im just going
5 to--if you see where I marked in pen there, if you
6 would read that for a moment.
7 (The witness complies with the
8 request.)
9 MR. PLACITELLA: Do you have a
10 question?
11 MR. QUINN: Im waiting--I was
12 waiting.
13 Q Have you finished looking?
14 A Go ahead.
15 Q Oh! Now, is that the union you were
16 a member of?
17 A Yeah, boilermakers.
18 Q Okay. So but its--you have no
19 recollection of receiving any of these
20 publications; is that--
21 A No.
22 Q Okay. Now, if you would, can I have
23 that back for just a moment? I just want to go to
24 page 10 here.
25 If you look at these paragraphs here,

85
1 its two quick paragraphs, if you could read them
2 for me briefly, and then let me know when youre
3 done.
4 (The witness complies with the
5 request.)
6 A Yeah. Its telling you everything I
7 told you, the dust and whatever. But we never--I
8 never got anything on this.
9 Q Okay. Now, this is--
10 A When did--when did this come out?
11 Q Well, if youll--thats what Im
12 going to ask you about.
13 If you go back to the cover page with
14 the ship on it--
15 A Yeah, 69.
16 Q --the date is April 1969.
17 And my question is, you know,
18 would--would you agree with me that this is an
19 article published from your union attempting to
20 inform its members about the dangers of asbestos?
21 MR. PLACITELLA: Im going to object
22 to this question.
23 He says hes never seen it, he
24 doesnt know anything about it. And how is
25 he supposed to agree with what you say it

86
1 says?
2 MR. QUINN: Well--
3 A Whats--whats in here, what youre
4 asking me, Ive never seen anything like this.
5 Q Okay. But--but you are--you have
6 testified that that is your union that you
7 belonged to.
8 A Definitely.
9 Q Correct?
10 Okay.
11 A Thats what Im here for.
12 MR. QUINN: And the document speaks
13 for itself. I mean, Im not--you can let
14 your objection stand.
15 If I could, I would like to have it
16 marked as--
17 MR. PLACITELLA: D-1.
18 MR. QUINN: --I guess D-1.
19 (International Brotherhood of
20 Boilermakers, Iron Ship Builders,
21 Blacksmiths, Forgers and Helpers publication
22 dated April 1969 received and marked Exhibit
23 D-1 for identification.)
24 MR. PLACITELLA: Ill make a request
25 for all publications in your possession--

87
1 MR. QUINN: Okay.
2 MR. PLACITELLA: --from the--related
3 to the boilermakers, the boilermakers
4 union.
5 MR. QUINN: Okay. Then--
6 MR. PLACITELLA: You dont have to
7 give them to me now. Just at some point--
8 MR. QUINN: Well, Id like to get
9 them authenticated if were going to--
10 MR. PLACITELLA: How is he going
11 authenticate them?
12 Hes never got them.
13 MR. QUINN: Well, he can--
14 MR. PLACITELLA: How is he going
15 authenticate them?
16 MR. QUINN: He can--well, if youll
17 stipulate that these are publications--
18 MR. PLACITELLA: I never saw them
19 before.
20 MR. QUINN: Okay. Well, then, let
21 me--let me keep going.
22 MR. PLACITELLA: Youre going to ask
23 him about things he never saw and try to get
24 him to authenticate it because it says
25 Boilermaker on it?

88
1 MR. QUINN: Well, well see what
2 Im--
3 MR. PLACITELLA: Ill use them when I
4 take your companys deposition.
5 MR. QUINN: Let me do it this way.
6 BY MR. QUINN:
7 Q Sir, Ive got several other newspaper
8 reproductions. If I were to go through each one
9 and ask you to look at the name of the publisher
10 as the International Brotherhood of Boilermakers,
11 Iron Ship Builders, Blacksmiths, Forgers and
12 Helpers, would you agree with me in each instance
13 that you were a member of that union?
14 A Yeah.
15 Q Give it a shot.
16 Well, Ill make such a representation
17 to you, then.
18 A I think you got more notices than we
19 got at the hall.
20 MR. QUINN: Move to strike that.
21 Question pending.
22 Q Now, weve talked at some length
23 about Foster Wheeler and your work at Deepwater.
24 Have we talked about all the ways you
25 believe you were exposed to asbestos from any

89
1 products or services offered by Foster Wheeler?
2 A No.
3 Q Can you tell me what other ways you
4 believe Foster Wheeler may have contributed to
5 your asbestos exposure?
6 A Just the material they send in.
7 Q Well, we--what material would that
8 be?
9 A We dont--we dont--the boilermakers
10 do not order this stuff. The company does.
11 Whatever comes it, thats what you use.
12 Q When you--
13 A And knowing--knowing looking at it,
14 you could tell a Ford from a Chevy, that asbestos
15 is another thing that you can tell.
16 Q When you just mentioned, you--you
17 said that the--the companies order the material.
18 A Right.
19 Q Do you mean the companies that you
20 were working for--
21 A Right--
22 Q --on the job site?
23 A --the companies I was working for.
24 Q Okay. And when you were at
25 Deepwater, you were never employed by Foster

90
1 Wheeler; is that correct?
2 A Babcock.
3 Q But not Foster Wheeler?
4 A No.
5 Q Okay. So--
6 A I dont think so. Now, I dont
7 remember that--
8 Q Okay.
9 A --that far back.
10 Q But as far as your work on Foster
11 Wheeler boilers, weve discussed all the ways you
12 believe you were exposed to asbestos--
13 A Yeah.
14 Q --is that correct?
15 Let me move on and ask you a question
16 about--or I wont limit myself to one
17 question--General Electric.
18 You told Mr. Placitella earlier that
19 you believe you worked in the vicinity of a
20 General Electric turbine?
21 A Yeah.
22 Q Can you tell me where that turbine
23 was located?
24 A On the main floor in the powerhouse.
25 Q Which powerhouse?

91
1 A Deepwater.
2 Now, dont ask me of I got anything
3 from there, because thats a clean floor for
4 turbines.
5 Q Someone will be happy to hear that,
6 Im sure.
7 A They dont--they dont put material
8 up there.
9 Q Other than--now, was this one turbine
10 at--at Deepwater--
11 A No.
12 Q --made by GE?
13 A It was more than one. I dont know
14 just how many there was, two or three, four.
15 Q Were they all manufactured by GE, or
16 could there have been others?
17 A No, I couldnt tell you that.
18 Q But you have a recollection of at
19 least one GE turbine at Deepwater?
20 A Yes.
21 Q Now, you--
22 A It had nothing to do with them.
23 Boilermakers have nothing to do with that. Thats
24 all millwright work.
25 Q Did you ever see that GE turbine

92
1 being worked on?
2 A Yes.
3 Q Can you tell me when that was?
4 A Well, I dont know the years.
5 Q But it would have been before 1965,
6 66--
7 A Yeah--
8 Q --in there?
9 A --in there someplace.
10 Q Do you have any records at home that
11 would refresh your recollection as to when you
12 worked at a particular site or who you worked
13 for?
14 A No.
15 Q Can you tell me on how many occasions
16 you observed the GE turbine being worked on?
17 A Steam generators.
18 Q No.
19 Can you tell me how many times you
20 saw the GE turbine being worked on?
21 A Every time I was in there, you know,
22 when I got a job for our repair, you worked--you
23 worked right there on the floor with them. Not
24 with them. They were--they were off by
25 themselves.

93
1 Q And now, you said that was a clean
2 floor.
3 A That was a clean floor, yeah.
4 Q And you were working on the same
5 floor as the turbine?
6 A No. Part of--part of your boiler,
7 you go into your boiler from the main floor, or
8 you go underneath it, or you go on the top of it.
9 Youre never on the same floor with them.
10 Q Okay. Did--could you see what they
11 were doing to the turbine?
12 A Yeah. Replacing stators and fan and
13 blades.
14 You know what they are?
15 Q I was going to ask you that same
16 question.
17 A Well, there you are.
18 What the hell are you asking me for?
19 Q Do you believe that the work of the
20 millwrights on the turbines caused you to be
21 exposed to asbestos?
22 A No.
23 Q Okay.
24 A Are we having fun yet?
25 Q Do you know who employed the

94
1 millwrights that were working on the GE turbine?
2 A No. Probably Westinghouse. If it
3 was a Westinghouse turbine, thats who hired
4 them.
5 Q Im only talking about the--the GE
6 turbine--
7 A Thats what Im talking about.
8 Q --not anybody else.
9 You just mentioned--
10 A All right. GE whoever it--whoever it
11 was, it belonged to.
12 Q But you dont--you dont know. You
13 just assume that if it was made by a certain
14 company, that company serviced it.
15 A Yeah, yes, that company.
16 Q Is that fair to say?
17 Okay.
18 A Yeah, fair enough, yeah. Thats got
19 nothing to do with the boilermakers.
20 Q But you never saw any GE personnel
21 working on that boiler; is that correct?
22 A GE?
23 Q Yes.
24 A No.
25 Q And by GE, I mean General Electric.

95
1 A Yeah.
2 Q Youre clear about that?
3 A All right.
4 Q Okay. Other than the Deepwater
5 facility, did you ever work around any other GE
6 turbines that you can remember?
7 A No.
8 MR. QUINN: I think thats all I have
9 for now, but I think you might be able to
10 bring me back in.
11 MR. PLACITELLA: Oh, Ill have a few
12 questions.
13 MR. QUINN: Okay.
14 THE VIDEOGRAPHER: Off the record at
15 11:37.
16 (A short recess was taken.)
17 THE VIDEOGRAPHER: Back on the record
18 at 11:40.
19 EXAMINATION
20 BY MR. SCHEETS:
21 Q Good morning, Mr. Skrabonja. My name
22 is Jason Scheets, and I represent United Engineers
23 in this matter.
24 A Okay.
25 Q I just want to take a step back and

96
1 talk generally about your work at PSE&G sites.
2 When you worked as PSE&G sites, and
3 correct me if--if it differs for any of the
4 different sites that you worked at, was it during
5 the winter?
6 A Yeah, winter, summer jobs.
7 Q You did winter and summers jobs at
8 PSE&G?
9 A Yeah.
10 Q Okay. Was this throughout the time
11 that you worked at PSE&G?
12 A Whats this?
13 Q Was this throughout the time that you
14 worked at PSE&G that you worked either in the
15 winter or the summer?
16 A Off and on. When the boiler went
17 down--
18 Q Okay.
19 A --we went in.
20 Q Okay.
21 A It was either summer or winter.
22 Q Okay. Were these--were these
23 scheduled shutdowns, or would you just be called
24 in if repairs were needed?
25 A Theyre scheduled.

97
1 Q Okay.
2 A Some of them is a re--very--very
3 seldom a--a repair job is called in.
4 Q Okay.
5 A Its scheduled.
6 Q Okay. And these would be scheduled
7 sometimes in the winter and sometimes in the
8 summer--
9 A Yeah.
10 Q --is that correct?
11 A Yeah. And its cold on the river.
12 Q Okay. And when you went to work,
13 when you went to PSE&G, what were you wearing?
14 A Whatever--if it was hot, light
15 clothes, if it was cold, heavy clothes.
16 Q Okay. Did you have to have a uniform
17 when you went to work?
18 A No.
19 Q Okay. When you got there and you
20 were going to perform your welding work, what did
21 you wear when you performed the welding?
22 A Sleeves, asbestos blankets, asbestos
23 gloves, because I was a welder.
24 Q Okay. Did you actually wear the
25 blankets, or you used the blankets in the

98
1 environment?
2 A Just to protect you.
3 Q Okay. Did you actually put the
4 blankets on you, or did you use them, put them on
5 the equipment?
6 A Well, if you were sitting down, youd
7 put them on your lap.
8 Q Okay. So you had gloves.
9 What else were wearing on your body?
10 Were you wearing an apron?
11 A Leather sleeves.
12 Q Sleeves?
13 A Leather sleeves or a leather jacket.
14 Q Okay. And why--did you always the
15 jacket?
16 A Well, if it was--it all depended what
17 you was doing, what--what kind of welding you was
18 doing.
19 Q Okay.
20 A If it was stake, if it was stick
21 welding, that--thats what you put on. You either
22 put leather on or just gloves.
23 Q Okay. So what type of welding would
24 require you to wear the jacket?
25 A Anything overhead--

99
1 Q Okay.
2 A --welding overhead on the casing.
3 Q And then what type of welding would
4 you just wear the sleeves?
5 A Same thing. If it was just welding
6 in front of you, a spark would just hit your arm,
7 and that was it.
8 Q Okay. But you wouldnt necessarily
9 be wearing the jacket if you were welding in front
10 of you; is that correct?
11 A Right.
12 Q Did you wear anything on your legs?
13 A Yeah. Asbestos blanket--
14 Q Okay.
15 A --that covered your legs.
16 Q Okay. Now, if you were standing and
17 welding, would you be wearing a blanket?
18 A No.
19 Q Okay. When you were weld--
20 A Stand away from it--
21 Q Okay.
22 A --reach.
23 Q Okay. If you were standing and
24 welding, were you--what were you wearing on your
25 legs?

100
1 A Just your clothes--
2 Q Okay.
3 A --regular clothes, regular work
4 clothes.
5 Q Would you be wearing jeans or some
6 other type of clothing?
7 A Well, I wore Carhartts.
8 Q Okay. And did--and you didnt
9 attempt to protect your--your pants from being
10 burned?
11 A Yeah.
12 Q Did you?
13 A Whats that?
14 Q Did you attempt to protect your pants
15 from being burned when you were standing and
16 welding?
17 A No. You just move back.
18 Q Okay. And you wore a face shield
19 when you welded?
20 A Yes.
21 Q Did you always wear a face shield?
22 A Oh, definitely.
23 Q And when you finished up the welding
24 for the day, you would take off the face shield,
25 the sleeves or the jacket, and go home?

101
1 A Thats right.
2 Q Okay. Was your upper body--was your
3 upper body dirty, covered in dust when you left
4 after welding?
5 A It wasnt that dirty, no, but you was
6 dirty.
7 Q Okay. I mean, was it--could you
8 visibly see dirt on your--on your shirt?
9 A Some spots, yes.
10 Q Okay. Would you--would you dust off
11 before you got in your car?
12 A Oh, yeah, you would dust off.
13 Q Okay. And, generally, when you were
14 working at PSE&G, what were your hours?
15 A In them days, it was eight to 3:30.
16 Q Okay. So you got done at 3:30?
17 A It was seven hours then. Then it
18 turned out to eight.
19 Q Okay. So, usually, you got done
20 working around 3:30 in the afternoon?
21 A 3:30, 4:30, either one.
22 Q And when you got home, what did you
23 do with your clothing when you got home?
24 A Took them off and threw them in the
25 corner.

102
1 Q Okay. Did you--did your clothes pile
2 up for the week?
3 A Every couple of days.
4 Q So you had several pair of the
5 Carhartts you would wear?
6 A Oh, yeah.
7 Q Okay. And when was the laundry
8 done?
9 A When?
10 Q Yeah.
11 A Well, when my wife or daughter washed
12 them--
13 Q Okay.
14 A --that was it.
15 Q Okay. When--when did your daughter
16 wash your clothes?
17 A When?
18 Q Yeah. What years?
19 A Oh, Christ! Who knows what year?
20 In the--in the 50s or 60s,
21 whatever.
22 Q Okay. So she was--she was born--
23 A She was--she was about 11 years old
24 when she started to do a lot of that garbage.
25 Q Okay. And--and you said she was

103
1 about 11 when she started helping your mom--or
2 helping her mom--
3 A Right.
4 Q --wash the clothes.
5 A Right.
6 Q Okay. When--what time--what day of
7 the week would they do the laundry?
8 A Whenever they were free, at night--
9 Q Okay.
10 A --or Sunday or Saturday--
11 Q So sometimes--
12 A --or Friday.
13 Q Sometimes she would do it at night
14 when shes home from school--
15 A Yeah.
16 Q --or sometimes on the weekends?
17 A Sometimes, yeah.
18 Q Okay. When you were working at
19 PSE&G, did they have changing trailers for you?
20 A Yeah.
21 Q Did you use those?
22 A Oh, yeah. You hung your--you hung
23 your clothes up, or whatever, when you went--when
24 you went in there. Thats where you met in the
25 mornings to go out on the job.

104
1 Q Okay. And--
2 A But you didnt leave your clothes
3 there, because they wouldnt be there the next
4 day.
5 Q Right. Okay.
6 A Simple as that.
7 Q Right. And you wore your work
8 clothes and then--
9 A Wore in and out, right.
10 Q Correct. So did you ever have a
11 change of clothes on site at PSE&G?
12 A No.
13 Q Okay. So you--you came in wearing
14 your--your Carhartts, and then you would assemble
15 your welding gear in the changing trailer?
16 A Well, that--that stayed in the--that
17 stayed in the workbox.
18 Q Okay.
19 A That was left there.
20 Q Okay. And where was the workbox
21 located?
22 A On the job site--
23 Q Okay.
24 A --where you were working. You leave
25 it there. Hopefully, it was there the next day.

105
1 Q What did you do in the changing
2 trailer?
3 A Well, wherever you had lunch.
4 Q Did you actually ever change clothes
5 while you were in the changing trailer?
6 A No.
7 Q Okay. So you never brought--
8 A We played cards.
9 Q Okay. How did you do?
10 A Pretty good. Jesus Christ!
11 Q Okay. So if I understand you
12 correctly, you never brought a change of clothes
13 with you to change into either before or after
14 work?
15 A No.
16 Q Okay. Did they have showers there?
17 A No. That was all companies.
18 Q And you testified that you worked for
19 United Engineers at PSE&G at certain times; is
20 that correct?
21 A Uh-huh.
22 Q Is that a yes?
23 A Yes.
24 Q Okay. You just have to say yes,
25 because on the--on the transcript it will--it will

106
1 appear fuzzy.
2 Did--did United Engineers issue you a
3 paycheck--a paycheck?
4 A Yes.
5 Q Okay. So when you--they paid you, it
6 said United Engineers?
7 A Yeah.
8 Q Okay. And how often would they pay
9 you?
10 A Once a week.
11 Q And let me understand your testimony
12 from earlier.
13 Did you testify that United Engineers
14 actually purchased the gloves and the blankets
15 that you used?
16 A Yeah. I imagine they did.
17 Q Do--do you know for a fact that
18 United Engineers purchased the gloves and blankets
19 that you used?
20 A Yes.
21 Q How do you know that?
22 A Well, because Public Service never
23 ordered them, and they come right into the tool
24 room.
25 Q Okay. Who--who delivered them to the

107
1 tool room?
2 And were talking about the gloves
3 and blankets.
4 A The company, United.
5 Q Are you okay?
6 A Yeah.
7 MR. PLACITELLA: Ill get you some
8 water.
9 THE WITNESS: No. Im all right.
10 A United.
11 MR. PLACITELLA: Ill get you good
12 water. Dont worry about it.
13 A United.
14 Q You say United Engineers employees
15 bring in the blankets and the gloves?
16 A No, I did not.
17 Q Okay. Do you know who delivered
18 the--the blankets and gloves to PSE&G?
19 A No, I dont.
20 Q Okay. So how do you know that United
21 Engineers actually purchased those materials if
22 you didnt see them bring it in and you didnt see
23 them order?
24 A The company I worked for wasnt
25 ordering them. So our tool room was being

108
1 replenished.
2 Q Okay. And who--and the tool room,
3 was that just used by the welders, or was that
4 used by various trades?
5 A No. That was by a boilermaker
6 issuing tools.
7 Q Okay. So there was a boilermaker in
8 there running the shop?
9 A Yes.
10 Q Do you recall who that was?
11 A Yeah. Georgie Dunner.
12 Q Okay. Now, was--did he work at the
13 various sites, or do you recall him at a specific
14 PSE&G site?
15 A Every job you go on you set up a tool
16 room and you have your own tool man.
17 Q Okay.
18 A So it could be a different man every
19 time you move.
20 Q Okay. And he was a--he was a--a
21 member of the local?
22 A Oh, yeah. 28.
23 Q Do you recall who worked the tool
24 shop at Bergen?
25 A No.

109
1 Q Do you recall who manned the tool
2 shop at Burlington?
3 A Happy Reeves.
4 Q Is that Happy?
5 A Happy, Hap Reeves.
6 Q Okay. And how about at Hudson?
7 A Well, that was somebody from North
8 Jersey, which it might have been Crosby.
9 Q Do you know? Do you recall it being
10 Crosby working in the tool room?
11 A No. Im not sure up there.
12 Q Okay. If youre not sure, I dont
13 want you to guess.
14 A Okay. Im not guessing.
15 Q Okay. Well, if youre not sure--
16 MR. PLACITELLA: Dont guess. All
17 right?
18 Q Do your best. But if youre not sure
19 of something, I dont want you to guess.
20 A No. I understand. Im trying
21 to--Im trying to make you understand that every
22 job is different.
23 Q Right.
24 A You have different tool rooms--
25 Q Right.

110
1 A --different men, different people
2 order, you know.
3 Q Right. Im just trying to, you know,
4 get from you what you recall. If you dont
5 remember something, thats fine, its no big deal,
6 and well just move on.
7 Do you recall who worked the tool
8 room at Linden?
9 A No.
10 Q And how about at Sewaren?
11 A No.
12 Q And how about at Mercer?
13 A No.
14 Q Okay. Now, before I--I--I asked you
15 about whether someone was manning the tool shop,
16 and you said somebodys name. I--I cant recall
17 what that name was.
18 Was it Dennis?
19 A Georgie Dunner.
20 Q Oh, George, George Dunner.
21 Now, do you recall--
22 A He was my tool room man, yeah.
23 Q Do you recall what site he worked at
24 with you--
25 A That was--

111
1 Q --or sites?
2 A --down at Salem on that job.
3 Q Okay. Was that the nuclear plant?
4 A Yeah.
5 Q Okay. Did you ever order the
6 blankets or gloves?
7 A No, sir.
8 Q Okay. Did you ever tell anybody when
9 you needed more blankets or gloves?
10 A Yes.
11 Q And--and who did you talk to?
12 A Well, they usually have a salesman
13 come around.
14 Q Okay. Who did the salesman work for?
15 A I dont know.
16 Q Okay. So you told him what you
17 needed, the salesman?
18 A Yeah. Well, they come in to sell,
19 and they talk to the foreman, or whatever, to get
20 an idea--
21 Q So--so--
22 A --and then they go back and talk to
23 the purchasing agent for the site.
24 Q Right. Now, was it the foreman who
25 was placing the orders?

112
1 A No.
2 Q Who--who was placing the orders?
3 A The company that you worked for.
4 Q Okay. So how did--how did they know
5 when you needed materials?
6 A The salesman went back and talked to
7 them.
8 Q Okay. So the salesman was basically
9 a go-between the--the workers and then the company
10 that was employing you?
11 A Anything he could sell.
12 Q Do you recall the names of any
13 salesmen at PSE&G?
14 A No.
15 Q And I may have asked this already,
16 but do you recall the names of any of the
17 companies that delivered the gloves or blankets to
18 any PSE&G site?
19 A No.
20 Q Did you ever unload trucks when they
21 came in delivering materials?
22 A I didnt even see the truck.
23 MR. SCHEETS: Okay, sir. I believe
24 thats all I have.
25 THE VIDEOGRAPHER: Off the record at

113
1 11:54.
2 (A short recess was taken.)
3 THE VIDEOGRAPHER: Back on the record
4 at 12:03.
5 EXAMINATION
6 BY MR. LaSALA:
7 Q Good afternoon, sir.
8 A Good morning. Good afternoon.
9 Q Good afternoon. My name is LaSala.
10 Im going to ask you a few questions only about
11 Paulsboro.
12 All right, sir?
13 A Yeah.
14 Q Okay. I think you first worked there
15 in a year thats near and dear to my heart, 1948;
16 is that correct?
17 A Probably, yes.
18 Q Okay.
19 A That was one of the first jobs I had.
20 Q Okay. And for how long did you work
21 there in the 1948 time frame?
22 A I was in and out of there quite a few
23 times. But one job was when they put the hoodray
24 up, when they put the cracking unit in, I worked
25 there. But I dont remember who they were.

114
1 Q Were you there initially for the
2 first time for about six months?
3 A Yeah.
4 Q When you say the cracking unit, are
5 you referring to the cigarette tower or something
6 else?
7 A No. The cracking unit is something
8 else.
9 Q When you worked on the cracking unit,
10 did you work outside?
11 A No. It was all your work was
12 inside.
13 Q What did you do--when did you work on
14 the cracking unit?
15 Was that in the 48 time frame?
16 A Probably, yeah.
17 Q Who was your employer at that point?
18 A I dont know whether it was United.
19 United had most of these Public Service jobs.
20 Q Im talking about Paulsboro, sir.
21 A Yeah, I know.
22 MR. PLACITELLA: Paulsboro, hes
23 talking about the refinery.
24 THE WITNESS: Yeah, I know. Im
25 trying to think of who the--who the

115
1 contractor was. It gets away.
2 Q When you worked for a contractor at
3 Paulsboro, did you have a foreman or a
4 supervisor?
5 A Yeah.
6 Q Okay. And were they the--did they
7 work for the contractor or employer?
8 A No, I didnt.
9 Q Okay. Who did you work for?
10 A Du Ponts. You worked for du Ponts
11 maintenance. They have their own maintenance in
12 Wilmington. When they have repair jobs or
13 something, they come in and supervise, but they
14 use union people.
15 Q So when you worked at Paulsboro--and
16 tell me if Im wrong about this--you worked for du
17 Pont maintenance out of Wilmington, and they ran
18 the job?
19 A Yeah.
20 Q Okay. And they provided the
21 supervisors or the foremen who you would report
22 to?
23 A No. The boilermakers had the
24 foremens--they--they had the foremen, but they was
25 overseeing.

116
1 Q Who did foremen that the boilermakers
2 have work for?
3 A Who did they have who?
4 Q The foremen that you talked about for
5 the boilermakers--
6 A Yeah. Me.
7 Q Who--you were the foreman?
8 A Yeah.
9 Q Okay. Were you the foreman on all
10 the boilmaker jobs at Paulsboro?
11 A No.
12 Q When you were the foreman on
13 boilmaker jobs at Paulsboro, who were you employed
14 by?
15 A Its stuck, but I cant think of the
16 damn thing now.
17 Was it United?
18 United Engineers.
19 Q Would you get your assignments from
20 whoever you were employed by at Paulsboro? They
21 would tell you what to do?
22 A Oh, yeah.
23 Q And they would supervise your work?
24 A Yeah.
25 Q And tell you if there was any issue

117
1 about your work, any problems?
2 A Yeah.
3 Q When you worked at Paulsboro, were
4 you provided with any clothing by your employers?
5 A No.
6 Q Okay. Were you empl--were you
7 provided--
8 A Yeah, gloves and, you know, whatever
9 youre doing.
10 Q Were there lockers at Paulsboro?
11 A No. Just change houses, trailers,
12 change houses.
13 Q The cigarette tower that you spoke
14 about before, do you recall when you worked on the
15 cigarette tower at Paulsboro?
16 A No, I dont. But that was all repair
17 jobs, in and out.
18 Q Did you finish your work at Paulsboro
19 in the early 1950s?
20 A Somewhere around there.
21 Q Was there ever a shop steward from
22 Local 28 on site at Paulsboro?
23 A Yes.
24 Q Okay. And who was that shop steward
25 who was on site at Paulsboro?

118
1 A Gees, I cant remember his name. We
2 have our own on the job sites.
3 Q If there was a safety issue at a job
4 site like Paulsboro--
5 A Yeah.
6 Q --would the shop steward be the
7 person who became involved in it?
8 A Yeah.
9 Q Do you recall the name of any of the
10 shop stewards who were at Paulsboro when you were
11 there?
12 A No.
13 Q Was the cigarette tower work
14 outside?
15 A No. When you got on the cigarette
16 tower, you had to go inside and cut the--cut the
17 trays out.
18 Q When you say inside--
19 A Its all inside work.
20 Q Okay. Are you saying--do you mean
21 inside, within the tower?
22 A Yes.
23 Q And the materials that you used on
24 working on the cigarette tower would have been
25 provided to you by your employer--

119
1 A Yes.
2 Q --at Paulsboro?
3 Now, Ive never heard of a hoodray.
4 Whats a hoodray?
5 A Its just a--its another unit for
6 processing oil.
7 Q Petroleum processing unit?
8 A Yeah.
9 Q Is that an indoor or an outdoor
10 unit?
11 A Its a big outdoor. Well, its
12 framed in. Everything is in framed.
13 Q When you worked on the hoodray at
14 Paulsboro, that was in that same time frame,
15 somewhere between 48 into the early 1950s?
16 A Yeah. The stack I put up didnt fall
17 down, so we was all right.
18 Q Now, you were asked some questions a
19 little while ago about dusting off your clothes
20 before you would go home and--
21 A Yeah.
22 Q --and how they were laundered.
23 Would your answer be the same at all
24 the work sites that you worked at?
25 A What?

120
1 Q Was your practice the same at all the
2 job sites--
3 A All of them. All of them.
4 MR. LaSALA: Thank you, sir.
5 A (Continuing) No showers, no change,
6 you know. Whatever you felt like doing.
7 MR. LaSALA: Thats all I have, sir.
8 Thank you.
9 THE WITNESS: Thank you.
10 THE VIDEOGRAPHER: Off the record at
11 12:09.
12 (Off the record.)
13 THE VIDEOGRAPHER: Back on the video
14 record at 12:10.
15 EXAMINATION
16 BY MR. McGRATH:
17 Q Mr. Skrabonja, Im Mike McGrath, and
18 I have a few questions for you.
19 (Off the record.)
20 THE VIDEOGRAPHER: Back on the record
21 at 12:11.
22 Q Mr. Skrabonja, Im Mike McGrath. I
23 have a few questions for you. I want to ask you
24 some questions about the Mercer Generating
25 Station.

121
1 A Mercer?
2 Q Right.
3 When you worked at Mercer, was that
4 an oil-fired plant or coal-fired?
5 A It was oil-fired, I think.
6 Q Okay. The same question for Sewaren,
7 when you were there, was it oil or coal?
8 A I think they were all coal up at that
9 end.
10 Q Okay. And just so its clear,
11 when--when you were at Bergen, was that oil or
12 coal?
13 A I think it was coal.
14 Q Okay. And Hudson, was that oil or
15 coal?
16 A I think that was all coal.
17 Q How about the Burlington station, was
18 that oil or coal?
19 A Burlington, I think they put a
20 gas-fire boiler in.
21 Q Okay. I hadnt even thought of
22 that. Okay.
23 A different kind of a question.
24 You told us about the boilers that
25 you worked on, and you--we had the diagram up

122
1 here, and I understood that.
2 Did you work on items at the Public
3 Service stations other than the boilers?
4 A No.
5 Q Okay. At any of the Public Service
6 stations that you were at, did you see any type of
7 conveyors?
8 A No. The only one I saw, dump coal,
9 was the Deepwater powerhouse.
10 Q Okay. At any of the Public Service
11 plants, did you ever work on any conveyors?
12 A No. Millwrights.
13 Q All right. Would you be near the
14 millwrights when they were working on the
15 conveyors?
16 A No.
17 Q Have you ever heard of a company
18 called United Conveyor Corporation?
19 A Ive heard of them, but I had nothing
20 to do with them.
21 Q Other than having heard the name, do
22 you know anything else about United Conveyor?
23 A No.
24 Q Now, if I understand you correctly,
25 the insulation work was done by a different trade,

123
1 not the boilermakers; is that correct? The new
2 materials going on.
3 A Going in, yeah.
4 Q You had to take off some of the old
5 material?
6 A Took it all out.
7 Q Okay.
8 A They put the brick in, and whatever,
9 and then we put cladding on it--
10 Q Okay.
11 A --sheet metal on the outside.
12 Q And you told us a couple times today
13 that you did not have anything to do with ordering
14 material--
15 A Right.
16 Q --is that right
17 A Right.
18 Q Did you ever unload trucks delivering
19 material?
20 A Big material, like stuff for the
21 stacks or tubes.
22 Q Did you ever unload any insulation
23 materials?
24 A No.
25 Q Nobody ever said, Hey, Ed, give us a

124
1 hand here, help us unload this stuff?
2 A Never did.
3 Q Okay. Different--different craft?
4 A Different craft.
5 Q Youre not supposed to be doing that?
6 A Insulators.
7 MR. McGRATH: Okay. Thats all the
8 questions I have. Thanks.
9 THE WITNESS: Okay. That was good.
10 THE VIDEOGRAPHER: Off the record at
11 12:14.
12 (Off the record.)
13 THE VIDEOGRAPHER: Back on the video
14 record at 12:15.
15 EXAMINATION
16 BY MR. JACKSON:
17 Q Good afternoon, sir. My name is
18 Damian Jackson. I have a few questions for you.
19 Okay?
20 A Go.
21 Q All right.
22 Are you familiar with a company
23 called Crane Company?
24 A Who?
25 Q Crane.

125
1 A No.
2 Q Okay. So you wouldnt attribute
3 anything from Crane as to attributing to your
4 asbestos exposure; is that correct?
5 A Right.
6 MR. JACKSON: Okay. Those are all
7 the questions I have for you, sir.
8 THE WITNESS: Good. That was better.
9 THE VIDEOGRAPHER: Off the record at
10 12:15.
11 (Off the record.)
12 THE VIDEOGRAPHER: Back on the video
13 record at 12:16.
14 EXAMINATION
15 BY MS. HARRIS:
16 Q Good afternoon, sir. My name is
17 Brandy Harris, and I have a couple questions for
18 you today.
19 Okay?
20 A Go.
21 Q Okay. Are you familiar with a
22 company by the name of Cleaver-Brooks?
23 A Beaver Brook?
24 Q Cleaver-Brooks.
25 A Cleaver-Brooks. Ive heard of it,

126
1 but Im not familiar with it too--too much.
2 Q Other than having heard of it, can
3 you tell me anything about Cleaver-Brooks?
4 A No.
5 Q Is it fair to say, then, that you
6 cant associate any exposure to asbestos from
7 Cleaver-Brooks?
8 A Right now, yes.
9 What do they do?
10 What are they?
11 Q In these Answers to Interrogatories,
12 Cleaver-Brooks is identified as a piece of
13 equipment.
14 A Okay.
15 Q Does that help you remember--
16 A Okay.
17 Q --Cleaver-Brooks?
18 A No. Thats all right. Its a piece
19 of equipment.
20 Q Does that change your testimony in
21 any way?
22 A No.
23 MS. HARRIS: Those are all the
24 questions I have for you. Thank you.
25 THE WITNESS: Good. Thank you.

127
1 THE VIDEOGRAPHER: Off the video
2 record at 12:17 p.m.
3 (Off the record.)
4 THE VIDEOGRAPHER: Were back on the
5 video record at 12:17 p.m.
6 EXAMINATION
7 BY MS. LYONS:
8 Q Good morning, sir. My name is Kristy
9 Lyons, Im from the law firm of Hoagland Longo,
10 and I just have a few questions for you.
11 Your daughter in--in her lawsuit had
12 answered questions called Answers to
13 Interrogatories.
14 Are you familiar with that term?
15 A No.
16 Q Okay. Its just questions and--and
17 answers that her attorneys would go over with her,
18 and--and she--she would answer the questions,
19 anywhere from her personal background to how she
20 believes she was exposed to asbestos.
21 Did you assist your daughter in
22 answering those Answers to Interrogatories?
23 A Yeah. Everything I brought home, she
24 was involved with.
25 Q Okay. But did you--did you help her

128
1 answer any of those questions?
2 Do you recall doing that?
3 A No.
4 Q Okay. You had testified previously
5 that you never ordered products. Correct?
6 A Whats this?
7 Q You never ordered products from--
8 A Never.
9 Q --companies?
10 A Right.
11 Q And you never unloaded trucks; is
12 that correct?
13 A Well, were talking about--yeah, I
14 unloaded trucks, but not--not with asbestos or
15 anything on them.
16 Q Okay. And did you ever go anywhere
17 to pick up supplies for your job site?
18 A No.
19 Q Okay. Are you familiar with a
20 company called W.W. Grainger?
21 A No.
22 Q Can you associate your exposure to
23 asbestos with W.W. Grainger?
24 A No.
25 Q Are you familiar with a company

129
1 called Goulds Pumps?
2 A No.
3 Q Can you associate your exposure to
4 asbestos with Goulds Pumps?
5 A No.
6 MS. LYONS: Thank you, sir. Thats
7 all I have.
8 THE WITNESS: Okay. Thank you.
9 MS. LYONS: Was that good?
10 THE WITNESS: That was good.
11 THE VIDEOGRAPHER: Off the video
12 record at 12:19.
13 (Off the record.)
14 THE VIDEOGRAPHER: Back on the video
15 record at 12:20.
16 EXAMINATION
17 BY MS. KIRKLAND:
18 Q Good afternoon. How are you?
19 A Im good.
20 Q Do you need to take a break before we
21 start?
22 A No. Im all right.
23 Q Okay. My name is Nadira Kirkland,
24 and I have to ask you about one company.
25 You had mentioned that you

130
1 encountered a Riley Stoker boiler at Hercules?
2 A Youll have to speak a little
3 louder.
4 Q Okay. You mentioned that you
5 encountered a Riley Stoker boiler at Hercules?
6 A No.
7 Did I?
8 I dont understand what youre--what
9 youre saying.
10 Q Okay. Do you know the name Riley
11 Stoker?
12 A Yes, Riley Stoker, yes.
13 Q What do you associate--what do you
14 associate the name Riley Stoker with?
15 A Come again?
16 Q Do you associate the name Riley
17 Stoker with any product or service?
18 A Boilers, Deepwater, I think they were
19 a Riley Stoker.
20 Q At where?
21 Im sorry.
22 A I think they were at Deepwater,
23 Deepwater power plant.
24 Q Did you work on the Riley Stoker
25 boiler at Deepwater?

131
1 A Yes.
2 Q Do you know how many Riley Stoker
3 boilers were at Deepwater power plant?
4 A I think the last one was five.
5 Q It was number five?
6 A It was five. Like I said before,
7 there was four in du Pont boiler. It was five.
8 Q How do you know the boiler that you
9 worked on at Deepwater was manufactured by Riley
10 Stoker?
11 A You look at the name tag on it.
12 Q Was the name Riley Stoker written on
13 the name tag?
14 A Yeah. You had a little plaque on
15 them.
16 Q Can you describe the dimensions of
17 this Riley Stoker boiler at the Deepwater power
18 plant?
19 A Are you--youre talking height?
20 Q Yes.
21 A Id say about six stories.
22 Q How about how wide, the width?
23 A What do we got here?
24 We got 50 foot, I guess. Theyre
25 all--theyre all alike.

132
1 Q Do you know how it was fueled or
2 fired?
3 A It was coal-fired. I know that
4 because it had a lot of trains of coal going in
5 there.
6 Q Do you know when was the first time
7 you worked on the Riley Stoker boiler at
8 Deepwater?
9 A No, I dont.
10 Q Do you know when was the last time
11 you worked on the Riley Stoker--
12 A I--
13 Q Just let me finish the question. I
14 know youre going to know where Im going with
15 these questions.
16 Do you know when was the last time
17 you worked on the Riley Stoker boiler at
18 Deepwater?
19 A No, I dont. Youre back in the 40s
20 on all this stuff.
21 Q Do you believe you worked on the
22 Riley Stoker boiler at Deepwater in the 40s?
23 A Well, sometime in around there. That
24 was--that was one of the easy jobs.
25 Q Can you recall what you did on the

133
1 Riley Stoker boiler?
2 A Do what?
3 Q Can you recall what you did on the
4 Riley Stoker boiler?
5 A Yeah. The floor repairs.
6 Q Was it repairs to the floor or
7 somewhere--
8 A Floor tubes and the floor itself. I
9 had to cut all the floor out, lancing it, rebuild
10 the floor.
11 Q You werent involved with the
12 installation of the Riley Stoker boiler; is that
13 correct?
14 A Right.
15 Q So the boiler was already there when
16 you went--
17 A Oh, yeah.
18 Q --to do the repair work?
19 A Yeah.
20 Q Do you believe--
21 A They were there about 50 years before
22 I got there. They were old ones.
23 Q Did you wear any gloves when you
24 worked on the Riley Stoker boiler?
25 A Yeah. Asbestos and leather.

134
1 Q Do you know who manufactured the
2 asbestos gloves that you wore?
3 A No, I dont.
4 Q How about the leather gloves? Do you
5 know who manufactured the leather glovers?
6 A No, I dont.
7 Q Did you wear any coveralls when you
8 worked on the Riley Stoker boiler at Deepwater?
9 A Just your own coveralls if
10 you--thats what you wore, coveralls.
11 Q But--but did you wear--
12 A There was nothing--
13 Q --coveralls?
14 A There was nothing given to you,
15 nothing issued.
16 Q Do you believe you were exposed to
17 asbestos while working on the Riley Stoker boiler
18 at Deepwater power plant?
19 A Oh, yeah.
20 Q How do you believe you were exposed
21 to asbestos?
22 A Hu?
23 Q How do you believe you were exposed
24 to asbestos?
25 A Well, when you lance a tube, you got

135
1 to use asbestos gloves, blanket because you got to
2 burn out the floor. Thats all fire comes back at
3 you.
4 Q Besides the gloves and blankets, do
5 you believe you were exposed to asbestos in any
6 other way while working on the Riley Stoker boiler
7 in--
8 A In the air.
9 Q --Deepwater?
10 A In the air.
11 Q Okay. Just--just ambient air?
12 A In the air.
13 Q Do you know who--strike that.
14 Do you know who manufactured the
15 blankets?
16 A No. I wish I knew. Id punch them
17 in the nose now.
18 Q Do you know how many times you worked
19 on the Riley Stoker boiler that you believe was at
20 Deepwater power plant?
21 A No. Two or three times,
22 diff--different years, different months.
23 Q Can you tell me a decade that you
24 would have worked on the Riley Stoker boiler that
25 you believe was at Deepwater power plant?

136
1 A Yeah.
2 Whats this?
3 Q Like a decade that you worked on the
4 Riley Stoker boiler at Deepwater.
5 A No, I dont.
6 Q Earlier today you testified that
7 there was a Riley Stoker boiler at Hercules.
8 Do you recall that testimony?
9 A Riley Stoker?
10 Q At Hercules.
11 A Yeah, in Pauls--in Gibbstown.
12 Q Do you know how many boilers were at
13 Hercules in Gibbstown?
14 A I think it was just one small one.
15 Q Can you give me the dimensions of
16 this Riley Stoker boiler that you believe was at
17 Hercules?
18 A Not really--
19 Q Was it--
20 A --no.
21 Q Was it around the same size as the
22 boiler that you described a few minutes ago being
23 at Deepwater?
24 A A little bit smaller.
25 Q A little smaller?

137
1 A Yeah. Most of these boilers are
2 pretty big.
3 Q Can you give me a decade when you
4 worked at Hercules on the Riley Stoker boiler?
5 A Do what?
6 Q A decade or time period.
7 MR. PLACITELLA: Do you understand
8 what shes asking?
9 Like was it the 50s or the 60s?
10 Thats what shes asking.
11 A The end of the 50s, beginning of the
12 60s.
13 Q Do you know how this boiler was fired
14 or fueled?
15 A I think that was an--an oil. Im not
16 sure.
17 Q Okay.
18 A I think most of the boilers was
19 mostly coal, I believe.
20 Q Do you know how many times you worked
21 on the Riley Stoker boiler at Hercules?
22 A Twice, I think.
23 Q Can you recall what you did on the
24 Riley Stoker boiler at Hercules?
25 A Yeah. We cut out the tubes. You cut

138
1 out the floor.
2 Q Anything else?
3 A Thats it. Thats all.
4 Q Okay. Do you believe you were
5 exposed to asbestos while working on the Riley
6 Stoker boiler at Hercules?
7 A Yes.
8 Q How do you believe you were exposed
9 to asbestos?
10 A I just said, gloves, blankets,
11 protection.
12 Q And you dont know who manufactured
13 the gloves; is that correct?
14 A No.
15 Q Okay. And you dont know who
16 manufactured the blankets; is that correct?
17 A No.
18 Q And you said protection.
19 What do you mean by protection?
20 A Gloves--
21 Q Okay.
22 A --leather sleeves, jackets, leather
23 jackets, stuff like that.
24 Q And the boiler that was at Hercules,
25 that was already in existence when you went to

139
1 repair it; is that correct?
2 A Yes.
3 Q Do you know the first time you would
4 have encountered the Riley Stoker boiler?
5 A No, I dont.
6 Q How about the last time?
7 A No.
8 Q If you had to add up the total time
9 that you spent working on the Riley Stoker boiler,
10 could you do that?
11 A A couple months, in and out.
12 MS. KIRKLAND: Thank you, sir. Those
13 are all the questions I have for you.
14 THE WITNESS: Thank you.
15 THE VIDEOGRAPHER: Off the video
16 record at 12:30.
17 (Off the record, followed by a
18 luncheon recess.)
19 THE VIDEOGRAPHER: Back on the video
20 record at 12:58.
21 EXAMINATION
22 BY MR. GRIES:
23 Q Good afternoon, sir.
24 How you doing?
25 A Good.

140
1 Q My name is Alan Gries, and I have
2 some questions for you as well.
3 Youve been talking for a couple of
4 hours this morning about different ways that you
5 believe you were exposed to asbestos. Correct?
6 A Uh-huh.
7 Q Are there any ways that you were
8 exposed to asbestos that we have not discussed
9 here this morning?
10 A No.
11 Q Did you ever do any automotive work
12 on your own vehicles?
13 A Yeah, but not--for myself, yes.
14 Q Okay. Do you believe any of that
15 work ever exposed you to asbestos?
16 A No.
17 Q No?
18 A No.
19 MR. GRIES: Okay. Thank you, sir.
20 THE WITNESS: All right.
21 THE VIDEOGRAPHER: Off the video
22 record at 12:59.
23 (Off the record.)
24 THE VIDEOGRAPHER: Back on the video
25 record at 1 p.m.

141
1 EXAMINATION
2 BY MR. COFFEY:
3 Q Good afternoon, sir. My name is Tom
4 Coffey, and I represent one of the defendants in
5 this case, du Pont, youve mentioned a couple of
6 times a couple of different ways.
7 The first time--thing I want to talk
8 to you about is when you were employed at the
9 Gibbstown--
10 A Gibbstown.
11 Q --facility, du Ponts Gibbstown
12 facility.
13 A Yeah.
14 Q During your previous deposition, you
15 mentioned that you worked there once for a couple
16 of weeks; is that correct?
17 A Yes.
18 Q Okay. And this was as a boilermaker
19 doing boiler work at work?
20 A Yeah.
21 Do you want me to tell you when I was
22 there?
23 When--when Kennedy was killed, thats
24 where I worked. And you got to remember them
25 things when you--that was something.

142
1 Q Was that at the end of your time at
2 Gibbstown?
3 A Yeah.
4 Q Okay. How long had you been there
5 for?
6 A A couple weeks.
7 Q In other words, you were employed
8 directly by du Pont on this project?
9 A Yes.
10 Q Did you have a foreman on the
11 project?
12 A Yes.
13 Q Who was it?
14 A Who was it. Who was it.
15 I dont know. They changed over so
16 many times, the boilermakers. I cant remember
17 his name.
18 Q During this project, did you wear a
19 uniform?
20 A No.
21 Q Did you wear your own personal
22 clothes?
23 A Whats this?
24 Q Did you wear your own personal
25 clothes?

143
1 A Yes.
2 Q Did du Pont provide you with any
3 guidelines on what clothing you could wear on
4 site?
5 A No. The only thing they said, no
6 matches, period.
7 Q No matches?
8 A No--no fire.
9 Q During this project, did you receive
10 any safety training?
11 A Not--no.
12 Q Was there a specific building that
13 you were working in at the Gibbstown plant?
14 A No. I was outside working on some
15 vessels, though.
16 Q Was--Im sorry.
17 A Go ahead.
18 Q Was all of the work out--outdoors?
19 A Yes.
20 Q Was there a locker room or a changing
21 room at the Gibbstown facility?
22 A No. Just the tool room.
23 Q Did you wear the same clothes only
24 where you worked?
25 A In and out.

144
1 Q Was this the only time you ever
2 worked at a du Pont facility?
3 A Do what?
4 Q Was this the only time that you
5 worked at a du Pont facility?
6 A Yes.
7 Q Did your union ever give you any
8 guidelines for what type of clothing you could
9 wear on a project?
10 A No.
11 Q What were you doing on these
12 vessels?
13 A Pulling trays out.
14 Q Is that--pulling the trays out, is
15 that similar to the work you described earlier
16 today at other sites?
17 A Uh-huh.
18 Q Were trays involved?
19 A Yeah, right.
20 Q Switch gears a little bit.
21 You mentioned a du Pont boiler at
22 a--at a powerhouse.
23 A Yeah.
24 Q And Im a little bit confused, so Im
25 going to try and get the benefit of your knowledge

145
1 and get a better understanding.
2 What did you mean that it was a du
3 Pont boiler?
4 A Well, it wasnt--not the name of
5 the--in other words, they--theres I think its
6 four or five down in Deepwater, and the fifth one
7 in there, it belongs to du Pont company, but the
8 powerhouse is operating it for them. They fire
9 up, and they send the steam over to the du Pont
10 company.
11 You with me?
12 Under the bridge here, you know where
13 the--
14 Q The Delaware Memorial Bridge?
15 A Yeah.
16 Q Is this on the--
17 A Thats the powerhouse right there on
18 the Jersey side. Its a du Pont-owned--they own
19 the boiler. But I dont know the name of the
20 boiler itself.
21 Q Whats the basis of your belief that
22 du Pont owned the boiler?
23 A Well, they supply--Public Service
24 maintained it, sent--fired up and sent steam over
25 to the plant, to their plant for operating.

146
1 Thats all. They--
2 Q So this boiler, it was dedicated to
3 providing power to the du Pont facility?
4 A Just the du Pont facility.
5 Q And you werent employed by du Pont
6 when you were providing maintenance on the du Pont
7 boiler?
8 A Do what?
9 Q Were you employed by du Pont when you
10 were doing maintenance on the du Pont boiler?
11 A No. Du Pont had their own
12 maintenance who was working for du Pont. Du
13 Ponts had their maintenance in Delaware,
14 Wilmington, Delaware. When there was work to be
15 done, they sent for people to work. But we was
16 under the du Pont supervision.
17 Q When you were working at the
18 powerhouse on the du Pont boiler, you were--
19 A No, no. Were--were talking about
20 Gibbstown.
21 Q Just--right now Im just talking
22 about at the powerhouse with the du Pont dedicated
23 boiler.
24 A Oh, okay. Go ahead.
25 Q Who were you employed by during that

147
1 time?
2 A I never worked on that one. You
3 asked me how many boilers there were, that were
4 there.
5 Q So you never worked on a du Pont
6 boiler, but it was there?
7 A No, not on that one, no, not on the
8 du Pont boiler.
9 Q I want now--I think that you were
10 starting to talk about the time when you were
11 working as part of a du Pont maintenance crew--
12 A Yeah.
13 Q --is that correct?
14 How many--
15 A Working for--
16 Q Go ahead.
17 A Well, maintenance people, their
18 office was in Wilmington, Delaware. All the
19 repairs they did, they went through their
20 maintenance people.
21 Q Earlier, you mentioned the Hercules
22 plant in Gibbstown and a refinery in Paulsboro.
23 Were there any other facilities that
24 you worked for while you were working for du
25 Ponts maintenance?

148
1 A No.
2 Q How long were you at Hercules
3 Gibbstown?
4 A A couple of weeks.
5 Q Was this only on one occasion?
6 A Yeah.
7 Q Did you have any kind of a uniform?
8 A No.
9 Q Was there anything identifiable on
10 you that identified you as a du Pont employee?
11 A Oh, yeah. You had a name tag.
12 Q And--go ahead.
13 A When you had a--when you had a
14 special--special job, they give you a plaque, you
15 had to put your name on it, that you was working
16 there, in that area.
17 Q What was on the name tag?
18 A My name.
19 Q Anything else?
20 A No.
21 Q Did it say du Pont on the name
22 tag?
23 A Yeah. Well, it was du--no. It was
24 a--they just put your name on it to let whoever
25 know who the foreman was, you know, if a du Pont

149
1 person asked you.
2 Q Besides your name, was there any
3 other information on the name tag?
4 A No.
5 Q You mentioned the placard that you
6 would put up next to you.
7 Besides your name, was there anything
8 on that?
9 A No.
10 Q Were you working as part of a crew at
11 the Gibbstown Hercules plant?
12 A Yeah.
13 Q How big of a crew was it?
14 A Well, it depends. Two, three, if you
15 needed five. If you was rigging, you needed
16 five. If was welding, you needed yourself.
17 Q So during those couple of weeks, it
18 varied from just being you to maybe being a
19 five-person crew?
20 A Yeah.
21 Q Was the entire crew part of du Pont
22 maintenance?
23 A No. They were--they were all Local
24 Union 28 people. You just work under du Pont
25 supervision. But the men come out of the hall,

150
1 the union hall.
2 Q Who paid you while you were working
3 at Hercules Gibbstown?
4 A Du Ponts maintenance.
5 Q So your check was cut by du Ponts?
6 A No. It had du Ponts maintenance on
7 it. You wasnt getting paid from the people in
8 Gibbstown. You were getting paid from the people
9 over in Wilmington, Delaware, their office, out of
10 that office.
11 Q Okay.
12 A They had their own people, engineers
13 and everything else down there.
14 Q Okay. Did you have a supervisor on
15 this project?
16 A Yeah. But dont ask me his name. I
17 cant remember his name. Yeah. He was like
18 supervision from their office in--in Delaware.
19 Q From du Pont maintenance?
20 A Yes.
21 Q While you were at Hercules Gibbstown,
22 did you wear the same clothes in and out?
23 A Uh-huh.
24 Q Was there a changing room available?
25 A You always had someplace available,

151
1 yes. But you had no showers or cleanup or
2 anything like that.
3 Q While at Gibbs--Hercules Gibbstown,
4 did you receive any safety training?
5 A Yeah. You had little meetings
6 before, what you could do and what you cant do,
7 and if you got on a ladder or you was burning.
8 Q Who ran those safety meetings at
9 Hercules Gibbstown?
10 A The foremen. They have a flier they
11 passed out.
12 Q Did you receive any safety training
13 or guidelines regarding what type of clothing you
14 could wear at Hercules Gibbstown?
15 A Uh-huh. The same thing, on the
16 fliers, let you know what you--you had to have
17 steel-toed shoes, and so on, no matches.
18 Q I know you were able to pinpoint for
19 me exactly when you were at du Ponts Rapano
20 facility in Gibbstown.
21 Are you able to tell me with any kind
22 of specificity when you were at Hercules
23 Gibbstown?
24 A No. But I tell you, you remember
25 when Kennedy got assassinated?

152
1 Well, thats where I was.
2 Now, what year was that?
3 Q November 1963.
4 A I remember exactly where I was
5 standing at the time.
6 So you remember that date?
7 Thats when I was there.
8 Q Was the Hercules Gibbstown project
9 before or after--
10 A I dont remember that.
11 Q Besides the work on the boiler at
12 Hercules Gibbstown, did you perform any other
13 work?
14 A No. Just vessel, open vessels.
15 THE WITNESS: That was your hammer
16 closing.
17 (The witness directed the last remark
18 to the videographer.)
19 Q Now, switching to the time at the
20 Paulsboro refinery.
21 A Yeah.
22 Q How many times did you work there for
23 du Pont maintenance?
24 A It wasnt ever--it wasnt
25 maintenance. It was new jobs, new work.

153
1 Everybody talks about the hoodray, thats one of
2 them, and the stack, and open up vessels.
3 Q How many times were you actually
4 employed by du Pont when you worked at the
5 Paulsboro refinery?
6 A I dont remember.
7 Q Do you remember if it was once, if it
8 was more than once?
9 A More than once.
10 Q Would your testimony regarding
11 uniforms and safety be the same at the Paulsboro
12 refinery as it was at Hercules Gibbstown?
13 A No. It would be a separate job,
14 different jobs, maybe a month later, maybe two
15 weeks later.
16 Q Earlier, you mentioned that your work
17 at the Paulsboro refinery was in the late 40s,
18 early 50s; is that correct?
19 A Uh-huh. Thats up.
20 Q When was the last time you worked at
21 the Paulsboro refinery while you were employed by
22 du Pont?
23 A I never connected them. Youre not
24 connecting du Ponts and Paulsboro. Paulsboro was
25 a different job.

154
1 Q So you never worked at the Paulsboro
2 refinery while you were employed by du Pont?
3 A Right.
4 Q And just so Im clear, the only time
5 you worked for du Pont maintenance was at the
6 Hercules Gibbstown plant?
7 A Right.
8 MR. COFFEY: Thank you for your
9 patience. I think thats all the questions
10 I have. Im going to take a--take a look at
11 my notes.
12 THE WITNESS: Thank you.
13 THE VIDEOGRAPHER: Off the video
14 record at 1:19.
15 (Off the record.)
16 THE VIDEOGRAPHER: Back on the video
17 record at 1:20.
18 EXAMINATION
19 BY MS. WEILL:
20 Q Good afternoon, sir. My name is
21 Elizabeth Weill. I represent one of the
22 defendants in this case.
23 You previously testified that there
24 was a Westinghouse turbine at one of your job
25 sites; is that correct?

155
1 A Deepwater powerhouse, Atlantic City
2 Electric.
3 Q Okay. There was a Westinghouse
4 turbine at the Deepwater--
5 A Yes.
6 Q --facility?
7 A Yeah.
8 Q And the Atlantic Electric, was that--
9 A Yeah.
10 Q --a separate facility?
11 A No. Thats the same thing--
12 Q Okay.
13 A --Deepwater and Atlantic City
14 Electric.
15 Q And--
16 A Theres four turbines down there.
17 Q Okay. There are four turbines--
18 A Yeah. I dont know whether theyre
19 all Westinghouse or not.
20 Q Okay. But its your--
21 A They were on a--they were on a
22 separate floor.
23 Q Sir, your testimony is that there was
24 one Westinghouse turbine there?
25 A Yeah, there was one, yes.

156
1 Q And how do you know that it was a
2 Westinghouse turbine?
3 A I talked to the people working there,
4 millwrights.
5 Q And, sir, what year--what time period
6 did you work at that location?
7 A What who?
8 Q Time period did you work at that
9 location?
10 A Oh, I dont--it was after, in the
11 50s, 60s, early.
12 Q Sir, other than at the Deepwater
13 power station, did you see a Westinghouse turbine
14 at any other facilities that you worked at?
15 A Did I see any other?
16 Yes, on the--on the power plant, on
17 the main floor.
18 Q Im sorry, sir. Other than at the
19 Deepwater power station--
20 A Yeah.
21 Q --the one we were just talking
22 about--
23 A Yeah.
24 Q --did you see a Westinghouse turbine
25 at any other job sites?

157
1 A No.
2 MS. WEILL: Okay. Thank you, sir. I
3 have no other questions.
4 A (Continuing) I didnt answer--I
5 didnt understand the question. Thats why I--
6 Q Okay. But now you understand.
7 A Yeah.
8 Q Other than Deepwater--
9 A Yeah, right.
10 Q --you did not see any Westinghouse
11 turbines at any other job sites; is that correct?
12 A Right.
13 MS. WEILL: Thank you.
14 THE VIDEOGRAPHER: Off the video
15 record at 1:22.
16 (Off the record.)
17 THE VIDEOGRAPHER: Back on the record
18 at 1:22.
19 EXAMINATION
20 BY MR. COLEMAN:
21 Q Good afternoon, Mr. Skrabonja. Im
22 Tom Coleman. I represent Garlock. I have some
23 questions. Well see how long I take.
24 I had a chance to look at your
25 previous testimony, and in reviewing that, it only

158
1 appeared that you associated Garlock with your
2 initial time at the Mobil facility.
3 Is that accurate?
4 MR. LaSALA: Thats not--
5 MR. PLACITELLA: Objection.
6 A No.
7 MR. PLACITELLA: Thats an unfair
8 statement.
9 A No. All--all the--all the--all the
10 places we worked and opened up vessels, Garlock
11 was a supplier for most of them.
12 Q When you say vessels, what do you
13 mean?
14 A Cigarette towers, the storage tanks,
15 they all had Garlock gaskets on them, on the
16 doorways. That was a big item in them days.
17 It seems to me that Garlock was
18 supplying blanket, too.
19 MR. COLEMAN: I move to strike the
20 nonresponsive portion.
21 Q Do you believe Garlock was a supplier
22 of products or a manufacturer of products?
23 A A sup--a supplier.
24 Q Did you see any trucks with the name
25 Garlock on it?

159
1 A No.
2 Q Did you unload any--
3 A But--
4 Q Im--Im sorry.
5 A Go ahead.
6 But Ive heard them order from
7 Garlock. Now, I thought that was a--that was just
8 a name you ordered through.
9 Q Okay.
10 A I dont believe they made it. Maybe
11 they did. I dont know. Its all gasket
12 material, Garlock.
13 Q Do you believe Garlock manufactured
14 any of the gasket material?
15 A Yeah, I think so, but Im not sure.
16 Q Okay. Do you believe that they both
17 manufactured and supplied the gasket material, or
18 one versus the other?
19 MR. PLACITELLA: Object to the form.
20 A I think they supplied.
21 Q Okay.
22 A You went right to the company.
23 Q Mr. Placitella and I both want to
24 make sure you understand the question and we
25 understand your answer.

160
1 Is it your testimony that Garlock
2 only supplied the gaskets?
3 MR. PLACITELLA: Thats not what he
4 said.
5 A No.
6 MR. PLACITELLA: Thats a
7 mischaracterization of what he just
8 testified to.
9 A No.
10 MR. COLEMAN: Hes saying both
11 things--
12 MR. PLACITELLA: Yeah, exactly--
13 MR. COLEMAN: --Chris. And then when
14 I--
15 MR. PLACITELLA: --they supplied and
16 they manufactured them.
17 MR. COLEMAN: And then when I asked
18 him...
19 Q Do you believe Garlock supplied the
20 gaskets?
21 A Thats who was shipping them in--
22 Q Okay.
23 A --Garlock.
24 Q Okay.
25 A But whether they made it or not, I

161
1 dont know.
2 Q Okay. Without guessing, can you tell
3 me if Garlock made any of the gaskets--
4 A I dont know.
5 Q --that you worked with?
6 Am I correct that you never did any
7 of the ordering of any Garlock gaskets?
8 A Right.
9 Q Do you associate any other product
10 with Garlock?
11 A Like Im saying, Im--Im kind of
12 thinking that the asbestos blanket was supplied by
13 them, too, or theyre--somehow theyre--I seem to
14 think theyre mixed together, Garlock and asbestos
15 blanket we was using. But I wouldnt put any
16 money on it.
17 Q Speaking about money, Im going to
18 take your chip away because its going like that
19 on the video.
20 A Good.
21 Q Did you ever order any Garlock
22 products?
23 A No, sir.
24 Q As a welder, did you have to
25 personally use any gasket material?

162
1 A Well, yes. When you--when you had to
2 do some welding around it, you had to scrape it
3 off out of the way around--around the manways and
4 stuff that it was sealing.
5 Q As a welder, did you ever have to
6 install any new gasket material?
7 A Yes.
8 Q Why would a welder install gasket
9 material?
10 A Well, I--I wasnt a welder on all
11 jobs. I was a mechanic on these jobs when they
12 were opening this.
13 Q Okay. So in the boilermakers union,
14 you were a welder and a mechanic?
15 A Thats right.
16 Q Any other--
17 A And I was a foreman, too.
18 Q Any other positions?
19 A Yeah. I run the Salem job for the
20 boilermakers.
21 Q Thats sometime in the mid-60s?
22 A The nuclear powerhouse, yes.
23 Q And I believe you said that there was
24 no asbestos used in the nuclear facility?
25 A I never seen it, not on the nuclear

163
1 part of it.
2 Q What--
3 A Maybe out--maybe out in the field.
4 They had other jobs in the field. But when you
5 worked in the reactor, there was nothing there.
6 Q What years did you work as a welder?
7 A As a welder?
8 Q Yes.
9 A From the time I got into the
10 boilermakers until 86, retired.
11 Q What years did you work as a
12 mechanic?
13 A In between all of them. The same
14 thing. It was either welding or mechanic.
15 Q And what years did you work as a
16 foreman?
17 A Where, on these other jobs or...
18 That powerhouse, I was there 10
19 years.
20 Q And thats Salem powerhouse?
21 A Thats right. Nuclear job.
22 Q So at--at Salem you were a foreman?
23 A Yes.
24 Q Prior to working at Salem in the
25 mid-60s, were you a foreman at any other time?

164
1 A Yes, on quite a few of them.
2 Q Did there come a point in time where
3 you were a foreman only?
4 A Only?
5 Q Yes.
6 A Yeah, at Salem.
7 Q Salem.
8 Prior to Salem, were you ever a
9 foreman only?
10 A No.
11 MR. PLACITELLA: Object to the form.
12 Q At any time prior to Salem, when you
13 were a foreman, would you do hands-on work?
14 A Do what?
15 Q Would you do hands-on work.
16 MR. PLACITELLA: Object to the form.
17 A Yeah.
18 Q So the foremens (sic) in the union
19 were working foremens?
20 A Not really. You help out or
21 something.
22 Q Some of them was--didnt come in--
23 A Yeah.
24 Q --or showed--or showed up late--
25 A Yeah.

165
1 Q --you would help out?
2 A Thats about it. But no hands-on if
3 youre a foreman.
4 Q You said when you were a mechanic,
5 you--you personally installed new gaskets.
6 Is that accurate?
7 A Yeah.
8 Q Okay. Im going to--Im going to go
9 back to when you were just doing welding work.
10 Besides scraping off some old
11 gaskets--
12 A Right.
13 Q --did you have any occasion to work
14 with gaskets in any other capacity?
15 A No.
16 Q Now, when you were a mechanic at any
17 point in time, besides installing new gaskets, did
18 you work with gaskets in any other capacity?
19 A No.
20 Q On any of the old gaskets that you
21 were removing, did you ever see any writing on
22 them?
23 A No.
24 Q On any of the new gaskets that you
25 were installing, did you ever see any writing on

166
1 them?
2 A There was writing on it, blue, but
3 I--I never took notice of what name was on it.
4 Most of it that we handled was Garlock made
5 special.
6 Q Was the writing blue or the gasket
7 blue?
8 A No. The gasket was white--
9 Q The gasket white--
10 A --with a stainless spring around some
11 of them to hold the gasket together.
12 Q And there was some writing on these
13 gaskets, and the--the color of the writing
14 itself--
15 A There was a stamp on the gasket that
16 youre using, but you dont read everything
17 you--you see. You wouldnt know it was a 14-inch
18 gasket or it was a 16-inch gasket or a 20-inch
19 gasket. Thats why they stamp it. So theres
20 writing on it somewhere or other on it.
21 Q And did the writing have to do with
22 the size of the gasket?
23 A Oh, yeah. You couldnt ask for a
24 20-inch gasket and put it on a 16-inch manway. So
25 you had to know--you had to know what youre

167
1 using.
2 Q I had a chance to look at your old
3 deposition transcript.
4 Besides using gaskets around
5 manways--
6 A Yeah.
7 Q --did you use gaskets in any other
8 type of equipment or anywhere else?
9 A No.
10 Q Now, you described these gaskets as
11 having a stainless ring around them?
12 A Yeah. Some of--
13 MR. PLACITELLA: He said some gaskets
14 had stainless--
15 A Some of them was metal--metal.
16 Special gaskets was on high pressure. They had a
17 stainless ring around them holding them together.
18 Q Im going to ask you some questions
19 about these gaskets with the stainless ring around
20 them.
21 A Yeah.
22 Q Was there a range of sizes?
23 A Yes. Uh-huh.
24 Q Can you tell me the range?
25 A Well, you had 16-inch manways. You

168
1 had 20-inch manways. You had different sizes.
2 Thats what you had to order. If youre putting a
3 new gasket on, you had to specify 20-inch gasket,
4 16-inch, 10-inch.
5 Q Can you tell me the smallest size and
6 the largest size of these--
7 A Well, when I--
8 Q --particular types?
9 A When I seen them, some of them was
10 like a six-inch tube coming out of the vessel, and
11 you had to put a gasket, a Garlock gasket in
12 there.
13 Q So six-inch was the smallest size?
14 A Thats the smallest I seen. Well, I
15 seen them smaller, but I dont know where.
16 Q Just with the gaskets with the
17 stainless ring them--
18 A Yeah.
19 Q --thats all I want to talk about
20 now.
21 So you remember six-inch gasket?
22 A Yeah.
23 Q Okay.
24 A Ive seen them smaller, too, for
25 smaller pipes, but I never handled them.

169
1 Q Okay.
2 A That was fitters work.
3 Q I just want to know the ones that you
4 handled or that you worked close to.
5 A Sixteen to 20 inch, 24.
6 Q Now, out--besides the size that had a
7 stainless ring around them, can you describe these
8 gaskets in any other way?
9 A Yeah. If you loused on them--loused
10 up on them, they all frayed, come apart.
11 Q What was that word?
12 A Frayed.
13 Q The other word.
14 Loused up?
15 A What are you--what are you talking
16 about?
17 Q What would cause the gaskets to
18 become frayed?
19 A Oh! Well, you--if you--if you drop
20 them or something, like you take a ring of rope
21 and you drop it, it started to come apart. Thats
22 what that one gasket would do.
23 Q Was this a preformed gasket?
24 A Well, it had to be made in a
25 factory.

170
1 Q Was there just a stainless ring
2 around the outside, or did the stainless ring--
3 A Yeah.
4 Q --cover the whole gasket?
5 A No. It was just around the outside.
6 Some of it was a piece of stainless ring, about a
7 quarter of an inch. Some of it was just--just
8 wrapped around it, little fine stuff, to hold it
9 together.
10 Q Now, you--you--
11 A It was made--thats made for a high
12 pressure.
13 Q Well get there.
14 Now, was this a rope-type product, or
15 was it more like a--a flat sheet?
16 A It was like a flat sheet.
17 Q Was there a range of thicknesses?
18 A Eighth of an inch.
19 Q Were they all around an eighth of an
20 inch?
21 A No. Some of them is thinner, some of
22 them is thicker.
23 Q Im just talking about the ones with
24 the stainless ring around them.
25 A Well, I just answered you.

171
1 Q Okay. I want to make sure youre--
2 A All sizes. All sizes.
3 Q I want to make sure youre--
4 A Well, youre--youre not listening.
5 Q Im listening.
6 A Yeah. Well, go ahead.
7 Q Were only talking about the
8 stainless gaskets.
9 A Yeah. Go ahead.
10 Q Some--some were smaller, bigger than
11 an eighth of an inch?
12 A What are we on that for? Because
13 its scare--because its asbestos?
14 Q We didnt get there yet.
15 Now--
16 A Christ!
17 Q --can you tell me how they felt?
18 A They felt cold in the wintertime.
19 Q Did they feel--
20 A Were getting a little silly now,
21 aint we?
22 Q No, were not.
23 A Yes, we are.
24 Q Do you know how they felt?
25 A Cold.

172
1 Q Okay. Were they smooth or slick?
2 A They were smooth.
3 Q Were they coarse or grainy?
4 A They was grainy.
5 Q Was one side slick and the other side
6 grainy?
7 A Right.
8 Q Or were certain gaskets all slick on
9 both sides and other gaskets were all grainy--
10 A Whatever you ordered.
11 Q --on both sides?
12 A Whatever was needed.
13 Q Okay. I--I--I dont want--I dont
14 want anything. I just want to know what you
15 remember.
16 A Go ahead.
17 Q Okay.
18 A What--what I remember, Im explaining
19 it to you.
20 Q Okay.
21 A Theyre all the same. For the big
22 one down to the little one, they were all made the
23 same--
24 Q Okay.
25 A --but only small sizes.

173
1 Q Thats fine.
2 A All right?
3 Q And how were they made?
4 A How the hell do I know made?
5 Theyre made with gasket material,
6 asbestos.
7 Q Do you know any other content of
8 these gaskets?
9 A No. These gaskets are all made up
10 special and sent on the job.
11 Q Where would you get them at the job?
12 A Warehouse.
13 Q Was that the unions warehouse or
14 whatever jobs warehouse?
15 A Whatever, whatever job.
16 Q Okay. So if you have Company Xs job
17 facility--
18 A Yeah.
19 Q --the company would actually provide
20 it?
21 A If you had to go to du Ponts and get
22 it out of their warehouse, thats where we went.
23 Q Did you see any of the original
24 packaging of these gaskets that had a stainless
25 ring around them?

174
1 A No.
2 Q Did you have to install any of the
3 gaskets with a stainless ring around them?
4 A Yes.
5 Q What would you have to do to install
6 a gasket with a stainless ring around it?
7 A If it was a high-pressure head,
8 thats what you had to put in. Wherever you had a
9 high-pressure head, a doorway or a pipe or
10 something, you took the--you took the door off,
11 and you had to put that on. It was for high
12 pressure.
13 Q I understand. You told me that the
14 gaskets for high pressure had a stainless ring
15 around them.
16 A Right.
17 Q I want to know how you installed
18 them.
19 A How you install them?
20 Q How did you personally install the
21 gaskets that had a stainless ring around them?
22 A Just pick it up and set it right
23 there on the door, and put a little piece of tape
24 to hold it up, and put the door on and put the
25 bolts on and close the hatch.

175
1 Q Was there any dust coming from the
2 gasket during that installation?
3 A No.
4 Q And how long did it take to pick the
5 gasket up and put it on the door and put the piece
6 of tape on it?
7 A It all depends on how fast you wanted
8 to work.
9 Q Fair enough.
10 If you wanted to work a normal pace,
11 how long would it take you?
12 A A couple minutes to put the--put the
13 gasket on, button the hatch up.
14 Q Do you associate Garlock with any of
15 these gaskets that had a stainless ring around
16 it?
17 A No, because I dont know the names of
18 them, who made them.
19 Q And why do you believe the gaskets
20 with a stainless ring around it contained
21 asbestos?
22 A Because thats the only thing that
23 would hold up. They wasnt the only one. Theyd
24 come in--theyd come in with just plain asbestos
25 gasket, no rings. And that was on the fire

176
1 doors. You didnt have a steel ring around it.
2 And they were made of asbestos.
3 MR. COLEMAN: I move to strike the
4 nonresponsive portions.
5 MR. PLACITELLA: It was very
6 responsive. You just didnt like the
7 answer.
8 Q Now, when I asked you why you believe
9 that those stainless ring gaskets contained
10 asbestos, you told me that thats the only thing
11 that would hold up.
12 Besides that answer, do you have any
13 other knowledge or information that those gaskets
14 that had the stainless ring contained asbestos?
15 A Well, I dont believe that its the
16 only thing that holds up. Thats the--thats what
17 it was called for, the safety regulations call
18 for, with a stainless steel ring around it for
19 high-steam, high-pressure pipe.
20 Now, if you put a piece of cardboard
21 in there or you put just a plain piece of regular
22 gasket, regular asbestos gasket, it would burn
23 out.
24 Q Okay. Whose safety regulations
25 called for that type of gasket?

177
1 A Well, the engineer. OSHA calls for a
2 lot of this stuff.
3 Q Now, you talked about gaskets that
4 did not have a steel ring around them. Correct?
5 A Yeah, right.
6 Q I want to ask some questions about
7 those.
8 Did you have an occasion to install
9 any gaskets that did not have a steel ring around
10 them?
11 A Yeah.
12 Q Do you know when the first time was?
13 A Whats this?
14 Q Do you know when the first time you
15 did that task?
16 A Yeah. Thats small--small boilers.
17 They have a little access door that you can take
18 off and go into. Every manway doorway had a
19 little piece of gasket in there, around it for a
20 seal.
21 Q Now, were these gaskets preformed?
22 A Yes.
23 Q Did these preformed gaskets have any
24 writing on them?
25 A No.

178
1 Q On any of these preformed gaskets,
2 did you see the original packaging that they came
3 in?
4 A I never seen any. I--I never handled
5 the packaging.
6 Q Since you never saw the original
7 packaging--
8 A No, because it went into the tool
9 room, and thats where we draw it out of.
10 Q Okay. Let me get my question out,
11 please.
12 Since you never saw the original
13 packaging and since there was never any writing on
14 these preformed gaskets, can you tell me who
15 manufactured any of those?
16 A No.
17 MR. PLACITELLA: Objection to the
18 form of your question.
19 He didnt say there was not writing.
20 He said he didnt see writing. Theres a
21 big difference.
22 Q Any of these preformed gaskets that
23 weve just talked about, can you tell me any of
24 the manufacturers of those?
25 A No.

179
1 Q Do you know one way or another
2 whether any of those gaskets contained asbestos?
3 A Most of them did, yes.
4 Q And why do you believe that most of
5 them contained asbestos?
6 A Because specs called for a--a fire
7 retardant, which would be asbestos.
8 Q Would they be the specs from the
9 boiler manufacturer?
10 MR. QUINN: Objection to form.
11 A From OSHA or the manufacturer of the
12 company who made the vessel, or whatever.
13 Q And when you say vessel, do you
14 also mean boiler?
15 A A tank.
16 Q A tank.
17 A Cigarette tower. Anything with a
18 manway in them.
19 Q Besides the gaskets that were used on
20 access doors for small boilers, did you personally
21 work with any other gasket that was used for any
22 other use?
23 A No.
24 Q Now, you also had occasion to remove
25 old gaskets?

180
1 A Right.
2 Q In any of the old gaskets you were
3 removing, did you know how long they were
4 installed?
5 A No. But when you--when you opened
6 them up, they usually was brown, and you had to
7 scrape them off, and they frayed.
8 Q Do you know the manufacturer of any
9 of the old gaskets that you actually removed?
10 A No, sir.
11 Q Do you know the manufacturer of any
12 old gaskets that were removed near you?
13 A No.
14 Q I guess I need to ask you some
15 questions about the blankets.
16 I believe you testified that you
17 think Garlock may have either supplied or made
18 them, but you would not put any money on it.
19 A Thats right.
20 Q I represent Garlock, and I am not
21 aware--
22 A I figured you was. You dont know
23 what youre talking about, for Christs sake.
24 Q I thought I--
25 A You dont--you dont understand

181
1 boilers. Thats--thats the only problem you
2 have.
3 Q Ive represented a lot of boiler
4 companies.
5 A Yeah, I know you did. But you never
6 worked on them and you dont know what the gasket
7 will do and what its for.
8 MR. PLACITELLA: All right. Lets--
9 A Thats all the questions youve been
10 asking me about.
11 Q I just want find out information,
12 thats all.
13 A For yourself--
14 Q Thats all.
15 A --not for your company.
16 Well, thats good. Youre learning.
17 Q Thats all I want to know.
18 A Youre learning.
19 MR. PLACITELLA: Okay, lets go.
20 Q Mr. Placitella will make sure things
21 go smoothly.
22 A Thanks.
23 Q Now, I represent Garlock. I am not
24 aware that Garlock ever manufactured or supplied
25 blankets.

182
1 A Well, thats what I said, I didnt
2 know.
3 Q Now--now, with that representation,
4 do you--do you know one way or another whether any
5 of the blankets you ever worked around were
6 actually manufactured or supplied by Garlock?
7 MR. PLACITELLA: Objection.
8 A No, I dont. The only--the only
9 thing, like Im saying, when we got asbestos rings
10 for the--the manways, close up manways, that was
11 all the same thing, so I figured one--one and
12 another.
13 Q Youre just making some assumptions?
14 A Thats all.
15 Like I said, if I find out who made
16 that asbestos blanket, Id punch them in the nose,
17 because that was a bad deal.
18 MR. PLACITELLA: I think he made the
19 blanket.
20 THE WITNESS: Id like to leave him
21 sleep under one of them one night.
22 MR. COLEMAN: He knows who made
23 them. Its not Garlock.
24 THE WITNESS: Thats all right. I
25 didnt say that they did. I assumed. Du

183
1 Pont says dont never assume.
2 You ever heard that from du Pont, did
3 you? Dont assume.
4 MR. COLEMAN: Theres a saying that
5 goes with assume.
6 MR. PLACITELLA: All right. You--you
7 guys could do this after.
8 Could we just finish the deposition?
9 Q Was your son Edward older than your
10 daughter Karen?
11 A No.
12 MR. COLEMAN: Okay. I think thats
13 all I have for now. I may have some
14 questions later if some other people ask
15 questions.
16 THE WITNESS: Okay.
17 MR. COLEMAN: Thank you.
18 THE WITNESS: Thank you.
19 THE VIDEOGRAPHER: Off the video
20 record at 1:53.
21 (Off the record.)
22 THE VIDEOGRAPHER: Back on the video
23 record at 1:54.
24
25

184
1 EXAMINATION
2 BY MS. FRANKEL:
3 Q Good afternoon. My name is Charone
4 Frankel. I did have a couple questions just for
5 the record about any substances you may have taken
6 in the last 12 hours.
7 Are you on any prescriptions that
8 youve taken today?
9 A No.
10 Q You have not taken any medicines
11 today?
12 A No.
13 Q Did you take any medicines before you
14 went to bed last night?
15 A Yes.
16 Q What did you take?
17 A I didnt take Viagra.
18 Theres a lot--I take a half a dozen
19 pills for my heart.
20 Q Do any of these medications ever
21 affect your memory?
22 A No. Its just going, age.
23 Q Me, too.
24 Have you consumed any alcohol in the
25 last 12 hours?

185
1 A Not for the last 12 years.
2 Q Is there any other reason why you
3 feel your memory or your understanding may somehow
4 be less than any other day?
5 A No.
6 Q Okay. I believe you mentioned
7 earlier that you used to work around certain
8 materials you described as refractory materials;
9 is that right?
10 A Was what?
11 Q You said refractory. I dont know if
12 that was your word or someone elses word.
13 MR. PLACITELLA: Refractory.
14 A Refractory, thats like a cement.
15 Thats just to seal up leaks in the--in the
16 boilers. Its--its heat resistant, most of it.
17 Q Was there just one type of refractory
18 material you used or more than one type?
19 A I really dont know. We only used
20 the one kind that I saw.
21 Q And what kind was that?
22 A Well, it looked look a mud, so you
23 could stuff it in the small spaces for...
24 Q Do you know who manufactured that
25 product?

186
1 A No.
2 Q Did you ever see any packaging of
3 that product?
4 A No.
5 Q I believe you also mentioned some
6 bricks.
7 A Some what?
8 Q Some bricks that you worked around.
9 A Fire brick.
10 Q Fire brick.
11 A Thats a heat-treated brick--
12 Q Okay.
13 A --for heat, thats all.
14 Q How many different types of fire
15 brick did you work with?
16 A I dont know whether if they changed
17 any one of the other. I worked around them.
18 Q Okay. So you would not be--
19 A I never handled them.
20 Q You did not handle.
21 A No.
22 Q Okay. Do you have any idea who
23 manufactured the fire bricks that you were
24 involved with?
25 A No, I dont.

187
1 Q Did they all look the same, to your
2 recollection?
3 A Yeah. Looked--some of them looked
4 like a regular house brick you stuff in the boiler
5 to keep the--keep the heat in. Thats all it is.
6 Q Were they all approximately the size
7 of a regular house brick?
8 A Yeah. Well, no. It all depended on
9 how--what--what you order.
10 Q So you recall bricks of different
11 sizes?
12 A Right.
13 Q Were they all the same color?
14 A Red, tan, from what I saw. I never
15 handled them. I had nothing to do with them.
16 Q So you never even removed the bricks?
17 A Yeah, tearing it out, thats all.
18 But going back was bricklayers or cement
19 finishers, whatever.
20 Q Did you tear out bricks at all your
21 jobs or just certain ones?
22 A No. Wherever--wherever they needed,
23 the fire walls or on the boilers, the flooring.
24 Q Do you know if any of those products
25 came from a company called Johns Manville?

188
1 A Yes.
2 Q Do you know which products?
3 A Some of them brick with Mansville
4 (sic).
5 Q And how do--how would you know if the
6 bricks came from Johns Manville?
7 A Because I know one of the fellow was
8 a supervisor worked out of a--out of an office for
9 Mansville. It was a personal friend. So I know
10 from talking to him.
11 Q So is that someone that supplied
12 materials to every place you worked?
13 A No. I never knew who ordered them or
14 when they was going to go in or what. They might
15 have stored them, brought some in and stored
16 them. Whatever we tore out, they had to rebuild,
17 thats all.
18 Q Were there certain workstations or
19 work sites where you knew that certain bricks came
20 from a company such as Johns Manville?
21 A Yeah. There was one in Gibbstown.
22 It was a muriatic acid plant.
23 Ever see a guy walk in that, muriatic
24 acid?
25 Soles come right off. They had to

189
1 get him a new pair of shoes.
2 Q So you say that was Gibbstown.
3 Was that a different Gibbstown than
4 the one youve been talking about?
5 A No. Its the same one.
6 Q Okay. The du Pont?
7 A Yeah.
8 Q Okay. Are there any locations where
9 you worked for the boilermakers union other than
10 what youve mentioned today, anything--
11 A The what?
12 Q Anyplace that you worked, any sites
13 that you havent mentioned yet today?
14 A No.
15 THE VIDEOGRAPHER: I have two minutes
16 left on the tape. I can change it now or
17 continue.
18 MS. FRANKEL: We can continue.
19 There was a question I had here
20 somewhere. Im sorry.
21 MR. LASH: You want him to change the
22 tape?
23 MS. FRANKEL: I dont think you have
24 to change the tape.
25 Q When you had your work clothes on,

190
1 would you have any contact with your daughter?
2 A Whats this?
3 Q When you would have your work clothes
4 on at home, did you have any contact with your
5 daughter?
6 A Yeah. A little hug once in a while.
7 Q When you say once in a while, would
8 that be every day or every week?
9 A Well, a couple times a week, at
10 least.
11 Q Did you say you worked at a point for
12 BMW?
13 A B & W.
14 Q B & W.
15 MR. PLACITELLA: B & W, Babcock &
16 Wilcox.
17 MS. FRANKEL: Okay. Good. Thats
18 what I thought.
19 THE WITNESS: That was down in
20 Deepwater.
21 MS. FRANKEL: Okay.
22 THE WITNESS: Okay.
23 MS. FRANKEL: I think thats all my
24 questions. Thank you so much.
25 THE WITNESS: Okay.

191
1 MR. PLACITELLA: Anybody else?
2 THE VIDEOGRAPHER: Off the record at
3 2:03 p.m.
4 (Off the record.)
5 THE VIDEOGRAPHER: Back on the video
6 record at 2:04.
7 FURTHER EXAMINATION
8 BY MR. PLACITELLA:
9 Q I just have a few follow-up
10 questions.
11 Is it your belief that Garlock
12 supplied the gaskets that went around the fire
13 doors?
14 A Around the what?
15 Q Is it your belief that Garlock
16 supplied the gaskets that went around the fire
17 doors? Is that your belief?
18 A From what I understand, yes.
19 Q Okay. Is it your belief that Garlock
20 supplied the gaskets that were removed from the
21 manways?
22 A That I couldnt say.
23 Q Okay. When you went to work at
24 Salem, was the Garlock gasket material continued
25 to be used after you worked there on the manways?

192
1 MR. COLEMAN: Object to form.
2 A No. I never had much to do down in
3 Salem.
4 Q Im--Im talking--
5 A The nuclear plant youre talking
6 about?
7 Q Right. Do you know at the nuclear
8 plant whether they used Garlock material at the--
9 A I think so.
10 Q Okay. And what would they use it
11 for?
12 A Manways and whatever.
13 Q Okay.
14 A It seems that they was the only one
15 that was supplying.
16 Q Okay. You talked about Deepwater,
17 work at Deepwater extensively.
18 In your prior deposition, you
19 indicated that you worked there in the 1960s.
20 Does that--does that refresh your
21 memory?
22 A Yes.
23 Q Okay. And you indicated in your
24 prior deposition that you worked on Riley Stoker
25 boilers while you were there.

193
1 A Yes.
2 Q All right. Did you come into contact
3 with insulation on the Riley Stoker boilers when
4 you did the work at Deepwater?
5 In other words, did you take
6 insulation out?
7 A Right.
8 Q Okay.
9 A Take the skin off, take the
10 insulation off.
11 Q Did you come into contact with
12 refractory material?
13 A Yes.
14 Q Did you get that on your clothing?
15 A Yes.
16 Q Okay. You talked about the Paulsboro
17 refinery, and Im--Im a little unclear on the
18 years.
19 Did you work at the Paulsboro
20 refinery after Karen was born?
21 A Yes.
22 Q Did you work at the Paulsboro
23 refinery before Karen was born?
24 A Yes.
25 Q Okay. In your prior deposition, you

194
1 indicated at the Paulsboro, the Mobil Paulsboro
2 refinery, you know that Foster Wheeler was a
3 contractor there.
4 A Yes.
5 Q Does--does that mean anything to you?
6 Do you recall them being there?
7 A No, I cant--I dont recall that.
8 Q As you sit here today, you cant
9 remember?
10 A Foster Wheeler.
11 Yeah, I think they--they worked on
12 the refractory, I think.
13 Q Okay. But thats as much as you can
14 remember.
15 A Thats about it.
16 Q In your prior deposition, when we
17 were talking about du Pont at Gibbstown, you
18 talked about working on a five-story high boiler.
19 Do you recall that?
20 A Yeah.
21 Q Okay. Did you work on a five-story
22 high boiler at Gibbstown?
23 A No.
24 Q Okay. You dont remember that
25 today?

195
1 A No, I dont.
2 Q Okay. When you worked on the Riley
3 Stoker boiler at--at Gibbstown, as you testified,
4 did you come into contact with insulation
5 products? Did you remove them?
6 A just the--yes.
7 Q Okay. Did you remove insulation
8 products, asbestos insulation products from the
9 Riley Stoker boiler at Gibbstown.
10 MS. KIRKLAND: Objection to form.
11 A No. I dont remember that.
12 Q You dont remember?
13 A No.
14 Q What--what did you--do you remember
15 what exactly you did on the Riley Stoker boilers
16 at Gibbstown?
17 A No.
18 Q You dont have a memory today?
19 Okay.
20 A There was so many in between.
21 Q Thats okay.
22 Did--you saw those brochures
23 that--that the lawyer for Foster Wheeler showed
24 you?
25 A No.

196
1 Q Did Foster Wheeler ever tell you what
2 it knew about the dangers of asbestos?
3 A No.
4 Q How about Garlock? Did Garlock ever
5 tell you that it was running experiments on
6 asbestos and health back in the 1940s?
7 A No.
8 MR. COLEMAN: Objection.
9 Q Is that something you wish you would
10 have been told?
11 A Yeah.
12 MR. PLACITELLA: Thats all the
13 question I have.
14 THE VIDEOGRAPHER: Off the video
15 record at 2:09.
16 (Off the record.)
17 THE VIDEOGRAPHER: Back on the video
18 record at 2:09.
19 FURTHER EXAMINATION
20 BY MR. QUINN:
21 Q Good afternoon, sir. This is Mike
22 Quinn again. We spoke earlier.
23 Are you okay to answer a few more
24 questions for me?
25 A Yeah. Go ahead.

197
1 Q I just want to ask you what Mr.
2 Placitella had asked you regarding refractory at
3 Paulsboro.
4 I believe you said you thought that
5 Foster Wheeler worked on the refractory--
6 A Yeah.
7 Q --at Paulsboro?
8 Do you know when this was?
9 A No, I dont.
10 Q Do you know if it was before or after
11 your daughter was born?
12 A Oh, yeah. No. Before.
13 Q It was before your daughter was
14 born.
15 A Yeah, right.
16 Q Okay.
17 A It was one of the early jobs as a
18 boilermaker.
19 Q Okay. And--and at this time on that
20 job were you employed by Foster Wheeler?
21 A The what?
22 Q Were you working for Foster Wheeler
23 when you saw them working on the refractory at
24 Paulsboro?
25 A Yeah, I think so.

198
1 Q Okay. Do you know--did you see that
2 refractory material come packaged at Paulsboro?
3 A No.
4 Q So do you know one way or the other
5 whether that refractory contained asbestos at
6 Paulsboro?
7 A No.
8 MR. QUINN: Thanks. Thats all I
9 have, sir.
10 THE WITNESS: Okay.
11 THE VIDEOGRAPHER: Off the video
12 record at 2:10.
13 (Off the record.)
14 THE VIDEOGRAPHER: Back on the video
15 record at 2:11.
16 FURTHER EXAMINATION
17 BY MS. KIRKLAND:
18 Q Good afternoon, sir.
19 How are you?
20 A Getting tired.
21 Q Do you want to take a break?
22 A No.
23 Q I just have to ask you a few
24 follow-up questions.
25 When Mr. Placitella was asking you

199
1 questions about the Riley Stoker boiler at
2 Deepwater--
3 A Yeah.
4 Q --you testified that you took out
5 insulation; is that correct?
6 A Yeah.
7 Q Do you--strike that.
8 Were you there when the
9 installation--insulation was installed on the
10 Riley Stoker boiler?
11 A No.
12 Q Do you know the manufacturer--
13 A Well, I was there when somebody else
14 was putting it back--
15 Q Okay.
16 A --because we had to close the boiler
17 up with steel.
18 Q Okay. But the insulation that you
19 were taking out when--the insulation that you were
20 removing, do you know who installed that
21 insulation?
22 A No, maam.
23 Q Do you know who manufactured that
24 insulation?
25 A No.

200
1 Q Do you know if it was original to the
2 boiler?
3 A I dont know. They were pretty old
4 boilers.
5 Q But do you know if the insulation was
6 original to the boiler?
7 A No.
8 Q Okay. And now the refractory
9 material that you testified that you took out from
10 the Riley Stoker boiler at Deepwater, do you know
11 who manufactured the refractory material?
12 A No.
13 Q Do you know when it was installed?
14 Prior to you removing it, do you know
15 when it was installed?
16 A No.
17 Q Do you know if it was original to the
18 boiler?
19 A It might have been.
20 Q How do you know that?
21 A Well, if the--the boilers was pretty
22 old and they was never--they were never repaired
23 that I know of.
24 Q Do you know the repair
25 history--strike that.

201
1 Can you recall the repair history of
2 the Riley Stoker boiler at Deepwater?
3 A No.
4 MS. KIRKLAND: Thank you, sir. Those
5 are all the questions I have for you.
6 THE VIDEOGRAPHER: Off the video
7 record at 2:12.
8 (Off the record.)
9 THE VIDEOGRAPHER: Back on the video
10 record at 2:13.
11 FURTHER EXAMINATION
12 BY MR. COLEMAN:
13 Q Good afternoon, Mr. Skrabonja. Im
14 Tom Coleman again. I have a few follow-up
15 questions regarding Garlock. Im going to try and
16 go as quick as possible.
17 Mr. Placitella asked you if you
18 continued using Garlock gaskets at Salem, and you
19 said no, that you personally used?
20 A No.
21 Q And you also told us earlier before
22 that you dont believe that theres any asbestos
23 used on the nuclear site--
24 A Right.
25 Q --at Salem.

202
1 And is that where you worked at
2 Salem, on the nuclear site?
3 A Yes, sir. I worked on the whole
4 plant, inside the react--inside the vessel and out
5 in the field.
6 Q Did you ever work with your
7 brother-in-law down at Salem--
8 A Did I--
9 Q --or your son-in-law at Salem?
10 A Yes.
11 Q What years did you work with him?
12 A 60s, late 60s.
13 Q Did he work there until you retired
14 in the mid-80s?
15 A Yes.
16 Q What did he do down at Salem?
17 A He was a foreman part-time, welder
18 part-time.
19 Q Was welding his trade?
20 A Yeah, he was welding.
21 Q Mr. Placitella--tella asked you about
22 gaskets used around fire doors. I want to ask you
23 some questions about those gaskets.
24 Did those gaskets have the stainless
25 steel ring around them?

203
1 A No.
2 Q What range of sizes did those gaskets
3 come in?
4 A Well, you had a 16-inch manway, you
5 had a 20-inch manway, and you had openings,
6 different openings, like a 24-inch opening, so a
7 man could crawl through them to get into the
8 vessel.
9 Q Im not sure if I heard the first
10 size, but I believe you said 16-inch?
11 A Yeah, 16, 20s. It all depended on
12 how big the--the opening was.
13 Q Now, were these gaskets also
14 preformed?
15 A Yes.
16 Q Were they roughly about an eighth of
17 an inch thick?
18 A Well, some of them come pretty
19 thick.
20 Q And youre describing quarter inch or
21 a half-inch?
22 A No, no, no. Theyre about
23 three-sixteenths, one-eighth, three-sixteenths, or
24 whatever. But they were all formed. Ordered them
25 that way.

204
1 Q Did you install those?
2 A I--I installed them, yeah.
3 Q How long would it take to install one
4 of these preformed fire door gaskets?
5 A If you get right on it, about
6 a--about a half-hour.
7 Q And--
8 A When youre opening the doors and
9 closing the doors or cleaning, you got to clean
10 the gaskets off.
11 Q So the whole process, opening it up--
12 A The whole process maybe would take an
13 hour or so.
14 Q Okay. The new gasket, how long would
15 it take you to install the new gasket?
16 A Can you blink fast?
17 Thats it.
18 Q Thats fine.
19 Was installing the new gasket a dusty
20 process?
21 A Hu?
22 Q Was installing the new gasket a dusty
23 process?
24 A A little. But taking the old one off
25 was.

205
1 Q Well get there.
2 A Okay.
3 Q The new gasket.
4 A No.
5 Q Was there--you--you said not a dusty
6 pros--a dusty process.
7 Was there any writing or identifying
8 marks on any of the new gaskets used for these
9 fire doors?
10 A No.
11 Q Did you see any of the original
12 packaging that the new gaskets came in--
13 A No.
14 Q --for these fire doors?
15 Do you know the manufacturer of any
16 of the old gaskets that had to be removed--
17 A No.
18 Q --on these fire doors?
19 A No.
20 Q Can you tell me how these fire door
21 gaskets felt when you touched them?
22 A Rough.
23 Q Rough on both sides or one side?
24 A Yeah, like--like rope on the
25 outside. They were rough.

206
1 Q Did they feel like theyre--
2 A The plain asbestos gasket, it was
3 just a wrapped gasket.
4 Q And what color were they?
5 A White.
6 Q Do you know one way or another
7 whether these gaskets contained asbestos?
8 MR. PLACITELLA: Objection.
9 A Thats what they looked like, yes.
10 Q They looked--
11 A It was asbestos gaskets, yes.
12 Q Okay. Why do you believe they were
13 asbestos gaskets?
14 A Well, I know what it looked like, and
15 I know what they ordered.
16 Q Okay. Did you see any writing
17 indicating that they contained asbestos?
18 A No.
19 Q Besides asbestos, what other
20 component parts were made into these gaskets?
21 A None that I know of, not on fire
22 doors or anything hot.
23 Q Now, in answering one of Mr.
24 Placitellas questions, you believed that Garlock
25 supplied gaskets for these fire doors from what

207
1 you understood.
2 My question is, what information did
3 you have that led you to believe that those were
4 supplied by Garlock?
5 A Well, the way I heard from people
6 talking, that the super on the job would order,
7 and theyd say theyre coming in, gasket
8 material.
9 Q Did they say gasket material or
10 specified Garlock--
11 A Garlock.
12 Q --gasket material?
13 A You heard--you heard Garlock. No
14 matter where you went, you heard Garlock.
15 Q Were you hearing Mr. Garlocks name--
16 A No. It was--
17 Q --the supervisor?
18 A No. It was your name, Garlock
19 gaskets.
20 Q Okay. Now, this is 40 to 50 years
21 ago?
22 A It could be a hundred years ago, Id
23 still remember it.
24 Q Im trying to figure out what you
25 remember. You told us earlier that your memory is

208
1 not as good today as it was in 98.
2 MR. PLACITELLA: You know what--you
3 know what, sir--
4 A Look, you want to get into an
5 argument with this, Im going to walk out of here.
6 MR. PLACITELLA: Im cutting the dep
7 off.
8 Ask him a question, or lets stop.
9 A Youre picking, picking, picking.
10 Youre not asking nothing. Youre not asking
11 nothing.
12 Q Im asking questions.
13 MR. PLACITELLA: All right. Were
14 going to take a--
15 A You aint asking nothing.
16 MR. PLACITELLA: How many--how many
17 questions do you have left?
18 MR. COLEMAN: I dont have much.
19 MR. PLACITELLA: Well, then, just ask
20 him a question and stop--
21 MR. COLEMAN: Im trying to.
22 MR. PLACITELLA: No, youre not.
23 MR. COLEMAN: Im not trying to fight
24 with him.
25 A What the hell are you asking me?

209
1 What are you asking me?
2 Q Im not trying to fight with you,
3 sir.
4 A What are you asking me?
5 MR. PLACITELLA: Hes got a heart
6 condition. Just ask him the question.
7 Okay? Hes got a sick daughter and a heart
8 condition. Ask him the question.
9 A You just dont want Garlock to pay
10 for anything is what youre doing.
11 Q I only have a few more questions,
12 sir.
13 Are you okay to continue?
14 A Oh, youre pretty smooth, you are.
15 Come on. Ask them. Lets get the
16 hell out of here.
17 Q Besides people talking about the
18 gaskets being supplied by Garlock--
19 A No, I dont know what they ordered,
20 but I seen invoices come in with Garlock gasket.
21 Q Can I finish my question?
22 A Okay?
23 Q Besides people talking about Garlock
24 supplying gaskets, do you have any other
25 information to believe that any of the gaskets

210
1 were manufactured or supplied by Garlock?
2 MR. PLACITELLA: He just said to you
3 that he saw invoices with the name on it.
4 A No, I dont.
5 MR. COLEMAN: There wasnt a question
6 pending.
7 Q Now, before a question was asked, and
8 you mentioned about invoices. Okay?
9 A Yeah.
10 Q When did you have an occasion
11 to--to--
12 A When I went to the warehouse to get
13 some out.
14 Q And there was invoices in there?
15 A No. I talked to the man that
16 supplied them--
17 Q Okay.
18 A --to hand them out, the tool room
19 man.
20 Q Any other reason besides talking to
21 the tool room man?
22 A Oh, Im done. Im done. Youre
23 not--youre not asking a damn thing, Buddy.
24 Q Im--Im asking--
25 A No, youre not.

211
1 Q --the last, possibly the last
2 question.
3 A You aint asking a damn thing.
4 MR. PLACITELLA: Why dont we--
5 A How do I know. How do I know. How
6 do I know.
7 MR. PLACITELLA: Why dont we take a
8 break.
9 That was the last question?
10 MR. COLEMAN: That was the last
11 question--
12 MR. PLACITELLA: That was the last
13 question.
14 MR. COLEMAN: --any other reason--
15 A Where do I live?
16 MR. COLEMAN: --besides what the man
17 said.
18 A Where I do live? Where I do live?
19 Do you know where I live?
20 MR. PLACITELLA: Do you have any
21 questions pending?
22 MR. COLEMAN: There was one.
23 A Do you know where I live?
24 Q Bellmawr.
25 A Where at?

212
1 Do you know the house?
2 MR. PLACITELLA: Do you have a
3 question for him?
4 Whats your question?
5 MR. COLEMAN: I--I asked him was
6 there--besides the gentleman telling you in
7 the tool room, was there any other reason,
8 and then he sort of answered it.
9 MR. PLACITELLA: Mr. Skrabonja, other
10 than anything youve already said about
11 Garlock, do you have any other information?
12 THE WITNESS: No, I dont.
13 MR. COLEMAN: Thank you, sir.
14 THE WITNESS: Cute.
15 THE VIDEOGRAPHER: Off the video
16 record at 2:22.
17 (The videotape deposition of Edward
18 Skrabonja concluded at 2:22 p.m.)
19
20
21
22
23
24
25

213
1 C E R T I F I C A T E
2 I, EDWIN SILVER (Certificate No.
3 XI00379), Certified Court Reporter and Notary
4 Public of the State of New Jersey, do hereby
5 certify that prior to the commencement of the
6 examination EDWARD SKRABONJA was duly sworn by me
7 to testify the truth, the whole truth and nothing
8 but the truth.
9 I DO FURTHER CERTIFY that the
10 foregoing is a true and accurate transcript of the
11 testimony as taken stenographically by and before
12 me at the time, place and on the date hereinbefore
13 set forth.
14 I DO FURTHER CERTIFY that I am
15 neither a relative nor employee nor attorney nor
16 counsel of any of the parties to this action, and
17 that I am neither a relative nor employee of such
18 attorney or counsel, and that I am not financially
19 interested in the action.
20
21
22 ----------------------------------------
23 Notary Public of the State of New Jersey
24 My Commission expires January 12, 2013
25 Dated: December 12, 2009