Document 0LwqZ0EqYn2DL5zomj1ow3E8x

1 their opinion, did you consider cost of developing Page 246 2 alternative materials to substitute out for asbestos in 3 making that determination? 4 A I didn't have to because there was no evidence 5 during the journey of the last 40 years that there was j 6 a risk. So I didn't have to do that analysis. 7 Q Your analysis of reasonableness is based on 8 the conclusion that there is a risk? 9 A No, actually it was a, it was based on evidence ; 10 as time moved forward, that there was no risk and they 11 were moving to eliminate the asbestos anyway. The two 12 thoughts or the two processes in motion simultaneously : 13 created reasonableness. 14 Q What level of risk of development of I 15 mesothelioma would the epidemiology studies that are on 16 Exhibit 15 detect? 17 THE WITNESS: Can I hear that again, please? j 18 (Record read.) 19 THE WITNESS: I don't know how to answer that. 20 BY MR. RUCKDESCHEL: 21 Q Would they detect a l-in-10,000 risk? 1 22 A Oh, that's your question. ! 23 Q That is my question. We'll make that my 24 question. And then we can change the number. 25 A I can't see a l-in-10,000 risk. ESQUIRE DEPOSITION SERVICES (415) 288-4280