Document EvD9eR01p0raZLzz8X5wNGr5b

IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS RICHARD MAHONEY, Plaintiff, v. No.: 06-L-1119 A. W. CHESTERTON, INC., et al., 1 2 3 4 5 6 7 8 9 Defendants. 10 11 12 13 VIDEOTAPED DISCOVERY DEPOSITION OF MARK WICK, MX., Taken on Behalf of the Plaintiff 14 May 17, 2007 15 16 17 18 19 Reported by: Valarie L. Schmit May, RPR Page 2 20 21 22 23 24 25 IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS RICHARD MAHONEY, Plaintiff, v. No.: 06-L-1119 A. W. CHESTERTON, INC., et al., Defendants. Page 3 VIDEOTAPED DISCOVERY DEPOSITION OF MARK WICK, M.D., produced, sworn and examined on behalf of the Plaintiffs the 17th day of May, 2007, at the Omni Hotel, 235 West Main Street, in the City of Charlottesville, State of Virginia, before Valarie L. S. May, RPR. APPEARAN CE S APPEARING TELEPHONICALLY: The Plaintiff was represented by Jonathan Ruckdeschel, Esq., of the Ruckdeschel Law Firm, LLC, 3645 Cragsmoor Road, Elliott City, Maryland 21024. APPEARING TELEPHONICALLY: The Plaintiff was represented by Nathan D. Mudd, Esq., of the law firm of SimmonsCooper, LLC, 707 Berkshire Boulevard, East Alton, Illinois 62024. Page 4 1 INDEX 2 Page 1 APPEARING TELEPHONICALLY: The Defendant CITGO Petroleum Corporation was represented by Rishi Agrawal, 2 Esq., of the law firm of Eimer, Stahl, Klevorn & 3 Examination By Mr. Ruckdeschel 6 Solberg, 224 S. Michigan Avenue, Suite 1100, Chicago, 3 Illinois 60604. 4 Examination By Mr. Hall 23 4 APPEARING TELEPHONICALLY: The Defendants 5 5 Bucyrus International, Superior Boiler and Eastman 6 7 EXHIBITS Kodak Company were represented by Rob Sanderson, Esq., 6 of the law firm of Foley & Mansfield PLLP, 1001 Highlands Plaza Drive West, Suite 400, St. Louis, 8 Exhibit No. 1 Notice to take Discovery Depo 23 7 Missouri 63110. 8 Exhibit No. 2 Report, 4.4.07 9 Exhibit No. 3 Invoice 23 23 APPEARING TELEPHONICALLY: The Defendants Aurora 9 Pump Company, Kentile Floors, J.C. Whitney & Company, SPX Cooling Technologies and Dezurik were represented Exhibit No. 4 Curriculum Vitae 10 Exhibit No. 5 Report, 4.27.07 23 23 10 by Richard McLennan, Esq., of the law firm of Gunty & McCarthy, 150 South Wacker Drive, Suite 1025, Chicago, 11 Illinois 60606. 11 12 The Defendant Marathon Petroleum Company, LLC, 12 13 was represented by Eric P. Hall, Esq., of the law firm 13 (The original exhibits were retained by the court of HeplerBroom, 103 West Vandalia Street, Suite 300, 14 Edwardsville, Illinois 62025. 14 reporter and attached to Mr. Ruckdeschel's transcript.) 15 APPEARING TELEPHONICALLY: The Defendant Borg 15 16 Warner was represented by Don Ward, Esq., of the law 16 firm of Herzog Crebs LLP, 515 North 6th Street, Suite 17 2400, St. Louis, Missouri 63101. 17 18 18 APPEARING TELEPHONICALLY: The Defendants Phelps 19 Dodge Industries, Inc., Kohler Company, McKesson 19 Corporation, Mohawk Industries, Daimler-Chrysler 20 Company, LLC, and Parker-Hannifin Corporation were 20 represented by Jim Bentivoglio, Esq., of the law firm 21 21 of Heyl, Royster, Voelker & Allen, 103 West Vandalia, Suite 100, Edwardsville, Illinois 62025. 22 22 23 23 APPEARING TELEPHONICALLY: The Defendant Sunoco was represented by Giuseppe Giardina, Esq., of the law 24 24 firm of Husch & Eppenberger, 190 Carondelet Plaza, Suite 600, St. Louis, Missouri 63105. 25 25 1 (Pages 1 to 4) POHLMAN REPORTING COMPANY (314) 421-0099 Page 5 Page 7 1 APPEARING TELEPHONICALLY: The Defendants Gibson-Homans/Baltimore-Ennis Lands Company was 2 represented by Nicholas Lykins, Esq., of the law firm of Johnson & Bell, 33 West Monroe Street, Suite 2700, 3 Chicago, Illinois 60603. 4 APPEARING TELEPHONICALLY: The Defendant T. H. 5 Agriculture & Nutrition, LLC, was represented by Peter Maginot, Esq., of the law firm of Lathrop & Gage, 10 6 South Broadway, Suite 1300, St. Louis, Missouri 63102. 7 APPEARING TELEPHONICALLY: The DefendantS 8 American Standard, Inc., and Weyerhaeuser were represented by Ashley Davis, Esq., of the law firm of 9 McGuireWoods, LLP, One James Center, 901 East Cary Street, Richmond, Virginia 23219. 10 11 APPEARING TELEPHONICALLY: The Defendants Clark-Reliance Corporation, Continental Teves, Inc., 12 and Cooper Electric Supply Company were represented by Timothy McGuire, Esq., of the law firm of Reeg & 13 Nowogrocki, LLC, 120 South Central Avenue, Suite 750, St. Louis, Missouri 63105. 14 15 The Defendant Exxon Mobil Company was represented by Bruce T. Bishop, Esq., of the law firm 16 of Willcox & Savage, One Commercial Place, #1800, Norfolk, Virginia 23510. 17 18 The deposition was videotaped by Art Brown, in association with Pohlman Reporting Company, 211 North 19 Broadway, Suite 2040, St. Louis, Missouri 63102. 20 21 22 23 24 25 1 apologize for any problems. If you cannot hear me, 2 just let me know, and I'll repeat the question. 3 A Okay. 4 Q Great. 5 Doctor, can you tell me what documents you 6 brought with you tonight? 7 A Yes. I brought a copy of the notice, my 8 report of April 4, 2007, in this case, my invoice in 9 this case dated April 6 of 2007, and a copy of my 10 curriculum vitae. 11 Q Okay. Is there another report that you've 12 issued in this case? 13 A No. 14 Q Okay. Is there a supplemental report 15 dated April 27? 16 A Oh, yes. Yes, there is. 17 Q Do you have that with you? 18 A I don't have that with me. I'm sorry. 19 Q All right. That's fine. 2 0 MR. RUCKDESCHEL: What I'd like to do, 21 madam reporter, at an appropriate time, we'll mark - 2 2 and we don't need to do it now, but we'll mark the 2 3 notice as 1, the April 4 report as 2, the invoice as 2 4 Exhibit 3 and the curriculum vitae as Exhibit 4. 2 5 BY MR. RUCKDESCHEL: Page 6 Page 8 1 THE VIDEOGRAPHER: This is the videotape 2 discovery deposition of Dr. Mark Wick. Today's date 3 is May 17, 2007, and the time is 6:42 p.m. This is 4 the case of Richard Mahoney versus A. W. Chesterton, 1 2 3 4 Q Now, Doctor, how much is the invoice for? A $1600. Q What does that reflect as a charge? A It reflects review of the pathology 5 Inc., et al. The case number is 06-L-1119 in the 5 materials and the medical records. That's four hours' 6 Madison County Circuit Court. My name is Art Brown. 6 worth of work. 7 I am the videographer representing Pohlman Reporting 7 Q Four hours at 400 an hour? 8 Company located at 211 North Broadway Street, St. 8 A Yes. 9 Louis, Missouri. All counsel will be reflected on the 9 Q Is that your standard rate? 10 stenographer's record. 10 A Yes. 11 11 Q Is that what you charge for testifying in 12 MARK WICK, M.D., 13 having been duly sworn, testified as follows: 14 15 DIRECT EXAMINATION 16 BY MR. RUCKDESCHEL: 17 Q Good evening, Dr. Wick. Can you hear me 18 okay? 19 A Actually, your audio's a little bit funny. 12 court as well? 13 A No. Depositions and court testimony are a 14 different rate. Depositions are 500 an hour. Court 15 testimony is 4250 a day. 16 Q What does that work out to an hour? I'm 17 bad at math. 18 A You mean the court appearances? 19 Q Yeah. 20 It's a little garbley. So if you can speak up 2 0 A It's not an hourly rate. It's a daily 21 consistently, that would be great. 22 Q Sure. Is this any better? 21 rate. So it's the same whether I'm in court for two 22 hours or six hours. 23 A A little bit, yes. 24 Q All right. I'll do my best. I have you 23 Q Okay. I got you. 24 Were there any drafts of the April 4 25 on a speaker because I'm here with my colleague. I 2 5 report? 2 (Pages 5 to 8) POHLMAN REPORTING COMPANY (314) 421-0099 Page 9 Page 11 1 A No. 1 Q Approximately how many times in the last 2 Q Were there any corrections made to it 2 two years? 3 after you first provided it to counsel? 3 A I can't say with any certainty because I 4 A No. 4 don't keep those sorts of records, but I would say 5 Q Are your opinions in this case reflected 5 it's been probably ten times or so in the last two 6 in your April 4, 2007, report as supplemented by the 6 years. 7 April 27 report? 7 Q Okay. In 2006, sir, can you approximate 8 A Yes. 8 for me how much money you made working as an expert 9 And, by the way, I have a copy now of the 9 witness? 10 April 27 report that defense counsel supplied. So we 10 A Yes. I made $100,000. And that's a 11 have that here. 11 combination of both medical malpractice work and 12 MR. RUCKDESCHEL: Okay. We'll mark that 12 asbestos litigation. And I don't keep track of the 13 as 5, madam reporter, at the end of the proceeding. 13 proportions regarding either of those two sources of 14 BY MR. RUCKDESCHEL: 14 income. 15 Q Let me ask you the question again, then. 15 Q Okay. At whose request have you provided 16 Are your opinions in this case reflected 16 medical malpractice testimony? And I mean plaintiff? 17 in the April 4 and April 27 report? 17 Defendant? Both? 18 A Yes 18 A It's about equally split between 19 MR. HALL: Objection as to overbroad. 19 plaintiffs and defendants. 20 BY MR. RUCKDESCHEL: 20 Q Okay. And in asbestos cases, have you 21 Q And the answer to that, Dr. Wick? 21 provided testimony at the request of attorneys 22 A Well, my -- my opinions are generally 22 representing plaintiffs? 23 reflected there. I can't say that they're going to 23 A In the last couple of years, no. 24 cover each and every question that you ask me tonight. 24 Q Okay. When was the last time that you did 25 But, basically, the -- my thinking on the case is 25 so? Page 10 Page 12 1 outlined in those two documents, yes. 1 A Probably about ten years ago. 2 Q Are the materials that you reviewed 2 Q How many times have you done so in your 3 reflected in your reports of April 4 and April 27, 3 career? 4 2007? 4 A Again, I'm estimating, because that's not 5 A Yes. 5 the sort of thing that I keep track of, but I would 6 Q Have you reviewed any of Mr. Mahoney's 6 say maybe five or six times. 7 deposition testimony? 7 Q Okay. And can you estimate for me, 8 A No. 8 Dr. Wick, on an average basis how many asbestos cases 9 Q Have you been informed about the substance 9 you would review in a typical year in the last ten 10 of any of Mr. Mahoney's deposition testimony? 10 years? 11 A No. 11 A Well, again, it's not the sort of thing I 12 Q Have you reviewed the reports or testimony 12 keep track of either, but I probably do now -- like 13 of any other experts in this case? 13 I've got a bunch of other things going on. I probably 14 A No. 14 do about five new cases each month. 15 Q Have you asked to review any of that 15 Q Five -- I'm sorry. Was that a range you 16 material? 16 provided? 17 A No. I never do. 17 A No. I say I probably do about five new 18 Q Who has retained you in this case? 18 asbestos cases each month. 19 A Roberts-Perryman. 19 Q Five new asbestos cases. 20 Q On behalf of what defendants? 20 A Yes. 21 A I don't know. That's something I usually 21 Q Okay. I understand. 22 don't ask. 22 Now, has that number decreased in recent 23 Q Have you worked for Roberts-Perryman 23 years? 24 before? 24 A Yes, because I've got other projects going 25 A Yes. 25 on. I'm presently editing two books, and I've got a 3 (Pages 9 to 12) POHLMAN REPORTING COMPANY (314) 421-0099 Page 13 Page 15 1 lot of other responsibilities. 1 Q And the same for that material; no lung 2 Q When did that decrease begin? 2 tissue and no pleural tissue uninvolved with tumor? 3 A Oh, I'd say about two years ago is when a 3 A That's correct. 4 lot of the projects ramped up. 4 Q Okay. In the next paragraph of your 5 Q Okay. Prior to that time, can you give me 5 report, Doctor, there's a sentence that states, quote, 6 a monthly average for new asbestos cases that you were 6 With regard to the causation of this patient's pleural 7 looking at in a typical year? 7 tumor, it has been contended that the lesion arose as 8 A In a year, probably about 100 to 120 a 8 a consequence of putative exposure to asbestos, close 9 year. 9 quote. 10 Q Thank you, Doctor. 10 Do you see that sentence? 11 Doctor, do you agree that Mr. Mahoney has 11 A Yes. 12 malignant pleural mesothelioma? 12 Q Are you asserting that Mr. Mahoney is 13 A Yes. 13 being untruthful in any way in his testimony? 14 Q Do you agree that that disease is almost 14 A I'm -- no. I'm asserting that Mr. Mahoney 15 certainly going to be the cause of his death? 15 can't say what his asbestos exposure was. 16 A Well, I don't know what his current status 16 Q What is the basis for your statement in 17 is right now, but absent other activity from other 17 that regard? 18 diseases that he has, yes, mesothelioma is almost a 18 A Well, no one can. 19 uniformly fatal disease. 19 Q Why? 20 Q Have you ever met Mr. Mahoney? 20 A Because asbestos exposure is an objective 21 A No. 21 piece of data, not a verbal piece of data. And 22 Q Doctor, looking at your April 4, 2007, 22 Mr. Mahoney, nor anybody else, can say at this point 23 report on the first page. 23 what his objective quantitative asbestos exposure is. 24 A Okay. I have it. 24 Q What quantity of asbestos exposure is 25 Q Okay. The last - 25 necessary for you, Dr. Wick, to attribute a malignant Page 14 Page 16 1 A You're kind of coming in and out on the 1 pleural mesothelioma to exposure to asbestos? 2 audio. 2 A A quantity in lung tissue that is 3 Q All right. Thank you for letting me know. 3 sufficient either to cause radiographic markers of 4 And I will -- again, I'm having a phone difficulty, 4 above background exposure, to wit, pleural plaques or 5 but we'll do our best. 5 pleural calcifications, or even better, in a digestion 6 There is a paragraph that says, "My 6 study of lung tissue, a quantity that is clearly - 7 microscopic examination..." Do you see that 7 clearly in excess of that of an age- and sex-matched 8 paragraph? 8 control population. 9 A Yes. 9 Q Dr. Wick, I want to ask you a hypothetical 10 Q All right. Am I correct that all of the 10 question. Here's my hypothetical question: An 11 materials you saw -- pathological materials you saw in 11 individual named Mr. Smith worked at a Johns-Manville 12 connection with your April 4, 2007, report was tumor? 12 factory making amosite-containing asbestos thermal 13 A Yes. 13 insulation. 14 Q Okay. And so you had no lung tissue to 14 Okay. That's the first part. Are you 15 determine whether there was pathological evidence of 15 with me? 16 asbestosis? 16 A Yes. 17 A That's right. 17 Q All right. Contemporary competently 18 Q And you had no nontumor pleural tissue 18 performed self-level measurements measure consistently 19 from which to determine whether there was pathological 19 dust levels of 10 fibers per cc of air on a 20 evidence of pleural plaques? 20 time-weighted average basis in that factory. 21 A Yes, that's right. 21 That's the next part. Do you have that? 22 Q With regard to the materials you were 22 A Yes. 23 provided in connection with your April 27 report, am I 23 Q Okay. Mr. Smith works in that factory for 24 correct that that material was all tumor as well? 24 40 years, eight hours a day, at 10 fibers per cc of 25 A Yes. 25 amosite asbestos. 4 (Pages 13 to 16) POHLMAN REPORTING COMPANY (314) 421-0099 Page 17 Page 19 1 You with me so far? 1 A Well, I don't use the word "authoritative" 2 A Yes. 2 because I know what it means -- I'm enough of an 3 Q Okay. Now, the fourth part is Mr. Smith 3 amateur lawyer to know what it means in the eyes of 4 develops a malignant pleural mesothelioma. 4 the law. He's certainly a well-respected, scholarly 5 Do you understand the fifth part of the 5 individual. But "authoritative" is a word I don't 6 hypothetical? 6 use. 7 A Yes, I do. 7 Q Okay. Are you aware that Dr. Roggli 8 Q All right. Mr. Smith does not have confirmed the diagnosis of malignant mesothelioma in 9 radiological evidence of plaques, asbestosis, and 9 this case? 10 there is no tissue available for a digestion or to 10 A Well, so did I. So I guess we agree on 11 pathologically confirm plaque or asbestosis. 11 that point. 12 That's the sixth part. Do you understand? 12 Q Okay. Do you have any knowledge as to 13 A Yes, I do. 13 whether Dr. Roggli considers Mr. Mahoney's tumor to be 14 Q Okay. Is Mr. Smith's mesothelioma caused 14 asbestos related? 15 by his exposure to asbestos in the Johns-Manville 15 A No, I have no knowledge of what he thinks 16 factory? 16 about that. 17 MR. HALL: Objection as an incomplete 17 Q I want you to assume hypothetically that 18 hypothetical. 18 Dr. Roggli believes that Mr. Mahoney has an 19 A Well, in that hypothetical, you have a 19 asbestos-related mesothelioma. 20 number of assumptions that would have to be made in 20 Is it fair to say you disagree with him if 21 order to say yes. And scientists and physicians do 21 that is the case? 22 not or at least should not make assumptions. 22 MR. HALL: Objection. Assumes facts not 23 So the answer to your question would be 23 in evidence. 24 that there is -- there would be, in your hypothetical, 24 A Well, you're asking me to assume something 25 no objective support for the contention that the 25 that you're not able to show me or have me read, but Page 18 Page 20 1 mesothelioma was caused by asbestosis. It would be a 1 if he or anybody else feels that this tumor is 2 very similar scenario to that pertaining to 2 definitively related to asbestos, I'd have to say, 3 Mr. Mahoney's case. 3 yes, I disagree. 4 BY MR. RUCKDESCHEL: 4 BY MR. RUCKDESCHEL: 5 Q Yes, it would. 5 Q Okay. Have you reviewed any of the 6 Now, Doctor, on page 3 of your report, 6 radiological films in this case? 7 there is a paragraph where you cite to Dr. Victor 7 A No. I've reviewed all of the reports on 8 Roggli's book from 1992. Do you see that paragraph? the films from the hospital radiologist but not the 9 A The paragraph beginning "Plaques"? Or films themselves. 10 where -- where are you, on page 3 or page 4 or where? 10 Q Did any of the reports that you reviewed 11 Q Page 3 there's a paragraph that starts, 11 reflect evidence of pleural plaques? 12 "These data agree well with the epidemiology..." 12 A No. 13 A Okay. I see it. I see it. 13 Q I'm sorry. What was that answer, sir? 14 Q Okay. Am I correct that you are there 14 A No, they did not. 15 citing Dr. Victor Roggli's book titled Asbestos 15 Q Okay. I'd like you to turn back to the 16 Associated Disease. 17 A Yes, I'm citing Roggli, Greenberg and 16 first page of your report, Doctor. 17 A Okay. 18 Pratt. 18 Q The last complete sentence on the first 19 Q All right. And that's the volume -- the 19 page states, quote, Objective scientific criteria are 20 first edition of that book, correct? 20 necessary for attribution of a mesothelioma to 21 A Yes. The same statement is present in the 21 asbestos exposure because those criteria are the only 22 second edition. 22 ones that are scientifically verifiable, close quote. 23 Q You agree that Dr. Roggli is a 23 Do you see that sentence? 24 well-respected and authoritative figure with respect 24 A Yes. 25 to the diagnosis of asbestos-related diseases? 25 Q Can you tell me which, if any, of the 5 (Pages 17 to 20) POHLMAN REPORTING COMPANY (314) 421-0099 Page 29 reflect8:3 20:11 reflected 6:9 9:5,16 9:23 10:3 reflects 8:4 regard 14:22 15:6 15:17 regarding 11:13 related 19:14 20:2 25:10 rely 22:6 repeat 7:2 report 2:8,10 7:8 7:11,14,23 8:25 9:6,7,10,17 13:23 14:12,23 15:5 18:6 20:16 21:1 21:12,17 reported 1:20 reporter 2:14 7:21 9:13 reporting 5:18 6:7 reports 10:3,12 20:7,10 represented 3:19 3:22 4:1,5,9,13,16 4:20,23 5:2,5,8,12 5:15 representing 6:7 11:22 request 11:15,21 respect 18:24 responsibilities 13:1 retained 2:13 10:18 review 8:4 10:15 12:9 reviewed 10:2,6,12 20:5,7,10 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