|
Q. |
And approximately
how many months or weeks do you recall working at the ____? |
|
Q. |
What were you
doing there at the ___? What job title did you have? |
|
Q. |
And what types of
asbestos products did you see there at ____? |
|
Q. |
Did you see any
other types that you can recall at ___? |
|
Q. |
When you were at
___, did you ever have to install and/or remove any
asbestos-containing products? |
|
Q. |
Do you recall any
particular brands of asbestos-containing product that you saw at ___? |
|
Q. |
Did you ever see
any government inspectors at any of the sites? |
|
Q. |
Did you ever see
anyone taking air samples/monitoring the air? |
|
Q. |
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. |
|
Q. |
All
right. Then what I'm going to do is ask you what their job title was;
whether or not you all worked side-by-side. What I mean by
side-by-side is within, say, 10 or 15 feet on a regular basis |
|
Q. |
Did you ever see
areas cordoned off because workers were either installing or removing
asbestos? |
|
Q. |
Did you see areas
wet down with water before workers removed or worked with asbestos? |
|
Q. |
Did you see
persons wearing special clothing when they worked with or removed
asbestos? |
|
Q. |
Did your employer
provide showers and lockers for those who worked with or removed
asbestos to change their clothes? |
|
Q. |
What was his
job? Where was he working? |
|
Q. |
Did you all work
side-by-side? |
|
Q. |
What was his job
title? |
|
Q. |
What was his job
title when you worked with him? |
|
Q. |
Do you keep up
with any of these gentlemen, talk to them on a regular basis? |
|
Q. |
Who have you
talked to, say, in the last year or so? |
|
Q. |
Do you know if
any of these gentlemen have an asbestos lawsuit? |
|
Q. |
Have you talked
to any of these gentlemen about your lawsuit? |
|
Q. |
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? |
|
Q. |
Have you ever
seen a "picture book?" (One with pictures of products or product
logos or product packages) |
|
Q. |
Have you ever
been shown lists of product names or products manufacturers? |
|
Q. |
Do you believe
you used and/or removed any asbestos-containing products? Follow up
per job site. |
|
Q. |
Did you ever
perform any maintenance on any vehicles? Where, when? |
|
Q. |
What did you do
-- brakes, clutches, gaskets, etc.? |
|
Q. |
Determine the
make and model of every vehicle worked on by the plaintiff. |
|
Q. |
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). |
|
Q. |
As to products
removed, ask whether the plaintiff can identify the manufacturer. |
|
Q. |
Can the plaintiff
say whether the product that is removed was original equipment? |
|
Q. |
Who made the
replacement part that you used? |
|
Q. |
Where did you
purchase the replacement part that you used? How did you install any
such products? |
|
Q. |
How did you
remove any such products? |
|
Q. |
Brands?
Manufacturers? |
|
Q. |
Describe
packaging -- warning labels? |
|
Q. |
Who was your
employer when you worked at ____? |
|
Q. |
Who gave you
directions re time, place, and manner of employment? |
|
Q. |
Your employer,
not premises owner, told you when to do your work, what to do and how
to do it, is that correct? |
|
Q. |
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? |
|
Q. |
Who supplied the
materials that you used when you worked at ____? |
|
Q. |
Where were the
materials that you used at ____ stored? |
|
Q. |
Do you recall
attending any safety meetings while you worked at ____? |
|
Q. |
Who was it
(employer or owner) who conducted the safety meetings? |
|
Q. |
Describe the area
in which you were performing your work (outside, inside, ventilation). |
|
Q. |
How long were you
working at ____? |
|
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?) |
|
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) |
PATIENT PROFILES
