Outline of Equipment - Machinery Company Defense Lawyer Deposition Questions
EXPOSURE QUESTIONS
Q.And approximately how many months or weeks do you recall working at the ____?
What were you doing there at the ___? What job title did you have?
And what types of asbestos products did you see there at ____?
Did you see any other types that you can recall at ___?
When you were at ___, did you ever have to install and/or remove any asbestos-containing products?
Do you recall any particular brands of asbestos-containing product that you saw at ___?
Did you ever see any government inspectors at any of the sites?
Did you ever see anyone taking air samples/monitoring the air?
I want to go over some of the co-workers that you've worked with. I'm going to ask you a series of questions about each one.
Did you ever see areas cordoned off because workers were either installing or removing asbestos?
Did you see areas wet down with water before workers removed or worked with asbestos?
Did you see persons wearing special clothing when they worked with or removed asbestos?
Did your employer provide showers and lockers for those who worked with or removed asbestos to change their clothes?
What was his job? Where was he working?
Did you all work side-by-side?
What was his job title?
What was his job title when you worked with him?
Do you keep up with any of these gentlemen, talk to them on a regular basis?
Who have you talked to, say, in the last year or so?
Do you know if any of these gentlemen have an asbestos lawsuit?
Have you talked to any of these gentlemen about your lawsuit?
Have you prepared a list of products that you believe contained asbestos that you feel you were exposed to on any of your jobs? Were you able to do this with no assistance?
Have you ever seen a "picture book?" (One with pictures of products or product logos or product packages)
Have you ever been shown lists of product names or products manufacturers?
Do you believe you used and/or removed any asbestos-containing products? Follow up per job site.
Did you ever perform any maintenance on any vehicles? Where, when?
What did you do -- brakes, clutches, gaskets, etc.?
Determine the make and model of every vehicle worked on by the plaintiff.
As to each vehicle, determine whether it was purchased new or used. If purchased used, determine how old (and how used) the vehicle was at the time of purchase (years and mileage).
As to products removed, ask whether the plaintiff can identify the manufacturer.
Can the plaintiff say whether the product that is removed was original equipment?
Who made the replacement part that you used?
Where did you purchase the replacement part that you used? How did you install any such products?
How did you remove any such products?
Brands? Manufacturers?
Describe packaging -- warning labels?
PREMISES LIABILITY
Who was your employer when you worked at ____?
Who gave you directions re time, place, and manner of employment?
Your employer, not premises owner, told you when to do your work, what to do and how to do it, is that correct?
Can you recall any conversations you had with the premises owner or any of his (its) employees as to how you should do your job?
Who supplied the materials that you used when you worked at ____?
Where were the materials that you used at ____ stored?
Do you recall attending any safety meetings while you worked at ____?
Who was it (employer or owner) who conducted the safety meetings?
Describe the area in which you were performing your work (outside, inside, ventilation).
How long were you working at ____?
IF YOUR PRODUCTS ID'D EARLIER IN DEPOSITION (sample questions only)
What features of the ____ lead you to believe it was a ____?
Can you identify any writing or numbers on the ____?
Model name or number?
What type of ____ was it? (compressor = plant air, etc.; pumps - centrifugal, etc.)
What was the ____ being used for? (pump = what material pumped; compressor - sand blasting; etc.)
How many ____ were at the site where you worked?
Where were the ____ located in the plant(s)?
Do you know where the ____ came from? (Distributor? Equipment company?)
Do you know the name of the distributor?
What was the size of the ____?
What was the shape of the ____?
Describe how this particular ____ worked.
Describe the components on this ____.
What were your specific encounters with each ____ (e.g. passer-by, equipment mechanic, just in the same building?)
When did you begin working with ____?
How long did you work with ____?
How did you use this particular ____?
How often did you use this particular piece of equipment? (daily, weekly, etc.)
Where did you do your job in relation to the location of the ____?
What factory process was this ____ used for?
Was this ____ ever repaired?
What kinds of repairs were performed on the ____?
Do you know who repaired the ____?
It wasn't your job to repair or service the ____, correct?
If it was his job:
Did you ever assemble the ____?
If there was a problem with the ____ who would you go to or tell about it?
What other ____ were in the plant?
Who/what trade serviced the ____?
How often were the ____ serviced? (was it routine?)
DESCRIPTION OF WORK DONE WITH ANY GASKETS AND PACKING
Location of gaskets/packing
Number of gaskets per pump
Circumstances under which remove/replace gaskets/packing
Maintenance schedules
Procedure for removing/replacing gaskets
Description of material being removed
Manufacturer of gaskets removed/installed
Steps taken (including time to perform)
Procedure for removing/replacing packing
Description of material being removed
Could not tell the difference between an asbestos gasket and non asbestos gasket, correct?
Manufacturer of packing removed/installed
Steps taken (including time to perform)
EXTERNAL INSULATION - DESCRIPTION OF WORK DONE WITH EXTERNAL INSULATION