Document Edq9nE7Zb1X4290VRX92M1p7x

Page 1 Page 3 1 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 2 STATE OF MISSOURI 3 4 GLENN BROWN, et al, 5 Plaintiffs, 6 vs. Cause No. 862-00694 1 IT IS HEREBY STIPULATED AND AGREED by and 2 between Counsel for the Plaintiff and Counsel for the 3 Defendant, that this deposition continuation may be taken 4 in shorthand by TOD MINNIGERODE, a Certified Shorthand 5 Reporter and Notary Public, and afterwards transcribed 7 MONSANTO COMPANY, 6 into typewriting, and that the deposition is to be 8 Defendant. 7 continued. 98 10 11 12 Volume III 9 10 13 Continued Deposition of R. EMMET KELLY, M.D. 11 o-O-o 14 On behalf of Defendant 12 15 June 12, 1990 13 R. EMMET KELLY, M.D., 16 17 18 19 20 WALLER REPORTING, INC. 14 of lawful age, being produced, sworn and examined on the 15 part of the Defendant, deposes and says: 16 EXAMINATION 17 QUESTIONS BY. MR. MC CREA: 21 515 Olive Street, Suite 1506 18 Q Dr. Kelly, how are you this morning, sir? 22 St. Louis, Missouri 63101 19 A Fine and yourself? 23 (314)621-2571 24 25 26 27 28 20 Q Pretty good. When we last convened we were 21 discussing Exhibit K-2, I believe, and if you would, sir, 22 turn to page 1023 as indicated by the article page number 23 at the top. The first full paragraph down about 24 two-thirds of the way, it states, "In approximately one 29 25 half of the workers exposed there developed comedones of a Page 2 Page 4 1 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 2 STATE OF MISSOURI 3 4 GLENN BROWN, et al, 1 particularly heavy and tenacious type with resultant 2 sebaceous, abscesses containing heavy yellow pus and 3 serum." Can you again for us describe a comedone in 5 Plaintiffs, 4 layman terminology? 6 vs. Cause No. 862-00694 7 MONSANTO COMPANY, 8 Defendant. 9 5 A It's something between a blackhead and a 6 boil. A boil is an infected comedone. A comedone is a 7 plugged up sebaceous gland. 10 8 Q And when it says of a particularly heavy and 11 CONTINUED DEPOSITION OF R. EMMET KELLY, M.tj). ,9 tenacious type, could you break that definition down for 12 produced, sworn and examined on behalf of the Defendant, 13 June 12, 1990, between the hours of eight o'clock in the 14 forenoon and five o'clock in the afternoon of that day, at 10 us? 11 A I don't know what he means by heavy. 15 the offices of Communitronics, 1907 S. Kingshighway, St. 12 Tenacious means like if I use a common definition means it 16 Louis, Missouri, before TOD MINNIGERODE, a Certified 13 took a little while to get well. You realize here he's 17 Shorthand Reporter and a Notary Public within and for the 18 State of Missouri. 19 20 14 talking about chloracne in Europe, not PCB's at all. This 15 is chlorinated naphthalene he's talking about in this. 16 Q All right, sir, and that's identified in that 21 APPEARANCES 17 paragraph as chlorinated naphthalene? 22 The Plaintiff was represented by Mr. Thomas M. 23 Carney of the law firm of Husch, Eppenberger, Donahue, 24 Cornfeld & Jenkins, 100 N. Broadway, St. Louis, MO 63101. 25 The Defendant was represented by Mr. David 18 A Yes. He refers to it at hexachlorobenzene -- 19 Well, it's all chlorinated naphthalene. In 1918, these 20 cases were long before PCB's were invented. 26 McCrea of the law firm of McCrea & McCrea, 119 South 21 Q Is that the same general family of chemicals, 27 Walnut Street, Bloomington, Indiana 47402. 28 29 30 22 chlorinated hydrocarbon family? 23 A Well, it depends on how widespread you 24 include the family. I mean, Italians and Irish and 31 25 Indians are all in the same family, but chlorinated Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 1 - 4 LEXOLDMON006807 Page 5 Page 7 1 naphthalene is a different thing entirely than chlorinated 1 MR. McCREA: Yes, 1 presume that we're still 2 diphenyl. 2 talking - 3 Q What are the chemical elements in chlorinated 3 Q (By Mr. McCrea) That still relates to 4 naphthalene? 4 chlorinated naphthalenes, does it not, Doctor? 5 A Chlorine, hydrocarbon -- chlorine, hydrogen, 5 A Yes. 6 carbon. 6 MR. CARNEY: I'm going to object to the 7 Q And those would be the same chemical elements 7 relevancy of that as opposed to the case we're involved 8 in a PCB, correct? 8 in, which is PCB's, and PCB's in any case are not the same 9 A Oh, yes, but it depends how they're -- 9 as chlorinated naphthalene. 10 Q Arranged? 10 Q (By Mr. McCrea) Dr. Kelly was there-Were 11 A Arranged. Coal is carbon, diamonds are 11 there varying opinions as to the manner in which 12 carbon, but they're a little different. 12 chlorinated naphthalenes caused the eruption on the skin? 13 Q Could chlorinated naphthalene be accurately 13 Did some authors believe it was an irritation, did some 14 described as chlorinated hydrocarbon? 14 believe it was the elimination of the chemical through the 15 A In one sense, yes. Usually people do not 15 sweat glands and did others believe it involved liver 16 refer to a ring compound, which the naphthalene is, as a 16 enzymes? 17 hydrocarbon. It's usual, the usual termination - 17 A 1 don't know where the enzymes are, but that 18 terminology for hydrogen is a straight chain carbon with 18 was a later belief. The first two beliefs 1 believe about 19 chlorine on it. But you could use that as a definition, 19 such as Teleky in 1918 was discarded sometime around the 20 yes. 20 1960's or seventies. But to answer your questions; yes, 21 Q In manufacturing chlorinated naphthalene do 21 with the exception that it was believed that there was 22 you begin the process with benzene as you do with PCB's? 22 some change in the fat metabolism and the enzyme activity 23 A 1 don't know how they make it. 23 of the body, yes. 24 Q It also states in that sentence, "With 24 Q And Teleky, his belief was what, that was 25 resultant sebaceous abscesses." Can you define that for 25 later changed in the sixties or seventies? Page 6 Page 8 1 us? 1 A Well, 1 don't know exactly what Teleky 2 A An abscess is a boil. Sebaceous means a 2 thought back there in 1918; but at that time the people 3 sweat gland. 3 believed that this material got on your skin, plugged up 4 Q And then it said -- 4 the sweat glands and caused it that way. 5 A An oily gland of the skin. It's an oil gland 5 Q And could -- 6 of the skin. 6 A 1 think that was pretty rudimentary 7 Q Containing heavy yellow pus and serum? 7 approach to it. 8 A Once it's infected, that's what the pus is. 8 Q And could that be described as more of an 9 Q Then it states in the next sentence that - 9 irritant effect rather than a systemic effect? 10 and I'm having a little difficulty reading, it looks like 10 A Well, irritant has a particular definition. 11 Teleky, T-e-l-e-k-y? 11 If you put paint remover into your skin you get red, 12 A Yes, sir. 12 that's an irritation. Here we are not talking 13 Q "Believes that the disease was due directly 13 particularly about irritation, we're talking about 14 to the halogen content of the substance," and by that is 14 chloracne. 15 he referring to the chlorine content? 15 Q Then below that on page 1024 is, "Report of a 16 A Yes. 16 Case," and in somewhat fine print it has, "History," of a 17 Q Turning over to page 1024-- Well, actually 17 case, and it describes the actual symptoms of a worker who 18 down to the bottom of 1023, it says, "Others," and then a 18 was employed for Swann Chemical, is that correct? 19 series of names, "Consider it to be dermatitis due to the 19 A That is correct. 20 absorption of chemical compounds by the lungs or 20 Q And does this article then go on - does it 21 gastrointestinal tract with elimination by way of the 21 just have the one case history, Doctor? 22 sebaceous glands." 22 A Well, it gives a short sketch of the sixteen 23 MR. CARNEY: I'm going to object to this line 23 cases but they just gave the detailed history of Mr. O.D., 24 of questioning. Are we still talking about a condition 24 whoever he was. 25 with exposure to chlorinated naphthalenes? 25 Q Would O.D. be the initials of an individual? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 5 - 8 LEXOLDMONOO68O8 Page 9 Page 11 1 A That's correct. 1 Q If an individual is working in PCB's and 2 Q And then on page 1025 it gives a summery of 2 experiences a condition of itching would that then 3 the symptoms and treatment in sixteen cases of acneform 3 indicate exposure of the skin to PCB's? 4 eruption, is that correct? 4 A Again it depends on what else he might be 5 A Yes, sir. 5 exposed to. Maybe he was exposed to chlorine, maybe he 6 Q Was it this author's belief that the acneform 6 was exposed to solvents. 7 eruptions were the result of exposure on the surface of 7 Q If there was no other chemical which by 8 the skin, and that it was not the result of systemic 8 history could explain the itching, would itching of the 9 poisoning? 9 worker's skin be an indication that there has been PCB 10 A I'll have to look, 1 don't think he has come 10 contamination of the skin? 11 out with anything. He does say that some of the problem 11 MR. CARNEY: Are you excluding anything 12 may have been due to skin irritation of - He doesn't make 12 outside the work place, like poisen ivy or some other 13 any positive statement of what he thinks is the cause, 13 condition that might cause itching. 14 whether it's systemic or local action. 14 MR. McCREA: Right. 15 Q All right, sir. In the report of a case 15 Q (By Mr. McCrea) If no other history of being 16 which is described on page 1024, in the first paragraph it 16 PCB's cause itching? 17 gives a description of blackheads on his face, neck, arms 17 A 1 think if you get enough of it on you it 18 and legs. Does that fairly well speak for itself? 18 may. 19 A Yes, sir. 19 Q Can itchingresult from systemic involvement? 20 Q In your opinion would that be an indication 20 A Of what? 21 ofchloracne? 21 Q PCB's. 22 A Not of and by itself. It depends really on 22 MR. CARNEY: I'm going to object to the 23 what they looked like. 23 question; it's vague and ambiguous to me. 24 Q What would indicate to you that that 24 A If the personhas developed chloracne from a 25 condition of blackheads on his face, neck, arms and legs 25 systemic involvement from PCB he may get itching. Page 10 Page 12 1 would be chloracne? 1 Q (By Mr. McCrea) Then it states, "In a short 2 A If it started around the cheekbones. If 2 time blackheads began to appear on the chest, back and 3 there were some pigmentation, it's -- Mr. O.D., being a 3 lower part of the abdomen, around the navel and on the 4 black man, 1 don't know of how well pigmentation could 4 scrotum and penis." Do you believe -- do you know of any 5 have been observed. 5 other conditions which can cause blackheads in those 6 Q Is it your opinion that if the condition does 6 particular areas of the body other than exposure to PCB's 7 not present itself initially on the cheekbones that you do 7 or related chlorinated hydrocarbons? For instance, can a 8 not have chloracne? 8 teenager experience conditions in those areas? 9 A No. No, 1 don't say that; but the majority 9 A 1 have never seen teenage acne on the scrotum 10 of them do start around the cheeks, around the eyes and 10 and penis. There are any number of chemicals ranging from 11 around the ears. 11 wood treating chemicals to agricultural chemicals that can 12 Q The next phrase states, "These areas itched 12 cause widespread chloracne which is -- could be in those 13 slightly." In your opinion could slight itching of the 13 areas. 14 skip of a worker exposed to PCB's be an indication of 14 Q And which wood treating chemicals and 15 chloracne? 15 which -- what was the other chemical? 16 A 1 don't think so. It all depends on what 16 A Pentachlorophenol. 17 else he might be exposed to, how long the PCB's were on 17 Q All right, is that -- 18 his skin. Itching in a chemical plant could come from a 18 A 2,4,5-T. 19 great number of things. 19 Q And those chemicals can also produce 20 Q Is itching a condition caused by an irritant 20 blackheads on the scrotum and penis? 21 effect on the skin or a systemic involvement of the 21 A Yes. 22 chemical? 22 Q What other skin conditions can appear on the 23 Aina worker it's due to the action on the 23 scrotum and penis as a result of exposure to PCB's, 24 skin. In some cases there are allergic reactions that are 24 related chlorinated hydrocarbons, pentachlorophenol, 25 systemic that are accompanied by itching. 25 2,4,5-T? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 9-12 LEXOLDMON006809 Page 13 Page 15 1 A 1 don't know of any. 1 A Certainly more rare to find it there than on 2 Q Could boils appear in those areas? 2 the face and arms and back. 3 A Well, it all depends. 1 mean, what you mean 3 Q The next sentence or at the bottom of that 4 by a boil, if you have chloracne there and these areas get 4 paragraph said, "When seen in December 1933 the patient 5 infected obviously you've had an abscess. A boil is 5 complained of lassitude, loss of appetite and loss of 6 usually referred to as an abscess in a hair follicle, but 6 libido and said that his cutaneous condition seemed to be 7 these are not in the hair follicles but you get pustules 7 improving." What is lassitude? 8 and infected comedones is an abscess. It's pretty close 8 A Tiredness. 9 to a boil. It's not exactly a boil in the terminology but 9 Q And can that be -- that condition would have 10 it's close. 10 to involve systemic, that would be a systemic involvement, 11 Q If you examined a worker and he had 11 would it not? 12 blackheads on his scrotum and penis would you suspect 12 A Could be systemic, could be psychological. 13 chloracne? 13 Q And what is loss of appetite? Speaks for 14 A No, not necessarily. 1 guess, I'd have to 14 itself? 15 say where else it was, if that's all the place -- the only 15 A 1 think so. 16 place it was 1 would not suspect chloracne. 16 Q And loss of libido, what is that? 17 Q If it was on other areas of his body, such as 17 A Loss of sexual drive. 18 his arms, his trunk, his face, would you suspect 18 Q And that would have to be systemic, would it 19 chloracne? 19 not? 20 A 1 would if there was any history of exposure 20 A Not necessarily. It could any number of 21 to any chlorinated compounds. 21 reasons, it could be social, it could be psychological, 22 Q If you observed abscesses on his scrotum and 22 could be due to domestic trouble. 23 penis and he had other skin problems would you suspect 23 Q If those symptoms corresponded in time to the 24 chloracne? 24 chloracne would you suspect a systemic poisoning? 25 A And a history of exposure to chlorinated 25 A No. 1 would not. Page 14 Page 16 1 compounds, yes, I'd suspect it. 1 Q Why not? 2 Q Do you know of any condition resulting from 2 A Because these symptoms are very common in 3 normal biological functions that can result in comedones 3 almost any number of occupational and non-occupational 4 or boils on the scrotum and penis? 4 conditions. Tiredness, loss of appetite, that can 5 A Sure. You get jockstrap itch, and if you get 5 occur - loss of libido, it can occur for any number of 6 jockstrap itch and you scratch it and it becomes infected 6 reasons. The largest percentage is psychological in these 7 you get boils and abscesses on the penis and scrotum. 7 cases. 8 Q Any other conditions? 8 Q If the worker had no history of complaints of 9 A There may be some but that's the most common 9 lassitude, loss of appetite and loss of libido before the 10 one. 10 onset of the chloracne would you find that to be 11 Q Have you ever seen it there as a result of 11 significant from the standpoint of cause and effect? 12 acne, teenage acne? 12 A No, 1 wouldn't; because here a man has been 13 A No. 1 haven't seen very many teenage acnes, 13 presumably off work, he's been going to several doctors. 14 either. 14 He's got a lot of changes in his before and after pattern. 15 Q Have you ever seen it reported as a result of 15 So 1 don't believe that one could just say that these 16 teenage acne? 16 symptoms, and remember these are symptoms, there's nothing 17 A Not that 1 recall. 17 objective that you can look at. These are symptoms that 18 Q Have you ever seen it reported as a result of 18 are very common and are seen in all sorts of instances. 19 acne fulminans, fulminans? 19 Q Could it be the result of systemic poisoning, 20 A That means a pretty serious acne. Fulminans 20 lassitude, loss of appetite and loss of libido? 21 means a fulminating acne and 1 don't know whether that 21 A 1 would think you would have to know more 22 refers to teenage acne or chloracne. Could be referred to 22 about the case to know that. After all, there has been 23 both, either one. 23 nothing else in here on these because the next sentence he 24 Q So is it fair to say it's rare to find 24 says, "On examination he seemed to be in good general 25 comedones and boils on the scrotum and penis? 25 health." Dr. Jones in the next sentence did not ascribe Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 13-16 LEXOLDMONOO6810 Page 17 Page 19 1 lassitude to the PCB's. 1 believe that Dr. Jones made a 1 McCrea, two that 1 know. Do you want to break it down or 2 statement that would not be said today, in the next 2 do you want me to -- 3 sentence, but he did not agree that this was due to his 3 Q (By Mr. McCrea) No. Just answer the last 4 PCB exposure. 4 one. 5 Q In the next sentence Dr. Jones states that, 5 A Well, in the first place before 1 answer the 6 "His --" meaning O.D. -- "complaint of lassitude was not 6 last one, you talked about the PCB's in Yusho. You must 7 borne out by anything more than the usual temperament of 7 realize that that has been acknowledged to be due to the 8 the Negro toward work." Dr. Kelly, isn't that flat-out a 8 presence of dibenzofurans in the PCB's. 9 racist statement? 9 Now to answer the last question, 1 would have to 10 A It certainly is, and remember this is Dr. 10 take a symptom into account with other -- with the 11 Jones, back in Georgia in 1935. So this is not my 11 physical examination and the laboratory studies and the 12 statement. 12 general -- what other findings there were, if there 13 Q Did Monsanto ever correct that statement by 13 were -- Well, that's the answer. 14 confronting Dr. Jones and pointing out to him that that 14 Q Dr. Kelly, you and your attorney acknowledge 15 statement was racist and had no basis whatsoever in fact? 15 that this was a racist statement by Dr. Jones in ascribing 16 MR. CARNEY: Let me object to this question. 16 lassitude and stating it was not borne out by anything 17 It's an obvious attempt by Mr. McCrea to try to attribute 17 more than the usual temperament of the Negro toward work; 18 a very racist statement made by a doctor that had nothing 18 and 1 know that you don't believe that and 1 know that no 19 to do with Monsanto back in the 1930's in the South and to 19 one believes that statement. Isn't it a fact then that 20 somehow try to attribute or connect that statement, which 20 lassitude was a documented symptom of this individual who 21 is abhorrent to Monsanto and to Dr. Kelly, as he's 21 was exposed to the chemicals in the workplace at Swann? 22 indicated, to Monsanto and it has no place in this lawsuit 22 A Yes, sir. He did tell Dr. Jones 1 feel 23 and to try to inject that to in this lawsuit is -- it's 23 tired. 24 very repugnant. 24 Q And that there was no explanation for that as 25 MR. McCREA: Well, lassitude is a symptom 25 Dr. Jones suggested, 1 mean, that is just totally outside Page 18 Page 20 1 which Dr. Kelly acknowledged was caused by the exposure of 1 the realm of any validity, correct? 2 the Japanese to the Yusho PCB in 1968. Lassitude is 2 A No. 1 don't know what you mean. It's 3 clearly documented in this article written in 1933. The 3 totally outside the realm of any validity; 1 don't know. 4 point is, what credence did the PCB industry give to this 4 1 can't make sense of that statement. 5 account of lassitude. 5 Q Well, he ascribed that to the fact that this 6 Q (By Mr. McCrea) Dr. Kelly, did you at any 6 man was black? 7 point in time as medical director of Monsanto believe that 7 A Well, he did say he could find no reason for 8 lassitude could be a symptom caused by exposure to 8 the lassitude. 9 chlorinated hydrocarbons from 1936 forward? 9 Q Well, isn't there-- 10 MR. CARNEY: I'm going to object to the 10 A Wait, just a minute, let me finish. He said 11 speech you made. Move to strike. 11 this complaint was not borne out by anything, now, okay. 12 A Let's have that question over please. 12 He didn't find anything else. He ascribed it to - in a 13 MR. McCREA: Could you read it back please? 13 racist manner which 1 disagree with; but 1 have to agree 14 (Reporter read back from the record as directed: 14 with this first part when he said he didn't find anything 15 MR. McCREA: "Well, lassitude is a symptom 15 to bear out the tiredness. 16 which Dr. Kelly acknowledged was caused by the exposure of 16 Q Well, isn't it a fact that the man had just 17 the Japanese to the Yusho PCB in 1968. Lassitude is 17 been exposed to PCB's, contaminated with whatever and had 18 clearly documented in this article written in 1933. The 18 a horrible skin condition and was complaining of lassitude 19 point is, what credence did the PCB industry give to this 19 and shouldn't the doctor have considered lassitude as a 20 account of lassitude? 20 consequence of the exposure? 21 Q (By Mr. McCrea) Dr. Kelly, did you at 21 A 1 would not -- 22 any point in time as medical director of Monsanto believe 22 MR. CARNEY: Let me just object; to have Mr. 23 that lassitude could be a symptom caused by exposure to 23 Kelly or Dr. Kelly speculate as to what was inside Dr. 24 chlorinated hydrocarbons from 1936 forward?") 24 Jones' mind at that time -- 25 A You have a multiple question there, Mr. 25 A Well, that's what 1 was going to say. 1 have Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 17-20 LEXOLDMONOO6811 Page 21 Page 23 1 no idea what Dr. Jones'thoughts were in 1935. 1 don't 1 exposure to the chemicals. How would you go about 2 know what he thought of, 1 cannot put myself inside his 2 determining that medically? 3 head. 3 A 1 don't think you can. 4 Q (By Mr. McCrea) But we know it's not related 4 Q Would you take a history and ask him if 5 to the reason ascribed by Dr. Jones, agreed? 5 during his twenty-six years he had ever felt tiredness 6 A Yes. 6 before? 7 Q We know that the man had exposure to PCB's 7 A 1 may have -- 1 certainly might, yes. 8 and had a skin condition that was very obvious, correct? 8 Q And in -- 9 A Yes. 9 A This doesn't say whether he had ever felt 10 Q Doesn't that givemedical credibility to the 10 tired before, either. 11 fact that the lassitude could be the result of the 11 Q Wouldn't that be something that you would 12 exposure to the chemical? 12 want to know as a doctor in trying to determine if the 13 A It's possible, butit could also as 1 said 13 chemicals caused lassitude? 14 earlier it could be due to a great number of psychological 14 A 1 am saying that, yes, but you have to 15 problems. Here a man is off work, here a man is making 15 remember that the question is: Did the chemical cause the 16 trips to the doctor, here a man is hanging around the 16 lassitude? Did the man's illness and the sociological 17 house. 1 don't know what was happening to him. 1 don't 17 changes in his environment cause the lassitude? Did being 18 know what made him tired; but you can see people who are 18 out of work cause the lassitude? 1 don't think anybody 19 ill that feel tired, and this man was in good general 19 can say this caused it, and this didn't cause it. 20 health according to what he seen, in good general health. 20 Q But if in fact the chemicals are causing 21 1 can't say any more than that. The general physical 21 lassitude then that means there is a systemic involvement 22 examination revealed nothing of importance outside of the 22 that is of significant, correct? 23 skin condition. 23 A No, not correct; because in the absence of 24 Q Describe to the jury your interpretation of 24 any physical signs, in the absence of any laboratory work, 25 the finds of lassitude in this article. 25 just the fact that a man feels tired is not a significant Page 22 Page 24 1 A Well, this article states that Mr. O.D. had 1 symptom, no, sir. 2 lassitude, which meant he felt tired. Dr. Jones says a 2 Q What about the libido, loss of libido? Have 3 general physical examination revealed nothing of 3 you seen that reported in the literature, other than this 4 importance. Dr. Jones said he seemed in good general 4 article? 5 health and his complaint of lassitude was not borne out. 5 A I've seen it reported in the literature for 6 Now if he stopped there that would be fine, he couldn't 6 probably fifty chemicals. 7 find the cause of the lassitude. Well, he proceeded on 7 Q How does chemical exposure result in loss of 8 what we know is a racist type of mindset, and that's all 1 8 libido? 9 can say about it. 9 A 1 don't think it's known and it's also -- 1 10 Q If 1 called you and asked you after you read 10 don't think it's known whether it does. 11 this article if you felt lassitude could be a consequence 11 Q Well, you stated that you have seen it 12 of this man's exposure to the chemicals, what would your 12 reported as a result of exposure to some fifty chemicals? 13 answer be? 13 A No. 1 didn't say as a result of exposure. 14 A Say that over. 1 want to get this exactly 14 Said in connection with. 15 right. 15 Q Can you describe some of those chemicals for 16 THE WITNESS: Could you read it please? 16 us, list some of them? 17 MR. McCREA: Read that back. 17 A No, 1 can't, but you can go through almost 18 (Reporter read back from the record as directed: 18 any trial and you will find that loss of libido is a very 19 Q "If 1 called you and asked you after 19 prominent symptom, no matter what the chemical is. 20 you read this article if you felt lassitude could be a 20 Q Describe to the jury your interpretation of 21 consequence of this man's exposure to the chemicals, what 21 the report of this worker that he experienced loss of 22 would your answer be?") 22 libido, based on all the knowledge which you have right up 23 A It might and it might not. 23 to this date? 24 Q (By Mr. McCrea) What would you, Dr. Kelly, 24 A Will you repeat that again? 25 do to determine if in fact the lassitude was caused by the 25 MR. McCREA: Could you read it back? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 21 - 24 LEXOLDMONOQ6812 Page 25 Page 27 1 MR. CARNEY: Yeah. Let me just for the 1 A 1 don't know what you mean, serious about 2 record object to the question on the ground that 1 think 2 what? So this man had some symptoms, yes, but his main 3 it's vague and ambiguous. 3 problem was his skin. He came in, and was treated for his 4 (Reporter read back from the record as directed: 4 skin. He was in pretty good, quite -- nothing of 5 Q "Describe to the jury your 5 importance in his physical examination outside the skin, 6 interpretation of the report of this worker that he 6 and he got well. 1 didn't pay a great deal of attention 7 experienced loss of libido, based on all the knowledge 7 to the symptoms, no. That's a whole -- you're picking one 8 which you have right up to this date?") 8 small item out of the whole makeup of the individual. 9 A Well, 1 can't describe what he -- because 1 9 Well, I'm not saying that libido isn't important, let me 10 didn't take the history, 1 don't know how much loss of 10 get that right, but -- 11 libido he had. 1 don't know how his libido was five years 11 Q 1 don't know that lassitude, loss of appetite 12 before this, and 1 don't think any -- When you say the 12 and loss of libido are any less significant than 13 knowledge 1 have up to this present date, my knowledge of 13 chloracne, Doctor. 14 libido being lost by workers who have alleged loss of 14 MR. CARNEY: Well, I'm going to object to 15 libido as a symptom, that's a pretty hard thing to prove. 15 what's more significant. 1 don't know what's more 16 Q (By Mr. McCrea) But the complaint is one 16 significant than what. 1 don't know how you compare loss 17 that's very specific, is it not? 17 of libido to loss of appetite in terms of -- 1 don't know 18 A Specific as to what, the chemical? 18 what you're trying to get him to compare them to. 19 Q As to symptom? 19 MR. McCREA: Well, he said that it's one 20 A Well, certainly, it's -- 20 small item. 21 Q And it's one that you take seriously, if 21 A Did 1 say small? 22 someone reports that to you and they report a chemical 22 Q (By Mr. McCrea) 1 thought you said one small 23 exposure, you know from your experience that loss of 23 item. 24 libido has been associated with exposure to some fifty 24 A Well, then 1 went to correct it. 1 do not 25 chemicals? 25 want to minimize loss of libido. Page 26 Page 28 1 A In conjunction with exposure, yes. 1 do not 1 Q Right. Did you service the workers at 2 know that it has -- 1 certainly did not say that that loss 2 Monsanto Company for loss of lassitude who were exposed tc 3 of libido has been caused by exposure to these fifty 3 PCB's? 4 chemicals. 1 said that loss of libido is a symptom that 4 A No. The physicians did, examining 5 is prominent in histories of people alleging injury from 5 physicians. 6 chemicals. 6 MR. CARNEY: I'm going to-- 7 Q This article dismissed outright those 7 Q (By Mr. McCrea) And did you instruct them to 8 symptoms of lassitude, loss of appetite and loss of 8 look for this condition? 9 libido, did it not, it gave them no credence? 9 A For what condition? 10 A 1 don't know what your interpretation is 10 Q Lassitude? 11 there. It gave them no credence what? He put it down, he 11 A No, sir, because a physician knows when he's 12 said, "This man told me that he has loss of libido." 12 examining a man, he asked him, "How have you been feeling? 13 Q Does he ever discuss it? 13 Are you tired?" He goes through a whole gamut of 14 A No, he doesn't discuss it, no. 14 questions. 15 Q But that was essentially documented in 1933 15 Q With this report in 1933 why didn't you 16 in this article which you have relied on in your direct 16 direct your physicians to look for those symptoms in the 17 examination as 1 recall and there's no other explanation 17 workers? 18 other than the chemical exposure or his being fatigued as 18 MR. CARNEY: Well, I'm going to object. 1 19 a result of being out of work? 19 think he's already answered that they knew how to take a 20 MR. CARNEY: I'm going to object to the form 20 history which would include those questions. 21 of the question. It's compound, it's vague and ambiguous. 21 A These physicians are people who have examined 22 Q (By Mr. McCrea) Let me ask this, 1 agree 22 workers all their life. They are experts at it. They 23 with that. Did you take those symptoms seriously when you 23 don't need to be told to look for one or two isolated 24 read this article, loss of libido, loss of appetite and 24 symptoms. You are picking one or two symptoms out of a 25 lassitude? 25 whole category of questions that people ask during the Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 25 - 28 LEXOLDMONOQ6813 Page 29 Page 31 1 course of a history and physical examination. 1 poison ivy get a symptom of itching, some people don't. 2 Q (By Mr. McCrea) Lassitude is one of those 2 Q And that's just because we don't all react in 3 symptoms which you stated earlier in your deposition was 3 the same way, fair statement? 4 related to the Japanese exposure to the Yusho oil, 4 A Yes. But that's over-simplistic, it all 5 correct? 5 depends on how much you get. Some people -- The same 6 A Yes, the Yusho oil. 6 person might react to a good-sized dose of poison ivy, and 7 Q Dr. Kelly, going down to physical 7 he wouldn't react at all to a small dose of poison ivy. 8 examination, it says, "On the forehead extending within 8 Q Have you ever seen two cases of chloracne 9 the hairline and on the cheeks, chin, nose and neck were 9 which are just identical? 10 numerous small very black tenacious comedones, their 10 A No. 11 distribution being best described as peppered within the 11 Q There is some variability to all of them, is 12 skin." Could you explain that description to the jury 12 that a fair statement? 13 in any more detail other than what is stated there? 13 A Oh, yes, from insignificant to severe. 14 A No, sir. 1 don't know what he meant. 14 Q What would be an example of an insignificant 15 Q When it says within the hairline, what does 15 case of chloracne? 16 that mean? 16 A Something a man doesn't know he has until a 17 A Well, 1 think everybody knows what a hairline 17 doctor looks at it and says, "1 think you've got 18 is. That's where your scalp stops and your forehead 18 chloracne." 19 starts. 19 Q What would those signs be of an insignificant 20 Q So there would have been according to this 20 case? 21 observation small very black tenacious comedones within 21 A Small blackheadsaround the cheekbones. 22 the hairline itself? 22 Q Anything else? 23 MR. CARNEY: Well, I'm going to object. 23 A That's it. 24 You're asking this witness to possibly speculate as to 24 Q Then the next, itsays, "Many of the 25 what those words mean and what Dr. Jones meant. 1 25 comedones surmounted firm shot-like cysts which in some Page 30 Page 32 1 think -- 1 don't know that this witness is any better at 1 areas contained viscid yellow pus." What does that, break 2 reading those words than the jury or the lawyers are. 2 that down for us? 3 MR. McCREA: 1 agree, 1 think it pretty well 3 A This means that these blackheads were sitting 4 speaks for itself. 4 on top of a cyst. A cyst is a collection of liquid or 5 Q (By Mr. McCrea) But 1 would like to clarify, 5 semi-viscous material or pus in these cases. So here we 6 doctor, if in fact there were small very black tenacious 6 have these little blackheads sitting on top of a circular 7 comedones inside the hairline. In other words -- 7 area that contained yellow pus. 8 A That's what he said. 8 Q Next sentence, "The pustular elements were 9 Q Have you seen that reported in other cases of 9 more noticeable on the neck." Can you tell the jury what 10 chloracne? 10 that would appear to be? 11 A 1 may or 1 may not have. It's not a very 11 A It means whatever he had were more noticeable 12 prominent -- it doesn't stand out very much in my mind. 12 in his neck than anyplace else. 13 Q But it did in this case? 13 Q What does it mean, pustular? 14 A Did and he reported it. 14 A That means the cysts that contained viscid 15 Q Isn't it true, Dr. Kelly, that there's a 15 yellow pus that he mentions in his previous sentence. 16 great variability among people to symptoms, for instance, 16 Q "Some shot-like comedones had appeared only 17 1 could walk through a patch of poison ivy and break out, 17 the shoulders, mid portion of the back and chest with an 18 and somebody else could lie down in the stuff and not be 18 occasional large cyst." Does that fairly well speak for 19 effected, is that generally safe -- Is that fair to say? 19 itself, Doctor? 20 A Well, no, because first of all you're 20 A 1 think so. 21 confusing terms. A symptom is a complaint that's not 21 Q "A particular peppering of the skin with 22 objective. You can't see it. A sign is what you would 22 tenacious carbon-colored comedones was apparent around the 23 get when you go into poison ivy. You would get a blister, 23 umbilicus and lower portion of the abdomen." Is that 24 you would get redness. A symptom would be itching. Now 24 descriptive in and by itself? 25 to answer your question, yes, some people when exposed to 25 A 1 think so. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 29 - 32 LEXOLDMONOQ6814 Page 33 Page 35 1 Q "The scrotum and penis were involved in a 1 outside ofthe skin. 2 similar process; the former being given more to the 2 Q But nothing specific? 1 mean, it's not -- he 3 formation of cysts." We've discussed that? 3 wasn't referred to a specialist in neurology by Dr. Jones. 4 A Yes. 4 A No, but he had no symptoms of findings 5 Q "The outer surfaces of the forearms and 5 that -- after all Dr. Jones is a physician, he would know 6 interior thigh showed similar but fewer comedones." Can 6 if a man had neurological symptoms or neurological 7 you show to the jury what is meant when they state the 7 findings. 8 outer surfaces of the forearms? Is that this part here? 8 Q Well, couldn't lassitude be a neurological 9 A That's outer, this is inner. 9 symptom? 10 Q So it would be this part of the forearm which 10 A No, sir, lassitude, a neurological -- it's 11 had comedones, correct? 11 hard to say whether a symptom is neurological or 12 A Yes, sir. Fewer they said. 12 psychological. 13 Q Yes. And then it says, "The anterior thighs 13 Q Could it be a neurological symptom? 14 likewise showed fewer comedones," and anterior would be 14 A 1 don't think so. 1 wouldn't include it as a 15 the front portion of the thigh? 15 neurological symptom. 16 A That's correct. 16 Q Can a person experiences lassitude as a 17 Q Have you seen that condition in other cases 17 result of medications? 18 of chloracne where it's on the outer forearm and the 18 A Oh, certainly. 19 anterior thigh? 19 Q And how is that brought about? 20 A Yes. But not limited to those areas, yes, 20 A You have medicines that are depressants. 21 sir. 21 You're using the term neurological and I'm using the term 22 Q In addition to other places? 22 psychological. 23 A Other places? 23 Q Well, if it's a depressant and it affects the 24 A Yes, sir. 24 brain? 25 Q Other places. Says, "The whole eruption was 25 A Yes, sir. That's correct. Page 34 Page 36 1 acneform but differed from acne particularly in the lack 1 Q And that can result in lassitude? 2 of a seborrheic appearance of the skin and in the 2 A Yes, sir. 3 peculiarly deep black of the comedones as well as a 3 Q Page 1025, treatment, they gave this man 4 general peppered distribution in areas not usually 4 radiation, correct? 5 involved with acne vulgaris?" Can you explain that to the 5 A Yes, sir. 6 jury? 6 Q Then microscopic examination. Dr. Kelly, 7 A Well, acne vulgaris means common acne, 7 have you ever done microscopic examination of skin samples 8 teenage acne which goes up to at adult life. Seborrhea is 8 of individuals in whom you suspected chloracne? 9 flaking of the skin, redness of the scalp and flaking of 9 A No, sir, 1 have not. 10 the skin also that accompanies teenage acne. The deep 10 Q And they describe on page 1025, "Summary of 11 blackheads seen in chloracne are not usually present in 11 the symptoms and treatment in sixteen cases of acneform 12 acne vulgaris, that's what he says. 12 eruption," and across the top it has case, and a number, 13 Q All right, sir. Then he goes on to describe 13 age, race, type of skin, type of eruption. Is that time 14 treatment and he goes on to describe microscopic 14 of exposure, 1 can't read it on mine? 15 examination on page 1025? 15 A Yes, time of exposure. 16 A Yeah. Well, he also, to end up, be complete, 16 Q Time of exposure, and special treatment and 17 he also ends up saying a general physical examination 17 it goes through all sixteen cases? 18 revealed nothing of importance. 18 A Yes, sir. 19 Q All right, sir. 19 Q Do you know which after these individuals you 20 A And the treatment, yes, sir. 20 consulted when you became medical director? 21 Q And on the general examination which revealed 21 A No, sir, they don't have the names down. 22 nothing of importance, what do you understand to be a 22 Q But you did consult -- 23 general physical examination? 23 A Some of them, yes. 24 A Examination ofthe heart, lungs, blood 24 Q Some of them when you became medical director 25 pressure, abdomen, neurological system; the whole business 25 for Monsanto Company? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 33 - 36 LEXOLDMONOQ6815 Page 37 Page 39 1 A Yes, sir. 1 c-o-l-l-o-r-a. 2 Q Did you make any inquiry into the symptoms of 2 Q And it makes reference in that same sentence 3 lassitude, loss of libido, loss of appetite? 3 at the end to scarring, "Leaving in their wake much 4 A Not that 1 recall. 1 don't know if 1 did. 1 4 scarring." Is that something that has been reported in 5 asked them how they were feeling. When they said they 5 chloracne, scarring? 6 felt fine 1 figured they had no symptoms. 6 A Well, it's been reported in chloracne, it's 7 Q Before you commenced your consultation with 7 been reported in teenage acne, it's been reported in adult 8 these individuals you had read this article? 8 acne. Wherever you incise a cyst that has pus in it, you 9 A Yes, sir. 9 get a scar from the incision and the healing. 10 Q The microscopic examinations described in 10 Q Next couple of pages describe the process of 11 this article, is there anything you feel is indicative of 11 manufacture, is that a fair statement, Doctor? 12 chloracne as aerolites of microscopic examinations? 12 A Yes, sir. 13 A Are we talking about this article or any 13 Q Break time. 14 time? 14 (Whereupon, a short break was taken.) 15 Q No. In general. 15 Q Dr. Kelly, we're ready to resume here. This 16 A Yes. Some dermatologists and some 16 morning we have discussed Exhibit K-2, which 1 believe you 17 pathologists believe that they could tell chloracne by 17 have in front of you? 18 microscopic examination. 18 A Yes, 1 do. 19 Q Who are some of those folks? 19 Q And for the record that document is titled, 20 A Suskind is one. 20 An Acneform Dermatergosis -- Can you pronounce that for 21 Q Who else? 21 me? 22 A Gosh, 1 don't remember them offhand, but -- 22 A No. That's a -- 1 think you're doing as well 23 Q Page lOtwenty-six is what, is that a 23 as anybody. That's an obsolete term. 24 photograph of a microscopic examination? 24 Q Authored by Jack W. Jones, M.D. and Herbert 25 A A section of the skin from the chest showing 25 S. Alden, M,D., Atlanta, Georgia. Do you know if you in Page 38 Page 40 1 the formation of the acneform eruption, eruption meaning a 1 fact interviewed the individual whose case was reported on 2 condition or rash, acneform being acne. 2 page 1024? 3 Q Is that a situation where they actually took 3 A No, sir, 1 do not. 4 a photograph of the microscopic -- 4 Q Just to be clear for the record and 1 think 5 A Yes, sir. 5 this has been asked and answered, but just to be totally 6 Q Picture? 6 clear, when you interviewed the workers who had been 7 A They took one out of the skin and sliced it 7 exposed to these chemicals in 1935 or 1936? 8 and put it on slide and put a microscope on it and put a 8 A Wait, 1 did not -- which of the dates, '35 or 9 camera on top of the microscope. 9 '36. 10 Q Page 1027, "Twenty-three of twenty-four men 10 Q When you interviewed them? 11 reported acneform eruption on the face and body." It says 11 A No, 1 didn't interview them in '35, 1 wasn't 12 of the twenty-three, sixteen were examined. What does 12 with Monsanto in '35. 1 didn't interview them in 1936, it 13 this mean, Doctor, just above the photograph, "In many 13 was '37 or '38. 14 patients numerous small sebaceous abscesses developed 14 Q Thank you. When you interviewed them, you 15 particularly around the -- 1 read that as c-o-l-l-o-r-a, 15 did not ask any of them if they had experienced tiredness 16 is that correct? 16 when they were exposed to the chemicals? 17 A Collar, collar, they just spelled it wrong. 17 A To the best of my knowledge, 1 did not. 1 18 1 think it's the collar line. That would be what 1 would 18 asked them if they had lost any work, how they were 19 think. 19 feeling and the response was favorable. They said, "1 20 Q That would be just above the collar around 20 feel fine." 21 your neck? 21 Q And just to be clear on the record, you did 22 A Yes. 22 not ask any of them if they had experienced a loss of 23 Q But that c-o-l-l-o-r-a is just a misspelling? 23 appetite when they developed the chloracne? 24 A 1 don't know. 1 don't know what else it 24 A You mean 1 did not ask them in 1937 whether 25 could be. 1 have never heard of a work like 25 they had lost their appetite in 1935? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 37 - 40 LEXOLDMONOQ6816 Page 41 Page 43 1 Q No. When they had the chloracne. 1 in the color of Aroclors? 2 A Well, that's when they had the chloracne, in 2 A Well, 1 don't have any specific knowledge, 3 '35. 3 but it may exist. 1 don't know. 4 Q 1 thought it was earlier. 4 Q What would that indicate to you if there was 5 A Well, it was very-- Well, whenever they had 5 a variation in colors? 6 the chloracne, no, 1 did not. 6 A 1 am not a manufacturing chemist. 1 cannot 7 Q And again to be clear for the record you did 7 comment on that. 8 not ask any of the individuals whom you interviewed if 8 Q On page 1030 at the bottom of the paragraph 9 they had experienced a loss of libido when they suffered 9 beginning, "In the beginning," it states -- and I'll read 10 the chloracne? 10 the sentence, "In the beginning an attempt at prevention 11 A 1 did not in 1937 or'37 or whenever. 1 11 of the condition was made by being especially careful that 12 discussed their case with the workers that has chloracne 12 all men engaged in the manufacture of chlorinated diphenyl 13 and when they were working for the Swann company 1 did not 13 should have a thorough bath after working hours and that 14 ask in 1937 or'38 if they had loss of libido. No, 1 did 14 they should wear freshly laundered clothing before 15 not. 15 starting work." Would you consider a deviation from that 16 Q And again, to be clear for the record, when 16 practice as an unsafe practice? 17 you interviewed the workers you had read this article? 17 A No. It all depends on what the working 18 A That's correct. 18 conditions were. In other words, if this referred to the 19 Q You had also 1 believe talked to Dr. Alden or 19 early days of manufacturing chlorinated biphenyl at 20 Jones? 20 Anniston, that's one thing. If it referred to after we 21 A 1 believe 1 had. I'm not sure 1 did. 21 had - after the modernization of the plant and the 22 Q Before you interviewed the workers? 22 improvement in the housekeeping and the improvement in 23 A At some-Yes. I'm not sure that 1 did. 1 23 ventilation they may not have had to do this. 24 mean, I'm not certain of that. That is fifty-five years 24 Q If a worker came up to you and he said, "Dr. 25 ago. 25 Kelly, when should 1 have a thorough bath after working Page 42 Page 44 1 Q Did you generate written materials as a 1 hours and wear freshly laundered clothing?" What would 2 result of your interview of those workers? 2 you tell him? 3 A No, 1 did not, no. 1 think you're stating 3 A About what? He just walks in and asks 4 this interview, 1 saw these workers while they were 4 anything? 5 working and 1 asked them if they had been - some of the 5 Q Yes. If he says, "Dr. Kelly, when should 1 6 ones that had been seeing Dr. Jones and during the course 6 have a thorough bath after working hours, and have freshly 7 while they were work, 1 talked to them about their present 7 laundered clothing?" What would you tell him? 8 medical condition. 8 MR. CARNEY: Are you talking about what 9 Q Could we - 9 period of time, what plant? Just generally a worker? Is 10 A It was not a formal interview. 10 he a PCB worker; is he in the Anniston plant? 11 Q Excuse me. Could we call that medical 11 MR. McCREA: Let's say in 1958. 12 examination? 12 Q (By Mr. McCrea) In 1958 if a worker called 13 A No. We could not. 13 you from the Bloomington, Westinghouse plant and asked 14 Q Did you interview them in an office type 14 under what conditions he should have a thorough bath after 15 setting? 15 working hours and have freshly laundered clothing, what 16 A No, 1 saw them at their workplace. 16 would you tell him? 17 Q Doctor, can differences in the color of PCB's 17 MR. CARNEY: I'm going to object because 1 18 indicate impurities? 18 think the doctor doesn't have knowledge of the Bloomington 19 A Yes. 19 plant. 20 Q Did Monsanto publish documents which 20 A 1 would tell him, "1 don't know exactly how 21 described variations in the color of certain Aroclors in 21 you're exposed. 1 don't know how much contact you've had 22 the manufacturing process? 22 with material. That is something for you to ask your 23 A 1 don't know whether they did or not. 23 supervisor, don't ask me." 1 don't know what his 24 Q As of this date you have no knowledge of 24 exposure - 1 don't know what else he was exposed when 25 documents published by Monsanto which describe variations 25 they were outside of PCB's. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 41 - 44 LEXOLDMONOQ6817 Page 45 Page 47 1 Q (By Mr. McCrea) If the worker asked you what 1 (Reporter read back from the record as directed: 2 exposure would require a thorough bath after working hours 2 Q "Would you consider soaked and 3 and wearing freshly laundered clothing, how would you 3 saturated clothing on one day with no thorough bath and no 4 describe that exposure that would necessitate those 4 freshly laundered clothing as an unsafe working 5 precautions? 5 condition?") 6 A 1 would say if you have your -- In the first 6 A 1 would consider if the person wore a 7 place, 1 don't know if 1 would be in a position to comment 7 clothing that was saturated with PCB's and wore it for a 8 on this man's work over there. 1 would have to take that 8 working day, that should in the be allowed. 9 into advisement -- under advisement. But as a general 9 Q (By Mr. McCrea) And would that be unsafe? 10 recommendation 1 would say that if your clothes is -- 10 A That again depends. 1 don't know if that has 11 clothes are soiled, soaked with the material you should 11 occurred. It's not been reported as causing any problems. 12 notwearthose. You should talk a bath or a shower 12 Sol can't answer whether it's unsafe. 13 immediately, or during your -- Shortly after such exposure 13 Q The next sentence states that, "These workers 14 occurred. 14 were also instructed to apply night and morning veterinary 15 Q And would you consider the failure to have a 15 white lotion to the affected parts." Do you know what the 16 thorough bath after working hours and wear freshly 16 purpose of that was? 17 laundered clothing under those circumstances an unsafe 17 A 1 haven't the slightest idea. 18 practice? 18 Q Doctor, do you know any of the gentlemen 19 MR. CARNEY: Well, I'm going to object to the 19 whose names are referenced in the abstracts of discussion 20 question. 1 think it leaves too many facts out. 1 don't 20 which begins at page 1033, Dr. Oliver S. Ormsby, Chicago? 21 know what you're talking about again, what other chemicals 21 A 1 do not know him. 22 the person might be exposed to, what the extent of the 22 Q Do you know Dr. Marion E.Sulzberger? 23 exposure -- There are too many factors there that you 23 A 1 know him by reputation.He was a very 24 haven't hypothesized. What time period, what plant, and 24 prominent dermatologist. 25 Dr. Kelly -- if you're referring to Bloomington again, he 25 Q Dr. H.G. Irvine? Page 46 Page 48 1 has indicated he's never seen that plant. 1 A No, 1 do not know him. Know of him either. 2 A It would have to be an assumption. 1 could 2 Q Dr. Kelly, who is Herbert Blumenthal? 3 answer that as far as the Monsanto plant is concerned. 3 A Herbert Blumenthal is a Ph.D. who is United 4 Q (By Mr. McCrea) What would your answer be as 4 States -- who's with the United States Public Health 5 far as Monsanto's plant is concerned? 5 Service --1 mean, the United States Department of 6 A 1 would say that if you're exposed to PCB's 6 Agriculture. 7 and your clothing is saturated with it at various areas 7 Q Did you recall correspondence with Dr. 8 you should take a bath and change your clothing. 8 Blumenthal regarding PCB's? 9 Q And would you also consider that an unsafe 9 A 1 know I've had correspondence with him. If 10 working condition? 10 you show me it will refresh my memory. 11 A Well, it depends how long it was repeated, 11 Q All right, sir. 12 how often it was repeated. 1 don't know. 1 mean, you are 12 MR. McCREA: Could the court reporter mark 13 asking for an assumption that I'm not in a position to 13 this as our next exhibit? 14 give. 1 just don't have all the facts on it. 14 (Whereupon, Plaintiffs Deposition Exhibit No. 3 15 Q Weren't you asked to give expert testimony as 15 was marked for identification.) 16 well as factual testimony as to the fact that if there 16 Q (By Mr. McCrea) Dr. Kelly, can you identify 17 were safe working conditions there would be no risk from 17 what is marked Plaintiffs Exhibit No. 3? 18 PCB's? 18 A Yes, sir. 19 A That's correct. 19 Q What is that? 20 Q Would you consider soaked and saturated 20 A This is a letter from me to Dr. Blumenthal. 21 clothing on one day with no thorough bath and no freshly 21 Q Sir, if 1 could look over your shoulder, 1 22 laundered clothing as an unsafe working condition? 22 just have one copy of this. Did you authorize the 23 A Are you saying then -- 23 exhibit? 24 MR. CARNEY: Read that question back. I'm 24 A Yes, 1 dictated it. 25 not sure 1 -- 25 Q In the first sentence you state, "1 thought Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 45 - 48 LEXOLDMONOQ6818 Page 49 Page 51 1 you would be interested in knowing Monsanto is committed 1 escape of PCB's into the environment? 2 to a program will allow the future use of our Aroclors 2 A 1 don't know when it was found that it was 3 only in those applications where escape to the environment 3 getting into the food chain. 1 don't know the exact time 4 can be prevented." First of all, for the jury are 4 of that. 5 Aroclors synonymous with PCB's? 5 Q In what way would PCB's entering the food 6 A Some Aroclors are PCB's, some Aroclors are 6 chain be a risk to individuals? 7 not PCB's. There could be chlorinated terphenyls. 7 A There might have been no risk at all. It 8 Q Could we substitute the word PCB's for 8 wasn't supposed to be in the food so we didn't want it 9 Aroclors and not change the impact of that first sentence? 9 there. 10 A Yes. 10 Q Did you have any scientific information that 11 Q When did Monsanto commit itself to a program 11 would suggest it was a risk? 12 to prevent escape of PCB's on the environment? 12 A No, sir. 13 A 1 can't answer that. 1 don't know the dates. 13 Q In 1970? 14 Q Will you describe that program for the jury 14 A No, sir. 15 that existed on the date of April 8, 1970 as you described 15 Q Had you read about Yusho? 16 to the U.S. Food and Drug Administration? 16 A Yes, sir. 1 believe 1 had at that - I'm not 17 A Well, we -- first of all 1 said we committed 17 sure about the dates. 1 thought 1 was referring to the 18 to the program, 1 don't know when we implemented the 18 United States food chain. There really wasn't in the food 19 program. But the program was to stop selling the material 19 chain, it was right in the food in Yusho. 20 for open uses. Open uses meaning plasticizers, paints, 20 Q And if it's in the food chain it's also in 21 lubricants and carbonless carbon paper. 1 don't know when 21 the food, is it not? 22 it was implemented but we were committed to do that. It 22 A Well eventually, yes; but 1 think there's a 23 takes a little while to get the bureaucratic machinery 23 little difference between a compound getting into the 24 going. 24 environment and going up the food chain and getting a 25 Q The bureaucratic machinery at Monsanto? 25 compound that -- pouring the material on your rice Page 50 Page 52 1 A And it's customers, yes. You have to give 1 pancakes. 2 them a little time before you stop pulling the rug out 2 Q In April 8, 1970 did you considerthe 3 from under them, their raw materials. 3 presence of PCB's in the food chain as a serious problem? 4 Q Why did you implement that program at 4 A Well, serious problem from the point of 5 Monsanto? 5 adulteration. 1 didn't consider it a serious problem from 6 A Well, 1 didn't. The company implemented it. 6 the health aspects. 7 Q Why did Monsanto implement that program? 7 Q Do you consider it a serious problem today? 8 A Because the material was getting into the 8 A No, sir. 9 environment and it was contaminating the environment and 9 Q If 1 called you up and asked you if you 10 it was staying there and we did not want to add any 10 consider PCB contamination of food a serious problem, your 11 contaminant to the environment that could help - that 11 answer today would be no? 12 would not be biodegradable. 12 A No, 1 didn't say that. 1 mean, it depends 13 Q In what way did the contamination of the 13 how you contaminate it. If you were pouring PCB into a 14 environment place the environment at risk as of April 8, 14 batter for cake mix or something like that, that's 15 1970 as you understood it? 15 contamination, but if you mean by that the presence of 16 A It was hurting the reproduction of birds. 16 PCB's in the marketplace basket, it is not a problem. 17 Q Did you consider that a fact that was 17 Where it is actually ingested accidently as it was in 18 established in science? 18 Yusho and Yucheng, yes, that was a problem; but in the 19 MR. CARNEY: At what point? 19 United States it is not a problem. 20 MR. McCREA: On the date of April 8th, 1970? 20 Q If 1 called you up and asked you about the 21 A I'm not sure about the dates, but 1 felt 21 environmental risks of owning a PCB transformer in a 22 quite sure of it. 22 substation next to a farmer's pasture, what explanation 23 Q (By Mr. McCrea) Were there other 23 would you give me as to the environmental risks and risks 24 implications other than the reproduction of birds that 24 of PCB's in the human food chain from the ownership of 25 encouraged Monsanto to introduce this program to prevent 25 that transformer in a substation? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 49 - 52 LEXOLDMONOQ6819 Page 53 Page 55 1 MR. CARNEY: Let me object to the question. 1 temperature ofthe fire. 2 1 don't understand the question. 1 think it's vague. Are 2 A 1 mean -- 3 you talking about farm - a transformer in the middle of a 3 MR. CARNEY: 1 think you're asking questions 4 farm crop? 1 don't understand what you're asking. 4 difficult to answer without the facts. 5 A 1 mean, if you want to describe - Here we've 5 Q (By Mr. McCrea) What would your advice be to 6 got this transformer on a pole in a farmer's field, right, 6 me if 1 asked you if it was safe to own that transformer 7 is that what you're talking about? 7 in that substation with two hundred gallons of PCB oil 8 Q (By Mr. McCrea) Yes, sir. 8 surrounded by a field in which there was hay consumed by 9 A What's he got in that field? 9 cattle? 10 Q He's got hay. 10 MR. CARNEY: And no leaking. 11 A 1 think the only risk he has if that 11 MR. McCREA: No leaking. 12 transformer leaks in the ground and there 1 think the 12 A I'd say it was safe. 13 amount of material that would be there in relationship to 13 Q (By Mr. McCrea) If 1 asked you the same 14 the amount of hay that a horse or a silage that a cow eats 14 question today about a transformer in a building that had 15 would depend on how much, how big the transformer was, how 15 no leaks, no malfunctions, contained two hundred gallons 16 much got into the silage. 16 of PCB oil; would there be any risk in your opinion to the 17 Q Could you explain those numbers to me if 1 17 ownership of that transformer? 18 made inquiry of you? 18 A Well, there's always a risk if it burned. 19 A Well, if you tell me how big the transformer 19 Q And what would that risk be? 20 is and how much PCB is in there and how much hay is going 20 A That the transformer would spill out the 21 to be contaminated 1 can explain it, but 1 can't make the 21 fluids and that during the fire PCB's could be ignited, 22 figures up myself for you. 22 they could be -- benzofurans could be formed in a 23 Q If it contained two hundred gallons of PCB 23 transformer, there's trichlorobenzene in there which could 24 oil and it was in a substation in the middle of a farmer's 24 form dioxins. They could be disseminated through the 25 field? 25 building. Certainly there's that risk. Page 54 Page 56 1 A Wait. We're talking about transformer in a 1 Q And how would you explain the health 2 pole the first time; now we're talking about dug down in 2 consequences of that particular fire and spread of furans 3 the bottom below a farmer's field? 3 throughout able? 4 Q No, in a substation. 4 MR. CARNEY: Let me -- 1 don't know what you 5 A Substation in his field? 5 mean by health consequences as opposed to having a 6 Q Right. 6 flammable transformer without the PCB oils, are you trying 7 A And you've got two hundred gallons in this? 7 to evaluate the relative risk of a PCB transformer versus 8 Q Right. 8 a non-PCB transformer. 9 A It's a pretty big substation. And it leaked? 9 MR. McCREA: No. I'm just asking him to 10 Q No, it didn't leak. 10 explain the health consequence to the people in the 11 A No. 11 building if the furans were contaminated. 12 Q It was just sitting there perking along? 12 A Well, 1 think in the first place once a fire 13 A Well, it was no problem. As long as it was 13 starts in the building everybody gets out. So it depends 14 contained there was no problem. 14 how fast you get out whether there's any risk or not. If 15 Q Would there by any risk to me as owner of 15 you aren't burned up, if you get out in time that you 16 that transformer in that as 1 described to you, a 16 aren't suffering from the consequences ofthe risk, you 17 transformer in a substation with two hundred gallons of 17 wont have any risk, you will get out. 18 PCB oil surrounded by a pasture of hay used to feed 18 Q (By Mr. McCrea) What if you don't? What if 19 cattle? 19 you're in there for twenty-four hours and you are exposed 20 A Well, the only risk would be if it leaks. 20 to the furans permeating the building? 21 Q Would that be a risk? 21 A How much exposure you've got to tell me. 22 A Yes, if you spill two hundred gallons out of 22 Q Well, I'm asking you for you evaluation. 23 it into his field, yes. 23 I'm making an inquiry of you and 1 want you to explain it 24 Q What if it burned? 24 to me with just the facts that have been given to me? 25 MR. CARNEY: Can you give us some idea ofthe 25 A Well, you haven't given me any facts. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 53 - 56 LEXOLDMON006820 Page 57 Page 59 1 MR. CARNEY: Well, I'll object. You are 1 the products of the fire, of combustion, from being 2 saying somebody is in a building burning for twenty-four 2 disseminated through the building, which would minimize 3 hours? 3 the risk very markedly. So it would be my opinion you 4 MR. McCREA: No, I'm asking, Tom, I'm asking 4 have to weigh all these factors. 5 him, Dr. Kelly, if 1 owned a transformer in a building 5 Q Weighing all the factors, if 1 asked you, Dr. 6 that contained PCB oil what are the risks of owning that 6 Kelly, what's the end line, should 1 replace it with a 7 transformer in that situation? 7 transformer with more risk of fire or should 1 keep the 8 MR. CARNEY: That wasn't the question you 8 PCB transformer with its risk, what's the bottom line? 9 asked. 9 A 1 would say it varies with the conditions but 10 MR. McCREA: Well, let's make that the 10 1 would believe that the PCB transformer is less risk than 11 question. 11 the one with an oil containing transformer. 12 A Is that the question? 12 Q Dr. Kelly, the next sentence on Plaintiffs 13 Q (By Mr. McCrea) Yes. 13 Exhibit No. 3 which is the second paragraph, states, 14 A Well, the risks are that if there's a fire 14 "Secondly-" and excuse me if 1 can look over your 15 and the contents of that transformer, which are 15 shoulder, "We have essentially a crash program underway to 16 trichlorobenzene and trichlor -- chlorinated biphenyl, two 16 find non-persistent, non-chlorinated substitute products." 17 different compounds are ignited and the fire is hot enough 17 Who initiated the crash program at Monsanto? 18 to reach certain temperature levels and not go to a level 18 A 1 think it was the division that manufactured 19 of which the material is completely disintegrated then 19 the PCB's, the division meaning the research, the sales, 20 there is a risk of these contaminants, these added 20 the marketing and the manufacturing group of the organic 21 compounds being formed. The amount of risk depends upon 21 division, which was one of the four manufacturing 22 the exposure a person has, and 1 can't say how much 22 divisions in the company. 23 exposure a person is going to have in that building. 23 Q And who were the individuals who initiated 24 Q If 1 asked you if 1 should continue to own 24 that crash program that you have described in your letter 25 that transformer knowing the risks that you know, what is 25 to the U.S. Food and Drug Administration? Page 58 Page 60 1 your answer? 1 A 1 think Minkler was one, who was 1 believe of 2 A 1 think 1 would have to equate that with what 2 the head of it at that time. 1 don't know. 1 don't 3 1 would do -- of what substitute 1 had. Do 1 run the risk 3 remember the other names at present, but Howard Minkler 4 of a fire that would be enormously more extensive with an 4 was to my impression, the best of my recollection the 5 oil filled transformer, or do 1 run the possible risk of 5 vice-president in charge of that particular division in 6 adverse consequences from the PCB fire? 1 don't know. 6 April of 1970. 7 Q So if 1 called you and asked you if 1 should 7 Q Where was the research being done for the 8 continue the ownership of that transformer your answer 8 crash program? 9 would be you don't know? 9 A At St. Louis. Maybe it was done at Dayton 10 A No. 1 don't think 1 said that, you are 10 also. 11 talking to me at- 11 Q Did Monsanto develop a non-persistent, 12 Q Well, your answer- 12 non-chlorinated substitute product? 13 A Well, 1 would say if 1 - 1 would say 1 would 13 A 1 don't know if they did subsequent to my 14 not -- 1 would weigh both factors and 1 would - and 14 departure. 1 don't know if we had developed one or not. 15 depending on whether or not the individual thought that 15 Q What were the non-persistent, non-chlorinated 16 there was a more serious problem relating to a use of a 16 substitute products that were the subject of the crash 17 flammable material in the transformer or a PCB containing 17 program in April, 1970. 18 fluid, if he thought there was more likelihood of a danger 18 A 1 haven't the slightest idea. There were 19 from the oil 1 would say keep on using it. Now speaking 19 phthalates, there were silicones, there were a whole 20 as of today you're talking about? 20 battery of them. 1 don't know what they - and they might 21 Q Right, 1990? 21 have looked at a hundred different potential products. 22 A Well, speaking as of 1990 1 would say then 22 Q When was that crash program started? 23 you should be in a position to insure that if that 23 A As 1 said 1 don't know it was implemented. 1 24 eventuality occurs in which a PCB transformer burns there 24 know that they were committed in April of 1970. 1 don't 25 should be methods to keep the material from the soot and 25 know when the research program started. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 57 - 60 LEXOLDMONOQ6821 Page 61 Page 63 1 Q Did you inform Westinghouse that you had 1 wrote this letter? 2 initiated a crash program to find non-persistent, 2 A Did 1 research what information? Whether the 3 non-chlorinated substitute products as you informed the 3 customers were using some of our product or somebody 4 U.S. Food and Drug Administration? 4 else's product. 5 A You mean me personally? 5 Q The names of the two large users and the type 6 Q Yes, sir. 6 of products they were switching to? 7 A No. 1 think that's commercial matters that 7 A Well, I'm sure 1 had known that two companies 8 the marketing group or technical service people would have 8 were using other products instead of PCB's, but when you 9 done, not me. 9 say research it, 1 don't know what you mean by that. 1 10 Q Do you know if Monsanto Company gave the same 10 knew enough to write them a letter and say two of these 11 information to Westinghouse that they are giving to the 11 people, two large producers were getting out PCB's. 12 U.S. Food and Drug Administration that describes a crash 12 Q Have you ever been asked about this letter in 13 program for non-persistent, non-chlorinated substitute 13 any other depositions that you've given for Monsanto? 14 products? 14 A 1 don't recall. 15 A No, 1 don't know. 15 Q Next sentence, "Obviously, Herb, you can 16 Q Why did you tell the U.S. Food and Drug 16 recognize the competitive aspect of developing and phasing 17 Administration that you were initiating a crash program, 17 into sales such time of substitutes, so at present we are 18 what's the relevance of that to them? 18 not making any widespread announcement." Would you 19 A Well, 1 don't know what the relevance is, but 19 explain why you are telling the U.S. Food and Drug 20 1 thought Herb and 1 were good friends and 1 thought 1 20 Administration that information? 21 would let him know how we were coming along. He was 21 A 1 don't know what my mindset was at that 22 interested in the same things we were interested in, in 22 time, but 1 think it speaks for itself. We are trying to 23 keeping it out of the food, and if -- 1 was telling him 23 get out of the PCB's, and we haven't reached a point where 24 that not only were we going to cut down the uses where it 24 we said we are going to get out of it because we don't 25 could escape into the environment but we're doing our best 25 know when a substitute will be available. Page 62 Page 64 1 to try to eliminate PCB's all together in those uses, in 1 Q Well, aren't you saying that we don't want 2 all uses. 2 everybody to know we're getting out of the PCB business 3 Q The next sentence states, "Already we have 3 because if we did they would capture the market on 4 two large users switching to substitutes of this type." 4 substitute fluids, so we're going to keep that information 5 Period. Who were these two large users? 5 ourselves, develop our own substitute fluids and retain 6 A 1 don't know, but 1 do not believe they're in 6 the market, is that what that says? 7 the electrical field. They may very well have been in the 7 A Of course not. Keep it ourselves? I'm 8 plasticizer field. 1 would imagine they were the 8 writing to the government and I'm keeping it to myself? 9 plasticizers. 9 Q Well, 1 don't know about that, but it says we 10 Q And today as you sit here you do not recall 10 are not making any widespread announcements? 11 who the two large users were? 11 A That's right; but after all there were two 12 A No, 1 do not. 1 do not even know what field 12 large users that were switching. 1 don't know if they 13 they were in. 13 switched to substitutes of ours or substitutes of somebody 14 Q Did you on the day you wrote the letter? 14 else, but they knew we were doing our best to get people 15 A I'm sure 1 did. 15 out. We had already told customers that we are cutting 16 Q And you say switching to substitutes of this 16 down the use of the material in not allowing for 17 type," what substitutes are you referring to in your 17 applications where it could get out. So 1 don't see 18 letter to the U.S. Food and Drug Administration? 18 anything wrong with what 1 told Herb. 19 A If I'm -- They were I'm going to say 19 Q It says, "You can recognize the competitive 20 non-persistent, non-chlorinated substitute products. 1 20 aspects of developing and phasing into sales such type of 21 don't know which ones they were. They were very probably 21 substitutes so at present we are not making any widespread 22 of the phthalate group,p-h-t-h-a-l-a-t-e. 22 announcement," isn't that so you can retain the sales 23 Q Were they manufactured by Monsanto? 23 market? 24 A 1 don't know. 24 A No, it really isn't, because we're not the 25 Q Did you research the information before you 25 only people manufacturing these fluids. We're not even Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 61 - 64 LEXOLDMONOQ6822 Page 65 Page 67 1 talking -- you know, I'm not saying, 1 don't know who 1 Q But you've testified to it a number of times, 2 these -- what fields these other users were in. 2 Dr. Kelly? 3 Q Dr. Kelly, isn't it a fact that you were the 3 A Well, certainly 1 have, but 1 mean, 1 don't 4 only company in the United States making PCBs? 4 know if I've seen the entire program. I've seen parts of 5 A That's true. 5 it. 6 Q And you knew that if PCB's are eliminated 6 Q The last sentence states, "On the other hand, 7 substitute fluids will be used? 7 if the publicity gets as red hot as it did in the case of 8 A If they work, yes. 8 DDT we may be forced to make such an announcement at any 9 Q And you wanted the market on the substitute 9 time." What do you mean by that statement? 10 fluids? 10 A Well, 1 think some decisions are made on 11 A No, that is not correct. Of course we were 11 scientific bases, some are made on commercial bases, some 12 in the business, we wanted to have as good a chance as 12 are made on emotional bases and some are made on political 13 anybody, if they liked our fluid, fine. But nobody had a 13 bases. In the case of DDT, here was a wonderful product 14 fluid at that particular time that could use to -- that 14 that wiped out probably a hundred million malaria deaths 15 could do all the things that's PCB's could do. 15 that was banned because of emotional and political 16 Plasticizers are -- fifty different plasticizers could be 16 reasons. 17 used. 17 So that's what 1 mean, they had some very red hot 18 Q That's -- Go ahead. 18 publicity. Now if such an emotional and political 19 A 1 don't know what else you want me to say? 19 situation occurred we would be forced to make such an 20 Ask me a question. 20 announcement. By such an announcement 1 guess 1 refer to 21 Q Why didn't you make a widespread announcement 21 we're getting out of all the sales and we're doing our 22 that you had this crash program and you were making 22 best to make a product that doesn't have these things in 23 substitute? 23 it. 24 A That's a marketing decision and 1 didn't have 24 Q Did you ever make such an announcement to the 25 nothing to do with it. 25 public? Page 66 Page 68 1 Q Well, can you explain it? You wrote the 1 A We certainly made announcements we were 2 letter? 2 getting out of the material. 1 don't know if we made any 3 A 1 can't explain it. 1 just said we're not 3 announcements that we were working on substitute 4 making any widespread announcements. 4 materials, that's a sales and marketing situation. 1 5 Q You don't know why? 5 don't know whether they did or not. 6 A 1 do not know the marketing responsibilities 6 Q As you sit here today based on your years 7 of a supplier to his customer. 1 don't know what the 7 with Monsanto and all of your testimony you don't know if 8 marketing people had in mind; whether or not they could 8 this announcement to which you have referred and which you 9 say to a customer, we're getting out right now. 1 don't 9 describe in your Plaintiffs Exhibit No. 3 was ever made? 10 know what the Monsanto reasons were. I'm afraid you'll 10 MR. CARNEY: Well, which announcement are you 11 have to ask someone else. 11 talking about? 1 think there's several things. 12 Q You didn't tell Westinghouse about this 12 MR. McCREA: It says, "We may be forced to 13 information? 13 make such an announcement at any time." 14 MR. CARNEY: Well, objection. 1 don't think 14 A 1 find it a little hard to say what 15 that was his testimony. 15 announcements I'm talking about, but certainly 1 know we 16 A 1 said before, 1 said 1 would not be the 16 made two very definite announcements. One, we're getting 17 person to talk to a customer. It would be the marketing 17 out of all the open uses of PCB's. No. 2, we're getting 18 people, the development people. 18 out all uses of PCB's and discontinuing use and - the 19 Q (By Mr. McCrea) Have you seen documents at 19 manufacture and sale of it. We made these two 20 Monsanto which described the crash program? 20 announcements. Whether or not we made the announcements 21 A In its entirety? 21 we've got a substitute for this or if we ever had a 22 Q Right. 22 substitute of what percentage of the market we ever had, 1 23 A 1 may have. 23 don't know. 24 Q You don't recall that? 24 Q (By Mr. McCrea) Did DDT cause adverse 25 A No. After twenty years 1 don't think 1 do. 25 environmental effects? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 65 - 68 LEXOLDMONOQ6823 Page 69 Page 71 1 A Yes. It caused thinning of birdshell eggs. 1 let me look at it and it may refresh my memory 1 may know 2 Q Anything else? 2 something about it. 1 don't recall at the present time. 3 A No. Not that 1 can recall. 3 It was certainly not a very prominent feature of PCB's, 4 Q Dr. Kelly, isn't it a fact that at the time 4 let me tell you. 5 of this letter Monsanto was using PCB's in pesticides to 5 Q But it could be? 6 extend the kill life? 6 A Possibly, if they experimented with it. 1 7 A No, it was not. That was a recommendation 7 don't know if they ever marketed for it. 1 don't recall 8 made by the Department of Agriculture, as extender in 8 it. 9 pesticides. To the best of my knowledge 1 have seen the 9 Q Are you familiar with any test grounds at 10 Department of Agriculture recommendation but it certainly 10 Florida State University in which PCB's were used as a 11 was an extremely small portion of the PCB business and 1 11 termiticide in wood by Monsanto? 12 doubt very much -- there may be an isolated Monsanto 12 A 1 have heard something about that. They did 13 statement about its use, but 1 don't recall seeing it in 13 have experimental -- they did some experiment on -- 1 14 technical bulletins. 14 don't know, soaking PCB's or soaking posts in PCB's and 15 Q Dr. Kelly, you don't recall any publications 15 putting it in the ground and 1 think they used it after 16 of Monsanto in which they stated that PCB's extend the 16 the question of nonbiodegradeability came in, they checked 17 kill life of pesticides by up to ten years? 17 it to see - they checked those areas, but 1 don't recall 18 A 1 may have seen them referring to Department 18 of ever having any sales effort or marketing effort 19 of Agriculture work, they may have quoted Department of 19 devoted to the use of PCB's as a wood treating chemical. 20 Agriculture findings. 20 Q Do you recall the years in which Monsanto was 21 Q Did Monsanto have any customers to which it 21 experimenting with PCB's by soaking wood posts in the 22 sold PCB's to use as an extender in pesticides to -- 22 chemical? 23 A 1 don't know if it did or not. 23 A No, and I'm not even sure if they just soaked 24 Q Monsanto had a wood treatment operation, 24 the wood. 1 don't know how they did it. 1 just heard 25 correct? 25 that sometime after 1 left the company. 1 don't know when Page 70 Page 72 1 A Yes, it did. 1 1 heard it. 2 Q And you manufacturedpentachlorophenol? 2 Q Monsanto sold its wood preserving business to 3 A Yes, we did. 3 Koppers, correct? 4 Q And did youmanufacture other wood 4 A 1 don't know to whom they sold, they disposed 5 preservatives? 5 of it. They hadn't sold it by the time 1 left, but 1 6 A Sodium pentachlorophenate, which was a sodium 6 don't believe they are in the wood treating business 7 salt of pentachlorophenol. 7 anymore. 8 Q Did you use PCB's as a termiticide? 8 Q With respect to Plaintiff's Exhibit 3, which 9 A Not that 1 ever heard of. 9 is your letter to Herb Blumenthal, dated April 8, 1970, 10 Q As you sit here today you have no knowledge 10 did you receive inquiries from him before you wrote this 11 of Monsanto experimenting with PCB's as a termiticide for 11 letter? 12 a wood protection? 12 A 1 don't think so, and if 1 did 1 would have 13 A That's a little different than what you said. 13 very probably said, "In reference to your letter and so 14 You said did they ever use it as a -- 1 understand by 14 and so, here is the information." 15 using it did they offer for sale as a termiticide. Ido 15 Q Did you authorize this letter or did you sign 16 not know whether or not they ever experimented with it or 16 it or did you do both? 17 not. 1 don't know. 1 have seen no articles on it. 17 A 1 did both. That's my secretary's initials. 18 Q Do you know Robert Arceneaux? 18 Q But the information contained in the letter 19 A 1 recognize the name. 1 cannot tag him with 19 was your information, not information supplied to you. In 20 any position or anything in the company. 20 other words, you knew and understood what was being 21 Q If he has described experiments by Monsanto 21 stated? 22 in using PCB's to kill termites as a wood preservative, 22 A Well, 1 got it from somebody. 23 that information is new to you? 23 MR. CARNEY: I'm going to object. 24 A It all depends. 1 would think so, but if you 24 Q (By Mr. McCrea) Somebody didn't come in to 25 will give me what information he is supposed to have said, 25 you with a letter and say, "Dr. Kelly, could you sign this Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 69 - 72 LEXOLDMONOQ6824 Page 73 Page 75 1 and send it to Herb Blumenthal?" 1 monitoring program of Westinghouse for its workers -- 2 A They certainly did not. 2 A No, sir. 3 Q Dr. Kelly, you retired from Monsanto Company 3 Q -- exposed to PCB's? 4 in 1974, is that correct? 4 A No, sir. 5 A That's correct. 5 Q Do you know if Westinghouse had a medical 6 Q When you retired did you own stock in 6 monitoring program for its workers exposed to PCB's? 7 Monsanto Company? 7 A No, sir, 1 do not. 8 A Yes, 1 did. 8 Q Did you ever establish a written protocol for 9 Q Do you own stock in Monsanto Company today? 9 medical monitoring of workers exposed to PCB's? 10 A Yes, sir. 10 A No, sir. 11 Q Now 1 -- Do you know the value of that stock? 11 Q Were you ever asked to describe a medical 12 A 1 haven't looked lately. It's been going 12 monitoring program for workers exposed to PCB's by any 13 down. 13 individual from Westinghouse Electric Corporation? 14 Q Do you know the approximate value of all of 14 A No, sir. You must remember that Westinghouse 15 your stock ownership in Monsanto Company? 15 Electric was a very sophisticated medical organization. 16 A 90,000, something like that. 16 It antedated mine, was bigger than the Monsanto and they 17 Q And do any other family members have stock 17 knew all about PCB's. They knew how the workers were 18 ownership in Monsanto? 18 exposed, which 1 didn't. 19 A Small amounts. 19 MR. McCREA: Going to ask that that answer 20 Q Do you know what -- 20 be stricken and that Doctor, could you -- Could the court 21 A Ten thou -- 21 reporter reread the question and could you answer the 22 Q Excuse me. Do you know what that would 22 question? 23 total? 23 THE WITNESS: 1 thought 1 did. 24 A Ten thousand dollars. 24 MR. CARNEY: Well, I'm going to object to the 25 Q Do you have what generally could be referred 25 motion to strike, because 1 think the doctor did answer Page 74 Page 76 1 to as stock options at this time, can you increase your 1 the question. You just didn't like the answer. 2 stock ownership? 2 MR. McCREA: Didn't say 1 didn't like the 3 A Only by going out in the open market and 3 answer. 1 want the answer. 4 buying it. 1 have no stock options. 4 Could the court reporter please reread the 5 Q Did you know any of the individuals at the 5 question? 6 Bloomington Westinghouse plant from 1957 which 1 will 6 (Reporter read back from the record as directed: 7 represent to you is the day 1 understand it opened until 7 Q "Were you ever asked to describe a 8 today? 8 medical monitoring program for workers exposed to PCB's by 9 A No, sir. 9 any individual from Westinghouse Electric Corporation?") 10 Q Did you know any of the -- 10 MR. CARNEY: Why don't you read the answer? 11 MR. CARNEY: Would you read that last 11 (Reporter read back from the record as directed: 12 question back? 1 just didn't hear it. 1 didn't hear the 12 A "No, sir. You must remember that 13 dates. 13 Westinghouse Electric has a very sophisticated medical 14 MR. McCREA: 1957 to today. 14 organization. At any date -") 15 MR. CARNEY: Okay. You don't need to read 15 THE WITNESS: Antedated, a-n-t-e-d-a-t-e-d. 16 it. 16 ("- antedated ours, was bigger than Monsanto 17 Q (By Mr. McCrea) Did you know any of the 17 and they knew all about PCB's. They knew how the workers 18 individuals at the Muncie, Indiana transformer plant from 18 were exposed, which 1 didn't.") 19 the date it opened in the fifties to this date? 19 Q (By Mr. McCrea) Who told you about the 20 A No, sir. 20 manner in which the workers were exposed to PCB's at 21 Q Did you know any of the individuals at the 21 Westinghouse? 22 Westinghouse transformer repair facility in Cincinnati, 22 A Nobody. 1 said 1 didn't know how they were 23 Ohio at any point in time up to and including today? 23 exposed. 24 A No, sir. 24 Q You said you knew how the workers were 25 Q Can you describe to the jury the medical 25 exposed? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 73 - 76 LEXOLDMONOQ6825 Page 77 Page 79 1 A 1 said 1 didn't know. They knew, yes. They 1 Q Right. Amend, change? 2 were manufacturing it, they were using it. 2 A Well, not change, well, I'll amplify one. 3 Q Okay. What is the source of your information 3 Q All right, sir? 4 there? 4 A At the close of one deposition you asked me 5 A 1 guess it's common sense. Ifyouhavea 5 did you put on the label, on PCB's, that it could kill 6 company that is using a material and it's in their plant 6 you, and 1 said no. I'd like to amplify that by saying; 7 they know how they are using it, they know how their 7 We manufacture aspirin; aspirin if you take too much of it 8 workers are exposed. 8 will kill you, we don't put that on the label. People 9 Q How were your workers exposed? 9 manufacture iron pills; if you take enough iron pills that 10 A They were exposed during the filling, during 10 will kill you. There are probably four hundred thousand 11 leaks in pumps, they were exposed during changes in pumps, 11 industrial chemicals that will kill people if you take too 12 they were exposed during flushing out of lines. 12 many. None of those are put on the label. 13 Q Were you exposed by fires? 13 Q Any other answers that you would like to 14 A No, sir. We didn't have any fires. 14 amend or modify; amplify in any way? 15 Q Were there any other ways in which your 15 A No; but 1 presumably will see the deposition 16 workers were exposed? 16 to correct it for errors. 17 A Well, they may have been exposed by cleaning 17 Q Absolutely correct. Dr. Kelly, have you 18 parts of the equipment. 18 reviewed any depositions of any of the plaintiffs in this 19 Q And that's common sense? 19 case? 20 A Beg your pardon? 20 A No, sir. 21 Q That's common sense? 21 Q Did you consult with Monsanto Company or the 22 MR. CARNEY: Well, 1 don't know what you mean 22 attorneys regarding questions to be addressed by Monsanto 23 by common sense. You're -- 23 to the plaintiffs in this case? Did you help them prepare 24 Q (By Mr. McCrea) Well, strike it. Were there 24 questions? 25 any other ways that your workers were exposed? 25 A No, sir. There may have been Page 78 Page 80 1 A 1 can't think of any. 1 interrogatories, but 1 don't even know if 1 did that. 2 Q Were there vapors? 2 Q 1 appreciate that, and 1 think you answered 3 A Well, yes. 1 said during filling, material 3 it. You didn't sit down with them and say, "Why don't you 4 came out hot. 4 ask this set of questions?" This might be helpful to our 5 MR. McCREA: Break. 5 case." 6 (Whereupon, a short break was taken.) 6 A No, sir. 7 Q (By Mr. McCrea) Dr. Kelly, we're back on the 7 MR. McCREA: Could the court reporter mark 8 record. Dr. Kelly, during the time that we had the 8 this as Plaintiff's Exhibit 4, 1 believe? 9 continuance of the deposition were there any materials 9 (Whereupon, Plaintiffs Deposition Exhibit No. 4 10 that you reviewed or any answers which you gave that you 10 was marked for identification.) 11 would like to bring to your attention? 11 Q Dr. Kelly, during the depositions of the 12 MR. CARNEY: Read that question back -- 12 plaintiffs in this case, the attorneys for Monsanto asked 13 MR. McCREA: It's a compound question, let 13 certain questions regarding health problems or health 14 me break it down. 14 symptoms; now 1 will represent to you that 1 abstracted 15 Q (By Mr. McCrea) Dr. Kelly, we had two days 15 those depositions and took a list of perhaps eighty-five 16 of depositions a week ago or so, following the continuance 16 percent of the questions which Monsanto asked to the 17 of the deposition during that interim time, were there any 17 plaintiffs. 18 materials that you reviewed as those materials relate to 18 1 have listed those symptoms on a document and 1 19 answers you gave which you would like to bring to our 19 would like to now hand your attorney that document so that 20 attention and if so what are those materials? 20 he may receive it and then 1 would like to hand it to you 21 A No, sir. 21 and then I'll address a question to the document and we 22 Q And the same question for any answers, were 22 can go from there? 23 there any answers which you gave which upon thinking about 23 A Yes. 24 them you would like to amplify them in any way? 24 MR. CARNEY: Let me just object for the 25 A To amplify? 25 record that Exhibit -- Plaintiff's Exhibit 4 is 1 believe, Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 77 - 80 LEXOLDMONOQ6826 Page 81 Page 83 1 six pages long and I'm not going to take the time -- 1 1 and they are multiple questions, or multiple choice 2 don't think you're proposing that 1 do to check make sure 2 questions. 3 the statements that you made about the document -- I'm not 3 I'm going to object to that being done at this 4 saying they are inaccurate, 1 just don't know about 4 deposition. 1 don't think that there is any basis for 5 checking them. 5 that kind of a questionnaire being done or taking up the 6 MR. McCREA: I'm not stating that they are 6 time of the jury or the - and the time of everybody here 7 totally accurate, all right. I'm not stating that each 7 while the doctor would have to answer that. It could take 8 and every health symptom and/or problem on that list is a 8 a significant amount of time. If-so 1 would object to 9 verbatim abstract from the depositions. But what 1 will 9 this as a format and 1 would object to the question 10 tell you is it's a good faith effort to duplicate all of 10 because 1 think the question's compound and vague and 11 the questions which you asked nearly all of our plaintiffs 11 ambiguous. 12 in some forty some depositions, and by you 1 mean 12 Q (By Mr. McCrea) Dr. Kelly? 13 Monsanto, and 1 also will represent to you that it 13 A Can 1 answer it? 14 includes perhaps eighty-five percent of the questions, 14 Q Just a second. It's important for me that 15 there are maybe fifteen percent that are not incorporated 15 you understand the document in question. 1 did this to 16 on this document. 16 save time and if you would like to go off the record and 17 MR. CARNEY: Okay, just for the record, 1 17 check those off, that's fine with me. You don't have to 18 think most of these problems that are listed in Exhibit 4 18 sit here on the record and do it. But rather than ask 19 and again I'm not going to take the time to look at them, 19 each one and then have it typed out in a deposition, 1 20 but 1 would say probably most of them are complaints that 20 thought this would save time. 21 various of the plaintiffs have made either in their 21 So with that -- with your attorney's objection, and 22 answers to interrogatories, in their petition in this 22 the question posed to you I'll ask you the courtesy, would 23 lawsuit, possibly complaints they made to treating doctors 23 you prefer to go off the record and respond to these 24 or complaints they have made in their depositions. So 1 24 various symptoms or would you prefer to stay on the record 25 don't know that this is a list that has any meaning other 25 and do it? Page 82 Page 84 1 than than forty or fifty people, some have made these 1 MR. CARNEY: Why don't we go off the record? 2 various complaints. 2 MR. McCREA: All right, agreed. 3 Q (By Mr. McCrea) All right, sir. Dr. Kelly, 3 (Whereupon, a discussion was held off the record.) 4 1 hand you what the court reporter has marked as 4 Q (By Mr. McCrea) Dr. Kelly, we're back on the 5 Plaintiff's Exhibit 4 and on the top of it states, 5 record - 6 "Deposition of R. Emmet Kelly, M.D.," June 12th 1990. 6 MR. CARNEY: Let me make a statement first. 7 The question which 1 would like to address to this 7 1 objected before and 1 want to reiterate my objection to 8 document is incorporated at the top of the page. 8 this way of proceeding. 1 object to having this witness 9 The question states: "In your opinion, based on 9 fill out a - answer a hundred and fifty questions in this 10 medical probability is there no causal relationship, 10 kind of a format. Number one, if 1 could - Let me see 11 comma, a possible causal relationship, comma, a probable 11 the document. Dr. Kelly, if you - We're talking about 12 causal relationship or a proven causal relationship 12 Exhibit 4. 1 want to further object in addition to the 13 between exposure to Yusho PCB oil which was contaminated 13 objections 1 made before to the form of the question. 14 with furans and other chemicals and each of the 14 1 believe the standard used in Missouri is not 15 following --" and what 1 would like for you to do is to 15 based on medical probability. This is a compound 16 simply go through that list and check the appropriate 16 question. It relates to PCB exposure in Yusho, the 17 response. If you're unable to provide an opinion 1 think 17 Japanese PCB oil which was contaminated with furans and 18 we should also have that category and you can simply X out 18 which the experts have indicated that it was the furans, 19 the symptom, if you have no opinion. 19 the heavy concentration of furans in the PCB oil in Yusho 20 MR. CARNEY: Let me object to the form of the 20 that caused the problems in Yusho and also the victims in 21 question and I'm going to object to the format. You know, 21 Yusho ate the PCB's, used it in cooking. So I'm going to 22 you're giving the witness a questionnaire to answer in a 22 object to this format and instruct the witness not to 23 deposition, we've got six pages listing probably 23 participate in filling out this questionnaire, in this 24 twenty-five health problems or symptoms on each page, so 24 form anyway. 25 you're talking about maybe a hundred and fifty questions 25 MR. McCREA: Well, 1 can ask them one at a Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 81 - 84 LEXOLDMONOQ6827 Page 85 Page 87 1 time and that would take probably six times as long as it 1 difference between eating them and having your skin come 2 would to fill out the form and 1 think that we certainly 2 in contact with them. We can debate that; but 1 don't 3 are entitled to Dr. Kelly's opinion for discovery purposes 3 know that our opinions matter really, it's going to be the 4 in this case for the reason that there was heating of 4 experts in the case. 5 PCB's in the Bloomington, Westinghouse plant, there were 5 Further, Dr. Kelly has not examined any of these 6 explosions on a daily and weekly basis of capacitors in 6 plaintiffs and does not intend to examine the plaintiffs 7 the Bloomington, Westinghouse plant, there were fires in 7 to determine what problems they had and whether they're 8 the Muncie plant in which the Muncie Fire Department was 8 related to PCB's. We had a panel of doctors in various 9 called to extinguish the fires and there was heating and 9 specialties who have done that and 1 assume you're going 10 there was also incidents of fire in Cincinnati; all of 10 to take their depositions and ask those specific 11 which are calculated according to Dr. Kelly's testimony to 11 questions. 12 produce furans at a window of six hundred to nine hundred 12 Sol don't know that this is the right witness to 13 degrees Fahrenheit. 13 cover the health problems that the plaintiffs have. Dr. 14 1 don't think there's been any evidence that 14 Kelly has never met any of the plaintiffs and we don't 15 absorption into the body by ingestion produce a more toxic 15 intend to have him examine any of the plaintiffs. With 16 or less toxic systemic reaction than absorption by route 16 regard to your comments about the explosions daily in 17 of entry through the skin or breathing. Therefore 17 Bloomington, et cetera, I'm not going to debate what that 18 Counsel's suggestion that ingestion or as he states eating 18 is, except that 1 don't that think you've accurately 19 of PCB's somehow distinguishes the factual situation in 19 characterized the conditions in the three plants. 20 Yusho in 1968, and Taiwan in 179, 1 don't think is 20 At any rate, my instruction to Dr. Kelly is not to 21 meaningful. 21 respond to the questions in this format as you -- in terms 22 The idea of the form, Tom, is to save time. We sat 22 of filling out a questionnaire with these problems that 1 23 through forty some depositions in which you and your 23 have outlined in the questionnaire that you've given to 24 associates addressed all of these questions one at a time 24 him. 25 to each and every one of our plaintiffs and we never 25 Q (By Mr. McCrea) Dr. Kelly, in your opinion, Page 86 Page 88 1 objected. Now it's our turn to determine the medical 1 based on medical probability, is there no causal 2 significance of these questions from Dr. Kelly, and 1 can 2 relationship between exposure to the Yusho PCB oil which 3 ask them one at a time and you can object and thus 3 was contaminated with furans and other chemicals and 4 eliminate the fact that it is a compound question or we 4 asthma? 5 can save time or have Dr. Kelly answer this form. 5 MR. CARNEY: Let me object and we'll have the 6 1 think the question is fair, 1 think that medical 6 question read back. Let me object to the form of that 7 probability is in fact the standard, it's the standard in 7 question again for the same grounds 1 outlined before, and 8 Missouri, it is more likely than not in his opinion is it 8 in addition what you're asking the doctor to do in this 9 more likely than not, and 1 think that the question's 9 question and in Exhibit 4 is to try to recollect what was 10 fair. 10 in the literature, the Japanese literature about what 11 MR. CARNEY: Well, again, 1 don't think there 11 symptoms and problems the Yusho victims who had the 12 will be any saving of time. 1 think it will save time to 12 heavily furan contaminated PCB's and they ate them and to 13 proceed without going through this elaborate questionnaire 13 try to recollect what was in there. 14 which will not -- 1 think is objectionable, so will not 14 1 don't think there's any evidence that Dr. Kelly 15 move this case along at all or the testimony. 1 mean, you 15 has independent knowledge as to what these Japanese 16 have the option of asking questions and 1 just -- 1 have 16 victims' problems were other than through the literature. 17 the option of objecting where 1 think they're improper. 17 We have the literature, that would be the best evidence of 18 1 would point out that again you're talking 18 what's contained in there and Dr. Kelly can give you his 19 about -- you're trying to relate again the symptoms or the 19 recollection but 1 don't know that that helps any. 20 problems of the plaintiffs in this case with -- and none 20 He probably if you get into the detail particularly 21 of these plaintiffs as 1 understand it were exposed to 21 that you have in Exhibit 4 would have to look at the 22 Japanese PCB's with the heavy furans that caused the 22 literature to determine whether asthma or something else 23 problems in Japan and Taiwan. 23 was a symptom of the Japanese Yusho victims who ate PCB 24 None of these plaintiffs as 1 understand it ate the 24 oils with heavy contaminants of the furans. 25 PCB's like they did in Japan and 1 believe there is a 25 Q (By Mr. McCrea) Dr. Kelly, you may answer. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 85 - 88 LEXOLDMONOQ6828 Page 89 Page 91 1 A Well, first of all you have to tell me what 1 question and all of those other reasons stated in your 2 you mean by medical probability; one out of a million, one 2 objection. 3 out of fifty, one out of two. 3 Q (By Mr. McCrea) Dr. Kelly, then, skin 4 Q More likely than not. 4 irritation and again with the understanding that we are 5 A Fifty-one percent? 5 answering the question at the top of the page and if you 6 Q Let me explain this. That's a good question. 6 don't understand that please address any lack of 7 I'm asking you if in your opinion based on medical 7 understanding? 8 probability is there no causal relationship between 8 A On all these we are talking about the Yusho 9 exposure to the Yusho PCB oil which was contaminated with 9 PCB oil, which is a Japanese Kanechlor, which is 10 furans and other chemicals and asthma. In other words, 10 contaminated with the chlorinated dibenzofurans and 11 can you tell us based upon your opinion on a more likely 11 contaminated with chlorinated quaterphenyls, that's what 12 than not basis if there was no causal relationship? 12 we're talking about? 13 A Based on- 13 Q That's right. 14 MR. CARNEY: Same objection. 14 A In an undetermined amount, various amounts in 15 A Based on my knowledge of the Yusho 15 the rice oil which they put in the stuff they cooked? 16 literature, is that correct? 16 Q Exactly correct. 17 Q (By Mr. McCrea) Your knowledge of the Yusho 17 A Okay. Skin irritation, 1 don't know what 18 literature, your attendance at seminars, your information 18 they are talking about. Skin irritation,what's the 19 from medical personnel throughout the world, any available 19 irritation? Redness? What was it? 1 don't know. How 20 source to you. 20 long did it last? It may be -- 1 will also have to say 1 21 A Well, all right. We start then. Asthma, 1 21 would probably have to go over the six articles that were 22 would have to know, A, the person's smoking habits. 1 22 summarized by Selikoff in his journal on the Yusho 23 would have to know whether they had asthma previously, 23 incident before 1 could be sure about all these things. 24 whether the asthma was exaggerated before 1 could answer 24 Put down a don't know on skin irritation. 25 any of those questions. 25 Q All right, sir. Skin rashes? Page 90 Page 92 1 Q What do you mean exaggerated? 1 A Yes, that's proven; if by skin rashes you 2 A Well, was it hastened by -- Did they get, 2 mean chloracne and pigmentation. 3 have asthma before and after they ate the PC -- Yusho PCB 3 Q Hearing problems? 4 oil with the furans in, or did they get more asthma. I'd 4 A There again, 1 don't know if they had 5 have to go back to the literature and look. 5 infected chloracne inside their ear canals, 1 don't know 6 Q All right. Skin irritation? 6 that. 1 would say none on that, none to not proven -- 7 MR. CARNEY: Could 1 -- because 1 assume 7 none to 1 don't know; because 1 don't know the basis for 8 you're going to go down this list. 8 the hearing problem. 1 don't know what hearing problem it 9 MR. McCREA: Yes. 9 is. 1 would suggest we also have a column, not enough 10 MR. CARNEY: Could 1 have a standing 10 information. 11 objection to this line of questioning, to the question in 11 Q Okay. Let's add that. 12 terms of the use of the world medical probability and the 12 A Huh? 13 question being compound and to the question being based on 13 Q All right, we'll add that. 14 the medical literature or the literature - the Yusho or 14 A Okay. 15 Japanese literature, which 1 think is a matter of record 15 Q And do you want to add not enough information 16 and would be the best evidence of what the problems were 16 to the hearing problem? 17 associated with that, and the fact that Dr. Kelly does not 17 A Hearing problems, correct. 18 have firsthand knowledge of this; so that we're not adding 18 Q Headaches? 19 anything other than Dr. Kelly's recollection of the 19 A Again, how often? One headache, one four 20 literature, and 1 think the question's vague and ambiguous 20 times a day, one lasting for weeks? Not enough 21 as well. If 1 can have a standing objection, then I'll 21 information. 22 try and unless 1 hear another objection not to continue my 22 Q Kidney problems? 23 objections and we can move faster. 23 A Again, what kind of problems? Getting up at 24 MR. McCREA: 1 agree that you may have a 24 night, passing blood, kidney stones? Not enough 25 standing objection as to the fact that it is a compound 25 information. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 89 - 92 LEXOLDMONOQ6829 Page 93 Page 95 1 Q Swelling? 1 A Same. 2 A Where? If it's in the gums some of the 2 Q Acne? 3 children had swelling of their gums; but 1 don't know 3 A Proven. 4 anyplace else. 4 Q Skin cancer? 5 Q Would you say proven as to children with 5 A Not prove, none. 6 swelling in their gums? 6 Q Boils? 7 A Yes. 7 A If by that you mean an infected cyst, proven, 8 Q Hypertension? 8 but a boil, again as 1 said a boil is around a hair 9 A Well, 1 think hypertension and high blood 9 follicle, but - so technically if it's a - by that you 10 pressure are the same. 10 mean an infected cyst, yes. 11 Q All right. Can we treat them as one? 11 Q Okay. I'm going to put infected cyst. 12 A Yes. It was alleged but further work showed 12 A Right. 13 that there wasn't any connection; so not proven. 13 Q And that's proven? 14 Q Stomach problems? 14 A Yes. 15 A There again, 1 don't know. That runs all the 15 Q Flushing of skin? 16 way from indigestion to stomach cancer. So 1 don't know 16 A Not enough information. 17 really how 1 could answer a question like that. 17 Q Skin discoloration? 18 Q Not enough information? 18 A Yes. 19 A Not enough information. 19 Q Unusual growth or loss of hair? Now, 1 think 20 Q Sinus problems? 20 we should break that down into two categories, first, 21 A Not enough information. 1 don't know what 21 unusual growth of hair? 22 kind of problems they had. 22 A Possible. 23 Q So would that be don't know and not enough 23 Q And second, unusual loss of hair? 24 information? 24 A Not enough information. 25 A That's correct, not enough information. 25 Q Allergies? Page 94 Page 96 1 Q Ulcerated esophagus? 1 A 1 don't know what you mean by that. Does 2 A 1 recall that there was one instance of 2 that mean they are allergic to PCB's, allergic to milk, 3 ulcerated esophagus, but it certainly without seeing the 3 allergic to rice? Not enough information. 4 report again and something if anybody else, if any othe 4 Q Let's interpret that as being after the 5 cases had it outside of the one I'd have to say not 5 exposure they became allergic to various things, not 6 proven. 6 PCB's. In other words, they became more of an 7 Q Prostate problems? 7 allergic-type person. 8 A Not enough information. 8 MR. CARNEY: Are you saying that's what the 9 Q Cysts? 9 articles in Yusho say? 10 A Yes, proven. 10 MR. McCREA: No, I'm just asking him. 11 Q Pneumonia? 11 MR. CARNEY: Do the articles in Yusho say 12 A Not proven. 12 that? 13 Q So that would be -- It is your opinion that 13 MR. McCREA: I'm asking him for his opinion 14 there was none? 14 of the symptoms in Yusho, based on articles, based on 15 A That's right, not proven. 15 seminars, based on communications with personnel within 16 Q Not proven. Peeling of feet? 16 Monsanto. 17 A Well, let's put feet and hands together. 1 17 MR. CARNEY: Well, 1 don't know that Dr. 18 mean, 1 don't know what they mean by peeling of that. 18 Kelly has indicated he has any information about Yusho 19 Q Let's add to that peeling of skin on the 19 other than what's contained in the literature. So 1 don't 20 bottom of feet? 20 know how you could be asking him and he 1 think he has 21 A Not enough information. 1 don't know if they 21 indicated he wasn't there and didn't examine them 22 were checked for fungi or not, if they had athlete's foot. 22 personally. 23 Q So that would be not enough information? 23 So again 1 don't - 1 think this is a waste of time 24 A That's correct. 24 to have Dr. Kelly try to recollect what's in the 25 Q Peeling of hands, peeling of skin on hands? 25 literature and whether it's in there in a sufficient Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 93 - 96 LEXOLDMON006830 Page 97 Page 99 1 amount to -- or clear enough with control groups, et 1 A I'd have to review that. Not enough 2 cetera, to make any kind of a determination as to 2 information. 3 whether -- what the probability is. 3 Q Emphysema? 4 MR. McCREA: I agree that all those 4 A Same answer. 5 variables exist, but I'm asking him his opinion based on 5 Q Sores that won't easily heal? 6 medical probability if there is no causal relationship, a 6 A I don't know what they mean by that, whether 7 possible causal relationship, a probable causal 7 they mean the sores from the infected chloracne or sores 8 relationship, or a proven causal relationship between 8 they might have got scraping their knees on bamboo? I 9 exposure to the Yusho PCB oil which was contaminated with 9 don't know. 10 furans and other chemicals and allergies. 10 Q Let's make that unrelated to chloracne. 11 Q (By Mr. McCrea) And the way I'd like to 11 Let's make that sores that are unrelated to chloracne. 12 phrase that is more prone to allergies after the exposure. 12 A Not proven. 13 A I'd have to review the literature. 13 Q So that would be none? 14 Q Do you understand the question; more prone to 14 A That's correct. 15 allergies? 15 Q Bronchitis? 16 A Yes. 16 A More information needed. 17 Q Thank you. So we'd say that's not enough 17 Q Not enough information, correct? 18 information? 18 A That's right. 19 A That's correct. 19 Q Breathing problems? 20 Q Hives? 20 MR. CARNEY: Objection to what is meant by 21 A Same answer, hives are an allergic reaction. 21 breathing problems; and again asking this witness to try 22 Q Profuse sweating? 22 to recollect everything in the literature that he read 23 A Here again I don't know if you -- again, I 23 about the Japanese victims where they ate PCB's laced with 24 need more information. If you get a bunch of infected 24 heavy amounts of furans that caused the problem. 25 cysts, you've got a fever, you've get sweating. So more 25 A Not enough information on what the symptoms Page 98 1 information. 1 2 Q Not enough information on that? 2 3 A That's correct. 3 4 Q Problems with toenails? 4 5 A Possible. 5 6 MR. CARNEY: Let me object to that on the 6 7 problem with toenails. I don't know, are you talking 7 8 about ingrown toenails, are you talking about thick 8 9 toenails, are you talking about what--It seemed to me 9 10 there are several types of problems with toenails, so 10 11 that's a vague question. 11 12 Q (By Mr. McCrea) Let's break that down. 12 13 First, thickened toenails? 13 14 A There were some changes in the toenails. I 14 15 don't know if they were problems for the people or not; 15 16 but there were some changes in the toenails. 16 17 Q Okay. Let's make that changes in toenails 17 18 rather than problems with toenails? 18 19 A Yes. 19 20 Q And that would be possible? 20 21 A Yes. 21 22 Q And the next one, let's make thatchanges in 22 23 fingernails? 23 24 A Possible also. 24 25 Q Shortness of breath? 25 Page 100 are. Q (By Mr. McCrea) In other words, that question is -- You don't know what is meant by the worcjl problems? A Yes. Q The same for the next one? A Throat, right. Q That's it's not understood what is meant by problems? A Correct. Q So that would be need more information as to the symptoms? A Yes. Q Increase or decrease in sensitivity to certain kinds of smells? A I just have no comment to make on that at all. Q So your answer would be no comment? A No comment. Q Altered sense of taste? A The same answer to that one. Q And that would be no comment? A That's correct. Q Epilepsy? A Not proven. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 97-100 LEXOLDMONOQ6831 Page 101 Page 103 1 Q Shaking or tremors in hands -- Excuse me, 1 A Yes; but 1 also though can also state that 2 shaking or tremors of hands? 2 somebody in that Yusho experience may have had epilepsy. 3 A 1 need more information. 3 Q Right, and 1 understand that; but you're 4 MR. CARNEY: Let me object. As we're going 4 stating it was not caused by the oil? 5 through these questions are you implying when you get an 5 A That's correct. 1 don't believe epilepsy was 6 answer not proven that it means it's possible or probable 6 caused by the Japanese PCB oil with -- 7 or- 7 Q And you're stating it wasn't possible that it 8 MR. McCREA: No. When it says it's not 8 was caused by the Yusho oil? 9 proven it means it can happen. 9 MR. CARNEY: Well- 10 MR. CARNEY: Well, again - 10 MR. McCREA: Just a second please. 11 MR. McCREA: When he says none, when he says 11 Q (By Mr. McCrea) Because we've get a category 12 it's not proven that means it's his opinion that it didn't 12 for possibility. 13 happen. 13 MR. CARNEY: Well, that's the problem. 14 MR. CARNEY: It didn't happen in the 14 You're assuming by his answering one question in your 15 literature in Japan? 15 multiple choice group an answer on other questions which 16 MR. McCREA: No, Tom, it didn't happen in 16 you're not asking, number one. Number two, when you say 17 Yusho. He's not restricted to the-- 17 none, 1 don't know whether you're asking him was there any 18 MR. CARNEY: Well, why don't you ask him if 18 epilepsy shown by any of the people who ate contaminated 19 he has any firsthand knowledge outside of the literature 19 Japanese PCB's laced with furans, with heavier 20 that's involved. It seems to me you're -- you know, now 1 20 concentrations of furans than in the U.S. PCB's, again. 21 object to all these questions on the further ground that 1 21 So 1 haven't still understood what you mean by none. 22 think your understanding of the answers and my 22 MR. McCREA: Didn't happen. 23 understanding certainly are different as to what's meant 23 MR. CARNEY: That no one in those articles- 24 by none, as to what's meant by proven. 24 MR. McCREA: Established that symptom as 25 MR. McCREA: None means that he's stating 25 being in anyway related to the exposure to PCB's? Page 102 Page 104 1 based on his opinion, he's stating in his opinion based on 1 THE WITNESS: Well, that isn't what you were 2 medical probability that that symptom was not caused by 2 saying. 3 the exposure to the Yusho PCB oil. That's what that 3 MR. CARNEY: Yeah, now you've changed the 4 means, it was not caused. 4 question. 5 MR. CARNEY: Well, that wasn't my 5 THE WITNESS: Well, you've changed the legal 6 understanding of what was meant by none. Maybe you need 6 parameter. 7 to - the problem with your questions, Mr. McCrea, when 7 MR. McCREA: Well, let's read the question 8 you're assuming definitions and terms without defining 8 again. 9 those terms in the question we have then the potential of 9 THE WITNESS: Yes, but not what you just - 10 a communication gap between a term that's undefined that 10 MR. McCREA: It was my error. 11 may mean a different thing to a witness than it does to 11 THE WITNESS: Just so we know the ground 12 you, Mr. McCrea. 12 rules of each one. 13 So 1 think if you're not going to define your terms 13 MR. McCREA: Believe me, when 1 get back to 14 in the question 1 think you have another flaw here that -- 14 Indiana I'd like to think that we understand the ground 15 and the flaw is that you have got questions with undefined 15 rules; and it's important for me, it's important for you, 16 terms. 16 it's important for your attorney. 17 MR. McCREA: 1 think that's a valid 17 Q (By Mr. McCrea) Go back to Page 1, the 18 objection. In other words, 1 wouldn't want to finish this 18 question at the top, please. 19 deposition and come back and face the realty that we 19 A Okay. 20 weren't talking about the same thing. 20 Q Let's look at that again, Dr. Kelly. It says 21 Q (By Mr. McCrea) Let's go to where we are, 21 in your opinion, based on medical probability is there no 22 epilepsy, all right. 1 have indicated on my sheet that 22 causal relationship? That could mean none, in my 23 you're stating as a matter -- that you in your opinion are 23 thinking. A possible causal relationship? That would 24 stating as a matter of medical probability that that 24 mean possible. A probable causal relationship? That 25 symptom was not caused by the exposure on the Yusho oil? 25 would mean probable; or a proven causal relationship, that Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 101 - 104 LEXOLDMONOQ6832 Page 105 Page 107 1 would mean proven. In other words, we have four 1 between PCB's and held effects, are you? 2 categories, it didn't happen, there is no indication -- 2 MR. CARNEY: No. What 1 am saying is with 3 A No. That isn't the category, it didn't 3 regard to the Japanese PCB's that the Japanese cooked with 4 happen. 4 and ate and those particular furans when you had much 5 Q As a result of PCB ingestion? 5 more - those PCB's had a much higher concentration of 6 A All right, fine, but you've got to say -- it 6 furans. It's something entirely different than the PCB's 7 happened, it happened there. 7 in the United States with a much lower furans and so 1 8 Q As a result - Read the question. Between 8 think there's a difference and I'm not sure that Dr. Kelly 9 exposure to Yusho PCB oil. All right? I'm not saying 9 has any more knowledge other than the literature about the 10 that they couldn't have interviewed a person who had 10 Japanese situation. 11 epilepsy and they would report this person has epilepsy; 11 MR. McCREA: Are you stating that Dr. Kelly 12 but this person had epilepsy before the exposure; 12 is not qualified as a medical practitioner to offer his 13 therefore it is concluded that there is no causal 13 opinion on the cause and effect relationship between the 14 relationship. 14 exposure to Yusho PCB oil and health problems? Are you 15 Now, if they interviewed the person and they said 15 stating he's not qualified to give that? 16 this person had epilepsy, the individual is thirty-four 16 MR. CARNEY: No. Dr. Kelly can speak for 17 years old, the individual never had epilepsy up until that 17 himself as to what he feels he can offer his opinions on. 18 date, there was nothing to explain the epilepsy based upon 18 All I'm doing is making a comment that there's a 19 other potential causes, that's to me what we're talking 19 difference, number one, and 1 don't think he has indicated 20 about. 20 that he has knowledge outside of the literature with 21 MR. CARNEY: Let me just make the objection 21 regard to the Japanese. 22 that just because one person out of all of the people that 22 MR. McCREA: He started off with skin 23 were - they ate the Japanese contaminated PCB's with 23 irritation, don't know, hearing problems, don't know. He 24 furans happened to get epilepsy doesn't mean that there's 24 also has given the answer not enough information on 25 any proof that PCB's of the Japanese variety that have the 25 several occasions, totally legitimate answers. Page 106 Page 108 1 furans causes epilepsy. 1 MR. CARNEY: I'm not disputing that all. But 2 MR. McCREA: Well, the doctor can answer it 2 1 am disputing that your questions are vague and 1 3 that way. 3 certainly had a different understanding as to what you 4 MR. CARNEY: Well, but that's not the - the 4 meant by none. Now Dr. Kelly may. 1 don't know that you 5 problem is your question's confusing as to when you say 5 defined the terms. 6 none. Do you mean none of the victims had epilepsy, when 6 MR. McCREA: None means he has stated based 7 they got epilepsy, whether the writers concluded one way 7 on as a medical doctor, based on information he has read 8 or the other that the epilepsy had anything to do with the 8 and based on the information that has come to his 9 Japanese people eating these PCB's with the furans? 1 9 attention that that problem was not caused by the 10 don't know what you mean when you say none. I'm 10 ingestion of the PCB Yusho oil, period. 11 ambiguous - 1 think it's ambiguous as to what you mean. 11 MR. CARNEY: Well, you're not even saying 12 MR. McCREA: What 1 mean is, I'm asking the 12 whether there was any indication that there was any 13 doctor for his opinion, all right; do you understand that 13 epilepsy. 14 correct, Tom? 14 MR. McCREA: Well, I'm asking him the 15 MR. CARNEY: Well, and again - 15 question and if there's been no indication - 16 MR. McCREA: Just a second. I'm asking him 16 MR. CARNEY: Well, go ahead and ask your 17 for his opinion; is there any problem with that? 17 questions. 1 think so far they have been very vague and 1 18 MR. CARNEY: 1 do have a problem with that, 18 think there's been an -- at least in terms of what 1 19 because the doctor has indicated that his knowledge is 19 understood your questions to be 1 have not understood the 20 based on some literature. Now there are articles that 20 definitions that you just recently defined your questions 21 cover this and 1 don't know that he has any opinions 21 to be. 22 outside of that literature with regard to the Japanese 22 MR. McCREA: None means none, possible means 23 people ingesting PCB's with furans. 23 possible. 24 MR. McCREA: You're not stating that he's 24 MR. CARNEY: None what? None what? 25 not qualified to discuss the cause and effect relationship 25 MR. McCREA: No connection. No connection Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 105 - 108 LEXOLDMONOQ6833 Page 109 Page 111 1 whatsoever. 1 MR. CARNEY: Objection. Well, I'm objecting 2 MR. CARNEY: Do the articles say there is no 2 to the form of the question, it's compound, as well as the 3 connection? 3 other objections. 4 MR. McCREA: No, that it's his 4 A 1 would say 1 would have to examine the Yusho 5 interpretation of the articles, it's his interpretation of 5 literature before answering that question. 6 the data, it's his opinion as medical doctor that there is 6 Q (By Mr. McCrea) Change in speech pattern? 7 no causal relation. 7 MR. CARNEY: I'm going to object. 1 don't 8 MR. CARNEY: Well, that's not the questions 8 know what you mean by change in speech pattern. 9 that 1 understood that you're asking. 9 MR. McCREA: It means a speech pattern which 10 THE WITNESS: Well I'd like to have a couple 10 has somehow been altered or change. 1 don't know that 11 more definitions clarified. 11 that's - 12 MR. McCREA: Yes, sir. 12 MR. CARNEY: That doesn't help cure my 13 THE WITNESS: When 1 say don't know, 1 mean 13 objection. 14 by that 1 don't -- have not checked the literature 14 A Well, I'll give a double-barreled answer to 15 recently to find out whether this -- whether 1 can make 15 that. 16 an - give an opinion on it. 16 Q (By Mr. McCrea) All right, sir. 17 MR. McCREA: That's exactly the way 1 17 A 1 don't -- 1 need more information as to what 18 understand your answers. 18 the change in speech pattern is. Is he talking about 19 THE WITNESS: All right, and when 1 say not 19 stuttering, is he talking about repeating words? And I'll 20 enough information that means as we were talking about 20 have to say I'll have to examine the literature, the Yusho 21 kidney problems, what kind of kidney problems were you 21 literature to see whether there's any possible or probable 22 talking about? 22 connection. You're asking me really to give an 23 MR. McCREA: That's exactly the way 1 23 epidemiological answer to any of these questions. 24 understood your answer, Dr. Kelly. That's exactly right. 24 Q Just asking for your opinion. 25 In other words, there isn't -- That's exactly the way 1 25 A Well, yes; but as 1 say I'll have to Page 110 Page 112 1 understood it. 1 double-check it to see if there's one person there with a 2 MR. CARNEY: Well, what is your - 2 speech pattern or fifty, with a changed speech pattern. 3 MR. McCREA: Ask him. Ask him. You said 3 Q 1 understand. 4 what is your -- 4 A Numbness in hands. Let's first separate this 5 MR. CARNEY: Well, what I'd like you to do is 5 out, numbness in hands. The same situation; I'll have to 6 just have you ask questions that are not so vague and 6 have more information as to how, when the numbness came 7 ambiguous that it leaves listeners confused as to what 7 on, how long it lasted and in what percentage of the 8 you're asking. That's what I'd like; if you could do that 8 people it was reported. 9 I'd appreciate it. 9 Q So that would be not enough information? 10 MR. McCREA: I'd like to satisfy your 10 MR. CARNEY: Well, again, you know, you're 11 questions for clarity. 11 trying to put him into a -- 12 MR. CARNEY: And up to date on this whole 12 MR. McCREA: No. 13 series of questions on Exhibit 4 1 think this whole series 13 MR. CARNEY: You made four categories, he's 14 of questions is riddled with ambiguity to the point where 14 given you an answer. 15 it's unintelligible to me what you're asking. 15 MR. McCREA: Okay. 16 Q (By Mr. McCrea) It's not easy, is it, 16 MR. CARNEY: And somehow you're trying to put 17 Doctor? Dr. Kelly, we're down to shaking or tremors of 17 him into a category of yours and 1 think that's improper. 18 hands, the question posed to you by this document is in 18 THE WITNESS: Well, my category is 1 need 19 your opinion based on medical probability is there no 19 more information on it, and two, 1 would have to review 20 causal relationship, a possible causal relationship, a 20 the Yusho literature to come out with an opinion. 21 probable causal relationship or a proven causal 21 Q (By Mr. McCrea) Okay, sir. Numbness in 22 relationship between exposure to Yusho PCB oil, which was 22 feet? 23 contaminated with furans and other chemicals and shaking 23 A Same answer. 24 or tremors of hands? Your answer is there's not enough 24 Q Coordination problems? 25 information? 25 A Same answer. Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 109 - 112 LEXOLDMONOQ6834 Page 113 Page 115 1 Q Unusual gait or walking characteristics? 1 A You mean they can't move their arms and legs? 2 A Same answer. 2 Q Right. 3 Q Next page, stumbling? 3 A 1 don't believe there's any causal 4 A The next two are really the same answer to 4 relationship. 5 that, stumbling or problems with balance. 5 Q Problems with bones? 6 Q Yes, sir. 6 MR. CARNEY: I'm going to object. Problems 7 A Same answer. 7 with bones is very broad. 8 Q And that answer is need more information? 8 Q (By Mr. McCrea) How about changes in bone 9 You would have to read the literature? 9 structure? Let's change that to change in bone 10 MR. CARNEY: I'm not sure that is - 10 structure? 11 Q (By Mr. McCrea) What is the answer? 11 MR. CARNEY: 1 don't know what you mean by 12 A Well, the answer is 1 would have to know more 12 changes in bone structure. The question's vague as well 13 about the stumbling, whether it was once or whether it was 13 as all of the other objections 1 have in my standing 14 all the time, and 1 would have to read the literature to 14 objection. 15 see -- the Yusho literature to see what the significance 15 Q (By Mr. McCrea) Okay, changes in bone 16 of the individual case reports might have been. 16 structure. 17 Q All right, sir, and that's true for stumbling 17 A I'd have to see more information on that. 18 and problems with balance, is that correct? 18 Q That's the break time. Thank you, Doctor. 19 A That's correct. 19 (Whereupon, a lunch break was taken.) 20 Q Arthritis? 20 Q Dr. Kelly, we're back on the record. Again 21 A Not proven. 21 referring to Plaintiff's Exhibit 4, is that the number, 22 Q Joint pain? 22 sir, on the document? 23 A I'd have to have more information and check 23 A Yes, sir. 24 the occurrence in the literature, of the Yusho literature. 24 Q The next symptom listed as 1 recall when we 25 MR. CARNEY: 1 just want to object to that 25 took our break is swelling of joints. Do you have an Page 114 Page 116 1 one as well as a couple of the others. 1 don't know what 1 opinion based on a medical probability if there is no 2 you mean by joint pain. 2 causal relationship, a possible causal relationship, a 3 MR. McCREA: Stiffness or soreness of 3 probable causal relationship or a proven causal 4 muscles. 4 relationship between exposure to the Yusho PCB oil which 5 MR. CARNEY: Again, 1 would object on the 5 was contaminated with furans and other chemicals and that 6 ground that 1 don't know what you mean by that. 6 particular symptom? 7 A Again, 1 need more information on how stiff 7 A 1 would have to have more information about 8 they were, how long they were -- how sore they were, and 8 the symptoms, when the swelling came on, how long it 9 I'd have to see the incidents in these people, by 9 lasted and 1 would also have to review the -- re-review 10 reviewing the Yusho literature following the ingestion of 10 the Yusho literature to see what the incidence of this 11 this Japanese PCB material. 11 particular symptom was. 12 Q (By Mr. McCrea) All right, sir. Paralysis? 12 MR. CARNEY: Do 1 still have my standing 13 A 1 don't think it's been proven, no. 13 objection? 14 Q And that would be again for clarity of the 14 MR. McCREA: Yes. 15 record you are stating in your opinion based on medical 15 Q (By Mr. McCrea) The next symptom, 16 probability there is no causal relationship? 16 rheumatism? 17 A What kind of paralysis? What are we talking 17 A Same answer. 18 about? Paralysis of the little finger or a stroke or one 18 Q Muscle spasms? 19 whole extremity? 1 don't know what you mean. Dropped 19 A Same answer. 20 eyelid? 1 mean, there are all sorts of paralysis, so 1 20 Q Muscle weakness? 21 say, 1 don't know. 1 could change my answer to I'd like 21 A Same answer. 22 to - 1 need more information but 1 don't think there is 22 MR. CARNEY: I'm going to object on the 23 any causal relationship. 23 ground that 1 don't know what is meant; what type of 24 Q Let's say paralysis of the limbs, hands, 24 muscle weakness we're talking about and where? 25 legs? 25 MR. McCREA: Again you understand that we Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 113 - 116 LEXOLDMONOQ6835 Page 117 Page 119 1 took this from questions which you addressed to your 1 can answer the same thing for the next two, and 1 would 2 clients. 2 have to re-review the literature of Yusho to find out if 3 MR. CARNEY: Well, as 1 recall at least in 3 the Japanese PCB had caused that at Yusho. 4 looking at some of those depositions that the questions 4 Q Problems with eyes? 5 would be asked in a general way, "Have you had muscle 5 A Yes, there were problems with eyes, if by 6 weakness?" And if they indicated they did then we asked 6 that you mean the eyelids, that was proven. 7 where and when and what type and got details. So what 1 7 Q Problems with vision? 8 am saying is when you just ask these general questions 8 A Again, there 1 would have to know what the 9 without any definition to it 1 think it is overbroad. 9 problems with and 1 think we can include blurred vision 10 Q (By Mr. McCrea) Muscle twitching? 10 under that for the sake of hurrying this along. I'd have 11 A I'll have to give the same answer that 1 11 to know more about what problems we're talking about and 12 would have to know more about what is meant by that 12 whether or not -- I'd have to re-review the literature 13 particular symptom and then re-review the literature to 13 with Yusho with the Japanese PCB. 14 see if that was a prominent symptom in the Yusho cases. 14 Q Glaucoma? 15 Q Swelling of hands? 15 A None. 16 A Same answer. 16 Q Loss of eyesight? 17 Q Multiple sclerosis? 17 A None. 18 A None. 18 Q Seeing spots? 19 Q Parkinson's disease? 19 A 1 mean by loss of eyesight, you mean complete 20 A None. 20 blindness? Is that what you mean by complete loss, it's 21 Q Back problems? 21 gone? 22 A Again, 1 would have to ask what back problems 22 Q 1 don't know. 23 are we talking about, and 1 would have to review the 23 A Gee, it's hard for me to answer then. 24 literature, the Yusho literature to see if they had any 24 Q 1 would assume it means not blindness, or it 25 particular become problems and how often it occurred. But 25 would state blindness? Page 118 Page 120 1 my opinion would be it would be very improbable. 1 A Five percent loss? 2 Q Disk problems? 2 Q Yes. 3 A PCB exposure has not been causally related to 3 A Hundred percent loss? 4 any disk problems. 1 presume, the vertebral disks. 4 Q Yes. Diminished. 5 MR. CARNEY: Again, Doctor, we're talking 5 A Well, I'd have to agree with you, 1 don't 6 about the Japanese situation -- 6 know what it means. 7 THE WITNESS: The Japanese - 7 Q We just took these from their depositions. 8 MR. CARNEY: Not the American. 8 MR. CARNEY: I'm going to object to that 9 THE WITNESS: The Japanese Yusho PCB with 9 characterization and 1 will say if in fact you did and I'm 10 chlorinated benzofurans and chlorinated terphenyls. 10 not saying you did or didn't; I'm not -- you haven't shown 11 Q (By Mr. McCrea) The answer to that would be 11 me the depositions, but 1 will say this: That if that 12 none? 12 question was asked, it was undoubtedly asked because one 13 A That's correct. 13 or more of the plaintiffs indicated that they had a 14 Q Back pain? 14 problem, that problem associated with PCB's. One of the 15 MR. CARNEY: Objection to what you mean by 15 problems with your clients, Mr. McCrea, is they're 16 back pain. 16 claiming that every problem they've had from ingrown 17 A 1 would have to know more about the symptom 17 toenails to headaches and everything in between was caused 18 and re-review the literature to see whether that was a 18 by PCB's. 19 prominent factor. 19 So since that's the position that you have taken we 20 Q (By Mr. McCrea) Let's make that pain in the 20 have had to go into all of these problems. If you could 21 spine, in the back? 21 be a little more specific in your complaint as to what you 22 A Same answer to that. 22 think is caused by PCB's we could narrow the focus, which 23 Q Ringing in ears? 23 1 would welcome. If we could limit it to chloracne we'd 24 A Again I'd have to know when that occurred, 24 have a much simpler time and we wouldn't have to take all 25 how often it occurred, how long it occurred and 1 think 1 25 this time. Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 117-120 LEXOLDMONOQ6836 Page 121 Page 123 1 Q (By Mr. McCrea) Seeing spots? 1 MR. McCREA: No. 2 A Again, 1 am unable to evaluate that symptom 2 MR. CARNEY: So again 1 don't know what you 3 and 1 would have to re-review the Yusho literature to see 3 mean by amount and again 1 don't know what you mean by 4 if their eating their PCB's caused spots in front of their 4 saying compounds. Are we talking about the Japanese PCB's 5 eyes. 5 with the heavy amount of furans in them? 6 Q Doctor, it is your opinion that PCB's 6 MR. McCREA: We can talk about anything you 7 ingested into the body as opposed to PCB's which have a 7 want to talk about. We can talk about PCB's with furans, 8 route of entry through the skin, if the amount is the 8 with quaterphenyls, with biphenylenes, with dioxin. We 9 same, once into the body -- 9 can talk about the Yusho PCB's with the furans and the 10 MR. CARNEY: Let me -- Are you finished? 10 quaterphenyls. We can talk about you PCB's that you 11 MR. McCREA: No. 11 manufacture with furans in it, as tested by Monsanto. 12 MR. CARNEY: 1 want to object as soon as 12 It doesn't matter. What I'm stating is this: If 13 you're finished. 13 you ingest as opposed to having a route of entry through 14 MR. McCREA: Okay. 14 the skin and the same amount ends up absorbed into your 15 Q (By Mr. McCrea) Is it your opinion that 15 body, are those compounds more toxic, according to Dr. 16 there's a difference of the toxicity between PCB's which 16 Kelly, if they're ingested? 17 are ingested into the body and PCB's which are absorbed 17 MR. CARNEY: Let me object, because number 18 through the skin? 18 one, you said it doesn't matter whether it's the Japanese 19 MR. CARNEY: Let me object because 1 think 19 PCB's with the heavy amount of furans or the American 20 the question is vague and ambiguous. You haven't 20 PCB's, and 1 beg to differ with you. 1 think there's a 21 mentioned the amount. 21 significant difference between the two, the American PCB's 22 MR. McCREA: Same amount. 22 1 think the record is clear on -- at least from Dr. 23 MR. CARNEY: You haven't mentioned whether 23 Kelley's testimony, has a very infinitesimal amount of 24 you're talking about the Yusho Japanese PCB'sthat had the 24 furans compared to the Japanese and the furans are what 25 heavy amount of furans that caused problems in Japan that 25 caused the problems in Japan. Page 122 Page 124 1 we haven't seen in the PCB's in America, and so 1 think 1 So 1 think it's a problem when you're trying to 2 the question's vague. 2 equate and say the same thing. 1 think the record is 3 Q (By Mr. McCrea) Doctor, if the -- Are you 3 clear that it isn't. They are not the same; and you're 4 stating that if the same identical compound of PCB's is 4 mixing again apples and oranges when you're talking about 5 ingested that it would be more toxic than that same -- 5 the same amount of PCB's in the body. 6 MR. CARNEY: 1 just wanted to make sure 1 had 6 I'll agree with you if you have the same amount of 7 time to object. Sometimes the doctor is quicker than 1 am 7 PCB's in the body you have the same amount of PCB's, but 8 with his answer, and so as soon as you're finished let me 8 the question is how much PCB's does it take to have your 9 know and I'll object. 9 hand in it or to be exposed through skin contact versus 10 THE WITNESS: 1 will wait for you, but just 10 drinking and getting the PCB's in your body that way. 11 keep reminding me, that's a problem of mine 1 answer a 11 It's a totally different situation and you're trying to 12 little too fast. 12 say it's the same, so 1 think your question is vague and 13 Q (By Mr. McCrea) Doctor, are you stating that 13 ambiguous. 14 if the same compound of PCB's is ingested as opposed to 14 MR. McCREA: Thank you for the agreement. 15 entering the body through the skin that there's a 15 Q (By Mr. McCrea) Doctor, have you performed 16 difference in toxicity in ingested PCB's as opposed to 16 any studies as to what the rate of skin absorption is of 17 PCB's absorbed through the skin? 17 PCB's on the skin? 18 A This is -- 18 A You mean the rate? 19 MR. CARNEY: Object, let me object. When you 19 Q Right. 20 say you are saying the same; 1 don't know what you're 20 A How much goes in in one minute, half hour, 21 talking about in terms of amount. 21 two hours, twenty-four hours. 22 MR. McCREA: Same amount. 22 Q Exactly. 23 MR. CARNEY: Same objection. What, if you 23 A No, 1 have not. 24 drink PCB oil versus sticking your hand in the same PCB 24 Q Do you know of any study in which that has 25 oil, would that be the same amount. 25 been done? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 121-124 LEXOLDMONOQ6837 Page 125 Page 127 1 A There may have. There are minimum lethal 1 A Yes. 2 doses by skin absorption, there are minimum lethal doses 2 MR. McCREA: Correct. 3 by oral intake. But to answer your question there may 3 Q (By Mr. McCrea) Or Taiwan, can we include 4 have been those studies. 1 don't know. 1 don't recall. 4 Taiwan in this? 5 Q But if the PCB's enter the body they don't 5 MR. CARNEY: Well, 1 think your question up 6 have less toxicity if they are ingested as opposed to 6 to now has just been Yusho? 7 going through the skin? 1 mean, there's nothing about the 7 THE WITNESS: Yusho. 8 skin absorption that makes them less toxic, or is there? 8 MR. McCREA: 1 agree. 9 A There could be, because remember if you 9 A Let's stick to this. Why don't you come up 10 swallow it, it's absorbed, it goes into the liver and also 10 with another questionnaire on Taiwan? 11 if you swallow, when these people swallowed the Japanese 11 Q (By Mr. McCrea) No, Doctor. Do you know of 12 PCB if one of them had an ulcerated esophagus, which is 12 any substantial differences between Yusho and Taiwan? 13 the gullet, which is the tube leading from the mouth on 13 A There may be. I'll have to check. 14 the stomach, he had that. 14 Q Do you know of any? 15 Whether that was caused by swallowing that PCB or 15 MR. CARNEY: Let me object here. You're 16 not 1 don't know. But certainly it could not be caused by 16 asking the witness to speculate about what's in literally 17 absorption through the skin, you would not get a ulcerated 17 hundreds of pages of writing in these two instances to 18 esophagus from the skin absorption. If it was absorbed 18 determine the differences. 19 through the skin it goes to the lungs first rather than 19 MR. McCREA: The question did not ask Dr. 20 the liver. Whether or not there's excretion from the 20 Kelly to speculate. The question is do you know of any 21 lungs or not is a question. 21 substantial differences between Yusho poisoning and 22 Q Which body organs produce enzymes? 22 poisoning in Taiwan? 23 A The liver. 23 A Well, what do you mean by substantial. 24 Q Any others? 24 Q (By Mr. McCrea) Something that you would 25 A I'm sure there are. As 1 said earlier I'm no 25 consider medically significant or scientifically Page 126 Page 128 1 enzymologist; but I'm sure there are other enzymes outside 1 significant? 2 of the liver. 2 A 1 would have to re-review both articles to 3 Q Are PCB's an enzyme inducer? 3 answer that. 4 A Yes. 4 Q What 1 mean by medically significant are the 5 Q And you can't tell us here today if there are 5 symptoms produced, scientifically significant are the dose 6 other organs which produce enzymes other than the liver? 6 response, the amount ingested, make up of the chemical? 7 A No, sir. 7 MR. CARNEY: I'm gong to object to the form 8 Q Problems with reading? 8 of the question. It's compound; you're asking at least 9 MR. CARNEY: Again, 1 have to know what you 9 three or four different questions in that question. 1 10 mean by problems with reading. The question's vague. 10 don't know which one you want him to answer. 11 Q (By Mr. McCrea) An inability to read and 11 Q (By Mr. McCrea) Let's break it down one at a 12 retain the information. In other words, the inability to 12 time. Do you know of any differences in the symptoms 13 look at a document, to read it and to retain the 13 between the Japanese symptoms and the Taiwanese victims'! 14 information? 14 A 1 would have to re-review the articles on 15 A And to remember it? 15 both. 16 Q Yes, sir. 16 Q Do you know of any significant differences 17 MR. CARNEY: Well, it's a compound question. 17 between the amount of PCB's with contaminants ingested in 18 You're asking about inability to read and then inability 18 Japan compared to Taiwan? 19 to retain what you have read, and so 1 object to the form. 19 MR. CARNEY: Talking about the amounts? 20 Q (By Mr. McCrea) Inability to retain what 20 MR. McCREA: Right. 21 you've read. 21 A 1 cannot be certain. My impression is the 22 A 1 would have to know more about the symptom 22 people in Yusho have had more. I'm not certain of that; 1 23 and re-review the literature. 23 would have to look again at the literature. 24 MR. CARNEY: Again for the record, we're 24 Q (By Mr. McCrea) Do you know of any 25 talking about the Japanese Yusho literature? 25 substantial differences in the chemicals in the PCB's in Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 125 - 128 LEXOLDMONOQ6838 Page 129 Page 131 1 Japan as opposed to Taiwan? 1 Q The eye itself, excluding the eyelid? 2 MR. CARNEY: Objection to the form. Contains 2 A 1 do not know of any. 3 an undefined term what you mean by substantial. 3 Q Inflamed or puffy eyes? 4 A Again 1 would have to look at the amounts 4 A Well, we skipped a few. 5 that were listed in both literatures to say whether or not 5 Q We did? 6 there were substantial differences. 6 A Irritated eyes. 7 Q (By Mr. McCrea) Dr. Kelly, the next one is 7 Q 1 thought we went over that. You said that 8 problems with lights, and make that oncoming headlights at 8 was proven? 9 night when driving? 9 A Well, we can take it inflamed or puffy eyes, 10 MR. CARNEY: Well, 1 don't know what you mean 10 unusual redness of the eyes, plus a discharge in the eyes. 11 by problems with oncoming lights. If you're in the path 11 Yes, those have been reported at Yusho. 12 of the lights 1 think you'd have the problem with it but 1 12 Q Heart problems? 13 don't know if that's what you mean. 13 A Again, 1 would have to know what the meaning 14 Q (By Mr. McCrea) Eye sensitivity with lights 14 of that symptom is or that condition is and re-review the 15 when driving at night? 15 literature of the Japanese poisoning with Kanechlor, the 16 A 1 don't believe the people in Yusho were 16 Japanese PCB. 17 driving automobiles; so 1 don't recall that symptom ever 17 Q Heart attack? 18 coming up. 18 A 1 certainly do not believe that has been 19 Q It probably didn't. Cataracts? 19 proven. 20 A No. 20 MR. CARNEY: Again we're talking about Japan, 21 MR. CARNEY: Let me, just for clarification, 21 Yusho? 22 are we back to just Yusho again? 22 A Yusho, Japan, Yusho. 23 MR. McCREA: Correct. 23 Q (By Mr. McCrea) Stroke? 24 Q (By Mr. McCrea) Cataracts? 24 A 1 do not believe there has been a causal 25 A No. 25 relationship between strokes and the ingestion of Japanese Page 130 Page 132 1 Q What are cataracts? 1 PCB oil with the furan contaminations. 2 A Opacity of the lens and of the eye. 2 Q Was your answer 1 do not believe there has 3 Q And what is the chemical composition? 3 been a definite causal relationship between stroke and the 4 A Calcium, presumably, and some colloid 4 injection of Yusho oil? 5 formation. 5 A That's correct. 6 Q Seeing spots in sunlight? 6 Q Is it your opinion that there is no 7 A Again, 1 would have to know more about the 7 relationship? 8 symptoms and re-review the literature on Yusho poisoning 8 A 1 would have to re-review the literature to 9 with the Japanese PCB's. 9 find out. 10 Q Irritated eyes? 10 Q Tightness in chest? 11 A Yes. 11 A Again, I'd have to know more about the 12 Q Eye disease? 12 symptom. 13 A Here again, you mean by an eye disease, 13 Q Peripheral neuropathy as it effects the 14 eyelid disease or eye disease? 1 don't know what you mean 14 nerves crossing the chest? 15 by that sentence. 1 mean, if 1 say yes, cataracts is an 15 A Well, that's not tightness of the chest. 16 eye disease, but 1 don't believe cataracts -- 16 That's pain along the ribs. 17 Q Are there any particular diseases of the 17 Q All right. My question is peripheral 18 eye -- 18 neuropathy? 19 A The eye itself? Not -- 19 A We're forgetting about tightness of the chest 20 Q -- that you feel are possibly, probably or 20 now, are we? 21 proven to have resulted from the ingestion of the Yusho 21 Q Yes, sir; and now as a subcategory, 22 PCB oil? 22 peripheral neuropathy as it effects the nerve endings in 23 A If you mean the globe of the eye itself or do 23 the chest area? 24 you mean the eyelids? Do you include that in your 24 MR. CARNEY: I'm going to object to the 25 blanket -- 25 definition of what peripheral neuropathy is. At least 1 Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 129 - 132 LEXOLDMONOQ6839 Page 133 Page 135 1 think you've mischaracterized it and it's my understanding 1 Q 1 understand that. 2 that it's in the ends of the nerves on the limbs, but 2 A Well, 1 just want to let the jury know that 3 maybe I'm wrong, I'm not a -- 3 there's a big difference between benzene and chlorinated 4 THE WITNESS: 1 wouldn't hear what you said. 4 biphenyl. 5 MR. CARNEY: The ends of the nerves at the 5 Q All right. Are there transformer fluids that 6 ends of the extremities; but 1 may be wrong and I'm not a 6 contain trichlorobenzene? 7 doctor, so I'll - but 1 think you mischaracterized what a 7 A Yes. 8 peripheral neuropathy is. 8 Q If a worker is exposed to a transformer which 9 MR. McCREA: I'm not a doctor, 1 could very 9 contains trichlorobenzene and polychlorinated biphenyls, 10 well have. 10 putting aside Yusho, would leukemia be a possible 11 Q (By Mr. McCrea) But Doctor, could you have 11 consequence of exposure? 12 peripheral neuropathy in the nerve endings in the chest 12 MR. CARNEY: Objection, 1 don't think you've 13 muscles? 13 given enough facts. The amount, the length of time, the 14 A Yes. 14 dose. 15 Q The question is now peripheral neuropathy, is 15 Q (By Mr. McCrea) Doctor, let me uncomplicate 16 the nerve endings in the chest? 16 the question, if 1 can. Is there a difference between 17 A 1 would have to review the article to find 17 toxicity of trichlorobenzene and benzene? 18 out whether there was any relationship. 18 A Oh, yes. 19 Q Tightness in heart area or pain? 19 Q All right, sir. In your opinion is 20 MR. CARNEY: Objection to the form, as well 20 trichlorobenzene associated with leukemia? 21 as 1 have my continuing standing objection, right Mr. 21 A No. 22 McCrea? 22 Q Anemia? Now we're back to Yusho. 23 MR. McCREA: Yes, we stipulate. 23 A 1 do not know if anemia has been associated 24 A 1 would have to review the symptoms of what 24 with the Yusho occurrence. 1 could have to know more 25 they are talking about to get more information about the 25 about the type of anemia, the extent of the anemia, what Page 134 Page 136 1 symptoms of what they mean by tightness in the heart area 1 happened to the blood counts and 1 would have to review 2 or pain 1 presume where he has pain in the heart area. 2 the literature to know if that was a significant finding. 3 Again 1 would need more information on that and 1 would 3 Q Gout? 4 then have to re-review the literature on the Yusho 4 A No, never heard of gout being associated with 5 incident using the Japanese contaminated PCB's. 5 anybody's PCB much less Yusho's. 6 Q (By Mr. McCrea) Unusual rapid or irregular 6 Q What causes gout? 7 heart beat? 7 A It's disturbance of the purine metabolism 8 MR. CARNEY: Objection to the form. It's 8 which causes a precipitation of uric acid in the joint 9 also vague; 1 don't know what you mean by unusual. 9 cavities. 10 A Again, 1 would have to know what caused 10 Q Liver problems? 11 irregular heart beat. 1 would have to know what caused 11 MR. CARNEY: I'm gong to object to that as 12 the rapidity of the heart. I'd have to know how long it 12 being undefined, what you mean by liver problems. 13 was. I'd have to know whether its was once in a while or 13 MR. McCREA: Swelling of the liver. 14 intermittent, so the answer is 1 do not have enough facts 14 MR. CARNEY: I'm not sure that these -- there 15 to give an adequate opinion on that. 15 was any measuring of the liver. 1 don't know that people 16 Q Diabetes? 16 know if their liver is swollen or not. 17 A No. 17 You can answer. 18 Q High blood sugar? 18 A It is possible. 19 A No. 19 MR. CARNEY: He's asking whether there's 20 Q Leukemia? 20 anything in the literature in Yusho? 21 A No. 21 A 1 think there was to the best of my 22 Q You acknowledge, Doctor, that benzene can 22 recollection, but we have defined liver problems to the 23 cause leukemia, correct? 23 swelling of the liver. 24 A Oh, yes, certainly. We aren't talking about 24 Q (By Mr. McCrea) Hepatitis? 25 benzene. 25 A Yes. If the liver is swollen it could be due Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 133 - 136 LEXOLDMON006840 Page 137 Page 139 1 to hepatitis. 1 A Any place? 2 Q Porphyria cutanea tarda? 2 Q Yes, sir. 3 A Do we get that one? 1 don't see it in here. 3 MR. CARNEY: You're again talking about the 4 Q As a liver problem? 4 Japanese ingestion of the Japanese PCB's with the furans? 5 A What? 5 MR. McCREA: Correct. 6 Q As a liver problem? 6 A 1 do not know if it has been statistically 7 A 1 thought you were asking for that. 1 done 7 proven that cancer has resulted from the oral intake of 8 know if that was reported in the Japanese Yusho incident 8 the Japanese PCB's. 9 are or not. 9 Q (By Mr. McCrea) Food allergies? 10 Q Elevated porphyrins as part of liver 10 MR. CARNEY: Objection to the form, it's 11 problems? 11 vague. 12 A If they had liver problems they may have had 12 A 1 don't know enough about the delineation of 13 elevated porphyrins. 1 do not know if they were, at the 13 that symptom and 1 would have to re-review the literature 14 present time, 1 do not recollect whether or not they 14 to answer the question. 15 tested for them or whether they were elevated to a 15 Q Motion sickness? 16 statistical positivity. 16 A Same answer. 17 Q Primary liver tumor? 17 Q Stomach problems? 18 A Is that also under problems? 18 MR. CARNEY: Objection to the form. It's 19 Q Yes, sir. 19 vague. 20 A 1 don't recall if the Japanese PCB's with the 20 A 1 presume by this you mean anything from a 21 chlorinated benzofurans, et cetera, caused primary liver 21 person having to take the Japanese equivalent of Maalox to 22 tumors. 1 am of the opinion it did not. 22 a cancer of the stomach? 23 Q Fatty degeneration? 23 Q (By Mr. McCrea) Yes, sir. 24 A That's possible. 24 A Well, 1 would have to know more about the 25 Q Induction of enzymes? 25 stomach problems and to re-review the literature. Page 138 Page 140 1 A That's possible. There's inductions of 1 Q Ulceration of the esophagus? 2 enzymes isn't all bad all the time. 2 A It's been stated that that occurred. At 3 Q Cirrhosis, which is the next one on the 3 least one case there, in Yusho. 4 chart? 4 Q 1 think that's a repeat of one on the first 5 A 1 do not know whether or not cirrhosis has 5 page. No -- well, yes, it is, and you've answered that. 6 been reported in the Yusho literature. 6 Can you tell us what you recall about that one case, 7 Q Hepatitis we have discussed. Tumors, and by 7 Doctor? 8 this, doctor, non-cancerous tumors? 8 A Not except that someone had -- I'd have to 9 A We mentioned that, too. You said hepatoma 9 re-review the literature, but one person had an ulcerated 10 above. Didn't you mention hepatoma under liver problems? 10 esophagus. 11 1 thought that was one of your subsidiary questions. 11 Q Problems with intestines? 12 Q Primary liver tumor? 12 A I'm going to give you the same answer on the 13 A That's a hepatoma. 13 next one, two, three, four, five, six, seven; it will save 14 Q You answered that? 14 some time. The answer is - 15 A And 1 said 1 did not know that that was 15 Q All right. 16 reported. 16 A The answer is 1 would have to know more about 17 Q And now the question is, excuse me, is 17 the delineation of these symptoms, the time factor 18 unrelated to the liver. This is to the body, tumors in 18 involved and 1 would have to know -- I'd have to re-review 19 the body, non-cancerous tumors? 19 the literature to see if in fact these occurred. 20 A 1 do not recall any such association in a 20 Q As a subcategory, Dr. Kelly, on problems with 21 causal manner. 21 intestines, fatty tumors of the intestines? 22 Q What about non-cancerous tumors of the liver? 22 A I'd have to know more about where this fatty 23 A Again, 1 do not know if any of them had 23 tumor was. 1 mean, the intestine is coated with fat. 24 occurred. I'd have to re-review the literature. 24 There are pieces of fat hanging down all along the 25 Q Cancer? 25 intestines and 1 don't know if that's considered a fatty Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 137-140 LEXOLDMONOQ6841 Page 141 Page 143 1 tumor or not, if it's a piece of fat. The omentum which 1 by proven fact; has it been proved in a law - proved up 2 hangs over almost the complete intestine is almost 2 in a lawsuit. 1 don't know that this witness is an expert 3 completely composed of fat, so -- 3 as to what's been proven in the courts of the United 4 Q Doctor, 1 think these next two have been 4 States or not. 5 previously answered -- No, they haven't. Unusual weight 5 Q (By Mr. McCrea) Has it been proven in 6 gain? 6 medical science that enzyme induction can enhance the 7 MR. CARNEY: 1 don't - 1 guess I'll object. 7 effects of enzyme induction? 8 1 don't know what you mean by unusual weight gain versus 8 MR. CARNEY: I'm going to object on the same 9 usual, usual. 1 don't know if there's a difference in 9 grounds, the use of the word proven. 1 don't know what 10 your mind or not. 10 you mean by that, it's an undefined term. 11 A Well, Mr. McCrea, I'd have to find out what 11 A If one takes antipyrine, which is a drug that 12 they mean by unusual weight gain and what they mean by 12 has been used previously in the reduction of fever and you 13 unusual weight loss. I'd have to look up in these 13 have enzyme induction you will speed up the elimination of 14 articles and see if some people gained weight and some 14 that antipyrine from the body. Whether that's good or bad 15 people lost weight as a result of the exposure to the 15 for the body 1 don't know, but it does effect that. 16 Japanese eating the Japanese PCB's. So 1 would have to 16 Q (By Mr. McCrea) How long has that been 17 see, there'd have to be a preponderance of one; 1 don't 17 known, Doctor? 18 believe you'd have it both ways. Some people would gain 18 A Ten years, give or take a few years. 19 weight and some people would lose weight as a result of 19 Q Do you recall where that was reported? 20 PCB's, so 1 can't answer that. 20 A Oh, it's reported often. 21 Q (By Mr. McCrea) Allergies to medications? 21 Q Are there any other medications? 22 MR. CARNEY: Objection. 1 don't know what 22 A There may well be. 23 you mean, what type of medications? Question's vague. 23 Q Which can be likewise affected in addition to 24 A 1 don't think that was talked about in there. 24 antipyrine? 25 1 would have to review the literature to give you an 25 A Antipyrine? Page 142 Page 144 1 answer to that. 1 Q Yes, sir. 2 Q (By Mr. McCrea) Can enzyme induction alter 2 MR. CARNEY: Objection to the form. It's 3 the effectiveness of medications? 3 vague. 4 A Well, sometimes it can enhance it. Sometimes 4 A There may have been. 1 mean, there may be. 5 it can all hurt. 5 1 just don't recall at the present time. 6 Q So it can both make it more effective and 6 Q (By Mr. McCrea) Now Doctor, loss of appetite 7 make it less effective? 7 and we're talking about you she PCB ingestion? 8 A It's a possibility. 8 A Well, I'll have to answer that the same way 1 9 Q Do you know how enzymes do that? 9 answered unusual weight gain, unusual weight loss. 10 A No, 1 don't. 10 There's loss of appetite and there's too much appetite. 1 11 Q Is that proven, that enzyme induction can 11 would have to know more about the symptoms and I'd have to 12 enhance and decrease the effectiveness of medications? 12 know more about - I'd have to re-review the literature to 13 MR. CARNEY: I'm going to object to the word 13 answer that question. 14 proven. That's an undefined term as to what you mean by 14 Q In 1933 the individual working for Swann 15 proven. 1 assume you're talking about the literature 15 Chemical complained of loss of appetite, is that not 16 here-- 16 correct? 17 MR. McCREA: No. 17 A My 1 see Exhibit 1 again? 18 MR. CARNEY: And 1 don't think the literature 18 Q Page 1024 under Report of Case, the first 19 uses the word proven. 19 full paragraph, second to the last line? 20 MR. McCREA: No. I'm not talking about the 20 A Yes, he complained of loss of appetite, yes, 21 Yusho literature. I'm asking Dr. Kelly if it's a proven 21 sir. 22 fact that enzyme induction can both improve or lessen the 22 Q Uncontrolled urge to eat, Yusho ingestion? 23 effectiveness of medication? 23 A 1 don't know. I'd have to re-review the 24 MR. CARNEY: Well, I'm going to object to the 24 literature on that. 25 use of the word proven fact. 1 don't know what you mean 25 Q Colitis? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 141-144 L EXO L D M O N006842 Page 145 Page 147 1 A Again, that is a catch-all phrase for 1 often they occurred, what their relationship was to the 2 everything from amoebic colitis to ulcerative colitis to 2 exposure, what was the extent of the exposure and then I'd 3 to spastic colitis to allergic colitis. I'd have to know 3 have to re-review the literature to find out whether it 4 more about the type of colitis. I'd have to review the 4 was a prominent findings at Yusho. 5 literature to be able to tell it. 5 Q Amnesia? 6 Q Kidney pain? 6 A That's pretty close to memory loss, 1 think 1 7 A Same answer to that, kidney pain could be 7 would include that under it. 8 kidney stone, could be pain in the region, could be pain 8 Q Were the - Were the Yusho -- Strike the 9 on emptying the bladder. 9 question. Disorientation? 10 Q Bladder problems? 10 A That I'd have to have more information what 11 A Again, I'd have to know more about what they 11 were they disoriented around time, place, people or what. 12 are talking about. 1 think we could take all three of 12 Q Speech disorder? 13 these, bladder problems, colon problems, spleen problems. 13 A Didn't we have that before? 14 I'd have to know what the problems with. 1 don't think 14 Q Very similar; speech problems 1 think it was. 15 the spleen has very many problems unless it gets too big; 15 A My answer would be the same for speech 16 but I'd have to know more about that and re-review the 16 disorder as 1 was for speech problems. 17 literature on the Yusho incident using the Japanese PCB's. 17 Q Okay. Lethargy? 18 Q Rectal bleeding? 18 A 1 would have to know more about it and 19 A There again I'd have to know whether that's 19 re-review the literature to see if it was prominent in the 20 associated with constipation, hemorrhoids, whether they do 20 Yusho episode. 21 a lot of stooping or lifting and 1 don't know without 21 Q Trouble sleeping? 22 re-reviewing the literature whether that was prominent at 22 A 1 think we can combine that with insomnia. 23 Yusho. 23 That's pretty close. 24 Q Painful urination? 24 Q All right, sir? 25 A 1 do not know whether that was a prominent 25 A 1 would have to say 1 would have to know more Page 146 Page 148 1 symptom or not. 1 about it. 1 would have to know more about the symptoms 2 Q Unusual color in urine? 2 and would have to re-review the literature to see if it 3 A 1 haven't the slightest idea what color they 3 was a positive finding. 4 are talking about. Purple, green, red? 1 don't know. 4 Q Trouble concentrating? 5 Q Fair enough. Blood in urine? 5 A Same answer. 6 A 1 think that has not been proven at all in 6 Q Nervousness? 7 the Yusho people. 7 A I'd have to know what they mean by 8 Q Would your answer be none? 8 nervousness. Does that mean a person is jittery, does 9 A 1 know of none, yes. 9 that mean a person has tremors, does that mean a person is 10 Q Frequent urination? 10 afraid to go out in the street, get hit by a ricksha. 11 A The same answer. 1 would have to say that 1 11 Q First jittery, under the category of 12 would have to know more about this, what other causes 12 nervousness, at Yusho. 13 there may have been for the urination and 1 would have to 13 A Beg your pardon? 1 can't hear you. 14 re-review the literature to see if that was a prominent 14 Q First, the subsymptom of jittery, under 15 finding in the Yusho episode after the ingestion of 15 nervousness? 16 Japanese PCB. 16 A 1 do not know if that was a prominent symptom 17 Q Dizziness? 17 at Yusho, so 1 cannot answer. 18 A 1 think we can take the next four. 18 Q Tremors? 19 Q All right, sir. 19 MR. CARNEY: 1 think that's vague. What kind 20 A Because the answer is just going to be the 20 of tremors. 21 same as 1 have just given you, periods of disorientation, 21 A 1 think 1 answered that before someplace. 22 blacking out, fainting and memory loss. 22 No, maybe 1 didn't; but 1 would have to know more about 23 Q All right, sir. What is your answer? 23 when the tremors came on, how long they came on, what 24 A That 1 would have to know more about a 24 muscles were involved and I'd have to re-review the 25 description of these symptoms, when they occurred, how 25 literature to see if it was a significant finding. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 145 - 148 LEXOLDMONOQ6843 Page 149 Page 151 1 MR. CARNEY: And I'll object on the ground 1 ingestion of the Japanese PCB's. 2 that further you haven't indicated what type of tremor. 2 Q Vertigo? 3 Q (By Mr. McCrea) Tremors of the hand? 3 A There again, people get very confused. Does 4 MR. CARNEY: Well, 1 would object. There are 4 vertigo mean you stand up and the room goes around, or do 5 various types of tremors of the hand and I'd have to know 5 you get lightheaded. So there's got to be a very definite 6 which ones you mean. Otherwise the question's overbroad 6 definition of what they mean by vertigo and what 1 mean by 7 and vague. 7 vertigo and what medical -- what is accepted as vertigo. 8 Q (By Mr. McCrea) Tremors of the hand? 8 But to answer your question 1 would have to know more 9 MR. CARNEY: Talking about a postural tremor 9 about that symptom and 1 would have to re-review the 10 or -- 10 literature. 11 A My answer is the same, I'd have to know more 11 Q Dr. Kelly, Exhibit 4, we have gone over every 12 about it. Is it a tremor when you reach for a glass of 12 symptom on that exhibit? 13 water. Is it shaking all the time like Parkinson's? 1 13 A Yes, sir. 14 don't know, I'd have to know more about it. 14 Q As medical director of -- 15 Q (By Mr. McCrea) Scared? 15 A May 1 correct you a minute? Because 1 said 16 MR. CARNEY: Objection. 16 yes and 1 want to correct that answer. 17 A Scared? 17 Q Yes, sir. 18 Q (By Mr. McCrea) Yeah. You said scared, 18 A You have gone over signs and symptoms. Skin 19 scared of being hit by a ricksha? 19 cancer is not a symptom, it's a sign. It's not a symptom. 20 A 1 do not believe that that was a prominent 20 A boil is not a symptom. High blood pressure is not a 21 symptom that 1 can recall. 21 symptom. 22 Q Anxiety? 22 Q All right. We have gone over all of the 23 A 1 do not believe that was prominent symptom 23 signs, which is something you can see, and all of the 24 in Yusho. 1 would have to re-review the literature to 24 symptoms, which is something that's reported? 25 find out. 25 A That's correct. Page 150 Page 152 1 Q Irritability? 1 Q On Plaintiff's Exhibit 4? 2 A Same answer. 2 A Yes, sir. 3 Q What is your answer on irritability, that you 3 Q My question to you, as medical director of 4 need more information? 4 Monsanto Company did you ever ask a single worker if he 5 A 1 would need more information to know what 5 had any of these specific problems? In other words, when 6 they would be irritated about, how often it would be 6 you sat down and did your medical evaluation of the 7 irritated, how long the periods of irritability would last 7 workers did you ask the worker a question such as: "Mr. 8 and then 1 would have to review the Yusho literature to 8 Worker, I'm going to ask you a series of questions. Have 9 find out if the ingestion of the Japanese PCB caused 9 you had any of the following: Asthma, skin irritation, 10 people to be more irritable than they were previously. 10 skin rashes?" Did you ever go through a list of questions 11 Q Injury to the immune system? 11 with the workers? 12 A That's possible. 12 MR. CARNEY: Let me object. 1 think you 13 Q Predisposed to cancer? 13 covered this in questions about what he did in his 14 A No, 1 do not believe so. 14 physical examinations at length last week when you were 15 Q Depression? 15 examining the witness, and I'm going to object to that. 1 16 A 1 would have to review the literature to find 16 think the question is vague and ambiguous. Are you asking 17 out if that was a prominent symptom at Yusho and 1 do not 17 did he ask specifically and each one of those or are you 18 recall it being. 18 asking on one? 1 don't know what the question is, very 19 Q Change in personality? 19 vague. 20 A Same answer. 20 Q (By Mr. McCrea) And 1 appreciate the 21 Q Unexplained crying? 21 objection and it's important for us to understand this 22 A Same answer. 22 answer. I'm not talking about these symptoms, Dr. Kelly, 23 Q Claustrophobia? 23 what 1 am asking you is did you ever specifically ask a 24 A 1 never heard of that before. It may have 24 worker about specific signs or symptoms? 25 been, but 1 never heard of it, at Yusho after the 25 A Yes. Not these, now, you're not talking Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 149 - 152 L EXO L D M O N006844 Page 153 Page 155 1 about those you've said. 1 A K what? 2 Q No? 2 Q K-87. 3 A Yes, 1 asked them if they had gained weight. 3 A Eighty-six documents in there? 4 1 asked them if they lost weight. 1 mean, when you take a 4 Q Right. Your attorneys asked you about those 5 physical examination you don't have a list to sit down and 5 documents. 6 say okay, "Do you have asthma? "No" do you have skin 6 MR. CARNEY: Do you have a second set that 7 irritation? "No." You go by symptoms. You start with 7 you could give to Dr. Kelly? 8 the head, you ask them about whether they had headaches, 8 (Whereupon, a discussion was held off the record.) 9 you develop when they got the headaches, if they had 9 Q (By Mr. McCrea) Doctor, I'm going to ask you 10 headaches. If they had eye problems you ask them about 10 a few questions about certain documents in this stack and 11 that. You ask them when they have had their glasses 11 1 will refer to them by the exhibit number in the lower 12 checked. You ask them -- you cover all these specific 12 right corner? 13 things but not specifically each one. 13 A Yes, sir. 14 Q Did you ever have a list of questions like 14 Q The first one- 15 when you go in for a driver's license, you know how they 15 MR. CARNEY: Why don't we just, so that we 16 sit there and they ask you if you had any of these. Did 16 can have -- if you just mention the exhibit number 1 could 17 you ever have a list of questions in which you checked off 17 have my associate hand the doctor that. That way he wont 18 the signs or symptoms on a written list? 18 have to juggle. 1 think our-just for the record our 19 A We have had some -- We would have asked 19 exhibits went from K-1 through K-108. 20 people about conditions that occurred infrequently in the 20 MR. McCREA: K-108, all right. 21 industrial environments. We would ask people if they had 21 Q (By Mr. McCrea) Dr. Kelly, can you review 22 back pain. We would ask people who were exposed -- 22 please Exhibit K-3? 23 Q Now we're talking about PCB workers? 23 A Yes, sir, 1 have it. 24 A No. You didn't mention PCB. You said did 1 24 Q Would you turn to page 298? 25 ever talk to any Monsanto workers. 25 A Yes, sir. Page 154 Page 156 1 Q Right. Let's restrict it to PCB workers. 1 Q First of all, the title of this document is 2 Did you ever have a specific list of signs and symptoms 2 what? 3 which you asked workers exposed to PCB's in Anniston or 3 A Symposium on Certain Chlorinated 4 Sauget, Illinois? 4 Hydrocarbons. 5 A Well, now remember, the people that 1 5 Q Does that include PCB's? 6 examined were the -- What was it, seventeen or 6 A It includes what he called PCB's. He did not 7 twenty-seven people at East St. Louis. 1 did not examine 7 test PCB's as he stated in his 1939 article, he tested 8 the workers at Anniston, the PCB workers. 1 talked to the 8 P -- polychlorinated diphenyl benzene, which is not a PCB. 9 workers at Anniston, when 1 asked them how they were 9 But he referred to that particular compound as a PCB 10 getting along, asked them if they had any problems, asked 10 through all these articles in 1937. 11 them when they went back to the doctor, asked them when 11 Q All right. On page 298 can you see in the 12 they went to St. Louis. The people in St. Louis where 1 12 second column the heading discussion? 13 gave the thorough examination in that one group that were 13 A Yes, sir. 14 still working there, 1 covered these things under the 14 Q The first sentence under that heading states 15 systems. 15 "These experiments leave no doubt as to the possibility of 16 Q Did you specifically ask them about specific 16 systemic effects from the chlorinated naphthalenes and 17 signs or symptoms on a written list? 17 chlorinated diphenyl." Is chlorinated diphenyl 18 MR. CARNEY: 1 think we're out of time. So 18 synonomous, the same as PCB? 19 we don't cut off the answer, save it for the break. 19 A Yes, it is. But remember now, he was not 20 MR. McCREA: Break. 20 using chlorinated diphenyl. This is an error that he 21 (Whereupon, a short break was taken.) 21 accepted and changed when he found out he was not testing 22 Q Dr. Kelly, your attorneys asked you about 22 chlorinated diphenyl so that whenever he refers to that in 23 documents which were identified as K-1 through K- 87? 23 these 1937 articles when he refers to chlorinated 24 A Me? 24 diphenyl, he is in error, he is referring to chlorinated 25 Q K-87. 25 diphenyl benzene and for accuracy we will have to get his Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 153 - 156 LEXOLDMONOQ6845 Page 157 Page 159 1 1939 article in which he reverses his nomenclature. 1 it was Swann workers and they had it -- but 1 wasn't going 2 Q Would you define systemic effects as written 2 to say when we bought a company that had it, 1 used the 3 in this sentence? 3 word we for simplicity. 4 A Yes, affects the body as a whole. 4 Q Was the statement accurate when you state, 5 Q Would you turn to page 307? 5 "We were never about to attribute as to cause whether it 6 A Yes, sir. 6 was impurity in the benzene we were using or to the 7 Q When did you determine the cause of the 7 chlorinated diphenyl." Was that statement accurate on 8 chloracne in the workers at Swann Chemical? 8 that date? 9 A When 1 read the literature on it. When 1 9 A 1 think so, yes. 10 read Jones'article. 10 Q And chlorinated diphenyl is synonomous with 11 Q Would you read the paragraph in the left 11 PCB? 12 column? Dr. R. Emmet Kelly, is that you? 12 A Yes. 13 A That is 1. The name is spelled wrong but 13 Q And when you said chlorinated diphenyl on 14 that is all right. One T in Emmet. 14 this date that was one and the same as PCB? 15 Q And would you read those two paragraphs into 15 A Well, not exactly, you are oversimplifying 16 the records? 16 it; because we didn't know -- at least 1 didn't know at 17 A "1 can't contribute anything to the 17 that time whether the impurity in the benzene caused a 18 laboratory studies; but there has been quite a little 18 chlorinated diphenyl, chlorinated styrene, chlorinated 19 human experimentation in the last several years, 19 diphenyl benzene or God knows what. So 1 didn't know 20 especially in our plant where we have been manufacturing 20 that -- so 1 believe this was an ad-lib statement 1 made 21 this chlorinated diphenyl. It has been our observation 21 there that probably in hindsight 1 might have been more 22 that although on one occasion we did have a more or less 22 precise. 23 extensive series of skin eruptions which we were never 23 Q And that statement was made after you read 24 able to attribute as to the cause whether it was an 24 the Jones and Alden article? 25 impurity in the benzene we were using or the chlorinated 25 A That's right, but after all Jones and Alden Page 158 Page 160 1 diphenyl, we have never had any systemic reactions at all 1 did not precisely know either. They said in our opinion 2 in our men." 2 this is probably -- in our opinion this is probably 3 Q Let's stop right there. Did you make that 3 chlorinated styrene or something else. 4 statement on the date of June 30, 1970? 4 Q Was that statement made after you talked to 5 A Yes, 1 did. 5 the workers at the Anniston, Alabama plant? 6 Q And before June 30, 1970 had you read the 6 A 1 can't answer that. 7 article by Jones and Alden? 7 Q You go down in that paragraph at the end and 8 A 1 very probably did. 8 you say also from chlorinated diphenyl alone there have 9 Q And on June 30, 1937 was that statement which 9 been no cases of systemic poisoning reported? 10 you gave accurate in which you state: "It has been our 10 A That's correct. 11 observation that although on one occasion we did have a 11 Q What do you consider a report of systemic 12 more or less extensive series of skin eruptions which we 12 poisoning? 13 were never able to attribute as to cause, whether it was 13 A A government report, a case report, a series 14 impurity in the benzene we were using or to the 14 of papers on -- a paper that, such as Jones and Alden had. 15 chlorinated diphenyl, we have never had any systemic 15 Q Do you consider a worker's report of 16 reactions at all in our men." Was that statement accurate 16 lassitude, loss of appetite and loss of libido a report? 17 on that date? 17 A To whom? 18 A Well, it depends what is meant by we, what 1 18 Q To you? 19 meant by we at that time. 1 don't believe that at that 19 A Well, 1 never got those. 20 particular time in June the 30th, 1937 1 was going to go 20 Q To Jones. You consider that a report? 21 into the structure, the subsidiary structures of Swann and 21 MR. CARNEY: Well, I'm going to object to the 22 when we bought Swann and 1 believe 1 used we in the 22 form of the question. 1 don't know what you mean by 23 all-inclusive sense meaning Monsanto and Swann. 23 report. 24 Q Was that statement accurate on that date? 24 MR. McCREA: I'm asking him. 25 A With that provision it's accurate, yes. That 25 MR. CARNEY: Well, 1 done know what you mean Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 157-160 L EXO L D M O N006846 Page 161 Page 163 1 in your question. The question is vague. 1 chlorinated diphenyl by itself or chlorinated diphenyl by 2 Q (By Mr. McCrea) Dr. Kelly, you state here: 2 itself by -- in conjunction with naphthalene reported as 3 "We have examined them very closely both from what 3 causing any systemic illness. 4 laboratory tests we thought might help us and from the 4 Q Dr. Kelly, isn't it a fact that Dr. Jones and 5 clinical viewpoint." When you say them, are you referring 5 Dr. Alden received a report from a worker that he suffered 6 to the sixteen men who experienced chloracne? 6 lassitude, loss of appetite and loss of libido, isn't that 7 A That's correct. 7 that a fact? 8 Q And did you inquire of those men as to their 8 A Yes, but the fact -- that's one fact. The 9 reports of lassitude, loss of appetite and loss of libido? 9 other fact is he didn't know what those people were 10 A No, sir; but in this report 1 am talking 10 exposed to. He said, "We've got an impurity in here, we 11 about medical reports in the medical literature, not a 11 don't know what it is. We think it may be chlorinated 12 report of an individual to a doctor, that is not what's 12 styrene." 13 usually considered to be a report. 13 Q But in your paragraph above you state that 14 Q And when you say also from chlorinated 14 you don't know if it was the impurity or the PCB? 15 diphenyl alone there have been no cases of systemic 15 A Well, that's correct, 1 didn't know it then. 16 poisoning reported. Were there cases of systemic 16 But then 1 knew afterwards when we had forty years of 17 poisoning reported from chlorinated diphenyl and other 17 experience just having chlorinated -- PCB's without 18 chemicals? 18 impurities and no ill effect then 1 was certainly 19 A They were reported, yes. They were reported 19 positive. 1 didn't know in 1937 but 1 certainly knew in 20 by Drinker but then Drinker changed his mind. 1 mean, he 20 1939 all the way up to 1974. 21 not only changed his mind, he accepted the fact that he 21 Q Do you have any statistics available for your 22 was in error. So 1 didn't know that at that time that he 22 workers in PCB's to show the percentage of workers on an 23 was going to then double-check the chlorinated diphenyl. 23 epidemiological basis who had lassitude, loss of appetite 24 He had reported it. 24 or loss of libido? 25 He had said that these people had systemic effects 25 A No, sir. Page 162 Page 164 1 from certain chlorinated hydrocarbons and he called it 1 MR. CARNEY: I'm going to object to the 2 chlorinated diphenyl when in truth it should have been 2 question before the doctor answers and that's the question 3 chlorinated diphenyl benzene. 3 is vague and ambiguous. 1 don't know what you mean by 4 So 1 went on his statement in 1937 and then when 1 4 several terms including the epidemiological basis. The 5 found out that -- Well, there never were any cases where 5 question's compound. So 1 object to the form and 1 object 6 chlorinated diphenyl was used by itself that had systemic 6 on the grounds that it's vague and ambiguous. 7 poisonings. Tremors were cases of chlorinated diphenyl 7 MR. McCREA: Could the reporter reread the 8 benzene, which was included as ten percent and chlorinated 8 question. 9 naphthalene that caused systemic poisoning. 9 (Reporter read back from the record as directed: 10 Q What were the effects resulting from the 10 "Q. Do you have any statistics available 11 systemic poisoning of that combination of chemicals and 11 for your workers in PCB's to show the percentage of 12 when were they reported? 12 workers on an epidemiological basis who had lassitude, 13 A Well, they were reported obviously sometime 13 loss of appetite or lass of libido?") 14 before 1937 but 1 don't know when. 14 A That's the question? 15 Q What were the effects of the systemic 15 Q (By Mr. McCrea) Yes, sir. 16 poisoning? 16 A No, 1 did not do any epidemiological studies 17 A Both. 17 as to the presence or absence of lethargy, loss of libido 18 Q Of those combinations of chemicals? 18 or loss of appetite. 19 A There were cases that had chlorinated 19 Q Do you have any numbers for those symptoms? 20 naphthalene alone that developed jaundice and death and 20 MR. CARNEY: I'm going to object. 1 don't 21 chloracne, not exactly in that order. There were cases of 21 know what you mean by do you have any numbers. 22 chlorinated naphthalene that had what was called ten 22 Q (By Mr. McCrea) The number of people who 23 percent chlorinated diphenyl in them which were also 23 experienced those symptoms who worked in PCB's? 24 reported in the literature as causing chloracne, jaundice 24 A We have no record of any of them ever telling 25 and death. But there were no cases reported that had 25 their examining physician that, so the number would be Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 161-164 LEXOLDMONOQ6847 Page 165 Page 167 1 zero. 1 Q And you didn't ask? 2 Q And no record of ever asking those questions? 2 A No, 1 didn't ask them. 3 MR. CARNEY: Well, let me object to the - 3 Q Doctor, 1 want to ask you about Renate 4 You mean a written record as opposed to a memory of 4 Kimbrough. Would you turn to Exhibit K-7? Who is Renate 5 asking? If we get hung up on this whether the doctor had 5 Kimbrough? 6 a written checklist, was asking certain questions or 6 A Renate Kimbrough is a scientist who works for 7 whether he had people fill out a form. 7 the United States government, she is probably the premier 8 MR. McCREA: 1 think we established he had 8 worker in PCB's. She's been a laboratory individual, she 9 no written checklist. 1 think we have established that he 9 is a pathologist, she's a -- has done a great deal of work 10 did an examination, a standard examination, a standard 10 in epidemiology, and in 1987 she was for the Center of 11 physical examination, but there was no checklist. 11 Environmental Health at the Centers for Disease Control of 12 Q (By Mr. McCrea) My question is: Do you have 12 the Public Health Service. 13 any numbers in writing of workers who experienced those 13 Q When she did her experiments on rats and 14 three symptoms, lassitude, loss of appetite, also of 14 determined that PCB's caused liver cancer -- 15 libido? 15 A APCB, 1260. 16 A We have no numbers in writing of oral that 16 Q Did she get that from Monsanto? 17 these people did have these symptoms. If you ask that, we 17 A Yes. 18 have no written record that these workers reported those 18 Q What was the chemical again? 19 three symptoms. 19 A Aroclor 1260, which is a PCB chlorinated to 20 Q 1 think we have been over that enough, 20 sixty percent. 21 Doctor. 21 Q When she did her studies on rats with the PCB 22 A Good. 22 obtained from Monsanto and determined that it caused 23 Q What information did you gain after June 30, 23 cancer in the livers of the rats did you hold her in 24 1937 with respect to the chloracne of the sixteen 24 regard as the premier scientist? 25 individuals who worked for Swann? 25 A Yes, 1 did. Page 166 Page 168 1 A You mean from then on out? 1 Q And did you -- 2 Q Right. 2 A May 1 explain? 3 A Fifteen, twenty years? 3 Q Certainly. 4 Q Right. 4 A Yes, but there's often differences of opinion 5 A Well, 1 obtained the information that the 5 between scientists. 6 chloracne had receded markedly in the years that 1 went to 6 Q Did you find any flaws with her work in which 7 Anniston before the war. 7 she took your PCB's from your factory and used them in an 8 Q Any other information which you obtained 8 experiment and produced cancer in rats? 9 after June 30, 1937? 9 A Yes. There were flaws because there's an 10 MR. CARNEY: Other than what he's already 10 interpretation by her pathologists. Her pathologists had 11 testified to about saying that they felt fine? Do you 11 a different viewpoint than the two independent 12 want him to repeat what he already said? 12 pathologists we picked. 13 Q (By Mr. McCrea) 1 think that -- Was that 13 Q Was she wrong? 14 before or after June 1937 when you interviewed the workers 14 A In our opinion she was, in hers she wasn't. 15 in the plants? 15 Q Did you tell her she was wrong? 16 MR. CARNEY: Again 1 want to object to you're 16 A No. We didn't have our scientists, 17 characterizing as interviewing. 1 think he's already 17 independent pathologists look at her slides by the time, 18 described what he did. 18 at that particular time. 19 A 1 saw them on almost yearly intervals. 19 Q Was she untrustworthy? 20 Q (By Mr. McCrea) Did you obtain any 20 A No, she wasn't untrustworthy. What leads you 21 information after June 30th of '37? 21 to believe that? 22 A No positive information that they had any 22 Q 1 just want to know your feelings. 23 complaints of libido, loss of appetite or loss of -- 23 A My feeling is she's entirely trustworthy. 24 Q They didn't come out and tell you that? 24 She's an excellent scientist, but scientists have 25 A No. They said they felt fine. 25 different opinions. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 165 - 168 LEXOLDMONOQ6848 Page 169 Page 171 1 Q And was the protocol which she did using your i Q What did they tell you? 2 PCB which produced cancer done in an appropriate protocol 2 A They said Richter and Parvis Pour didn't find 3 under excellent scientific standards? 3 as many cancers as Dr. Kimbrough's pathologists. 4 A 1 didn't investigate the protocol. 1 took 4 Q When did they tell you that? 5 her word for it, and 1 accepted the fact that she's a good 5 A Sometime after 1974, between 1974 and 1980. 6 scientist and what she did is good work. Now if her other 6 1 don't know the first time 1 heard it. 7 pathologists came out with a point of view that was 7 Q Did Dr. Parvis, is that his name? 8 different for other pathologists, you've got to weigh both 8 A That's right. 9 of them. 9 Q Publish a study on his review of the cancer 10 Q Who were the pathologists who disagreed with 10 slides? 11 her pathologic interpretation that there was cancer? 11 A 1 don't know if he -- 1 have never seen it in 12 A Dr. Parvis, P-a-r-v-i-s, P-o-u-r, of the 12 a medical journal, whether he published the report and 13 Eppeley, E-p-p-e-l-e-y, Institute of Cancer of the 13 sent it to Dr. Kimbrough and sent it to Monsanto. 1 would 14 University of Nebraska Medical School -- 14 imagine he did but 1 don't recall seeing it. 15 Q Did he -- 15 Q Did anyone other than Dr. Parvis and Dr. 16 A And wait, that's one and Dr. Gordon Richter, 16 Richter by your testimony disagree with the results of the 17 R-i-c-h-t-e-r. 1 think it's Gordon Richter, but it's 17 Kimbrough studies using your PCB's? 18 Richter of the Department of Pathology of Northwestern 18 MR. CARNEY: Again you're talking about the 19 University Medical School. 19 rat studies? 20 Q Are you knowledgeable about the trip Dr. 20 MR. McCREA: Correct. 21 Gordon Richter took with the Monsanto personnel to 21 A 1 don't know. 1 mean, 1 don't know anyone 22 Washington D.C. in which he reviewed the slides of the 22 else. 1 don't know; they may have, they may not. 1 don't 23 cancer in the rats and told your people that was cancer? 23 know of any else. 1 know these two had different points 24 A No, sir, I'm not. When was that? 24 of view than Dr. Kimbrough's pathologists. 25 Q I'll be glad to furnish you a transcript of 25 Q (By Mr. McCrea) But you've never seen Page 170 Page 172 1 his testimony? 1 anything in writing from either one of them? 2 A Fine. Would you give me the date? 2 A Well, 1 may very well have. 1 don't recall 3 Q 1 certainly will. 3 it. 4 A Fine. But I'm not familiar with that, 1 4 Q Was that significant finding by Dr. Kimbrough 5 don't recall it at present. 5 with regard to the manufacture and use of PCB's as far as 6 Q Where is Dr. Richter now? 6 Monsanto was concerned? 7 A 1 don't know. 7 MR. CARNEY: Objection to the form of the 8 Q But your testimony is that this individual 8 question. It contained undefined terms. 9 looked at the slides and said there was no cancer? 9 A Would you repeat the question, please? 10 A No. He did not. He didn't say there was no 10 MR. McCREA: Could you reread the question, 11 cancer. He said there were many fewer than the 186 or 11 please? 12 something that Dr. Kimbrough's pathologist said. 12 (Reporter read back from the record as directed.) 13 Q Were you employed at Monsanto when Monsanto 13 A Well, it certainly was a matter of concern. 14 flew him out there to look at the slides? 14 We had a two year study and that gave negative results and 15 A 1 don't know when they flew him out. 15 we had -- here was this other study that gave positive 16 Q Did you ever talk to Mr. Lavinskas about 16 results. So it was a matter of concern, yes. 17 that? 17 Q (By Mr. McCrea) Your two year study was done 18 A No, 1 didn't. 18 by who? 19 Q So you're not familiar, Dr. Kelly, with his 19 A By. Dr. Calandra, I.B.T. 20 review of those slides? 20 Q Was he indicted for fraudulently preparing 21 A 1 don't recall I've seen his review, no. 21 reports and giving them to the United States government? 22 I've been told about his review. 22 MR. CARNEY: With regard to the PCB study? 23 Q Where did -- Who told you about his review? 23 MR. McCREA: No, with regard to the work he 24 A Somebody at Monsanto. 1 don't recall the 24 did at I.B.T. 25 name. 25 A 1 don't know if Dr. Calandra was indicted or Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 169 - 172 LEXOLDMONOQ6849 Page 173 Page 175 1 not. 1 A 1 don't follow you all at all. What 2 Q (By Mr. McCrea) What does it mean to be 2 information did 1 want when 1 started the studies at 3 indicted? 3 I.B.T.? 1 wanted information on the toxicity of some 4 MR. CARNEY: I'm going to object, this is not 4 products. 1 don't know which the products they were. 5 a lawyer talking but a doctor and you're asking him about 5 They may have been plasticizers. 1 don't know which our 6 a technical legal term. 1 don't know that he's claiming 6 first product was. We sent them products from the 7 any expertise in the area of criminal law. 7 agriculture department. We sent them products from the 8 Q (By Mr. McCrea) Was your toxicologist, Paul 8 organic division. We sent them products from the 9 Wright, a participant in the I.B.T. studies, which is 9 inorganic division. 1 don't know which the first ones we 10 Industrial Bio-Test, Northbrook, Illinois? 10 used. 11 MR. CARNEY: I'm going to object to the form 11 Q Who made the decision to do toxicological 12 of the question, mischaracterizes the record. 12 studies on PCB's at I.B.T. in 1970? 13 A He was not a Monsanto employee when he was 13 A Idid. 14 working at I.B.T. 14 Q What factors did you take into account in 15 Q (By Mr. McCrea) Did Monsanto pay his 15 making that decision to do toxicological studies of PCB's 16 attorney's fees of about a million, $400,000? 16 at I.B.T. in 1970? 17 A 1 don't know that of myself. That would be 17 A Several factors, one, the reputation of the 18 hearsay. 1 just don't know. 18 laboratory, which was of the highest, it's list of 19 Q Have you talked to Paul Wright about the work 19 customers, Dow, DuPont, U.S. Army, Food and Drug 20 he did at Industrial Bio-Test and the laboratory studies 20 Department, many pharmaceutical companies. Two, our 21 which he carried out? 21 experience with the individuals and the laboratory on our 22 MR. CARNEY: Are you talking about after he 22 own products that were done prior to using -- prior to 23 finished his work at I.B.T.? 23 I.B.T. using the PCB's. 24 MR. McCREA: At any time. 24 This was not the first one we had. We had -- 1 25 A Well, I'm sure 1 had, when he came back it's 25 can't tell you when they started but we had at least five Page 174 Page 176 1 natural to say, "Paul, what have you been doing up there, 1 to eight years of experience with them. Our results were 2 what have you been working on?" But 1 don't have the 2 excellent, our results were accepted as gospel by the 3 details of it. 1 never received in the slightest inkling 3 government. 4 that everything was not in accord with good scientific 4 Q Why did you feel it was necessary in 1970 for 5 methods and principles. 5 Monsanto to obtain this toxicological data from I.B.T. on 6 Q (By Mr. McCrea) Did you review the I.B.T. 6 PCB's? 7 studies in coming to that conclusion? 7 A Well, you mean from I.B.T. or from anybody? 8 A Well, 1 read them. 1 had George Lavinskas 8 Q From I.B.T.? 9 who was our pathologist review them. We also had the Food 9 A Because 1 thought they were the best 10 and Drug people review them, we sent the results to the 10 laboratory to do it. 11 Food and Drug Administration, they reviewed them. 11 Q But why did you need to do the test? 12 Q And you determined that everything which was 12 A Well, that was what 1 was asking, the reason 13 done at I.B.T. according to the information presented to 13 for the tests or the reason we had done at I.B.T. 14 you was done in a scientifically appropriate manner? 14 Q 1 think you established the reason for using 15 MR. CARNEY: Well, I'm going to object. 1 15 I.B.T., it was reputation, their experience and excellent 16 think you're mischaracterizing by he determined. Are you 16 results. 17 saying did he make an independent investigation or did 17 A And also their list of satisfied customers. 18 he - 1 don't know what you mean by he determined. 18 Q Why did you feel it was necessary to run 19 Q (By Mr. McCrea) Let's tell the jury a little 19 these tests? 20 bit about I.B.T. Why did Monsanto make the decision to do 20 A Because there was no long term studies on 21 tests at I.B.T.? 21 I.B.T. -- 1 mean, on PCB's that it was showing up in the 22 A Because we had used I.B.T. almost since they 22 environment. It was showing up in some of the fish, sport 23 started the laboratory. 23 fish and 1 don't know when it started showing up in milk, 24 Q What information did you not have that you 24 but there was no long term studies on it so we wanted to 25 wanted when you started these studies at I.B.T.? 25 find out what the long term effects were. Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 173 - 176 LEXOLDMON006850 Page 177 Page 179 1 Q And by long term effects, is that the same as 1 Q (By Mr. McCrea) Do you understand that he 2 chronic effects? 2 takes the Fifth Amendment when asked about I.B.T., against 3 A Yes. 3 self-incrimination? 4 Q You as medical directorat Monsanto Company 4 A 1 understand he has, yes. 5 made the decision to use I.B.T. because there were no long 5 Q Can you explain to the jury the reasons he 6 term or chronic studies showing the effects of PCB? 6 elected to depart from Monsanto and go to I.B.T.? 7 A That's correct. 7 MR. CARNEY: Well, I'm going to object 8 Q Who made the decision to send Paul Wright 8 because 1 think this would call for speculation. There's 9 from Monsanto to I.B.T.? 9 been no foundation that he even had much contact with Mr. 10 A 1 don't think there ever was a decision made 10 Wright. 11 to send Paul Wright from Monsanto to I.B.T. 1 believe 11 Q (By Mr. McCrea) Did Paul Wright tell you why 12 Paul Wright was either recruited by I.B.T. or applied 12 he wanted to leave Monsanto and go to I.B.T.? 13 himself. He was not sent by anybody as far as 1 know. 13 A Not that 1 can recollect. 14 Q Who made the decision to employ Paul Wright 14 Q Did you discuss with him his departure from 15 at Monsanto after he finished his work at I.B.T.? 15 Monsanto and new job at I.B.T.? 16 A That was a decision made by the medical 16 A 1 really don't know. 1 mean, he may have 17 department. 1 was the ultimate individual to say go or no 17 said what kind of an outfit is I.B.T., do you know Joe 18 go. It was on the recommendation of our people who knew 18 Calandra, or something like that; but remember he was not 19 Paul Wright from his days in the agricultural division. 1 19 working for me. He was in an entirely different building. 20 didn't know him but other people did know him. 20 He was in a different division, he was in the agricultural 21 1 don't know if -- 1 think George Lavinskas was 21 division. He was in the research department over there. 22 with us then, and certainly Elmer Wheeler knew him from 22 1 doubt if 1 say Paul twice in my life before he went up 23 going up to Calandra to I.B.T. during those two years Paul 23 to I.B.T. 24 was up there. 24 Q Did anyone explain to you why he left 25 Q Was Paul write indicted for falsifying 25 Monsanto and went to I.B.T.? Page 178 Page 180 1 toxicological studies at I.B.T.? 1 A There may have been, but it didn't seem like 2 A 1 do not know if details of the indictment. 2 a big deal to me one way or the other. He was a man going 3 Q Was he convicted in a jury trial of 3 into a toxicological laboratory; 1 guess he wanted do some 4 falsifying studies? 4 work in toxicology. 5 A He was convicted. 1 don't know of what he 5 Q Do you know that while he was at I.B.T. he 6 was convicted. 1 don't know whether it was a jury trial 6 was involved in Monsanto's toxicological studies of the 7 or a judge, 1 do not know. 7 long term or chronic effects of PCB's? 8 Q Did he serve time in prison? 8 A He may. 1 may have known that or may not. 1 9 A That 1 don't know either. 9 don't know whether he was or not. 1 didn't -- 1 don't 10 Q When Paul Wright left Monsanto to go to 10 know whether he was. His name may be on some of those 11 I.B.T. did you, and by you 1 mean you yourself, have an 11 reports. 1 don't know. If they are on the reports 12 understanding that when he finished at I.B.T. he would be 12 obviously he was. 13 welcome back at Monsanto? 13 Q Did you receive any updates from Paul Wright 14 A No. In fact 1 have really no recollection of 14 while he was working at I.B.T. on the Monsanto PCB long 15 when Paul went up there, because he wasn't working in the 15 term studies? 16 medical department at that time. He was working in the 16 MR. CARNEY: By updates are you talking about 17 agricultural research department. 17 anything prior to the formal report? 18 Q Dr. Kelly, do you understand that we cannot 18 MR. McCREA: Correct. 19 take the deposition of Dr. Kelly -- or Dr. Wright, do you 19 A There were quarterly reports, whether they 20 understand that? 20 were quarterly or semiannual reports sent by I.B.T. Paul 21 A 1 don't know. 21 Wright may have been one of the signatures on those. 22 MR. CARNEY: I'm going to object to that. 22 Usually there was a more senior person than Dr. Wright on 23 A 1 mean, 1 don't know anything about the legal 23 these reports. So Paul's name may very well have been on 24 ramifications of what you can or you can't do in this 24 one of those. 25 case. 25 But 1 believe that Paul was not only working for on Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 177-180 LEXOLDMONOQ6851 Page 181 Page 183 1 Monsanto projects. He wasn't working just on PCB's. 1 1 MR. CARNEY: Are you talking about 2 don't know how many various compounds the I.B.T. was 2 conclusions or summaries of the findings? 1 don't know 3 working on at that time. 1 don't know if Paul was in 3 what you mean. 4 charge of the acute testing, chronic testing or what kind 4 Q (By Mr. McCrea) Did Monsanto ever change the 5 of testing. 5 conclusions on reports done by I.B.T. on toxicological 6 Q (By Mr. McCrea) Were the studies done by 6 studies on PCB's? 7 I.B.T. for Monsanto on the long term effects of PCB's done 7 A No. They did not change the conclusions 8 in a scientifically appropriate manner? 8 there may be some changes suggested as to how the 9 A Yes. 9 conclusions should be worded. 10 Q Were the studies done by I.B.T. reliable? 10 Q What do you know about that? 11 A On PCB's? 11 A Well, there was a question whether something 12 Q On the long term effects of PCB's? 12 should be called tumorogenic or not carcinogenic. 13 A Yes, they certainly were. 13 Q Did you participate in that decision-making 14 Q Were the studies trustworthy? 14 process? 15 A Yes. 15 A No, 1 did not. 16 Q Were the studies accurate? 16 Q Tell us what happened in that regard. 17 A Yes. 17 A Well, 1 don't know. 1 mean, all 1 know is 18 Q Were the studies honest? 18 what 1 saw during one of these depositions the last six 19 A Yes. 19 years or something. 20 Q And do you believe the United States 20 Q Since you last worked at Monsanto in '74 the 21 government should rely on those studies? 21 only information you have is what you saw at a deposition? 22 A Yes. They do. 22 A Well, 1 may have seen some Monsanto papers. 23 Q And do you believe that the citizens of this 23 1 may have been, there may have been some anecdotal 24 country should relay on those studies? 24 remarks made. 1 don't know if I'm having lunch out there 25 A Yes. 25 and the question comes up 1 may hear about it. But I've Page 182 Page 184 1 Q Dr. Kelly, isn't it a fact that 1 had no reports that 1 have seen or discussions as to if or 2 representatives of Monsanto Company were highly critical 2 when or why Monsanto would have wanted to do some 3 of the work done at I.B.T., its reliability, its veracity, 3 editorial comment on the reports. 4 and its accuracy? 4 Q Have you ever changed the wording on a 5 A 1 don't believe that's correct. 1 would like 5 conclusion of a toxicological study? 6 you to show me those papers. 6 A 1 can't -- 7 Q All right, sir. Have you seen any documents 7 MR. CARNEY: Are you talking about a summary 8 that have been prepared by individuals on be half of 8 or a conclusion? 9 Monsanto Company which sharpy criticized the work done at 9 MR. McCREA: Just what the question says? 10 I.B.T., its accuracy, veracity and reliability? 10 A Well, you said the wording. 11 A No, sir. 11 Q (By Mr. McCrea) Right. 12 MR. CARNEY: I'm going to object to the 12 A Well, a person may have used a particular 13 question. 1 done know what you mean by sharply 13 term and 1 may have said this is what you want to change 14 criticized. 1 assume you're talking about PCB studies? 14 it to, yes. 1 certainly also changed it on the Drinker 15 A Are you talking about PCB now? 15 study when it came out and called chlorinated diphenyl and 16 Q (By Mr. McCrea) Yes, sir. 16 1 called him up and said, "Look, this isn't - How do you 17 A No, 1 never seen any. On PCB's? 17 know this is a chlorinated diphenyl?" So 1 think I'm 18 Q Right. 18 responsible for his next paper. That not only changed the 19 A No, sir. 1 never seen any. 19 study, it changed the paper. 20 Q Did Monsanto ever change the wording on 20 Q Did the studies at I.B.T. establish that 21 studies prepared by I.B.T.? 21 PCB's were slightly tumorogenic? 22 MR. CARNEY: 1 object here. 1 think the 22 A Yes, 1 don't know whether they said slightly. 23 question is vague. And to be talking about the actual 23 1 don't know if that was the term. They did say that at 24 findings? 24 some levels there were non-malignant tumors found. 25 MR. McCREA: No. 25 Q And do you understand how the PCB's produced Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 181 - 184 LEXOLDMONOQ6852 Page 185 Page 187 1 the non-malignant tumors? 1 Q And to what did the advice of counsel relate? 2 MR. CARNEY: Could you read that question 2 A 1 didn't believe that was my business. 3 back? 3 Q Why did you call him and ask him about Texas? 4 (Reporter read back from the record as directed: 4 A Well, 1 wanted to know why he didn't want to 5 Q "And do you understand how the PCB's 5 testify. 6 produced the non-malignant tumors?") 6 Q What? 7 A 1 do not believe that the secret of how 7 A 1 wanted to know why he didn't want to 8 chemicals cause tumors is understood. It certainly isn't 8 testify. 9 understood by me and 1 don't know if by people much 9 Q Is that the only reason? 10 smarter than 1 have written down how a particular compound 10 A 1 think that's a -- that was a good enough 11 causes a tumor. 11 reason. 1 mean, whatever a counsel may have said, Paul 12 Q (By Mr. McCrea) Did Monsanto -- Strike the 12 doesn't want to testify on the advice of counsel, do you 13 question. Were the studies at I.B.T. peer reviewed by the 13 want to talk to him and see if you can get any reasons? 14 independent scientists? 14 Q And do you know the reason? 15 A Well, if you give them to the scientists of 15 A No, 1 didn't inquire that much. That was his 16 the government -- 1 don't really know what you mean by 16 business. 1 just wanted to be sure that he was definite 17 peer review, now, Mr. McCrea. If you send a compound to a 17 in his mind on the advice of counsel he didn't want to 18 laboratory they do the work and send it back to you. Do 18 testify. 19 they send it out to competing laboratories and say, "Hey 19 Q Other than that conversation have you talked 20 look, did we do this all right?" That's never done. 20 to Paul Wright since he was indicted? 21 But we sent this data to the government, it 21 A No, sir. 22 certainly was peer reviewed by the government because they 22 Q Have you ever asked Paul if he falsified 23 had the data. The sliding were peer reviewed by the 23 data? 24 government, if that's what you mean. But if you think or 24 A No. 25 you're equating that a report you get from an independent 25 Q Have you ever asked -- Page 186 Page 188 1 commercial laboratory with a paper in the New England 1 A 1 didn't believe he would. 2 journal of medicine, they are worlds apart. 2 Q But you've never asked him? 3 Q All right, sir, that's exactly what 1 meant. 3 A No, 1 never asked him. 4 A Yes. They are never peer reviewed in that 4 Q Have you ever questioned him about the 5 sense, no. 5 accuracy of the I.B.T. studies? 6 Q Did you know that Monsanto paid the 6 MR. CARNEY: You know, 1 think this is 7 attorney's fees for Paul Wright? 7 misleading in that 1 believe this all occurred after Dr. 8 A 1 don't know, myself. I've heard -- 8 Kelly was retired from the company and 1 don't know that 9 MR. CARNEY: You've already asked that. 9 he has any right to pry into somebody's life and ask them 10 A -- anecdotal rumors, but 1 don't know. 10 personal questions of the sort you're suggesting. 1 think 11 Q (By Mr. McCrea) Have you talked to Paul 11 you ought to at least make it clear to the jury that Dr. 12 Wright since he was indicted? 12 Kelly was no longer employeed by Monsanto, but retired, to 13 A Yes. 13 put it in context. 14 Q Can you tell us when you talked to him and 14 Q (By Mr. McCrea) The I.B.T. studies were done 15 what you said to him and what he said to you? 15 from '70 to '75? 16 A Sure. 16 A If you show me the final report I'll be able 17 Q All right. 17 to -- Let's be accurate on this. 18 A 1 said, "Paul, there's a case down in Texas, 18 Q All right, sir. 19 1 understand you don't want to testify," and he said, "No, 19 A If you just show me the final report 1 could 20 1 don't want to testify on advice of counsel." 1 said 20 give you an estimation. 21 "Okay, fine. How's everything else going?" That's the 21 Q Was the entire series of studies done 22 extent of it. 22 pursuant to authorization? 23 Q Did he tell you why he did not want to 23 A Yes, in conjunction with the United States 24 testify in a PCB case? 24 government, the Department of Food and Drug 25 A Yeah. On advice of counsel. 25 Administration. We went up there before we started these Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 185 - 188 LEXOLDMONOQ6853 Page 189 Page 191 1 studies. We told them where we were going to go, what we 1 Q That's not what we're talking about? 2 were going to do and do you have any suggestions. It's 2 A What were we talking about? 3 those big thick ones down there. 3 Q The long term studies? 4 Q Thank you. All right, Dr. Kelly, I'll look 4 A 1 thought we were off that. The long term, 5 at this with Counsel. Exhibit K-71, Report to Monsanto 5 dermal is not long term. That was started presumably in 6 Chemical Company. Subacute Dermal Toxicity of Aroclor 6 1968 sometime. 7 1248? 7 Q And ended in '71? 8 A Oh, no, that isn't the one, because that only 8 A That's right. 9 takes two months to do. 9 Q Were there studies subsequent to that? 10 Q That was 1963? 10 A 1 don't know when the chickens were done. We 11 A Right. 11 had some testing done on chickens. 1 thought that was 12 MR. CARNEY: 1 thought you were talking about 12 subsequent to these. 13 the long term studies? 13 Q All right. Maybe we can take some time 14 MR. McCREA: 1 am, excuse me. 14 during the break and line those dates up. Dr. Kelly, if 15 (Whereupon, a discussion was held off the record.) 15 an individual called you from Westinghouse Electric 16 A Here it is, K-76. The final report was dated 16 Corporation and asked to summarize the results of the long 17 November the 21st, 1971. They were probably started 17 term or chronic studies what would you have told them? 18 sometime in the latter months of 1968 because to run a two 18 MR. CARNEY: Well, I'm going to object 19 year testing you have got to run a range finding to be 19 because 1 think it's overbroad as to what area. 1 mean, 20 sure you've got a dose that the animals can take for two 20 they - 21 years, so you're fooling around with those doses until you 21 A 1 would have told them 1 will sit down and 22 get the right dose. 22 make a summery of these and send it to you. 23 Then after you sacrifice the animals after two 23 Q (By Mr. McCrea) You couldn't answer that 24 years you've got to fix the tissues and wait around to get 24 question -- 25 the pathologist to read the slides which also takes time. 25 A Right off the top of my head, no. We're Page 190 Page 192 1 Then you've got to the get the report together. So it's 1 dealing remember with three different substances, three 2 at least three years and we started these sometime in 2 different levels, two different species and 1 wanted to 3 1968. 3 give him the figures on all of them. 4 Q (By Mr. McCrea) Do you know if when they 4 Q If an individual from Westinghouse Electric 5 started Paul Wright was working for I.B.T.? 5 Corporation called you in 1973 and asked you if based on 6 A 1 don't know that. 6 the studies which were done at I.B.T. if you felt there 7 Q Now were there additional studies, Dr. Kelly, 7 was any cause of concern for the workers in the 8 other than the one that ended November of '71 ? 8 Bloomington, Westinghouse plant from the long term effects 9 A Well, sure they were doing some on ducks or 9 of PCB's what would your answer have been? 10 chickens, they were doing skin testing on rabbits. 10 A Well, I'd say, "What is your exposure?" 1 11 Q Were those done pursuant to your authority or 11 don't know how they're working with the material. 12 someone else? 12 Q If he said that the exposure was moderate 13 A No, mine. 13 what would you tell him, what advice would you give him 14 Q And when did those studies end? 14 based on the studies at I.B.T.? 15 A Well, you have them there and I'll tell you. 15 MR. CARNEY: Objection to the use of the word 16 Q 1 don't see it. 16 moderate as vague? 17 A Don't youhave chickens there someplace? 17 A Any information 1 would give a worker at any 18 It's not a big thick one. You've got a dermal, which is 18 plant would be based on several things. It would be based 19 skin on rabbits, and you've got --1 think a chicken 19 on the testing we did back in 1954, an analysis of air 20 study. 20 test, inhalation studies for ninety days. It would be 21 Q I'll have to have you locate that. 21 based on information in the literature on PCB's in 1963. 22 A The dermal toxicity was finished in March of 22 1 don't think there was much at that time. It would be 23 1963. 23 based on lack of information or the lack of any positive 24 Q That's not what we're talking about, is it? 24 results. 25 A Uh-huh. 25 It would be based on my own experience, that with Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 189 - 192 LEXOLDMONOQ6854 Page 193 Page 195 1 our own workers, so 1 would take into account the PCB 1 MR. CARNEY: Well, 1 - 2 studies at I.B.T., yes, and 1 would say you have a product 2 MR. McCREA: 1 might, but look- 3 that you should avoid breathing at elevated temperatures 3 MR. CARNEY: It seems to me and I'm not 4 or in confined spaces, you should avoid repeated or 4 trying to be difficult but we're -- This thing's getting 5 prolonged skin contact. 5 stretched out over a lengthy period, you know, we're 6 Q Based on the I.B.T. studies, you would tell 6 talking about trial testimony and here we have had a week 7 them that? 7 intermission already and we came back thinking that one 8 A 1 said based on all three. 8 day would do it and 1 agreed to that. I'd prefer to get 9 MR. CARNEY: 1 think we've got no time. 9 the deposition done in consecutive days. 1 was prepared 10 MR. McCREA: Break. 10 to do that, the- 11 (Whereupon, a short break was taken.) 11 MR.McCREA: We're driving from Bloomington, 12 MR. CARNEY: I'd just like to say when we 12 Indiana to St. Louis to do this deposition so it's no 13 took this last break to change tapes we had agreed to go 13 picnic from our standpoint. Secondly, we've got a hundred 14 one more tape or one more hour and now when we're ready tc> 14 and eight documents here, none of which 1 had. 1 was not 15 start up Mr.McCrea has indicated he wants to quit. 1 15 given copies. 1 did give you copies of my exhibits, which 16 would be prepared to go a couple more hours and 1 think 16 Dr. Kelly has and you have. 1 didn't receive copies of 17 Dr. Kelly would, too. 1 can understand putting some 17 yours and 1 think you get to the point of diminishing 18 reasonable time limit on it. 18 returns when you extend things to a point where it's just 19 On the other hand, 1 think we have been going at 19 not productive, so my recommendation is we do three tapes 20 this for a long time and we were told, Mr.McCrea, when we 20 tomorrow. 21 broke last time early and decided to not make a formal 21 1 absolutely have got to be back in Bloomington by 22 objection to going the next day and this deposition was 22 3:00 o'clock or 3:30 or 4:00 to interview a client who has 23 supposed to continue until concluded, that you would 23 a work comp hearing the next day, Thursday, and 1 mean 1 24 complete the deposition in one more day. 24 have to be there. His name is a Larry Martin. So 25 Now we're at 4:00 o'clock or it's now 4:15 on this 25 that's - 1 think if we can get in three tapes tomorrow Page 194 Page 196 1 one more day and we're not only not complete but 1 that would be productive. 2 apparently another half a day isn't going to complete the 2 Also on the record 1 need to know the cases in 3 deposition, and so I'm just objecting to that for the 3 which Dr. Kelly testified and you stated you were going to 4 record, and 1 guess the only other thing I'd like to at 4 ask Monsanto for those and 1 would like to have those 5 least put on the record is that we are agreeable that 5 before tomorrow if you can get them. 6 we're going to start at 7:30 and going until 11:30 6 MR. CARNEY: Well, you know, Dr. Kelly has 7 tomorrow? 7 given you all of the information- 8 MR.McCREA: That's awful early to start. 1 8 MR. McCREA: Well - 9 would agree to 8:30. 1 just -- 1 don't, 8:30 to 11:30, 1 9 MR. CARNEY: - that he has on that and 1 10 think, 7:30 is awful early. 10 simply don't know whether there's any other information to 11 MR. CARNEY: Well, we're only going to do- 11 be had. 12 1 thought we had an agreement, Mr. McCrea. We asked the 12 THE WITNESS: One Market Plaza, One Market 13 studio if they would come in early so they could start at 13 Plaza, that's whatever, A.D.R or something like that. 14 7:30. 1 thought we had an agreement. Now we're not only 14 MR. CARNEY: Well, let's- 15 quitting early but we in an effort to try to get this 15 MR. McCREA: Maybe we can go off the record 16 done. 1 thought we had an agreement that we start at 16 and figure out some of those other cases. 17 7:30. 17 MR. CARNEY: Let me just while you're on the 18 MR.McCREA: Let's make it 8:00 o'clock. If 18 record you made some comments about the exhibits. 1 19 we can do three full tapes tomorrow morning -- how long 19 believe that we have had an extra copy of the exhibits in 20 are the tapes, an hour? 20 the courtroom or in the studio here and you have been 21 MR. CARNEY: Yes. 21 looking at those from time to time during the three days 22 MR. McCREA: We can do three tapes tomorrow 22 that we have had the depositions. 23 that should take us to about 11:30. 23 1 just for the first time this morning you handed 24 MR. CARNEY: Are you going to finish? 24 me some exhibits that you intend to use. 1 haven't had 25 MR. McCREA: 1 doubt it. 25 time to look at them but 1 don't think it's fair to say Kelly, R. Emmet M.D. (fmrMons Med Dir) in BROWN Volume 3 Pages 193 - 196 LEXOLDMONOQ6855 Page 197 Page 199 1 that we have held back on exhibits and that you have given 2 us exhibits. I think you have had those exhibits in this 1 NOTARIAL CERTIFICATE 2 State of Missouri ) 3 City of St. Louis ) 3 courtroom. 4 MR. McCREA: I'm not saying that, and I 4 I, TOD MINNIGERODE, a Certified Shorthand 5 Reporter and a duly commissioned Notary Public within and 6 for the State of Missouri, do hereby certify that pursuant 5 acknowledge that I think I've been through these exhibits 7 to agreement there came before me at the offices of 6 but I just, to me, there's not much I want out of this 7 stack, okay. 8 Communitronics, 1907 S. Kingshighway, St. Louis, Missouri. 9 R. EMMET KELLY, M.D., 10 who was by me first duly sworn to testify to the truth and 8 THE WITNESS: You talking to me now? 11 nothing but the truth of all knowledge touching and 9 MR. McCREA: No, I can't turn that far. But 12 concerning the matters of controversy in this cause; that 13 the witness was thereupon examined under oath and said 10 there's not much I want out of this stack, but I think if 14 examination was reduced to writing by me; that the 11 I can take this with me tonight and go through it. 12 There's just not a whole lot that I want. 15 deposition is to be continued by agreement of all parties; 16 and that this deposition is a true and correct record of 17 the testimony given by the witness. 13 MR. CARNEY: I'm willing to give you my only 14 copy of it. Appreciate your not marking the copies. 18 19 I further certify that I am neither attorney 20 nor counsel for nor related nor employed by any of the 15 MR. McCREA: I have marked them. I have 21 parties to the action in which this deposition is taken; 16 marked them. 17 MR. CARNEY: Well, I appreciate since that's 22 further, that I am not a relative or employee of any 23 attorney or counsel employed by the parties hereto or 24 financially interested in this action. 18 my only clean copy I'd like to keep those clean. They are 19 not working copies. I have got the court reporter's 25 26 IN WITNESS WHEREOF, I have set my hand and 27 seal on July 18, 1990. 20 exhibits, that's not -- My only other copies are those 28 My commission expires June 3, 1991. 21 exhibits; I know you have put a quite a few marks on it 22 already. 29 30 31 ------Notary Public 23 MR. McCREA: I put a few marks on it. 32 24 THE WITNESS: At what time is it tomorrow? 33 34 25 MR. CARNEY: 8:00 o'clock tomorrow. 35 Page 198 Page 200 1 THE WITNESS: And then what's the next time? 1 COURT MEMO 2 MR. CARNEY: And are we agreeable that if we 2 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 3 don't conclude tomorrow you will start in the morning on 3 STATE OF MISSOURI 4 8:00 o'clock Friday and go to conclusion. 4 5 MR. McCREA: Did you check the calendar for 5 Glenn Brown, et al, vs. Monsanto Company 6 Friday? 6 862-00694 7 (Whereupon, a discussion was held off the record.) 7 8 MR. McCREA: We can't do it on Thursday 8 CERTIFICATE OF OFFICER AND 9 because of your conflict? 9 STATEMENT OF DEPOSITION CHARGES 10 MR. CARNEY: It's the doctor's conflict and 10 11 your conflict. 11 DEPOSITION OF R. EMMET KELLY, M.D. 12 MR. McCREA: True, that's agreed. 12 TAKEN ON BEHALF OF THE DEFENDANT 13 MR. CARNEY: I'd like to just so we have-- 13 6/12/1990 14 If you don't conclude on Friday can we go into Saturday to 14 Name and address of person or firm having custody of 15 conclude? 15 the original transcript: 16 MR. McCREA: Yes. 16 Mr. Thomas M. Carney 17 MR. CARNEY: Okay. 17 Husch & Eppenberger 18 MR. McCREA: There is no way this is going 18 190 Carondelet Plaza, Suite 600 19 to go beyond Friday. 19 St. Louis, MO 63105 20 THE WITNESS: What time we start on Friday? 20 21 MR. CARNEY: 8:00 o'clock. 21 22 THE WITNESS: And what time tomorrow? 22 23 MR. CARNEY: 8:00 o'clock. 23 24 (Deposition continued.) 24 25 25 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Pages 197 - 200 LEXOLDMONOQ6856 Page 201 1 ORIGINAL TRANSCRIPT TAXED IN FAVOR OF: 2 Mr. Thomas M. Carney 3 Husch & Eppenberger 4 190 Carondelet Plaza, Suite 600 5 St. Louis, MO 63105 6 Total: 7 8 Upon delivery of transcripts, the above 9 charges had not been paid. It is anticipated 10 that all charges will be paid in the normal course 11 of business. 12 GORE PERRY GATEWAY & LIPA REPORTING COMPANY 13 515 Olive Street, Suite 700 14 St. Louis, Missouri 63101 15 IN WITNESS WHEREOF, 1 have hereunto set 16 mv hand and seal on this dav of 17 Commission expires 18 19 Notary Public 20 21 22 23 24 25 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 Page 201 LEXOLDMONOQ6857 [& - absorbed] Transcript Word Index & 1933 (cont.) 37 & 144:14 3 2:24,26 200:17 201:3,12 1935 48:14,17 59:13 68:9 72:8 1 1 104:17 144:17 154:23 155:19 100 2:24 1023 3:22 6:18 1024 6:178:159:1640:2 144:18 1025 9:2 34:15 36:3,10 1027 38:10 1030 43:8 1033 47:20 108 155:19,20 lOtwenty 17:11 21:1 40:7,25 155:22 199:28 1936 3:00 18:9,24 40:7,12 195:22 1937 3:30 40:2441:11,14 156:10,23 195:22 158:9,20 162:4,14 163:19 30 165:24 166:9,14 158:4,6,9 165:23 166:9 1939 307 156:7 157:1 163:20 157:5 1954 30th 192:19 158:20 166:21 1957 314 74:6,14 1:23 1958 35 44:11,12 40:8,11,1241:3 1960's 36 7:20 40:9 1963 37 189:10 190:23 192:21 40:1341:11 166:21 1968 38 18:2,17 85:20 189:18 190:3 40:1341:14 191:6 37:23 1970 4 7 167:4 7:30 194:6,10,14,17 70 188:15 700 201:13 71 189:5 190:8 191:7 74 183:20 75 188:15 76 189:16 8 8 49:15 50:14 52:2 72:9 8:00 194:18 197:25 198:4,21,23 8:30 194:9,9 862-00694 11:30 49:15 50:15,20 51:13 52:2 4 1:6 2:6 200:6 194:6,9,23 60:6,17,24 72:9 158:4,6 80:8,9,25 81:18 82:5 84:12 87 119 175:12,16 176:4 88:9,21 110:13 115:21 154:23,25 155:2 2:26 1971 151:11 152:1 8th 12 189:17 4:00 50:20 1:152:13 1973 193:25 195:22 9 1248 189:7 1260 167:15,19 12th 82:6 1506 1:21 179 85:20 18 199:27 186 170:11 190 200:18 201:4 1907 2:15 199:8 1918 4:19 7:19 8:2 1930's 17:19 192:5 1974 73:4 163:20 171:5,5 1980 171:5 1987 167:10 1990 1:15 2:13 58:21,22 82:6 199:27 1991 199:28 2 2 3:21 39:16 68:17 2,4,5 12:18,25 21st 189:17 298 155:24 156:11 4:15 193:25 400,000 173:16 47402 2:27 5 515 1:21 201:13 6 6/12/1990 200:13 600 200:18 201:4 621-2571 1:23 63101 1:22 2:24 201:14 63105 200:19 201:5 90,000 73:16 a a.d.r 196:13 abdomen 12:3 32:23 34:25 abhorrent 17:21 able 56:3 145:5 157:24 158:13 188:16 abscess 6:2 13:5,6,8 abscesses 4:2 5:25 13:22 14:7 38:14 absence 23:23,24 164:17 absolutely 79:17 195:21 absorbed 1933 121:17 122:17 123:14 15:4 18:3,1826:1528:15 125:10,18 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6858 [absorption - antedated] absorption added ahead amounts 6:20 85:15,16 124:16 125:2 57:20 65:18 108:16 73:19 91:14 99:24 128:19 125:8,17,18 adding air 129:4 abstract 90:18 192:19 amplify 81:9 addition al 78:24,25 79:2,6,14 abstracted 33:22 84:12 88:8 143:23 1:4 2:4 200:5 analysis 80:14 additional alabama 192:19 abstracts 190:7 160:5 anecdotal 47:19 address alden 183:23 186:10 accepted 80:21 82:7 91:6 200:14 39:25 41:19 158:7 159:24 anemia 151:7 156:21 161:21 169:5 addressed 159:25 160:14 163:5 135:22,23,25,25 176:2 79:22 85:24 117:1 alleged animals accidently adequate 25:14 93:12 189:20,23 52:17 134:15 alleging anniston accompanied administration 26:5 43:20 44:10 154:3,8,9 10:25 49:16 59:25 61:4,12,17 allergic 160:5 166:7 accompanies 62:18 63:20 174:11 188:25 10:24 96:2,2,3,5,7 97:21 announcement 34:10 adult 145:3 63:18 64:22 65:21 67:8,20 accord 34:8 39:7 allergies 67:20,24 68:8,10,13 174:4 adulteration 95:25 97:10,12,15 139:9 announcements account 52:5 141:21 64:10 66:4 68:1,3,15,16,20 18:5,20 19:10 175:14 193:1 adverse allow 68:20 accuracy 58:6 68:24 49:2 answer 156:25 182:4,10 188:5 advice allowed 7:20 19:3,5,9,13 22:13,22 accurate 55:5 186:20,25 187:1,12,17 47:8 30:25 46:3,4 47:12 49:13 81:7 158:10,16,24,25 159:4 192:13 allowing 52:11 55:4 58:1,8,12 75:19 159:7 181:16 188:17 advisement 64:16 75:21,25 76:1,3,3,10 82:22 accurately 45:9,9 alter 83:7,13 84:9 86:5 88:25 5:13 87:18 aerolites 142:2 89:24 93:17 97:21 99:4 acid 37:12 altered 100:18,21 101:6 103:15 136:8 afraid 100:20 111:10 106:2 107:24 109:24 acknowledge 66:10 148:10 ambiguity 110:24 111:14,23 112:14 19:14 134:22 197:5 afternoon 110:14 112:23,25 113:2,4,7,8,11 acknowledged 2:14 ambiguous 113:12 114:21 116:17,19 18:1,16 19:7 age 11:23 25:3 26:21 83:11 116:21 117:11,16 118:11 acne 3:14 36:13 90:20 106:11,11 110:7 118:22 119:1,23 122:8,11 12:9 14:12,12,16,19,20,21 ago 121:20 124:13 152:16 125:3 128:3,10 132:2 14:22 34:1,5,7,7,8,10,12 41:25 78:16 164:3,6 134:14 136:17 139:14,16 38:2 39:7,8 95:2 agree amend 140:12,14,16 141:20 142:1 acneform 17:3 20:13 26:22 30:3 79:1,14 144:8,13 145:7 146:8,11,20 9:3,6 34:1 36:11 38:1,2,11 90:24 97:4 120:5 124:6 amendment 146:23 147:15 148:5,17 39:20 127:8 194:9 179:2 149:11 150:2,3,20,22 151:8 acnes agreeable america 151:16 152:22 154:19 14:13 194:5 198:2 122:1 160:6 191:23 192:9 action agreed american answered 9:14 10:23 199:21,24 3:1 21:5 84:2 193:13 195:8 118:8 123:19,21 28:19 40:5 80:2 138:14 activity 198:12 amnesia 140:5 141:5 144:9 148:21 7:22 agreement 147:5 answering actual 124:14 194:12,14,16 199:7 amoebic 91:5 103:14 111:5 8:17 182:23 199:15 145:2 answers acute agricultural amount 78:10,19,22,23 79:13 81:22 181:4 12:11 177:19 178:17 53:13,14 57:21 83:8 91:14 101:22 107:25 109:18 ad 179:20 97:1 121:8,21,22,25 122:21 164:2 159:20 agriculture 122:22,25 123:3,5,14,19,23 antedated add 48:6 69:8,10,19,20 175:7 124:5,6,7 128:6,17 135:13 75:16 76:15,16 50:1092:11,13,1594:19 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6859 [anterior - bases] anterior 33:13,14,19 anticipated 201:9 antipyrine 143:11,14,24,25 anxiety 149:22 anybody 23:18 39:23 65:13 94:4 176:7 177:13 anybody's 136:5 anymore 72:7 anyplace 32:12 93:4 anyway 84:24 103:25 apart 186:2 apparent 32:22 apparently 194:2 appear 12:2,22 13:2 32:10 appearance 34:2 appeared 32:16 appetite 15:5,13 16:4,9,20 26:8,24 27:11,17 37:3 40:23,25 144:6,10,10,15,20 160:16 161:9 163:6,23 164:13,18 165:14 166:23 apples 124:4 applications 49:3 64:17 applied 177:12 apply 47:14 appreciate 80:2 110:9 152:20 197:14 197:17 approach 8:7 appropriate 82:16 169:2 174:14 181:8 approximate 73:14 approximately 3:24 april asking (cont.) attribute 49:15 50:14,20 52:2 60:6 99:21 103:16,17 106:12,16 17:17,20 157:24 158:13 60:17,24 72:9 108:14 109:9 110:8,15 159:5 arceneaux 111:22,24 126:18 127:16 authored 70:18 128:8 136:19 137:7 142:21 39:24 area 152:16,18,23 160:24 165:2 authority 32:7 132:23 133:19 134:1,2 165:5,6 173:5 176:12 190:11 173:7 191:19 asks authorization areas 44:3 188:22 10:12 12:6,8,13 13:2,4,17 aspect authorize 32:1 33:20 34:4 46:7 71:17 63:16 48:22 72:15 arms aspects authors 9:17,25 13:18 15:2 115:1 52:6 64:20 7:13 army aspirin author's 175:19 79:7,7 9:6 aroclor associate automobiles 167:19 189:6 155:17 129:17 aroclors associated available 42:21 43:1 49:2,5,6,6,9 25:24 90:17 120:14 135:20 63:25 89:19 163:21 164:10 arranged 135:23 136:4 145:20 avoid 5:10,11 associates 193:3,4 arthritis 85:24 awful 113:20 association 194:8,10 article 138:20 b 3:22 8:20 18:3,18 21:25 assume 22:1,11,20 24:4 26:7,16,24 87:9 90:7 119:24 142:15 back 8:2 12:2 15:2 17:11,19 37:8,11,1341:17 133:17 156:7 157:1,10 158:7 159:24 182:14 assuming 102:8 103:14 18:13,14 22:17,18 24:25 25:4 32:17 46:24 47:1 74:12 76:6,11 78:7,12 84:4 articles 70:17 91:21 96:9,11,14 assumption 46:2,13 88:6 90:5 102:19 104:13,17 115:20 117:21,22 118:14 103:23 106:20 109:2,5 asthma 118:16,21 129:22 135:22 128:2,14 141:14 156:10,23 ascribe 16:25 ascribed 20:5,12 21:5 ascribing 19:15 88:4,22 89:10,21,23,24 90:3,4 152:9 153:6 ate 84:21 86:24 88:12,23 90:3 99:23 103:18 105:23 107:4 athlete's 94:22 153:22 154:11 164:9 172:12 173:25 178:13 185 3 4 18 19219 1957 21 197:1 bad 1382 14314 balance aside 135:10 atlanta 39:25 113:5,18 bamboo asked attack 998 22:10,19 28:12 37:5 40:5 131:17 40:18 42:5 44:13 45:1 attempt banned 6715 46:15 52:9,20 55:6,13 57:9 17:1743:10 57:24 58:7 59:5 63:12 attendance barreled 11114 75:11 76:7 79:4 80:12,16 89:18 based 81:11 117:5,6 120:12,12 153:3,4,19 154:3,9,10,10 154:11,22 155:4 179:2 186:9 187:22,25 188:2,3 191:16 192:5 194:12 attention 27:6 78:11,20 108:9 attorney 19:14 80:19 104:16 199:19 199:23 24:22 25:7 68:6 82:9 84:15 88:1 89:7,11,13,15 90:13 9614 14 15 97 5 1021 1 104:21 105:18 106:20 108:6,7,8 110:19 114:15 asking attorneys 1161 192 5 14 18 18 21 23 29:24 46:13 53:4 55:3 56:9 79:22 80:12 154:22 155:4 56:22 57:4,4 86:16 88:8 attorney's 192:25 193:6,8 89:7 96:10,13,20 97:5 83:21 173:16 186:7 67:11,11,12,13 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOO686O [basis - carcinogenic] basis best (cont.) blumenthal bunch 17:15 83:4 85:6 89:12 92:7 90:16 136:21 176:9 48:2,3,8,20 72:9 73:1 97:24 163:23 164:4,12 better blurred bureaucratic basket 30:1 119:9 49:23,25 52:16 beyond body burned bath 198:19 7:23 12:6 13:17 38:11 54:24 55:18 56:15 43:13,25 44:6,14 45:2,12 big 85:15 121:7,9,17 122:15 burning 45:16 46:8,21 47:3 53:15,19 54:9 135:3 145:15 123:15 124:5,7,10 125:5,22 57:2 batter 180:2 189:3 190:18 138:18,19 143:14,15 157:4 burns 52:14 bigger boil 58:24 battery 75:16 76:16 4:6,6 6:2 13:4,5,9,9 95:8,8 business 60:20 bio 151:20 34:25 64:2 65:12 69:11 bear 173:10,20 boils 72:2,6 187:2,16 201:11 20:15 biodegradable 13:2 14:4,7,25 95:6 buying beat 50:12 bone 74:4 134:7,11 biological beg 14:3 77:20 123:20 148:13 biphenyl began 43:19 57:16 135:4 12:2 biphenylenes beginning 123:8 43:9,9,10 biphenyls begins 135:9 47:20 birds behalf 50:16,24 1:142:12200:12 birdshell belief 69:1 7:18,24 9:6 bit beliefs 174:20 7:18 black believe 10:4 20:6 29:10,21 30:6 3:21 7:13,14,15,18 12:4 34:3 16:15 17:1 18:7,22 19:18 blackhead 37:1739:1641:19,21 51:16 4:5 59:10 60:1 62:6 72:6 80:8 blackheads 80:25 84:14 86:25 103:5 9:17,25 12:2,5,20 13:12 104:13 115:3 129:16 31:21 32:3,6 34:11 130:16 131:18,24 132:2 blacking 141:18 149:20,23 150:14 146:22 158:19,22 159:20 168:21 bladder 177:11 180:25 181:20,23 145:9,10,13 182:5 185:7 187:2 188:1,7 blanket 196:19 130:25 believed bleeding 7:21 8:3 145:18 believes blindness 6:13 19:19 119:20,24,25 benzene blister 5:22 134:22,25 135:3,17 30:23 156:8,25 157:25 158:14 blood 159:6,17,19 162:3,8 34:24 92:24 93:9 134:18 benzofurans 136:1 146:5 151:20 55:22 118:10 137:21 bloomington best 2:27 44:13,18 45:25 74:6 29:11 40:17 60:4 61:25 85:5,7 87:17 192:8 195:11 64:14 67:22 69:9 88:17 195:21 115:8,9,12,15 bones 115:5,7 borne 17:7 19:1620:11 22:5 bottom 6:18 15:3 43:8 54:3 59:8 94:20 bought 158:22 159:2 brain 35:24 break 4:9 19:1 30:17 32:1 39:13 39:14 78:5,6,14 95:20 98:12 115:18,19,25 128:11 154:19,20,21 191:14 193:10,11,13 breath 98:25 breathing 85:17 99:19,21 193:3 bring 78:11,19 broad 115:7 broadway 2:24 broke 193:21 bronchitis 99:15 brought 35:19 brown 1:4 2:4 200:5 building 55:14,25 56:11,13,20 57:2 57:5,23 59:2 179:19 bulletins 69:14 c cake 52:14 calandra 172:19,25 177:23 179:18 calcium 130:4 calculated 85:11 calendar 198:5 call 42:11 179:8 187:3 called 22:10,19 44:12 52:9,20 58:7 85:9 156:6 162:1,22 183:12 184:15,16 191:15 192:5 camera 38:9 canals 92:5 cancer 93:16 95:4 138:25 139:7,22 150:13 151:19 167:14,23 168:8 169:2,11,13,23,23 170:9,11 171:9 cancerous 138:8,19,22 cancers 171:3 capacitors 85:6 capture 64:3 carbon 5:6,11,12,18 32:22 49:21 carbonless 49:21 carcinogenic 183:12 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6861 [careful - chlorinated] careful cases (cont.) certainly checklist 43:11 36:17 94:5 117:14 160:9 15:1 17:10 23:7 25:20 26:2 165:6,9,11 carney 161:15,16 162:5,7,19,21,25 35:18 55:25 67:3 68:1,15 cheekbones 2:23 6:23 7:6 11:11,22 196:2,16 69:10 71:3 73:2 85:2 94:3 10:2,7 31:21 17:16 18:10 20:22 25:1 cataracts 101:23 108:3 125:16 cheeks 26:20 27:14 28:6,18 29:23 129:19,24 130:1,15,16 131:18 134:24 163:18,19 10:1029:9 44:8,17 45:19 46:24 50:19 catch 168:3 170:3 172:13 177:22 chemical 53:1 54:25 55:3,10 56:4 145:1 181:13 184:14 185:8,22 5:3,7 6:20 7:14 8:18 10:18 57:1,8 66:14 68:10 72:23 categories certificate 10:22 11:7 12:1521:12 74:11,15 75:24 76:10 77:22 95:20 105:2 112:13 199:1 200:8 23:15 24:7,19 25:18,22 78:12 80:24 81:17 82:20 category certified 26:18 71:19,22 128:6 130:3 84:1,6 86:11 88:5 89:14 28:25 82:18 103:11 105:3 2:16 3:4 199:4 144:15 157:8 167:18 189:6 90:7,10 96:8,11,17 98:6 112:17,18 148:11 certify chemicals 99:20 101:4,10,14,18 102:5 cattle 199:6,19 4:21 12:10,11,11,14,19 103:9,13,23 104:3 105:21 54:19 55:9 cetera 19:21 22:12,21 23:1,13,20 106:4,15,18 107:2,16 108:1 causal 87:17 97:2 137:21 24:6,12,15 25:25 26:4,6 108:11,16,24 109:2,8 110:2 82:10,11,12,12 88:1 89:8 chain 40:7,16 45:21 79:11 82:14 110:5,12 111:1,7,12 112:10 89:12 97:6,7,7,8 104:22,23 5:18 51:3,6,18,19,20,24 88:3 89:10 97:10 110:23 112:13,16 113:10,25 114:5 104:24,25 105:13 109:7 52:3,24 116:5 128:25 161:18 115:6,11 116:12,22 117:3 110:20,20,21,21 114:16,23 chance 162:11,18 185:8 118:5,8,15 120:8 121:10,12 115:3 116:2,2,3,3 131:24 65:12 chemist 121:19,23 122:6,19,23 132:3 138:21 change 43:6 123:2,17 126:9,17,24 127:5 causally 7:22 46:8 49:9 79:1,2 111:6 chest 127:15 128:7,19 129:2,10 118:3 111:8,10,18 114:21 115:9,9 12:2 32:17 37:25 132:10,14 129:21 131:20 132:24 cause 150:19 182:20 183:4,7 132:15,19,23 133:12,16 133:5,20 134:8 135:12 1:6 2:6 9:13 11:13,16 12:5 184:13 193:13 Chicago 136:11,14,19 139:3,10,18 12:12 16:11 22:7 23:15,17 changed 47:20 141:7,22 142:13,18,24 23:18,19 68:24 106:25 7:25 104:3,5 112:2 156:21 chicken 143:8 144:2 148:19 149:1,4 107:13 134:23 157:7,24 161:20,21 184:4,14,18,19 190:19 149:9,16 152:12 154:18 158:13 159:5 185:8 192:7 changes chickens 155:6,15 160:21,25 164:1 199:12 16:1423:1777:11 98:14,16 190:10,17 191:10,11 164:20 165:3 166:10,16 caused 98:17,22 115:8,12,15 183:8 children 171:18 172:7,22 173:4,11 7:12 8:4 10:20 18:1,8,16,23 characteristics 93:3,5 173:22 174:15 178:22 22:25 23:13,19 26:3 69:1 113:1 chin 179:7 180:16 182:12,22 84:20 86:22 99:24 102:2,4 characterization 29:9 183:1 184:7 185:2 186:9 102:25 103:4,6,8 108:9 120:9 chloracne 188:6 189:12 191:18 119:3 120:17,22 121:4,25 characterized 4:148:149:21 10:1,8,15 192:15 193:9,12 194:11,21 123:25 125:15,16 134:10 87:19 11:24 12:12 13:4,13,16,19 194:24 195:1,3 196:6,9,14 134:11 137:21 150:9 characterizing 13:24 14:22 15:24 16:10 196:17 197:13,17,25 198:2 159:17 162:9 167:14,22 166:17 27:13 30:10 31:8,15,18 198:10,13,17,21,23 200:16 causes charge 33:18 34:11 36:8 37:12,17 201:2 105:19 106:1 136:6,8 60:5 181:4 39:5,6 40:23 41:1,2,6,10,12 carondelet 146:12 185:11 charges 92:2,5 99:7,10,11 120:23 200:18 201:4 causing 200:9 201:9,10 157:8 161:6 162:21,24 carried 23:20 47:11 162:24 163:3 chart 165:24 166:6 173:21 cavities 138:4 chlorinated case 136:9 check 4:15,17,19,22,25 5:1,3,13 7:7,8 8:16,17,21 9:15 16:22 center 81:2 82:1683:17 112:1 5:14,21 6:25 7:4,9,12 12:7 30:13 31:15,20 36:12 40:1 167:10 113:23 127:13 161:23 12:24 13:21,25 18:9,24 41:1267:7,13 79:19,23 centers 198:5 43:12,19 49:7 57:16 59:16 80:5,12 85:4 86:15,20 87:4 167:11 checked 60:12,15 61:3,13 62:20 113:16 140:3,6 144:18 certain 71:16,17 94:22 109:14 91:10,11 118:10,10 135:3 160:13 178:25 186:18,24 41:24 42:21 57:18 80:13 153:12,17 137:21 156:3,16,17,17,20 cases 100:15 128:21,22 155:10 checking 156:22,23,24 157:21,25 4:20 8:23 9:3 10:24 16:7 156:3 162:1 165:6 81:5 158:15 159:7,10,13,18,18 30:9 31:8 32:5 33:17 36:11 159:18 160:3,8 161:14,17 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 L EXO L D M O N006862 [chlorinated - consecutive] chlorinated (cont.) clothes 161:23 162:1,2,3,6,7,8,19 45:10,11 162:22,23 163:1,1,11,17 clothing 167:19 184:15,17 43:14 44:1,7,15 45:3,17 chlorine 46:7,8,21,22 47:3,4,7 5:5,5,196:15 11:5 coal choice 5:11 83:1 103:15 coated chronic 140:23 177:2,6 180:7 181:4 191:17 colitis Cincinnati 144:25 145:2,2,3,3,4 74:22 85:10 collar circuit 38:17,17,18,20 1:1 2:1 200:2 collection circular 32:4 32:6 colloid circumstances 130:4 45:17 colon cirrhosis 145:13 138:3,5 color citizens 42:17,21 43:1 146:2,3 181:23 colored city 32:22 1:1 2:1 199:3 200:2 colors claiming 43:5 120:16 173:6 column clarification 92:9 156:12 157:12 129:21 combination clarified 162:11 109:11 combinations clarify 162:18 30:5 combine clarity 147:22 110:11 114:14 combustion claustrophobia 59:1 150:23 comedone clean 4:3,6,6 197:18,18 comedones cleaning 3:25 13:8 14:3,25 29:10,21 77:17 30:7 31:25 32:16,22 33:6 clear 33:11,14 34:3 40:4,6,21 41:7,16 97:1 coming 123:22 124:3 188:11 61:21 129:18 174:7 clearly comma 18:3,18 82:11,11 client commenced 195:22 37:7 clients comment 117:2 120:15 43:7 45:7 100:16,18,19,22 clinical 107:18 184:3 161:5 comments close 87:16 196:18 13:8,10 79:4 147:6,23 commercial closely 61:7 67:11 186:1 161:3 commission 199:28 201:17 commissioned compound (cont.) 199:5 111:2 122:4,14 126:17 commit 128:8 156:9 164:5 185:10 49:11 185:17 committed compounds 49:1,17,22 60:24 6:20 13:21 14:1 57:17,21 common 123:4,15 181:2 4:12 14:9 16:2,18 34:7 77:5 concentrating 77:19,21,23 148:4 communication concentration 102:10 84:19 107:5 communications concentrations 96:15 103:20 communitronics concern 2:15 199:8 172:13,16 192:7 comp concerned 195:23 46:3,5 172:6 companies concerning 63:7 175:20 199:12 company conclude 1:7 2:7 28:2 36:25 41:13 198:3,14,15 50:6 59:22 61:10 65:4 concluded 70:20 71:25 73:3,7,9,15 105:13 106:7 193:23 77:6 79:21 152:4 159:2 conclusion 177:4 182:2,9 188:8 189:6 174:7 184:5,8 198:4 200:5 201:12 conclusions compare 183:2,5,7,9 27:16,18 condition compared 6:24 9:25 10:6,20 11:2,13 123:24 128:18 14:2 15:6,9 20:18 21:8,23 competing 28:8,9 33:17 38:2 42:8 185:19 43:11 46:10,22 47:5 131:14 competitive conditions 63:16 64:19 12:5,8,22 14:8 16:4 43:18 complained 44:14 46:17 59:9 87:19 15:5 144:15,20 153:20 complaining confined 20:18 193:4 complaint conflict 17:6 20:11 22:5 25:16 198:9,10,11 30:21 120:21 confronting complaints 17:14 16:8 81:20,23,24 82:2 confused 166:23 110:7 151:3 complete confusing 34:16 119:19,20 141:2 30:21 106:5 193:24 194:1,2 conjunction completely 26:1 163:2 188:23 57:19 141:3 connect composed 17:20 141:3 connection composition 24:14 93:13 108:25,25 130:3 109:3 111:22 compound consecutive 5:16 26:21 51:23,25 78:13 195:9 83:10 84:15 86:4 90:13,25 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6863 [consequence - deal] consequence 20:20 22:11,21 56:10 135:11 consequences 56:2,5,16 58:6 consider 6:19 43:15 45:15 46:9,20 47:2,6 50:17 52:2,5,7,10 127:25 160:11,15,20 considered 20:19 140:25 161:13 constipation 145:20 consult 36:22 79:21 consultation 37:7 consulted 36:20 consumed 55:8 contact 44:21 87:2 124:9 179:9 193:5 contain 135:6 contained 32:1,7,14 53:23 54:14 55:15 57:6 72:18 88:18 96:19 172:8 containing 4:2 6:7 58:17 59:11 contains 129:2 135:9 contaminant 50:11 contaminants 57:20 88:24 128:17 contaminate 52:13 contaminated 20:17 53:21 56:11 82:13 84:17 88:3,12 89:9 91:10 91:11 97:9 103:18 105:23 110:23 116:5 134:5 contaminating 50:9 contamination 11:1050:1352:10,15 contaminations 132:1 content 6:14,15 contents 57:15 context corresponded custody 188:13 15:23 200:14 continuance correspondence customer 78:9,16 48:7,9 66:7,9,17 continuation counsel customers 3:3 3:2,2 186:20,25 187:1,11 50:1 63:3 64:15 69:21 continue 187:12,17 189:5 199:20,23 175:19 176:17 57:24 58:8 90:22 193:23 counsel's cut continued 85:18 61:24 154:19 1:132:11 3:7 198:24 country cutanea 199:15 181:24 137:2 continuing counts cutaneous 133:21 136:1 15:6 contribute couple cutting 157:17 39:10 109:10 114:1 193:16 64:15 control course cyst 97:1 167:11 29:1 42:6 64:7 65:11 32:4,4,18 39:8 95:7,10,11 controversy 201:10 cysts 199:12 court 31:25 32:14 33:3 94:9 convened 1:1 2:1 48:12 75:20 76:4 97:25____________________ 3:20 80:7 82:4 197:19 200:1,2 conversation courtesy 187:19 83:22 convicted courtroom 178:3,5,6 196:20 197:3 cooked courts 91:15 107:3 143:3 cooking cover 84:21 87:13 106:21 153:12 coordination covered 112:24 152:13 154:14 copies cow 195:15,15,16 197:14,19,20 53:14 copy crash 48:22 196:19 197:14,18 59:15,17,24 60:8,16,22 corner 61:2,12,17 65:22 66:20 155:12 crea cornfeld 3:17 2:24 credence corporation 18:4,19 26:9,11 75:13 76:9 191:16 192:5 credibility correct 21:10 5:8 8:18,19 9:1,4 17:13 criminal 20:1 21:8 23:22,23 27:24 173:7 29:5 33:11,16 35:25 36:4 critical 38:1641:1846:1965:11 182:2 69:25 72:3 73:4,5 79:16,17 criticized 89:16 91:16 92:17 93:25 182:9,14 94:24 97:19 98:3 99:14,17 crop 100:10,23 103:5 106:14 53:4 113:18,19 118:13 127:2 crossing 129:23 132:5 134:23 139:5 132:14 144:16 151:15,16,25 crying 160:10 161:7 163:15 150:21 171:20 177:7 180:18 182:5 cure 199:16 111:12 d d.c. 169:22 daily 85:6 87:16 danger 58:18 data 109:6 176:5 185:21,23 187:23 date 24:23 25:8,13 42:24 49:15 50:20 74:19,19 76:14 105:18 110:12 158:4,17,24 159:8,14 170:2 dated 72:9 189:16 dates 40:8 49:13 50:21 51:17 74:13 191:14 david 2:25 day 2:14 46:21 47:3,8 62:14 74:7 92:20 193:22,24 194:1 194:2 195:8,23 201:16 days 43:19 78:15 177:19 192:20 195:9 196:21 dayton 60:9 ddt 67:8,13 68:24 deal 27:6 167:9 180:2 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 L EXO L D M O N006864 [dealing - disintegrated] dealing 192:1 death 162:20,25 deaths 67:14 debate 87:2,17 december 15:4 decided 193:21 decision 65:24 174:20 175:11,15 177:5,8,10,14,16 183:13 decisions 67:10 decrease 100:14 142:12 deep 34:3,10 defendant 1:8,14 2:8,12,25 3:3,15 200:12 define 5:25 102:13 157:2 defined 108:5,20 136:22 defining 102:8 definite 68:16 132:3 151:5 187:16 definition 4:9,12 5:198:10 117:9 132:25 151:6 definitions 102:8 108:20 109:11 degeneration 137:23 degrees 85:13 delineation 139:12 140:17 delivery 201:8 depart 179:6 department 48:5 69:8,10,18,19 85:8 169:18 175:7,20 177:17 178:16,17 179:21 188:24 departure 60:14 179:14 depend 53:15 depending details diminishing 58:15 117:7 174:3 178:2 195:17 depends determination dioxin 4:235:9 9:22 10:16 11:4 97:2 123:8 13:331:5 43:1746:11 determine dioxins 47:10 52:12 56:13 57:21 22:25 23:12 86:1 87:7 55:24 70:24 158:18 88:22 127:18 157:7 diphenyl deposes determined 5:2 43:12 156:8,17,17,20 3:15 167:14,22 174:12,16,18 156:22,24,25 157:21 158:1 deposition determining 158:15 159:7,10,13,18,19 1:132:11 3:3,6 29:3 48:14 23:2 160:8 161:15,17,23 162:2,3 78:9,17 79:4,15 80:9 82:6 develop 162:6,7,23 163:1,1 184:15 82:23 83:4,19 102:19 60:11 64:5 153:9 184:17 178:19 183:21 193:22,24 developed direct 194:3 195:9,12 198:24 3:25 11:24 38:14 40:23 26:16 28:16 199:15,16,21 200:9,11 60:14 162:20 directed depositions developing 18:14 22:18 25:4 47:1 76:6 63:1378:1679:1880:11,15 63:16 64:20 76:11 164:9 172:12 185:4 81:9,12,24 85:23 87:10 development directly 117:4 120:7,11 183:18 66:18 6:13 196:22 deviation director depressant 43:15 18:7,22 36:20,24 151:14 35:23 devoted 152:3 177:4 depressants 71:19 disagree 35:20 diabetes 20:13 171:16 depression 134:16 disagreed 150:15 diamonds 169:10 dermal 5:11 discarded 189:6 190:18,22 191:5 dibenzofurans 7:19 dermatergosis 19:8 91:10 discharge 39:20 dictated 131:10 dermatitis 48:24 discoloration 6:19 differ 95:17 dermatologist 123:20 discontinuing 47:24 differed 68:18 dermatologists 34:1 discovery 37:16 difference 85:3 describe 51:23 87:1 107:8,19 121:16 discuss 4:3 21:24 24:15,20 25:5,9 122:16 123:21 135:3,16 26:13,14 106:25 179:14 34:13,14 36:10 39:10 42:25 141:9 discussed 45:4 49:14 53:5 68:9 74:25 differences 33:3 39:16 41:12 138:7 75:11 76:7 42:17 127:12,18,21 128:12 discussing described 128:16,25 129:6 168:4 3:21 5:148:8 9:1629:11 37:10 different discussion 42:21 49:15 54:16 59:24 5:1,12 57:17 60:21 65:16 47:19 84:3 155:8 156:12 66:20 70:21 166:18 70:13 101:23 102:11 107:6 189:15 198:7 describes 108:3 124:11 128:9 168:11 discussions 8:1761:12 168:25 169:8 171:23 184:1 description 179:19,20 192:1,2,2 disease 9:17 29:12 146:25 difficult 6:13 117:19 130:12,13,14 descriptive 55:4 195:4 130:14,16 167:11 32:24 difficulty diseases detail 6:10 130:17 29:13 88:20 diminished disintegrated detailed 120:4 57:19 8:23 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6865 [disk - employee] disk documents (cont.) drive effective 118:2,4 155:3,5,10 182:7 195:14 15:17 142:6,7 disks doing driver's effectiveness 118:4 39:22 61:25 64:14 67:21 153:15 142:3,12,23 dismissed 107:18 174:1 190:9,10 driving effects 26:7 dollars 129:9,15,17 195:11 68:25 107:1 132:13,22 disorder 73:24 dropped 143:7 156:16 157:2 161:25 147:12,16 domestic 114:19 162:10,15 176:25 177:1,2,6 disorientation 15:22 drug 180:7 181:7,12 192:8 146:21 147:9 donahue 49:16 59:25 61:4,12,16 effort disoriented 2:23 62:1863:19 143:11 174:10 71:18,1881:10 194:15 147:11 dose 174:11 175:19 188:24 eggs disposed 31:6,7 128:5 135:14 189:20 ducks 69:1 72:4 189:22 190:9 eight disputing doses due 2:13 176:1 195:14 108:1,2 125:2,2 189:21 6:13,19 9:12 10:23 15:22 eighty disseminated double 17:3 19:7 21:14 136:25 80:15 81:14 155:3 55:24 59:2 111:14 112:1 161:23 dug either distinguishes doubt 54:2 14:14,23 23:10 48:1 81:21 85:19 69:12 156:15 179:22 duly 160:1 172:1 177:12 178:9 distribution 194:25 199:5,10 elaborate 29:11 34:4 dow duplicate 86:13 disturbance 175:19 81:10 elected 136:7 dr dupont 179:6 division 3:18 7:10 16:25 17:1,5,8,10 175:19 electric 59:18,19,21 60:5 175:8,9 17:14,21 18:1,6,16,21 e 177:19 179:20,21 divisions 59:22 dizziness 146:17 doctor 7:48:21 17:18 20:19 21:16 23:1227:13 30:6 31:17 32:19 38:13 39:11 42:17 44:18 47:18 75:20,25 83:7 88:8 106:2,13,19 108:7 109:6 110:17 115:18 118:5 121:6 122:3,7,13 124:15 127:11 133:7,9,11 134:22 135:15 138:8 140:7 141:4 143:17 144:6 154:11 155:9 155:17 161:12 164:2 165:5 165:21 167:3 173:5 doctors 16:13 81:23 87:8 doctor's 198:10 document 19:14,15,22,25 20:23,23 ear 21:1,5 22:2,4,24 29:7,25 92:5 30:15 35:3,5 36:6 39:15 earlier 41:19 42:6 43:24 44:5 21 14 29 3 414 125 25 45:25 47:20,22,25 48:2,7 early 48:16,20 57:5 59:5,12 65:3 43:19 193:21 194:8,10,13 67:2 69:4,15 72:25 73:3 19415 78:7,8,15 79:17 80:11 82:3 ears 83:12 84:4,11 85:3,11 86:2 1011 11823 86:5 87:5,13,20,25 88:14 easily 88:18,25 90:17,19 91:3 995 96:17,24 104:20 107:8,11 east 107:16 108:4 109:24 154:7 110:17 115:20 123:15,22 127:19 129:7 140:20 easy 110:16 142:21 151:11 152:22 eat 154:22 155:7,21 157:12 144:22 161:2 163:4,4,5 169:12,16 eating 169:20 170:6,12,19 171:3,7 171:13,15,15,24 172:4,19 85 18 87 1 106 9 121 4 141:16 172:25 178:18,19,19 eats 180:22 182:1 188:7,11 53:14 189:4 190:7 191:14 193:17 prlitnrial 39:19 80:18,19,21 81:3,16 82:8 83:15 84:11 110:18 115:22 126:13 156:1 documented 18:3,18 19:20 26:15 documents 42:20,25 66:19 154:23 195:16 196:3,6 drink 122:24 drinker 161:20,20 184:14 drinking 124:10 1843 6ff6Ct 8:9,9 10:21 16:11 106:25 107:13 143:15 163:18 effected 30:19 75:13,15 76:9,13 191:15 192:4 electrical 62:7 elements 5:3,7 32:8 elevated 137:10,13,15 193:3 eliminate 62:1 86:4 eliminated 65:6 elimination 6:21 7:14 143:13 elmer 177:22 else's 63:4 emmet 1:132:11 3:1382:6 157:12 157:14 199:9 200:11 emotional 67:12,15,18 emphysema 99:3 employ 177:14 employed 8:18 170:13 199:20,23 employee 173:13 199:22 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 L EXO L D M O N006866 [employeed - exposure] employeed epilepsy (cont.) 188:12 106:1,6,7,8 108:13 emptying episode 145:9 146:15 147:20 encouraged eppeley 50:25 169:13 ended eppenberger 190:8 191:7 2:23 200:17 201:3 endings equate 132:22 133:12,16 58:2 124:2 ends equating 34:17 123:14 133:2,5,6 185:25 engaged equipment 43:12 77:18 england equivalent 186:1 139:21 enhance error 142:4,12 143:6 104:10 156:20,24 161:22 enormously errors 58:4 79:16 enter eruption 125:5 7:12 9:4 33:25 36:12,13 entering 38:1,1,11 51:5 122:15 eruptions entire 9:7 157:23 158:12 67:4 188:21 escape entirely 49:3,12 51:1 61:25 5:1 107:6 168:23 179:19 esophagus entirety 94:1,3 125:12,18 140:1,10 66:21 especially entitled 43:11 157:20 85:3 essentially entry 26:15 59:15 85:17 121:8 123:13 establish environment 75:8 184:20 23:1749:3,12 50:9,9,11,14 established 50:14 51:1,24 61:25 176:22 50:18 103:24 165:8,9 environmental 176:14 52:21,23 68:25 167:11 estimation environments 188:20 153:21 et enzyme 1:4 2:4 87:17 97:1 137:21 7:22 126:3 142:2,11,22 200:5 143:6,7,13 europe enzymes 4:14 7:16,17 125:22 126:1,6 evaluate 137:25 138:2 142:9 56:7 121:2 enzymologist evaluation 126:1 56:22 152:6 epidemiological eventuality 111:23 163:23 164:4,12,16 58:24 epidemiology eventually 167:10 51:22 epilepsy everybody 100:24 102:22 103:2,5,18 29:17 56:13 64:2 83:6 105:11,11,12,16,17,18,24 evidence experience 85:14 88:14,17 90:16 12:8 25:23 103:2 163:17 exact 175:21 176:1,15 192:25 51:3 experienced exactly 24:21 25:7 40:15,22 41:9 8:1 13:9 22:14 44:20 91:16 161:6 164:23 165:13 109:17,23,24,25 124:22 experiences 159:15 162:21 186:3 11:2 35:16 exaggerated experiment 89:24 90:1 71:13 168:8 examination experimental 3:16 16:24 19:11 21:22 71:13 22:3 26:17 27:5 29:1,8 experimentation 34:15,17,21,23,24 36:6,7 157:19 37:18,24 42:12 153:5 experimented 154:13 165:10,10,11 70:16 71:6 199:14 experimenting examinations 70:11 71:21 37:10,12 152:14 experiments examine 70:21 156:15 167:13 87:6,15 96:21 111:4,20 expert 154:7 46:15 143:2 examined expertise 2:12 3:14 13:11 28:21 173:7 38:12 87:5 154:6 161:3 experts 199:13 28:22 84:18 87:4 examining expires 28:4,12 152:15 164:25 199:28 201:17 example explain 31:14 11:8 29:12 34:5 53:17,21 excellent 56:1,10,23 63:19 66:1,3 168:24 169:3 176:2,15 89:6 105:18 168:2 179:5,24 exception explanation 7:21 19:24 26:17 52:22 excluding explosions 11:11 131:1 85:6 87:16 excretion exposed 125:20 3:25 10:14,17 11:5,5,6 excuse 19:21 20:17 28:2 30:25 42:11 59:14 73:22 101:1 40:7,16 44:21,24 45:22 138:17 189:14 46:6 56:19 75:3,6,9,12,18 exhibit 76:8,18,20,23,25 77:8,9,10 3:21 39:1648:13,14,17,23 77:11,12,13,16,17,25 86:21 59:13 68:9 72:8 80:8,9,25 124:9 135:8 153:22 154:3 80:25 81:18 82:5 84:12 163:10 88:9,21 110:13 115:21 exposure 144:17 151:11,12 152:1 6:25 9:7 11:3 12:6,23 13:20 155:11,16,22 167:4 189:5 13:25 17:4 18:1,8,16,23 exhibits 20:20 21:7,12 22:12,21 155:19 195:15 196:18,19 23:1 24:7,12,13 25:23,24 196:24 197:1,2,2,5,20,21 26:1,3,18 29:4 36:14,15,16 exist 44:24 45:2,4,13,23 56:21 43:3 97:5 57:22,23 82:13 84:16 88:2 existed 89:9 96:5 97:9,12 102:3,25 49:15 103:25 105:9,12 107:14 110:22 116:4 118:3 135:11 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6867 [exposure - flew] exposure (cont.) facts feelings findings 141:15 147:2,2 192:10,12 45:20 46:14 55:4 56:24,25 168:22 19:12 35:4,7 69:20 147:4 extend 134:14 135:13 feels 182:24 183:2 69:6,16 195:18 factual 23:25 107:17 finds extender 46:16 85:19 fees 21:25 69:8,22 fahrenheit 173:16 186:7 fine extending 85:13 feet 3:19 8:16 22:6 37:6 40:20 29:8 failure 94:16,17,20 112:22 65:13 83:17 105:6 166:11 extensive 45:15 felt 166:25 170:2,4 186:21 58:4 157:23 158:12 fainting 22:2,11,20 23:5,9 37:6 finger extent 146:22 50:21 166:11,25 192:6 114:18 45:22 135:25 147:2 186:22 fair fever fingernails extinguish 14:24 30:19 31:3,12 39:11 97:25 143:12 98:23 85:9 86:6,10 146:5 196:25 fewer finish extra fairly 33:6,12,14 170:11 20:10 102:18 194:24 196:19 9:18 32:18 field finished extremely faith 53:6,9,25 54:3,5,23 55:8 121:10,13 122:8 173:23 69:11 81:10 62:7,8,12 177:15 178:12 190:22 extremities falsified fields fire 133:6 187:22 65:2 55:1,21 56:2,12 57:14,17 extremity falsifying fifteen 58:4,6 59:1,7 85:8,10 114:19 177:25 178:4 81:15 166:3 fires eye familiar fifth 77:13,14 85:7,9 129:14 130:2,12,13,14,16 71:9 170:4,19 179:2 firm 130:18,19,23 131:1 153:10 family fifties 2:23,26 31:25 200:14 eyelid 4:21,22,24,25 73:17 74:19 first 114:20 130:14 131:1 far fifty 3:23 7:18 9:16 19:5 20:14 eyelids 46:3,5 108:17 172:5 177:13 24:6,12 25:24 26:3 41:24 30:20 45:6 48:25 49:4,9,17 119:6 130:24 197:9 65:16 82:1,25 84:9 89:3,5 54:2 56:12 84:6 89:1 95:20 eyes farm 112:2 98:13 112:4 125:19 140:4 10:10 119:4,5 121:5 130:10 53:3,4 figure 144:18 148:11,14 155:14 131:3,6,9,10,10 farmer's 196:16 156:1,14 171:6 175:6,9,24 eyesight 52:22 53:6,24 54:3 figured 196:23 199:10 119:16,19 fast 37:6 firsthand f 56:14 122:12 face 9:17,25 13:18 15:2 38:11 102:19 facility 7422 fact 17:15 19:1920:5,1621:11 22:25 23:20,25 30:6 40:1 46:16 50:17 65:3 69:4 86:4 86:7 90:17,25 120:9 140:19 142:22,25 143:1 161:21 163:4,7,8,8,9 169:5 178:14 182:1 factor 11819 14017 factors 45:23 58:14 59:4,5 175:14 175:17 factory 168:7 faster 90:23 fat 7:22 140:23,24 141:1,3 fatigued 26:18 fatty 137:23 140:21,22,25 favor 201:1 favorable 40:19 feature 71:3 feed 54:18 feel 19:22 21:19 37:11 40:20 130:20 176:4,18 feeling 28:12 37:5 40:19 168:23 figures 90:18 101:19 53:22 192:3 fish fill 176:22,23 84:9 85:2 165:7 five filled 2:1425:11 41:24 80:15 58:5 81:14 82:24 120:1 140:13 filling 175:25 77:10 78:3 84:23 87:22 fix final 189:24 188:16,19 189:16 flaking financially 34:9,9 199:24 flammable find 56:6 58:17 14:24 15:1 16:10 20:7,12 flat 20:14 22:7 24:18 59:16 17:8 61:2 68:14 109:15 119:2 flaw 132:9 133:17 141:11 147:3 102:14,15 149:25 150:9,16 168:6 flaws 171:2 176:25 168:6,9 finding flew 136:2 146:15 148:3,25 170:14,15 172:4 189:19 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOO6868 [florida - good] florida formed 71:10 55:22 57:21 fluid former 58:1865:13,14 33:2 fluids forty 55:21 64:4,5,25 65:7,10 81:12 82:1 85:23 163:16 135:5 forward flushing 18:9,24 77:12 95:15 found focus 51:2 156:21 162:5 184:24 120:22 foundation folks 179:9 37:19 four follicle 38:10 56:19 57:2 59:21 13:6 95:9 79:10 92:19 105:1,16 follicles 112:13 124:21 128:9 13:7 140:13 146:18 follow fraudulently 175:1 172:20 following frequent 78:1682:15 114:10 152:9 146:10 food freshly 49:16 51:3,5,8,18,18,19,20 43:14 44:1,6,15 45:3,16 51:21,24 52:3,10,24 59:25 46:21 47:4 61:4,12,16,23 62:18 63:19 friday 139:9 174:9,11 175:19 198:4,6,14,19,20 188:24 friends fooling 61:20 189:21 front foot 33:15 39:17 121:4 94:22 full forced 3:23 144:19 194:19 67:8,19 68:12 fulminans forearm 14:19,19,20 33:10,18 fulminating forearms 14:21 33:5,8 functions forehead 14:3 29:8,18 fungi forenoon 94:22 2:14 furan forgetting 88:12 132:1 132:19 furans form 56:2,11,20 82:14 84:17,18 26:20 55:24 82:20 84:13,24 84:19 85:12 86:22 88:3,24 85:2,22 86:5 88:6 111:2 89:10 90:4 97:10 99:24 126:19 128:7 129:2 133:20 103:19,20 105:24 106:1,9 134:8 139:10,18 144:2 106:23 107:4,6,7 110:23 160:22 164:5 165:7 172:7 116:5 121:25 123:5,7,9,11 173:11 123:19,24,24 139:4 formal furnish 42:10 180:17 193:21 169:25 format further 82:21 83:9 84:10,22 87:21 84:12 87:5 93:12 101:21 formation 149:2 199:19,22 33:3 38:1 130:5 future glad 49:2 169:25 g gland gain 141:6,8,12,18 144:9 165:23 gained 141:14 153:3 gait 113:1 gallons 53:23 54:7,17,22 55:7,15 gamut 28:13 gap 102:10 gastrointestinal 4:7 6:3,5,5 glands 6:22 7:15 8:4 glass 149:12 glasses 153:11 glaucoma 119:14 glenn 1:4 2:4 200:5 globe 130:23 6:21 gateway 201:12 gee 119:23 general 4:21 16:24 19:12 21:19,20 21:21 22:3,4 34:4,17,21,23 37:15 45:9 117:5,8 generally 30:19 44:9 73:25 generate 42:1 gentlemen 47:18 george 174:8 177:21 georgia 17:11 39:25 getting 50:8 51:3,23,24 63:11 64:2 66:9 67:21 68:2,16,17 92:23 124:10 154:10 195:4 give 18:4,1921:1046:14,15 50:1 52:23 54:25 70:25 88:18 107:15 109:16 111:14,22 117:11 134:15 140:12 141:25 143:18 155:7 170:2 185:15 188:20 192:3,13,17 195:15 197:13 given 33:2 56:24,25 63:13 87:23 107:24 112:14 135:13 146:21 195:15 196:7 197:1 199:17 gives 8:22 9:2,17 giving 61:11 82:22 172:21 go 8:20 23:1 24:17 30:23 57:18 65:18 80:22 82:16 83:16,23 84:1 90:5,8 91:21 102:21 104:17 108:16 120:20 148:10 152:10 153:7,15 158:20 160:7 177:17,18 178:10 179:6,12 189:1 193:13,16 196:15 197:11 198:4,14,19 god 159:19 goes 28:13 34:8,13,14 36:17 124:20 125:10,19 151:4 going 6:23 7:6 11:22 16:13 18:10 20:25 26:20 27:14 28:6,18 29:7,23 44:17 45:19 49:24 51:24 53:20 57:23 61:24 62:19 63:24 64:4 72:23 73:12 74:3 75:19,24 81:1 81:19 82:21 83:3 84:21 86:13 87:3,9,17 90:8 95:11 101:4 102:13 111:7 115:6 116:22 120:8 125:7 132:24 140:12 142:13,24 143:8 146:20 152:8,15 155:9 158:20 159:1 160:21 161:23 164:1,20 173:4,11 174:15 177:23 178:22 179:7 180:2 182:12 186:21 189:1,2 191:18 193:19,22 194:2,6,6,11,24 196:3 198:18 gong 128:7 136:11 good 3:20 16:24 21:19,20 22:4 27:4 31:6 61:20 65:12 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6869 [good - hydrocarbons] good (cont.) hand hearsay 81:10 89:6 143:14 165:22 67:6 80:19,20 82:4 122:24 173:18 169:5,6 174:4 187:10 124:9 149:3,5,8 155:17 heart gordon 193:19 199:26 201:16 34:24 131:12,17 133:19 169:16,17,21 handed 134:1,2,7,11,12 gore 196:23 heating 201:12 hands 85:4,9 gosh 94:17,25,25 101:1,2 110:18 heavier 37:22 110:24 112:4,5 114:24 103:19 gospel 117:15 heavily 176:2 hanging 88:12 gout 21:16 140:24 heavy 136:3,4,6 hangs 4:1,2,8,11 6:7 84:19 86:22 government 141:2 88:24 99:24 121:25 123:5 64:8 160:13 167:7 172:21 happen 123:19 176:3 181:21 185:16,21,22 101:9,13,14,16 103:22 held 185:24 188:24 105:2,4 84:3 107:1 155:8 189:15 great happened 197:1 198:7 10:1921:1427:6 30:16 105:7,7,24 136:1 183:16 help 167:9 happening 50:11 79:23 111:12 161:4 green 21:17 helpful 146:4 hard 80:4 ground 25:15 35:11 68:14 119:23 helps 25:2 53:12 71:15 101:21 hastened 88:19 104:11,14 114:6 116:23 90:2 hemorrhoids 149:1 hay 145:20 grounds 53:10,14,20 54:18 55:8 hepatitis 71:9 88:7 143:9 164:6 head 136:24 137:1 138:7 group 21:3 60:2 153:8 191:25 hepatoma 59:20 61:8 62:22 103:15 headache 138:9,10,13 154:13 92:19 herb groups headaches 61:20 63:15 64:18 72:9 97:1 92:18 120:17 153:8,9,10 73:1 growth heading herbert 95:19,21 156:12,14 39:24 48:2,3 guess headlights hereto 13:14 67:20 77:5 141:7 129:8 199:23 180:3 194:4 heal hereunto gullet 99:5 201:15 125:13 healing hexachlorobenzene gums 39:9 4:18 93:2,3,6________________ health hey h h.g. 47:25 habits 89:22 hair 13:6,7 95:8,19,21,23 hairline 29:9,15,17,22 30:7 half 3:25 124:20 182:8 194:2 halogen 6:14 16:25 21:20,20 22:5 48:4 52:6 56:1,5,10 80:13,13 81:8 82:24 87:13 107:14 167:11,12 hear 74:12,12 90:22 133:4 148:13 183:25 heard 38:25 70:9 71:12,24 72:1 136:4 150:24,25 171:6 186:8 hearing 92:3,8,8,16,17 107:23 195:23 185:19 high 93:9 134:18 151:20 higher 107:5 highest 175:18 highly 182:2 hindsight 159:21 histories 26:5 history 8:16,21,23 11:8,15 13:20 13:25 16:8 23:4 25:10 28:20 29:1 hit 148:10 149:19 hives 97:20,21 hold 167:23 honest 181:18 horrible 20:18 horse 53:14 hot 57:17 67:7,17 78:4 hour 124:20 193:14 194:20 hours 2:13 43:13 44:1,6,15 45:2 45:16 56:19 57:3 124:21,21 193:16 house 21:17 housekeeping 43:22 howard 60:3 how's 186:21 huh 92:12 190:25 human 52:24 157:19 hundred 53:23 54:7,17,22 55:7,15 60:21 67:14 79:10 82:25 84:9 85:12,12 120:3 195:13 hundreds 127:17 hung 165:5 hurrying 119:10 hurt 142:5 hurting 50:16 husch 2:23 200:17 201:3 hydrocarbon 4:22 5:5,14,17 hydrocarbons 12:7,24 18:9,24 156:4 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMON006870 [hydrocarbons - inorganic] hydrocarbons (cont.) importance 162:1 21:22 22:4 27:5 34:18,22 hydrogen important 5:5,18 27:9 83:14 104:15,15,16 hypertension 152:21 93:8,9 impression hypothesized 60:4 128:21 45:24 improbable 118:1 i.b.t. 172:19,24 173:9,14,23 174:6,13,20,21,22,25 175:3 175:12,16,23 176:5,7,8,13 176:15,21 177:5,9,11,12,15 177:23 178:1,11,12 179:2,6 179:12,15,17,23,25 180:5 180:14,20 181:2,7,10 182:3 182:10,21 183:5 184:20 185:13 188:5,14 190:5 192:6,14 193:2,6 idea 21:1 47:17 54:25 60:18 85:22 146:3 identical 31:9 122:4 identification 48:15 80:10 identified 4:16 154:23 identify 48:16 ignited 55:21 57:17 iii 1:12 illinois 154:4 173:10 illness 23:16 163:3 imagine 62:8 171:14 immediately 45:13 immune 150:11 impact 49:9 implement 50:4,7 implemented 49:18,22 50:6 60:23 implications 50:24 implying 101:5 improper 86:17 112:17 improve 142:22 improvement 43:22,22 improving 15:7 impurities 42:18 163:18 impurity 157:25 158:14 159:6,17 163:10,14 inability 126:11,12,18,18,20 inaccurate 81:4 incidence 116:10 incident 91:23 134:5 137:8 145:17 incidents 85:10 114:9 incise 39:8 incision 39:9 include 4:24 28:20 35:14 119:9 127:3 130:24 147:7 156:5 included 162:8 includes 81:14 156:6 including 74:23 164:4 inclusive 158:23 incorporated 81:15 82:8 increase 74:1 100:14 incrimination 179:3 independent 88:15 168:11,17 174:17 185:14,25 indiana information (cont.) 2:27 74:18 104:14 195:12 72:18,19,19 77:3 89:18 indians 92:10,15,21,25 93:18,19,21 4:25 93:24,25 94:8,21,23 95:16 indicate 95:24 96:3,18 97:18,24 9:24 11:3 42:18 43:4 98:1,2 99:2,16,17,25 indicated 100:11 101:3 107:24 108:7 3:22 17:22 46:1 84:18 108:8 109:20 110:25 96:18,21 102:22 106:19 111:17 112:6,9,19 113:8,23 107:19 117:6 120:13 149:2 114:7,22 115:17 116:7 193:15 126:12,14 133:25 134:3 indication 147:10 150:4,5 165:23 9:20 10:14 11:9 105:2 166:5,8,21,22 174:13,24 108:12,15 175:2,3 183:21 192:17,21 indicative 192:23 196:7,10 37:11 informed indicted 61:3 172:20,25 173:3 177:25 infrequently 186:12 187:20 153:20 indictment ingest 178:2 123:13 indigestion ingested 93:16 52:17 121:7,17 122:5,14,16 individual 123:16 125:6 128:6,17 8:25 11:1 19:20 27:8 40:1 ingesting 58:15 75:13 76:9 105:16,17 106:23 113:16 144:14 161:12 ingestion 167:8 170:8 177:17 191:15 85:15,18 105:5 108:10 192:4 114:10 130:21 131:25 individuals 139:4 144:7,22 146:15 36:8,19 37:8 41:8 51:6 150:9 151:1 59:23 74:5,18,21 165:25 ingrown 175:21 182:8 98:8 120:16 inducer inhalation 126:3 192:20 induction initially 137:25 142:2,11,22 143:6,7 10:7 143:13 initials inductions 8:25 72:17 138:1 initiated industrial 59:17,23 61:2 79:11 153:21 173:10,20 initiating industry 61:17 18:4,19 inject infected 17:23 4:6 6:8 13:5,8 14:6 92:5 injection 95:7,10,11 97:24 99:7 132:4 infinitesimal injury 123:23 26:5 150:11 inflamed inkling 131:3,9 174:3 inform inner 61:1 33:9 information inorganic 51:10 61:11 62:25 63:2,20 175:9 64:4 66:13 70:23,25 72:14 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6871 [inquire - knew] inquire 161:8 187:15 inquiries 72:10 inquiry 37:2 53:18 56:23 inside 20:23 21:2 30:7 92:5 insignificant 31:13,14,19 insomnia 147:22 instance 12:7 30:16 94:2 instances 16:18 127:17 institute 169:13 instruct 28:7 84:22 instructed 47:14 instruction 87:20 insure 58:23 intake 125:3 139:7 intend 87:6,15 196:24 interested 49:1 61:22,22 199:24 interim 78:17 interior 33:6 intermission 195:7 intermittent 134:14 interpret 96:4 interpretation 21:24 24:20 25:6 26:10 109:5,5 168:10 169:11 interrogatories 80:1 81:22 intervals 166:19 interview 40:11,12 42:2,4,10,14 195:22 interviewed 40:1,6,10,14 41:8,17,22 105:10,15 166:14 interviewing j jury (cont.) 166:17 jack 178:3,6 179:5 188:11 intestine 39:24 k 140:23 141:2 intestines 140:11,21,21,25 introduce 50:25 invented 4:20 investigate 169:4 investigation 174:17 involve 15:10 involved 7:7,15 33:1 34:5 101:20 140:18 148:24 180:6 involvement 10:21 11:19,25 15:1023:21 irish 4:24 iron 79:9,9 irregular 134:6,11 irritability 150:1,3,7 irritable 150:10 irritant 8:9,10 10:20 irritated 130:10 131:6 150:6,7 irritation 7:13 8:12,13 9:12 90:6 91:4 91:17,18,19,24 107:23 152:9 153:7 irvine 47:25 isolated 28:23 69:12 italians 4:24 itch 14:5,6 itched japan 86:23,25 101:15 121:25 123:25 128:18 129:1 131:20,22 japanese 18:2,17 29:4 84:17 86:22 88:10,15,23 90:15 91:9 99:23 103:6,19 105:23,25 106:9,22 107:3,3,10,21 114:11 118:6,7,9 119:3,13 121:24 123:4,18,24 125:11 126:25 128:13 130:9 131:15,16,25 134:5 137:8 137:20 139:4,4,8,21 141:16 141:16 145:17 146:16 150:9 151:1 jaundice 162:20,24 jenkins 2:24 jittery 148:8,11,14 job 179:15 jockstrap 14:5,6 joe 179:17 joint 113:22 114:2 136:8 joints 115:25 jones 16:25 17:1,5,11,14 19:15 19:22,25 20:24 21:1,5 22:2 22:4 29:25 35:3,5 39:24 41:20 42:6 157:10 158:7 159:24,25 160:14,20 163:4 journal 91:22 171:12 186:2 judge 178:7 juggle 155:18 july kanechlor 91:9 131:15 keep 58:19,25 59:7 64:4,7 122:11 197:18 keeping 61:23 64:8 kelley's 123:23 kelly 1:132:11 3:13,187:10 17:8 17:21 18:1,6,16,21 19:14 20:23,23 22:24 29:7 30:15 36:6 39:15 43:25 44:5 45:25 48:2,16 57:5 59:6,12 65:3 67:2 69:4,15 72:25 73:3 78:7,8,15 79:17 80:11 82:3,6 83:12 84:4,11 86:2,5 87:5,14,20,25 88:14,18,25 90:17 91:3 96:18,24 104:20 107:8,11,16 108:4 109:24 110:17 115:20 123:16 127:20 129:7 140:20 142:21 151:11 152:22 154:22 155:7,21 157:12 161:2 163:4 170:19 178:18 178:19 182:1 188:8,12 189:4 190:7 191:14 193:17 195:16 196:3,6 199:9 200:11 kelly's 85:3,11 90:19 kidney 92:22,24 109:21,21 145:6,7 145:8 kill 69:6,17 70:22 79:5,8,10,11 kimbrough 167:4,5,6 171:13,17 172:4 kimbrough's 170:12 171:3,24 kind 83:5 84:10 92:23 93:22 97:2 109:21 114:17 148:19 179:17 181:4 10:12 itching 10:13,18,20,25 11:2,8,8,13 11:16,19,25 30:24 31:1 item 27:8,20,23 ivy 11:1230:17,2331:1,6,7 199:27 june 1:15 2:13 82:6 158:4,6,9,20 165:23 166:9,14,21 199:28 jury 21:24 24:20 25:5 29:12 30:2 32:9 33:7 34:6 49:4,14 74:25 83:6 135:2 174:19 kinds 100:15 kingshighway 2:15 199:8 knees 99:8 knew 28:19 63:10 64:14 65:6 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6872 [knew - line] knew (cont.) know (cont.) lassitude (cont.) 72:20 75:17,17 76:17,17,24 175:4,5,9 176:23 177:13,20 36:1 37:3 160:16 161:9 77:1 163:16,19 177:18,22 177:20,21 178:2,5,6,7,9,21 163:6,23 164:12 165:14 know 178:23 179:16,17 180:5,9 lasted 4:11 5:23 7:17 8:1 10:4 180:10,11 181:2,3 182:13 112:7 116:9 12:4 13:1 14:2,21 16:21,22 183:2,10,17,17,24 184:17 lasting 19:1,18,18 20:2,3 21:2,4,7 184:22,23 185:9,16 186:6,8 92:20 21:17,1822:8 23:1225:10 186:10 187:4,7,14 188:6,8 lately 25:11,23 26:2,10 27:1,11 190:4,6 191:10 192:11 73:12 27:15,16,17 29:14 30:1 195:5 196:2,6,10 197:21 laundered 31:16 35:5 36:19 37:4 knowing 43:14 44:1,7,15 45:3,17 38:24,24 39:25 42:23 43:3 49:1 57:25 46:22 47:4 44:20,21,23,24 45:7,21 knowledge lavinskas 46:1247:10,15,18,21,22,23 24:22 25:7,13,13 40:17 170:16 174:8 177:21 48:1,1,949:13,18,21 51:2,3 42:24 43:2 44:18 69:9 law 56:4 57:25 58:6,9 60:2,13 70:10 88:15 89:15,17 90:18 2:23,26 143:1 173:7 60:14,20,23,24,25 61:10,15 101:19 106:19 107:9,20 lawful 61:19,21 62:6,12,21,24 199:11 3:14 63:9,21,25 64:2,9,12 65:1,1 knowledgeable lawsuit 65:19 66:5,6,7,10 67:4 68:2 169:20 17:22,23 81:23 143:2 68:5,7,15,23 69:23 70:16 known lawyer 70:17,18 71:1,7,14,24,25 24:9,10 63:7 143:17 180:8 173:5 72:4 73:11,14,20,22 74:5 knows lawyers 74:10,17,21 75:5 76:22 28:11 29:17 159:19 30:2 77:1,7,7,22 80:1 81:4,25 koppers layman 82:21 87:3,12 88:19 89:22 72:3 4:4 89:23 91:17,19,24 92:4,5,7 1 92:7,8 93:3,15,16,21,23 94:18,21 96:1,17,20 97:23 98:7,15 99:6,9 100:3 101:20 103:17 104:11 106:10,21 107:23,23 108:4 109:13 111:8,10 112:10 113:12 114:1,6,19,21 115:11 116:23 117:12 118:17,24 119:8,11,22 120:6 122:9,20 123:2,3 124:24 125:4,16 126:9,22 127:11,14,20 128:10,12,16 label 79:5,8,12 laboratories 185:19 laboratory 19:11 23:24 157:18 161:4 167:8 173:20 174:23 175:18,21 176:10 180:3 185:18 186:1 laced 99:23 103:19 leading 125:13 leads 168:20 leak 54:10 leaked 54:9 leaking 55:10,11 leaks 53:12 54:20 55:15 77:11 leave 128:24 129:10,13 130:7,14 131:2,13 132:11 134:9,10 134:11,12,13 135:2,23,24 136:2,15,16 137:8,13 138:5 341 91 6 19223 23 large 32:18 62:4,5,11 63:5,11 6412 138:15,23 139:6,12,24 140:16,18,22,25 141:8,9,22 142:9,25 143:2,9,15 144:11 144:12,23 145:3,11,14,16 145:19,21,25 146:4,9,12,24 147:18,25 148:1,7,16,22 149:5,11,14,14 150:5 151:8 largest 166 larry 195:24 lass 164:13 156:15 179:12 leaves 45:20 110:7 leaving 39:3 left 71:25 72:5 157:11 178:10 179:24 legal 104:5 173:6 178:23 legitimate 152:18 153:15 159:16,16 159:19 160:1,22,25 161:22 162:14 163:9,11,14,15,19 164:3,21 168:22 170:7,15 171:6,11,21,21,22,23,23 172:25 173:6,17,18 174:18 15:5,7 16:9,20 17:1,6,25 18:2,5,8,15,17,20,23 19:16 19:20 20:8,18,19 21:11,25 22:2,5,7,11,20,25 23:13,16 2317 18 21 26 8 25 27 11 107:25 legs 9:18,25 114:25 115:1 length 135:13 152:14 28:2,10 29:2 35:8,10,16 lengthy 195:5 lens 130:2 lessen 142:22 lethal 125:1,2 lethargy 147:17 164:17 letter 48:20 59:24 62:14,18 63:1 63:10,12 66:2 69:5 72:9,11 72:13,15,18,25 leukemia 134:20,23 135:10,20 level 57:18 levels 57:18 184:24 192:2 lib 159:20 libido 15:6,16 16:5,9,20 24:2,2,8 24:18,22 25:7,11,11,14,15 25:24 26:3,4,9,12,24 27:9 27:12,17,25 37:3 41:9,14 160:16 161:9 163:6,24 164:13,17 165:15 166:23 license 153:15 lie 30:18 life 28:22 34:8 69:6,17 179:22 188:9 lifting 145:21 lightheaded 151:5 lights 129:8,11,12,14 liked 65:13 likelihood 58:18 likewise 33:14 143:23 limbs 114:24 133:2 limit 120:23 193:18 limited 33:20 line 6:23 38:18 59:6,8 90:11 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6873 [line - mccrea] line (cont.) long lungs market 144:19 191:14 4:20 10:17 46:11 54:13 6:20 34:24 125:19,21 64:3,6,23 65:9 68:22 74:3 lines 81:1 85:1 91:20 112:7 m 196:12,12 77:12 lipa 201:12 liquid 32:4 list 24:16 80:15 81:8,25 82:16 90:8 152:10 153:5,14,17,18 154:2,17 175:18 176:17 listed 80:1881:18 115:24 129:5 listeners 110:7 listing 82:23 literally 127:16 literature 24:3,5 88:10,10,16,17,22 89:16,18 90:5,14,14,15,20 96:19,25 97:13 99:22 101:15,19 106:20,22 107:9 107:20 109:14 111:5,20,21 112:20 113:9,14,15,24,24 114:10 116:10 117:13,24 117:24 118:18 119:2,12 121:3 126:23,25 128:23 130:8 131:15 132:8 134:4 136:2,20 138:6,24 139:13 139:25 140:9,19 141:25 142:15,18,21 144:12,24 145:5,17,22 146:14 147:3 147:19 148:2,25 149:24 150:8,16 151:10 157:9 161:11 162:24 192:21 literatures 129:5 little 4:13 5:12 6:10 32:6 49:23 50:2 51:23 68:14 70:13 114:18 120:21 122:12 157:18 174:19 liver 7:15 125:10,20,23 126:2,6 136:10,12,13,15,16,22,23 136:25 137:4,6,10,12,17,21 138:10,12,18,22 167:14 livers 167:23 local 9:14 locate 190:21 114:8 116:8 118:25 134:12 143:16 148:23 150:7 176:20,24,25 177:1,5 180:7 180:14 181:7,12 189:13 191:3,4,5,16 192:8 193:20 194:19 longer 188:12 look 9:10 16:17 28:8,16,23 48:21 59:14 71:1 81:19 88:21 90:5 104:20 126:13 128:23 129:4 141:13 168:17 170:14 184:16 185:20 189:4 195:2 196:25 looked 9:23 60:21 73:12 170:9 looking 117:4 196:21 looks 6:1031:17 lose 141:19 loss 15:5,5,13,16,17 16:4,5,9,9 16:20,20 24:2,7,18,21 25:7 25:10,14,23 26:2,4,8,8,12 26:24,24 27:11,12,16,17,25 28:2 37:3,3 40:22 41:9,14 95:19,23 119:16,19,20 120:1,3 141:13 144:6,9,10 144:15,20 146:22 147:6 160:16,16 161:9,9 163:6,6 163:23,24 164:13,17,18 165:14 166:23,23 lost 25:1440:18,25 141:15 153:4 lot 16:14 145:21 197:12 lotion 47:15 louis 1:1,22 2:1,16,24 60:9 154:7 154:12,12 195:12 199:3,8 200:2,19 201:5,14 lower 12:3 32:23 107:7 155:11 lubricants 49:21 lunch 115:19 183:24 m.d. 1:13 2:11 3:13 39:24 82:6 199:9 200:11 maalox 139:21 machinery 49:23,25 main 27:2 majority 10:9 makeup 27:8 making 21:15 56:23 63:18 64:10,21 65:4,22 66:4 107:18 175:15 183:13 malaria 67:14 malfunctions 55:15 malignant 184:24 185:1,6 man 10:4 16:1220:6,1621:7,15 21:15,16,19 23:25 26:12 27:2 28:12 31:16 35:6 36:3 180:2 manner 7:11 20:13 76:20 138:21 174:14 181:8 man's 22:12,21 23:16 45:8 manufacture 39:11 43:12 68:19 70:4 79:7,9 123:11 172:5 manufactured 59:18 62:23 70:2 manufacturing 5:21 42:22 43:6,19 59:20 59:21 64:25 77:2 157:20 march 190:22 marion 47:22 mark 48:12 80:7 marked 48:15,17 80:10 82:4 197:15 197:16 markedly 59:3 166:6 marketed 71:7 marketing 59:20 61:8 65:24 66:6,8,17 68:4 71:18 marketplace 52:16 marking 197:14 marks 197:21,23 martin 195:24 material 8:3 32:5 44:22 45:11 49:19 50:8 51:25 53:13 57:19 58:17,25 64:16 68:2 77:6 78:3 114:11 192:11 materials 42:1 50:3 68:4 78:9,18,18 78:20 matter 24:19 87:3 90:15 102:23,24 123:12,18 172:13,16 matters 61:7 199:12 me 3:17 mccrea 2:26,26,26 7:1,3,10 11:14 11:15 12:1 17:17,25 18:6 18:13,15,21 19:1,3 21:4 22:17,24 24:25 25:16 26:22 27:19,22 28:7 29:2 30:3,5 44:11,12 45:1 46:4 47:9 48:12,16 50:20,23 53:8 55:5,11,13 56:9,18 57:4,10 57:13 66:19 68:12,24 72:24 74:14,17 75:19 76:2,19 77:24 78:5,7,13,15 80:7 81:6 82:3 83:12 84:2,4,25 87:25 88:25 89:17 90:9,24 91:3 96:10,13 97:4,11 98:12 100:2 101:8,11,16,25 102:7,12,17,21 103:10,11 103:22,24 104:7,10,13,17 106:2,12,16,24 107:11,22 108:6,14,22,25 109:4,12,17 109:23 110:3,10,16 111:6,9 111:16 112:12,15,21 113:11 114:3,12 115:8,15 116:14,15,25 117:10 118:11,20 120:15 121:1,11 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6874 [mccrea - naphthalenes] mccrea (cont.) means (cont.) microscope monitoring 121:14,15,22 122:3,13,22 23:21 32:3,11,14 34:7 38:8,9 75:1,6,9,12 76:8 123:1,6 124:14,15 126:11 101:6,9,12,25 102:4 108:6 microscopic monsanto 126:20 127:2,3,8,11,19,24 108:22,22 109:20 111:9 34:14 36:6,7 37:10,12,18 1:7 2:7 17:13,19,21,22 18:7 128:11,20,24 129:7,14,23 119:24 120:6 37:24 38:4 18:22 28:2 36:25 40:12 129:24 131:23 133:9,11,22 meant mid 42:20,25 46:3 49:1,11,25 133:23 134:6 135:15 22:2 29:14,25 33:7 99:20 32:17 50:5,7,25 59:17 60:11 136:13,24 139:5,9,23 100:3,8 101:23,24 102:6 middle 61:10 62:23 63:13 66:10,20 141:11,21 142:2,17,20 108:4 116:23 117:12 53:3,24 68:7 69:5,12,16,21,24 143:5,16 144:6 149:3,8,15 158:18,19 186:3 milk 70:11,21 71:11,20 72:2 149:18 152:20 154:20 measuring 96:2 176:23 73:3,7,9,15,18 75:16 76:16 155:9,20,21 160:24 161:2 136:15 million 79:21,22 80:12,16 81:13 164:7,15,22 165:8,12 medical 67:14 89:2 173:16 96:16 123:11 152:4 153:25 166:13,20 171:20,25 18:7,22 21:10 36:20,24 mind 158:23 167:16,22 169:21 172:10,17,23 173:2,8,15,24 42:8,11 74:25 75:5,9,11,15 20:24 30:12 66:8 141:10 170:13,13,24 171:13 172:6 174:6,19 179:1,11 180:18 76:8,13 82:10 84:15 86:1,6 161:20,21 187:17 173:13,15 174:20 176:5 181:6 182:16,25 183:4 88:1 89:2,7,19 90:12,14 mindset 177:4,9,11,15 178:10,13 184:9,11 185:12,17 186:11 97:6 102:2,24 104:21 22:8 63:21 179:6,12,15,25 180:14 188:14 189:14 190:4 107:12 108:7 109:6 110:19 mine 181:1,7 182:2,9,20 183:4 191:23 193:10 194:8,12,18 114:15 116:1 143:6 151:7 36:14 75:16 122:11 190:13 183:20,22 184:2 185:12 194:22,25 195:2,11 196:8 151:14 152:3,6 161:11,11 minimize 186:6 188:12 189:5 196:4 196:15 197:4,9,15,23 198:5 169:14,19 171:12 177:4,16 27:25 59:2 200:5 198:8,12,16,18 178:16 minimum monsanto's mean medically 125:1,2 46:5 180:6 4:24 13:3,3 19:25 20:2 27:1 23:2 127:25 128:4 minkler months 29:16,25 32:13 35:2 38:13 medication 60:1,3 189:9,18 40:24 41:24 46:12 48:5 142:23 minnigerode morning 52:12,15 53:5 55:2 56:5 medications 2:16 3:4 199:4 3:1839:1647:14 194:19 61:5 63:9 67:3,9,17 77:22 35:17 141:21,23 142:3,12 minute 196:23 198:3 81:12 86:15 89:2 90:1 92:2 143:21 20:10 124:20 151:15 motion 94:18,18 95:7,10 96:1,2 medicine mischaracterized 75:25 139:15 99:6,7 102:11 103:21 186:2 133:1,7 mouth 104:22,24,25 105:1,24 medicines mischaracterizes 125:13 106:6,10,11,12 109:13 35:20 173:12 move 111:8 114:2,6,19,20 115:1 members mischaracterizing 18:11 86:15 90:23 115:1 115:11 118:15 119:6,19,19 73:17 174:16 mr.mccrea 119:20 123:3,3 124:18 memo misleading 193:15,20 125:7 126:10 127:23 128:4 200:1 188:7 multiple 129:3,10,13 130:13,14,15 memory missouri 18:25 83:1,1 103:15 117:17 130:23,24 134:1,9 136:12 48:10 71:1 146:22 147:6 1:2,22 2:2,16,18 84:14 86:8 muncie 139:20 140:23 141:8,12,12 165:4 199:2,6,8 200:3 201:14 74:18 85:8,8 141:23 142:14,25 143:10 men misspelling muscle 144:4 148:7,8,9,9 149:6 38:1043:12 158:2,16 161:6 38:23 116:18,20,24 117:5,10 151:4,6,6 153:4 160:22,25 161:8 mix muscles 161:20 164:3,21 165:4 mention 52:14 114:4 133:13 148:24 166:1 171:21 173:2 174:18 138:10 153:24 155:16 176:7,21 178:11,23 179:16 mentioned 182:13 183:3,17 185:16,24 121:21,23 138:9 187:11 191:19 195:23 mentions meaning 32:15 17:6 38:1 49:20 59:19 met 81:25 131:13 158:23 87:14 meaningful metabolism 85:21 7:22 136:7 means methods 4:11,12,126:2 14:20,21 58:25 174:5 mixing 124:4 mo 2:24 200:19 201:5 moderate 192:12,16 modernization 43:21 modify 79:14 n name 70:19 157:13 170:25 171:7 180:10,23 195:24 200:14 names 6:19 36:21 47:19 60:3 63:5 naphthalene 4:15,17,19 5:1,4,13,16,21 7:9 162:9,20,22 163:2 naphthalenes 6:25 7:4,12 156:16 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6875 [narrow - opacity] narrow non object (cont.) o'clock 120:22 16:3 56:8 59:16,16 60:11 179:7 182:12,22 191:18 2:13,14 193:25 194:18 natural 60:12,15,1561:2,3,13,13 objected 195:22 197:25 198:4,21,23 174:1 62:20,20 138:8,19,22 84:7 86:1 offer navel 184:24 185:1,6 objecting 70:15 107:12,17 12:3 nonbiodegradeability 86:17 111:1 194:3 offhand nearly 71:16 objection 37:22 81:11 normal 66:14 83:21 84:7 89:14 office nebraska 14:3 201:10 90:11,21,22,25 91:2 99:20 42:14 169:14 northbrook 102:18 105:21 111:1,13 officer necessarily 173:10 115:14 116:13 118:15 200:8 13:14 15:20 northwestern 122:23 129:2 133:20,21 offices necessary 169:18 134:8 135:12 139:10,18 2:15 199:7 176:4,18 nose 141:22 144:2 149:16 oh necessitate 29:9 152:21 172:7 192:15 5:9 31:13 35:18 134:24 45:4 notarial 193:22 135:18 143:20 189:8 neck 199:1 objectionable Ohio 9:17,25 29:9 32:9,12 38:21 notary 86:14 74:23 need 2:17 3:5 199:5,31 201:19 objections oil 28:23 74:15 97:24 100:11 noticeable 84:1390:23 111:3 115:13 6:5 29:4,6 53:24 54:18 55:7 101:3 102:6 111:17 112:18 32:9,11 objective 55:16 57:6 58:5,19 59:11 113:8 114:7,22 134:3 150:4 november 16:17 30:22 82:13 84:17,19 88:2 89:9 150:5 176:11 196:2 189:17 190:8 observation 90:4 91:9,15 97:9 102:3,25 needed number 29:21 157:21 158:11 103:4,6,8 105:9 107:14 99:16 3:22 10:19 12:10 15:20 observed 108:10 110:22 116:4 negative 16:3,5 21:14 36:12 67:1 10:5 13:22 122:24,25 130:22 132:1,4 172:14 84:10 103:16,16 107:19 obsolete oils negro 115:21 123:17 155:11,16 39:23 56:6 88:24 17:8 19:17 164:22,25 obtain oily neither numbers 166:20 176:5 6:5 199:19 53:17 164:19,21 165:13,16 obtained okay nerve numbness 166:5,8 167:22 20:11 74:15 77:3 81:17 132:22 133:12,16 112:4,5,6,21 obvious 91:1792:11,1495:11 98:17 nerves numerous 17:1721:8 104:19 112:15,21 115:15 132:14 133:2,5 29:10 38:14 obviously 121:14 147:17 153:6 nervousness 148:6,8,12,15 o 13:5 63:15 162:13 180:12 186:21 197:7 198:17 occasion old neurological 34:25 35:6,6,8,10,11,13,15 8:23,25 10:3 17:6 22:1 157:22 158:11 occasional 105:17 olive 35:21 neurology 199:13 32:18 occasions 1:21 201:13 Oliver 35:3 neuropathy 132:13,18,22,25 133:8,12 133:15 new 70:23 179:15 186:1 night 47:14 92:24 129:9,15 nine 85:12 ninety 192:20 nomenclature 157:1 6:23 7:6 11:22 17:16 18:10 20:22 25:2 26:20 27:14 28:18 29:23 44:17 45:19 53:1 57:1 72:23 75:24 80:24 82:20,21 83:3,8,9 84:8,12,22 86:3 88:5,6 98:6 1014 21 1117 113 25 114:5 115:6 116:22 120:8 12112 19 122 7 9 19 19 123:17 126:19 127:15 128:7 132:24 136:11 141:7 142:13,24 143:8 149:1,4 152:12,15 160:21 164:1,5,5 164:20 165:3 166:16 173:4 107:25 occupational 16:3,3 occur 16:5,5 occurred 45:14 47:11 67:19 117:25 118:24,25,25 138:24 140:2 140:19 146:25 147:1 153:20 188:7 occurrence 113:24 135:24 occurs 58:24 173:11 174:15 178:22 47:20 omentum 141:1 once 6:8 56:12 113:13 121:9 134:13 oncoming 129:8,11 ones 42:6 62:21 149:6 175:9 189:3 onset 16:10 opacity 130:2 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6876 [open - pcb's] open outside (cont.) parameter paul's 49:20,20 68:17 74:3 101:19 106:22 107:20 104:6 180:23 opened 126:1 pardon pay 74:7,19 overbroad 77:20 148:13 27:6 173:15 operation 117:9 149:6 191:19 parkinson's pc 69:24 oversimplifying 117:19 149:13 90:3 opinion 159:15 part pcb 9:20 10:6,13 55:16 59:3 owned 3:15 12:3 20:14 33:8,10 5:8 11:9,25 17:4 18:2,4,17 82:9,17,19 85:3 86:8 87:25 57:5 137:10 18:1944:1052:10,13,21 89:7,11 94:13 96:13 97:5 owner participant 53:20,23 54:18 55:7,16 101:12 102:1,1,23 104:21 54:15 173:9 56:6,7,8 57:6 58:6,17,24 106:13,17 107:13 109:6,16 ownership participate 59:8,10 64:2 69:11 82:13 110:19 111:24 112:20 52:24 55:17 58:8 73:15,18 84:23 183:13 84:16,17,19 88:2,23 89:9 114:15 116:1 118:1 121:6 74:2 particular 90:3 91:9 97:9 102:3 103:6 121:15 132:6 134:15 owning 8:10 12:6 32:21 56:2 60:5 105:5,9 107:14 108:10 135:19 137:22 160:1,2 52:21 57:6 65:14 107:4 116:6,11 110:22 114:11 116:4 118:3 168:4,14 opinions p 117:13,25 130:17 156:9 118:9 119:3,13 122:24,24 158:20 168:18 184:12 125:12,15 130:22 131:16 7:11 87:3 106:21 107:17 168:25 opposed 7:7 56:5 121:7 122:14,16 123:13 125:6 129:1 165:4 option 86:16,17 options 74:1,4 3:22,22 6:17 8:15 9:2,16 34-15 36'3 10 37 23 38 10 40:2 43:8 47:20 82:8,24 91:5 104:17 113:3 140:5 144:18 155:24 156:11 1575 pages 39:10 81:1 82:23 127:17 185:10 132:1 136:5 144:7 146:16 particularly 150:9 153:23,24 154:1,8 4:1,8 8:13 34:1 38:15 88:20 156:8,9,18 159:11,14 parties 163:14 167:15,19,21 169:2 199:15,21,23 172:22 177:6 180:14 parts 182:14,15 186:24 193:1 47:15 67:4 77:18 pcbs parvis 65:4 169:12 171:2,7,15 pcb's oral 125:3 139:7 165:16 186:6 201:9,10 passing 92:24 4:14,20 5:22 7:8,8 10:14,17 11:1,3,16,21 12:6,23 17:1 oranges 124:4 order 162:21 11322 1142 11814 1620 132:16 133:19 134:2,2 145:6,7,8,8 153:22 pasture 52:22 54:18 patch 30:17 19:6,8 20:17 21:7 28:3 42:17 44:25 46:6,18 47:7 48:8 49:5,6,7,8,12 51:1,5 52:3,16,24 55:21 59:19 organic 59:20 175:8 organization 75:15 76:14 14524 paint 811 path 129:11 pathologic 169:11 62:1 63:8,11,23 65:6,15 68:17,18 69:5,16,22 70:8 70:11,22 71:3,10,14,14,19 71:21 75:3,6,9,12,17 76:8 organs 125:22 126:6 4920 pathologist 76:17,20 79:5 84:21 85:5 167:9 170:12 174:9 189:25 85:19 86:22,25 87:8 88:12 original 200:15 201:1 521 pathologists 37:17 168:10,10,12,17 96:2,6 99:23 103:19,20,25 105:23,25 106:9,23 107:1,3 ormsby 47:20 878 169:7,8,10 171:3,24 107:5,6 120:14,18,22 121:4 pathology 121:6,7,16,17,24 122:1,4 ought 188:11 outer 49:21 160:14 184:18,19 1861 169:18 patient 15:4 122:14,16,17 123:4,7,9,10 123:19,20,21 124:5,7,7,8 124:10,17 125:5 126:3 33:5,8,9,18 outfit 160:14 182:6 183:22 patients 38:14 128:17,25 130:9 134:5 137:20 139:4,8 141:16,20 179:17 outlined 87:23 88:7 outright 3:23 4:17 9:16 15:4 43:8 59:13 144:19 157:11 160:7 163:13 pattern 16:14 111:6,8,9,18 112:2,2 paul 173:8,19 174:1 177:8,11,12 145:17 151:1 154:3 156:5,6 156:7 163:17,22 164:11,23 167:8,14 168:7 171:17 172:5 175:12,15,23 176:6 26:7 outside 157:15 177:14,19,23,25 178:10,15 176:21 180:7 181:1,7,11,12 179:11,22 180:13,20,25 182:17 183:6 184:21,25 11:12 19:25 20:3 21:22 27:5 35:1 44:25 94:5 114 12 17 18 20 24 181:3 186:7,11,18 187:11 187:20,22 190:5 185:5 192:9,21 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6877 [peculiarly - precautions] peculiarly person pigmentation poisoning 34:3 11:24 31:6 35:16 45:22 10:3,4 92:2 9:9 15:24 16:19 127:21,22 peeling 47:6 57:22,23 66:17 96:7 pills 130:8 131:15 160:9,12 94:16,18,19,25,25 105:10,11,12,15,16,22 79:9,9 161:16,17 162:9,11,16 peer 112:1 139:21 140:9 148:8,9 place poisonings 185:13,17,22,23 186:4 148:9 180:22 184:12 11:12 13:15,16 17:22 19:5 162:7 penis 200:14 45:7 50:14 56:12 139:1 pole 12:4,10,20,23 13:12,23 personal 147:11 53:6 54:2 14:4,7,25 33:1 188:10 places political pentachlorophenate personality 33:22,23,25 67:12,15,18 70:6 150:19 plaintiff polychlorinated pentachlorophenol personally 2:22 3:2 135:9 156:8 12:16,24 70:2,7 61:5 96:22 plaintiffs porphyria people personnel 1:5 2:5 79:18,23 80:12,17 137:2 5:15 8:2 21:18 26:5 28:21 89:19 96:15 169:21 81:11,21 85:25 86:20,21,24 porphyrins 28:25 30:16,25 31:1,5 person's 87:6,6,13,14,15 120:13 137:10,13 56:1061:8 63:11 64:14,25 89:22 plaintiff's portion 66:8,18,18 79:8,11 82:1 pesticides 48:14,17 59:12 68:9 72:8 32:17,23 33:15 69:11 98:15 103:18 105:22 106:9 69:5,9,17,22 80:8,9,25 82:5 115:21 posed 106:23 112:8 114:9 125:11 petition 152:1 83:22 110:18 128:22 129:16 136:15 81:22 plant position 141:14,15,18,19 146:7 ph.d. 10:18 43:21 44:9,10,13,19 45:7 46:13 58:23 70:20 147:11 150:10 151:3 48:3 45:24 46:1,3,5 74:6,18 77:6 120:19 153:20,21,22 154:5,7,12 pharmaceutical 85:5,7,8 157:20 160:5 positive 161:25 163:9 164:22 165:7 175:20 192:8,18 9:13 148:3 163:19 166:22 165:17 169:23 174:10 phasing plants 172:15 192:23 177:18,20 185:9 63:16 64:20 87:19 166:15 positivity peppered photograph plasticizer 137:16 29:11 34:4 37:24 38:4,13 62:8 possibility peppering phrase plasticizers 103:12 142:8 156:15 32:21 10:12 97:12 145:1 49:20 62:9 65:16,16 175:5 possible percent phthalate plaza 21:13 58:5 82:11 95:22 80:1681:14,15 89:5 120:1 62:22 196:12,13200:18201:4 97:7 98:5,20,24 101:6 120:3 162:8,23 167:20 phthalates please 103:7 104:23,24 108:22,23 percentage 60:19 18:12,13 22:16 76:4 91:6 110:20 111:21 116:2 16:6 68:22 112:7 163:22 physical 103:10 104:18 155:22 135:10 136:18 137:24 164:11 19:11 21:21 22:3 23:24 172:9,11 138:1 150:12 performed 27:5 29:1,7 34:17,23 plugged possibly 124:15 152:14 153:5 165:11 4:7 8:3 29:24 71:6 81:23 130:20 period physician plus posts 44:9 45:24 62:5 108:10 28:11 35:5 164:25 131:10 71:14,21 195:5 physicians pneumonia postural periods 28:4,5,16,21 94:11 149:9 146:21 150:7 picked point potential peripheral 168:12 18:4,7,19,22 50:19 52:4 60:21 102:9 105:19 132:13,17,22,25 133:8,12 picking 63:23 74:23 86:18 110:14 pour 133:15 27:7 28:24 169:7 195:17,18 171:2 perking picnic pointing pouring 54:12 195:13 17:14 51:25 52:13 permeating picture points practice 56:20 38:6 171:23 43:16,16 45:18 perry piece poisen practitioner 201:12 141:1 11:12 107:12 persistent pieces poison precautions 59:1660:11,1561:2,13 140:24 30:17,23 31:1,6,7 45:5 62:20 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6878 [precipitation - put] precipitation primary process (cont.) proven (cont.) 136:8 137:17,21 138:12 183:14 97:8 99:12 100:25 101:6,9 precise principles produce 101:12,24 104:25 105:1 159:22 174:5 12:19 85:12,15 125:22 110:21 113:21 114:13 precisely print 126:6 116:3 119:6 130:21 131:8 160:1 8:16 produced 131:19 139:7 142:11,14,15 predisposed prior 2:12 3:14 128:5 168:8 142:19,21,25 143:1,3,5,9 150:13 175:22,22 180:17 169:2 184:25 185:6 146:6 prefer prison producers provide 83:23,24 195:8 178:8 63:11 82:17 premier probability product provision 167:7,24 82:10 84:15 86:7 88:1 89:2 60:12 63:3,4 67:13,22 158:25 prepare 89:8 90:12 97:3,6 102:2,24 175:6 193:2 pry 79:23 104:21 110:19 114:16 productive 188:9 prepared 116:1 195:19 196:1 psychological 182:8,21 193:16 195:9 probable products 15:12,21 16:6 21:1435:12 preparing 82:11 97:7 101:6 104:24,25 59:1,16 60:16,21 61:3,14 35:22 172:20 110:21 111:21 116:3 62:20 63:6,8 175:4,4,6,7,8 public preponderance probably 175:22 2:17 3:5 48:4 67:25 167:12 141:17 24:6 62:21 67:14 72:13 profuse 199:5,31 201:19 presence 79:10 81:20 82:23 85:1 97:22 publications 19:8 52:3,15 164:17 88:20 91:21 129:19 130:20 program 69:15 present 158:8 159:21 160:2,2 167:7 49:2,11,14,18,19,19 50:4,7 publicity 10:7 25:13 34:11 42:7 60:3 189:17 50:25 59:15,17,24 60:8,17 67:7,18 63:1764:21 71:2 137:14 problem 60:22,25 61:2,13,17 65:22 publish 144:5 170:5 9:11 27:3 52:3,4,5,7,10,16 66:20 67:4 75:1,6,12 76:8 42:20 171:9 presented 52:18,19 54:13,14 58:16 projects published 174:13 81:8 92:8,8,16 98:7 99:24 181:1 42:25 171:12 preservative 102:7 103:13 106:5,17,18 prolonged puffy 70:22 108:9 120:14,14,16 122:11 193:5 131:3,9 preservatives 124:1 129:12 137:4,6 prominent pulling 70:5 problems 24:19 26:5 30:12 47:24 50:2 preserving 13:23 21:1547:11 80:13 71:3 117:14 118:19 145:22 pumps 72:2 81:18 82:24 84:20 86:20,23 145:25 146:14 147:4,19 77:11,11 president 87:7,13,22 88:11,16 90:16 148:16 149:20,23 150:17 purine 60:5 92:3,17,22,23 93:14,20,22 prone 136:7 pressure 94:7 98:4,10,15,18 99:19 97:12,14 purple 34:25 93:10 151:20 99:21 100:4,9 107:14,23 pronounce 146:4 presumably 109:21,21 112:24 113:5,18 39:20 purpose 16:1379:15 130:4 191:5 115:5,6 117:21,22,25 118:2 proof 47:16 presume 118:4 119:4,5,7,9,11 105:25 purposes 7:1 118:4 134:2 139:20 120:15,20 121:25 123:25 proposing 85:3 pretty 126:8,10 129:8,11 131:12 81:2 pursuant 3:20 8:6 13:8 14:20 25:15 136:10,12,22 137:11,12,18 prostate 188:22 190:11 199:6 27:4 30:3 54:9 147:6,23 138:10 139:17,25 140:11 94:7 pus prevent 140:20 145:10,13,13,13,14 protection 4:2 6:7,8 32:1,5,7,15 39:8 49:12 50:25 145:15 147:14,16 152:5 70:12 pustular prevented 153:10 154:10 protocol 32:8,13 49:4 proceed 75:8 169:1,2,4 pustules prevention 86:13 prove 13:7 43:10 proceeded 25:15 95:5 put previous 22:7 proved 8:11 21:2 26:11 38:8,8,8 32:15 proceeding 143:1,1 79:5,8,12 91:15,24 94:17 previously 84:8 proven 95:11 112:11,16 188:13 89:23 141:5 143:12 150:10 process 82:12 92:1,6 93:5,13 94:6 194:5 197:21,23 5:22 33:2 39:10 42:22 94:10,12,15,16 95:3,7,13 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6879 [putting - relate] putting quicker read (cont.) recommendation 71:15 135:10 193:17 122:7 24:25 25:4 26:24 36:14 45:1069:7,10 177:18 q quit 37:8 38:1541:1743:9 195:19 qualified 106:25 107:12,15 quarterly 180:19,20 quaterphenyls 91:11 123:8,10 question 11:23 17:16 18:12,25 19:9 23:15 25:2 26:21 30:25 45:20 46:24 53:1,2 55:14 57:8,11,1265:20 71:16 74:12 75:21,22 76:1,5 78:12,13,22 80:21 82:7,9 82:21 83:9,15,22 84:13,16 86:4,6 88:6,7,9 89:6 90:11 90:13,13 91:1,5 93:17 97:14 98:11 100:3 102:9,14 103:14 104:4,7,18 105:8 108:15 110:18 111:2,5 120:12 121:20 124:8,12 125:3,21 126:17 127:5,19 127:20 128:8,9 132:17 133:15 135:16 138:17 139:14 144:13 147:9 151:8 152:3,7,16,18 160:22 161:1 161:1 164:2,2,8,14 165:12 172:8,9,10 173:12 182:13 182:23 183:11,25 184:9 185:2,13 191:24 questioned 188:4 questioning 6:24 90:11 questionnaire 82:22 83:5 84:23 86:13 87:22,23 127:10 questions 3:17 7:20 28:14,20,25 55:3 79:22,24 80:4,13,16 81:11 81:14 82:25 83:1,2 84:9 85:24 86:2,16 87:11,21 89:25 101:5,21 102:7,15 103:15 108:2,17,19,20 109:8 110:6,11,13,14 111:23 117:1,4,8 128:9 138:11 152:8,10,13 153:14 153:17 155:10 165:2,6 188:10 question's 83:10 86:9 90:20 106:5 115:12 122:2 126:10 141:23 149:6 164:5 193:15 quite 27:4 50:22 157:18 197:21 quitting 194:15 quoted 69:19___________________ r rabbits 190:10,19 race 36:13 racist 17:9,15,18 19:1520:13 22:8 radiation 36:4 ramifications 178:24 range 189:19 ranging 12:10 rapid 134:6 rapidity 134:12 rare 14:24 15:1 rash 38:2 rashes 91:25 92:1 152:10 rat 171:19 rate 87:20 124:16,18 rats 167:13,21,23 168:8 169:23 raw 50:3 reach 57:18 149:12 reached 63:23 react 31:2,6,7 reaction 85:16 97:21 reactions 10:24 158:1,16 read 46:24 47:1 51:15 74:11,15 76:6,10,11 78:12 88:6 99:22 104:7 105:8 108:7 113:9,14 126:11,13,18,19 126:21 157:9,10,11,15 158:6 159:23 164:9 172:12 174:8 185:2,4 189:25 reading 6:10 30:2 126:8,10 ready 39:15 193:14 realize 4:13 19:7 really 9:22 51:18 64:24 87:3 93:17 111:22 113:4 178:14 179:16 185:16 realm 20:1,3 realty 102:19 reason 20:7 21:5 85:4 176:12,13 176:14 187:9,11,14 reasonable 193:18 reasons 15:21 16:6 66:1067:16 91:1 179:5 187:13 recall 14:17 26:17 37:4 48:7 62:10 63:14 66:24 69:3,13 69:15 71:2,7,17,20 94:2 115:24 117:3 125:4 129:17 137:20 138:20 140:6 143:19 144:5 149:21 150:18 170:5,21,24 171:14 172:2 receded 166:6 receive 72:10 80:20 180:13 195:16 received 163:5 174:3 recognize 63:16 64:19 70:19 recollect 88:9,13 96:24 99:22 137:14 179:13 recollection 60:4 88:19 90:19 136:22 178:14 record 18:14 22:18 25:2,4 39:19 40:4,21 41:7,16 47:1 76:6 76:11 78:8 80:25 81:17 83:16,18,23,24 84:1,3,5 90:15 114:15 115:20 123:22 124:2 126:24 155:8 155:18 164:9,24 165:2,4,18 172:12 173:12 185:4 189:15 194:4,5 196:2,15,18 198:7 199:16 records 157:16 recruited 177:12 rectal 145:18 red 8:11 67:7,17 146:4 redness 30:24 34:9 91:19 131:10 reduced 199:14 reduction 143:12 refer 5:16 67:20 155:11 reference 39:2 72:13 referenced 47:19 referred 13:6 14:22 35:3 43:18,20 68:8 73:25 156:9 referring 6:15 45:25 51:17 62:17 69:18 115:21 156:24 161:5 refers 4:18 14:22 156:22,23 refresh 48:1071:1 regard 87:16 106:22 107:3,21 167:24 172:5,22,23 183:16 regarding 48:8 79:22 80:13 region 145:8 reiterate 84:7 relate 78:18 86:19 187:1 18:13,1422:10,16,17,18,20 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOO688O [related - runs] related report responsible richter 12:7,24 21:4 29:4 87:8 8:15 9:15 24:21 25:6,22 184:18 169:16,17,18,21 170:6 103:25 118:3 199:20 28:15 94:4 105:11 144:18 restrict 171:2,16 relates 160:11,13,13,15,16,20,23 154:1 ricksha 7:3 84:16 161:10,12,13 163:5 171:12 restricted 148:10 149:19 relating 180:17 185:25 188:16,19 101:17 riddled 58:16 189:5,16 190:1 result 110:14 relation reported 9:7,8 11:19 12:23 14:3,11 right 109:7 14:15,18 24:3,5,12 30:9,14 14:15,18 16:1921:11 24:7 4:169:15 11:14 12:17 relationship 38:11 39:4,6,7,7 40:1 47:11 24:12,13 26:19 35:17 36:1 22:15 24:22 25:8 27:10 53:1382:10,11,12,12 88:2 112:8 131:11 137:8 138:6 42:2 105:5,8 141:15,19 28:1 34:13,1948:11 51:19 89:8,12 97:6,7,8,8 104:22 138:16 143:19,20 151:24 resultant 53:6 54:6,8 58:21 64:11 104:23,24,25 105:14 160:9 161:16,17,19,19,24 4:1 5:25 66:9,22 79:1,3 81:7 82:3 106:25 107:13 110:20,20 162:12,13,24,25 163:2 resulted 84:2 87:12 89:21 90:6 110:21,22 114:16,23 115:4 165:18 130:21 139:7 91:13,25 92:13 93:11 94:15 116:2,2,3,4 131:25 132:3,7 reporter resulting 95:12 99:18 100:7 102:22 133:18 147:1 2:17 3:5 18:14 22:18 25:4 14:2 162:10 103:3 105:6,9 106:13 relative 47:1 48:12 75:21 76:4,6,11 results 109:19,24 111:16 113:17 56:7 199:22 80:7 82:4 164:7,9 172:12 171:16 172:14,16 174:10 114:12 115:2 124:19 relay 185:4 199:5 176:1,2,16 191:16 192:24 128:20 132:17 133:21 181:24 reporter's resume 135:5,19 140:15 146:19,23 relevance 197:19 39:15 147:24 151:22 154:1 155:4 61:18,19 reporting retain 155:12,20 156:11 157:14 relevancy 1:20 201:12 64:5,22 126:12,13,19,20 158:3 159:25 166:2,4 171:8 7:7 reports retired 182:7,18 184:11 185:20 reliability 25:22 113:16 161:9,11 73:3,6 188:8,12 186:3,17 188:9,18 189:4,11 182:3,10 172:21 180:11,11,19,20,23 returns 189:22 191:8,13,25 reliable 183:5 184:1,3 195:18 ring 181:10 represent revealed 5:16 relied 74:7 80:14 81:13 21:22 22:3 34:18,21 ringing 26:16 representatives reverses 118:23 rely 182:2 157:1 risk 181:21 represented review 46:17 50:14 51:6,7,11 remarks 2:22,25 97:13 99:1 112:19 116:9,9 53:11 54:15,20,21 55:16,18 183:24 reproduction 117:13,23 118:18 119:2,12 55:19,25 56:7,14,16,17 remember 50:16,24 121:3 126:23 128:2,14 57:20,21 58:3,5 59:3,7,8,10 16:16 17:10 23:15 37:22 repugnant 130:8 131:14 132:8 133:17 risks 60:3 75:14 76:12 125:9 17:24 133:24 134:4 136:1 138:24 52:21,23,23 57:6,14,25 126:15 154:5 156:19 reputation 139:13,25 140:9,18 141:25 robert 179:18 192:1 47:23 175:17 176:15 144:12,23 145:4,16 146:14 70:18 reminding require 147:3,19 148:2,24 149:24 room 122:11 45:2 150:8,16 151:9 155:21 151:4 remover reread 170:20,21,22,23 171:9 route 8:11 75:21 76:4 164:7 172:10 174:6,9,10 185:17 85:16 121:8 123:13 renate research reviewed rudimentary 167:3,4,6 59:19 60:7,25 62:25 63:2,9 78:10,18 79:18 169:22 8:6 repair 178:17 179:21 174:11 185:13,22,23 186:4 rug 74:22 respect reviewing 50:2 repeat 72:8 165:24 114:10 145:22 rules 24:24 140:4 166:12 172:9 respond rheumatism 104:12,15 repeated 83:23 87:21 116:16 rumors 46:11,12 193:4 response ribs 186:10 repeating 40:19 82:17 128:6 132:16 run 111:19 responsibilities rice 58:3,5 176:18 189:18,19 replace 66:6 51:25 91:15 96:3 runs 59:6 93:15 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOO688I [sacrifice - silicones] s school selling sexual sacrifice 169:14,19 49:19 15:17 189:23 science semi shaking safe 50:18 143:6 32:5 101:1,2 110:17,23 149:13 30:1946:17 55:6,12 scientific semiannual sharply sake 51:1067:11 169:3 174:4 180:20 182:13 119:10 scientifically seminars sharpy sale 127:25 128:5 174:14 181:8 89:18 96:15 182:9 68:19 70:15 scientist send sheet sales 167:6,24 168:24 169:6 73:1 177:8,11 185:17,18,19 102:22 59:19 63:17 64:20,22 67:21 scientists 191:22 short 68:4 71:18 168:5,16,24 185:14,15 senior 8:22 12:1 39:14 78:6 salt sclerosis 180:22 154:21 193:11 70:7 117:17 sense shorthand samples scraping 5:15 20:4 77:5,19,21,23 2:17 3:4,4 199:4 36:7 99:8 100:20 158:23 186:5 shortly sat scratch sensitivity 45:13 85:22 152:6 14:6 100:14 129:14 shortness satisfied scrotum sent 98:25 176:17 12:4,9,20,23 13:12,22 14:4 171:13,13 174:10 175:6,7,8 shot satisfy 14:7,25 33:1 177:13 180:20 185:21 31:25 32:16 110:10 seal sentence shoulder saturated 199:27 201:16 5:24 6:9 15:3 16:23,25 17:3 48:21 59:15 46:7,20 47:3,7 sebaceous 17:5 32:8,15 39:2 43:10 shoulders Saturday 4:2,7 5:25 6:2,22 38:14 47:13 48:25 49:9 59:12 32:17 198:14 seborrhea 62:3 63:15 67:6 130:15 show sauget 34:8 156:14 157:3 33:7 48:10 163:22 164:11 154:4 seborrheic separate 182:6 188:16,19 save 34:2 112:4 showed 83:16,20 85:22 86:5,12 second series 33:6,14 93:12 140:13 154:19 59:13 83:14 95:23 103:10 6:19 110:13,13 152:8 shower saving 106:16 144:19 155:6 157:23 158:12 160:13 45:12 86:12 156:12 188:21 showing saw secondly serious 37:25 176:21,22,23 177:6 42:4,16 166:19 183:18,21 59:14 195:13 14:20 27:1 52:3,4,5,7,10 shown saying secret 58:16 103:18 120:10 23:14 27:9 34:17 46:23 185:7 seriously sickness 57:2 64:1 65:1 79:6 81:4 secretary's 25:21 26:23 139:15 96:8 104:2 105:9 107:2 72:17 serum sign 108:11 117:8 120:10 section 4:3 6:7 30:22 72:15,25 151:19 122:20 123:4 166:11 37:25 serve signatures 174:17 197:4 seeing 178:8 180:21 says 42:6 69:13 94:3 119:18 service significance 3:15 4:8 6:18 16:24 22:2 121:1 130:6 171:14 28:1 48:5 61:8 167:12 86:2 113:15 29:8,15 31:17,24 33:13,25 seen set significant 34:12 38:11 44:5 64:6,9,19 12:9 14:11,13,15,18 15:4 80:4 155:6 199:26 201:15 16:11 23:22,25 27:12,15,16 68:12 101:8,11,11 104:20 16:18 21:20 24:3,5,11 30:9 setting 83:8 123:21 127:25 128:1,4 184:9 31:8 33:17 34:11 46:1 42:15 128:5,16 136:2 148:25 scalp 66:19 67:4,4 69:9,18 70:17 seven 172:4 29:18 34:9 122:1 170:21 171:11,25 140:13 154:7 signs scar 182:7,17,19 183:22 184:1 seventeen 23:24 31:19 151:18,23 39:9 self 154:6 152:24 153:18 154:2,17 scared 179:3 seventies silage 149:15,17,18,19 selikoff 7:20,25 53:14,16 scarring 91:22 severe silicones 39:3,4,5 31:13 60:19 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6882 [similar - started] similar sketch sodium 33:2,6 147:14 8:22 70:6,6 simpler skin soiled 120:24 6:5,6 7:12 8:3,11 9:8,12 45:11 simplicity 10:18,21,24 11:3,9,10 sold 159:3 12:22 13:23 20:18 21:8,23 69:22 72:2,4,5 simplistic 27:3,4,5 29:12 32:21 34:2,9 solvents 31:4 34:10 35:1 36:7,13 37:25 11:6 simply 38:7 85:17 87:1 90:6 91:3 somebody 82:16,18 196:10 91:17,18,24,25 92:1 94:19 30:18 57:2 63:3 64:13 single 94:25 95:4,15,17 107:22 72:22,24 103:2 170:24 152:4 121:8,18 122:15,17 123:14 somebody's sinus 124:9,16,17 125:2,7,8,17 188:9 93:20 125:18,19 151:18 152:9,10 someplace sir 153:6 157:23 158:12 148:21 190:17 3:18,21 4:166:129:5,15,19 190:10,19 193:5 somewhat 19:2224:1 28:11 29:14 skip 8:16 33:12,21,24 34:13,19,20 10:14 soon 35:10,25 36:2,5,9,18,21 skipped 121:12 122:8 37:1,9 38:5 39:12 40:3 131:4 soot 48:11,18,21 51:12,14,16 sleeping 58:25 52:8 53:8 61:6 73:10 74:9 147:21 sophisticated 74:20,24 75:2,4,7,10,14 sliced 75:15 76:13 76:12 77:14 78:21 79:3,20 38:7 sore 79:25 80:6 82:3 91:25 slide 114:8 109:12 111:16 112:21 38:8 soreness 113:6,17 114:12 115:22,23 slides 114:3 126:7,16 132:21 135:19 168:17 169:22 170:9,14,20 sores 137:19 139:2,23 144:1,21 171:10 189:25 99:5,7,7,11 146:19,23 147:24 151:13 sliding sort 151:17 152:2 155:13,23,25 185:23 188:10 156:13 157:6 161:10 slight sorts 163:25 164:15 169:24 10:13 16:18 114:20 182:7,11,16,19 186:3 slightest source 187:21 188:18 47:17 60:18 146:3 174:3 77:3 89:20 sit slightly south 62:10 68:6 70:10 80:3 10:13 184:21,22 2:26 17:19 83:18 153:5,16 191:21 small spaces sitting 27:8,20,21,22 29:10,21 193:4 32:3,6 54:12 30:6 31:7,21 38:14 69:11 spasms situation 73:19 116:18 38:3 57:7 67:19 68:4 85:19 smarter spastic 107:10 112:5 118:6 124:11 185:10 145:3 six smells speak 23:5 37:23 81:1 82:23 85:1 100:15 9:18 32:18 107:16 85:12 91:21 140:13 155:3 smoking speaking 183:18 89:22 58:19,22 sixteen soaked speaks 8:22 9:3 36:11,17 38:12 45:11 46:20 47:2 71:23 15:13 30:4 63:22 161:6 165:24 soaking special sixties 71:14,14,21 36:16 7:25 social specialist sixty 15:21 35:3 167:20 sociological specialties sized 23:16 87:9 31:6 species 192:2 specific 25:17,18 35:2 43:2 87:10 120:21 152:5,24 153:12 154:2,16 specifically 152:17,23 153:13 154:16 speculate 20:23 29:24 127:16,20 speculation 179:8 speech 18:11 111:6,8,9,18 112:2,2 147:12,14,15,16 speed 143:13 spelled 38:17 157:13 spill 54:22 55:20 spine 118:21 spleen 145:13,15 sport 176:22 spots 119:18 121:1,4 130:6 spread 56:2 St 1:1,22 2:1,15,24 60:9 154:7 154:12,12 195:12 199:3,8 200:2,19 201:5,14 stack 155:10 197:7,10 stand 30:12 151:4 standard 84:14 86:7,7 165:10,10 standards 169:3 standing 90:10,21,25 115:13 116:12 133:21 standpoint 16:11 195:13 start 10:10 89:21 153:7 193:15 194:6,8,13,16 198:3,20 started 10:2 60:22,25 107:22 174:23,25 175:2,25 176:23 188:25 189:17 190:2,5 191:5 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6883 [starting - swelling] starting stomach styrene summarize 43:15 93:14,16 125:14 139:17,22 159:18 160:3 163:12 191:16 starts 139:25 subacute summarized 29:19 56:13 stone 189:6 91:22 state 145:8 subcategory summary 1:2 2:2,18 33:7 48:25 71:10 stones 132:21 140:20 36:10 184:7 103:1 119:25 158:10 159:4 92:24 subject summery 161:2 163:13 199:2,6 200:3 stooping 60:16 9:2 191:22 stated 145:21 subsequent sunlight 24:11 29:3,13 69:16 72:21 stop 60:13 191:9,12 130:6 91:1 108:6 140:2 156:7 49:19 50:2 158:3 subsidiary supervisor 196:3 stopped 138:11 158:21 44:23 statement 22:6 substance supplied 9:13 17:2,9,12,13,15,18,20 stops 6:14 72:19 19:15,19 20:4 31:3,12 29:18 substances supplier 39:11 67:9 69:13 84:6 straight 192:1 66:7 158:4,9,16,24 159:4,7,20 5:18 substantial supposed 159:23 160:4 162:4 200:9 street 127:12,21,23 128:25 129:3 51:8 70:25 193:23 statements 1:21 2:27 148:10201:13 129:6 sure 81:3 stretched substation 14:5 41:21,23 46:25 50:21 states 195:5 52:22,25 53:24 54:4,5,9,17 50:22 51:17 62:15 63:7 3:24 5:24 6:9 10:12 12:1 stricken 55:7 71:23 81:2 91:23 107:8 17:5 22:1 43:9 47:13 48:4,4 75:20 substitute 113:10 122:6 125:25 126:1 48:5 51:18 52:19 59:13 strike 49:8 58:3 59:16 60:12,16 136:14 173:25 186:16 62:3 65:4 67:6 82:5,9 85:18 18:11 75:25 77:24 147:8 61:3,13 62:20 63:25 64:4,5 187:16 189:20 190:9 107:7 143:4 156:14 167:7 185:12 65:7,9,23 68:3,21,22 surface 172:21 181:20 188:23 stroke substitutes 9:7 stating 114:18 131:23 132:3 62:4,16,17 63:17 64:13,13 surfaces 19:1642:3 81:6,7 101:25 strokes 64:21 33:5,8 102:1,23,24 103:4,7 106:24 131:25 subsymptom surmounted 107:11,15 114:15 122:4,13 structure 148:14 31:25 123:12 115:9,10,12,16 158:21 suffered surrounded statistical structures 41:9 163:5 54:18 55:8 137:16 158:21 suffering suskind statistically studies 56:16 37:20 139:6 19:11 124:16 125:4 157:18 sufficient suspect statistics 164:16 167:21 171:17,19 96:25 13:12,16,18,23 14:1 15:24 163:21 164:10 173:9,20 174:7,25 175:2,12 sugar suspected stay 175:15 176:20,24 177:6 134:18 36:8 83:24 178:1,4 180:6,15 181:6,10 suggest swallow staying 181:14,16,18,21,24 182:14 51:11 92:9 125:10,11 50:10 182:21 183:6 184:20 suggested swallowed stick 185:13 188:5,14,21 189:1 19:25 183:8 125:11 127:9 189:13 190:7,14 191:3,9,17 suggesting swallowing sticking 192:6,14,20 193:2,6 188:10 125:15 122:24 studio suggestion swann stiff 194:13 196:20 85:18 8:18 19:21 41:13 144:14 114:7 study suggestions 157:8 158:21,22,23 159:1 stiffness 124:24 171:9 172:14,15,17 189:2 165:25 114:3 172:22 184:5,15,19 190:20 suite sweat stipulate stuff 1:21 200:18 201:4,13 6:3 7:15 8:4 133:23 30:1891:15 Sulzberger sweating stipulated stumbling 47:22 97:22,25 3:1 113:3,5,13,17 summaries swelling stock stuttering 183:2 93:1,3,6 115:25 116:8 73:6,9,11,15,17 74:1,2,4 111:19 117:15 136:13,23 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6884 [switched - think] switched taiwanese tell (cont.) testing 64:13 128:13 66:1271:481:1089:1,11 156:21 181:4,4,5 189:19 switching taken 126:5 140:6 145:5 166:24 190:10 191:11 192:19 62:4,16 63:6 64:12 3:3 39:14 78:6 115:19 168:15 171:1,4 174:19 tests swollen 120:19 154:21 193:11 175:25 179:11 183:16 161:4 174:21 176:13,19 136:16,25 199:21 200:12 186:14,23 190:15 192:13 texas sworn talk 193:6 186:18 187:3 2:123:14 199:10 45:12 66:17 123:6,7,7,9,10 telling thank symposium 153:25 170:16 187:13 61:23 63:19 164:24 40:14 97:17 115:18 124:14 156:3 talked temperament 189:4 symptom 19:641:1942:7 141:24 17:7 19:17 thick 17:25 18:8,15,23 19:10,20 154:8 160:4 173:19 186:11 temperature 98:8 189:3 190:18 24:1,19 25:15,19 26:4 186:14 187:19 55:1 57:18 thickened 30:21,24 31:1 35:9,11,13 talking temperatures 98:13 35:15 81:8 82:19 88:23 4:14,15 6:24 7:2 8:12,13 193:3 thigh 102:2,25 103:24 115:24 37:13 44:8 45:21 53:3,7 ten 33:6,15,19 116:6,11,15 117:13,14 54:1,2 58:11,20 65:1 68:11 69:17 73:21,24 143:18 thighs 118:17 121:2 126:22 68:15 82:25 84:11 86:18 162:8,22 33:13 129:17 131:14 132:12 91:8,12,18 98:7,8,9 102:20 tenacious thing 139:13 146:1 148:16 105:19 109:20,22 111:18 4:1,9,12 29:10,21 30:6 5:1 25:15 43:20 102:11,20 149:21,23 150:17 151:9,12 111:19 114:17 116:24 32:22 119:1 124:2 194:4 151:19,19,20,21 117:23 118:5 119:11 term things symptoms 121:24 122:21 123:4 124:4 35:21,21 39:23 102:10 10:19 61:22 65:15 67:22 8:17 9:3 15:23 16:2,16,16 126:25 128:19 131:20 129:3 142:14 143:10 173:6 68:11 91:23 96:5 153:13 16:17 26:8,23 27:2,7 28:16 133:25 134:24 139:3 176:20,24,25 177:1,6 180:7 154:14 192:18 195:18 28:24,24 29:3 30:16 35:4,6 142:15,20 144:7 145:12 180:15 181:7,12 184:13,23 thing's 36:11 37:2,6 80:14,18 146:4 149:9 152:22,25 189:13 191:3,4,5,17 192:8 195:4 82:24 83:24 86:19 88:11 153:23 161:10 171:18 termination think 96:14 99:25 100:12 116:8 173:5,22 180:16 182:14,15 5:17 8:6 9:10 10:16 11:17 15:15 128:5,12,13 130:8 133:24 182:23 183:1 184:7 189:12 terminology 16:21 23:3,18 24:9,10 25:2 134:1 140:17 144:11 190:24 191:1,2 195:6 197:8 4:4 5:18 13:9 25:12 28:19 29:17 30:1,3 146:25 148:1 151:18,24 tape termites 31:17 32:20,25 35:14 38:18 152:22,24 153:7,18 154:2 193:14 70:22 38:19 39:22 40:4 42:3 154:17 164:19,23 165:14 tapes termiticide 44:18 45:20 51:22 53:2,11 165:17,19 193:13 194:19,20,22 70:8,11,1571:11 53:12 55:3 56:12 58:2,10 synonomous 195:19,25 terms 59:18 60:1 61:7 63:22 156:18 159:10 tarda 27:17 30:21 87:21 90:12 66:14,25 67:10 68:11 70:24 synonymous 137:2 102:8,9,13,16 108:5,18 71:15 72:12 75:25 78:1 49:5 taste 122:21 164:4 172:8 80:2 81:2,18 82:17 83:4,10 system 100:20 terphenyls 85:2,14,20 86:6,6,9,11,12 34:25 150:11 taxed 49:7 118:10 86:14,17 87:18 88:14 90:15 systemic 201:1 test 90:20 93:9 95:19 96:20,23 8:9 9:8,14 10:21,25 11:19 technical 71:9 156:7 173:10,20 101:22 102:13,14,17 11:25 15:10,10,12,18,24 61:8 69:14 173:6 176:11 192:20 104:14 106:11 107:8,19 16:1923:21 85:16 156:16 technically tested 108:17,18 110:13 112:17 157:2 158:1,15 160:9,11 95:9 123:11 137:15 156:7 114:13,22 117:9 118:25 161:15,16,25 162:6,9,11,15 teenage testified 119:9 120:22 121:19 122:1 163:3 12:9 14:12,13,16,22 34:8 67:1 166:11 196:3 123:20,22 124:1,2,12 127:5 systems 34:10 39:7 testify 129:12 133:1,7 135:12 154:15 teenager 186:19,20,24 187:5,8,12,18 136:21 140:4 141:4,24 t tag 70:19 taiwan 85 20 86 23 127 3 4 10 12 127:22 128:18 129:1 12:8 199:10 teleky testimony 6:11 7:19,24 8:1 46:15,16 66:15 68:7 85:11 tell 86:15 123:23 170:1,8 19:22 32:9 37:17 44:2,7,16 171:16 195:6 199:17 44:20 53:19 56:21 61:16 142:18 145:12,14 146:6,18 147:6,14,22 148:19,21 152:12,16 154:18 155:18 159:9 163:11 165:8,9,20 166:13,17 169:17 174:16 176:14 177:10,21 179:8 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6885 [think - ulceration] think (cont.) time (cont.) toxicity trustworthy 182:22 184:17 185:24 140:14,17 144:5 147:11 121:16 122:16 125:6 168:23 181:14 187:10 188:6,10 190:19 149:13 154:18 158:19,20 135:17 175:3 189:6 190:22 truth 191:19 192:22 193:9,16,19 159:17 161:22 168:17,18 toxicological 162:2 199:10,11 194:10 195:17,25 196:25 171:6 173:24 178:8,16 175:11,15 176:5 178:1 try 197:2,5,10 181:3 189:25 191:13 180:3,6 183:5 184:5 17:17,20,23 62:1 88:9,13 thinking 192:22 193:9,18,20,21 toxicologist 90:22 96:24 99:21 194:15 78:23 104:23 195:7 196:21,21,23,25 197:24 173:8 trying thinks 198:1,20,22 toxicology 23:12 27:18 56:6 63:22 9:13 times 180:4 86:19 112:11,16 124:1,11 thinning 67:1 85:1 92:20 tract 195:4 69:1 tired 6:21 tube thirds 19:23 21:18,19 22:2 23:10 transcribed 125:13 3:24 23:25 28:13 3:5 tumor thirty tiredness transcript 137:17 138:12 140:23 105:16 15:8 16:4 20:15 23:5 40:15 169:25 200:15 201:1 141:1 185:11 thomas tissues transcripts tumorogenic 2:22 200:16 201:2 189:24 201:8 183:12 184:21 thorough title transformer tumors 43:13,25 44:6,14 45:2,16 156:1 52:21,25 53:3,6,12,15,19 137:22 138:7,8,18,19,22 46:21 47:3 154:13 titled 54:1,16,17 55:6,14,17,20 140:21 184:24 185:1,6,8 thou 39:19 55:23 56:6,7,8 57:5,7,15,25 turn 73:21 tod 58:5,8,17,24 59:7,8,10,11 3:22 86:1 155:24 157:5 thought 2:16 3:4 199:4 74:18,22 135:5,8 167:4 197:9 8:2 21:2 27:22 41:4 48:25 today treat turning 51:1758:15,1861:20,20 17:2 52:7,11 55:14 58:20 93:11 6:17 75:23 83:20 131:7 137:7 62:10 68:6 70:10 73:9 74:8 treated twenty 138:11 161:4 176:9 189:12 74:14,23 126:5 27:3 23:5 38:10,10,12 56:19 191:4,11 194:12,14,16 toenails treating 57:2 66:25 82:24 124:21 thoughts 98:4,7,8,9,10,13,14,16,17 12:11,1471:1972:6 81:23 154:7 166:3 21:1 98:18 120:17 treatment twice thousand told 9:3 34:14,20 36:3,11,16 179:22 73:24 79:10 26:12 28:23 64:15,18 76:19 69:24 twitching three 169:23 170:22,23 189:1 tremor 117:10 38:10,12 87:19 128:9 191:17,21 193:20 149:2,9,12 type 140:13 145:12 165:14,19 tom tremors 4:1,9 22:8 36:13,13 42:14 190:2 192:1,1 193:8 194:19 57:4 85:22 101:16 106:14 101:1,2 110:17,24 148:9,18 62:4,17 63:5 64:20 96:7 194:22 195:19,25 196:21 tomorrow 148:20,23 149:3,5,8 162:7 116:23 117:7 135:25 throat 194:7,19,22 195:20,25 trial 141:23 145:4 149:2 100:7 196:5 197:24,25 198:3,22 24:18 178:3,6 195:6 typed thursday tonight trichlor 83:19 195:23 198:8 197:11 57:16 types tightness top trichlorobenzene 98:10 149:5 132:10,15,19 133:19 134:1 3:23 32:4,6 36:12 38:9 82:5 55:23 57:16 135:6,9,17,20 typewriting time 82:8 91:5 104:18 191:25 trip 3:6 8:2 12:2 15:23 18:7,22 total 20:24 36:13,15,16 37:14 73:23 201:6 39:13 44:9 45:24 50:2 51:3 totally 54:2 56:15 60:2 63:17,22 19:25 20:3 40:5 81:7 65:1467:9 68:1369:4 71:2 107:25 124:11 72:5 74:1,23 78:8,17 81:1 touching 81:19 83:6,6,8,16,20 85:1 199:11 85:22,24 86:3,5,12,12 toxic 96:23 113:14 115:18 85:15,16 122:5 123:15 120:24,25 122:7 128:12 125:8 135:13 137:14 138:2 169:20 trips 21:16 trouble 15:22 147:21 148:4 true 30:1565:5 113:17 198:12 199:16 trunk 13:18 u u.s. 49:16 59:25 61:4,12,16 62:18 63:19 103:20 175:19 uh 19025 ulcerated 94:1,3 125:12,17 140:9 ulceration 140:1 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOO6886 [ulcerative - westinghouse] ulcerative unusual (cont.) variety walnut 145:2 144:9,9 146:2 105:25 2:27 ultimate updates various want 177:17 180:13,16 46:7 81:21 82:2 83:24 87:8 19:1,2 22:14 23:12 27:25 umbilicus urge 91:14 96:5 149:5 181:2 50:10 51:8 53:5 56:23 64:1 32:23 144:22 varying 65:19 76:3 84:7,12 92:15 unable uric 7:11 102:18 113:25 121:12 82:17 121:2 136:8 ventilation 123:7 128:10 135:2 151:16 uncomplicate urination 43:23 166:12,16 167:3 168:22 135:15 145:24 146:10,13 veracity 175:2 184:13 186:19,20,23 uncontrolled urine 182:3,10 187:4,7,12,13,17 197:6,10 144:22 146:2,5 verbatim 197:12 undefined use 81:9 wanted 102:10,15 129:3 136:12 4:12 5:19 49:2 58:16 64:16 versus 65:9,12 122:6 174:25 175:3 142:14 143:10 172:8 65:14 68:18 69:13,22 70:8 56:7 122:24 124:9 141:8 176:24 179:12 180:3 184:2 understand 70:14 71:19 90:12 142:25 vertebral 187:4,7,16 192:2 34:22 53:2,4 70:14 74:7 143:9 172:5 177:5 192:15 118:4 wants 83:15 86:21,24 91:6 97:14 196:24 vertigo 193:15 103:3 104:14 106:13 users 151:2,4,6,7,7 war 109:18 112:3 116:25 135:1 62:4,5,11 63:5 64:12 65:2 veterinary 166:7 152:21 178:18,20 179:1,4 uses 47:14 Washington 184:25 185:5 186:19 49:20,20 61:24 62:1,2 vice 169:22 193:17 68:17,18 142:19 60:5 waste understanding usual victims 96:23 91:4,7 101:22,23 102:6 5:17,17 17:7 19:17 141:9,9 84:20 88:11,16,23 99:23 water 108:3 133:1 178:12 usually 106:6 128:13 149:13 understood 5:15 13:6 34:4,11 161:13 view ways 50:15 72:20 100:8 103:21 180:22 169:7 171:24 77:15,25 141:18 108:19,19 109:9,24 110:1 V viewpoint 185:8,9 underway 59:15 undetermined 91:14 undoubtedly 120:12 unexplained 150:21 unintelligible 110:15 united 48:3,4,5 51:18 52:19 65:4 107:7 143:3 167:7 172:21 181:20 188:23 university 71:10 169:14,19 unrelated 99:10,11 138:18 unsafe 43:16 45:17 46:9,22 47:4,9 47:12 untrustworthy 168:19,20 unusual 95:19,21,23 113:1 131:10 134:6,9 141:5,8,12,13 vague 11:23 25:3 26:21 53:2 83:10 90:20 98:11 108:2,17 110:6 115:12 121:20 122:2 124:12 126:10 134:9 139:11,19 141:23 144:3 148:19 149:7 152:16,19 161:1 164:3,6 182:23 161:5 168:11 viscid 32:1,14 viscous 32:5 vision 119:7,9 volume 192:16 valid 102:17 validity 20:1,3 1:12 vs 1:6 2:6 200:5 vulgaris 34:5,7,12 value w 73:11,14 wait vapors 20:10 40:8 54:1 78:2 169:16 189:24 variability wake 30:1631:11 39:3 variables walk 97:5 30:17 variation walking 43:5 113:1 variations walks 42:21,25 44:3 varies waller 59:9 1:20 122:10 weakness 116:20,24 117:6 wear 43:14 44:1 45:12,16 wearing 45:3 week 78:16 152:14 195:6 weekly 85:6 weeks 92:20 weigh 58:14 59:4 169:8 weighing 59:5 weight 141:5,8,12,13,14,15,19,19 144:9,9 153:3,4 welcome 120:23 178:13 went 27:24 131:7 154:11,12 155:19 162:4 166:6 178:15 179:22,25 188:25 westinghouse 44:1361:1,11 66:1274:6 74:22 75:1,5,13,14 76:9,13 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOQ6887 [westinghouse - zero] westinghouse (cont.) work (cont.) wrong 76:21 85:5,7 191:15 192:4 69:19 93:12 167:9 168:6 38:17 64:18 133:3,6 157:13 192:8 169:6 172:23 173:19,23 168:13,15 we've 177:15 180:4 182:3,9 wrote 33:3 53:5 68:21 82:23 185:18 195:23 62:14 63:1 66:1 72:10 103:11 163:10 193:9 195:13 worked 164:23 165:25 183:20 y whatsoever 17:15 109:1 wheeler worker 8:17 10:14,23 13:11 16:8 24:21 25:6 43:24 44:9,10 25:1 34:16 104:3 149:18 186:25 177:22 whereof 44:12 45:1 135:8 152:4,7,8 152:24 163:5 167:8 192:17 172:14,17 189:19 199:26 201:15 white workers 3:25 25:14 28:1,17,22 40:6 166:19 47:15 widespread 4:23 12:12 63:18 64:10,21 65:21 66:4 willing 197:13 window 85:12 wiped 67:14 witness 22:16 29:24 30:1 75:23 76:15 82:22 84:8,22 87:12 99:21 102:11 104:1,5,9,11 109:10,13,19 112:18 118:7 118:9 122:10 127:7,16 133:4 143:2 152:15 196:12 197:8,24 198:1,20,22 199:13,17,26 201:15 wonderful 67:13 wood 12:11,14 69:24 70:4,12,22 71:11,19,21,24 72:2,6 word 49:8 100:3 142:13,19,25 143:9 159:3 169:5 192:15 worded 183:9 41:12,17,22 42:2,4 47:13 75:1,6,9,12,17 76:8,17,20 76:24 77:8,9,16,25 152:7 152:11 153:23,25 154:1,3,8 154:8,9 157:8 159:1 160:5 163:22,22 164:11,12 165:13,18 166:14 192:7 193:1 worker's 11:9 160:15 working 11:1 41:1342:5 43:13,17 43:25 44:6,15 45:2,16 46:10,17,22 47:4,8 68:3 144:14 154:14 173:14 174:2 178:15,16 179:19 180:14,25 181:1,3 190:5 192:11 197:19 workplace 19:21 42:16 works 167:6 world 89:19 90:12 worlds 186:2 wright 173:9,19 177:8,11,12,14,19 178:10,19 179:10,11 23 5 2511 41-24 66 25 68:6 69:17 71:20 105:17 143:18,18 157:19 163:16 166:3,6 176:1 177:23 183:19 189:21,24 190:2 yeiiow 4:2 6:7 32:1,7,15 yucheng 52:18 yusho 18 2 17 19 6 29 4 6 5115 51:19 52:18 82:13 84:16,19 84:20,21 85:20 88:2,11,23 89:9,15,17 90:3,14 91:8,22 96:9,11,14,18 97:9 101:17 102 3 25 103 2 8 105 9 107:14 108:10 110:22 111:4,20 112:20 113:15,24 114:10 116:4,10 117:14,24 118:9 119:2,3,13 121:3,24 123:9 126:25 127:6,7,12,21 128:22 129:16,22 130:8,21 131:11,21,22,22 132:4 134:4 135:10,22,24 136:20 137:8 138:6 140:3 142:21 144:22 145:17,23 146:7,15 147:4,8,20 148:12,17 149:24 150:8,17,25 wording 182:20 184:4,10 words 180:13,21,22 186:7,12 187:20 190:5 write 1365 z 29:25 30:2,7 43:18 72:20 63:10 177:25 zero 89:10 96:6 100:2 102:18 writers 165:1 105:1 109:25 111:19 106:7 126:12 152:5 writing wore 64:8 127:17 165:13,16 47:6,7 172:1 199:14 work written 11:12 16:13 17:8 19:17 18:3,18 42:1 75:8 153:18 21:1523:18,24 26:19 38:25 154:17 157:2 165:4,6,9,18 40:18 42:7 43:15 45:8 65:8 185:10 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 3 LEXOLDMONOO6888