Document 3eNEq2kRp1yz0QQ0r7MDR0MN6

334 336 1 Sayers 1 Sayers 2 computed. It's almost 5:30 now. 2 MR. WILL: Yes, let's talk to him. He 3 MR. WILL: 1 have some other things I 3 left the room. He doesn't leave any 4 would like to cover with the witness. 4 instructions. 5 MR. POLK: That's fine. You can do it 5 MR. GOLDMAN: Actually he did leave 6 in the morning. 1 don't have any problem 6 instructions to call his hotel. 7 with that. 7 MR. WILL: Right. Where is he 8 MR. WILL: 1 don't think we have any 8 staying? 1 have no idea where he's staying. 9 arrangements to do that. We can take a 9 MR. SHIPLEY: Do you know where he's 10 15-minute break ifyou want to grab a 10 staying? 11 sandwich or something like that. II MR. BROWNSON: Do whatever you want -- 12 MR. POLK: There is not a judge in the 12 MR. SHIPLEY: What is unreasonable 13 country, Trevor, that would say my request 13 about stopping -- he has ten minutes of 14 to resume in the morning is out of line. 14 examination that has been going all day. 15 MR. WILL: Nobody has made 15 What is wrong with that? 16 arrangements to do it tomorrow. 16 MR. BROWNSON: 1 say Trevor resumes at 17 MR. POLK: This deposition is noted to 17 his peril. 1 will sit here until he's done. 18 continue from day to day until completed. 18 He can do whatever he wants. 19 MR. BROWNSON: Right. 19 MR. WILL: Let's go back on the video 20 MR. WILL: I want to at least finish a 20 record. 21 couple things, and then we can take a break. 21 THE VIDEOGRAPHER: The time is 5:32 22 These will be very short. 22 p.m. We're back on the record. 23 MR. POLK: The record will reflect 1 23 MR. BICKS: I'm going to suggest to 24 am leaving the room. It is now 5:30. 1 24 Lulanne, can you go out and find Mr. Polk 25 have health issues 1 have to deal with. 1 25 and offer to bring him up something from our 335 337 1 Sayers 1 Sayers 2 haven't eaten all day. I'm going to leave 2 cafeteria if he would like something to eat? 3 the room. 3 I'm happy to actually have my secretary 4 If we're going to resume in the 4 bring him up something. Let's see what he 5 morning, that's fine. You can call my hotel 5 would like. Thank you. 6 and let me know what time we're resuming. 6 Q. Mr. Sayers, in that Exhibit 13 -- 7 Otherwise reserve my right to restrain all 7 A. Yes. 8 uses of this deposition in any proceedings 8 Q. -- Mr. Brownson directed your attention 9 relating to any of my cases in any 9 to the reference to an experiment with respect to 10 jurisdiction in the country, most 10 3,4-benzopyrene in asbestos. Do you see that? 11 particularly Minnesota. II A. Yes, 1 do. 12 MR. WILL: I ask you wait for five 12 Q. To your understanding as there any 13 minutes. I have two subjects to cover. 13 3,4-benzopyrene in Calidria? 14 Then we can discuss this off the video 14 A. To my knowledge, there was no material 15 record. 15 of that sort present. 16 MR. POLK: No, sir. 1 don't feel 16 0- In Calidria? 17 well. Don't you get it? 17 A. In Calidria asbestos. 18 MR. BROWNSON: Trevor, he doesn't feel 18 MR. BROWNSON: Objection, leading. 19 well. He's asking for a break, and you're 19 Q. Did you have an understanding of what 20 ignoring him. Your notice says it will be 20 type of asbestos had 3,4-benzopyrene in it? 21 completed from day to day. 21 A. I believe it was crocidolite. 1 do 22 (Mr. Polk leaves proceedings.) 22 remember the reference to that. 23 MR. BROWNSON: 1 think you are being 23 Q. You were asked a question about whether 24 unreasonable. You have a guy who has some 24 your current company, Scapa, had any connection 25 sort of illness. Can we take a moment here? 25 with Union Carbide or any of its subsidiaries. Do SPHERION DEPOSITION SERVICES (212)490-3430 85 (Pages 334 to 337)