Document 2qX8n6ympdvEMx90rO3oRbRdp

Page 2760 1 MR. SHELLENBERGER: Thank you, Your Honor. 2 This is Tuesday, October 24th, 1995, page 3 3170, line 16. 4 Your Honor, at this time the plaintiffs have 5 a very brief reading of trial testimony conducted in 6 the Abate I, the first Consolidation in 1992; and this 7 is the testimony of Dr. Thomas F. Mancuso, and the 8 date is March 17th of 1992. 9 Reading of trial testimony of Dr. Mancuso 10 taken on March 17th, 1992. 11 READING OF TRIAL TESTIMONY OF DR. THOMAS F. MANCUSO 12 TAKEN ON MARCH 17, 1992 13 (Whereupon, the questions were read by Mr. 14 Shellenberger and Mr. McGowan and the answers were 15 read by Mr. Ignatowski.) 16 BY MR. SHELLENBERGER: 17 Q Doctor, would you state your name and your 18 business address, please. 19 A Dr. Thomas F. Mancuso, capital 20 M-a-n-c-u-s-o, 5127 Elsworth Avenue, Pittsburgh, 21 Pennsylvania. Page 2761 1 Q Where did you go to medical school, sir? 2 A Creighton University, Omaha, Nebraska. 3 Q What year did you graduate? 4 A 1937 . 5 THE COURT: Before you continue, let me just 6 ask, are there any defense designations? 7 MR. McGOWAN: Your Honor, I believe there is 8 a page or two that I will read. 9 THE COURT: Okay. I just wanted to make 10 sure I got that correct. 11 Thank you, Mr. McGowan. 12 MR. McGOWAN: If no one has any objection, 13 we will expedite and summarize the things. 14 MR. IGNATOWSKI: I don't have it. 15 MS. TOSTANOSKI: It is in there. 16 MR. McGOWAN: It takes a minute. 17 BY MR. SHELLENBERGER: 18 Q Did you ultimately enter a field of 19 specialty in the practice of medicine? 20 A I did, sir. 21 Q What is that? j 1 Industrial medicine, in 1942. Page 2762 2 Q Do you hold a Master's degree in public 3 health? 4 A Yes, sir. 5 Q Did you work for the Surgeon General of the 6 United States? 7 A Yes, sir. 8 Q As distinguished from clinical medicine or 9 hands-on doctoring, what kinds of medicine did you 10 practice? 11 A Public health is the specialty of industrial 12 medicine and industrial hygiene which, in contrast to 13 clinical medicine, which is focused on individuals, 14 the public health, and industrial medical aspects 15 focused on hundreds and thousands and eventually 16 millions of individuals, and in groups of all of those 17 individuals who are exposed to the microchemical 18 environment, the toxic dusts, fumes, vapors, mists and 19 gases in which they are exposed during the work 20 environment, in contrast to the microbiological 21 environment or causation of the disease that the 1 doctor in practice uses, the causation by bacteria, Page 2763 2 virus. 3 That would quickly summarize it. 4 Q All right. If I could try and put it in my 5 own terms so I can understand what you said, the 6 average doctor out there will take one patient and 7 examine him and he will diagnose, hopefully, what that 8 patient has, right? 9 A Yes, sir. 10 Q What you are doing is look at groups of 11 patients and trying to find out what causes disease in 12 an individual patient; is that fair? 13 A Yes, sir, the industrialpopulation. 14 Q Sir, have you been therecipient of any 15 awards and recognitions of your practice in public 16 health? 17 A Yes, sir. 18 Q Did you receive an award in the late 1980s 19 from the Steelworkers of America? 20 A Yes, 1987, sir. 21 Q Were you recognized by international 1 scientists all over the world in the organization Page 2764 2 called the Collegium Ramazzini? 3 A Yes, sir, in 1988 there were two 4 international scientists selected, Dr. Clemmesson from 5 Denmark and Dr. Mancuso, myself, from the United 6 States. 7 Q Doctor, the jury has heard the name American 8 Conference of Governmental Industrial hygienists. 9 Have you held an office in that 10 organization? 11 A Yes, sir. 12 Q What office did youhold? 13 A The highest office was chairman in 1958, 14 sir. 15 Q Did you hold that office? 16 A Yes, sir. 17 Q Have you publishedany articles in the 18 scientific literature, Doctor, that dealt with 19 asbestos disease? 20 A Yes, sir. 21 Q Can you tell us approximately how many? Page 2765 1 A I think there were eight major articles, 2 sir. 3 Q Eight major articles on asbestos? 4 A Yes, sir. 5 Q Have you been called upon to present your 6 findings at international meetings of scientists, that 7 is; your findings on asbestos? 8 A Yes, sir. 9 Q Have you been called upon to testify before 10 governmental agencies, including the Congress of the 11 United States? 12 A Yes, sir. 13 Q Did you serve as an advisor to the 14 Occupational Safety and Health Administration when 15 that agency came into existence? 16 A Yes, sir, as part of a congressional review 17 that I carried out. 18 Q Doctor, did you serve as vice-president of 19 the American College of Preventive Medicine? 20 A Yes, sir. 21 Q You have been a consultant with the Surgeon 1 General of the United States on air pollution? Page 2766 2 A Yes, sir. 3 Q Now, I have asked you to prepare some way to 4 show the jury -- when you say five million particles 5 per cubic foot, five million sounds like a lot to me. 6 But have you prepared something to show the 7 jury what five million looks like in connection with 8 asbestos? 9 A Yes, Ihave. I have to do it by weight 10 because it is microscopic in nature and you can't see 11 it, but only if you do it by weight can you see a tiny 12 speck, and I have prepared that sample. 13 Q Is that sealed so it won't get out? 14 A Yes, it is sealed. The tiny white point is 15 100 percent pure asbestos. 16 Q Is it five million particles, the white 17 spec? 18 A The white spec. 19 MR. SHELLENBERGER: That would conclude our 20 portion, Your Honor. 21 THE COURT: Mr. McGowan. 1 MR. McGOWAN: 3179. Page 2767 2 MR. IGNATOWSKI: I don't have your counter 3 designations. 4 MR. McGOWAN: All right. 3179, do you have 5 that page of the deposition? 6 MR. SHELLENBERGER: What? 7 MR. McGOWAN: 3179, do you have it? 8 It is just one page. 9 One second, Your Honor. 10 (Whereupon, pause.) 11 MR. IGNATOWSKI: Line 8, yes. 12 BY MR. McGOWAN: 13 Q You have a little vial of asbestos that you 14 showed us yesterday that you said was asbestos. 15 A Yes, 100 percent asbestos. I don't have it 16 here. I have turned it over for the Court to have. 17 Q Who measured that asbestos? 18 A Professor John Fohlinger at the University 19 of Pittsburgh, who has his own private consulting 20 company. 21 Q You did not measure it, did you? 1. A No. It was done by a specialist, a Page 2768 2 professor in industrial hygiene chemistry. 3 Q Did you count the fiber? 4 A No, the professor of industrial hygiene did 5 it by weight. He took care of that, sir. 6 Q They just handed you a vial and told you 7 what was in it? 8 A With an attached affidavit saying what it 9 was. 10 Q You did not personally prepare that, did 11 you? 12 A No, I am a professor of industrial 13 medicine. I rely upon professors of industrial 14 chemistry to do that. 15 MR. McGOWAN: That is all. Thank you, Your 16 Honor. 17 THE COURT: Thank you. Next. 18 MS. HINES: Your Honor, at this time I would 19 like the Court to take judicial notice that Mr. Wood's 20 case was filed in September of 1992. I 21 And next, we will have the reading of the