Document E8OnGLJBqMp0xyOmG94ZNLe0

318 1 Sayers 2 this document with this witness, just 3 like -4 MR. WILL: I'll make copies. 5 MR. POLK: Yeah, but, Trevor, you're 6 using the document with the witness prior to 7 offering it and allowing us to object to it 8 and allowing us to review it. 1 object to 9 the document, period. 10 MR. WILL: No different than what was II done earlier. 12 Q. My question is this: Having just read 13 that statement by Mr. Myers that warnings were put 14 on in 1968 -- 15 MR. BROWNSON: Objection, pleading. 16 Q. -- do you have any reason to dispute 17 what it says there? 18 MR. POLK: Objection, leading, hearsay. 19 lacks foundation. 20 A. No, 1 have no reason to dispute it. 21 MR. POLK: Excuse me, sir, don't answer 22 until 1 am completed with my objection. 23 THE WITNESS: I'm sorry. 24 MR. POLK: Okay? Thank you. 25 MR. WILL: Are you finished? 320 1 Sayers 2 show it to me. 3 MR. WILL: Let's go off the video 4 record. 5 THE VIDEOGRAPHER: The time is 5:13 6 p.m. We're going off the record. 7 (Pause.) 8 THE VIDEOGRAPHER: The time is 5:16 9 p.m. We're back on the record. 10 Q. Mr. Sayers, I'm going to ask you to II assume that Mr. John Myers has testified that Union 12 Carbide put a warning label on its Calidria 13 asbestos in 1968. 14 A. Yes. 15 Q. Assuming he says that, do you have any 16 reason to doubt what Mr. Myers would say? 17 A. No. 18 MR. BROWNSON: Objection, leading. 19 Q. Do you have any information that would 20 tell you that Mr. Myers was wrong? 21 A. None whatsoever. 22 Q. Do you hold yourself out as an authority 23 as to when Union Carbide put warning labels on its 24 Calidria asbestos? 25 A. No, 1 certainly don't. 319 321 1 Sayers 1 Sayers 2 MR. POLK: Yes, 1 am. And I'm going 2 Q. You were asked a question by Mr. Polk 3 to ask for the record again, just like 3 about warnings. In your experience in England in 4 Mr. Lanier did, please don't show the 4 1966 and 1967, was it common for companies to put 5 witness documents until you have had us look 5 warnings on bags of material? 6 at them. 6 MR. POLK: I'll object. It lacks 7 MR. WILL: Mr. Polk, all through 7 foundation. 8 Mr. Brownson's examination we did exactly 8 A. In my -- 9 the same thing, which was to give the 9 MR. BROWNSON: Same objection. 10 witness a document. I'm happy to give you a 10 Q. Go ahead. II copy of this. II A. In my limited experience, the answer to 12 MR. BROWNSON: 1 gave the witness only 12 that is no. 13 documents that have been produced to me by 13 Q. Mr. Polk asked you a number of questions 14 Union Carbide. 14 about whether you would have liked to have known 15 MR. WILL: You can have it. 15 things about the Conwed plant. Do you remember 16 MR. POLK: I'd like to have a copy of 16 that sort of line of questions? 17 the document so I can review it and decide 17 A. 1 do, yes. 18 whether or not 1 want to recross this 18 Q. In responding to those questions, did he 19 witness based on a document you just used on 19 mention to you that there were approximately 3,000 20 direct with him. That's a fair request, and 20 tons of amosite asbestos used in the Conwed plant? 21 I'm asking for it now. 21 MR. POLK: Object to the form, 22 MR. WILL: I'll ask somebody to make a 22 argumentative. 23 photocopy of the document so we all have it. 23 MR. BROWNSON: I object as leading and 24 MR. BICKS: It's a one-page document. 24 argumentative. 25 MR. POLK: That's fine, if you just 25 A. No, I didn't. SPHERION DEPOSITION SERVICES (212)490-3430 81 (Pages 318 to 321)