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Answers. Ask a question in plain English. The answer cites the page it came from, so checking it takes seconds.

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000001

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000002

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000003

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000004

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000005

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000006

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000007

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000008

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000009

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000010

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000011

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000012

EXHIBIT38

Whitfield v. Hale Mfg. No. 23-1247

REC 000013

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000014

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000015

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000016

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000017

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000018

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000019

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000020

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000021

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000022

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000023

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000024

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000025

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000026

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000027

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000028

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000029

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000030

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000031

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000032

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000033

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000034

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000035

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000036

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000037

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000038

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000039

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000040

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000041

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000042

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000043

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000044

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000045

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000046

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000047

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000048

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000049

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000050

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000051

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000052

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000053

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000054

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000055

EXHIBIT39

Whitfield v. Hale Mfg. No. 23-1247

REC 000056

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000057

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000058

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000059

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000060

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000061

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000062

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000063

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000064

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000065

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000066

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000067

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000068

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000069

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000070

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000071

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000072

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000073

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000074

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000075

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000076

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000077

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000078

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000079

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000080

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000081

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000082

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000083

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000084

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000085

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000086

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000087

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000088

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000089

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000090

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000091

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000092

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000093

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000094

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000095

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000096

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000097

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000098

EXHIBIT40

Whitfield v. Hale Mfg. No. 23-1247

REC 000099

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000100

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000101

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000102

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000103

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000104

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000105

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000106

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000107

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000108

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000109

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000110

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000111

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000112

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000113

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000114

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000115

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000116

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000117

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000118

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000119

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000120

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000121

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000122

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000123

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000124

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000125

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000126

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000127

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000128

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000129

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000130

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000131

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000132

 7  Q. You were on site that
 8     morning?
 9  A. From five thirty on,
10     yes.
11  Q. Who inspected the
12     relief valve that
13     morning?
14  A. I did. I inspected it
15     myself, the morning
16     of April 9, before
17     first shift.
18  Q. Is that inspection
19     in the service log?
20  A. It should be, yes.

REC 000133

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000134

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000135

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000136

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000137

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000138

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000139

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000140

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000141

EXHIBIT41

Whitfield v. Hale Mfg. No. 23-1247

REC 000142

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000143

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000144

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000145

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000146

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000147

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000148

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000149

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000150

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000151

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000152

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000153

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000154

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000155

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000156

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000157

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000158

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000159

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000160

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000161

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000162

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000163

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000164

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000165

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000166

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000167

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000168

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000169

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000170

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000171

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000172

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000173

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000174

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000175

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000176

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000177

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000178

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000179

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000180

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000181

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000182

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000183

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000184

EXHIBIT42

Whitfield v. Hale Mfg. No. 23-1247

REC 000185

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000186

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000187

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000188

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000189

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000190

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000191

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000192

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000193

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000194

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000195

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000196

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000197

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000198

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000199

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000200

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000201

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000202

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000203

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000204

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000205

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000206

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000207

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000208

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000209

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000210

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000211

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000212

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000213

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000214

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000215

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000216

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000217

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000218

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000219

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000220

THE RECORD CONTINUES · REC 000221 TO REC 041206

DEPOSITION OF D. WHITFIELD · VOL. II PAGE 212

 7  Q. You were on site that
 8     morning?
 9  A. From five thirty on,
10     yes.
11  Q. Who inspected the
12     relief valve that
13     morning?
14  A. I did. I inspected it
15     myself, the morning
16     of April 9, before
17     first shift.
18  Q. Is that inspection
19     in the service log?
20  A. It should be, yes.

FINDING · DEP. 212:14 Read against Ex. 41, the line 4 service log: no entry for April 9. Last inspection entry March 27 (REC 001846).

The whole production, in one place. REC 000001 TO REC 041206 · 41,206 PAGES

DEPOSITION OF D. WHITFIELD · VOL. II PAGE 212

 7  Q. You were on site that
 8     morning?
 9  A. From five thirty on,
10     yes.
11  Q. Who inspected the
12     relief valve that
13     morning?
14  A. I did. I inspected it
15     myself, the morning
16     of April 9, before
17     first shift.
18  Q. Is that inspection
19     in the service log?
20  A. It should be, yes.

FINDING · DEP. 212:14 Read against Ex. 41, the line 4 service log: no entry for April 9. Last inspection entry March 27 (REC 001846).

Reads. Scanned filings, PDFs, Word files, and spreadsheets. Adil turns your documents into searchable text, including pages that were only ever images.

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000001

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000005

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000006

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000008

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000009

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000010

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000011

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000012

Organizes. It proposes folders, labels, and clear file names for the whole production. You approve each change before it lands.

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000003

EXHIBIT38

Whitfield v. Hale Mfg. No. 23-1247

REC 000013

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000015

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000017

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000020

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000032

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000034

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000037

Cross-references. Adil checks testimony against the documents. When a witness and an exhibit disagree, the conflict gets marked.

 7  Q. You were on site that
 8     morning?
 9  A. From five thirty on,
10     yes.
11  Q. Who inspected the
12     relief valve that
13     morning?
14  A. I did. I inspected it
15     myself, the morning
16     of April 9, before
17     first shift.
18  Q. Is that inspection
19     in the service log?
20  A. It should be, yes.

REC 000133

DEPOSITION OF D. WHITFIELD · VOL. II PAGE 212

 7  Q. You were on site that
 8     morning?
 9  A. From five thirty on,
10     yes.
11  Q. Who inspected the
12     relief valve that
13     morning?
14  A. I did. I inspected it
15     myself, the morning
16     of April 9, before
17     first shift.
18  Q. Is that inspection
19     in the service log?
20  A. It should be, yes.

FINDING · DEP. 212:14 Read against Ex. 41, the line 4 service log: no entry for April 9. Last inspection entry March 27 (REC 001846).

Flags. It raises what you did not ask about, like a date that does not fit the timeline or a log entry that is not there.

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000057

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000058

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000059

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000060

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000061

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000062

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000063

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000064

Answers. Ask a question in plain English. The answer cites the page it came from, so checking it takes seconds.

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000001

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000002

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000003

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000004

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000005

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000006

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000007

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000008

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000009

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000010

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000011

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000012

EXHIBIT38

Whitfield v. Hale Mfg. No. 23-1247

REC 000013

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000014

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000015

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000016

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000017

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000018

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000019

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000020

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000021

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000022

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000023

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000024

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000025

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000026

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000027

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000028

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000029

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000030

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000031

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000032

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000033

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000034

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000035

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000036

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000037

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000038

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000039

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000040

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000041

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000042

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000043

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000044

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000045

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000046

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000047

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000048

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000049

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000050

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000051

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000052

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000053

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000054

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000055

EXHIBIT39

Whitfield v. Hale Mfg. No. 23-1247

REC 000056

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000057

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000058

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000059

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000060

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000061

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000062

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000063

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000064

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000065

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000066

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000067

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000068

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000069

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000070

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000071

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000072

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000073

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000074

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000075

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000076

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000077

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000078

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000079

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000080

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000081

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000082

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000083

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000084

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000085

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000086

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000087

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000088

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000089

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000090

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000091

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000092

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000093

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000094

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000095

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000096

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000097

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000098

EXHIBIT40

Whitfield v. Hale Mfg. No. 23-1247

REC 000099

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000100

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000101

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000102

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000103

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000104

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000105

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000106

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000107

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000108

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000109

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000110

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000111

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000112

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000113

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000114

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000115

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000116

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000117

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000118

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000119

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000120

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000121

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000122

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000123

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000124

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000125

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000126

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000127

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000128

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000129

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000130

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000131

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000132

 7  Q. You were on site that
 8     morning?
 9  A. From five thirty on,
10     yes.
11  Q. Who inspected the
12     relief valve that
13     morning?
14  A. I did. I inspected it
15     myself, the morning
16     of April 9, before
17     first shift.
18  Q. Is that inspection
19     in the service log?
20  A. It should be, yes.

REC 000133

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000134

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000135

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000136

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000137

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000138

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000139

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000140

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000141

EXHIBIT41

Whitfield v. Hale Mfg. No. 23-1247

REC 000142

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000143

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000144

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000145

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000146

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000147

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000148

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000149

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000150

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000151

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000152

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000153

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000154

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000155

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000156

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000157

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000158

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000159

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000160

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000161

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000162

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000163

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000164

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000165

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000166

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000167

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000168

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000169

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000170

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000171

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000172

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000173

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000174

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000175

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000176

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000177

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000178

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000179

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000180

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000181

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000182

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000183

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000184

EXHIBIT42

Whitfield v. Hale Mfg. No. 23-1247

REC 000185

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000186

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000187

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000188

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000189

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000190

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000191

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000192

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000193

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000194

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000195

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000196

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000197

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000198

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000199

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000200

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000201

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000202

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000203

 5  Q. The incident report,
 6     Exhibit 42, page 2.
 7  A. All right.
 8  Q. The first alarm reads
 9     6:41 AM. Who logged it?
10  A. The shift lead.
11  Q. Not you?
12  A. Not me. I arrived
13     after the alarm.

REC 000204

18  Q. Take your time.
19  A. (Reviewing document.)
20  Q. Page six. The entry
21     dated March 27.
22  A. I see it.
23  Q. Is that your initial
24     in the margin?
25  A. It appears to be.

REC 000205

14  Q. Did anyone tell you to
15     update the binder?
16  A. I would not say told.
17  Q. What would you say?
18  A. It was suggested that
19     the binder be current.
20  Q. By Mr. Calloway?
21  A. By his email, yes.

REC 000206

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000207

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000208

 3  Q. I am handing you what
 4     has been marked as
 5     Exhibit 41. Do you
 6     recognize it?
 7  A. It looks like the
 8     service log.
 9  Q. The log for which line?
10  A. Line 4. The relief
11     assembly.

REC 000209

CERTIFICATE OF REPORTER

I certify that the
foregoing is a true and
accurate transcript of
the proceedings taken in
the above-entitled matter,
and that review of the
transcript was requested
before filing.

REC 000210

12  Q. Who kept the log?
13  A. Facilities. Whoever
14     was on shift.
15  Q. Was that duty written
16     down anywhere?
17  A. It was understood.
18  Q. Understood by whom?
19  A. By everyone. The floor,
20     and management.

REC 000211

INDEX OF EXHIBITS

Ex. 38  Purchase order
Ex. 39  Commissioning
        report
Ex. 40  Weekly schedule,
        posted copy
Ex. 41  Service log, line 4
Ex. 42  Incident report
Ex. 43  Photographs (12)
Ex. 44  Correspondence

REC 000212

 7  Q. When did you first see
 8     the April service log?
 9  A. At my deposition. That
10     was the first time.
11  Q. Not during the audit?
12  A. Not that I recall.
13  Q. You signed the audit
14     cover sheet, correct?
15  A. I signed a lot of
16     things that week.

REC 000213

FROM     D. Whitfield
SENT     Apr 11, 9:14 AM
TO       R. Calloway
RE       RE: Line 4 binder

Understood. Pulling the
binder this afternoon.
Will flag anything thin.
D.

REC 000214

CONFIDENTIAL
SUBJECT TO PROTECTIVE ORDER

MEMORANDUM
RE: Unit 7 maintenance
    staffing, Q1

Coverage on line 4 fell to
one technician for the two
weeks preceding April 9.
Overtime requests pending.

REC 000215

FROM     R. Calloway
SENT     Apr 11, 8:02 AM
TO       D. Whitfield
RE       Line 4 binder

Dan. Before Thursday’s
walkthrough, make sure the
log binder is current
through this week. They
will ask.  R.

REC 000216

10  Q. You testified the
11     morning was routine.
12  A. It was routine.
13  Q. Does routine include
14     an inspection?
15  A. On an inspection day,
16     yes.
17  Q. Was the ninth an
18     inspection day?
19  A. It was a Wednesday.

REC 000217

21  A. I want to be careful
22     here.
23  Q. Please.
24  A. The week of the ninth
25     was short-staffed.
26     Some entries ran late.
27  Q. Ran late, or were
28     never made?

REC 000218

SERVICE LOG · LINE 4
UNIT 7 RELIEF ASSEMBLY

02/27  insp. RC  no except.
03/06  insp. DW  no except.
03/13  insp. RC  no except.
03/20  insp. DW  no except.
03/27  insp. DW  seal wear
       noted. monitor.

REC 000219

 9  Q. How often was the
10     valve inspected?
11  A. Weekly. That was the
12     schedule.
13  Q. Was the schedule kept?
14  A. To my knowledge, yes.
15  Q. Whose knowledge would
16     be better than yours?
17     MR. DANES: Objection.

REC 000220

THE RECORD CONTINUES · REC 000221 TO REC 041206

The whole production, in one place. REC 000001 TO REC 041206 · 41,206 PAGES

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WHITFIELD V. HALE MFG. · NO. 23-1247 · 41,206 PAGES

You

“Was the relief valve inspected before the failure?”

Adil

The record holds two accounts. Whitfield testified that he inspected the valve himself on the morning of April 9 Dep. 212:14. The line 4 service log shows no entry for that day; the last inspection entry is March 27, with a note to monitor seal wear Ex. 41 · REC 001846. Two days after the failure, Calloway wrote Whitfield to bring the log binder current Ex. 44 · REC 002107. The accounts do not align.

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