Document 0q5Gwj53k7kbLdJvR79pN19Xd

218 1 Sayers 2 draw your attention to page 4 there under the 3 introduction. The first thing you say is that 4 "Union Carbide U.K. Limited has been promoting the 5 sale of Coalinga asbestos forjust over two years"; 6 right? That's your opening sentence? 7 A. Yes. 8 Q. 1 want to make sure we're clear here. 9 Coalinga asbestos is the same thing as Calidria 10 asbestos? II A. Yes. 12 Q. Those are two different names for the 13 same thing; right? 14 A. They're synonymous, yes. 15 Q. You recognize that as the Union Carbide 16 chrysotile asbestos mined at King City, California? 17 A. Correct. 18 Q. At the Union Carbide mine? 19 A. Thai's right. 20 Q. Then you say, "During this time, the 21 public has become increasingly aware of the 22 considerable health risks associated with the use 23 of this material." 24 Do you see that? 25 A. 1 do. 220 1 Sayers 2 saying, look it, you know, you're trying to sell us 3 the Union Carbide asbestos but we have questions 4 about the use ofasbestos in our mills? 5 A. Yes. 6 Q. Then you continue and you say, these 20 7 or so customers or over 20 customers have requested 8 an assurance that Union Carbide's material will not 9 be a source ofdanger to their employees; correct? 10 A. Yes. II Q. And at least as far as you were 12 concerned, once you completed your review and 13 completed your report, you concluded that you could 14 not give any kind of absolute assurance that there 15 was no health hazard with that asbestos or any 16 other kind of asbestos? 17 A. Definitely could not. 18 Q. There were some health hazards, maybe 19 different kinds, associated with the use of 20 asbestos? 21 A. So it appeared, yes. 22 Q. One of those hazards that you 23 specifically identified and talked about in your 24 report and found reference to in the scientific 25 literature was mesothelioma? 219 1 Sayers 2 Q. Now, when you wrote that, you didn't say 3 that the public was becoming increasingly aware of 4 considerable health risks associated with other 5 kinds of asbestos; you said "this material"; right? 6 What you meant there was asbestos? 7 A. 1 meant asbestos, not specifically 8 Coalinga. 9 Q. But you also didn't mean specifically 10 other kinds of asbestos. What you meant was all II asbestos? 12 A. 1 did 13 Q. Then when you continue and you say, "So 14 far. over 20 potential customers have raised the 15 issue." you're talking about 20 potential customers 16 of Union Carbide Calidria chrysotile asbestos? 17 A. That's right. 18 Q. To whom you were trying to sell this 19 asbestos in your job as a salesperson? 20 A. Yes. 21 Q. And these customers were these 22 papermaking mills that you told us about earlier? 23 A. That is fight. 24 Q. So just if 1 could summarize this, the 25 papermaking mills in England were coming to you and 221 1 Sayers 2 A. Yes. 3 Q. Then you continue and you say that Union 4 Carbide's replies up to this time. May 12th, 1967, 5 to these customers has been based on two 6 communications sent from the New York office. And 7 by that 1 assume you mean the New York office of 8 Union Carbide. 9 A. That is so, yes. 10 Q. Sent over to England; right? II A. Yes. 12 Q. The first is March 22nd, 1966. Do you 13 know what that was? 14 A. Yes. 15 Q. What? 16 A. 1 think this was this table this 17 morning. 18 MR. WILL; It's an exhibit. 1 think he 19 means it's -- it's Exhibit 5,1 believe. 20 MR. BROWNSON: Can you point that out 21 for us? 22 MR. WILL: Sure. Yes, it's Exhibit 5. 23 THE WITNESS; That's it. 24 Q. So the first thing Union Carbide 25 showed the customers was what's been marked as SPHERION DEPOSITION SERVICES i ->\ inn > ,i "?rv 56 (Pages 218 to 221)