Document 6wmMpMwGQ95Xk0EDDK96MKo0m

238 1 Sayers 2 Union Carbide headquarters in New York? 3 A. It was addressed to Mr. Frank Dexter, 4 yes. 5 Q. He's also saying that to Dr. Demehl, 6 who's at Union Carbide headquarters in New York in 7 the medical department? 8 A. Yes. 9 Q. And he's saying it to this Mr. Frangos 10 at Union Carbide headquarters in New York? It A. Yes. 12 Q. And he's saying it to Dr. F. Mumpton at 13 Niagara Falls, New York? 14 A. Correct. 15 Q. That's a Union Carbide research 16 facility, was it not? 17 A. It was, yes. 18 Q. And he's saying it to a Mr. Polderman at 19 office. Is that the office in -20 A. That was the Belgium office. 21 Q. -- Belgium? 22 A. Polderman ran the Belgium office. 23 Q. Then he is saying it to Mr. Pufahl, to 24 you and to Mr. Woolery, who is also at Niagara 25 Falls. 240 1 Sayers 2 Q. Well, he had seen it and he had read it 3 and he understood it, didn't he? 4 MR. WILL: Same objection. 5 A. I presume so, yes. 6 Q. You had at least shown it to him? 7 A. He had a copy. 8 Q. And you felt he had at least looked at 9 it and read it? 10 A. 1 can't recall when he had read it. II Q. But you would expect he would have read 12 it? 13 A. Indeed, right. Our paths crossed but 14 little at that particular point in time. We were 15 both moving. 16 (Sayers Exhibit 18, letter dated 9/13/67 17 from Hall to Dexter, Bates stamped A16698 18 through 99, marked for identification, as of 19 this date.) 20 Q. Let me show you Exhibit 18, a letter of 21 September 13, 1967, again to Mr. Frank Dexter on 22 the 45th floor of Union Carbide Corporation, 270 23 Park Avenue, New York, New York, from again your 24 boss, Dr. Thomas Hall at Union Carbide, Belgium. 25 1 will ask you first, do you recognize 239 1 . Sayers 2 A. That's right. 3 Q. Can we conclude from this that the 4 information, then, contained in your report titled 5 "Asbestos as a Health Hazard in the United Kingdom" 6 was getting conveyed across the Atlantic Ocean to 7 the headquarters of Union Carbide by at least 8 August 1st. 1967? 9 MR. WILL: Objection to the form. 10 assumes facts not in evidence. 11 A. 1 don't think we can say it on the 12 basis of this letter, no. But 1 know that my boss. 13 Peter Cheston. had already sent the documents out 14 in May. 15 Q. He had sent the documents over to New 16 York, and now on August I4lh you've got Mr. Hall 17 coming over to New York from Belgium to talk about 18 asbestos matters? 19 A. That's what it says. 20 Q. At the time he was going over, he had in 21 mind the information in your report called 22 "Asbestos as a Health Hazard in the United 23 Kingdom"? 24 MR. WILL: Objection. 25 A. 1 have no idea. 241 1 Sayers 2 that letter? 3 A. Yes, 1 do. 4 Q. Take a look at the letter after Mr. Will 5 has a chance to review it here. 6 A. Page I 1 have seen. Page 2 I'm not so 7 sure 1 have. 8 Q. I'm going to ask you about that, but 9 let's start with page 1. 10 MR. WILL: You don't have another copy? II Q. If you look at page 1, Dr. Hall is 12 telling Mr. Dexter over in New York that he is 13 enclosing with the letter a copy of the report made 14 by Ian Sayers -- that's you; right? 15 A. Yes. 16 Q. -- our asbestos representative in the 17 U.K. concerning a recent meeting he attended of the 18 Asbestos Fibers Importers Committee. 19 A. Yes. 20 Q. The details of the meeting are given in 21 the report. 22 Then somebody has written - when he 23 says "a copy of the report," they have written the 24 word "over." If you go over, there are some 25 handwritten notes. Do you see that? SPHERION DEPOSITION SERVICES (212)490-3430 61 (Pages 238 to 241)