IN THE COURT OF COMMON PLEAS OF ALLEGHENY COLINTY, PENNSYLVANIA
`TEISHA
`of JAMES STOLICH, Deceased,
`Plaintiff,
`vs.
`AO SMITH CORPORATION, et al.,
`Defendants.
`NO. G.D. t7-0t2893
`CODE: 012
`REPLY TO PLAINTIF'F'S' RESPONSE TO
`MOTION FOR SUMMARY JUDGMENT
`BASED ON LACK OF PRODUCT
`IDENTIF'ICATION
`FILED ON BEHALF OF DEFENDANT
`ALLIED GLOVE CORPORATION
`Counsel of Record for This Defendant:
`Concetta A. Silvaggio, Esquire
`PA I.D. #437T2
`Ronald J. Richert, Esquire
`PA I.D. #88317
`WILLMAN & SILVAGGIO, LLP
`Firm #465
`One Corporate Center
`5500 Corporate Drive, Suite 150
`Pittsburgh, PA 15237
`4t2-366-3333
`412-366-3462 (Fax)
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`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`TEISHA STOLICH, Administratrix of the Estate
`of JAMES STOLICH, Deceased,
`NO. G.D. 17-012893
`Plaintift
`VS.
`AO SMITH CORPORATION, et al.,
`Defendants.
`RBPLY TO PLAINTIFF'S RESPONSE TO
`MOTION F'OR SUMMARY JUDGMENT BASED ON LACK OF PRODUCT IDBNTIFICATION
`AND NOW comes Defendant, Allied Glove Corporation (hereinafter referred to as "Allied
`Glove"), by and through its attorneys Willman & Silvaggio,LLP, and files the following Reply to
`Plaintiff s Response to Motion for Summary Judgment based on lack of product identification:
`BACKGROUND
`Plaintiff s claims against this Defendant are based on allegations that Mr. Stolich was exposed to
`asbestos. Plaintiff filed a complaint with the Allegheny County Court of CoÍrmon Pleas on or about
`September 18,2017 alleging inter alia that plaintiff/decedent James Stolich was exposed to asbestos-
`containing products allegedly supplied or manufactured by Allied Glove.
`The only co-worker witness offered by plaintiff in this case was Tyrone Williams. Mr. Williams
`testified that he did not work with Mr. Stolich but worked in the same area. (Dep. p. 31.) He testified that
`he saw Mr. Stolich working on top of the coke batteries at the Clairton Works every third week. (Dep. p.
`30.) He first saw Mr. Stolich ín 1975 and worked in his vicinity from 1975 until 1980 when Mr. Williams
`became a laborer. (Dep. pp. 38-39.) After becoming a laborer, Mr. Williams sa\M Mr. Stolich only from a
`distance. (Dep. p. 38.) Mr. Williams clarified that the only place he saw Mr. Stolich working was on top of
`the batteries (Dep. p. 60.)
`Mr. Williams testified that he does not know whether Mr. Stolich worked with or around any
`asbestos-containing products. (Dep. pp. 45-46.) Importantly, also, he testified that Mr. Stolich was required
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`to wear a respirator when he was working on top of the coke batteries (Dep. p. 50).
`As outlined in the Eckenrod and Gregg opinions, plaintiff has failed to show that Mr.
`Stolich was directly or indirectly exposed to a product supplied, used or installed by Allied Glove
`Corporation with the requisite frequency, regularity and proximity. As such, there is no genuine issue as to
`any material facts and, therefore, Defendant Allied Glove Corporation is entitled to judgment as a matter
`of law.
`For the foregoing reasons, Allied Glove Corporation's Motion for Summary Judgment based on
`lack ofproduct identification should be granted.
`Respectfully Submitted,
`WILLMAN & SILVAGGIO, LLP
`One Corporate Center
`5500 Corporate Drive, Suite 150
`Pittsburgh, PA 15237
`412-366-3333
`BY: /s/ Edward O'Connell
`Edward O'Connell, Esquire
`Counsel for Defendant,
`Allied Glove Corporation
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`724-869-770s
`TYRONE WILLIAMS
`marsiliocourtreporting. com
`Page I
`IN THE COURT OF COMMON PLEAS1_
`2
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`OF ALLEGHENY COUNTY PENNSYLVANIA
`TEISHA STOLICH, Administratrix
`of t.he Estate of ,JAMES STOLICH,
`Deceased,
`)
`) crvri, DrvrsroN
`) ASBESTOS
`Plaint.iff, )
`vs.
`AO SMITH CORPORATION, êt àI. ,
`Defendants.
`) mo. c.D
`) 17 -01,2893
`t_0 )
`11
`1,2
`l_3 DEPOSITION OF TYRONE hJTLLIAMS
`1,4 Monday, May 2I, 201-8
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`1,6 MARSILIO COURT REPORTTNG SERVICE
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`TH]S TRANSCRIPT IS PROHIBTTED WITHOUT WRITTEN
`AUTHORIZATTON FROM THE CERTTFY]NG AGENCY
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`Electronically signed by Sheila Rivers (601-407-888-8574)
`Marsilio Court Reporting Service
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`Page 30
`1 Q. Did Mr. Stolich have a nickname at the
`2 plan|?
`3 A. Yes. Hollywood.
`4 Q. Hollywood?
`5 A. Yes.
`6 Q. Did you have a nickname?
`7 A. No. Everybody just called me Tate. My
`8 grandparents raised me, so everybody thought I
`9 was -- my last name was Tate, so everybody called me
`10 Tate.
`1l a I have to ask, why did they call Mr.
`12 Stolich Hollywood?
`13 A. He was a nice-looking guy.
`14 a And did you work with Nft. Stolich?
`15 A. I worked on top of the batteries. He
`16 worked there every day. I worked there -- I worked
`l1 on top as a utility man, so I just seen him every
`18 third week, because I worked all three turns.
`19 a Okay. So Mr. Stolich always was on top,
`20 above ground on top ofthe batteries and the
`2I standpipes?
`22 A. While I was on the battery. I don't know
`23 what happened after I left the batteries.
`Page 32
`I -- like I say, it's been a while, My first five
`years I spent, I think, on the coke works, five or
`four years. In that time I worked with him.
`a. Okay. I understand your afÍidavit says in
`the early'80s, you bid into the labor gang.
`A. Well, I got a -- no, that would be in the
`beginning of around '80, I bid in the labor gang,
`yes.
`a. Okay. So I'm trying to put bookends on the
`time frame when you saw Mr. Stolich or worked around
`him. Would that be when you started in December'74
`until 1980?
`A. Yes.
`a. Okay.
`A. Yes. Yes.
`a. And you don't recall having encountered him
`after you became a member of the labor gang?
`A. I used to see him from a distance, because
`most of the labor gang work was throughout the mill,
`so I just seen him, you know, in passing.
`a. Okay.
`A. Yes.
`a. Again, up on top of the batteries or for
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`a Sure. The only place you ever saw him was
`up on top of the batteries and the standpipes?
`A. Yes. Because that was his job, and when I
`worked as a utility man, that was my job on top of
`the batteries.
`a. So is it the case that you actually worked
`with Mr. Stolich or more that you would see him as
`someone who was present at the mill?
`A. I would see him as present. I didn't work
`right beside him or hand and hand. We just worked
`in the same area.
`a Okay.
`A. Yes.
`a Did you know Mr. Stolich before you met him
`at USX --
`A. No. Sorry.
`No, I didn't know him til we met on the
`batteries.
`a Can you give us an idea ofhow long you
`worked around him at USX or, for example, what span
`of years from the time you started until the time he
`left?
`A. I starled in the last month of '74, and
`Page 33
`the standpipes?
`A. Yeah. Yeah. Yeah. Because we didn't
`go -- labor gang, we wasn't equipped -- I mean, had
`the equipment at that time to go on top of the
`batteries.
`a. Sure.
`A. Because you had to wear certain uniform on
`top of the batteries.
`a That's what you did once every three weeks
`or once a month, approximately?
`A. When I was on the batteries, I wasn't in
`the labor gang,I was actually on the coke works.
`a I'm sorry. I meant through your time --
`was it general utility man slash --
`A. Utility man.
`a -- door cleaner?
`A. I was utility man at that time when I was
`on top of the batteries.
`Door cleaners was on the first level.
`Utility man was on top of the battery with
`Mr. Stolich where he worked.
`a Okay. Now, you said you started at
`Clairton in December of 7914?
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`124-869-7705
`TYRONE ÏVILLIAMS
`9 (Pages 30 to 33)
`marsi I iocourtreporting.com
`Electronically signed by Sheila Rivers (601-407-BBB-8574)
`Marsilio Court Reporting Service
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`Page 38
`pipe cleaning, and he would be directly behind the
`sand pipe, yeah.
`a. Okay.
`A. Cleaning the line or open them up.
`a Okay. And then you testified before that
`after your work as a utility man/door cleaner, you
`bid into the labor gang and became a laborer
`sometime around 1980?
`A. Yes. Yes.
`a And am I right that after that time, you
`didn't actually work with --
`A. No.
`a -- Mr. Stolich?
`A. No, not at all.
`a Okay. You'd see him from a distance?
`A. Yeah, because like I said, on coke ovens,
`you had to wear certain type uniform, and we could
`just wear jeans, shirt, you know. So we weren't
`allowed on coke ovens with our dress.
`ou were down on the ground?
`es. Labor gang, yes.
`a Okay
`A. Yes.
`aYA,Y
`Page 40
`1 Q. Okay. While you did work at U.S. Steel,
`2 were you ever laid offl
`3 A. I'mtrying to think did I -- I don't think
`4 I was laid off at any time when I was on the coke
`5 ovens.
`6 Ithink when I got in the labor gang,
`7 that's when I got laid off. Not when I was on the
`8 coke works.
`9 Q. Okay. How long was that layoff when you
`10 were in the labor gang?
`11 A. I think we got laid off -- like I said, I
`12 can't recall.
`13 a Okay.
`14 A. It wasn't real long. But then the second
`15 time, it was, like, permanent.
`16 a Okay. When you worked at USX, were you
`l7 ever on strike?
`18 A. No.
`19 a. Okay. Mr. Williams, I'm going to shift to
`20 Mr. Stolich now.
`2I Do you recall the first time you saw Mr.
`22 Stolich at USX Clairton?
`23 A. Yeah. It was on top of the battery -- I
`Page 39
`1 Q. And you would maybe look up and see him up
`2 there --
`3 A. Well, at that time, we had -- we got to
`4 know each other. He would holler my name, I would
`5 holler his name, something like that.
`6 Q. Can you tell us or estimate for us how far
`1 it is from the ground floor to the top of the
`8 battery where you saw Mr. Stolich? Good ways up?
`9 A. Yeah. I can't say for sure. Yeah, I mean,
`10 we could -- I didn't have to look twice to tell who
`11 it was.
`12 a Sure. After you became a laborer, did you
`13 hold any other positions or titles at USX?
`14 A. No.
`15 a. You retired as a laborer?
`16 A. I got laid off as a laborer.
`17 a You got laid off. Okay. When was that,
`18 sir?
`19 A. It was in the early'80s. Not -- I think I
`20 worked in the labor gang maybe four more years
`2l before I got laid off.
`22 a Early mid'80s?
`23 A. Yes. Yes.
`Page 4l
`1 mean, at work on the batteries, yes.
`2 Q. And I'm looking for, if you can do it for
`3 me, I mean, ideally a day, a month and a year. But
`4 you can just give me a month or even ayear.
`5 A. '75, that's all I can tell you.
`6 Q. Okay. And let me ask you this: When is
`7 the last time you saw Mr. Stolich?
`8 A. He invited me and my wife over, had a
`9 little Super Bowl thing, because he could cook, and
`10 he invited us to come over. And it was about ten
`1 1 years ago.
`12 a Okay.
`13 A. Yeah.
`14 a Had you maintained a fairly regular
`15 friendship with Mr. Stolich after you both left?
`16 A. Oh, yes. Yeah. We was pretty close until
`17 I went -- when I went into the ministry, we kind of
`18 parted our ways.
`19 a When did you do that?
`20 A. I went in ministry about 20 years ago.
`21 a Okay.
`22 A. Yes.
`23 a I take it, then, you know that he became
`724-869-710s
`TYRONE WILLIAMS
`11 (Pages 38 to 41)
`marsil iocourtreporting. com
`Electronically signed by Sheila Rivers (601-407-BBB-8574)
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`Page 42
`1 sick.
`2 A. I didnt know he was that sick, no.
`3 Q. I don't think I asked you, do you recall
`4 what Mr. Stolich's actual job title or position was?
`5 A. Like I said, when I was on the batteries,
`6 they classified him as a tar chaser, and his job was
`7 keeping, I think, the lines open.
`8 Q. lVhat lines are you referring to?
`9 A. That ran across the batteries, I mean,
`10 because the tools, he had -- I think he unplugged
`11 them, and there was a little -- I think there was a
`12 little pit, too, that some of the material ran into
`13 or the liquid, and I'm not sure, you know, what they
`t4 did.
`15 a Just so I'm clear, was the liquid running
`16 through those lines tar?
`l7 A. I'm pretty sure, because his shoes and
`18 stuff would be black, so I guess that's why they
`19 called it tar chaser.
`20 a Okay. Do you know whether Mr. Stolich ever
`2I held any other position or had any other job title?
`22 A. No. No,I don't.
`23 a So as far as you know, he was a tar chaser,
`Page 44
`I supervisors or foremen?
`2 A. I guess -- I don't know if they had a
`3 foreman, but I think the general foreman that was in
`4 charge of the whole unit, like the foreman,I guess
`5 that might have been their boss, the general
`6 foreman.
`7 Q. Okay.
`8 A. Yes.
`9 Q. You don't recall any names?
`10 A. LarryNosich(phonetic). Coupleofthem,
`I 1 theypassed on.
`12 a. Okay.
`l3 A. I don't know if Ray DeCola (phonetic) --
`14 I'm not sure Ray DeCola...
`15 a Ray DeCola?
`16 A. Yeah.
`17 a. You're not sure if he's alive?
`18 A. No. Like I said, they were all older than
`19 us. Because the two -- I know Hays Carwell, he
`20 passed away. Like I said, I'm not sure. The two
`2I that I'm real familiar with, they passed on.
`22 a Let me askyou this, Mr. Williams, and
`23 these next questions I'd like you to be mindful of
`Page 43
`1 and that's it?
`2 A. Yes. Yes. Yes.
`3 Q. Now, your affidavit says that you saw him
`4 working on top of the batteries and around sand
`5 pipes and lids.
`6 Can you give us just a thumbnail sketch of
`7 what exactly he was doing when you saw him?
`B A. He, like I said, I could just tum around,
`9 I could see him working, and he was, like, working
`10 on the lines, you know.
`11 a How would he do that? How would he work on
`12 the lines?
`13 A. Like I said, they had a tool, I don't --
`14 and a wrench, and I don't know -- like, I actually
`l5 don't know how they did it, but they would be
`16 opening and closing things and unplugging, yes.
`l7 a. When you say unplugging, you mean the
`1B lines?
`19 A. Yes.
`20 a. Through which the tar was running?
`2l A. Yes. Because I think at different points,
`22 they had buildup.
`23 a. Do you recall any of Mr. Stolich's
`Page 45
`1 the distinction I'm drawing between working with and
`2 working around, Working around means that Mr.
`3 Stolich was not touching or working hands on with a
`4 particular piece of equipment or a product, but that
`5 was in his vicinity. And when I ask you about
`6 hands-on products that Mr. Stolich worked with, I
`7 meanphysically in his hands, he touched physically.
`B Okay?
`9 A. Okay. Hands on is the --
`10 a. Touching, just as it sounds.
`11 Working around is products he's not
`12 touching, but they're sort of around where he's
`13 working.
`14 A. Okay.
`15 a. Okay?
`16 A. (Nodding head up and down.)
`I7 a. Do you believe that Mr. Stolich worked
`18 around any products that contained asbestos at U.S.
`19 Steel?
`20 A. I really don't know -- I really don't know,
`2l because I don't know what the material was that them
`22 sand pipes and everything was -- you know, I really
`23 don't know what the material was.
`124-869-710s
`TYRONE WILLIAMS
`I 2 (Pages 42 to 45)
`marsil i ocourtreporting. com
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`Page 46
`1 Q. You're saying sand pipes, not standpipes,
`2 correct?
`3 A. Yes, sand pipes.
`4 a What were the sand pipes for?
`5 A. Actually, where they released pressure off
`6 the ovens, you know. They were about seven or
`7 eight -- six, seven, eight feet, and they -- when
`8 they push a certain oven, you pull down on them to
`9 release the pressure, and that's what the sand pipes
`l0 were. And you had to keep them clean, which I had
`1l to do, yeah.
`12 a How about products that Mr. Stolich worked
`13 with hands on, do you have any information or can
`14 you provide any testimony that he worked hands on
`15 with any products and materials that contained
`16 asbestos?
`17 A. No.
`18 a Do you recall the last time you saw Mr.
`19 Stolich at U.S. Steel Clairton?
`20 A. It was in the'80s.
`2l a. In the '80s?
`22 A. Yes.
`23 a When you left?
`Page 48
`1 A. Yes. But not the names.
`2 Q. Can you tell me generally what these
`3 outside contractors or outside contractor was doing,
`4 the nature of the work?
`5 A. I just seen them sandblasting pipes that
`6 were -- that wasn't on the batteries, that was
`7 across the road. I really don't know. I just seen
`8 them sandblasting, that's about it.
`9 Q. Okay. These pipes that you saw being
`10 sandblasted, that's not in the area where Mr.
`11 Stolich worked?
`12 A. No. It was across the roadway, yes.
`i3 a Any other generic types of work that you
`14 saw being performed by outside contractors?
`15 A. I couldn't tell you what they were doing,
`16 but they had outside contractors working on the
`17 boiler house.
`18 a The boiler house?
`19 A. Yes. But, like I said, I don't know what
`20 they were...
`2I a Okay. And can you tell us where the boiler
`22 house was in relation to the tops of the batteries
`23 where Mr. Stolich worked?
`Page 47
`1 A. Yes.
`2 Q. Okay. To the best of your recollection,
`3 Mr. Williams, have we talked about all of the jobs
`4 you observed Mr. Stolich performing at USX?
`5 A. That I observed him doing all his jobs?
`6 Q. No. Have we talked about, have you told us
`7 all of the jobs you recall him performing at USX?
`8 Is there anything else you saw him do that we
`t haven't talked about?
`10 A. No.
`11 a Do you know if Mr. Stolich served in the
`12 military?
`13 A. No.
`14 a Do you know if Mr. Stolich was laid off at
`15 any point in his career at U.S. Steel?
`16 A. No.
`17 a Do you know if Mr. Stolich was ever on
`18 strike while --
`19 A. No.
`20 a -- he was employed at U.S. Steel?
`21 Do you recall, Mr. Williams, any outside
`22 contractors being present at U.S. Steel while you
`23 worked there?
`Page 49
`A. The boiler house was on -- really on the
`other side of the mill, located by some other
`batteries, not the batteries that we worked on.
`Because the batteries are located all throughout the
`mill.
`a Okay. Do you recall the names of any
`suppliers of materials or products to U.S. Steel?
`A. No.
`a Mr. Williams, have we now discussed all of
`the asbestos-containing products that you believe
`Mr. Stolich worked with or around at U.S. Steel?
`A. Best of my knowledge.
`a While you worked at U.S. Steel,
`Mr. Williams, did you ever wear any type of
`breathing protection, a dust mask or a respirator?
`A. A respirator.
`a You wore a respirator?
`A. Yes.
`a Okay. Do you know the type of respirator
`that you wore?
`A. No.
`a When did you first wear a respirator at
`U.S. Steel?
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`TYRONE WILLIAMS
`13 (Pages 46 to 49)
`marsiliocourtreporting. com
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`Page 50
`I A. A respirator is something they issue you as
`2 part of your uniform on the batteries when you work
`3 on the coke works.
`4 a So when you were working on the batteries
`5 as a utility man, you were wearing a respirator?
`6 A. Yes. Had to wear a respirator. If you
`7 didn't, you know, you could get written up. But you
`8 had to...
`9 Q. You first wore a respirator when you first
`10 worked on one of the batteries?
`11 A. That's part of the uniform, your
`12 respirator.
`13 a. Okay. So the first time you were up on the
`14 battery, you had a respirator?
`15 A. That's part of the uniform. Yes.
`16 a Do you recall seeing Mr. Stolich wearing a
`I7 respirator up on the battery?
`18 A. Yes. He -- yos, he had it. It was part of
`19 his equipment. I seen him, yeah, he had a
`20 respirator.
`2l a Okay. And when you were up there, you
`22 always wore it, right?
`23 A. Sometimes I took it off, yes.
`Page 52
`A. Just a couple.
`a. Okay. Do you recall the subject of
`asbestos ever being discussed af any of these union
`meetings?
`A. Not at the meetings I was at, no.
`a Do you recall seeing Mr. Stolich present at
`these union meetings?
`A. No, I can't say that I seen him. Because
`we were on different, you know, turns and
`everything. They had them listed for different
`times, you know.
`a. Do you recall receiving publications from
`the union?
`A. Yes. But I can't remember what they were.
`a And you can't then recall if any of those
`publications discussed the topic ofasbestos?
`A. I can't remernber ever getting anything
`about asbestos, no.
`a Do you know if Mr. Stolich received aîy --
`A. No,I don't.
`a -- of those publications?
`Do you recall safety meetings while you
`worked at U.S. Steel?
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`Page 5 I
`a Okay. I didn't ask you this: Were you a
`member of anyunion during your time at U.S. Steel?
`A. Yes.
`a. What union was that?
`A. The union, I can't recall the numbers or
`anlhing.
`a Steelworkers?
`A. Yes.
`a Can you tell us the dates when you were in
`the steelworkers union?
`A. I think after you got first 30 days or
`whatever, that you become a union employee.
`a. So sometime in 1975?
`A. Yes.
`a Do you know whether Mr. Stolich was a
`member of the union?
`A. Yes. Everybody in on the batteries were
`union.
`a The same union as you?
`A. Yes.
`a You just don't remember the local number?
`A. No.
`a Did you attend union meetings?
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`Page 53
`A. I think more the safety meeting or
`whatever, what unit you was with, your foreman, you
`know, he went over sometimes safety things, yeah.
`Not collectively like all the steelworkers, no, I
`can't remember a safety meeting like that.
`a. Okay. Did you ever attend a safety meeting
`wirh IvIr. Srolich?
`A. No.
`a While you worked at U.S. Steel Clairton
`Works, were employees permitted to smoke cigarettes
`on the job?
`A. No. I think in the lunchroom area, yeah.
`a. Generally speaking, do you know whether or
`not Mr. Stolich smoked cigarettes?
`A. I didn't see him smoking in the mill, no.
`I think after I left the mill, we, you know, became
`friends, I think I seen him smoke cigarettes before.
`a From your friendship with Mr. Stolich after
`you left U.S. Steel, can you provide us any
`information about any medical condition or medical
`treatments he went through?
`A. I can't remember him, like, being sick,
`whatever, but I remember him hurting his back, yeah.
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`724-869-7705
`TYRONE WILLIAMS
`l4 (Pages 50 to 53)
`marsiliocourtreporting. com
`Electronically signed by Sheila Rivers (601-407-888-8574)
`Marsilio Court Reporting Service
`6fae3ba 1 -48b4-4bd 5-9b98-af42a94dl¡941:
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`Page 58
`1 Q. And there are numerous ovens with each
`2 battery, correct?
`3 A. Yes.
`4 a What battery were you working with him at?
`5 A. At7 to 72battery.
`6 Q. Seven to 72?
`7 A. Yes.
`8 Q. Does that include 7 , 8, 9 , l0 , lI , 12?
`9 A. Yes.
`10 a And each of those batteries would consist
`1 1 ofmaybe 60,70 ovens within eachbattery, conect?
`12 A. Yes, because they had an A and a B series,
`13 and I think each series went up to the 30s, so it
`14 would be 60 something ovens, yes.
`15 a And the 7 to 12 batteries, were they the
`16 only batteries that you saw Mr. Stolich work on?
`17 A. Yes.
`18 a And they're the only ones that you worked
`19 on?
`20 A. Yes,7 to 12, yes.
`2l a Were the 7 to 12 batteries physically
`22 connectedto each other?
`23 A. Yes. They ran all the way down the one
`Page 60
`a He was always up top?
`A. Yes.
`a And you said that as a tar chaser, he kept
`the lines clean?
`A. Yes.
`a And he would do that byusing metal tools,
`correct?
`A. Yes. I used to see him with a tool, yes.
`a. And they were wrenches and whatever else
`was used, correct?
`A. And, like I said, there was, I think, a
`pick, too, but I don't know whatever tool he used
`to -- I guess to run off of the tar, whatever, I
`don't know what kind of tool.
`a The tar came from the emissions from the
`coke batteries, correct? This was the by-products
`ofthe coke process?
`A. I just know it just ran, you know, the
`line, the length, yes. I don't know.
`a Now, you said that Mr. Stolich, when he was
`up top, and you did when you were working on top of
`the batteries, had a certain uniform you had to
`wear?
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`Page 59
`1 roadway, yes.
`2 Q. And could you describe the size of the 7 to
`3 12 batteries? I mean, to give you a perspective,
`4 U.S. Steel Clairton Works is four acres in general,
`5 that's the size of the facility. Would lhe7 to 12
`6 batteries take up half of the facility?
`7 A. No. No.
`8 Q. Not?
`9 A. No. I would say 7 to 12 batteries would be
`10 like a couple city blocks, I mean, long, yes.
`11 a A1l right. And these coke batteries, 7 to
`12 12,they were large metal structures, correct?
`13 A. Yes.
`14 a They weren't movable in any wa¡ were they?
`15 You couldn't move them from one location to another?
`16 A. No. No.
`l7 a. And, to the best of your knowledge, coke
`l8 and carbon is a necessary ingredient in the
`19 manufacturing of steel, correct?
`20 A. Yes.
`2l a. You never saw Mr. Stolich work as a
`22 doorman, did you?
`23 A. No.
`Page 61
`1 A. Yes.
`2 Q. What was that uniform?
`3 A. You had to wear a yellow uniform that was
`4 flame-retardant, and it consisted of pants and
`5 jacket. You had to wear it at alltimes.
`6 Q. And you had to wear steel-toed shoes?
`7 A. Steel-toed shoes. And some of the jobs,
`8 because it was so hot up there, you had to wear
`9 wooden clogs over your metatarsals.
`10 a Because your shoes would melt?
`11 A. Burn up.
`12 a You also mentioned a respirator.
`13 A. Yes.
`14 a The entire time that Mr. Stolich was on top
`15 of the batteries, he was required, was he not, to
`16 wear a respirator?
`17 A. Yes. Everyone that was on the batteries
`18 were required to wear a respirator.
`19 a Could you describe that respirator for me,
`20 best you recall?
`21 A. A11I -- it was a metal respirator with a
`22 strap that went all around and, you know, just
`23 basically just covered your nose and your mouth,
`724-869-7705
`TYRONE WILLIAMS
`16 (Pages 58 to 61)
`marsili ocourtreporting. com
`Electronically signed by Sheila Rivers (601-407-888-8574)
`Marsilio Court Reporting Service
`6f ae3ba 1 -48b4-4bd5-9b98-af42a34db94b
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`CERTIFICATE OF SERVICE
`been sent via First Class Mail, Postage Prepaid and e-mail to plaintiff s counsel and notice of the same has
`been sent to all counsel of record via electronic mail.
`Respectfully Submitted,
`WILLMAN & SILVAGGIO, LLP
`One Corporate Center
`5500 Corporate Drive, Suite 150
`Pittsburgh, PA 15237
`412-366-3333
`BY: /s/ Edward O'Connell
`Edward O'Connell, Esquire
`Counsel for Defendant,
`Allied Glove Corporation
`
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