Document 2NBgGY65MOwjoM57QBMbOe24a
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PLAINTIFFS EXHIBIT
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PLAINTIFF'S EXHIBIT
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to C. S. Ballard - CP6 subject Asbestos Interrogatory
Produced pursuant to order of Judge Derwln Maplee, Circuit Court. Jacfceon County. Mieelseippi In et.al. v. GAF Corporation, et.al.
intra-company correspondence
date May 26, 1931
from Jon L. Konzen, M.D. - Til
phone 8237 cc:
CLAIMED PRIVILEGED
BX OCF
A number of these questions which you asked me to answer, including #63, 64, 65, 66, 70, 81, 835, 83F, 83J and 83K, are remarkably similar to previously answered ouestions. It would be important to check my answers for consistency with the previous answers. If there is any
inconsistency, please contact me.
Question #63 Question *64
Epidemiological evidence suggests a relationship between asbestos overexposure and cancer of the gastro-incestinal tract.
The epidemiological evidence linking cancer of the throat with asbestos overexposure is not strong.
Question *65
There is reasonable epidemiological evidence which suggests that asbestos overexposure contributes to cancer of the stomach.
Question *66
Same answer as *64.
Question #70 Question *81
Yes.
Question 81 is so broad that I am not sure that you can
give an answer. If you would choose to read into the question the word "normal structure" then the answe** would be yes. However, the anatomical structure of abnormal lungs would not be the same as normal lungs.
Question #S3E
I personally learned of it between I960 and 1964. It would be important to check previous answers to this question with regard the company. I joined the company in 1968; thereror= the company would have had knowledge, certainly at chat time
Question #83F
The best answer is"l"(after 1972), while there was some suggestion before 1972 the best evidence was developed after 1972.
Question #33J
- I don't believe that I am the best source of this information since it was generally accepted when I came with the comany in 1963 that installation of asbestos containing materials could cause asbestos related oisease.
Question 3<
- The answer to this question would Drobubly relate to a oerio of time prior to my coming with the company. 1 learned of the relationship djrir.g my residency training in the period
"H"(I960 thru 1964).
02 006 1264
C. S. Ballard - CP6
Produced pursuant to order of Judge Darwin Maples, circuit Court. Jackson
County. Mississippi in Abrams, et.al. v. GAP Corporation, et.ai.
CLAIMED
PRIVILEGED
page - 2
by OCF
May 26, 1931
If you have any questions or continents, please contact me.
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02 006 126
f.
Produced pursuant to order of Judge Darwin Maples. Circuit Court. Jacltson County. Mississippi in Abrans.
v. GAF Corporation. et._aL,
1970 - 1980.
_
Claimed
privileged B3T OCF
I
60. Inhalation of asbestos fibers is the cause of
|| asbestosis. ii i
I
I 61 ! mesothelioma
\
Inhalation of asbestos fibers is a cause of
I
62.
j lung cancer.
I 1
jj
Inhalation of asbestos fibers is a cause of
63. Inhalation and/or ingestion of asbestos i fibers is a cause of cancer of the gastro-intestihal tract. i
'i
64. Inhalation of asbestos fibers is a cause of '! cancer of the throat. i
63.
02 006 126
Produced pursuant to order of Judge Darwin Maples, Circuit Court, Jackson County, Mlsoiseippl In Abrams, at.al. v- GAP Corporation, et.al.
CLAIMED
!i PRIVILEGED
! BY OCF
65. Inhalation of asbestos fibers is a contribut ing cause of cancer of the stomach.
66. Inhalation and/or ingestion of asbestos fibers is a cause of cancer of the anus.
67. There is no known medical cure for asbestosis.
lioma
68. There is no known medical cure for raesothe-
II i 69. Asbestosis is a progressive disease.
i
64.
ii
02 006 126'
t
i*
.y
.i
65.
02 006 126S
Produced pursuant to order of Judge Darwin Maples. Circuit Court. Jackson
CLAIMED
. I PRIVILEGEDCounty. Mississippi is Abrams, t.al. v. GAy Corporation, at.al.
I BYOCF
77. The first symptoms of asbestosis do not
normally appear until many years after exposure to asbestos-
containing dust.
78. Asbestos has been classified as a "hazardous substance" under The Hazardous Substance Act, 5 U.S.C. Section 1261, et 3eg.
79. The effects of inhalation of asbestos may be cumulative.
80. Asbestosis causes the individual affected to be more susceptible to other cardio-pulmonary diseases.
81. The anatomical structure of the lungs of all human beings are the sane from a medical and scientific standpoint.
71.
02 006 1269
CLAIMED
PRIVILEGED
Produced pursuant to order of Judge
BY OCF
Darwin Maples, Circuit Court, Jackson County, Mississippi Is Abrans. et.al. v. SAP Corporation, et.al.
j 1968 - 1970;
ti
k. 1970 - 1972;
1. After 1972.
83.E.
You first learned that a person could
develop a malignant pleural tumor as a result of exposure
to asbestos-containing dust in:
a. 1920 - 1930;
b. 1930 - 1935;
c. 1935 - 1940; i
81.
02 006 1270
Ocp d 1940 1945;
Produced pursuant to order of Judge Darwin Maples, Circuit Court, Jackson County, Mississippi in Abraas. et.al. y. GAP Corporation. et.a]j-
e. 1945 - 1950;
f. 1950 - 1955?
g. 1955 - 1960?
h. 1960 - 1964?
i. 1964 - 1968? j. 1968 - 1970?
82. }
02 006 1271
Produced pursuant to order of Judge
Derwla Maples, circuit Court, Jackaon
k. 1970 - 1972;
County, Mississippi In Abrst.al. v. GAP Corporation, et.al.
ii
1. After 1972. i
.1 i
83.F.
You first learned that a person could
\i develop cancers of the gastro-intestinal area as a result
11
i! of exposure to asbestos-containing dust in;
a. 1920 - 1930; | ii il
b. 1930 - 1935? II
c. 1935 - 1940; i i
d. 1940 - 1945;
83.
02 006 1272
e. 1945 - 1950; f. 1950 - 1955;
CLAIMED privileged
BX OCF
Produced pursuant to order of Judge Darwin Maples, Circuit Court, Jackson County, Mississippi in Abraas, st. al. v. GAP Corporation. et.al__.
g. 1955 - 1960; h. 1960 - 1964?
i. 1964 - 1968?
j. 1968 - 1970; tr,i:
' 3 -cantair..
V 1 O p a c: ^ tr
k. 1970 - 1972?
84 02 00 R i9
h. I960 - 1964;
CLAIMED PRIVILEGED
BY OCF
Produced pursuant to order of Judge
Darwin Maples, Circuit Court, Jackson
County, Mississippi In
|
t.al. v. GAP Corporation, et.al.
i. 1964 - 1968;
j. 1968 - 1970;
k. 1970 - 1972;
1. After 1972.
You first learned that a person working in.the area in which your asbestos-containing products were being instal}*#* or torn out could develop asbestos-related disease in:
90
02 006 1271
CLAIMED PRIVILEGED
BY OCF
h. 1960 - 1964;
Produced pursuant to order of Judge
i Darwin Maples, Circuit Court, Jackson County, Mississippi in Abrams,
i et.al. v. GAP Corporation, et.al.
i
i
I
li i. 1964 - 1968;
j. 1968 - 1970;
k. 1970 - 1972;
1. After 1972.
ii
83.X
You first learned that a person who was
i II not occupationally exposed to asbestos could develop asbestos-
related. disease in*
a. 1920 - 1930;
i 92
l
1)2 006 127.5
b. 1930 - 1935 c. 1935 - 1940;
Produced pursuant to order of Judge Darwin Maples, Circuit Court, Jackson County, Mississippi In Abrams, et.al, v. GAP Corporation, at.ai.
CLAIMED PRIVILEGED
BY OCF
d. 1940 - 1945;
e. 1945 - 1950;
f. 1950 - 1955; I1I g. 1955 - 1960;
h. I960 - 1964;
93.
02 006 1276
Produced pursuant to order of~Judg*
Darwin Maples. Circuit Court. Jackson
i County, Mississippi in
,
i i. i 1964 - 1968; et.al. v. GAP Corporation, et.al.
j. 1968 - 1970;
CLAIMED PRIVILEGED
BY OCF
k. 1970 - 1972;
1. Aftar 1972.
83.L.
You know that aorta of your own employees
i who had been exposed to asbestos dust had become ill with or l
!, contracted the disease of asbestosis in:
t * a. 1920 - 1930;
,1
itI
!!
It iI
II b. 1930 - 1935;
}
f l
M
94. i
02 006 1277