Document 8zY7RR8wQOYVbjdyRQVBEqXy

BRADLEY & MERRELJJOMES, JONES, GLOBE & BROW N, CH ARTERED Savonth Floor -- Bank of Am arloa P iara 300 South Fourth S tra w i ab Vagaa, Navada 89101*6026 <702) 386*4202 MESSAGE FROM XERO X 7024: fTQ2) 335-1655 DATE: Ja_ly J6. KV4 ____________ TO: -r>v. " Cl l . ft P: PHONE # : FROM: C U E N T /M A T T E B : Neva.da Power v. Monaanto C U E N T /M A T T E R NO .: T1027.2 D O C U M E N T(S ) D ESC R IPTIO N : E-Xp e r t D is c e s i V-S NUM BER OF PAGES (Including co var p a g a ): UV &. TT AK. l IMESSAGE: I i ' i ' y 6 U ~ A f G -in Ol. vJ *9 / IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (702) 385-4202 arid ask tor: Robert Osterloh. Ext 81B TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) ** COUNT TOTAL PAGES SCANNED : 5 TOTAL PAGES CONFIRMED : 5 * * * SEND * * * !No. REMOTE STATIO N START T l ME DI RAT 1ON #PAGES MODE 1 Z31 6 1 5 8 4 3 2 3 1 0 7 - 3 0 - 9 3 9 : 49AM 2 21" 5 / 5 ___ NOTE : No. : OPERATION NLMBER PD : POLLED BY REMOTE MB : SEND TO MAILBOX TOTAL 0 :0 2 21" 5 40 SF : : S4-T8O0R0BEPS& SELECTED FORWARD EC Rl PG : P O LLING A REMOTE MP ERROR CORRECT RELAY 1N 1T 1ATE MULT 1-P O LLIN G RESULTS COMPLETED 9600 G2 : G2 COMMUNICATION RS : RELAY STATION RM : RECEIVE TO MEMORY BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of America Pia7a 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 MESSAGE FROM XEROX 7024: (7021 385-1655 DATE: mi TO: Gilts FAX#: 3 - 2 3 1 PH O N E #: ( U s H - M 0** FROM: CUENT/MATTER: Nevada Power v. Monsanto CUENT/MATTER NO.: 11927.2 DOCUMENT(S) DESCRIPTION: EXjperl' isclosure NUMBER OF PAGES (including cover page): MESSAGE: W ifL y - T T Xtv T CkouAJ^S uja 5" THIS THJ3COPY IS INTENDED ONLY FOR THE ADDRESSEE NAMED ABOVE iT MAY CONTAIN INFORMATION THAT IS PFBVILEGED AND CONFIDENTIAL F YOU HAVE RECEIVED THE TELECOPY IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE. DESTROY ALL COPIES, AND DO NOT DISSEMINATE THE INFORMATION TO ANYONE. THANK YOU FOR YOUR ASSISTANCE. IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (702) 385-4202 and ask for: Robert Osterloh, Ext. 615 p Nevada Power Company v. Monsanto C o . , et a l . Case No. CV-S-89-555-LDG-LRL PRETRIAL WITNESS STATEMENT Dr. Arnold Schecter 88 Aldridge Avenue Binhamton, New York 13903 SUMMARY OF TESTIMONY Dr. Schecter is a senior medical and scientific authority on many aspects of, including but not limited to public health and medical aspects of PCB residues including closely related PCDD and PCDF residues in human tissues in industrialized as well as less industrialized nations. Dr. Schecter has devoted over 10 years' time to the study of PCBs, PCDDs and PCDFs with patients. Dr. Schecter has been an advisor/consultant to the World Health Organization (WHO), U.S. Environmental Protection Agency (EPA), and the Agency for Toxic Diseases and Subtance Registry for the Centers for Disease Control (CDC). In addition, Dr. Schecter conducts ongoing research in the United States, Russia, China, Vietnam, an Japan on PCBs, PCDDs and PCDFs. As a county Health Commissioner, Dr. Schecter was the first to point out the dangers of PCBs, PCDDs and PCDFs in PCB transformer fires. Dr. Schecter received a B.A. in Liberal Arts and a B.S. in Physiology and Neurophysiology from the University of Chicago, his M.D. from Howard University Medical School, and his M.P.H. from Columbia University School of Public Health. Dr. Schecter's post graduate training has included a mini-residency in Occupational Medicine at the University of Cincinnati College of Medicine and in Occupational Medicine at the University of Illinois Medical School in Chicago, Illinois and at Mt. Sinai Medical Center in New York and at New York University Medical Center and various courses at Occupational Medical national meetings. Currently, and for the past three years, Dr. Schecter is a professor at the Department of Preventive Medicine, SUNY Health Science Center in Syracuse, New York and in the Clinical Campus at Binghamton, New York. Previously he trained and served on the faculties of Harvard Medical School, SUNY Downstate Medical School and the New Jersey Medical School. He is also a staff member at Our Lady of Lourdes Hospital in Binghamton, New York and the United Health Services Hospitals in Binghamton and Johnson City, New York. As an extensively published author on PCBs, PCDDs and PCDFs, Dr. Schecter's expertise is relied upon by many persons researching the issues surrounding these chemicals. Some of Dr. Schecter1s membership affiliations are: the Association of Teachers of Preventive Medicine; the American College of Epidemiology; he is a Fellow in the American College of Occupational and Environmental Medicine; a Fellow in the American Collge of Preventive Medicine; a Fellow in the American College of Physicians; a member of the Amercian Association for the Advancement of Science; and a member of the Society for Epidemiologic Research and belongs to other other scientific and professional organizations. In this litigation, Dr. Schecter is presented as an expert on the toxicology of PCBs, dioxins and dibenzofurans (PCB related compounds). In the last eleven years, Dr. Schecter's research has focused on PCB, PCDD and PCDF residues found in patients' bodies and movement of the PCBs, PCDDs and PCDFs through the human body; points of collection within the human body for PCBs, PCDDs and PCDFs; the biological half-lives of PCBs, PCDDs and PCDFs; and the movement of PCBs, PCDDs and PCDFs through the placenta and to the fetus. Dr. Schecter's research has also focused on the background exposures of human populations to PCBs, PCDDs and PCDFs as well as the bioaccumulation of PCBs, PCDDs and PCDFs in the general human population. Dr. Schecter will testify to the impact of additional PCBs, PCDDs and PCDFs when added to the background levels already present in the human population. Dr. Schecter is of the opinion that PCBs, PCDDs and PCDFs are inherently dangerous to laboratory animals, wildlife and humans. He is also of the opinion that levels of PCBs, PCDDs and PCDFs must be reduced to lower the existing background human body burdens. Dr. Schecter will also testify that the PCB equipment at Nevada Power which is above and below the existing EPA standards is defectively hazardous becasue of toxicity, persistence and bioaccumulation. The basis for Dr. Schecter's testimony will be his education, research experience, training and understanding of the current literature on PCBs, PCDDs and PCDFs. Dr. Schecter will also review publications from his published research as well as other research and reports generated by research on PCBs, PCDDs and PCDFs. Among the more general sources of Dr. Schecter1s information will be general scientific literature on PCBs, PCDDs and PCDFs along with recent NIOSH, E P A f CDC, Air Force and o'-her government agency research. D r . Schecter may review materials covered at scientific meetings and information covered with or discussed with other experts. Another category of information upon which D r . Schecter may rely includes pertinent research provided by state agencies and symposia and other publications dealing with halogenated aromatic hydrocarbon toxicity. At the request of Nevada Power attorneys, Dr. Schecter may I Ialso review learned treatises of other experts or any other i documents related to the case which Nevada Power attorneys provide for his review. Finally, Dr. Schecter may also be called upon to explain and define any scientific terms used by the defendants in documents gathered by Nevada Power during discovery and presented to him. j:\ncv\ijs\xprt\schcctcr.dis