10 Joseph Bidwell, for plaintiff, direct. would make it somewhere 9 or 10 foot from the ground. Q. This was a brick building with tile facing? A. Yes. Q. A. The school house is built out of brick? Q. It is on what kind of a foundation? Q. And from the concrete to the first story what is the material that it is constructed of? A. It is constructed of brick or a veneer of brick on the outside. Q. How wide is that? A. 4 inches with a 12 inch tile on the inside with a 2 inch air chamber between the tile and the brick. Q. Is that the way it is constructed to the first story? A. To the first story; makes an 18 inch wall. Q. On the southwest side of the building between the main entrance and the southwest corner how many openings were there in the main building? A. I think there were three. Q. I mean on the southwest; on the southwest corner or southwest side where this accident happened, how many openings were there in the wall? A. Way across the building? Q. No. A. Or from the corner to the main door? Q. From the corner to the main door? 12 A. I won't say for certain, but either three or four openings to that door. 13 Joseph Bidwell, for plaintiff, direct. Q. On the side of the building from the main entrance to the corner on the side where this accident happened, how many of them? A. I think there were three. Q. I don't think you understand my question. The accident happened on what portion of this building? Was it on the west side or east side or north side or south side? A. I should call it the north side. I am a little turned around like that; it was on the side of 3d street. Q. On the side of that building or 3d street from the center hall to the south where you were laying these joists how many openings are there in the wall? From the center of the building south to where these joists were being put on? You were on a wall how long? A. 24 foot. Q. How many openings were there in that wall? A. I should say there was three; I won't say for certain; I can't say; I don't remember. Q. That wall had got to be about how high? A. 15 Between 9 and 10 feet, I should judge. Q. Were you there when it was being constructed? A. Yes, sir. Q. And it was constructed of what material at that height? 18 17 16 Joseph Bidwell, for plaintiff, direct. A. Brick for face and tile for inside. Q. Give the dimensions so that I can get them. A. 4 inch brick facing with a 12 inch tile with a 2 inch chamber between the brick and the tile. A. They moved over on the other side of the building and started to work over there. Q. And what did they move with them? A. Their scaffolds and all their planks and such as that; what they had to work on. Q. And after they had moved, was there any scaffolding on this side of the building? A. No; there wasn't. Q. Where the accident happened? A. No; there wasn't. Q. Was there a door or a window casing put in there? A. It was a window casing and they were supposed to make a door casing out of it; that is what it was calculated for; a door. Q. About how large a space in the wall did that occupy? A. About 40 inches wide and about 7 feet long. Q. And what was put in there at the time of the accident? A. There weren't anything in there only the frame. Q. About what were the dimensions of that frame on top? The dimensions? Q. Did it set in between the tile or in between the brick? A. In between the tile. Q. What, if anything, was put on top of the brick? A. If it was put there, it was put there for the protection of the brick. Q. What was put there? A. 78ths inch board, 6 inches wide. Q. Where were they laid? A. They were laid over the brick. 19 Q. How with reference to the length of the wall? N A. It was 24 feet from the corner to the main entrance. Q. Were they laid the entire length of the 24 feet? A. They were laid the entire length. Q. How were they laid with reference to the window casing 7 inches wide? A. Laid over the opening. Q. Came right up close to the window? A. No, sir; the same as that there (indicating), so that there was no space between whatever that a man could notice, could see. Q. When did you first start working upon this wall? A. The day before. 21 23 22 Q. Joseph Bidwell, for plaintiff, direct. The day before the accident? A. Yes, sir. Q. Who directed you, if anybody, to go working A. He told us to put in the joists and when we We got around to this place to put in our headers. started to frame our headers. in? Q. You started the day before to put the joists A. Yes, sir. Q. Was he around there all the time? A. Yes, sir; back and forth and all around there. Q. And were these boards on this wall at this time? A. Yes, sir. Q. Describe the joists that you put on there? A. They were 2 by 12 joists, 15 foot long; I should judge they weighed in the neighborhood of 150 pounds apiece; somewhere around there. Q. How were they laid? A. They were laid up; both ends bevelled off and then they were laid up on the 2-inch face and then there was a strip put on the top to hold them from tipping over and then shimmed up with slate. Q. Were they laid from the tile on the wall to the partition wall? A. Yes, sir; 4-inch partition inside. Q. From the 4-inch partition to the outside wall? |