Document 7ONN4GEaV2vDEkydBV9GwY8k8

1 exposures to asbestos in a systematic fashion? Page 293 2 A I think the inferences from the various studies 3 I summarize in my paper should not be much different 4 from Joe Mallia. 5 Q Those inferences relate to groups of 6 individuals who all will have different work practices? 7 A That's right. 8 Q And there has been no study of individuals 9 with work practices specifically like Joe who filed, 10 blew out, cleaned up in the way he did and worked with 11 cars and trucks? 12 A Oh, you'd be I think incorrect about that. As 13 I said, before, I have no problem using that historical 14 database to predict the risk to Mr. Mallia because 15 those studies were conducted in earlier years when the 16 exposures were higher, when grinding or occurred and 17 blow-out was prevalent. And there was no warnings. I 18 mean you got warnings in his era as well. 19 So the fact that he's got warnings and you're 20 comparing him against a cohort that was more exposed is 21 why I can believe that there is no relationship between 22 his disease and his work as a brake mechanic. 23 Q Which of the studies in your 2003 paper 24 occurred during times when there was substantial 25 grinding in your opinion? ESQUIRE DEPOSITION SERVICES (415) 288-4280