IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`CIVIL DIVISION -ASBESTOS
`
`f
`
`JAMES E, BARRICKMAN and MARY
`BARRICKMAN,his wife
`
`GD No. 19- 012857
`
`Plaintiffs,
`
`¥.
`
`AO, SMITH CORPORATION,et al.
`
`Defendants.
`
`Code: 012
`
`PLAINTIFF’S CONSOLIDATED
`
`RESPONSE TO ALL DEFENDANTS’
`PRODUCT IDENTIFICATION
`MOTIONS FOR SUMMARY
`JUDGMENT
`
`
`
`Filed on behalf of Plaintrffs
`
`Counsel of Record forthis Party:
`
`Cori J. Kapusta
`PA LD. #91958
`
`,
`
`Esquire
`
`L. Deihl, Esquire
`Holly
`PA LD. #94901
`
`KAPUSTA DETHL & SCHWEERS,
`LLC
`445 Fort Pitt Boulevard
`Suite 500
`Pittsburgh, PA 15219
`(412) 904-5080
`
`4
`
`VOLUME3
`
`

`

`
`ee
`
`JEROME SCHULTZ
`
`-
`
`VOLUME I
`
`IN THE COURT OF COMMON PLEAS
`
`ALLEGHENY COUNTY, PENNSYLVANIA
`
`JEROME
`
`an
`
`SCHULTZ,
`
`individual,
`
`Plaintiff,
`
`VS,
`
`CBS
`
`CORPORATION,
`
`et al.,
`
`)
`
`}
`
`}No. 02-15250
`}
`
`Defendants.
`
`}
`
`VOLUME I
`
`DEPOSITION O# JEROME SCHULTZ,
`
`Thursday,
`
`June 26, 2008
`
`10
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`ii
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`12
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`13
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`14
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`22
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`23
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`AUTHORIGATION FROM THE CERTIFYING AGENCY MARSILIO COURT REPORTING SERVICE
`
`COPY
`
`REPRODUCTION AND/OR DISTRIBUTION OUTSIDE
`OF THE LAW FIRM THAT PURCHASED THIS
`TRANSCRIPT IS PROHIBITED WITHOUT
`
`WRITTEN
`
`.
`
`1-877-728-6220
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`|
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`EXHIBIT
`
`D
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`

`ro 2
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`MeBM
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`Bob
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`JEROME SCHUMTZ - VOLUME T
`
`i
`
`IN THE COURT OF COMMON PLEAS
`PENNSYLVANIA
`ALLEGHENY
`
`COUNTY,
`
`JEROME SCHULTZ, an individual,
`Plaintiff,
`
`vs.
`CBS CORPORATION, et al,,
`Defendants.
`
`}
`}
`}No, 02-1525
`}
`}
`
`VOLUHE I
`DEPOSITION OF JEROME SCHULTZ,
`Thursday, dune 26, 2008
`
`REPRODUCTION AND/OR DISTRIBUTION OUTSIDE
`OF THE LAW PERM THAT PURCHASED THIS
`TRANSCRIPT IS PROHEBITED WITHOUT WRITTEN
`AUTHORI@ATION FROM THE CERTIFYING AGENCY
`
`HARSIEIO COURT REPORTING SERVICE
`L-877-720-G220
`
`WEROME SCHULTZ ~ VOLUME I
`
`3
`
`RPPEARANCES
`On behaif of the Plaintiffs;
`Carrie L. Furlan, Esquire
`Goldberg, Persky &
`White, F.C.
`103¢ Fifth Avenue
`PA 15219
`
`Pittsburgh,
`
`a
`
`on behalf of the Defendant CBS
`Corporation,
`Delaware
`corporation, £/k/a Viacom Inc.,
`successor
`by merger to CBS
`Corporation,
`Pennsylvania Corporation £/k/a Westinghouse
`Electric Corporation and General Motors:
`Erika L, Mullenbach, Esquire
`Eckert Seamang Cherin & Mellott, LLC
`U,§, Steel Tower, 44th Floor
`15219
`Pittsburgh, PA
`
`a
`
`On behalf of the Defendant Argo Packing Company:
`Deborah Tanaamorelli, Esquire
`ih
`Wimer Law Offices, P.C.
`655 Allegheny Avenue
`Oakmont, PA i5149
`
`MARSILIO couUaRT REPORTING SERVICE
`L-877-726-6220
`
`wmwerSeNTOeweBwYPGS
`BOOMBobboRBBBboboe
`werePomhkweamMonmhtimF
`NNNNDPPPPPePpPE
`
`
`JEROME SCHULTZ — VOLUME Zz
`
`a
`
`DEPOSITION OF JEROHE SCHULTZ,
`taken pursuant to the Pennsylvania Rules of civil
`Procedure,. before Marlanue Marsilio, Reglaterad
`Professional Reporter-Notary Public 1n and for
`on
`the Conmonwealth of Pennsylvania,
`Thursday,
`June 26, 2008, at the offices of Goldberg, Persky
`&
`White, P.C., 1030 Fifth Avenue, Pittsburgh,
`PA
`at 1:30 o'clock p.m.
`15219, commencing
`
`1-877-720-6220
`
` MARSILIGO COURT REPORTING SERVICE
`15213 MARSELIO COURT REPORTING SERVICE
`
`JEROME SCHULY2 ~ VOLUME I
`
`.
`
`4
`
`On behalf of the Defendants I,U, North America
`and Certain-Teed Corporation:
`Yonl &. Capelli, esquire
`Wilbraham Lawler & Buba
`Two Gateway Center, 17 North
`PA 15222
`Pittsburgh,
`
`On behalf of the Defendants George V. Hamilton,
`Inc,, Stockham Valves &
`Pittinga:
`Jason M. English, Esquire
`Willman & Arnold, LLP
`705
`Park Drive
`McKnight
`Pittsburgh, PA 15237
`
`On behalf of the Defendant Cashco:
`Willian J. KePartland, Esquire
`Maxshall, Dennehey, Warner,
`Coleman &
`Goggin
`2900 U.S. Steel Tower
`PA
`
`Pittsburgh,
`
`1-877-728-6220
`
`
`
`
`
`

`

`BMNMNMHRroboFoftbPoPoRReWhHMOowewmoPbhPS
`
`wnaAneww
`oOomatohinomletoop
`et
`wnPoweewdHhiteseWwhwYP
`BFBDBOBSRRRetotter
`
`*
`
`JEROME SCHULTZ ~ VOLUME T
`
`5
`
`On behalf of the Defendant Eaton Corporation (via
`telephone}:
`Rebecca Williams, Esquire
`Goldberg, Miller & Rubin, P.C;
`121 South Broad Street
`.
`Suite 1500
`
`Philadelphia,
`
`PA 19107-4534
`
`behalf of the Defendant Crane Co,;
`Hegan E. Smith Mliler, Esquire
`Gates
`Kah
`Henry W. Oliver Building
`535 amithfleld Street
`Pittsburgh, PA 15222
`
`On behalf of the Defendants Eichleay, M.8.
`Jacobs, and Minnotte:
`Ryan H, Krascanko, Esquire
`fimmer Kunz
`3300 0.8. Steel
`
`Building
`
`Pittsburgh,
`
`1-877-728-6220
`
`JEROWE SCHULTZ - VOLUME &
`
`7
`
`.
`
`behalf of the Defendant The okonite Company:
`Walter L. McDonough, Esquire
`Swartz Campbell
`fuo
`Tdberty Place, 28th Floor
`50 South L6th street
`PA 19102
`
`Philadelphia,
`
`On behalf of the Defendants F. 8. wright of
`Pittsburgh, Hunter Sales Coxporation, Goulds
`Pumps, and Triangle Wire & Cable:
`Hal DB, Coffey, Esquire
`Grogan Graffam
`Four Gateway Center
`22th Floor
`
`Pittsburgh,
`
`PA 15222
`
`Beazer Bast, Theim,
`
`On behalf of the
`Defendants
`INC, and
`Treco;
`Matthew 0. Galley, Esquire
`Pletragallo Gordon Alfano Bosick &
`38th Floor One Oxford Centre
`
`Raspanti
`
`1-877-728-6220
`
`a
`ee
`ad
`eeee
`
`JEROME SCHULTS - VOLUHE I
`
`&
`
`On behalf of the Defendant Safety First
`Industries:
`Banialle G. Barozzini, Esquire
`Maron Plerce, LEC
`Landmarks Building, Suite 256
`15219
`Pittsburgh, PA
`
`On behalf of the Defendants Martin Marietta,”
`Fabri Valve, Nagle Pumps, Atlas Industries,
`inc.,
`and J.M. Foster:
`Any J. Brinkos, Zaquire
`Dickle, NeCamey & Chilcote
`Two PPG Place, Suite 400
`PA 15222
`Pittsburgh,
`
`On behalf of the Defendants Allied Glove
`Corporation, and Dravo:
`James Traficante, Require
`Swartz Campbell
`‘4750 U.S, Steal Tower
`Pittsburgh, PA 15219
`
`MARSILIO COURT REPORTING SERVICE
`i-877-728-6220
`
`JERGME SCHULF2Z ~ YVOLUHE I
`
`8
`
`On behalf of
`the Defendant Sepco:
`James §. Ehrman, Esquire
`Margolis Edelstein
`535 William Penn Place
`Suite 3300
`Pittsburgh, PA 15219
`
`On behalf of the Defendants Powar
`Inc.
`(via telephone}:
`Sealite,
`Erie Santos, Esquire
`Bailey, Riley, Buch & Hayman
`Post Office Box 631
`Wheeling, WV 26003-0081
`
`Piping,
`
`and
`
`on behalf of the Defendant Riley stoker
`Corporation:
`Kathryn &. Johnston, Esquire
`Reed, Luce, Tosh, Wolford & Douglass
`804
`Street
`Turnpike
`Beaver, PA 15009
`
`MARSILIG COURT REPORTING SERVICE
`1-877-728-6220
`
`oooatchtneotoot
`wnFtoOWwWFFSHOewweK
`weweeOoWwWSBSHOewwNRRe
`HinSeteWwPI
`wees
`
`
`
`
`
`
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`
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`
`
`PA 15219 HAREILIO COURT REPORTING SERVICE
`Pittsburgh, PA 15219 MARSILIG COURT REPORTING SERVICE
`
`

`

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`uwPreoWwwasGHOe&BP
`Pe
`ASeWwBe
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`woes
`
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`
`JEROME SCHULTZ ~ VOLUHE &
`
`3
`
`WITNESS:
`
`JEROME SCHULTA
`
`BRAMINATION BY:
`MS. MULLENBACH
`
`EXHIBITS:
`None.
`
`1-877-728-6220
`
`JEROME BGRULTZ - VOLUME 7
`
`ii
`
` MARSILIO COURT REPORTING SERVICE
`Correct. MARSILIO COURT REPORTING SERVICE
`
`over each other.
`We need to not speak
`ff
`you could, walt to answer until I'm done asking you
`and 1/11 wait for you to finish,
`the
`question,
`IE you don't understand something, please
`know, and I can
`let me
`If you don't kuow
`repeat it.
`the angwer to something, you cap say I don't know,
`us
`and that's fine. “If you need a break,
`just let
`know. Okay?
`Can you state your full name for the
`record, please.
`A.
`derome R. Schultz.
`@. What's the R stand for?
`.
`A.
`Raymond.
`Do you currently live at 4027 Inland
`Q.
`Avenue
`A.
`@.
`digits of
`A.
`
`Correct.
`--
`in West Mifflin? And the last four
`Social Security number are 23947
`your
`Correct,
`You were born January 22, 1945?
`Correct.
`And that sakes you 63 years old?
`
`--
`
`1+077+728-6220
`
`JEROME SCRULTZ ~ VOLUME £
`
`16
`
`PROCEEDINGS
`(1:57 o'clock p.m.}
`.
`JEROME SCHULTZ,
`been first duly sworn, was
`the witness, having
`deposed and testified as follows:
`BXANINATION
`
`£111 be
`
`BY HA. MULLENBACH:
`Sir, my name is Erika Mullenbach,
`@.
`asking most of the
`questions.
`A.
`You talk too fast.
`I'll glow down,
`Q.
`And I'm hard of
`“A,
`hearing.
`I'1L slow down and 1/11 speak more
`Q.
`Okay.
`slowly and speak up.
`Have you ever been deposed before? Have
`a group of
`you ever been asked questions by
`attorneys?
`A,
`No.
`some ground
`E's just going to explain
`@.
`rules, Basically you're under oath as if you were
`You need to respond verbally, yes, no.
`in court.
`No huh-uhs or uh-huhs, head shakes, nothing like
`
`L+O77-728+6220
`
`JEROHNE SCHULPZ -—
`
`VOLUMR X
`
`Ja
`
`g.
`A.
`
`How long have you been ak that Inland
`Q.
`Avenue address?
`A.
`Almost four years,
`Do you own that home?
`‘Yes.
`Is there an
`@.
`outstanding mortgage?
`No, it's paid off now.
`A.
`Q. Where did you live before this Inland
`Avenue address?
`A.
`Rankin, Kenmore Avenue.
`Do you know the house number?
`607,
`How long did you live at the Kenmore Avenue
`
`that. HARSILIO COURT REPORTING SERVICE
`How long did you live there with your mom? MARSILIO COURT REPORTING SERVICE
`
`0.
`Au
`@.
`address?
`A,
`Q@.
`A.
`
`Maybe two years.
`Did you own that home?
`No, my wife's parents did.
`Where did you live before the Kenmore
`,
`@.
`Avenue home?
`A. With my mother,
`What was her address?
`Q.
`A,
`217 Sixth Street, Braddock.
`
`Q.
`
`LeS77-728-6220
`
`
`
`
`
`
`
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`
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`
`
`

`

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`OeawsFotomeHome&MH©
`NMMMPPPeeebeoppebe
`wenYFSeDeweoOWePesehc
`wowwRwseAPewwhe
`
`Almost 21 years.
`A.
`to
`Have you ever done any home
`Q.
`remodeling
`the Inland Avenue address that you live in now, any
`roofing work, any interior renovations?
`A.
`No, nok really.
`What about the Kenmore Avenue address, did
`Q@.
`you do any renovatloa?
`A.
`It wasn't my house,
`What about your mom's home on Sixth Street,
`Q.
`did you ever do any home remodeling?
`A.
`No. Wo,
`Are you currently married?
`Divorced.
`When did you divorce?
`About 15 years ago.
`What was your wife's name?
`RoseMaxie.
`What was her maiden name?
`Busco (phonetic).
`Did your wife smoke?
`No, not really.
`How many times have you been married,
`
`'
`
`1-877-728-6220
`
`EROME SCHULTZ - VOLUME 7
`
`15
`
`.
`
`just MARSILIO COURT REPORTING SERVICE
`Did she smoke? MARSILIG COURT REPORTING SERVICE
`
`No.
`When did he pags away?
`--
`15 or 20 years.
`i would say 15
`staybe
`How old was he when he passed away?
`About 65.
`Do you know what he died From?
`Old age,
`Did your father smoke?
`He smoked off and on, Marlboro cigarettes,
`Marlboro tobacco, something.
`Did he smoke when you were
`Q@.
`the home?
`A. wasn't there,
`running around,
`What was your mother's nage?
`Clara.
`Is she still alive?
`‘
`No.
`When did she pass away?
`Before my dad.
`How old was she when she passed away?
`She was abouk 67.
`
`growing up in
`
`I was in the mill or
`:
`
`L-B77-7290-8226
`
`JEROME SCHULTZ - VOLUME 1
`
`13
`
`JEROME SCHULTZ ~ VOLUME I
`
`l4
`
`mnoebhhe
`osePOwpowRewDe
`wes
`weMReeOotemMemOeONOS
`
`AieWwNM
`wen
`
`RAfepd
`BOONOROReheR
`BeeMBPPEeeMepeptBe
`
`One,
`Bo you have any children?
`Yea,
`I'm assuming it's a son, Terry Schultz?
`Yes.
`How old is Terry?
`I make him about 36,
`Does ferry smoke?
`No.
`Loes he have any kind of health problems? .
`None that I know,
`Did he ever have cancer?
`No,
`Any breathing problems?
`Huh-wh,
`Bid you ever work with Terry for pay for a
`
`Yes, your gon Terry.
`No.
`What's your father's name?
`Frederick.
`Tg he aliva?
`MARSILIG COURT REPORTING SERVICE
`1-877-728-6220
`
`job, did you ever work with him to make money? Ry son?
`AL
`
`JEROME SCHULTZ —
`
`VOLUME I
`
`16
`
`No.
`What did she pass away from?
`Diabetes.
`Did she ever have any cancer?
`No,
`Any heart problems?
`Her diabetes.
`Besides diabetes, Any breathing problems?
`ox
`Did she have any reaplratery
`breathing problems?
`Ay
`No.
`How about your father, did he ever have
`Q.
`cancer?
`A,
`
`No.
`
`Q.
`A,
`
`Q.
`
`or
`‘
`Any respiratory
`breathing problems?
`None that I know of.
`Did you ever work with your father for pay?
`Wo.
`Did you ever work with your mom?
`.
`No,
`Do you have any brothers or sisters?
`Yes.
`How many byothars or gisters do you have?
`Two sisters and four brothers.
`MARSILIO COURT REPORTING SERVICE
`L-a??-728-62206
`
`
`
`
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`
`
`
`
`

`

`WoeweAinieImF
`WwePrPSSWwweaHNeYhee
`AinS&WwHy
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`wroaow
`
`ee
`
`i
`
`
`
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`wMMwoweMmemoFSeWwhroS
`NMMMHeEPEPReBeee
`WwaTOoUEmmLoBDit
`BwBFRebrbebopoeroreooRob
`wwHPSPowHWSeWYhwFPOo
`
`JEROME SCHULTZ
`
`— VOLUME I
`
`17
`
`What are the names of your sisters?
`Dolores and Bernadette.
`Is Dolores still alive?
`Yea,
`bid she have any health
`problems, any
`cancer, respiratory problems, heart problems?
`A.
`Idon't know.
`She lives in Delaware.
`bid you ever work with Dolores?
`g.
`A.
`No.
`Bernadette, is she still alive?
`.
`¥es.
`Does she have any health problema?
`:
`;
`Nok that ft know of.
`bid you ever work with her for pay?
`;
`Wo.
`What about, you said you had four brothers.
`me the names of your brothers, please?
`you give
`A.
`Rudolph, me, Jerome, Anthony, and Paul.
`Is Rudolph still alive?
`No,
`When did he pass away?
`About seven years ago.
`Bo you know
`
`1-877-728-6226
`
`-- HMARSILIO CQURT REPGRTING SERVICE
`Basic electric shop, machine shop, auto MARSILIO COURT REPORTING SERVICE
`
`JEROME SCHULTA
`
`-
`
`VOLUME T
`
`13
`
`bid you ever -work with Anthony?
`.
`Na.
`Now, Paul, is he still alive?
`.
`Yas,
`Does ha have any keaith problems?
`None that I know of,
`bid you ever work with Paul?
`Huh-uh.
`Is there any history of cancer or
`or heart problems in your
`respiratory problews
`family besides the diabetes?--
`
`the diabetes goes to the heart.
`A, would
`So I would say diabetes led to a heart, whatever.
`You graduated nigh school, correct?
`Q@.
`As
`yes.
`Did you take any collega classes
`@.
`afterwards?
`A.
`No. Vocational school.
`Twas just going to ask you, where did you
`Q@.
`go to vocational school?
`A.
`Braddock High School.
`What were you studying?
`
`Q.
`A,
`
`‘
`
`1-87 7+728~-6220
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`
`
`
`
`
`
`JEROME SCHULTZ - VOLUME I
`
`.
`
`16
`
`Let's see, Hold on,
`
`I make it seven
`
`Do you know what he died from?
`Diabetes.
`How old was he when he died?
`
`--~-
`
`FLEty-seven.
`Did you ever work with Rudolph for pay?
`No, No.
`--
`I think you sald Jerome
`That's me,
`I thought you had
`That's you.
`-MR. EHRMAN; Anthony.
`Is Anthony still alive?
`Yes, Anthony.
`Same thing.
`No, he's dead.
`Diabetes?
`Yes,
`How old was he when he passed away?
`He was about maybe 53 or something.
`hold it. Yeah, he's been dead a
`speil.
`--
`Did you
`Q@
`it might be 57 to 56 or
`A.
`Eamight be wrong.
`He was one year uader me, But itts been
`something.
`like five or six years or Ho.
`
`--
`
`He
`
`| MARSILIO COURT REPORTING SERVICE
`Many years do you guess? MARSILIG COURT REPORTING SERVICE
`
`1-877-728-6220
`
`JEROHE SCHULTZ
`
`-
`
`VOLUME I
`
`20
`
`and carpenter shop.
`shop, drafting,
`.
`What was that?
`Carpenter shop.
`then did you take these vocational classes?
`Sophomore, and when I vas a
`junior.
`When you were in high school?
`Yeah.
`bid you take
`anything else besides these?
`bid you take anything after your time at Braddock?
`A.
`No, No.
`Have you ever smoked?
`Off and on. Weekend warrior.
`When did you atart smoking?
`15 years ago, 20.
`Maybe
`When did you stop smoking?
`@.
`A.
`Twenty years ago, something like that.
`i5 years ago.
`So you smoked for about five years?
`@.
`off and on:
`A.
`I
`Stopped, quit,
`--
`smoked
`Le wasn't no
`habit, just charisma, you
`stopped
`look at me, 1'm smoking.
`know, kids charisma,
`About how long did you smoke, about how
`@.
`
`@.
`A.
`@.
`A.
`
`oh,
`
`A-AT7+72B+6220
`
`

`

`JEROME SCHULTZ
`
`-
`
`VOLONE I
`
`a1
`
`JEROME SCHULTE - VOLUME £
`
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`I'd say off and on ten years,
`What did you smoke?
`I started out with Mariboros.
`--
`Filtered or
`Pardon me?
`Filtered or unfiltered?
`Filtered,
`About how many packs per day did you smoke?
`I never went to a
`I jost them.
`pack.
`Bid you ever smoke cigars?
`No.
`Chewing tobacco?
`No.
`Did you ever serve in the
`No.
`Were you ever drafted?
`No,
`It says here that you were
`Army in 1963 due to a double hernia,
`correct?
`A.
`Right,
`@. I going to go into your work
`
`rejected by the
`is that
`
`now.
`
`history
`
`:
`
`military?
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`L-B7T-728-6220
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`JEROME SCHULTZ - VOLUME
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`a3
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`Couple hours a day. Wait.
`
`A couple hours
`
`probably
`
`weekends?
`A.
`a week.
`working there, ag a
`Q. Wher did you start
`freshman in high school, before?
`that was later on. That waa
`A,
`Wo,
`the end of my sophomore year.
`What about the chicken atore, when did you
`@.
`Btart working there?
`A. Weekends.
`Did you start when you were a freshman or
`Q@,
`.
`Later?
`A.
`
`later on, senior.
`No,
`Do you believe that any of your work as a
`@.
`janitor exposed you ko asbestos?
`Ae
`No,
`Q. After high school, what was your first job,
`where did you work?
`Et was either the mill or the Army,
`A,
`Army rejected me, so I went to the mill.
`So you went to the mill around 1964. Does
`@.
`that sound right?
`A.
`
`‘The
`
`wMeSStewmaoHinelsfkOeOa
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`Did you work at all during high school, any. kind of MARSIGIO COURT REPORTING SERVICE
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`Yeah. MARSILIC COURT REPORTING SERVICE
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`
`
`
`
`
`
`jobs?
`A,
`Janitor,
`Q@. Where were you a
`janitor?
`A, Miller's Drugstore and day's Restaurant in
`Braddock, and the chieken store, Samboli's
`(phonetic) .
`Was this for all four years of high school?
`Q.
`was
`A.
`No, weekends. Except
`the drugstore, I
`there two hours a day.
`So the drugstore you were there two hours a
`Q.
`day even
`during the week?
`A,
`Yes,
`Even during school?
`0.
`A.
`Yes.
`Bid you start working at the drugstore when
`@.
`you were a freshman or was it later on in high
`achool?
`A.
`
`Freshman.
`Did you work Ehere before you were a
`
`Wa.
`And the Jay's Restaurant,
`couple houra a
`work there, was ik a
`
`how often did you
`or
`day
`just
`
`@.
`freshman?
`A.
`
`1-877-728-6220
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`JEROME SCHULTZ —
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`VOLUME TI
`
`.
`
`24
`
`Q. Which mill was this?
`A.
`Edgar Thomson in Braddock,
`What was your first position when you
`Q.
`started at Edgar Thomson?
`A.
`Helper in the foundry,
`MS, BAROZZINI:
`Elm sorry, where?
`THE WETNESS: Helper in the foundry.
`BY MS. HULLENBACE:
`How long were you a
`two years.
`About
`fo until abouk 1966?
`Yeah, something Like that.
`What were your job duties as a helper?
`General laborer, cleanup, ix mud, set
`molds. Actually, anything they wanted ma to do,
`had to do ik,
`This was in the foundry, it was one
`@.
`-hat you were in?
`One big building, about a
`city block.
`Do you believe that any of your work as a
`Q.
`helper exposed you to asbestos?
`A.
`Ob, yeah.
`
`helper in the foundry?
`
`I
`
`,
`
`building
`A.
`
`the MARSIEIO COURT REPORTING SERVICE
`Q. Which products do you belleve you were MARSILIG COURT REPORTING SERVICE
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`LH877~728~-6220
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`SERONE SCHULTZ
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`-
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`VOLUME I
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`a5
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`JEROME SCHULTZ
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`-
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`VOLUME £E
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`26
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`A.
`
`I was too young.
`No.
`was there any other
`Besides the mud,
`@.
`products you believe exposed you to asbestos during
`this time as a
`helper?
`--
`fell, later on
`A,
`Are we still talking about this time when
`@.
`you were a helper?
`.1I moved up to the craneman and ali
`A.
`Yeah.
`that. But before that, okay, right alongside the
`mad mixing box was the ovens.
`They called them
`ovens.
`That's where they used to bake the cores.
`--
`that was fuli of asbestos
`And they used to
`bricks. Bricklayers used to come in and rebrick
`thew, put insulation around the doors,
`like big
`planks like this and saw them up with carpenter
`saws. And then I went into the crane.
`let's talk about these
`bricklayers. Did
`Q
`ever
`lay brick or were you just around
`you yourself
`people doing this work?
`’
`TY used to mix the mud.
`A.
`Do you believe the bricks contained
`@.
`asbestos?
`A,
`
`4
`
`imagine they did.
`
` MARSIEEO COURT REPORTING SERVICE
`Whatever they did there, MARSILIO COURT REPORTING SERVICE
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`1-877-728-6220
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`FEROME SCHULTA
`
`- VOLUME I
`
`.
`
`28
`
`A. Well, it was all different.
`It was where
`they wanted to put you.
`I was under the Manning
`Act.
`‘That's like you had
`Remember the
`Manning Act?
`so many white people.
`to have so many black people,
`And I think they used to call me
`I was
`whitey,
`one in there,
`about
`the only
`--
`dust so I understand, you say
`Q.
`--
`A,
`wherever they
`‘wo years, ail part of
`sent me.
`They told me I had to go to shakeout
`--
`today
`or you go mlx mud or you go sei molds ox
`I just want to make sure I understand.
`so
`Q.
`the two years you were a
`helper, you also worked in
`the shakeout hole?
`A,
`Yeah, Right,
`wherever they sent me.
`Was the shakeout hole in the foundry?
`Q.
`A.
`Yeah,
`What about the shakeout hole do you believe
`@.
`exposed you to asbestos, what about your work there?
`A, Well, we used to take the flask apart and
`get the ingot out,
`then put
`the flask back together
`them in the shower to cool them down.
`and then put
`But the ladles were there,
`the ladle liners.
`too,
`
`L+ B77 9728-6220
`
`
`
`
`
`
`were
`
`exposed Eo?
`A.
`Pardon me?
`Q. Which products do you believe you
`exposed to that contained asbestos?
`When I started mixing that mud,
`A.
`they used
`that to put
`the stools together, you know, put the
`flask on.
`I mixed that and set mud, And it was
`‘
`asbestos.
`How often did you mix this mud?
`Q.
`A. When-they told me.
`Sometimes it wouldn't
`or when it was my turn.
`be for three or four days
`FE somebody didn't come back or
`on ug or
`quit
`they told me to go and mix mud.
`something,
`Over this two-year period, did you have to
`Q.
`--
`nix mud every week? Was it
`It was every week.
`Was it once a week, multiple times a week?
`Sometimes all week, sometimes twice a week.
`You said you mixed the mud, Was it from
`--
`like a container ox
`or
`A.
`Cement bag
`bags, whatever.
`Do you know the name brand, manufacturer or
`of thia mud,
`
`g.
`
`supplier
`
`£~-8 797-729-6220
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`JEROME SCRULTZ -
`
`VOLUME I
`
`at
`
`Q.
`
`or
`
`Bo you know the nawe brand, manufacturer
`of the bricks?
`supplier
`--
`A.
`I used to always remember that K
`that
`wag in pallets, and they had that %-A-Y-L-T-0 or
`‘they had a
`something like that,
`big piece of white
`It was in paljets.
`paper inside of it.
`You said you believe the insulation around
`Q.
`the doors contained asbestos?
`Yeah. That was
`A.
`planks.
`saw.
`them up with the carpenter
`And do you know the name brand,
`@.
`manufacturer ox
`supplier of this insulation?
`I can'e answer that.
`A.
`in your time as a helper, any other
`@.
`products that you believe exposed you to asbestos,
`--
`anything you worked around or
`A.
`When 1 used to work in the shakeout hole,
`they used to line the ladles. They used to Line
`the stoppers for the iron and
`them with bricks,
`that. hey used to dump the ladles owt right where
`Then a bulldozer would
`we shook out
`the ingots.
`come in and scrape it all out
`the next day.
`@.
`
`this cement that you used? HAREILIO COURT REPORTING SERVICE
`How long aid you work in the shakeout hole? MARSILIO COURT REPORTING SERVICE
`
`They used Eo saw
`
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`GERGHE SCHULTZ - VOLUHE I
`
`23
`
`That's where the iron was
`being put in to.
`Those
`guys would jackhammer them insides there and take
`them and dump them into where we shook out the
`.
`molds.
`
`Then every day, at the end of the turn,
`the
`bulldozer would push it outside, and Ehen they would
`load it on trucks or cars and then we would start
`all over
`again.
`so I understand, do you helieve the
`So
`@.
`just
`-~-
`ladie liners exposed you to asbestos?
`E'm trying
`A.
`Isat there and ate lunch with them.
`NS. FUREAN: She's asking what types of
`products the ladle liners were
`using,
`They used that brick, K-A-Y-T-0 or
`A.
`li-9,
`something,
`So you believe you were exposed to asbestos
`Q@.
`and bricks. Was there any other praducte?
`A.
`‘they used to jackhammer the bricks out of
`the ladle, stake Ehe stoppers and all that.
`Anything else besides the brick that you
`Q.
`believe you wara
`exposed te asbastos?
`They used to smear that mud on the ridge,
`‘A.
`
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`JEROME SCHULTZ
`
`— VOLUME F
`
`31
`
`I couldn't answer’ that.
`So 1966 you went ko work on the cranes?
`Yes,
`Did your job title change?
`My whak?
`Your job title. Were you a
`
`helper still or
`
`I was a craneman,
`No,
`How long were you a craneman?
`two years or
`About
`something.
`About 1968?
`Two years,
`two-and-a-half years.
`Where were you a craneman, what part of the
`
`on the zim. MARSILIO COURT REPORTING SERVICE
`§&0, MARSILIO COURT REPORTING SERVICE
`
`thing.
`
`i was still in the same
`in the foundry?
`--
`I was on che
`But E wad
`That's where they rammed the ingots
`or make the wold,
`take the ingot
`What were your job duties as a craneman,
`Q.
`what ware you doing?
`the process was started all over
`A. Well,
`and they would make the mold up again.
`again,
`
`ranming slide,
`--
`che molds to
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`JEROME SCHULTZ - VOLUME £
`
`36
`
`‘This was in the shakeout hole?
`@.
`A, And on the top of the ladle.
`‘They used to
`alx it down there and seal off the brick with the
`iron so that when they poured the iron in the ladle
`the ladle wouldn't melt.
`.
`Do you know the name brand, manufacturer ox
`Q.
`supplier of this mud that you mixed?
`A.
`i can't remember that. That's the same mud
`I mixed for the stools.
`Anything else that you believe you vere
`@.
`exposed to asbestos during thia time as a
`helper?
`You said you worked in the oveas, you mixed mud, you
`set molds, you cleaned, you were a
`general laborer,
`else?
`and you worked in the shakeout hole.
`anything
`A.
`That's about it.
`Then I went up in the
`.
`cranes,
`
`So in about 1966 you went up into the
`
`that you know of? MARSILIO COURT REPORTING SERVICE
`peliave you were exposed Lo at this time? MARSILIO COURT REPORTING SERVICE
`
`f.
`cranes?
`A.
`Yeah, about
`something like that,
`When you were a heiper, do you remember any
`Q@.
`o£ youx co-workers? Are any of them stili alive
`
`two years,
`
`two and a half,
`
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`JEROME SCRULT2 —- VOLUME IE
`
`32
`
`they had a
`big round table, and the guy would ram
`this sand and mud, whatever Ehat stuff was, around
`it, and then I would pick it up and push it in the
`oven,
`Q. Were you in at crane cab or crane cap?
`A,
`Crane cab.
`8o you were in the crane cab and the crane
`Q.
`would pick it up and move it?
`A,
`Right.
`Do you believe you were
`Q.
`when you were a Craneman?
`the whole place was
`A. Well,
`scrape it out of your eyes,
`Where do you think that dust came from?
`Q.
`‘The basic product that the mili was
`A.
`making.
`Can you name any specific products that you
`@.
`believe contained asbestos that you worked around or
`hands on with at the time you were a craneman?:
`A,
`Twas away from that then, but I want up
`--
`like 50 feet in the air, and you could see all
`you can see the mist.
`Bub you can't name any products Ehat you
`Q,
`
`exposed to asbestos
`
`dusty. You can
`
`1-877-728-6220
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`
`
`
`
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`

`VERONE SCHULTZ
`
`- VOLUME
`
`33
`
`JEROHE SCHUL?R - VOLUME FE
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`34
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`Then they MARSILIO COURT REPORTING SERVICE
`
`A.
`Wo. Ne,
`How often were you 50 feet in the air? Did
`Q@.
`you spend moet of your day up there?
`A. Well, sometimes eight hours,
`ten hours,
`--
`ox 19 minutes.
`half hour break for lunch
`So you can't name any specific products at
`@
`this time?
`A.
`No,.
`After you were a craneman in 1968, what was
`Q@.
`your job bitle?
`I told them I
`A. Welk, when ¢ signed in,
`wanted to be part of the maintenance and that.
`so
`--
`me a
`an
`not a
`job app
`they got
`job application,
`interview over at ukilities.
`‘And I went over there
`interview, and I become a laborer over
`and I got an
`there,
`So you became a laborer. What building
`@.
`were you in?
`A.
`Sterling boilerhouge.
`were you a laborer in the sterling
`How long
`Q.
`bollerhouse?
`I'd say almost a year or
`A,
`--
`know, it wag a
`graduating
`
`something. You
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`JEROME SCHULTZ ~- VOLUME I
`
`35
`
`What did you do om the ground floor? What
`@.
`were your job duties down there?
`A.
`clean up.
`They used to shovel
`Bagically
`the ashes out, and I would shovel them in hoppers
`and they would haul them away.
`Did you work on Ehe second floor then,
`too?
`@.
`Yeah, hat was the
`A.
`firing floor, That's
`where we had to report to work in the morning,
`on any of the other
`Were you working
`Q@.
`floors, Ehe other three Floors?
`The other ones above were the boilers and
`A.
`that. And if a boiler was down, you had to break
`the brick out and
`and go into the boiler
`everything
`the clinkers and the clunkers and bust
`and pick out
`them up and throw them down so
`they could get rid of
`them,
`—
`How often did you break
`Q-
`the brick
`these boilers?
`When here was a boiler outage,
`I would
`A.
`~~
`--
`thexe was ona,
`two, chree,
`four, five
`say
`there was five boilers in there.
`So I'd say maybe
`every six weeks,
`‘Then we'd stay in there for,
`like,
`ten
`days, and then brick it back up,
`°
`1-877-728-6229
`
`out of
`
`,
`
`it, you know what I mean, if I could handle the
`job,
`They gave me the worst
`jobs.
`So what were some of your job duties for
`Q.
`this year when you were a laborer?
`A.
`Basic things. Clean up,
`Clean up. Anything else?
`Q@,
`A,
`Blow soot, going in the boilers and
`cleaning them out.
`Do you believe you were
`exposed to any
`Q.
`asbestos during this time as a laborer?
`A.
`the ground floor, that's where they
`fell,
`used to keep that brick,
`What brick?
`@.
`KeA-¥-3-0, 1-0, or
`A.
`something.
`So this was where they stored it?
`Q@.
`--
`It was stored
`the bottom was like a
`A.
`storage house, and the boilers were above. This is
`a
`now.
`pretty big building
`§So, how often did you work on Ehis ground
`Q@.
`floor?
`I can't answer that, because we was all
`A.
`over that place,
`too. There was five Floors in
`
`1-877-728-6220
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`JEROME SCHULPZ - VOLUME IT
`
`36
`
`@.
`took out?
`Because you could see that.
`A.
`label with red jetters inside on it.
`cellophane baq.
`But that's the brick you put
`Q.
`A, Well,
`
`L+O77-728-6226
`
`It had a white
`it was ina
`
`in?
`
`
`
`
`
`-
`
`there. MARSILIG COURT REPORTING SERVICE
`that's the ones we carried up, and MARSILIO court REPORTING SERVICE
`
`.
`
`in?
`
`would have another one out, and we'd go down there
`over
`and do the same
`thing.all
`again.
`You took the brick out. Did you ever
`Q..
`install the brick back in?
`Sometimes I mixed the
`A.
`Sometimes I had to.
`--
`mud. Only the
`bricklayers put the brick in
`--
`Sa you didn't
`Q.
` --
`A.
`back chen.
`So you took the brick out, but you didn't
`Q@.
`actually put the brick
`A.
`No,
`You said you mixed the mud though?
`@.
`A.
`Yeah. That was.laborer jobs.
`Do you know the name brand, manufacturer or
`Q.
`supplier of the brick that you took out?
`‘hat K-A-Y-L-f-0 or
`A.
`something,
`How do you know it was that brick that you
`
`

`

`JEROME SCHULTZ
`
`~ VOLUME 1
`
`37
`
`JEROME SCHULTZ - VOLUME I
`
`34
`
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`If they had to do work
`that's what
`they put in,
`inside the bollers or
`something, we would break it
`all out, and they would brick that up. Hot
`spot
`they calied it,
`‘The brick though that you took out of the
`Q@.
`boiler, you don't know who manufactured that brick,
`you just took it out?
`-»
`na,
`A.
`Wo.
`7
`But the brick that you carried up, which
`Q.
`--
`the name brand, manufacturer ox
`,
`supplier
`A.
`Yeah,
`«+
`=
`Wag
`
`ox
`
`something. Kayto or
`
`K-A-¥-L-T-0
`something.
`You didn't work hands on with that brick
`@.
`that they were
`installing, correct?
`I passed the brick or stacked the
`A.
`No.
`‘That wags a laborer's
`brick for the bricklayers.
`they did was set the brick.
`,
`I mixed the
`job. All
`mud,
`
`Q@.
`A,
`
`@.
`
`supplier
`A,
`
`Do you know the name brand, manufacturer or
`of the mud that you mixed?
`
`1-877+728+6220
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`JEROME SCHULTZ ~
`
`VOLUME I
`
`33
`
`engines in
`
`‘That was in No.
`2 powerhouse right next
`A.
`door to sterling bollerhouse,
`How Long were you in pump and
`Q.
`the No, 2
`powerhouse?
`A, Well, that's where i staxted my
`I staxted dolng mechanical work and
`apprenticeship.
`i was a pump and
`engine helper for about
`that,
`or
`ten
`‘Then you graduated
`something.
`maybe
`years
`up, handyman, general pump and
`engine repaizman.
`Let's stick with what you were
`doing in
`@.
`How long were you a helper then in the No.
`1969,
`powerhouse?
`A.
`‘Ten years.
`§o to about 1979 then?
`‘Ten years.
`Q.
`A,
`Yeah, something like that.
`Let's talk about thig, As a helper, what
`Q@.
`were your job duties in the No, 2
`powerkouse?
`A,
`We used to take the equipment apart, pumps
`and that, work on bollers,
`fans, start
`taking the
`generators apazk.
`let's talk about each of these. You said
`Q@.
`you took equipment apart. What
`type of equipment
`
`on
`
`2
`
`Na. MARSTLIG COURT REPORTING SERVICE
`did you take apart? “MARSILIO COURT REPORTING SERVICE
`
`3-B77-T2B-6226
`
`Qf.
`
`supplier
`A,
`
`Besides the brick and the md, is there any
`9.
`other products you believe exposed you to asbestos
`during this time in the bollerhouse?
`Pipe insulation. That was
`part of our
`A.
`Job.
`Lf somebody busted up the insulation on the
`ye
`pipe,
`would have to put pipe insulation on it.
`So you yourself installed pipe insulation?
`:
`Q.
`A.
`Yeah.
`Do you know the name brand, manufacturer ox
`of the pips insulation you installed?
`can't remember that.
`No, I
`What Floors did you install this pipe
`@.
`insulation on?
`A.
`Everything above the first floor. Not the
`that was the fan floor.
`fifth Eloor;
`Any other products that you believe you
`Q@.
`were exposed to during thia time that contained
`asbestos?
`--
`J did that For about a year.
`No