Document Exb76YOQ9G6Ykn86wpL98GkeL

1 MS. TOSTANOSKI: Are you done? Page 1841 2 MR. WILLIAMS: I just want to make one 3 further point, Your Honor. 4 I will go ahead and submit a written proffer 5 of a couple of lines of questions with supporting 6 materials for your review at a later time for 7 inclusion into the court record. 8 Thank you. 9 THE COURT: Thank you. 10 Ms. Tostanoski. 11 MS. TOSTANOSKI: Very briefly. Despite the 12 fact that Dr. Hammar was proffered as only in the 13 Grewe case, he did cover a number of generic issues. 14 One particularly, Mr. Ignatowski asked the 15 doctor a question as to whether or not sand, silica or 16 lime caused or contributed to mesothelioma. Those are 17 ingredients only of plaster. 18 I am not aware of any exposure of Mr. Grewe 19 to sand, silica or lime. I think that was an attempt 20 to use him in the Vandergucht case, Your Honor. 21 And if permitted, Mr. McGowan or myself