David Hyde August 03, 2017 AUQIO TRANSCRIPTION OF DEPOSITION OF DAVID HYDE Date: August 3, 2017 Time: 12:22 p.m. 1:27 p.m. SPEAKERS: John Gaanger, Attorney Philip B?ker, Att?rney David Hyde Videographer Transcribed by: Annette M. Montalvo, RDR, CRR EXHIBIT U.S. LEGRL SUPPORT 866-339w2608 David Hyde August 03, 2017 2 the following was transcribed from an audio reoor?ing, to witzi THE This is the testimony of David Hyde, taken August 3, 2017, and the time is 12:22 p.m. I am going to swear you in, okay? the witness was duly sworn.) THE VIDEOGRAPHBR: You may proceed. DAVID HYDE, oalled as a witness herein, having been Eirst duly sworn, was examined and testified as follows: BY MR. GSANGER: Would you do me a favor and introduce yourself to the ladies and gentlemen of the jury? A Yes. My name is David Hyde. I was a tire builder at Goodyear, from 1977 until 2009. So is it fair to say that you are an eyewitness to the conditions in the tire building room during 2007, 2008 time frame? A Yes. Okay. And the first thing I want to ask you about is what sort of experience you had with sources of moisture or contamination getting contaminated into the tire building process. Is that something you saw with your own eyes? A Yes. U.S. LEGAL SUPPORT 866?339?2608 David Hyde August 03, 2Q17 3 Tell me about about the statue of the roof in the tire building room at the Danville plant during the 200?, 2008 time frame. A It leaked all the time. Whenever it rained outside, what happened in the plant? It came in the piant when it when it rained. And that isn't only in parts of the plant that are isolated away from the tire building room; is that true? A Say again? Let me ask it this way:' What parts of the plant had roof leaks? A Throughout the whole plant. That includes the tire building room? A Yes. Were there ever leaks that were right aboVe the tire building machines? tee. Were there ever leake right above the area where the green tire components that are being ready for use and tire assembly were stored? A Yes. Did you ever see rainwater leaking down on top of tire building machines? I A Yes. Did you ever see rainwater leaking down on top of green U.S. LEGAL SUPPORT 366?339?2608 David Hyde August 03, 2017 4 tire components? A Yes. What solution did Goodyear employ during the 200?, 2008 time frame, rather than repairing the leaks, what solution did they apply in the tire building room? A We used a poly, a product that we used to separate the rubber, we used that as we made makeshifts tents over the machines to funnel the water away from the machines onto the floor. Did you ever see puddles on the floor? A Oh, yes. Were puddles on the tire building room floor a common occurrence in the 200?, 2008 time frame? A Yes. If someone were to go in the plant during the, you know, during a rainy season, what would they probably see in that plant? A Water. And do you think when visitore or guests well, let me back up, heoause I?m assuming something. Did anybody other than the workers ever get a chance to tour or see the plant? A The other people? Yes. A Yes. U.S. LEGAL SUPPORT 866?339?2608 David Hyde August 03, 2017 5 Tell me about that. What kind of what kind of tours did you see at the plant? A Trucking companies would come in the plant, or just guests, Vendors would come into the plant. And when a big customer's going to come in the plant, did did you do anything with respect to the plastic tents, the makeshift tents that they put over the tire building machines? A They never tried to hide it. So you come in the plant, and it was there for everybody to see, that there was a plastic tarp strung up over a tire building machine; true? a Well, they were pretty cautious of where they took them. You know, they had a, you know, an area they would take them. They wouldn't just take them all over the tire room. They had -- they they had areas they would take them, and they wouldn?t take them all over everywhere, you know, just certain machines they would take them to. Now, with respect to when there wee a heavy rainstorm and the water would would collect in the plant did u~ did the water ever come up through the floor? A Oh, yes. It would come up so hard that it would blow up the manhole, the covers would come up into the air. So if it was a hard rain, the water wouldn't just be coming from the roof, but would be coming up through the U.S. LEGAL SUPPORT 866?339?2608 David Hyde August 03, 2017 6 Okay; And that was in the 200?, 2008 time frame? A Yes. Now, what ie the tolerance for building moieture oi some kind into a truck tire? A Zero. All right. And did you ever have an opportunity to see with your own eyes rubber that was coming to you as a tire builder, building truck tires, where there was Some moisture between the rubber components up in the crown region of the tire? A Yes. Yes. Now, what components did you that sometimes would come to you wet? A I seen it on the ioeide oi the tread, on the inboard of the tread, ano also gum strip of the tread. All right. And so that the ladies and gentlemen of the jury who are not as familiar with the tire building process as you are can understand, when the tread is put on the tire, what does it look like? A It's black, it's thick, about an inch the ?ifferent different treads are different Some can be probably inch, inch and a half thick. Some could be a quarter of an inch thick. It could be thie wide, it could be this U.S. LEGAL SUPPORT 866w339~2608 David Hyde August 03, 201? 7 wide. They?re all different. And when the tread rubber comes out of the extruder, it's it?s white hot; is that true? A Yes. And eihce the tread is tee het tight fresh when it comes out of the extruder for a tire builder to work with, what happens to the tread? A It's ran through water. And sometimee the tread, as it is received by the tire builder, it isn?t just that, you knew, flat piece of rubber, it has additional components that have been added to it; is that fair te say? A Yes. What additional components would get added to the tread before that tread reaches the tire builder who's building a truck tire at the Banville plant in the 2008 and 200? time frame? A The gum strip. Okay. And so these gum stripe will be put on the undereide er the part of the tread that will ultimately become the underside of the tread; fair? A Right. Now, when you have seen moisture trapped between the gum strip and the tread, where did you see that? A On the under edge of the gum Strip. U.S. LEGAL SUPPORT 866w339?2608 David Hyde August 03, 2017 8 And if you press down on the edge of the gum strip, what would happen? A Water would come out. And if a truck tire wee built on an RTN truck tire building machine, is there anything about the way that the tire builder Would receive that tread piece that would make it more difficult to defect moisture trapped between the gum atrip and the tread itself? A Well, the automatic hooker would pick the tread up and put it on the conveyer. He would he would not see that. So it ought to be flipped over with the gum pieces on the bottom eide that he doesn't see? A Exactly. Okay. Was there ever an issue well, let me back up a little bit. Beeide the issue of ?m well, let me back up even further. About how often did you see this Scenario where you would see water on the tread and sort of trapped between the tread and the gum strips? A It's really hard to say. I built tires for 32 years. It?s hard to say. It's enough. Let me wn yeah. Let me go ahead and establish that, During that 32?year period, what different job titles did you hold? U.S. LEGAL SUPPORT 866?339?2608 David Hyde August 03, 2017 A I built tires for 32 years. Okay. A So that's all I ever did, built tires. I just want to make sure that the jury didn?t get the that you were doing one job and then only Johnny?oome?lately to the tire building trade. You were a tire builder that whole time? A I got hired January 23, 19?7, and my last day on the job wae December 13, 2008. Was detecting the water under the gum strip something that you needed to have a good out for, or would it be very easily detected? A You have to have a good for it. It is very hard to detect. Sometimes I caught it, and sometimes QC hae caught it down at the tubere, and it's come to my machine and shut me down, after finding it down at the tubers. Um -- yea. Now, in terms of the the quantity of times that you've seen-Sort of some moisture trapped between the gum strip and the tread, is this something that you?ve aeen dozen of times, hundreds of times, or thousands of times? A I'd say maybe 20, 25 times, 39 times. We're talking probably maybe total, you know, thousand treade, maybe, over the Years. So a thousand -u a thousand treads maybe? A Probably. U.S. LEGAL SUPPORT 866-339?2608 David Hyde August 03, 2017 lo Okay. And how often did that moisture get passed the tire buildex like yourself and not get detected until the tire had gone through quality control inspection? A That I can?t anewer. 9 Okay. But that did happen; fair? A I'm sure. Yeah. And other than trapping moisture between components. are there any other things that you don't want to get trapped between the components when you're building a truck tire like or assembled at the Danville plant? A Run that question by me again, please. Well, we know that there?s an issue about trapping water between the oomponente of the tire. correct? A Right. hir. You don?t want air. Okay. And how does air get trapped between the components ot a truck tire being built at the Denville plant? A The head in the header and barrier, gets air between them. Okay. And eometimee the jury might hear the term ?blister," and sometimes the jury might hear the term ?blow." Are you familiar with those two terms? A Yes. Yee. Do you underetend them to describe anything different. one from the other, or do you understand them to be two - - U.S. LEGAL SUPPORT 866~339?2603 David Hyde August 03, 2017 ll UNIDENTIFIEB ATTORNEY: You know what, let me go ahead and get that oh. UNIDENTIFIED SPEAKER: Did you talk to that THE WITNESS: Did he cut it off? UNIDENTIFIED SPEEKER: Are we off? UNIDENTIFIED SPEAKER: I think if we shut the deer, we'll be all right. UNIDENTIFIED SPEAKER: Okay. THE WITNESS: IS he off? UNIDENTIFIED SPEAKER: I don't know. Are you off? THE VEDEDGRAPHER: We?re Still on the record. THE WITNESS: Okay. BY MR. GSANGER: Gkay. When we talk about blisters and blows, are thoee two different terms for the same thing, or is there a slight difference between those two terms? A Those are different terms. A blister, you?re talking about the liner blister, is between your header and your barrier. blow could be your tread blow or a sidewall blow, something like that. And what is a tread blow? A Tread blow could be like we just talked about, it could be water up under it, or it could be a belt separation, could cause a tread blow. Sidewall blow. U.S. LEGAL SUPPORT 865~339?2608 David Hyde August 03, 2017 12 Is quality control supposed to catch a blow in the -- in the tread? A Well, they they should Catch it down at the K-ray, when they X?ray the tire. SupposedlyI they?re Supposed to be able to they're supposed to Kmray every tire that goes out of there, but, you know, human error, you know. When you were working as a tire builder in the Danville plant, did you ever have a tool at your tire building machine to help you with dress? A Yes. What was that tool? a An all [phonetio}. And what did you use an all for? A To poke the poke the air out of the tire, to prick it; emooth it down. And that was a tool that Goodyear provided for you? A Yes. So Goodyear was aware of the fact that you would be needing to use an all to take air out of A Exactly. Okay. Now, if you had one tire that had some trapped air in itf you might use an all; is that fair to say? A Yes. Was there maybe a different process that was used when you would have a whole run of tires; where you were seeing U.S. LEGAL SUPPORT 866?339-2608 David Hyde August 03, 2017 13 lots of trapped air in them? A I don't know how often they've done it. but I have known them to take a bunch of tires down to the Banbury, to a room that's used for the process of heating up rubber down in the Banbury. I've known them to oerry tires down to that room and heat up the tiresthe liners. Rather than scrap the tires, they would heat it up and try to, you know, get the air out that way. I don't know how often they done that. but I?ve known them to do that. And when would they take a run of tires down to the Banbury? What would be the circumstances? A If it'e a lot of tires. And what could they fix by heating up the tires near the Banbury? A I think it would.juet eoften the rubber up, probably, in the liner area. and it would maybe just l- the air could escape out of the liner. I don't know how often they?ve ever done that. I have known them to do it, but I don't know how often they've done that. I would think that if they had a lot of, you know, had some kind of a mishap. you know. a lot of air in there, they would try to save the tire by doing that. Let me ask this: In addition to the trapped air and the moieture that would sometimes contaminate the tire building was there any moisture or solvent or ointment that tire builders might use that would somehow have an effect on U.S. LEGAL SUPPORT 866?339?2608 David Hyde August 03, 2017 is the tire building process? a We had a hand cream. I personally didn't use it, but it was called Ply?2 (phonetic). It was given out to the tire builders who aauted it. It was a cream we used. it was it was like a barrier cream. And what the purpose of using the cream was to keep the solvent we used a solvent called Kangen. And, also, it keeps the rubberr you know, from break you know, getting on your skin. It was like a barrier. And I didn?t use it, I just I just didn't like using itand didn't let it dry, it would get on the product. I done that, use it too quick, and it wouldn?t allow the rubber to he tacky. And I just didn't like using it. And when you say you didn't use it, are you talking about the Ply~2 hand cream or the Reagan Kaugen? A The Ply~2 hand cream. I just personally didn?t like using it. I didn?t like putting anything on my hands. I just -- just liked -- didn't like putting anything on my hands when I was building tires. And the Ply~2 hand cream that some tire builders used, that was provided by Goodyear? A Right. It was provided by Goodyear. And were there any instructions that came with this Ply~2 hand cream? A To let it dry before you used it, because it would U.S. LEGAL SUPPORT 866-339?2608 ?LaDavid Hyde August 03, 2017 15 contaminate the rubber. Because the stock, it would a? it would not be tackydry. Is the -- is the hand cream something that was used in the 200?, 2008 time frame? A I'm quite sure, yeah. It probably still is being used, I'm sure. Now, you mentioned a solvent called Ranges; do you remember that? A Yes. Would you tell the ladies and gentlemen of the jury what Kangen is? A I always called it Odine {phonetic}. USed to be called Odine, and maybe still does. But it's a solvent we use, it makes we put it on the rubber, it makes it tacky. Sometimes we get dry stock, overaged stock, it may be dry, and you put it on the stock, and it makes it tacky. I say stock. The rubber. Sometimes we get tread that it may be getting close to being overaged. Like, for instance, on tread, we?re not supposed to use tread that's more than seven days old. Sometimes it'll be getting close to the seven days, and it will start getting a little bit dry, and we?ll put the Odine on it, swab it with Odine, and make it more tacky SO it will stick to the product, stick to the belt when we put it on. U.S. LEGAL SUPPORT 366-339?2698 David Hyde August 03, 2017 16 And that's what we use it for, to make the product sticky, tacky. And was the Odine or Kangen available to the tire builder building truck tires at the Danville plant in the 2007, 2068 time Eseme? A Yes. Did you have was it in a bottle or a bucket or a swabused a swab. We used a swab. And you take the swab right next to your machine? A Right. Okay. How often did the tire builders at the Deeville plant, who were making tires in the 2007, 2008 time frame, make use of this solvent? A Every day. Every day. Every day. It was a must have, Odine. It was a must. I would like to add, also, that when we had our shut down, we usually it was in August. he come back, we shut down a week. We had a horrible time with dry stock. You know, we out a week, we had all the stock is there, and it was real dry when we come back. A lot of it was really overaged. We would try they would have really needed Odine to make it tacky. What components would you sometimes use Odine on? Would you sometimes use them on the belts? U.S. LEGAL SUPPORT 866?339?2608 David Hyde August 03, 2917 17 A Most of the time most of the time you use it when you build your belt package, you would put it on your fourth -- your last belt. The last belt you put on ie your fourth belt. Then you have your complete package. You put it on your fourth belt, and you also would have an Ddine bucket. That's your tread package. That's your I mean, your tread up the tread area, and you swab your treade. All right. Now, the tire building process for the commercial truck tires being built at the Denville plant, those truck tires in that building process, is it physical labor or ie it just completely automated? A The RTS is more is more physical than, say, the new NG machine. Uhnhuh. A The MG machine is a little a little more automated. You still ?n still physical, not as much ee the RTS. The more physical is the the aircraft, is probably the most physical out there, more manual. Put the go ahead. I'm going to detine some terms so that the jury will understand. A All right. When you say that's a new kind of tire building machine, right? A Exactly. Exactly. If you refer to RTS or RTN, thoee are the old style LECEUL 866~339-2608 David Hyde August 03, 2017 18 A Exactly. tire building machines, correct? A Right. Okay. And at the Danville plant, they both make aircraft tires and alao truck and hue tirea; true? A Right. You were I won't put words in your mouth. What kind of tires did you make? A Truck tires and bus tires. Okay. And so when you?ve been talking about the tire building processes, you?re talking about the truck tire process? A Right. Okay. All right. And in terms of the RTS and the RTN machines, were they the ones that involved physical labor? A Yes. Okay. Was it was it {inaudible} strenuous? A Very. And as a result of doing repetitive strenuous work, did that ever have any repercussions on the tire builders? A Oh, yes. What would you see? a What would I see? Yes. What would happen to them as a result of continuous U.S. LEGAL SUPPORT 866?339?2608 David Hyde August 03, 2017 19 A Bed backs, rotetor tears, which I suffer from both. Lot of pain. Lot oi ashes. With the pain, what was sometimes the consequence of the fact that you got a lot of tire builders in pain? A Ibuprofen, painkillers, eelfumedioation, you know. Did you have an Opportunity to see occasions where tire builders were perhaps overmedioatee or, you know, whether it?s prescription drugs or alcohol or nonprescription drugs? A Yes, Is that something you saw in the 200?, 8 excuse me. Is that something that you saw in the 2007, 2008, 2009 time frame? A Yes. Okay. Tell me about some examples of that. What sort of tire building processes did you see where maybe tire builders were impaired through drugs or alcohol and were building tires in the 200?, ?08, and 2009 time frame? A My hearing is bad. Repeat that one more time. Tell me about some examples that you might have seen in the 200? time period, 2008, and 2009 time periods, where tire builders were building truck tires at the Danville plant and they were impaired by drugs or alcohol. A I really can?t w? to be honest with you, 1 can?t say in that during that time maybe right around that time period. I can't specifically say exactly 200?, 2008, but 866?339?2603 David Hyde August 03, 2017 20 maybe right beEore then, maybe 2006, 2005. 2006. 1 seen I seen people come in drunk and be taken home by the shop steward. Management would have shop steward take him home. They'd be drunk. I seen that. And we didn't talk about this earliet, but I will tell you this. Earlier than that. I seen people up in the break room I mean, up in the locker room do a line of cocaine. I seen people build tires smoking pot. We?re talking way back. Hmm. A Uh. Yes. In the w- more in like the 200?, 2008 time frame, were there any about people getting arrested at the plant or arrested for conduct at the plant? A That happened. that happened after I left. Okay. A That happened after 2009. I lett 2009. That happened probably around 2011. Okay. And so I guess what I?m saying is that you've seen with your own eyes some impaired tire building in the 2005, 2006 time frame? A Right. Right. Well a~ And it was still a problem in 2011 after you left? A Right. 2011 is when the people were arrested for selling drugs, right. That was about 2010, 2011. And the people who were arrested in 2010, 2011 for U.S. LEGAL SUPPORT 866-339~2608 David Hyde August 03, 2017 21 selling drnga at the Danville plant, those people worked at the plant during 2006 and '07 and ?08 and '09? A Exactly. Exactly. Were they selling drugs at the plant, to your understanding, at that time? A Probably Were. Okay. Did you ever have an opportunity to View any tire buildera who had adjusted the buttons or settings on their tire building machines? A Yes. Tell me about what that what that meane and how you accomplish that? A On the RTS machine, the turret, when you?re building tires on the RTS machine, the belt man, when the tire pope off the turret, the band man kicks the tire off, the belt man picks the tire up with the hoist, the band man puts the bead in, he gets out of the way, the turret stripe out -- the belt man, his job is to push the button to Send the turret around. Gives the band man time to get out of the way. This particular builder, the same one who got arrested for selling drugs, he took on his own to peg out that button that sends turret around. So when it stripe out, he doesn't have to push the button to send around, he can be behind the machine doing something else. That button that -u by that button being pegged out, it automatically goes U.S. LEGAL SUPPORT 866?339-2608 David Hyde August 03, 2017 22 around. By doing that, he put that band man in jeopardy. The hand man thinks because he's not standing there, he thinks that button -- that turret's not going to go around. Put it in automatic, you know, he jeopardized that band man's life. end the way it got caught was he forgot, when his shift ended, he forget to pull that peg out. So when the next builder came in on third shift, he almost got killed. And he was sent out tor that. And what time frame was that? A That was when I was there when that happened, that probably around 2008. I was still there when that happened. And why a? what would the advantage he to a tire builder from pegging the button? A No advantage. Just being stupid. and did you ever see any tire builders building truck tires at the Danville plant speed up their machines? A Yes. What would be the proeese of speeding up a machine? A Make a little bit more money. And how were they able to do speed up an automated machine, an automated process? A You had buttons on the machine that you turned the dial up, and it cauSes the stitches to stitch out a little faster. When you're stitching sidewalls down, it stitches it out a U.S. LEGAL SUPPORT 866-339?2608 David Hyde Auguat 03, 2D17 23 little faster, and it caused the machine to go a little bit faster. You have to be very careful to do that. You can scrap tires. Was there a different policy with respect to drug use at the aircraft tire aide o? the Danuille plant vereue the truck tire side of the Danville plant? A What I remember, when I worked out there, I don't know if it was pretty sure it was FAA regulations. I could be wrong on this. What I remember, if you get caught doing drugs, I can?t Swear to this, but what I remember, if you get caught doing drugs at the Danuille plant, you cannot deal aircraft tires after you?re caught doing drugs, but you could build tires or the truck tire division, but you couldn't you couldn?t build tires for the aircraft Side. Well, let me ask you about specifically about the truck building, truck tire building side. On the truck building tire side, if you got caught testing_poeitive for drugs while you were in the tire building process, did you get a chance to go back and continue to build truck tires, or were you automatically terminated? A You're allowed to come back. First time. Any employee. Anybody. Now, do I understand correctly that the Danuille plant is run as a continuous operation? A Yes. U.S. LEGAL SUPPORT 866-339-2608 David Hyde August 03, 201? 24 What does that mean? A It runs 24f7. And do you recall when Danville first became a Continuous operation plant? A It was April of 1998, right atter Easter, we started continuous operation. What did Shifting the Danville plant over to a continuous operation plant, what ef?eot did that have on the quality of the tires produced? A My opinion, and not just my opinion, it was the evidence was there. it went down. Production went down, Quality went down. Quality went just went it was terrible. Scrap went through the roof. It's never me it's never been what it used to be. That plant's never been what it used to be, when we went to a continuous operation. Production?s never been what it used to be. Talking about the 200?, 2008, 2009 time frame, do you think that Goodyear was putting more emphasis on making production goals, or more emphaaie on putting out safe quality tires? A Well, they talked the talk, but they don't walk the walk. Did they ever have any mottos at the at the plant in terme of the quality control? A Uh, they had a think called CAPP. I wish you?d asked me vthis earlier, I Could have thought about it, what it meant, U.S. LEGAL SUPPORT 866?339?2608 David Hyde August 03, 2017 25 because it's lost out there. The word is CAPE, I have to tell you, I wish you asked me thie earlier, what it meant, it's been so long. It?s customer action we I can?t remember what it was. They have a motto, but I'm just all i can tell you is I am very disappointed in my Company. That's why I'm here today. I'm very disappointed in my company. Did you ever hear a phrase involving "round and black"? A Oh, yeah. Round and black and out the back. Where did you hear the phrase ?round and black and out the back?? A That's common at Goodyear. That?s why that's how the employees looked at Goodyear. Like I just told you, they talk a talk, but they don't walk the walk. What does it mean "round and black and out the back"? A They just .. it is just a term, lot of the employees have, it just it is just a term we have. it's just it?s hard to explain. It?s just, um it?s like I just said, you know, Goodyear talks the talk, but they don't walk the talk. They, you know, they say they went to build a quality product. But just, um, you juet don't understand the stuff l've seen out there. It's not good. MR. GSANGER: Pass the witness. Do you have any questions? MR. BAKER: Let's go off the record to minute. U.S. LEGAL SUPPORT 866?339~2608 David Hyde August 03, 2017 26 MR. GSANGER: Sure. THE VIDEOGRAPHER: We?re Off the record at 12:57 p.m. (WHEREUPON, a was had from 12:5? p,m. to 1:22 THE VIDEGGRAPHER: We?re baCk on the record at 1:22 p.m. BY MR. GSANGER: Now, when a tire builder who's working at the Danville plant making truck tifES is putting steel belts onto the tire, that those steel belts axe made out of a particular type of material, oorxeot? A Yes. What kind of material is that? A It'e rubber and wire, And that rubber and wire, it's ?w it?s ?a it'e process a by which parallel wires get sent through a calen?ar machine and that calendare rubber onto the wires; is that correct? A Exactly. Is that a process that Danville does innhouse at its plant? A Yes. At the wire calendar. Now, sometimes were there occasions when Danville would have a Chanda to use wire calendared at another plant? A Yes. U.S. LEGAL SUFPORT 365?339?2608 David Hyde August 03, 2017 27 When would those oiroumetsnoee arise? A From what I remember, when they would get behind, and the wire calendar at Danville would go down, they would get stock from a wire calendar in Topeka, Kansas. And Goodyear has another tire building plant that builds truck tires in Topeka? A Yes. How did the quality of the calendered wire that was supplied by Toyeke compare to the quality of the wire that had been oalendered and made in?hoose in Danville? A It was much superior. Which one was much superior? A Topeka. Why was it much superior? A I just from my memory, it was. It was much suoerior, I've been I have been over at the wire calendar ?h excuse me, the Alpha here, and the Alpha operators told me that it was much superior, it was easier to work with. And they got we they it produced lees less scrap as they were working with it. I, myself, have seen the difference, how much scrap die they put on the floor versus the Danville wire calendar, when they worked with it. It was just a much superior yroduet, Why was the wire calendered at the Danville plant not as good as the wire oalendered at the Topeka plant? U.S. LEGAL SUPPORT 866-339?2608 David Hyde August 03, 2017 28 A They ran it fast. too fast. They ran the Danville one too fast? A Yes. And as a tire builder, with decades of experience building truck tires, what does the quality of the wire calender haVE to do with your ability to place the belts on straight and to get good belt splices? A What does the quality wv well, you get dog earswith it. The angle. the angle of the belt is very important, when you Splice it together. If the angle?e not right, then you get dog ears. And that's very important. Would you tell the ladies and gentlemen. what is a dog ear? A It's when you when you when you apply the wire the belt onto your drum, it'e one solid turn. Then you have to out it. Then you butt it together. And the angle has to be exactly perfect. If it's not, then you have excessed angle. And that's actually a dog ear. And there?s no tolerance. Has to butt perfectly. And if you?ve got like a quarter inch of a dog ear in a belt eplioer, what does that tell you? A That?s not going to go. You can't have that. Should you scrap that tire? A well, it?ll be a scrapped tire if you let it go. What U.S. LEGAL SUPPORT 866~339-2608 David Hyde August 03, 2017 29 you have to do as a tire builder, you book off, you go back you back off about a foot, foot and a half, and out that excess belt off, then you bring it down and out a little more out. The pol} your stock down and butt the angle will be right. Sometimes it will, sometimes it don't. You have to work with itwhere it will butt up right. It takes time. If a tire got out of the plant with like a quarter inch dog earthe plant with a belt that wasn't centered on the belt beneath it, would that be following the standards or would it be a deviation from Goodyear standards? A It would not fall on standards, no. MR. GSANGER: Thank you very much. I appreciate your time. THE WITNESS: Thank you. MR. GSANGER: Do you have anything, Phil. MR. BAKER: No, that?s good. Thank you. THE VIDEOGRAPHER: This concludes the testimony of David Hyde. And the time we're off the record, and the time is 1:27 p.m. (WHEREUPON, at 1:27 the proceedings were concluded, and the audio recording ends.) U.S. LEGAL SUPPORT 866-339?2608 David Hyde August 03, 2017 30 CERTIFICATE OF TRANSCRIBER I, Annette M. Montalvof do hereby certify that the foregoing transcript is a true and correct record of the reoorded proceedings; that said proceedings were transcribed to the best of my ability from the audio recording as provided; and that I am neither counsel for, related to, nor employed by any of the parties to this case and have no interest, financial or otherwise, in its outcome. MHW Annette M. Montalvo, RDR, CRR NCRA Membership No. 833506 Dated August 25, 2017 U.S. LEGAL SUPPORT 366?339?2603 David Hyde 339%: .93.: 39.17.. 3 07 21:2 3 2:4 08 19:17 21:2 30 9:21 09 21:2 32 8:21 9:1 32-year 8:24 1 12:22 2:4 12:57 26:2,4 8 19:10 13 9:9 197? 2:15 9:8 A 1998 24:5 1:22 26:4,6 accomplish 21:12 '2 aches 19:2 action 25:3 20 9:21 add 16:17 2005 20:1,19 added 1:11:14 2005 20:1,20 addition 21:2 13:22 2007 2:18 3:2 additional 4:3,13 6:3 ?:11,14 7:16 15:5 adjuated 21:8 16:4,13 advantage 19:10,11,17, 20,25 20:11 ahead 8:23 24:17 11:2 17:18 2008 2:18 3:2 air 5:23 4:3:13 5=3 10:14,1s,17 7:16 9:9 15:5 13,14,19321 16=4s13 13:1,6,8,16, 19:11,20,25 20:11 22:12 24:17 2009 2:16 19:12,17,20 20:16 24:17 2010 20:24,25 2011 20:17, 2017 2:4 23 9:8 24/7 24:2 25 9:21 21,22 aircraft 17:17 18:4 23:5,12,14 alcohol 19:8, 16,22 allowed 23:21 apply 4:5 April 24:5 area 3:18 5:14 13:16 17:7 areas 5:16 arrested 20:12,13,23, 25 21:21 assembled 10:10 assembly assuming 1:20 ATTORNEY audio 2:2 August 2:4 16:18 automated 17:11,15 22:21,22 automatic 8:9 22:5 automatically 21:25 23:20 aware 12:18 back 4:20 8:14,16 16:18,21 20:8 23:19,21 25:9,11,15 26:6 backs bad BAKER Banbury 5,11,14 band 21:15, 16,19 22:2,3, 5 19:1 19:1,13 25:25 13:3, barrier 10:17 11:20 14:5,9 bead 18:17 21:16 header 10:17 11:19 belt 11:24 15:25 17:2,3, 21:14,15,17 26:10,ll big 5:5 bit 8:15 15:23 22:20 23:1 black 6:22 blister 10:20 11:18,19 blisters 11:15 blow 5:22 10:20 11:20, 22,23,25 12:1 blows 11:15 hooker 8:9 bottle 15:7 bottom 8:12 break 14:8 20:6 bucket 16:? 17:5 build 17:2 20:7 23:13, 14,19 25:20 builder 2:15 6:10 7:6,10, 15 8:6 9:7 10:2 12:7 16:3 21:20 22:7,13 26:9 builders 13:25 14:4,20 16:12 18:20 19:4,7,15,21 21:8 22:16 building 2:18,23 3:2, 8,13,16,23 4:5,12 5:7,12 6:5,10,19 7:15 8:5 10:9 12:8 13:23 14:1,19 16:4 17:8,10, 22 18:2,11 19:15,16,21 9:6 U.S. LEGAL SUPPORT 866?339?2603 David Hyde Augcet 03, 201? 20:19 21:9,13 22:16 23:16, 17,18 built 3:4,21 9:1,3 10:1? 17:9 bunch 13:3 bus 18:5,9 button 21:18, 22,23,24,25 22:4,14 buttons 21:8 22:23 C-a-p?p 25:1 calendar calendared 26:24 calendars 26:18 called 2:9 14:3,6 15:8, 13 24:24 CAPP 24:24 25:1 careful carry catch 12:1,3 caught 9:14 22:6 23:9,11, 12,1? caused 23:1 cautious 5:13 chance 4:21 23:19 26:24 circumstances 13:11 close 22 cocaine 20:7 collect 5:20 commercial 17:9 23:2 13:5 15:19, common 4:12 25:12 companies 5:3 company 25:6, 7 complete 12:4 completely 17:11 components 3:19 4:1 6:11,14 2:11, 14 16 16:24 con?itions 2:18 conduct 20:13 consequence 19:3 contaminate 13:23 15:1 contaminated 2:23 contamination 2:23 continue 23:19 continuous 18:25 23:24 24:3,6,7,15 control 10:3 12:1 24:23 conveyer 8:10 correct 10:13 18:2 26:12,18 correctly 23:23 covers 5:23 cream 14:2,4, 5,6,15,16,20, 24 15:4 crown 6:11 customer 25:3 customer's 5:5 cut 11:4 Danville 3:2 7:16 12:7 16:4,12 17:9 18:1 19:21 21:1 22:17 23:5,6, 11,23 21:3,? 26:9,20,23 David 2:3,8, 15 day 9:8 16:15 days 15:21,22 deal 23:11 December 9:9 defect define 12:19 describe 10:23 detect 9:14 detecte? 9:12 10:2 detecting 9:10 dial 22:23 difference 11:17 diffiCult 8:7 DIRECT 2:11 disappointed 25:5,6 division 23:13 door 11:6 dozen 9:19 dress 12:9 drug 23:4 drugs 19:8, 16,22 20:24 21:1,4,21 23:10,11,l2, 18 drunk 20:2,4 dry 14:10,25 15:3,16,23 16:19,21 duly 2:6,9 earlier 20:5 24:25 25:2 easily 9:12 Eaeter 24:5 edge 7:25 8:1 e?fect 13:25 24:8 emphasis 24:18,19 employ 4:3 employee 23:21 employees 25:13,16 ended 22:6 error 12:6 escape 13:1? establish 3:23 evidence 24:11 EXAMENATION 2:11 examined 2:10 examples 19:11,19 excuse 19:10 experience 2:22 explain extruder 6 9:11,13 eyes 2:24 6:9 20:19 eyewitness 2:1? 25:18 7:2, U.S. LEGAL SUPPORT 866~339?2608 David Hyde o3,_2017 FAA 23:8 fact 12:18 19:4 fair 2:17 7:12,21 10:5 12:22 familiar 6:19 10:21 faster 23:1,2 favor 2:13 finding 9:16 fix 13:13 flat flipped 8:11 floor 4:9,10, 12 5:21 6:1 forget 22:7 forgot 22:6 fOurth 17:2, 3,5 frame 2:19 3:3 4:4,13 6:3 7:17 15:5 16:5,13 19:12,17 20:11,20 22:10 24:17 fresh 7:5 funnel 4:8 22:2d gentlemen 2:1? 6:18 15:11 goals 24:19 good 9:11,13 25:22 Goodyear 2:16 4:3 12:16.18 14:21,22 24:18 25:12, 13,19 green GSANGER 2:12 11:14 25:23 26:1,8 guess 20:18 guests 4:19 5:4 gum 6:17 ::18,19,23,25 8:1,7,ll,20 9:10,18 hundreds 9:20 Hyde 2:4,8,15 I half 6:24 hand 14:2,15, 16,20,24 15:4 hands 14:17, 16 happen 8:2 10:5 18:24 happened 3:5 20:14,16 22:11,12 hard 8:21,22 9:13 25:18 hear 10:19,20 25:8,10 hearing 19:18 heat 13:6,? heating 13:4, 13 heavy 5:19 hide 5:9 hired 9:8 20:9 hoist 21:16 hold 8:25 home 20:2,3 honest 19:23 horrible 16:19 hot 7:3,5 human 12:6 Ibupro?en 19:5 impaired 19:16,22 20:19 impression 9:5 in-houee 25:20 inaudible 18:17 inboard 6:16 inch 6:22,24, 25 includes 3:13 inside 6:16 inspection 10:3 instance 15:20 instructions 14:23 introduce 2:13 involved 18:15 involving 25:8 isolated 3:8 issue 8:14,16 10:12 issues 20:12 Johnny?come- lately 9:6 jury 2:14 6:19 9:4 10:19,20 15:11 17:19 Kengen 14:7, 15 15:8,12 16:3 kicks 21:15 killed 22:8 kind 5:1 6:6 13:20 17:22 18:7 26:14 January 9:8 jeopardized 22:5 jeopardy 22:2 jOb 8:21 9:5, 8 21:18 labor 17:11 18:15 ladiee 2:14 6:18 15:11 leaked 3:4 leaking 3:22, 25 leaks 3:11, 15,13 4:4 left 20:14, 16,22 life 22:5 liner 11:19 13:16,1? liners 13:6 locker 20:6 long 25:3 looked 25:13 lost 25:1 lot 13:12,19, 20 16:21 19:1,2,4 25:16 lots 13:1 LEGEL SUPPORT 866?339~2608 David Hyde 41497431: .93: 2.017 machine 5:12 8:5 9:15 12:8 16:10 17:13, 15,23 21:13, 14,24 22:19, 32,23 23:1 26:1? machines 3:16,23 4:8 5:8,18 18:2, 15 21:9 22:17 made 4:7. 26:11 make 8:6 9:4 15:24 16:1, 14,23 18:4,8 22:20 makes 17 makeshift 5:7 makeshifte making 16:13 24:18 26:10 man 21:14,15, 16,18,19 22:2,3 man'e 22:5 Management 20:3 manhole manual material 26:12,14 means 21:11 meant 24:25 25:3 mentioned 15:8 minute mishap 13:20 moisture 2:22 6:5,10 7:23 8:7 9:18 15:15, 5:23 17:18 25:25 10:1,? 13:23, 24 money 22:20 motto 25:4 mottoe 24:22 mouth 18:? neeoed 9:11 16:23 needing 12:19 NG 17:12,15, 22 nonprescriptio 19:8 occasions 19:6 26:23 4:13 Odino 15:13, 14,23,24 16:3,16,23,24 17:5 ointment 13:24 operation 23:24 24:4,6, 8,15 opinion 24:10 opportunity 6:8 19:6 21:7 overaged 15:16,20 16:21 overmedioeted 19:7 p.m. 2:4 26:3,4,5,7 package 11:2, 4,6 pain 19:2,3,4 painkillers 19:5 parallel 26:1? part 7:20 parts 3:7,10 Pass 23:23 passed 10:1 peg 21:21 22:7 pegged pegging 22:14 people 4:23 20:2,6,7,12, 23,25 21:1 period 8:24 19:20,25 periods 19:20 pereonally 14:2,16 phonetic 12:12 14:3 15:13 phrase 25:8, 10 physical 17:10,12,16, 17 18:15 pick 8:9 picks 21:16 piece 7:10 8:6 pieces 8:11 plant 3:2,5, 6,7,10,12 4:15,17,22 5:2,3,4,5,10, 20 7:16 10:10,16 12:8 16:4,13 17:9 18:4 19:21 20:12,13 21:1,2,4 22:17 23:5,6, 11,23 24:4,7, 8,22 26:10, 21:25 21,24 plant?s 24:14 plastic 5:6, 11 Ply-2 14:3, 15,16,20,23 15:4 poke 12:14 polioy 23:4 goly 4:6 pope 21:14 positive 23:1? pot 20:7 preeoription 19:8 press 8:1 pretty 5:13 23:8 prick 12:14 problem 20:22 proceed process 2:24 6:19 12:24 13:4,24 14:1 17:8,10 18:12 22:19,22 23:18 26:16, 20 processes 18:11 19:15 produced 24:9 product 4:6 14:11 15:25 16:1 25:20 production 24:11,19 Production's 24:15 provided 12:16 14:21, 22 puddles 4:10, 12 pull 22:7 purpose 14:5 U.S. LEGAL SUPPORT 865?339?2608 David Hyde .meesust 03; 2017 push 21:18,23 put 6:20 7:19 8:10 14:10 15:15, 17,23,25 17:2,3,4,13 18:7 22:2,: puts 21:16 putting 14:17,18 24:18,19 26:10 QC 9:14 quality 10:3 12:1 24:8,12, 19,23 25:20 quantity 9:17 quarter 6:24 question 10:11 questions 25:24 quick 14:11 rain 5:24 rained 3:5,6 rainstorm 5:19 rainwater 3:22,25 rainy 4:16 ran 7:8 reaches ready real recall receive received recess 26:4 record 11:12 25:25 26:2,6 ?:15 3:19 16:21 24:3 8:6 7:9 recording 2:2 re?er 17:25 region 6:11 regulations 23:3 remember 15:9 25:4 repairing 4:4 Repeat 19:18 repercussions 18:20 repetitive 18:19 respect 5:6, 19 23:4 result 18:19, 24 roof 3:1,10 5:25 24:13 room 2:18 3:2,8,13 4:5, 12 5:15 13:3, 5 20:6 rotator 19:1 round 25:8,9, 10,15 RTN 8:4 17:25 18:14 RTS 17:12,16, 25 18:14 21:13,14 rubber 6:9,11 7:2,10 13:4,15 12 15:1,15,18 26:15,16,18 run 10:11 12:25 13:10 23:24 runs 24:2 safe 24:19 save 13:21 scenario 8:18 scrap 13:? 23:3 24:13 season 4:16 self- medication 19:5 selling 20:23 21:1,4,21 send 21:18,23 sends 21:22 separate 4:6 separation 11:24 Settings 21:8 shift 22:6,8 shifting 24:? shop 20:2,3 shut 9:15 11:6 16:17,18 side 8:12 23:5,6,14,16, 17 sidewall 11:20.25 sidewalls 22:25 skin 14:8 slight 11:16 smoking 20:? smooth 12:15 soften 13:15 solution 4:3, 4 solvent 13:24 14:6 15:8,14 16:14 sort 2:22 8:19 9:18 19:14 scurces 2:22 SPEAKER 11:3, 5,6,8,10 specifically 19:25 23:15 speed 22:17, 21 speeding 22:19 standing 22:3 start 15:23 started 24:5 status 3:1 steel 26:10, 11 steward 20:3 stick 15:25 sticky 16:1 stitch 22:24 stitches 22:24,25 stitching 22:25 stock 15:2, 16,1? 16:19, 20 stored 3:20 strenuous 18:17,19 strip 6:17 7:18,24,25 3:1,8 9:10,18 strips 7:19 8:20 strung 5:11 stuff 25:21 stupid 22:15 style 17:25 suffer 19:1 supposed 12:1,4,s 15:21 Supposedly 12:4 swab 15:24 16:7,9,10 17:7 swear 2:5 23:10 sworn 2:6,9 U.S. LEGAL SUPPORT 866-339~2608 David Hyde 93.: 3017. tacky 14:12 15:2,15,17,24 16:2,23 talk 11:3,15 20:1 24:21 25:13,14,19 talked 11:23 24:21 talking 9:21 11:18 14:14 18:10,11 20:8 24:17 talkS tarp tears tents term 10:19,20 25:16,17 tarminated 23:20 terms 9:1? 10:21,25 11:16,17,18 17:19 18:14 24:23 terrible 24:12 testified 2:10 testimony 2:3 teating 23:17 thick 6:22, 24,25 thickneas 6:23 thing 2:21 11:16 things thinks thought thousand 9:22,24 25:19 5:11 19:1 10:8 22:3 24:25 thausands 9:29 time 2:4,18 3:2,4 4:4,13 6:3 7:16 15:5 16:5,13, 19 17:1 20,2: 20:11, 20 21:5,19 22:10 23:21 24:1? times 9:17, 19,20,21 tire 2:15,18, 23 3:1,8,13, 15,19,22 4:1, 5,12 5:7,11, 15 6:6,9,12, 19,20 7:6,9, 15,16 8:4,6 926,7 10:2,9, 13,16 12:4,5, 7,8,14,21 13:21,23,25 14:1,3,20 16 3,12 22 18:2,10, 11,20 19:4,5, 15,20 20:19 21:7,9,14,15, 16 22:13,16 23:5,6,13,16, 11,18 26:9,10 tires 5:10 8:21 9:1,3 12:25 13:3,5, 6,1,10,12,13 14:19 16:4,13 17:9,10 18:5, 8,9 19:16,21 20:7 21:14 22:17 23:3, 24:9,20 26:10 titles 8:25 today 25:6 told 25:13 tolerance 6:5 teal 12:8,11, 16 top 3:22,25 total 9:22 tour 4:22 tours 5:1 trade 9:6 transcribed 2:1 trapped 2:23 8:1,19 9:18 10:8,15 12:21 13:1,22 'trapping 10:7,12 tread 6:16, 1?,20 7:2,5, 1,9,14,15,20, 21,24 8:6,8, 9,19,20 9:19 11:20,22,23, 25 12:2 15:19,20,21 17:6,? treads 6:23 17:7 truck 6:6,10 7:16 8:4 10:9,15 16:4 17:9,10 18:5, 9,11 19:21 22:15 23:5, 13,16,19 26:10 Trucking 5:3 true 3:8 5:12 2:3 13:5 tubers 9:15, 16 turned 22:23 turret 21:13, 15,17,18,22 turret'a 22:4 type 26:11 Uh~huh 17:14 ultimately 7:20 underaide 7:20,21 undarstand 6:20 10:23,24 17:20 23:23 25:21 understandi?g 21:5 UNIDENTIFIED ll:1,3,5,6,8, 10 Vendors 5:4 veraus 23:5 View 21:7 visitors 1:19 walk 24:21 25:14,19 wanted 14:4 water 4:8,18 5:20,21,2& 8:3,19 9:10 10:12 11:24 week 16:19,20 wet 6:15 White 7:3 Wide 6:25 7:1 wire 26:15, 15,22,24 wires 26:1?, 18 wit 2:2 word 25:1 LEGAL SUPPORT 866?339-2608 David Hyde . August ?3r 2017 words 18:? WOrk 7:6 18:19 worked 21:l 23:7 workers 4:21 working 12:7 26:9 wrong 23:9 1. X-ray 12:3,4, years 8:21 9:1,23 LEGAL SUPPORT 866h339?2608