Document 50gmNXgkQJM0J03Vrjr8Xoy70

222 1 Sayers 2 Exhibit Number 5? 3 A. I wouldn't say it was the first thing. 4 1 carried these documents around with the Demehl 5 report, which 1 used predominantly. 6 Q. Well, it's the first thing mentioned in 7 your report, but it's one of three things that you 8 say -9 A. There was no specific order. 10 Q. Can 1 see that? 11 A. Certainly (handing). 12 Q. If 1 can summarize this, up until the 13 time of your report on May 12th, 1967, you were 14 attempting to reassure your papermaking customers 15 in England about asbestos health hazards by showing 16 them information from three things: Dr. Demehl's 17 toxicology report; this letter, which is entitled 18 "Asbestos Toxicology" -- 19 A. Yes. 20 Q. -- and also a letter ofOctober 7th, 21 1966. 22 A. Which is also a table this morning; no? 23 Q. That's what you talked about? 24 A. It was in similar vein to that. 25 Q. And you felt that further information 224 1 Sayers 2 A. During that time period, no. 3 Q. Right. When you say "no," I guess I'm 4 not sure my question was clear. That's basically 5 what they got? 6 A. They got nothing more. 7 Q. Yes. 8 Now, you were shown today a report by 9 the Union Carbide -- a study Union Carbide 10 commissioned from the Mellon Institute in II Pittsburgh, and we talked about that. That was of 12 July 8, 1966; correct? 13 A. Yes. 14 MR. WILL: Excuse me, Mr. Brownson. Can 15 we go off the record? There's a disturbance 16 at the end of the conference room. 17 THE V1DEOGRAPHER: 2:44 p.m. We're 18 going off the record. 19 (Pause.) 20 THE VIDEOGRAPHER: The time is 2:46 21 p.m. We're back on the record. 22 Q. 1 was asking you about the report of 23 the Mellon Institute of July 8th, 1966. As 1 24 understand it, until you were shown it today, you 25 had not seen it? 223 1 Sayers 2 was needed to convey to these customers that these 3 three things weren't giving them the kind of 4 assurance that they were looking for from you? 5 A. Yes, it was as desirable. 6 Q. Just so I'm clear here, the further -- 7 was any further information ever given to customers 8 while you were calling on these papermaking mills? 9 A. No. We relied first and foremost on the 10 Demehl toxicology report. 11 Q. So what you were handing, then, to 12 customers in the papermaking business in England 13 was the asbestos toxicology report by Dr. Dernehl? 14 A. That is so. 15 Q. Even though, as you say in the 16 introduction to your report, that didn't seem to be 17 giving them all the assurances they wanted; 18 correct? 19 A. Right. 20 Q. And you were hoping to be able to give 21 them further and more information? 22 A. Yes. 23 Q. Again, as far as you know, they never 24 got further written assurances or information? 25 That's basically what they got? 225 1 Sayers 2 A. That is so. 3 Q. So clearly this was not something you 4 were giving to your customers in the papermaking 5 business over in England back in the 1960s? 6 A. Definitely not, no. 7 (Sayers Exhibit 13, letter dated 2/4/66 8 to Cheston, Bates stamped U005926, marked 9 for identification, as of this date.) 10 Q. Let me show you what we've marked as II Exhibit Number 13, which for the record is a letter 12 addressed to Mr. Peter Cheston of Union Carbide 13 Limited, 8 Grafton Street, London, England, of 14 February 4th, what looks like 1966. 15 Does that look right? Can you tell? 16 A. It looks like it, yes. 17 Q. Have you ever seen this before? 18 A. I'm pretty sure 1 would have done, yes, 19 working so close to Peter. 20 Q. And when you say "so close to Peter," 21 you said his office was five feet away? 22 A. Five yards. 23 Q. It was a small operation you had in that 24 office; right? 25 A. Yes. SPHERION DEPOSITION SERVICES (212)490-3430 57 (Pages 222 to 225)