Document 225vr1aJpdd7B9gdrm3DJNgp

322 1 Sayers 2 Q. Is that a factor you would have liked or 3 been interested in knowing? 4 A. Very much so. 5 Q. And Mr. Polk asked you a question if 6 you -- whether you would like to know how many 7 people had died from the Conwed plant. Do you 8 recall that question? 9 A. 1 do. 10 Q. Do you feel that without the information II about amosite that question was misleading? 12 MR. BROWNSON: Objection, leading. 13 A. 1 must say yes. 14 Q. Do you feel it was maybe a half-truth? 15 MR. BROWNSON: Objection, leading. 16 A. It could have been. 17 Q. Tell me, Mr. Sayers, you were asked 18 about whether you would be interested in how many 19 people had gotten sick from exposure to Calidria 20 asbestos; do you remember that? 21 A. I do. 22 Q. Did Mr. Polk tell you anything about the 23 experience at King City, California, where the 24 workers mined and milled Calidria asbestos? 25 MR. POLK: Objection, leading. 324 1 Sayers 2 worked only with Calidria asbestos? 3 A. Yes, 1 certainly would. 4 Q. Would you think that was relevant 5 information? 6 A. Indeed. 7 Q. And by not giving you that information. 8 do you think you were given a half-truth? 9 MR. BROWNSON: Objection, leading. 10 argumentative. 11 A. I do. 12 Q. You were asked a number of questions 13 about whether in your opinion asbestos could be 14 hazardous or cause injury. Do you recall that line 15 of questioning? 16 A. Yes, 1 do. 17 Q. I want to make sure I understand, 18 because 1 thought I heard you say a couple of 19 different things to Mr. Polk. 20 Do you have the Demehl toxicology 21 report, which is Exhibit 4? 22 A. 3. 23 Q. 3,1 apologize. 24 A. Yes. 25 Q. It starts out very first sentence says. 323 1 Sayers 2 A. No. 3 Q. Did Mr. Polk tell you anything about the 4 fact that there hadn't been any cases of 5 mesothelioma out there? 6 MR. POLK: Objection, leading. 7 MR. BROWNSON: Objection, leading. 8 A. That was my understanding. 1 was 9 surprised by the revelation. 10 Q. Did Mr. Polk tell you that, though? II A. No. 12 Q. Did Mr. Polk tell you that there hadn't 13 been any cases of lung cancer among the people out 14 there? 15 MR. POLK: Same objection, leading. 16 self-serving. 17 A. No, he did not. 18 Q. Did Mr. Polk tell you that there hadn't 19 been any cases of asbestosis of the workers out 20 there, among the workers out there? 21 A. No, he did not. 22 MR. POLK: Same objection. 23 MR. BROWNSON: Same objection. 24 Q. Would you be interested in knowing 25 about the health experience of the workers who 325 1 Sayers 2 "It has been known for many years that some persons 3 working in asbestos production were prone to 4 develop a disabling lung disease. In time, this 5 condition became known as asbestosis and was 6 related to exposure to high concentrations of 7 asbestos dust." 8 Did I read that correctly? 9 A. Yes, you did. 10 Q. When you were working for Union Carbide II in 1965, '66, '67, what was your belief about 12 whether high -- exposure to high concentrations of 13 asbestos dust could in fact cause asbestosis? 14 A. Yes, 1 understood that to be the case. 15 Q. When you looked at Exhibit 2, the New 16 York -- excuse me, the Sunday Times article about 17 mesothelioma, did you also understand that in some 18 circumstances asbestos could cause mesothelioma? 19 A. 1 understood the article, but it was 20 clear that that particular disease was in its very 21 early days, and 1 don't think it was fully 22 categorized. 23 Q. When you did your reading of your 24 articles and your talking with the medical 25 professionals, as 1 read your report, you were told SPHERION DEPOSITION SERVICES (212)490-3430 82 (Pages 322 to 325)