Document 2q0g0ygQazbwj7yJOMDk6vqV7

IN' THE UNITED STATES DISTRICT n';\'~Z 7 Or. THE NORTHERN DIETPIC" OF 0 T_l.3 :;T f EASTFRN DIVI f I 0' Ti'.T UNITED SI ATE? OF AMERICA , ' Plaintiff, Vs . OUTBOARD MARINE CORPORATION, Defendant, Third Farty Plaintiff, vs . MONSANTO COMPANY, Third Party Defendant. } ) \ ) ) ) ) ) 7' ) ) ) ) ) r. - L The sworn statement of NORMAN T JOHNS' taken at the Henkel Corporation, 2360 Eas Devon Avenue, DesPlaines, Illinois, on Thursday September 20, 1979, at 8:50 o'clock A.M., uron interrogatories propounded by Mr. Bruce A Feathrrstone . PRESENT: "r.-. Mr. Norman T. Johnson, Mr. Bruce A. Featherstone, Ms. Jane Holier. Reported for LA SALLE REPORTING SERVICE, by Jane Holler. DEPOSmON EXHIBIT _ %S,, HARTOLDMON0041499 d Did you discuss this noint K 1 th Mr. Sten ber;r? A. We talked about where it w as concent rat 5 nr yes. And the implication certainly it could <* i r. t c the food chain by wav of lake trout in Lake *'! c h i d And by "it" you mean PCB? A. PCB. d Other than yourself and Mr. Stenberr, was there anyone else who was a party to this conversation? A. I don't remember, other than Bob Daminai would have been there on both those occasions. v.'e did not make calls on a customer without the salesman. d Did there come a time when Monsanto sold Johnson a Pydraul fluid other than Pydraul A-200? A. Yes. We started to reformulate to Droduce a new product which was based on chlorinated ternhenyl and a lower chlorine content biphenyl which would greatly minimize or hopefully eliminate the higher chlorinated material, chlorinated biphenyl that was showing up in the environment. And that product was called Pydraul A-200B. 12 d Pydraul A-200B? A Yes. HARTOLDMON0041500 c\ Did Monsanto advise Johnson Motors that Pydraul A - ? 00 had been reformulated to ? v d ra u1 A-2333? A. A b s c 1 u t e 1 v , ^ What v:as said tc John nor. Motors about the chemical differences between Pydraul A-209B, the substitute fluid, from its predecessor Pydraul A - ? 3 3 ? A. We would have defined tne chemistry of the terphenyl and the chemistry of the biphenyl , and talked about the percent are of chlorine on each of the rinr;s and how we were taking a solid material and blending it with the low chlorinated licuid material to gain solubility, and derive a replace ment hydraulic fluid that would be low in the hirher chlorinated biphenyl materials. Q Who were these discussions.- with at Johnson Motors? A. I would remember the discussion with John Nevill. ' Q Did you tell Mr. Nevill the reasons for the reformulation to Pydraul A-200B? A. No question. We had been keeping Johnson Motors informed about the whole PCB problem, and they certainly recognized the reformulation was an HARTOLDMON0041501