FILED: ERIE COUNTY CLERK 02/24/ :21 PM INDEX NO /2016 NYSCEF DOC. NO. 55 RECEIVED NYSCEF: 02/24/2017. Exhibit G

Transcription

1 Exhibit G

2 HOWARD MUNSCHAUER STATE OF NEW YORK SUPREME COURT : COUNTY OF ERIE HOWARD E. MUNSCHAUER, Plaintiff, - vs - Index No. 0/0 SOUTH BUFFALO RAILWAY COMPANY, c/o CT Corporation System, BEAZER EAST, INC., f/k/a KOPPERS COMPANY, INC. f/k/a THIEM CORPORATION in its own right and as successor in interest to UNIVERSAL REFRACTORIES, INC., c/o Corporation Service Company, CBS CORPORATION f/k/a VIACOM INC., successor by merger to CBS CORPORATION f/k/a WESTINGHOUSE ELECTRIC CORPORATION, FERRO ENGINEERING DIVISION OF ON MARINE SERVICES COMPANY, LLC c/o National Registered Agents, Inc., FOSECO, INC., c/o CT Corporation System, FRONTIER INSULATION CONTRACTORS, INC., f/k/a FRONTIER INSULATION AND ASBESTOS, INC., GENERAL ELECTRIC COMPANY, GRINNELL LLC, c/o The Corporation Trust Company, HONEYWELL INTERNATIONAL INC., f/k/a ALLIEDSIGNAL, INC., as successor in interest to THE BENDIX CORPORATION, c/o Corporation Service Company, INDUSTRIAL INSULATION SALES, INC., INSUL COMPANY, INC., INSULATION DISTRIBUTORS, INC.,

3 ITT CORPORATION f/k/a ITT INDUSTRIES, INC., individually and as successor to ITT FLUID PRODUCTS CORP. ITT HOFFMAN ITT BELL & GOSSETT COMPANY and ITT MARLOW, c/o CT Corporation System, NIAGARA INSULATIONS, INC., f/k/a NIAGARA ASBESTOS CO., INC., UNION CARBIDE CORPORATION, c/o CT Corporation System, Defendants Examination before trial of HOWARD MUNSCHAUER, Plaintiff, taken pursuant to Notice under Article of the Civil Practice Law and Rules, in the offices of JACK W. HUNT & ASSOCIATES, INC.,, Buffalo, New York, on July, 0, commencing at :0 a.m., before LYNN MYERS, Notary Public. 0 APPEARANCES: LIPSITZ & PONTERIO, LLC, By MATTHEW J. MORTON, ESQ., Delaware Avenue, th Floor, Buffalo, New York 0, () -00, mjm@lipsitzponterio.com, Appearing for the Plaintiff.

4 FLYNN WIRKUS YOUNG, P.C., By SCOTT R. ORNDOFF, ESQ., Delaware Avenue, Suite, Buffalo, New York 0, () -, Appearing for the Defendant, South Buffalo Railway Company, c/o CT Corporation System. WARD GREENBERG HELLER & REIDY LLP, By SCOTT R. JENNETTE, ESQ., 0 Bausch & Lomb Place, Rochester, New York 0, () -000, sjennette@wardgreenberg.com, Appearing for the Defendant, Beazer East, Inc., f/k/a Koppers Company, Inc. f/k/a Thiem Corporation in its own right and as successor in interest to Universal Refractories, Inc., c/o Corporation Service Company. BARCLAY DAMON LLP, By DANIELLE M. CARDAMONE, ESQ., The Avant Building, 00 Delaware Avenue, Suite 00, Buffalo, New York 0, () -00, dcardamone@barclaydamon.com, Appearing for the Defendant, Ferro Engineering Division of on Marine Services Company, LLC c/o National Registered Agents, Inc. 0

5 0 MARIN GOODMAN, LLP, By RICHARD P. MARIN, ESQ., 00 Mamaroneck Avenue, Suite 0, Harrison, New York, () -, Appearing for the Defendant, Foseco, Inc., c/o CT Corporation System, via telephone. GOLDBERG SEGALLA LLP, By JASON A. BOTTICELLI, ESQ., Main Street, Suite 00, Buffalo, New York 0, () -00, Appearing for the Defendants, Frontier Insulation Contractors, Inc., f/k/a Frontier Insulation and Asbestos, Inc., and Industrial Insulation Sales, Inc. SEDGWICK LLP, By WILLIAM T. MIEDEL, ESQ., Raymond Boulevard, th Floor, Newark, New Jersey 0-, () -000, Appearing for the Defendant, CBS Corporation f/k/a Viacom Inc., successor by merger to CBS Corporation f/k/a Westinghouse Electric Corporation and General Electric Company. ZIMMER KUNZ PLLC, By RYAN A. ZELI, ESQ., Grant Street, Suite 000, Pittsburgh, Pennsylvania, () -000, Appearing for the Defendant, Insul Company, Inc.

6 0 BARCLAY DAMON LLP, By CAROL G. SNIDER, ESQ., The Avant Building, 00 Delaware Avenue, Suite 00, Buffalo, New York 0, () -00, Appearing for the Defendant, Insulation Distributors, Inc. MORGAN, LEWIS & BOCKIUS, LLP, By JOHN M. VASSOS, ESQ., 00 Louisiana Street, Suite 000, Houston, Texas 00, () 0-0 Appearing for the Defendant, ITT Corporation f/k/a ITT Industries, Inc., individually and as successor to ITT Fluid Products Corp. ITT Hoffman, ITT Bell & Gossett Company and ITT Marlow, c/o CT Corporation System, via telephone. LEWIS BRISBOIS BISGAARD & SMITH LLP, By KIP J. ADAMS, ESQ., One International Place, Third Floor, Boston, Massachusetts 0 () -, kip.adams@lewisbrisbois.com, Appearing for the Defendant, Niagara Insulations, Inc., f/k/a Niagara Asbestos Co., Inc. SMITH, MURPHY & SCHOEPPERLE, LLP, By LYNN D. GATES, ESQ., Ellicott Square Building, Buffalo, New York 0, () -, gates@smithmurphy.com, Appearing for the Defendant, Union Carbide Corporation.

7 (STIPULATIONS: Waive filing and signing of the transcript, waive Oath of the Referee, reserve all objections until trial, with exception of objections as to form, an objection by one defense attorney deemed to be an objection by all.) :0: H O W A R D M U N S C H A U E R, Rossler :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0:00 :0:0 :0:0 0 Avenue, Cheektowaga, New York 0, after being duly called and sworn, testified as follows: EXAMINATION BY MS. SNIDER: Q. Good morning, Mr. Munschauer. A. Good morning. Q. I introduced myself a few minutes ago off the record, but I'll do so again on the record. My name is Carol Snider. I'm an attorney with the law firm of Barclay Damon here in Buffalo, New York, and I'll be the first attorney asking you questions today. A. Okay. Q. I am sure there'll be attorneys asking

8 Munschauer - Snider - // :0:0 :0:0 :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: 0 you a number of questions after me, I just get to be first up to bat, as the saying goes. A. Okay. Q. If at any time I ask you a question, you don't understand my question, or you didn't hear me, or if you just would like me to repeat it or rephrase it, please let me know that, okay? A. Okay. Q. That same instruction is going to apply with all the other attorneys here today as well. A. Okay. Q. Secondly, this is not a marathon, okay. If you need a break, even if it's just for two minutes or if it's for 0 minutes, you have to let me know that, okay? A. Okay. Q. You're in charge of when we start and when we stop, other than your attorney, okay? A. Okay. Q. We have a court reporter here, and the purpose of the court reporter is so that she can take down everything that I say and everything that you say.

9 Munschauer - Snider - // :0: :0: :0: :0: :0:0 :0:0 :0:0 :0: :0: :0: :0: :0: :0: :0:0 :0: :0: :0: :0: :0: :0: :0: :0: :0: 0 A. Okay. Q. So it's very important that I let you finish your answer before I start to talk because, otherwise, we're talking on top of one another and she'll have a difficult time accurately recording what is being said. But it's also equally important that you wait for me to get out my full question before you say anything, for two reasons: One, obviously she needs to take down what my question is before you start to talk, but also you may think you know what I'm asking but I don't want you to give a wrong answer because my question was going to be different. Fair enough? A. Fair enough. Q. Also, the court reporter can only take down words, they can't take down gestures, nods of the head. So if you tell me that something was as far away as to the end of the room, that may be fine for me but it's not gonna work when somebody reads this transcript in six months, okay? A. I understand.

10 Munschauer - Snider - // :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0:0 :0:0 :0:0 :0:0 :0: :0: :0: 0 (A recess was then taken.) BY MS. SNIDER: Q. Mr. Munschauer, back on the record. I just have some general background questions. Before you came here today to testify, did you take any medication? Q. What have you taken so far today? A. Spiriva and Metformin. Q. Anything else? Q. Do you think either of those medications are going to affect your ability to give testimony? Q. If you take any additional medications today, will you let us know that? Q. Before coming here today, did you read any documentation, look at any records, picture books, photographs, view any videos in order to prepare for this deposition today?

11 Munschauer - Snider - // :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: Q. Did you do any computer research regarding Bethlehem Steel, railroads, or asbestos before coming here today? Q. Did you talk to anyone about your testimony other than your counsel or someone from your counsel's office? Q. Sir, I want to mark this as Exhibit A for identification. It's going to be Munschauer A for identification. The following was marked for Identification: :0: MUNSCHAUER EXH. A Plaintiff's Verified :0: Answers to Interrogatories :0: :0: :0: :0: :0: :0: :0: :0:0 :0: 0 BY MS. SNIDER: Q. Mr. Munschauer, I'm going to show you what's been marked as exhibit -- Munschauer Exhibit A for identification. It's a document entitled Plaintiff's Verified Answers to Interrogatories, and it has your name on it. Do you see that document? A. Oh, yes. Q. And it says right here, Plaintiff's

12 Munschauer - Snider - // :0: :0: :0: :0:0 :0: :0: :0: :0: :0: :0: :0: :0: :0: ::00 ::0 ::0 ::0 :: :: ::0 :: :: :: 0 Verified Answers to Interrogatories. Q. Have you seen this document, to your recollection, before my showing it to you right now? Q. Okay. I want to show you the last page of this document, it's a document entitled verification, and it has your name on it there also. And it has a signature above that name, is that your signature? A. Yes, it is. Q. Okay. Do you remember meeting with your attorney, Mr. Morton, and signing this document? A. If that's my signature, I met with him. Yeah, because that is my signature. Q. Okay. Do you have a recollection of reading all pages of this document before you signed it? Q. I have some information, background information I'm going to try to go over quickly

13 Munschauer - Snider - // :: :: :: :: ::0 :: :: :: :: ::0 :: :: :: :: :: :: ::0 :: :: :: :: :: :: 0 just to confirm that the information I have is correct, okay? Is your date of birth September rd,? A. That's correct. Q. And what's your age? A.. Q. What is your wife's name? A. Alice. Q. Munschauer? A. Munschauer, yes. Q. And is her maiden name Weiss? Q. W-E-I-S-S? Q. What is your date of marriage? A. Oh. //0. Q. So have you been married about months? Q. And how long did you know Alice before you married her? A. Oh, about 0 years. Q. Had you ever resided in the same home

14 Munschauer - Snider - // :: :: :: ::0 :: :: :: :: :: :: :: :: ::0 ::0 :: :: :: :: ::00 ::0 ::0 ::0 ::0 0 with Alice before you married her? Q. For how long? A. Three years. Q. Is Alice a smoker? Q. Has she been a smoker at all during the 0 years you've known her? A. I don't know. I've never seen her smoke. Q. Okay. Does anyone else live with you and Alice? Q. You had a prior marriage before Alice, correct? Q. What was your former wife's name? A. Joanne Celotto. Q. C-E-L-O-T-T-O? Q. And how did that marriage end? A. She was cheating on me -- Q. So you divorced her?

15 Munschauer - Snider - // ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: ::0 0 A. -- with my best friend. I got a divorce, yes. Q. I'm sorry. Approximately, when did that divorce occur? A. My gosh. It was in the '0s. I don't really remember the date, though. Q. Was Joanne a smoker during your marriage? A. Yes, she was. Q. Did she smoke in the home? Q. Did she work outside the home? Q. What did she do for a living? A. She worked at Canisius College. She cooked for the priests. Q. In the 0 years that you've known your current wife, Alice, did she work -- have an outside job? A. She works, yes. Q. Where does she work? A. Blue Cross Blue Shield. Q. Has she worked -- is that where she's

16 Munschauer - Snider - // ::0 ::0 ::0 :: :: :: :: :: :: :: :: :: :: :: ::0 ::0 ::0 :: :: :: :: :: :: 0 always worked? Well, I don't know, you know, if she worked someplace else before that. Q. But that's what you're aware of? A. She's been there almost 0 years. Q. Does she have like an administrative position? A. Yes, she is. Q. Your father's name was Howard as well, correct? Q. Was he Howard I. Munschauer? A. I don't know if it was I or E. Q. Okay. Are you a Howard E. Munschauer, Jr.? Q. Okay. So he must have been Howard Munschauer, Sr.? Q. And is your father still with us? Q. And from what did he pass away? A. Lung cancer.

17 Munschauer - Snider - // :: :: :: :: :: ::0 ::0 ::0 :: :: :: :: ::00 ::0 ::0 ::0 :: :: :: :: :: :: :: 0 Q. How old was he? A. He was. Q. Was your father a smoker? A. Yes, he was. Q. Did he smoke in the home when you were growing up? Q. Did your -- withdrawn. Where did your father work when you were growing up in the family home? A. He worked at Bethlehem Steel. Q. And what did he do at Bethlehem Steel? A. He was an assistant pit foreman. Q. In what department, do you know? A. I don't know. Q. And your mother, is she still with us? A. Yes, she is. Q. How old is she? A. Oh, I think she's. I don't know. Q. Okay. What year was she born, do you know? A. I don't know. Q. Okay. Is she on her own still or does

18 Munschauer - Snider - // :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: ::0 ::0 ::0 0 she live in an assisted living facility? A. She's in a assisted living facility in Jamestown. Q. And how is her health for an -year-old? A. Well, she don't know me at all. She hasn't known me for three years. Q. So she has a memory disorder? Q. I'm sorry. That's very hard. When you were growing up in the family home, did your mom work outside the home? Q. Was your mom a smoker when you were growing up? Q. Now, you have two sisters and a brother? Q. Is Jessie your oldest sister? Q. She's older than you, right? A. Yeah.

19 Munschauer - Snider - // ::0 ::0 ::0 :: :: :: :: ::0 :: :: :: :: :: ::0 :: :: :: :: :: :: :: :: :: 0 Q. Okay. How is Jessie's health? A. Good, good. Q. Is her last name Agnoli? Q. Has Jessie ever been diagnosed with a lung or respiratory cancers of any type? A. Not that I know of. Q. Are you aware of any diagnosis of any cancers at all with Jessie? Q. Does Jessie have children? Q. Are you aware of any of Jessie's children being diagnosed with any cancers? Q. And you have a brother Frank? Q. And he's a little bit younger than you? Q. How old is he? A. He's got to be like. Q. Okay. And how is Frank's health? A. Good.

20 Munschauer - Snider - // :: :: ::0 :: :: :: :: :: :: :: ::00 ::00 ::0 ::0 :: :: :: :: :: :: :: :: :: 0 Q. Has he ever been diagnosed with any type of cancers at all? Q. What about his children, does he have children? Q. Has any of his children been diagnosed with any type of cancers? Q. And Rosemary is the baby, right? Q. And how old is Rosemary? A. Oh, gosh, she's got to be like three years younger than him. Q. So if he's, that makes her about? Q. How is Rosemary's health? A. Rosemary has lung -- or breast cancer. Q. How long has she had breast cancer? A. I'm thinking about eight months. Q. I'm sorry to hear that. Does Rosemary have children?

21 Munschauer - Snider - // 0 :: :: :: :: ::0 :: :: :: :: :: :: :: :: :: :: :: :: ::0 ::0 ::0 ::0 :: :: 0 Q. Have any of her children ever been diagnosed with cancer? Q. Okay. Can I go back a little bit about your grandparents? A. Sure. Q. On your mom's side, did any of your mom's grandparents ever be diagnosed with a cancer at all to your knowledge? A. My mom's grandparents? Q. Your mom's parents. A. Oh. No. Q. Your grandparents, but on your mom's side? Q. Okay. And your dad's grandparents, did you -- or your dad's parents, your grandparents on your dad's side? A. I never met my father's parents. Q. Okay. And you don't know whether they'd ever had any cancers at all? A. No, I don't. Q. What about any aunts and uncles, the

22 Munschauer - Snider - // :: :: :: ::0 :: :: :: :: :: ::0 :: :: ::0 :: :: :: :: :: :: ::0 ::0 ::0 :: 0 sisters and brothers of your parents, do you know whether any of them had ever been diagnosed with any cancers? A. My Uncle Joe. Q. Is that your father's brother or your mother's brother? A. My mother's brother. Q. And what type of cancer did he have? A. I never got the real story. All I heard was he had like five types of cancer. Q. Okay. Do you know how old he was when he came down with the cancer? A. Like or. Q. Okay. When you were growing up in the family home, did any of your sisters or your brother, did they smoke in the family home when you were growing up with them? Q. Did you live with any of your siblings after you moved out of the family home? Q. And you have three children, correct?

23 Munschauer - Snider - // :: :: :: :: ::0 ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: 0 Q. And these are children with your wife -- your first wife Joanne? Q. You have a daughter named Kim? Q. How old is Kim? Should have studied for this test, Mr. Munschauer. A. She's got to be like maybe 0. No, she can't be 0. Q. No, she can't be 0 because you would have been when you had her. MR. MORTON: Hey, you never know. THE WITNESS: Let's see. BY MS. SNIDER: Q. Do you remember what year she was born in? A. I know what year my son was born. I don't know the years my daughters were born. Q. Is your -- is Kim the oldest? A. Kim's the oldest. Q. Your son is Howard? Q. What year was Howard born?

24 Munschauer - Snider - // ::00 ::0 ::0 ::0 ::0 :: :: :: :: ::0 :: :: :: :: :: :: :: :: :: :: ::0 :: :0:00 0 A. '. The blizzard of '. Q. Was it nine months after the blizzard of ' or was he born during the blizzard of '? A. Nine months. Q. And he's Howard, III, correct? Q. When was the last time Howard lived with you? A. When he was three years old. Q. Okay. So he went and lived with his mom after the divorce or after the separation? A. So when he was three years old is when we got our divorce, so did if you take that away it's 0 some years. years we been divorced. Q. Yeah, would have been around 0 you divorced. Okay. You have another daughter in between Kim and Howard, Angela? A. Angela Munschauer, yes. Q. Okay. And how old is Angela? If Howard is about -- A. She's got to be -- it's years apart. Q. Okay. Howard's about, about.

25 Munschauer - Snider - // :0:0 :0:0 :0:0 :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0:0 0 A. Then she's got to be. Q. Okay. About. All right, then. A. And Kim's got to be. Q. Okay. We'll put approximately. A. Approximately. Q. Okay. How is Kim's health? A. Good. Q. Has she ever been diagnosed with any types of cancers? A. Not to my knowledge. Q. Has she ever lived with you after she became an adult? Q. How is Angela's health? A. Angela's got some problems with her stomach, but I don't -- it's nothing to do with cancer. Q. Has Angela ever lived with you since she was an adult? Q. And how is Howard's health? A. Good. Q. And you've already told me he's never

26 Munschauer - Snider - // :0: :0: :0: :0: :0: :0: :0: ::0 ::0 :: :: :: :: :: :: ::0 :: :: :: :: :: :: :: 0 lived with you -- Q. -- since he was three years old? A. No, he hasn't. Q. Do you have any other children? I hope not. Q. Where were you born, Mr. Munschauer? A. I was born in Silver Creek, New York. Q. And that's -- for the people who aren't from here, that's south of Buffalo, correct? Q. Did you grow up in Silver Creek? Q. How old were you when you moved out of Silver Creek? A. I was born in Silver Creek. I lived in Angola until I was like nine years old. Q. So about? Q. And then where did you move after that? A. Well, that was the time my mother and father were going through something and they sent me to Kentucky to live with my aunt and uncle.

27 Munschauer - Snider - // :: :: :: ::0 ::0 ::0 ::0 :: :: :: :: :: ::0 :: :: ::0 :: :: :: :: :: :: :: 0 Q. Where in Kentucky? A. Hopkinsville. Q. And how long did you live with your aunt and uncle? A. One year. Q. When you were living with your aunt and uncle, do you know what your aunt did for a living, or did she work outside the house? A. It was a farm. It was like in the back, country back in the hills. Q. So both of them were farmers? A. Yeah. Q. Do you know what they raised? A. Tobacco. Q. Did your aunt smoke during the year that you lived there? Q. Did your uncle smoke during the year that you lived there? Q. They were tobacco farmers, but they didn't smoke the product? A. That's correct.

28 Munschauer - Snider - // :: :: :: :: :: :: :: :: ::0 ::0 ::0 :: :: :: :: :: ::0 :: :: :: :: :: :: 0 Q. Did you work on the farm for that -- when you were about nine years of age? Q. Other than chores? A. Just chores, go fishing. Q. And then about, did you move back north? A. I came back to Angola and lived with my grandparents. Q. What were their names? A. Mary Catalano and Frank Catalano. Q. And what did your grandparents do for a living at that point in time? A. My grandfather was a farmer. He also worked at Bethlehem Steel. And they used to hire people to do all the picking, like grapes and strawberries and black berries and whatever. That's what they used to do. Q. And how long did you live with your grandparents? A. Well, on and off for a couple years. Q. Okay. How old were you when you last lived with your grandparents, do you remember?

29 Munschauer - Snider - // :: ::0 :: ::00 ::0 ::0 ::0 ::0 ::0 ::0 :: :: :: :: :: :: :: :: :: :: :: :: ::0 0 A. I really don't remember. I think I was like or. Q. So about, '? Was your grandfather a smoker when you lived with him? Q. Was your grandmother a smoker when you lived with her? Q. Was anybody else living with your grandparents at that point in time? Q. And then when you were about, did you go someplace else to live? A. From there I went to live with my Uncle Joe and my Aunt Pam in Lawtons, New York, on a dairy farm. Q. How long did you live with your Uncle Joe and Aunt Pam? A. Well, a couple years. Q. Till about,? Q. Okay. So you were about -- no.,

30 Munschauer - Snider - // ::? :: :: :: :: :: :: :: :: :: ::0 ::0 ::0 ::0 :: :: :: :: :: :: :: :: :: 0 A. Yeah. Q. How old? A. Yeah, could be. Q. Did either your Uncle Joe or your Aunt Pam smoke? Q. Did anyone live with them that smoked? Q. Where did you go then? A. Then what did I do then? I don't know. Q. Did you ever go back and live with your parents? Well, I went to live with my father years after when I was like for about a year, and then I got my own apartment. Q. Now, when you were living with these various relatives, did you go to school in those areas? Q. And did you eventually complete high school?

31 Munschauer - Snider - // 0 :: :: :: :: :: ::0 :: :: :: :: ::00 ::0 ::0 :: :: :: :: :: :: :: ::0 ::0 :: 0 Q. What's the highest grade that you went? A. Seventh grade. Q. And did you ever get a GED? Q. When you were living with your dad and you were, were you working at that point? A. I started work at the Buffalo Club. Q. And how old were you when you started to work at the Buffalo Club? A. I think I was. Q. Was it a busboy? A. I started out as a busboy. I got my own apartment. Q. Did you have any brothers or sisters, or were you an only child? A. No, I had -- we went through -- Q. Oh, I'm sorry. Never mind, I already did that. Did they live with you at all or did they travel around with you? Q. Okay. Sorry about that. I had a brain infarction.

32 Munschauer - Snider - // :: :: :: :: :: :: :: ::0 :: :: :: ::0 ::0 ::0 :: :: :: :: :: :: :: :: :: 0 A. That's all right, I was thinking if I had more. Q. Well, I think you have enough. A. Okay. Q. So they -- and I apologize, did they travel around with you to these various homes or did they go to other relatives' homes? A. No, they didn't. My brother lived with my father. My older sister -- my younger sister was adopted out, and then finally my parents got her back. But, no, they never lived with me. Q. Okay. When you first started working at the Buffalo Club as a busboy, did they allow smoking in the club? A. Yes, they did. Q. How long did you work at the Buffalo Club? A. I believe three years. Q. Okay. So if you were when you started, it would about? A. Let's see, I went to work for South Buffalo at '. So I don't know. I was. It's around there. I can't really remember.

33 Munschauer - Snider - // :: :: :: :: :: :: ::0 ::0 ::0 ::0 ::0 :: :: :: :: :: ::0 :: :: :: :: :: ::0 0 Q. Well, if you were born in, if you add to I think you come up with about ', would be like the fall of ', and that would have been your first job that you can remember having for pay? A. Yes, it could have been, yes. Q. Okay. And did you stay there until you went to work for the railroad in -- Q. -- or did you have other jobs? A. I stayed there and then I got the job on the railroad and I gave my notice. Q. What was the month that you got your job on the railroad? A. I believe it was April of '. Q. And did you have other jobs at the Buffalo Club other than busboy? A. Well, when I turned drinking was legal at that time, I became a waiter. I was able to serve drinks and such. Q. And did you stay a waiter between ' and when you left?

34 Munschauer - Snider - // ::0 :: :: :: :: :: ::0 ::0 ::0 ::0 ::0 :: :: :: :: :: :: :: :: :: :: :: :: 0 Q. And was that a full time job? Q. And so you said you lived with your dad for a year and then you got a job at the Buffalo Club, so you would have moved back in with your dad when you were about and lived with him until you were about? Q. For all those places that we've talked about, all those different homes, your aunts and your uncles and your grandparents, do you think simply from living in that home you would have been supposed to asbestos or asbestos-containing products? Q. What about at the Buffalo Club when you were working at the Buffalo Club, any reason to believe you would have been exposed to asbestos or asbestos-containing products from working at the Buffalo Club? Q. And do you have any personal information as to whether your father ever worked

35 Munschauer - Snider - // :: ::0 :: :: :: :: :: :: :: :: :0:00 :0:0 :0:0 :0:0 :0:0 :0: :0: :0: :0: :0: :0: :0: :0: 0 with any asbestos-containing products when he worked at Bethlehem Steel during the period of time that you lived with him? A. No, I don't. Q. And what about your uncle who worked at Bethlehem Steel, do you have any personal information as to whether your uncle ever worked with any asbestos-containing products during the period of time that you lived with your uncle and he worked at Bethlehem Steel? A. Uncle? Q. Well, you said you had an uncle that lived in Angola and had a farm and he worked at Bethlehem Steel, Frank Catalano? A. That's my grand -- oh, my grandfather. Q. Oh, I'm sorry. I apologize. A. That was my grandfather. Q. Okay. Any reason to believe that your grandfather worked with any -- excuse me. Do you have any personal information about your grandfather working with any asbestos-containing products when you were living with him and he was working at Bethlehem Steel?

36 Munschauer - Snider - // :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: ::00 ::0 ::0 ::0 ::0 :: :: :: :: :: :: :: :: 0 A. No, I don't. Q. Sir, are you a smoker presently? A. Not anymore, no. Q. When did you last smoke cigarettes? A. I quit two years ago completely just cold turkey. It's over two years because it was a year before I just quit. Q. And did you have any medication prescribed for you to assist you in quitting? A. No, no. Q. Did you have any patches or over-the-counter products that you bought to assist you in quitting? A. I've tried patches for years to try and quit, they never worked for me. I just quit. I just quit cold turkey. Q. Had you ever quit cold turkey before? Q. How many times? A. Oh, maybe four times, maybe. Q. And what's the longest you went without smoking? A. Almost three years.

37 Munschauer - Snider - // :: :: :: :: :: :: :: :: :: :: :: ::00 ::0 ::0 ::0 :: :: :: ::0 :: :: :: :: 0 Q. And when was that? A. Now. Q. Okay. And, I'm sorry, that was a poor question on my part. Before this period of time, on those other occasions when you quit what was the longest period of time you were successful in not smoking? A. Four months. Q. And what brought you back to smoking after not smoking for four months? A. Well, I think it's like an addiction, you start seeing people smoke, you hang around people that are at lunch, they have their lunch, they have a cigarette, the smell of it. Even today I smell a cigarette I sort of feel like I would want one, but I won't because I know what I've been through. Q. And what made you quit almost three years ago? A. I don't know, I just, I didn't like the smell that was on my clothes, for one thing. Especially in the wintertime, you can smell the smoke worse. It's disgusting. And I just made up

38 Munschauer - Snider - // :: :: :: :: :: :: :: ::0 :: :: :: ::0 ::0 :: :: :: :: ::0 :: :: :: :: :: 0 my mind, I just quit. Q. When did you first start smoking? How old were you? A. Teenager. Q. Were you on the tobacco farm or -- Q. -- after that? A. After that. Q. Do you remember, approximately, how old you were? A..,. Q. By the time you started working at the Buffalo Club, approximately how many cigarettes or packs of cigarettes were you smoking a day? A. I don't think I smoked a pack a day or even half a pack a day. Q. Was there some point in time when you began to smoke more than half a pack a day? A. Well, yes, there was. Q. And when was that? A. When I started working on the railroad. Q. So about?

39 Munschauer - Snider - // :: :: ::0 :: :: ::0 :: ::0 ::0 ::0 :: :: :: :: :: :: :: :: :: :: :: ::0 :: 0 Q. And when you started working on the railroad, let's say, let's kind of move forward to ' or ', approximately how many cigarettes were you smoking a day by the later 0s? A. I don't know, maybe a pack. Q. And do you remember ever smoking more than a pack a day, and I don't mean like one day here but I mean on a regular basis? A. Oh. No, no. Q. When you've gone to the doctors and they've asked you about your background, do doctors -- have they in the past asked you how much you smoked per day? Would there be times of how many cigarettes you would smoke and when you started, would those be questions you remember the doctor asking? A. I can't remember doctors ever asking me that. They knew I smoked and they told me I should quit. Q. Do you ever remember filling out any type of forms like, oh, I've had my tonsils out or I've had my appendix out and some of those forms would have on how much you smoke every day or how

40 Munschauer - Snider - // :: :: :: :: :: :: :: :: :: :: :: :: :: ::00 ::0 ::0 ::0 ::0 ::0 :: :: :: :: 0 much you used to smoke every day, do you remember that? Q. Okay. And when you filled those forms out, would you be truthful when you filled them out and tell the truth? Q. Because you would want the doctors to have accurate information, right? A. Well, sometimes it's embarrassing to even know that you're smoking. Q. Right. But you would be honest with your doctors? A. So, I don't know. I don't know if I would be honest with them in that sense. Q. Would you have downplayed how much you smoked to the doctors? A. I could have. Q. You wouldn't have told them you smoked more than you did? A. Never. Q. So you were likely to either minimize how much you smoked or be truthful, one or the

41 Munschauer - Snider - // 0 :: other? :: :: :: :: :: :: ::0 :: :: ::0 :: :: :: ::0 :: :: ::0 :: ::0 :: :: ::0 0 Q. Okay. How did you get the job at the railroad in April of? A. They were hiring, I went and applied for it. Q. What was the name of this company you went and applied for besides the railroad? A. South Buffalo Railway. Q. And did South Buffalo Railway have a territory where their trains traveled? Q. And where would that have been? A. Inside Bethlehem Steel, the Ford Plant, Republic Steel, Donner Hanna. And Station C, but I don't know what was over there. And we'd travel all through the whole steel plant. Q. Would you go -- would the railroad, I should say, go anyplace else to pick up supplies or pick up material in order to transport it to or from the various plants? A. We would go to the Ford Plant and pull a Ford train out and somebody would come in from a

42 Munschauer - Snider - // :: :: ::0 ::0 ::0 :: :: :: :: ::0 :: :: :: :: :: ::0 :: :: :: :: :: :: :: 0 different railroad and pick up the train with auto parts. We would just do a lot of work in the steel plant. Q. Okay. I've never worked for South Buffalo railroad, so I'm gonna firmly admit to you that these are probably really stupid questions as far as you're concerned, okay? A. Nothing's stupid. Nothing's stupid. Q. Okay. Was the -- and if I'm wrong, you tell me. Okay. Was the South Buffalo railroad's purpose to transport the material that was being produced at these various plants off site so that it could be picked up for transport someplace else? Q. Then you tell me what South Buffalo Railways purpose was. A. I can tell you what I did. Q. Do you know what South Buffalo Railway's purpose was? A. To do all the business at the Bethlehem Steel, so transfer, to pull cars from the mills for transporting them to different yards, to pull the steel and slag out of the furnaces to bring to the

43 Munschauer - Snider - // ::0 BOF. ::0 ::0 ::0 :: :: :: ::0 :: :: :: :: :: :: ::0 :: :: :: :: :: :: :: :: 0 Q. So was it to transport material from one place inside Bethlehem Steel to another place inside Bethlehem Steel? Q. And, as far as you know, you're not aware of South Buffalo Railway transporting raw material into Bethlehem Steel? A. In what respect? Raw material, what kind of raw material? Q. Well, if they needed coal, for example, Bethlehem Steel needed coal to fire a power plant, you're not aware that South Buffalo Railway transported that coal into the plant, are you? A. Somebody brought it to the plant. We would take it and pushed up to the coal dumpers on the west side. Q. Okay. So it was only moving material, as far as you're aware or as far as your job duties were involved, within the plant -- Q. -- of Bethlehem Steel?

44 Munschauer - Snider - // :: :: ::0 ::0 :: :: :: :: :: :: ::0 :: :: :: ::0 :: :: :: :: :: :: :: ::0 0 Q. For Ford you told us you recalled transporting auto parts that had been manufactured at the Ford Plant out of the plant to another site where it was picked up by another means of transportation, correct? Q. Okay. Anything else that you did in connection with the Ford Plant? Q. Republic Steel -- you said Republic, but you're talking Republic Steel, correct? Q. Were your job duties at Republic Steel relative to South Buffalo Railway similar to what they were at Bethlehem Steel, transporting material within the plant? A. We would go in there -- this didn't happen all the time, once in a while -- and move cars around for some reason. I don't know why. Just pull some cars out of there and bring them back to the steel plant and bring empty cars there. Q. Okay. Donner Hanna, what did you do for Donner Hanna?

45 Munschauer - Snider - // :: :: :: :: :: :0:00 :0:00 :0:0 :0:0 :0:0 :0:0 :0:0 :0:0 :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: 0 A. We pulled coke out of there. Q. And did you transport the coke someplace? A. We brought it to the steel plant. Q. Bethlehem Steel? Q. Also Republic Steel? A. Republic Steel, no. Q. Okay. And Station C, did you ever work at Station C or transport things to and from Station C? Q. What was done at Station C? A. Station C was a huge huge yard, railroad yard, and we would take the loads from different tracks in the steel plant, whatever they were, put air on the train, get an air test, and take them over to Station C and a different railroad would come in and pick them up. Q. Was Station C located within the Bethlehem Steel facility? Q. Was it located near the Bethlehem Steel

46 Munschauer - Snider - // :0: :0:0 :0: :0: :0: :0: :0: ::0 ::0 ::0 :: :: :: ::0 :: :: :: :: ::0 :: :: :: :: 0 facility? A. It was -- it's hard to explain. It's -- you would leave the steel plant and go over Route over the bridge. It was like two miles up over a hill and down a huge hill and then there would be all these yards down there and different trains would come in and pick up materials. Q. Was Station C only used to transport material from Bethlehem Steel or did you go to Station C from these other facilities as well? A. No, we just -- we just brought stuff there and brought stuff back. Q. Right, but only to and from Bethlehem Steel or to and from also -- A. Just from Bethlehem Steel. Q. Okay. Thanks. So, let's go back to your first employment at South Buffalo Railway, which you said was April of. When you first started working there, did you have to have any training or was it on-the-job training? A. It was on-the-job training. Q. And what was your first job duty?

47 Munschauer - Snider - // :: :: :: :: :: :: :: :: ::0 ::0 ::0 :: :: :: :: :: ::0 :: :: :: :: :: ::0 0 A. I was a fireman. Q. And I'm gonna kind of go over, get all your job duties and the years that you had them, and then I'll come back and ask some detail, okay? A. Okay. Q. Okay. How long were you a fireman? A. I'm gonna say about nine years. Q. So if you started in April of, that would make it till about? A. I think so because after that I became a switchman. Q. And how long were you a switchman? A. Five years. Q. Till about? A. I believe so, yes. Q. And after you were a switchman, did you have any other job at South Buffalo -- or South Buffalo Railway? Q. Did you leave the company from that position? A. Got laid off. Q. As a fireman, were you assigned to work

48 Munschauer - Snider - // :: :: :: :: :: ::00 ::0 ::0 ::0 ::0 :: :: :: :: :: :: :: :: ::0 :: :: ::0 :: 0 on a particular train or with a particular crew? A. I was on what they call a extra board, it's like a roster and it's just -- it's like revolving where they pick up the guys if they have an opening, they call you up and they tell you where you're supposed to work. But it was always a fireman's job, and I would go to that job. Q. So different trains? Q. Would you always work the same shift or would it be different shifts? A. No, it would always be -- well, most of the time it would be different shifts. Q. And one week could you work days and the next week you could work evenings and then go back to days again, or would it vary from day to day? A. I could work this morning and then come back tomorrow afternoon, or the next day the nights, or depends how slow the board was. If they didn't have any openings, they wouldn't even call you. You could -- might just work four days a week.

49 Munschauer - Snider - // :: :: :: :: ::0 :: :: ::0 ::0 ::0 ::0 ::0 ::0 :: :: :: :: :: :: :: :: :: :: 0 Q. Were you only paid four days a week that particular week then or were you paid for all five? A. No, if you worked four days you were paid four days. You were guaranteed four days. Q. And can you tell me -- well, withdrawn. Was there only one class of fireman? For example, sometimes you hear about people, they were, you know, pipefitter A or a pipefitter B and they had different jobs. Q. Are there different classes of fireman or is it just fireman? A. Just fireman. Q. Okay. Why don't you tell us what you did as a fireman for South Buffalo Railway. A. Okay. Q. Go ahead. I'm just throwing this away. A. Okay. Now, say this is the engine. Q. The table's the engine? Q. Okay. A. This is good right here. And this is

50 Munschauer - Snider - // :: ::0 :: :: :: ::0 ::0 :: :: :: :: :: :: ::0 ::0 ::0 ::0 :: ::0 :: :: :: :: 0 the nose of the engine, this is the cab. Okay. Engineer sits there, fireman sits here. Q. Stop for a second. So, we're seating at a table that's about 0 feet long, maybe feet long -- Q. -- and you're pointing to the other end of this feet, and that's the nose or the front of the engine -- Q. -- correct? Now, I know some of these questions are gonna sound stupid, but I'm pretty stupid sometimes. The engine's the first car on the train that pulls the rest of the train, correct? A. You are correct. Q. And would the engine car be about as long as this table? A. It's probably a little longer. Q. Okay. So about feet long would you say, 0 feet long? A. About 0 feet. Q. Okay. And where you sat -- well,

51 Munschauer - Snider - // 0 :: ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: ::00 ::00 ::0 ::0 :: 0 withdrawn. Did you sit as a fireman for your job? A. Yes, I did. Q. And where would you sit? Would you sit at the front, the very front of the engine car or the very back of the engine car? A. The back of the engine is where you have the cab, the engine cab. Q. Okay. A. Okay. Q. So an old fashioned kind of cab is there would be a bump at the end, a bump up? A. It's not an old fashioned. Q. It's still like this? A. Yes, they're still like this -- Q. Okay. A. -- I believe. This is a diesel engine now. Q. All right. A. It's not the old coal. That's why they had fireman in the first place, to stoke the old steam engines, but that's not why I was a fireman. Q. Okay. Continue on. So you're sitting

52 Munschauer - Snider - // :: :: :: :: :: :: :: :: :: :: :: :: :: ::0 :: :: :: :: ::0 :: :: :: :: 0 there in your seat. A. I'm sitting here just like this. That's the head of the engine. Q. Okay. And you're facing, that would have been -- A. Near the engineer. Q. Where am I sitting? A. You're sitting right there facing that way. Q. So you are sitting parallel to the engineer -- Q. -- on the back, the very back of the diesel engine? Q. Okay. A. Now, you have switchmen that are on the ground, a lot of times -- well, if they're working on my side, I have to take signals and pass them onto the engineer so he knows if he should go forward, backwards, slow up, highball, stop. These are all signals that I pass onto the engineer. Q. From the signalman who's on the outside

53 Munschauer - Snider - // :: :: ::0 ::0 ::0 ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :: ::0 ::0 :: 0 of the car? A. The brakeman that's on the outside on my side working. Now, they could be 0 cars away and they'd give me a signal, like that means stop. Tell the engineer stop. Q. Okay. Now, you waved your hand up above. A. Up above. Q. Okay. And that was your job? A. Yes, taking signals from the ground. Now, if they were working on his side, I'd just sit there, you know. Q. All right. A. But a lot of times they couldn't work on his side, that's why they had a fireman. Q. What percentage of your day when you were a fireman would you be sitting in that chair? A. Seven hours. Q. So your -- most of your day? Q. And if you got a lunch break -- I presume you got a lunch break at some point?

54 Munschauer - Snider - // :: :: :: ::0 :: :: :: :: :: ::00 ::0 ::0 :: :: :: :: :: :: ::0 :: :: :: :: 0 Q. Did you take a lunch break at the same time the engineer took a lunch break? Q. Where would you take your lunch break? A. We would take it in whichever location we were at. If we were at the junction or G office or D or the west side, wherever we were at we would take our lunch. Q. Would you take your lunch at a very set time, meaning, oop, it's noon, time to take lunch, or would you say, it's about lunchtime, we're at a particular location, good place to stop and take lunch? A. Never, never. Q. Never what? A. We would never take a lunch at a precise time. If we were doing a job, we did the job. We couldn't just stop the job and just go take a lunch. Q. So you would take a lunch at a -- when the job was done and when you were at a convenient location to take a lunch?

55 Munschauer - Snider - // ::0 ::0 :: :: :: :: ::0 :: :: :: :: :: ::0 ::0 ::0 ::0 :: :: :: :: :: ::0 :: 0 Q. When you were working at Bethlehem Steel, would you eat lunch in the Bethlehem Steel lunchrooms? Q. Would you eat anyplace else when you were working at Bethlehem Steel? A. On the engine. Q. You mean inside the car? A. Yes, inside the cab of the engine. Q. When you worked inside the engine as a fireman between and, did you wear any type of mask or respirator when you were doing your job? Q. Were there any type of -- was there any type of smoke -- because the window was open, right? Q. -- was there any type of smoke or fumes inside the cabin? A. Well, you could smell diesel fuel all the time.

56 Munschauer - Snider - // :: :: ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :0:00 :0:0 :0:0 :0:0 :0: :0: :0: 0 Q. Where was the motor that was burning the diesel fuel and releasing the diesel fumes? A. Right in front of the cab. Q. So in front of you meaning -- A. Well -- Q. -- the direction you were travelling when you were going forward? Q. Do you know the make or model of any of these engines you rode in as a fireman? Q. Do you know who manufactured any of them? A. ALCO, I believe, but I'm not sure. I think it's ALCO because I used to have to check the engines before we'd go. Q. What were you checking for? A. I would check the oil, the sand to make sure we had sand, and just different things around like the fire extinguishers, make sure they were up, things like that before we went to work on a job. Q. When you were a fireman, did you have

57 Munschauer - Snider - // :0: :0:0 :0:0 :0:0 :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: :0: ::0 ::0 ::0 :: :: :: 0 any responsibilities for repair of the engines at all? Q. When you were a fireman, did you have any responsibilities for the repair of any part of the train? Q. When you were a fireman, were you present when others did repairs on the engines or other parts of the train? Q. When you were a fireman, do you believe you were exposed to diesel fumes? Q. How so? A. Well, you could smell it all day long, especially when your window's open. And in the summertime you always have your window open. But in the wintertime, yes, too. Q. When you were a fireman, do you believe you were exposed to asbestos when you were working as a fireman?

58 Munschauer - Snider - // :: :: ::0 :: :: :: ::0 :: :: :: ::0 :: :: ::0 :: :: :: ::0 ::0 :: :: :: :: 0 Q. How so? A. Well, when you put on the brakes, I never knew that -- I never thought that the brakes were made of asbestos, it never even dawned on me, but you put on the brakes quite frequently. Q. And -- A. And the dust flies up. Q. And when you say put on the brakes, you mean the brakes of the engine, correct? A. Yes, those are air brakes. Q. Any other way that you think you may have been exposed to asbestos when you worked as a fireman for South Buffalo Railway other than the brakes from the engine? A. We used to take lunch in some of the buildings and there were guys working up on the pipes periodically in the junction and at the west side. Q. Do you know the names of any of these guys? Q. Do you know what their trade was, these guys?

59 Munschauer - Snider - // :: :: :: :: :: ::0 :: :: :: :: ::0 :: :: :: :: :: :: :: :: :: ::00 ::0 ::0 0 Q. Do you know whether they were Bethlehem Steel employees? A. I couldn't tell you that. Q. So you don't know if they were Bethlehem Steel employees, outside contractors, you just know you remember seeing this? A. Yeah. Q. How close were you to any of these guys when you saw them doing their work? A. Well, I remember one time I was -- we had the benches by the, in the locker room, along the side I was sitting there, and maybe they were like 0 foot up on a ladder. Q. Other than recalling seeing them working on the pipes, do you remember what they were doing on the pipes? A. They were covering the pipes. Q. Do you know what the product was they were using to cover the pipes? A. No, I don't. Q. Do you know what ran in the pipes; what was going through the pipes?

60 Munschauer - Snider - // ::0 ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: ::0 ::0 ::0 ::0 :: :: 0 A. I was thinking it must have been water, but I don't know. Q. Are you able to give me a description of the material that they were using to cover the pipes? Q. Do you remember seeing any of the boxes or bags that the material came out of? Q. And I want to make certain we're clear, you told me about this time when you were at your lockers or in the locker room and you saw these people 0 feet up working on a ladder working on the pipes and you didn't know any of the material, you couldn't give me a description, didn't know their names, and couldn't give me a description of the boxes or bags, is that true for every time you saw people working on pipes, you didn't know who they were, you couldn't give me a description of the boxes or bags? A. No, never knew who anybody was. Q. And you never knew what ran through any of the pipes that they were working on; is that

61 Munschauer - Snider - // 0 :: right? :: :: :: :: ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: ::0 :: 0 Q. Okay. It's not right or I am right? A. You are right. Q. Okay. All right, then. Any other way you think you might have -- well, withdrawn. Do you know that those products that those people that were working on the pipes contained asbestos or you think it might have? MR. MORTON: Form. THE WITNESS: No, I don't. I don't know. BY MS. SNIDER: Q. Okay. You don't know one way or the other? Q. Okay. Any other way that you think you might have been exposed to asbestos when you were a fireman for South Buffalo Railway? A. Bricklayers. Q. Where did you see the bricklayers? A. By the BOF. Q. And what products did you see the

62 Munschauer - Snider - // :: :: ::00 ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: 0 bricklayers working with? A. I don't know the products, but there were repair tracks over by the station and they would be, I don't know if you know what a sub is, it's the things that carry the hot steel, they would be in there repairing them taking the old brick out and putting new brick in. This would be on days when I worked over there, I could see them doing this stuff. Q. And the material that they were using in between the bricks, is that what you're talking about in terms of laying the material down, or did the bricks adhere to each other? A. I don't know. I know we would be sitting there waiting for our jobs and I would just be watching these guys doing -- you know, just looking around the plant and I noticed them guys working there all the time and just putting new brick in, probably because the steel would have probably melted the torpedo. Q. And then they were taking the old brick out?

63 Munschauer - Snider - // ::00 ::0 ::0 :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: :: ::0 :: :: :: 0 Q. Any other way you think you might have been exposed to asbestos? A. Other than the brakes, and the bricks, and the -- Q. People working on -- A. -- the pipe coverings, it could have been -- it could have been asbestos anywhere in the steel plant. Q. After you stopped working as a switchman in -- or as a fireman in, you became a switchman -- Q. -- is that correct? Q. And you told me a little bit about what switchman did from your perspective as a fireman, which was they gave signals out to the fireman and the engineer. Q. Is that pretty much what a switchman did or did you do other stuff too? A. Well, we'd go to different mills to pick up different cars, bring them to different