Document 4vDnOeQVn2kaMQNqyNEny2GYQ

350 1 Sayers 2 from this to be examined by Dr. Demehl and perhaps 3 issued for salespeople. 4 Q. And who did you expect to select the key 5 points? 6 A. Oh, the experts in New York. 7 (Sayers Exhibit 24, memorandum dated 8 4/3/69 from Lane, Bates stamped A03137 9 through 41, marked for identification, as of 10 this date.) II Q. Let me show you what we've marked as 12 Exhibit 24. For the record, it's a memorandum 13 dated April 3rd, 1969, from K..S. Lane to a number 14 of people; correct? 15 A. Yes, that is correct. 16 Q. Do you recall ever seeing this document 17 before? 18 A. No, because 1 left the company before 19 that date. 20 Q. You left the asbestos aspect of it?' 21 A. Yes. 22 MR. BROWNSON: 1 think he said he had 23 left the company. 24 Q. Had you left Union Carbide Belgium on 25 that date? 352 1 Sayers 2 as of this date.) 3 Q. 1 want to show you what we've marked as 4 Exhibit 25. Is that a document dated January 19th, 5 1968, from Paul McDaniel to John Riddle? 6 A. Yes. 7 Q. Do you recall seeing this document 8 before? 9 A. No, I don't. 10 Q. 1 want to direct your attention to the II second paragraph. Do you see the statement there 12 that says, "The limit of 5 million particles per 13 cubic foot" -- 14 A. Yes. 15 Q. -- "that we observe in our operations is 16 still recognized in the United States as 17 satisfactory for chrysotile, but there is strong 18 feeling that it is much too high for crocidolite"? 19 A. Yes. 20 MR. BROWNSON: Objection. It's leading 21 and also the document speaks for itself and 22 it's without foundation. 23 Q. Looking at Exhibit 6, Mr. Sayers, do 24 you see any statement in Exhibit 6 that says 5 25 million particles per cubic foot is still 351 1 Sayers 2 A. No, 1 had not. 1 had left -- the 3 asbestos product had been handed over to the U.S. 4 at that time. 5 Q. Do you see the sentence in the second 6 paragraph that says, "We briefly discuss" -- let me 7 back up a second. This document is referring to a 8 revision to the 1964 asbestos toxicology report. 9 A. Yes. 10 MR. BROWNSON: Objection, leading. 11 Q. Do you see in the second paragraph it 12 says, "We briefly discuss mesotheliomas, but data 13 is too scanty as yet for a definite policy to be 14 established"? 15 A. Yes. 16 Q. Do you see that statement appearing 17 there in the Exhibit 6, the 1969 toxicology report: 18 "The data is too scanty for a definite policy to be 19 established"? 20 MR. BROWNSON: Objection. The document 21 speaks for itself. 22 A. No, 1 don't. 23 (Sayers Exhibit 25, document dated 24 1/19/68 from McDaniel to Riddle, Bates 25 stamped A07074, marked for identification, 353 1 Sayers 2 satisfactory for chrysotile? 3 MR. BROWNSON: Objection. The document 4 speaks for itself. It's also leading. 5 A. No, 1 do not. 6 Q. Do you see at the top of Exhibit 25 in 7 the first paragraph where it says, "The relation 8 between chrysotile and mesothelioma is not clear. 9 If it exists, it apparently is much less pronounced 10 than that from crocidolite." Do those words II appear? 12 MR. BROWNSON: Objection, it's leading. 13 the document speaks for itself, it's without 14 foundation. 15 A. Yes. 1 read that. 16 Q. Do you see any statement in Exhibit 6, 17 the 1969 toxicology report, that says the 18 relationship between chrysotile and mesothelioma is 19 not clear? 20 MR. BROWNSON: Same objections as 1 said 21 before. 22 A. No. 1 do not. 23 Q. Take a look, if you would, please, in 24 your report at page 15. paragraph 6.1.2. 25 A. Yes. SPHERION DEPOSITION SERVICES (212)490-3430 89 (Pages 350 to 353)