Document Gzv2242a8kr3rgGKr9dJpa71V

In The Matter Of: Judith Bechtold, et al. v. Monsanto Company, et al George Levinskas, Ph.D June 7, 1994 Gore & Perry Reporting Company 100 North Broadway Suite 1175 St. Louis, MO 63102 (314) 241-6750 or (314) 621-4790 Original File levg0607.arr, 54 Pages Word Index included with this Mim-U-Script WATER PCB-SD0000048349 Judith Bechtold, et aL v. Monsanto Company, et aL George Levinskas, Plx,D June 7,1994 IN THE CIRCUIT COURT - CITY OF ST. LOUIS STATE OF MISSOURI JUDITH BECHTOLD, wile ol/and STEPHEN E. BECHTOLD, ELIZABETH TAMEWITZ, as Personal Representative ol her deceased husband, Kennelh F. Tamewitz, KELLIE LEE TRISLER, as Personal Representative ot her deceased mother, NINA TRISLER, PHYLLIS GOODMAN, as Personal Representative ot her deceased husband, CHARLES GOODMAN, JR,, Plaintiffs, vs. NO. 822-00911 MONSANTO COMPANY and WEST1NGHDUSE ELECTRIC CORPORATION, Defendants. Deposition ot GEORGE LEVINSKAS, Ph.D. Taken on June 7, 1994 Page 1 - IN THE CIRCUIT COURT - CITY OF ST. LOUIS STATE OF MISSOURI JUDITH BECHTOLD, wfle ol/and STEPHEN E. BECHTOLD, ELIZABETH TAMEWITZ, as Personal Representative ol her deceased husband, Kenneih F Tarrtewiiz, KELLIE LEE TRISLER, as Personal Representative of her deceased mother, NINA TRISLER, PHYLLIS GOODMAN, as Personal Representative of her deceased husband, CHARLES GOODMAN, JR., Plaintiffs, vs. NO. 922*00911 MONSANTO COMPANY and WEST1NGHOUSE ELECTRIC CORPORATION, Defendants. Page 2 Deposition ol GEORGE LEVINSKAS, Ph.D., taken on behalf of the Plaintiffs, at the law offices of Husch L Eppenberger, 100 North Broadway, Suite 1300, in the City of St. Louis, State of Missouri, on the 71h day of June, 1934, before Victoria L. Wilson, Registered Professional Reporter and Notary Public. Page 3 Page 4 APPEARANCES OF COUNSEL: FOR THE PLAINTIFFS: MR. C. JOSEPH MURRAY MURRAY LAW FIRM 909 Poydras Street, Suite 2550 New Orleans, LA 70112 FOR THE DEFENDANT MONSANTO COMPANY: MR. THOMAS M. CARNEY Husch & Eppenberger 100 North Broadway, Suit 1300 St. Louis, Missouri $3102 FOR THE DEFENDANT WEST1NGHOUSE ELECTRIC: MS. JEANA D. McFERRDN Lewis, Rice & Fingersh 8t82 Maryland Avenue, Suit 400 St. Louis, Missouri $3105 INDEX PAGE Examination by Mr. Murray Examination by Mr. Carney Examination by Mr. Murray EXHIBITS (None marked) 6 45 4$ Page 5 Page 6 ID GEORGE LEVINSKAS, Ph.D. (2) of law ful age, having been first duly sworn to 13) testify the truth, the whole truth, and Ns nothing but the truth in the case aforesaid, |5] deposes and says in reply to oral [6] interrogatories propounded as follows, to-wit: Gore & Perry 800 878-6750 I?) EXAMINATION 18) QUESTIONS BY MR. MURRAY: 19) Q: Good morning, Dr. Levinskas. My name |ioj is Joe Murray. I represent the plaintiffs in up this case and I'm here today to ask you U2) various questions about some of the issues U3) involved in the case. Most of the issues in |H) this case are similar, if not identical, to psithe issues involved in the Cecil Scott versus U6) Monsanto case which was tried back in 1987 or [17] '88, as I remember it, and I believe you gave [is] testimony in that case, as well as a U9] deposition; is that correct? 120) A: I was deposed. I did not testify. 121) Q: Okay. I have got your deposition 122) here and I'm going to try not to repeat what 123) was asked in that depo sition to try and [24) shorten this up as much as possible. So most 125J of the questions I will be asking you today Page 7 U) will relate to the time period after 1987, [2) okay? 13) A: 1987? N) Q: '87 when you were deposed, yes, sir. [5) I say most, not all. 16) Now, as you know from being de posed [7) before, this lady is going to be taking down is) everything that's said so it is necessary for 19] you to answer out loud whenever a question is no] ad dressed to you, okay? UD A: Yes. 112) Q: Okay. Now, Dr. Levinskas, I want to (13) go way back with you right now and talk about 114) your education, both undergraduate and U5) graduate school, okay? Give me the name of ii6) the col lege that you graduated from in [17] un dergraduate school. [is] A: Wesleyan University, 119) Q: And as I understand it, that was a 120) degree in chemistry? 121) A: It was a major in chemistry, yes. 122) Q: BS? 123) A: BA,AB. 124) Q: What year was that? 125) A: 1949. Page 8 ID Q: Were there any toxicology courses 12) that you took in your under graduate studies? 13) A: None. Hi Q: And as I understand it, you did not 15) receive a Master's but went straight to a 16) Ph.D., correct? [7] A: Right. 18) Q: And what school was that from? 19) A: University of Rochester.________ Min-U-S cript no) Q: Is that different than Rochester UD Institute ofTechnology? 112) A: Yes, sir, it is. U3l Q: Separate college completely? H4) A: Completely separate. U5) Q: What year did you receive your Ph.D.? lie) A: 1953. ' U7) Q: And in what field was that Ph.D. 118) awarded? U9) A: Pharmacology. 120) Q: Would that be the same course that 1121) would take if I wanted to be a pharmacist? 122) A: No. [23) Q: Pharmacology relates to what? Tell [24] me generally what that is. 125) A: It is the study of the science of Page 9 ID drugs, their effects, pi Q: Does it include the study of the b) effects of chemicals that are not consid ered HI as drugs? 15) A: It covers some but it is not [6) pri marily directed to that subject. 17j Q: Tell me -- can I make a distinction is) for our purposes today between tox icology and 19) pharmacology, meaning the -- for our purposes uoj "toxicology" referring to health effects or [ip toxico logical effects of chemicals and [12) "pharmacology" would be the effects of chugs? U3) MR. CARNEY: Let me object. Are you [14) asking him if it is okay if you do that or are ii5) you saying is that a fair way to do it? 116) MR. MURRAY: I'm asking him if we can in) agree on that definition for these purposes nsj today. 119) A: I don't think it would be a valid [20]definition. 121) Q: Tell me how we can distinguish 122) between those two fields, if you can. 123) A: I think the nature -- the intent of 124) the chemicals differs. Any drug given in [25) excess dose will produce toxic signs so you Page 10 ID are studying the effects of chemicals, both [2] good and bad, on biological tis sues or living [3) organisms and I accept one set of chemicals as N) more associ ated with industry and the other is (5) more associated with medicine but I don't [6) think that distinction is really this -- 17] A: I would sayatthepresenttime that 18) the procedures are probably [9] indis tinguishable. Back when I started out, [ios there was a tendency to be more -- different up spectrum of tests being used with some overlap [ 12] in each of these two fields. Page 1 - Page 10 WATER PCB-SD0000048350 George Levinskas, Ph.D June 7, 1994 Judith Bechtold, et aL v. Monsanto Company, et aL (131 Q: That's what I want to get into today (i4) and I'm talking now in terms of back when you 115) were doing your graduate work in the early [16] fifties. What were the standard tests run on ii7j industrial chemicals to determine the toxic (is) effects on humans, if there were any? 119) MR. CARNEY: In the fifties? (20j MR. MURRAY: Yes, I'm talking about 121]the early fifties. [22] MR. CARNEY: I'm going to object [23] because I don't know that this wit ness was [24] involved. When did you graduate from -- [25] A: '53. Page 11 ID MR. CARNEY: '53. You know, all I'm [2] saying is don't speculate. If you know how to 13] answer his question from firsthand knowledge, [4] that's fine but don't speculate about what you [5] might think happened before you were in volved [6] in that area. [7] A: Oh, back in the fifties there were no 18] standards or reference points or defined, 19] agreed-upon procedures for doing the testing, (ioj either in drugs, that I am aware of, or in in) industrial chem icals. [12] Q: Okay. Tell me, then, what the study 113] of pharmacology was all about during that time 114] period. What type of courses is did you [15] take? What was the general thrust of your 116] studies? [17] A: I took more or less the pre-clinical (is) sciences that the medical students took at the [19] university -- the medical school at the (201 University of Rochester -- physiology, [21] biochemistry, pharma cology -- subjects of that [22] sort, the pre-clinical sciences. 123] Q: Did any of those courses deal with [24] the tests that were being used at the time, [25] whether there was stan dard tests or not, the Page 12 IU potential, the possible testing that could 12] occur to determine the toxic effects of either [3] drugs or chemicals on humans? 14] A: We had laboratory sessions with [5] tests, if you will, or lesson plans that [6] demonstrated the effects of chemicals. [7] Insofar as I recall or I can recall from [8] others, there were no -- there were no [9] procedures describing testing or how one goes no) about finding the ad verse effects of [ii] chemicals. [i2] Q: Well, how were they determined back [13] then? [14] A: Largely through the efforts of [15] individual investigators and their own [16] thoughts. U7] Q: And they would, I assume, de velop 118) tests or experiments or some son of 119] scientific procedure to deter mine what the 120) adverse effects might be? [2i] A: Yes. 122] Q: Ail right. And during your studies 123] at the University of Rochester, were you made 124] aware of the procedures that these individuals 125] would use? Page 13 [i] A: The textbooks that were used would [2] describe the experiments or refer to the [3] experiments that earlier researchers had done [4] to uncover or discover or understand the [51 biological effect of drugs. To that extent, [6j we were exposed to testing procedures which [7] was a recital of an individual investigator's 18) efforts and hopefully some exposure to his way (9) of thinking. [10] Q: So back even in the early fifdes Hi) when an article, scientific article, was [i2] published talking about the re sults of an [13] experiment that was run, the person writing [i4] that article would usually talk about what he [15) did in order to reach his conclusions, right? [16] A: That would be common pracdce, yes. U7] Q: In the early fifdes, did it ever [18] occur that a scientist would use feeding [19] studies to try and determine the toxic effects [20] of drugs? And when I am saying, "feeding 121] studies," I'm talk ing about animal studies. 122] A: There are published reports of animal [23] studies that predate thefifties, yes. 124] Q: And did those studies have a [25] generally accepted length of time that they Page 14 [1] would run? [2] A: I have -- [3] MR. CARNEY: I'm going to object to 14] the question as to what's meant by "generally [5] accepted." I think he has testified there [6] really wasn't any gen erally accepted procedure m during that time. [8] A: I have seen reports labeled, "The [9] Chronic One-month Toxicity Studies in Rats," [io] and I have seen reports, "Chronic Two-year [11] Toxicity Study in Rats." If the term [12] "chronic" was used for one-month and for 24- [13] month duration tests, I would have to conclude [14] there was very little standardkation. [15] Q: There were, during the early fif ties [16] and possibly before then, twoyear studies U7] that were run, feeding studies? [is] A: Yes. 119) Q: Do you remember during that time [20] period -- |2i) MR. CARNEY: Are you talking about [22] for industrial chemicals or drugs or anything? [23] MR. MURRAY: No, I'm just talking 124] about feeding studies. 125] MR. CARNEY: Okay. Page 15 ID Q: Do you remember why, if there. were [2] reasons given, why one person might choose one [3] month and one person might choose two years if [4] they were both labeled "chronic"? [5] A: I would have no reason to even [6] speculate why they would use that ter minology. [7] Q: Now, let me get to the gist of [8] Mr. Carney's previous objection. Were these 19) feeding studies only done with regard to 110] pharmaceutical drugs as opposed to industrial [11] chemicals? 112) MR. CARNEY: Are you talking about [13] the two-year ones? 114] MR. MURRAY: Yes. [15] A: I wouldn't profess to be able to U6] speak to all the literature but my general [17] impression, I think it would be substantiated, [is] is that most of the long-term studies at that 119] time were being done on non-drug materials. [20] Q: Okay. Industrial chemicals, then? [21] A: Industrial or other use chemicals, [22] yes. [23] Q: Let me make sure we are not [24] miscommunicating. Is it your understanding [25] that the long-term studies were being done on Page 16 ID the industrial chemicals? [2] MR. CARNEY: Let me object. Again, [3] don't speculate. If you know -- [4] Q: I'm only asking for your [5] recol lection. [6] MR. CARNEY: But if he is talking \i\ about in the fifties, now -- 18] A: I would say in the fifties that there [9] were probably more long-term studies done on (ioj non-drug uses of materi als than on drug uses. HD Q: Now, when you graduated in 1953, what [12] did you do? U3) A: I went to the University of [14] Pittsburgh to the department of occupa tional U5Jhealth in the school of public health, [16] graduate school of public health, to do 117] teaching and research. [18] Q: What fields were you -- first of all, U9] let's go with teaching.What fields were you 120] teaching in? [2i] A: I developed a course that was called [22] "Applied Toxicology" and I gave a series -- [23] not a series -- I gave lectures in several [24] other courses at the school. ______________________ Page 11 - Page 16 Min-U-S cript Gore & Perry 800 878-6750 _ >, - " , ' _ ` \ ' * ` - _ _ ' . WATER PCB-SD0000048351 Judith Bechtoid, et aL v. Monsanto Company, et aL George Levinskas, Ph.D June 7,1994 [25) Q: And what was your field of re search?_ Page 17 ID A: We had contracts with the govern ment |2) and the general topic was health hazards of 13) military chemicals and, most specifically, a [4j class of com pounds called boron hydrides. 15) Q: Boron hydrides? [6] A: Hydrides. [7) Q: And what were you attempting to learn [s] from your research? 19) A: We wanted to improve our rio) un derstanding of what effects these chem icals in) would produce in military per sonnel who were [12] using them and also to get some idea of how 113] they produce these effects and what we might |i4) do to protect or to treat indi viduals who [15] might be exposed. [16) Q: Were your efforts directed to wards [17) acute effects or chronic ef fects or was any |i8] distinction made? U9) A: Predominantly acute effects be cause [20) the materials were very lim ited in supply. [2i) Q: And what type of tests or experi ments [22) did you develop to try and learn about these [23] chemicals? 124) A: We did what many other people have [25) done; we would take animals, expose them to Page 18 m the chemicals by the various routes of [2] exposure that people would be exposed if they |3) handle them. [4) Q: And that would either be injec tion, [5) inhalation or skin absorption? [6] A: Correct, [7) Q: And what were the durations of the [8) tests that you ran? [9) A: As I indicated, most were short no) term. We did one inhalation study for six Hi) months and I spent several months working with 112) test tube experiments without whole animals. Ii3) Q: How long were you at the Univer sity [14) of Pittsburgh? [15) A: Five years. [16) Q: Was the thrust of your research [i7j during that entire five-year period on these [is) boron hydride chemicals? [19) A: That was the major -- the major [20) research effort was on that, yes, it was. [21) Q: Okay. Were there any other [22) chemicals -- let me ask you specifically, were [23] you doing any chronic studies on any chemicals 124) during that fiveyear period? [25) A: No. Page 19 ID Q: Where did you go after the Univer sity |2) of Pittsburgh?___________________ [3) A: I joined the American Cyanamid [4) Company. [5) Q: As I understand it from your previ ous [6) testimony, American Cyanamid had its own m toxicological lab and you were the director of [8) it; is that correct? [91 A: That's correct. [io] Q: What type of chemicals was American pi) Cyanamid producing dur ing that time period? Ii2) A: At that time they had a rather wide U3) range -- agricultural chemi cals, various dyes, U4j polymers, organic chemicals -- general all- [15] around chemical producer. 116) Q: Did American Cyanamid have a policy [17) when you went with them with regard to the [is) testing of its prod ucts? U9) A: I am not aware of any formal pol icy. [20) Q: How did you determine what products pu fo test and which ones didn't need testing? [22) A: There would be a variety of rea sons. 123) One could be regulatory re quirements, another [24) could be cus tomer complaints or employee [25] com plaints, a third one could be just general Page 20 ID interest of the people who were man ufacturing [2] the product wanted to know more about it. 13) Q: You first went with American Cyanamid [4j in 1958? 15] A: That's correct. [6) Q: Didyourun -- let me back up.You [7) left them in what year? 18) A: 1971. 19) Q: During the time period between 1958 po) and 1971, did that toxicological laboratory ui) run any chronic feeding studies? [12] A: Yes. U3) Q: Was that something that was done on a [14] regular basis or was it something unusual? Ii5) MR. CARNEY: I'm going to object to [16) what you mean by "regular basis" or what you [i7j mean by "unusual." Ii8) Q: How often did it occur that you would |i9) run chronic studies? [20] A: First, I guess we would have to [21] define the term "chronic." [22) Q: Okay.What was your definition of [23J "chronic"? [24] A: I would regard any study of less than [25) a year's duration as either being acute or Page 21 11) subchronic. It would be hard to guess but I [2) would say probably -- certainly less than a [3) dozen chemicals at the time at Cyanamid that |4] we ran a chronic study on. [5) Q: When you first went to work there in [6] 1958, were there any chronic stud ies going on [7) at that time? [8j A: There was one that was just being 191 finished when I joined them, po) Q: Do you remember the duration of that pi) test? [12] A: Two years. 113) Q: You used the term "subchronic." I |i4) have also heard the term "subacute" used. p5) What would be the distinction between those [16) two? P7) A: Those of us who use "subchro nic" are [18] older in the field than those who use [19) "subacute." [20) Q: They are basically the same term? [21] A: They cover the same basic term but it [22) is a generational phrase, I think. [23) Q: Are you aware of any chronic studies [24) that were done, let's take the time period [25) while you were at Cyanamid but I want to talk Page 22 ID about just in general terms, not just at 12) Cyanamid, but were you aware of any chronic [3] studies that were done that did not use [4] feeding as the method of exposing the animal [5) to the chemical? [6) A: I have indicated we did a sixmonth [7) inhalation study with boron hydrides. 18) Q: Under your definition, though, that [9) would be subchronic? po) A: That would be subchronic.That's my [i i) definition,though.I am not aware of studies [12] that would last two years other than the [13) feeding studies at that time. P4) Q: Has that changed over the years? Are [15] there any of those type of studies other than [i6j feeding studies done now adays? in) A: Yes. [is] Q: Okay. And would those studies use U9) both inhalation and absorption or only [20) absorption or only inhala tion? [2i) A: Well, absorption is the process of 122) the chemical getting into die animal. 123) Q: I guess I'm talking about skin 124) absorption. 125) A: Skin studies are done; inhalation are Page 23 ID done; feeding are done. 12) Q: And is the general time period used [3] nowadays still about two years? 14) A: It may be slightly beyond two years [5) because some of the strains of rats they are |6) using are living a little bit longer than they m used to. Gore & Perry 800 878-6750 Min-U-S cript Page 17 - Page 23 WATER PCB-SD0000048352 George Levinskas, Ph-D June 7,1994 Judith Bechtold, et aL v. Monsanto Company, et aL [8] Q: Basically, when you do a long-term 19] chronic study, you want to use the -- well, no] let me ask you that. Is the gen eral intent in] when doing a long-term study to try and do it 112] over the life span of the animal? ii3i MR. CARNEY: Object to him [i4] speculating as to what other people's 115] intentions are. (16) A: It depends on the purpose of the ini study and it would be true only for the (18) shorter-lived animals; it would not be true if 119] we were working with elephants. 120] Q: All right.Let's talk about the time 121] period now, Dr. Levinskas, of 1987 and |22] beyond. You were asked various questions in [23] your previous deposi tion about your opinion [24] with regard to health hazards associated with (25] PCB exposure and I guess I want to make sure Page 24 ID or find out if that general opinion has 12] changed in the period subsequent to 1987.1131 guess the thrust of my question is has any new (4) scientific evidence come out that makes you |5] think that exposure to PCB's might cause |6] some thing other than the chloracne liver [7] effects and the dermal effects that you [8] described in your previous testi mony? [9] MR. CARNEY: Well, let me object. I [10] don't think the witness -- he may have |ii] reviewed his testimony in Scott but I'm not [12] aware of it and so I'm not -- I don't want to [13] oppose the line of questioning but I just want [i4] to voice that objection and the other (15] objec tion I would make is this witness isn't [16] being proffered as an expert on what is going |i7] on in science today. He is re tired, as I [is] understand it, so I'm not sure he is qualified 119] to say what is happening in the literature. ' [20] And I don't want you to speculate on [2i] that unless you have followed the literature [22] and are comfortable. [23]Q: I'm sorry about that, Dr. Levinskas. [24] I should have asked you that previously. You (25] are not still em ployed by Monsanto? [1] A: No, I'm retired. Page 25 [2] Q: All right. When did you retire? 13] A: September '91. 14] Q: During the period between '87 and [5] '91, did you attempt to keep up with the [6] scientific literature concern ing PCB's? [7] A: I kept a general interest in it but I [8] did not make a concerted effort to be kept up [9] to date. no] Q: What about the period after 1991?__________________________ _______ Hi] A: Less concerted. [12] Q: In order to be fair to you, since you [13] really -- you haven't reviewed your testimony, ]i4] let me talk just in general terms now about 115] your opin ion today with regard to the toxic [16] effects of exposure to PCB's and let's first |i7] take what I would describe as the acute |is] effects of exposure to PCB's. In your 119] opinion, are there any acute effects of [20] exposure to PCB's? 121] A: I would say as a class of com pounds, [22] they are relatively non-toxic, rather low in 123] toxicity in terms of single exposures by [24] essentially all routes of exposure. [25] Q: So if somebody was working with the Page 26 ID material for a day and got some on their skin [2] and maybe even swallowed a little bit, that 13] normally wouldn't cause any acute effects? [4] And when I say, "a little bit," I talk about [5] some thing that might accidentally get in their [6] mouth as opposed to drinking a glass of it. m A: As I indicated, other than the [8] messiness of the ones that may be oily, I 19] don't anticipate that there would be any [to] significant adverse health ef fects. [11] Q: Now, I would like to talk to you, [12] then, about the potential chronic effects of [13] working with PCB's over a long period of time [14] and I don't want to go into a hypothetical 115] question that talks about, you know, if he got [16] this on his skin every day, I'm talking about 117] the potential effect if some body was really [is] messy with it, what could be the potential 119] effect of it? [20] A: Based on the animal studies, ifyou [21] have repeated prolonged exposure, like many [22] other compounds that we call the chlorinated [23] hydrocarbons, these would be absorbed and they ]24] will attack and damage the liver. 125] Q: In your opinion, is that the only Page 27 m organ they would attack? [2] A: I think that's the first thing that [3] one would see signs of, liver injury, liver [4] damage. [5] Q: So I won't ask you about the -- I [6] guess I'm talking about -- I'm not interested [7] in the symptoms relating from that liver [8] damage. Tell me now if there would be any [9] other health effects other than liver damage. lio] A: I guess my position would be I think [in that unless you can get enough to produce [12] liver damage, I don't think you are going to [13] see anything else. [i4] Q: Okay. I understand that but -- [15] A: Yes. [16] Q: But let's go beyond that. Let's 117] assume that you have got enough to produce 1 is] liver damage. Are there any other potential ]i9] effects that might occur? [20] A: I guess my difficulty here is that if [21] one got liver damage, I would expect someone 122] to notice this and the ex posures would stop. [23] In other words, I can't conceive of someone 124] having bad liver damage and continuing to be [25] exposed until something else trig gers and Page 28 ID something else triggers and some thing else [2] triggers and so I think that the sentinel [3] warning sign would be the liver injury and [4] then that would cease or cause the exposures [5] to cease. [6]Q: Let me ask you this: You talked [7] about chloracne in your previous testi mony. |8] Would chloracne be a possible effect that [9] could be associated with PCB exposure? [io] A: There are very early published [11] reports indicating chloracne from expo sure to [12] PCB's. Subsequently, and not -- I don't mean [13] in the fifties or sixties, but some years [14] after those twenties and thirties exposures, [15] they found that there probably were mix tures [16] of biphenyls with what they the halo axis [17] axis, the chlorinated axis, and that the [is] chloracne may be due to chlorinated paraffins, [19] so I really -- I'm not aware ofany reports [20] attributing chloracne solely to PCB's. I [2i] think there is a lot of confusion in that [22] early literature and I really have a difficult [23] time making up my mind on this. [24] Q: I was going to ask you that. The [25] articles that I have seen, in any event, that Page 29 ID talk about the combinations that may be [2] occurring and what might be caus ing the [3] chloracne versus what other thing might be ]4] causing it, is it gener ally true that none of [5] those articles can ever make a definite [6] distinction as to this chemical is the one [7] that is causing it as opposed to that one? [8] Are you aware of any that have? 19] MR. CARNEY: I'm going to object. I [io] think it is a little -- I assume you are UD talking about the Tricker studies. [12] Q: All of those. All of the studies [13] that you are aware of. Do you know of any of [i4] them that have definitively attributed the [15] chloracne to one chemical as opposed to 116] another? [17] MR. CARNEY: I'm going to object for [18] the record that I think those studies speak [19] for themselves and Page 24 - Page 29 Min-U-Script Gore & Perry 800 878-6750 WATER PCB-SD0000048353 Judith Bechtold, et al v. Monsanto Company, et al George Levinskas, Ph.D June 7, 1994 would be the best evidence [20] of what they say rather than this witness's [21] recollection of what they say and he might not 122] have seen those for a number of years. [23] But if you know for sure -- but I [24] just caution you not to speculate on what they [25] said. Page 30 |i] A: My comment is, I think in this same [2] direction, that these published papers make [3] statements about what they think are causing [4] the chloracne and it is later work which cast [5] doubt on those, the validity of those [6] conclu sions, and since we don't have the m samples that were used, essentially, to go [8] back and analyze, we are not in a position to [9] make a distinction. It is well known that the [ioj so-called chlori nated paraffins, the halo |ii] axis, as a trade name, particularly, are [12] notori ous chloracne producers.I mean that [13] much is known. But some of those early [14] compounds, there is difficulty iden tifying |i5] with certainty what was used and it makes it [i6] difficult to draw con clusions, [17] Q: Okay. And that's my understand ing of [is] the literature, as well. I mean it is not H9] something that can be defin itively stated one [20] way or another, is it? [21] A: No. [22] Q: Now, with regard -- well, let's be [23] specific. Have you read anything over the [24] years between '87 and throughout that makes [25] you believe that PCB's could be a potential Page 31 [1] carcinogen? [2] MR. CARNEY: In humans? [31 Q: In humans, yes. [4] A: I have not seen anything that would [5] cause me to think they would be a potential [6] carcinogen in years. [7] Q: I have some documents that I want to [8] go over with you, Dr. Levinskas, some of which [9] don't have your name anywhere on them and my [ioj intent in asking you about these documents is [11] just to see if you recognize them and can tell [12] me what they are. I'm going to first showyou [131a document which has been marked as [i4] MONS040440. U5] A: I really don't recall having seen [16] this document before. I may have but I really 117] don't -- I really don't -- it doesn't ring a [is] bell. [19] MR. CARNEY: It looks like it is out [20] of something else. [21] MR. MURRAY: That's what I thought [22] and I couldn't tell what it was, that's why I [23] was going to take my shot with Dr. Levinskas. [24] A: it has three other trade names. I [25] don't think those are Monsanto trade names. Page 32 [1] Gofin is not, I'm sure. [2] MR. CARNEY: That's the European PCB, [3] isn't it? [4] A: It sounds like -- looks like an [5] industry type document but I don't re call [6] having seen it before. [7] G: Let me ask you, th en, Dr. Levinskas, [8] ifyou would agree with the statement that [9] when dealing with PCB's at ele vated [ioj temperatures via hot ovens, welding, et [in cetera, where vapors are apparent, inhalation [12] of these vapors must be strictly avoided by [13] using proper exhaust ventilation and organic [14] cartridge respirators or air-blowing apparatus [15] away from operators? [16] MR. CARNEY: I'm going to object to It?] the question because I think it is vague and [i8j it talks about elevated temperatures but it [19] doesn't talk about what they are and, you [20] know, what kind of other ventilation there [21] might be. There are a lot of variables there [22] that I didn't recall in your read ing it that [231 might be necessary to really definitively [24] answer that ques tion. [25] A: There are so-called threshold limit Page 33 [i] values that have been set for Aroclors and at [2] elevated temperatures it would be easier to [3] increase the airborne concentration so taking [4] those two, you would -- it would be prudent to 15] advise people to take extra precautions if 16] they are working in a heated atmo sphere [7] because it just makes the air concentrations [8] that much higher. [9] Q: I guess I should have read that whole [10] paragraph and it does talk about at room in] temperature PCB's give off negligible fumes [12] and are, therefore, harmless to breathing. 113] Would you agree with that? [14] A: I would say yes. [15] Q: At room temperatures, do PCB's give [16] off an odor? [17] A: I haven't really looked at large work [is] places. I'm not conscious of any appreciable [19] odor from the small quantities that I have [20J handled. [21] Q: So you would expect if there is an [22] odor in the air that it is more likely than [23] not it's been heated to some extent? [24] A: Well, the elevated temperatures will [25] increase the air concentration. It is my Page 34 [l] understanding that at room tempera ture the [2] vapor pressure which would indicate the ease [3] with which it gets in the air is so low that [4] they don't represent much of a hazard. I [5] haven't been exposed to,youknow,extended [6] periods of time or large volumes but I don't [7] recall any particular odor asso ciated with it. [8] Q: So your answer is really you don't [9] know? [10] A: Yes. [11] Q: Okay. This is another one ofthose [12] documents that your name is on here, although [13] it doesn't appear that you wrote it. Can you [14] look at that and tell me ifyou recognize it? [ 15] This is, for the record, labeled MONS030773 [16] and when I say, "labeled,'' that's just the [17] Bates number on the first page ofthe [is] document. [19] MR. CARNEY: Did you say his name is [20] on here? - |2i] MR. MURRAY: Not on that page, on the [22] next page. [23] MR. CARNEY: Okay. [24] A: This is an apparent epidemiology [25] study done on Monsanto employees, The primary Page 35 [1] investigator is -- [2] MR. CARNEY: Well, what he asked you [3] is do you recall this document? [4] A: I was going to say I was not in volved [5] in this. This copy came across my desk [6] because Dr. Johanson was reporting to me but I [7] was not involved in it, other than reading the [8] memo. [9] Q: Okay. Who is Dr.Johanson? [ioj A: At that time he was the manager of [in toxicology reporting to me. [12] Q: Do you know if he is still em ployed |i3) by Monsanto? [14] A: Yes. [15] Q: Let me ask you this: During your [16] period at Monsanto, did Monsanto ever run any [17] in-house epidemiologi cal studies, and when I [is] am talking about in-house, I mean actually the [19) employees of Monsanto performing the study? [20] MR. CARNEY: On PCB's? [21] Q: Yes, on PCB's. [22] A: Yes. [23] Q: All right. When was that done? 124) A: This would be one of them, in August [25] '15 .We had a young lady,Judy -- did another Page 36 ID study, I think, and then Bill Gaff)' may have [2] done some later on --JudyZack, I think. I [3] think Judy Zack did one. She Gore & Perry 800 878-6750 Min-U-S cript Page 30 - Page 36 WATER PCB-SD0000048354 George Levinskas, FirD June 7,1994 Judith Bechtold, et al v. Monsanto Company, et aL was in tie hi medical department. And then later Dr.Bill [5) Gaffy joined us as an epidemiologist. I don't [6) know whether he did or not. He may have. 17] Q: Judy Zack. Bill Gaffy. And this one [8] was apparently done by -- is it Doctor or [9] Mister Johanson? [to] A: Doctor. No, let me take it back. I 111) don't know whetherJudy Zack did a PCB study. |i2] She did some studies but I don't recall [13] whether it was PCB's. [H] Q: Was any study, epidemiological study, [is] on PCB's done in-house by Monsanto ever [16] published? ini A: That I'm not aware of. I don't know [is] the answer to that. I don't recall, [19] Q: The general gist of what I under stand [20] from what occurred with Dr. Johanson is that 121] he did some prelim inary epidemiological work [22] dealing with a mortality study, correct? [23] A: I would have to reread the letter. I [24] don't recall. I was not involved in it and I [25] don't recall. Page 37 |i) Q: He mentions a consultant in here. Do [2] you know who that was? 13) A: As I say, I was not involved in [4] that, I don't recall the details of it, [5] Q: He talks about a department 246 [6] cohort at Krummerick. Do you know which [7] department that was? [8] A: No, I do not. [9] Q: Do you know Mr, E. C. Barnes? [10] A: That name doesn't ring a bell. Hi] MR. CARNEY: Is he a Westinghouse [12] person? [13] MR. MURRAY: That's what I don't [14] know. [15] MR, CARNEY: Is this in the forties? [16] MR. MURRAY: Apparently, yes. in] MR. CARNEY: There is a -- [18] MR. MURRAY: But I didn't see the U9] letterhead so I couldn't tell who it is. [20] MR. CARNEY: There is an E. C. Barnes 121] industrial hygienist at Wes tinghouse. The 122] reason I know that is I was just looking at a 123] letter, a 1947 letter, from Barnes to somebody 124] that came out of a Westinghouse file so I [25] assume -- I think it is E, C., I'm not sure, Page 38 ID but that's my assumption. Can I look at that [2] Barnes letter? 13] MR. MURRAY: This is the original. [4] Apparently it was retyped onto this. 15] MR. CARNEY: Let me just read into [6] the record that Barnes Bates stamp. On the [7] original, there is an NPC00002135. In the [8] lower righthand comer there is another Bates [9] stamp number 745090 and at the upper [io] right-hand comer there is an HD000133 and [ii] then there is a -- the typed copy of this [12) letter has a HD000135. 113) MR. MURRAY: Can I go on? 114] MR. CARNEY: Yes. [15] Q: Dr. Levinskas, who is K. Warren [16] Easely? in] A: He is a Monsanto employee who was in [is] ourWashington office in some aspects. [i9] Q: Do you know if he is still em ployed [20] by Monsanto? [2i] A: I'm sure he is not employed. I don't [22] recall when he left. [23] Q: What was his job descripdon when he [24] was employed at the Wash ington office? [25] A: I am not aware of it.When I would Page 39 [i] make visits to Washington to meet with [2] regulatory agencies or some thing, he would be [3] there. I don't know his specific job [4] description. 15] Q: Do you know ifhe was a lawyer or [6] not? [7] A: I don't know his background. [8] (Recess) [9] Q: I'm going to take another shot with [io] you, Dr. Levinskas, and show you a document [ii] which has Bates stamp number SEM76859 and ask [121 you if you have ever seen that. 113] A: I don't really recall seeing this [14] document. 115) Q: Don't recognize the handwrit ing? 116] A: Other than to say it is not mine. [17] Q: Okay.Do you know anybody with the [is] initials "WSJ"? [19] A: I can't think of anybody with those [20] initials. [2i] MR. CARNEY: Did you read the Bates [22] stamp numbers in? [23] MR. MURRAY: Yes.Ireadthe SEM [24] number, anyway. [25] MR. CARNEY: Okay. Page 40 [i] Q: No idea of who may have gener ated [2] this document or where it may have come from? 13] A: As I said, I don't recall seeing it [4] before and I really have no knowledge of it. 15] Q: Okay. This document makes a [6] reference which reads, "Levinskas caused [7] Calandra (IBT) to change lan guage from 'mildly [8] tumoragenic' to 'does not appear to be [9] carcinogenic.'" And then above that statement no] it's got in parentheses, "(How justified?)" [ii] Do you remember anybody at Monsanto ever [12] discussing that issue with you? [13] A: That's been brought up in [i4] de positions. That goes back to a memo I wrote [15] where I had two sets of re ports that IBT had [16] supplied and I reviewed them in their [17] editorial con text and I said since you have nsj basi cally the same findings in all three [19] studies, you have -- in the second goround, [20] you have changed the termi nology. [21] Q: Doctor, I don't mean to interrupt you [22] but you are right, you have dis cussed that [23] issue in previous testi mony. [24] A: That's a reference to that. [25] Q: My question related to do you Page 41 [1] remember anyparticularperson com ing to you [2] during the time at Monsanto and specifically [3] asking you about that issue? And basically [4] what I am trying to get at is somebody who may [5] have generated this document. [6] A: I don't recall anybody coming in [7] specifically to talk to that subject. [8] Q: All right. [9] MR. CARNEY: Other than his [io] con versations with lawyers. [11] MR. MURRAY: Obviously.Obviously. [12] A: So that's what I was trying to refer U3] to. [14] Q: That's the only reason I was ask ing. U5] Again, I don't want to go back into all these [16] other issues. We might be here for a week if [17] I did. [is] With regard to the epidemiological [19] studies that were done in-house at Monsanto, [20) do you know why they were done, at whose 121] suggestion they were done? [22] A: No, I do not know. [23] Q: You were not part of that process as [24] to making that decision to go ahead and do it [25] or not? Page 42 HI A: I was not involved in that. [2] Q: Okay. Was there an epidemiologi cal [3] department or a section at Monsanto? [4] A: No, not at that time. 15] Q: There is a document with an SEM [6] number of 052789 regarding a meet ing that was [7] held with NIOSH appar ently some time in 1974. [8] I will show you that document and just ask you [9] to review it and tell me if you recognize it. [10] A: I have seen this document before in [ii] depositions. To the best of my recollection, 112] I did not meet -- I did not attend this [13] meeting with NIOSH. [14] Q: Okay. Let me just direct your 115] attention to the last page of the docu ment [i6] where it lists those people Page 37 - Page 42 Min-U-S cript Gore & Perry 800 878-6750 WATER PCB-SD0000048355 Judith Bechtold, et aL v. Monsanto Company, et aL George Levinskas, Ph.D June 7,1994 present at the [17] meeting and your name is present along with [is] others for Monsanto Company; is that correct? |i9] A: Yes. (20) Q: That doesn't help you remember the (2i) meeting, huh? Or do you think that that's [22] inaccurate? 123] A: I know Dr.Wagener by reputation [24] only. I do not recall ever having met him. [25] And when I say I don't recall being at this__________________________ Page 43 [l] meeting, I still say I have never met [2] Dr. Wagener personally and had I been at that (3) meeting, I think I would have remembered him, [4] at least. [5] Q: So you think that that's probably a 16) mistake? [7] A: So I don't recall having been at that [8] meeting. [9] Q: Well, let me ask you this: This memo no] talks about a possible study with -- an up epidemiological study with using Monsanto 112] employees and, as best I can tell from this, 113] it appears that NIOSH wants to do it. Do you |i4) know whether or not such a study ever took [15] place? [16] A: I -- I really don't know anything 117] about the epidemiological studies. 118) Q: Okay. Are you aware of the stud ies |i9] that were done in-house by Monsanto on certain 120] Aroclors to de termine dibenzol furan [21) contamina tion and dibenzol dioxin [22) contamina tion? [23] A: I'm not sure of what, if anything, [24] was done for analysis, [25] Q: Generally, are you aware that that Page 44 [1] took place at some point? [2] A: I think they probably were done but I [3] have no knowledge of such studies. 14) Q: Let me ask you about knowledge of any |5) other studies that may have been done outside |6) of Monsanto with regard to that issue and I [7] guess specif ically I'm more interested in the |8) time period after 1987. Are you aware of any 19] recent work that's been done in that field? [10] A: I generally do not pay much atten tion [ii] to the analytical data. I'm really not aware 112] of any analysis. [13] Q: Okay. Let me just make suit I cover [14] all bases and ask you specific ally if you are 115] aware of any work that has been done on any [16] Inerteen prod ucts with regard to furan or |i7) dioxin contamination? [is] A: I have no knowledge of work done on [19] Inerteens. 120) Q: Okay. Let me ask you -- I don't pi) remember this -- did you ever visit the [22] Westinghouse Bloomington plant? [23] A: No. [24] Q: During your time at Monsanto, were [25] you ever asked -- strike that. Page 45 |i] You didn't go to work for Monsanto [2] until after '71? [3] A: July 71 I started. [4] Q: Other than the EBT studies, are you [5] aware of any other chronic toxicity studies [6] that were done by Monsanto on any aroclor [7] product? [8] A: I'm not aware of any others done by [9] Monsanto. [10] Q: Were you aware of any others done at [ii] the request of Monsanto? [12] A: No. U3] MR. MURRAY: Thank you, [H] Dr. Levinskas. That's all I have. [15] MR. CARNEY: Let me just ask you a [16] couple ox questions. [17] EXAMINATION [18] QUESTIONS BY MR. CARNEY: [19] Q: You mentioned a long-term test that [20] was being done at American Cyanamid when you [21) got there. What kind of material was being 122) tested? [23] A: That was a polymer, which is called a [24] wet strength resin, and it was to be used for [25] food packaging. Page 46 [l] Q: You mentioned, I think, that dur ing [23 the time you were at American Cyanamid there 13) were approximately a dozen tests, long-term |4) tests, that were done. Can you tell me what [5] kind of materials, just genetically, were [6] being tested in those long-term tests? [7] A: They are what we call food con tact |8] chemicals used for packaging or holding food [9] and pesticides where there would be the [ioj likelihood of a residue, if used according to uu direc tions. [12] Q: Residue on the food? [13] A: On the food. Ii4] Q: And was it generally true in the [15] fifties that the kind of long-term tests that [ 16) you were familiar with had to do either with |i7) food contact materials or pesticides where [is] there was a resi due? [19] A: I would say that certainly the great [20] majority would be in that cate gory. [2i] Q: Was it customary to your knowl edge in [22] the fifties to do long-term studies on [23) industrial chemicals? [24] A: I would say there were a few, if any, [25) being done on industrial chemi cals. Page 47 [t] MR. CARNEY: Okay. I don't have [2] anything else. [3] EXAMINATION [4] QUESTIONS BY MR. MURRAY: [5] Q: Dr. Levinskas, wasn't "industrial |6) chemicals" the term we used earlier when you [7] talked about that the long term studies that [8] were done were being done on industrial |9) chemicals? [ioj A: I tried to make the comment once or [ii] twice of saying, "non-drug uses," and a food [12] packaging material is or isn't an industrial 113] chemical, depends on how you want to classify [143 it but it is certainly not a drug use. [15] Q: There was certainly no prohibi tion [16] against doing those long-term studies on [i7] industrial chemicals, was there? [18] A: I'm not aware there has ever been a |i9] prohibition against doing studies on a 120] chemical. [2t] Q: I guess the point I am making is [22] there is really -- there wasn't some [23] obstruction to doing it on industrial [24] chemicals as opposed to chemicals that may 125] have contact with food? Page 48 HI A: Probably. The motivating force, 112] guess, in doing them was somebody had to 131 perceive a need for it and it was not a 14) perception in most of the industry that there [5] was need for such studies at that time. [6] That's the only conclu sion I could draw, [7] Q: That's the point I'm making, though, [8] that if somebody wanted to do chronic testing [9] on chemicals in the early fifties, they 110] certainly could have done it and, in fact, ni) chronic testing was being done during that [12] period of time on other types of chemi cals? [13] A: In response to specific needs. [14] MR. MURRAY: Okay. Thank you. [15] MR. CARNEY: I have no further [i6] questions. Page 49 COMES NOW THE WITNESS, GEORGE LEVINSKAS, Ph.D., and having read the foregoing transcript of the deposition taken on the 7th day of June, 1994, acknowledges by signature hereto that ft is a true and accurate transcript of the testimony given on the date hereinabove mentioned. GEORGE LEVINSKAS, Ph.D. Subscribed and sworn to me before this day of_________________________ 1994. My Commission expires;________ _ _ Notary Public vw Bechtold v. Monsanto Page 50 ID State of Missouri [2] SS. [3] City of St. Louis [4] I, Victoria L. Wilson, a Notary Public in [5] and for the State ofMissouri, duly 16) commissioned, qualified and au- Gore & Perry 800 878-6750 Min-U-S cript Page 43 - Page 50 WATER PCB-SD0000048356 Lawyer's Notes ! l i WATER PCB-SD0000048357 Judith Bechtold, et al v. Monsanto Company, et a! George Levinslias, Ph-D June 7,1994 o 052789 42:6 1 100 50:14 1300 50:14 14 51:18 1947 37:23 1949 7:25 1953 8:16; 16:11 1958 20:4,9; 21:6 1971 20:8,10 1974 42:7 1987 6:l6;7:l,3; 23:21; 24:2; 44:8 1991 25:10 1994 50:17; 51:17 1997 51:18 2 24 14:12 246 37:5 5 53 10:25; 11:1 7 71 45:2, 3 745090 38:9 75 35:25 7th 50:17 * 87 7:4; 25:4; 30:24 88 6:17 9 91 25:3, 5 A AB 7:23 able 15:15 above 40:9 absorbed 26:23 absorption 18:5; 22:19, 20,21,24 accept 10:3 accepted 13:25; 14:5, 6 accidentally 26:5 according 46:10 across 35:5 actually 35:18 assume 12:17; boron 17:4, 5; 18:18; 12:3, 6, 11; 14:22; contracts 17:1 acute 17:17,19; 27:17; 29:10; 37:25 20:25; 25:17, 19; 26:3 assumption 38:1 22:7 both 7:14; 10:1; 15:11, 20, 21; 16:1; conversations 17:3,10, 23; 18:1,18, 41:10 addressed 7:10 administer 50:7 adverse 12:10,20; 26:10 atmosphere 33:6 attack 26:24; 27:1 attempt 25:5 attempting 17:7 15:4; 22:19 breathing 33:12 Broadway 50:14 brought 40:13 22,23; 19:10,13,14; 21:3; 46:8,23, 25; 47:6, 9,17, 24, 24; 48:9, 12 chemistry 7:20, 21 copy 35:5; 38:11 corner 38:8,10 correctly 51:1 couldn't 31:22; advise 33:5 attend 42:12 BS 7:22 chloracne 24:6; 37:19 aforementioned 51:2 aforesaid 6:4; 50:16, 16, 22 Again 16:2; 41:15 against 47:16,19 attended 50:13 attention 42:15; 44:10 attorney 51:12 attorneys 50:17; 51:14 c C 37:9, 20, 25 Calandra40:7 call 26:22; 46:7 28:7, 8,11,18, 20; 29:3,15; 30:4,12 chlorinated 26:22; 28:17, 18; 30:10 choose 15:2,3 Chronic 14:9,10, counsel 51:4, 5,10, 12 couple45:l6 course 8:20; 16:21 courses 8:1; 11:14, 23; 16:24 age 6:2 agencies 39:2 agree 9:17;32:8; 33:13 agreed-upon 11:9 agreement 51:10 agricultural 19:13 ahead 4l:24 air 33:7, 22, 25; 34:3 air-blowing 32:14 airborne 33:3 along 42:17 although 34:12 American 19:3,6, 10,16; 20:3; 45:20; 46:2 attributed 29:14 attributing 28:20 August 35:24 authorized 50:6 avoided 32:12 awarded 8:18 aware 11:10; 12:24; 19:19; 21:23; 22:2, 11; 24:12; 28:19; 29:8,13; 36:17; 38:25; 43:18, 25; 44:8, 11, 15; 45:5, 8, 10; 47:18 away 32:15 axis 28:16,17,17; 30:11 called 16:21; 17:4; 45:23 came 35:5; 37:24 can 9:7,16,21,22; 12:7; 27:11; 29:5; 30:19; 31:11; 34:13; 38:1, 13; 43:12; 46:4 carcinogen 31:1,6 carcinogenic 40:9 carefully 50:19 CARNEY 9:13; 10:19, 22; 11:1; 14:3, 21,25; 15:12; 16:2,6; 20:15; 23:13; 24:9; 29:9,17; 31:2,19; 32:2,16; 34:19,23; 35:2,20; 37:11,15, 12; 15:4; 17:17; 18:23; 20:11,19,21, 23; 21:4,6,23; 22:2; 23:9; 26:12; 45:5; 48:8,11 Circuit 50:10 City 50:3,10,15 civil 50:9 class 17:4; 25:21 classify 47:13 cohort 37:6 college 7:16; 8:13 combinations 29:1 comfortable 24:22 coming 41:1, 6 comment 30:1; Court 50:10, 12 cover 21:21; 44:13 covers 9:5 customary 46:21 customer 19:24 Cyanamid 19:3,6, 11,16; 20:3; 21:3, 25; 22:2; 45:20; 46:2 D damage 26:24; 27:4, 8, 9, 12, 18,21,24 data 44:11 date 25:9 day 26:1,16; 50:17; analysis 43:24; 17, 20; 38:5,14; 47:10 51:16 '' 44:12 analytical 44:11 analyze 30:8 animal 13:21,22; 22:4, 22; 23:12; 26:20 animals 17:25; 18:12; 23:18 anticipate 26:9 anybody 39:17,19; 40:11; 41:6 anyway 39:24 anywhere 31:9 apparatus 32:14 apparent 32:11; 34:24 apparently 36:8; B BA 7:23 back 6:16; 7:13; 10:9,14; 11:7; 12:12; 13:10; 20:6; 30:8; 36:10; 40:14; 41:15 background 39:7 bad 10:2; 27:24 Barnes 37:9,20, 23; 38:2, 6 Based 26:20 bases 44:14 basic 21:21 basically 21:20; 23:8; 40:18; 41:3 39:21,25; 41:9; 45:15,18; 47:1; 48:15 Carney's 15:8 cartridge 32:14 case 6:4,11,13,14, 16, 18; 50:22 cast 30:4 category 46:20 cause 24:5; 26:3; 28:4; 31:5; 50:9, 12 caused 40:6; 50:25 causing 29:2,4,7; 30:3 caution 29:24 cautioned 50:20 cease 28:4, 5 Commission 51:18 commissioned 50:6 common 13:16 Company 19:4; 42:18 complaints 19:24, 25 complete 51:6 completely 8:13,14 compounds 17:4; 25:21; 26:22; 30:14 conceive 27:23 concentration 33:3, 25 concentrations 33:7 concerning 25:6 deal 11:23 dealing 32:9; 36:22 decision 41:24 define 20:21 defined 11:8 definite 29:5 definition 9:17,20; 20:22; 22:8,11 definitively 29:14; 30:19; 32:23 degree 7:20 demonstrated 12:6 department 16:14; 36:4; 37:5, 7; 42:3 depends 23:16; 47:13 37:16; 38:4; 42:7 basis 20:14,16 Cecil 6:15 concerted 25:8,11 deponent 51:9 appear 34:13; 40:8 Bates 34:17; 38:6,8; certain 43:19 conclude 14:13 deposed 6:20; 7:4, 6 appears 43:13 Applied 16:22 appreciable 33:18 approximately 46:3 area 11:6 aroclor45:6 Aroclors 33:1; 43:20 around 19:15 article 13:11, 11,14 articles 28:25; 29:5 aspects 38:18 39:11,21 believe 6:17; 30:25 bell 31:18; 37:10 best 29:19; 42:11 ; 43:12 beyond 23:4,22; 27:16 Bill 36:1,4,7 biochemistry 11:21 biological 10:2; 13:5 biphenyls 28:16 certainly 21:2; 46:19; 47:14,15; 48:10 certainty 30:15 certify 50:7, 8; 51:11 cetera 32:11 change 40:7 changed 22:14; 24:2; 40:20 chemical 19:15; 22:5, 22; 29:6,15; 47:13, 20 conclusion 48:6 conclusions 13:15; 30:6,16 confusion 28:21 conscious 33:18 considered 9:3 consultant 37:1 contact 46:7,17; 47:25 contamination 43:21, 22; 44:17 deposes 6:5 deposition 6:19,21, 23; 23:23 depositions 40:14; 42:11; 50:8 dermal 24:7 describe 13:2; 25:17 described 24:8 , describing 12:S description 38:23; 39:4 associated 10:4,5; bit 23:6; 26:2, 4 , chemicals 9:3,11, context 40:17 desk 35:5 23:24; 28:9; 34:7 Bloomington 44:22 I 24; 10:1,3,17; 11:11; continuing 27:24 details 37:4 Gore & Perry 800 878-6750 Min-U-Script 052789 - details WATER PCB-SD0000048358 George Levinskas, Ph-D June 7, 199^ Judith Bechtold, et aL v. Monsanto Company, et aL determine 10.17; during 11:13; 12:22; EXAMINATION 6:7; 12:2,19,13:19; 19:20; 43:20 r* >-mined 12.12 v lop 12:17; 17:22 developed 16:21 14:7,15, 19; 18:17, 24; 19:11; 20:9; 25:4; 35:15; 4l:2;44:24; 46:1; 48:11 dyes 19:13 45:17; 47:3 examined 50:19 excess 9:25 exhaust 32:13 expect 27:21; 33:21 dibenzol 43:20, 21 different 8:10; 10:10 E experiment 13:13 experiments 12.18; differs 9:24 difficult 28:22; 30:l6 difficulty 27:20; 30:14 dioxin 43:21; 44:17 direct 42:14 directed 9:6; 17:16 direction 30:2 directions 46:11 director 19:7 discover 13:4 discussed 40:22 discussing 40:12 distinction 9:7; 10:6; 17:18; 21:15; 29:6; 30:9 E 37:9, 20, 25 each 10:12 earlier 13:3; 47:6 early 10:15,21; 13:10,17; 14:15; 28:10, 22; 30:13; 48:9 ease 34:2 Easely 38:16 easier 33:2 editorial 40:17 education 7:14 effect 13:5; 26:17, 19; 28:8 effects 9:1,3, 10, 11, 12; 10:1, 18; 12:2,6, 10, 20; 13:19; 17:10, 13:2,3; 17:21; 18:12 expert 24:16 expires 51:18 expose 17:25 exposed 13:6; 17:15; 18:2; 27:25; 34:5 exposing 22:4 exposure 13:8; 18:2; 23:25; 24:5; 25:16, 18, 20, 24; 26:21; 28:9, 11 exposures 25:23; 27:22; 28:4, 14 extended 34 5 extent 13:5; 33:23 extra 33:5 distinguish 9:21 Doctor 36:8,10; 40:21 document 31:13, 16; 32:5; 34:18; 35:3; 10,14; 40:2, 5; . ; 42:5, 8, 10, 15 documents 31:7, 10; 34:12 done 13:3; 15:9,19, 25; 16:9; 17:25; 20:13; 21:24; 22:3, 16, 25; 23:1,1; 34:25; 35:23; 36:2, 8, 15; 41:19, 20, 21; 43:19, 24; 44:2, 5, 9,15,18; 45:6,8,10, 20; 46:4, 25; 47:8, 8; 48:10, 11 dose 9:25 doubt 30:5 down 7:7 dozen 21:3; 46:3 Dr 6:9;7:12;23:21; 24:23; 31:8, 23; 32:7; 35:6,9; 36:4,20; 38:15,'39:10; 4 2:23; 43:2; 45:14; 47:5 draw 30:16; 48:6 drinking 26:6 drug 9:24; 16:10; 47:14 drugs 9:1, 4,12; 11:10; 12:3; 13:5, 20; 14.-22; 15:10 ; 28:18 duly 6:2; 50:5, 19 duration 14:13; 20:25; 21:10 durations 18:7 13,17,17,19; 24:7, 7; 25:16,18,19; 26:3, 10,12; 27:9, 19 effort 18:20; 25:8 efforts 12:14; 13:8; 17:16 either 11:10; 12:2; 18:4; 20:25; 46:16; 51:12 elephants 23:19 elevated 32:9,18; 33:2, 24 else 27:13,25; 28:1, 1; 31:20; 47:2 employed 24:25; 35:12; 38:19, 21, 24 employee 19:24; 38:17 employees 34:25; 35:19; 43:12 enough 27:11,17 entire 18:17 epidemiological 35:17; 36:14, 21; 41:18; 42:2; 43:11, 17 epidemiologist 36:5 epidemiology 34:24 Eppenberger 50:14 essentially 25:24; 30:7 et 32:10 European 32:2 even 13:10; 15:5; 26:2 event 28:25 every 26:16 everything 7:8 evidence 24:4; 29:19 F fact 48:10 fair 9:15; 25:12 familiar 46:16 feeding 13:18,20; 14:17,24; 15:9; 20:11; 22:4,13,16; 23:1 . few 46:24 field 8:17; 16:25; 21:18; 44:9 fields 9:22; 10:12; 16:18,19 fifties 10:16,19,21; 11:7; 13:10,17, 23; 14:15; 16:7, 8; 28:13; 46:15,22; 48:9 file 37:24 find 24:1 finding 12:10 findings 40:18 fine 11:4 finished 21:9 first 6:2; 16:18; 20:3, 20; 21:5; 25:16; 27:2; 31:12; 34:17; 50:19 firsthand 11:3 Five 18:15 five-year 18:17, 24 followed 24:21 follows 6:6 food 45:25; 46:7,8, 12, 13, 17; 47:11, 25 force 48:1 foregoing 50:23; 51:1 formal 19:19 forth 51:2 forties 37:15 found 28:15 full 51:6 fumes 33:11 furan 43:20; 44:16 further 48:15; 51:11 health 9:10; 16:15, 15,16; 17:2; 23:24; 26:10; 27:9 heard 21:14 heated 33:6, 23 held 42:7 help 42:20 hereby 50:8 higher 33:8 Institute 8:11 intent 9:23; 23:10; 31:10 intentions 23:15 interest 20:1; 25:7 interested 27:6; 44:7; 51:13 interrogatories 6:6 interrupt 40:21 G Gaffy 36:1, 5,7 gave 6:17; 16:22, 23 general 11:15; 15:16; 17:2; 19:14, 25; 22:1; 23:2,10; 24:1; 25:7, 14; 36:19 generally 8:24; 13:25; 14:4,6; 29:4; 43:25; 44:10, 46:14 generated 40:1; 41:5 generational 21:22 holding 46:8 hopefully 13:8 hot 32:10 huh 42:21 humans 10:18; 12:3; 31:2, 3 Husch 50:13 hydride 18:18 hydrides 17:4,5,6; 22:7 hydrocarbons 26:23 hygienist 37:21 hypothetical 26:14 into 10:13; 22:22; 26:14; 38:5;4l:15; 50:25 investigator 35:1 investigator's 13:7 investigators 12:15 involved 6:13,15; 10:24; 11:5; 35:4,7; 36:24; 37:3; 42:1 issue 40:12,23; 41:3; 44:6 issues 6:12,13,15; 41:16 genericaily 46:5 GEORGE 6:1 gets 34:3 gist 15:7; 36:19 given 9:24; 15:2; 51:8 glass 26:6 go-round 40:19 goes 12:9; 40:14 Gofin 32:1 1 IBT 40:7, 15; 45:4 idea 17:12; 40:1 identical 6:14 identifying 30:14 impression 15:17 improve 17:9 in-house 35:17,18; J job 38:23; 39:3 Joe 6:10 Johanson 35:6,9; 36:9, 20 joined 19:3; 21:9; 36:5 Judy 35:25; 36:2,3, 7,11 Good 6:9; 10:2 36:15; 41:19; 43:19 July 45:3 government 17:1 inaccurate 42:22 June 50:17 graduate 7:15; 10:15,24; 16:16 include 9:2 increase 33:3, 25 justified?) 40.10 graduated 7:16; 16:11 great 46:19 guess 20:20; 21:1; 22:23; 23:25; 24:3; 27:6,10, 20; 33:9; 44:7; 47:21; 48:2 H halo 28:16; 30:10 hand 51:15 handle 18:3 handled 33:20 handwriting 39:15 happened 11:5 happening 24:19 hard 21:1 harmless 33:12 haven't 25:13; 33:17; 34:5 indicate 34:2 indicated 18:9; 22:6; 26:7 indicating 28:11 indistinguishable 10:9 individual 12:15; 13:7 individuals 12:24; 17:14 industrial 10:17; 11:11; 14:22; 15:10, 20,21; 16:1; 37:21; 46:23,25; 47:5, 8,12, 17, 23 industry 10:4;32:5; 48:4 Inerteen 44:16 Inerteens 44:19 inhalation 18:5,10; 22:7,19, 20,25; 32:11 K K 38:15 keep 25:5 kept 25:7, 8 kind 32:20; 45:21; 46:5,15 knowledge 11:3; 40:4; 44:3, 4,18; 46:21 known 30:9, 13 Krummerick 37:6 L L 50:4 lab 19:7 labeled 14:8; 15:4; 34:15,16 laboratory 12:4; 20:10 hazard 34:4 initials 39:18, 20 lady 7:7; 35:25 hazards 17:2; 23:24 injection 18:4 language 40:7 HD000133 38:10 injury 27:3; 28:3 large 33:17; 34:6 HD000135 38:12 Insofar 12:7 Largely 12:14 determine - Largely Min-U-S cript Gore & Perry 800 878-6750 WATER PCB-SD0000048359 Judith Bechtold, et ah v. Monsanto Company, et aL George Levinskas, Ph-D June 7, 1994 last 22:12; 42:15 later 30:4; 36:2, 4 lawful 6:2 lawyer 39:5 lawyers 41:10 learn 17:7,22 least 43:4 lectures 16:23 left 20:7; 38:22 length 13:25 less 11:17; 20:24; 21:2; 25:11 lesson 12:5 letter 36:23; 37:23, 23; 38:2,12 letterhead 37:19 LEVINSKAS 6:1,9; 7:12; 23:21; 24:23; 31:8,23; 32:7; 38:15; 39:10; 40:6; 45:14; 47:5 life 23:12 likelihood 46:10 likely 33:22 limit 32:25 limited 17:20 line 24:13 lists 42:16 literature 15:16; 24:19,21; 25:6; 28:22; 30:18 little 14:14; 23:6; 26:2, 4; 29:10 liver 24:6;26:24; 27:3,3,7,9,12,18, 21, 24; 28:3 living 10:2; 23:6 long 18:13; 26:13 long-term 15:18,25; 16:9; 23:8,11; 45:19; 46:3,6,15,22; 47:7, 16 longer 23:6 look 34:14; 38:1 looked 33:17 looking 37:22 looks 31:19; 32:4 lot 28:21; 32:21 loud 7:9 Louis 50:3,11,15; 51:16 low 25:22; 34:3 lower 38:8 M major 7:21; 18:19,19 majority 46:20 makes 24:4;30:15, 24; 33:7; 40:5 making 28:23; 41:24; 47:21; 48:7 manager 35:10 manufacturing 20:1 morning 6:9 many 17:24; 26:21 mortality 36:22 March 51:18 marked 31:13 Master's 8:5 material 26:1;45:21; 47:12 Most 6:13,24;7:5; 15:18; 17:3; 18:9; 48:4 motivating 48:1 mouth 26:6 materials 15:19; much 6:24; 30:13; 16:10; 17:20; 46:5, 17 33:8; 34:4; 44:10 may 23:4; 24:10; MURRAY 6:8,10; 26:8; 28:18; 29:1; 31:16; 36:1, 6; 40:1, 9:16; 10:20; 14:23; 15:14; 31:21; 34:21; 2; 41:4; 44:5; 47:24 maybe 26:2 mean 20:16,17; 28:12; 30:12,18; 35:18; 40:21 37:13,16,18; 38:3, 13; 39:23:41:11; 4 5:13; 47:4; 48:14 must 32:12 meaning 9:9 N meant 14:4 medical 11:18,19; 36:4 medicine 10:5 meet 39:1; 42:12 meeting 42:6,13, 17, 21; 43:1, 3, 8 memo 35:8; 40:14; 43:9 name 6:9; 7:15; 30:11; 31:9; 34:12, 19; 37:10; 42:17 names 31:24, 25 nature 9:23 necessary 7:8; 32:23 need 19:21; 48:3, 5 mentioned 45:19; 46:1 needs 48:13 negligible 33:11 mentions 37:1 messiness 26:8 new 24:3 next 34:22 messy 26:18 NIOSH 42:7,13; met 42:24; 43:1 43:13 method 22:4 might 11:5; 12:20; 15:2, 3; 17:13,15; non-drug 15:19; 16:10; 47:11 non-toxic 25:22 24:5; 26:5; 27:19; 29:2,3, 21; 32:21, 23; 41:16 mildly 40:7 military 17:3,11 mind 28:23; 50:18 mine 39:16 miscommunicating 15:24 Missouri 50:1, 5,11, 15; 51:16,21 mistake 43:6 Mister 36:9 mixtures 28:15 MONS030773 34:15 MONS040440 31:14 Monsanto 6:16; None 8:3; 29:4 nor 51:13 normally 26:3 North 50:14 notarial 51:15 Notary 50:4; 51:20 nothing 6:4; 50:21 notice 27:22; 50:9 notorious 30:12 nowadays 22:16; 23:3 NPC00002135 38:7 number 29:22; 34:17; 38:9; 39:11, 24; 42:6 numbers 39:22 24:25; 31:25; 34:25; 35:13,16,16,19; 36:15; 38:17,20; o 40:11; 41:2,19; 42:3, 18; 43:11,19; 44:6, 24; 45:1, 6, 9,11 month 14:13; 15:3 months 18:11, ll oaths 50:7 object 9:13; 10:22, 14:3; 16:2; 20:15; 23:13; 24:9; 29:9,17; 32:16 more 10:4, 5,10; 11:17; 16:9; 20:2; 33:22; 44:7 objection 15:8; 24:14,15 objections 51:5 i obstruction 47:23 parentheses 40:10 pre-clinical 11:17, Obviously 41:11,11 part 41:23 22 occupational 16:14 occur 12:2; 13:18; 20:18; 27:19 occurred 36:20 occurring 29:2 odor 33:16,19,22; 34:7 off 33:11,16 office 38:18, 24 offices 50:13 often 20:18 oily 26:8 older 21:18 once 47:10 one 10:3; 12:9; 15:2, 2,3; 18:10; 19:23,25; 21:8; 27:3,21; 29:6, 7,15; 30:19; 34:11; 35:24; 36:3,7 One-month 14:9,12 ones 15:13; 19:21; 26:8 only 15:9; 16:4; 22:19, 20; 23:17; 26:25; 41:14; 42:24; 48:6 onto 38:4 operators 32:15 opinion 23:23; 24:1; 25:15, 19; 26:25 oppose 24:13 opposed 15:10; 26:6; 29:7,15; 47:24 oral 6:5 order 13:15; 25:12 organ 27:1 organic 19:14; 32:13 organisms 10:3 original 38:3,7 others 12:8; 42:18; 45:8,10 out 7:9; 10:9; 24:1,4; 31:19; 37:24 outside 44:5 ovens 32:10 over 22:14; 23:12; 26:13; 30:23; 31:8 overlap 10:11 own 12:15; 19:6 P particular 34:7; 41:1 precautions 33:5 particularly 30:11 predate 13:23 \ parties 51:12,14 pay 44:10 PCB 23:25; 28:9; 32:2; 36:11 PCB's 24:5; 25:6, 16,18, 20; 26:13; 28:12, 20; 30:25; 32:9; 33:11,15; 35:20, 21; 36:13,15 pending 50:9 people 17:24; 18:2; 20:1; 33:5; 42:16 Predominantly 17:19 preliminary 36:21 present 10:7;42:l6, 17 ' pressure 34:2 previous 15:8; 19:5; 23:23; 24:8; 28:7; 40:23 previously 24:24 primarily 9:6 primary 34:25 people's 23:14 perceive 48:3 perception 48:4 performing 35:19 period 7:1; 11:14; 14:20; 18:17, 24; 19:11; 20:9; 21:24; 23:2, 21; 24:2; 25:4, 10; 26:13; 35:16; 44:8; 48:12 periods 34:6 person 13:13; 15:2, 3; 37:12; 41:1 personally 43:2 personnel 17:11 pesticides 46:9,17 Ph.D 6:1; 8:6, 15,17 pharmaceutical 15:10 pharmacist 8:21 Pharmacology 8:19, 23; 9:9,12; 11:13,21 phrase 21:22. physiology 11:20 Pittsburgh 16:14; 18:14; 19:2 place 43:15; 44:1 probably 10:8; 16:9; 21:2; 28:15; 43:5; 44:2; 48:1 procedure 12:19; 14:6 procedures 10:8; 11:9; 12:9, 24; 13:6 process 22:21; 41:23 produce 9:25; 17:11,13:27:11,17 producer 19:15 producers 30:12 producing 19:11 product 20:2; 45:7 products 19:18,/ ) 44:16 profess 15:15 proffered 24:16 prohibition 47:15, 19 prolonged 26:21 proper 32:13 propounded 6:6; 51:4,7 protect 17:14 prudent 33:4 public 16:15,16; 50:4; 51:20 places 33:18 published 13:12, plaintiffs 6:10 22; 28:10; 30:2; 36:16 plans 12:5 purpose 23:16 plant 44:22 purposes 9:8,9,17 point 44:1;47:21; pursuant 50:8 48:7 points 11:8 policy 19:16,19 Q polymer 45:23 qualified 24:18; 50:6 packaging 45:25; 46:8; 47:12 polymers 19:14 quantities 33:19 position 27:10; 30:8 questioning 24:13 page 34:17,21,22; 42:15 pages 51:1 possible 6:24; 12:1; 28:8; 43:10 possibly 14:16 R papers 30:2 potential 12:1; ran 18:8; 21:4 paraffins 28:18; 30:10 paragraph 33:10 26:12,17,18; 27:18; 30:25; 31:5 practice 13:16 range 19:13 rather 19:12; 25:22; 29:20 Gore & Perry 800 878-6750 Min-U-Script last - rather WATER PCB-SD0000048360 George Levinskas, Ph-D June 7,1994 Judith Bechtold, et aL v. Monsanto Company, et aL Rats 14:9,11; 23:5 reach 13:15 read 30:23; 33:9; r 39:21,23 r^.ng 32:22; 35:7 reads 40:6 really 10:6; 14:6; 25:13; 26:17; 28:19, 22; 31:15,16,17; 32:23; 33:17; 34:8; 39:13;40:4;43:l6; 44:11; 47:22 reason 15:5; 37:22; 41:14 reasons 15:2; 19:22 recall 12:7,7; 31:15; 32:5, 22; 34:7; 35:3; 36:12,18, 24,25; 37:4; 38:22; 39:13; 40:3; 41:6; 42:24, 25; 43:7 receive 8:5,15 recent 44:9 Recess 39:8 recital 13:7 recognize 31:11; 34:14; 39:15; 42:9 recollection 16:5; 29:21; 42:11 record 29:18;34:15; 38:6 ... '-H 13:2; 41:12 jrence 11:8; 40:6, 24 referring 9:10 regard 15:9; 19:17; 20:24; 23:24; 25:15; 30:22; 41:18; 44:6, 16 regarding 42:6 regular 20:14,16 regulatory 19:23; 39:2 relate 7:1 related 40:25; 51:13 relates 8:23 relating 27:7 relatively 25:22 remarks 51:4 remember 6:17; 14:19; 15:1; 21:10; 40:11; 41:1; 42:20; 44:21 remembered 43:3 repeat 6:22 repeated 26:21 reply 6:5 reported 50:24 reporting 35:6, li '"oorts 13:22; 14:8, 28:11, 19; 40:15 represent 6:10; 34:4 reputation 42:23 request 45:11 requirements 19:23 reread 36:23 shorthand 50:24 research 16:17,25; 17:8; 18:16, 20 researchers 13:3 shot 31:23; 39:9 show 31:12; 39:10; 42:8 residue 46:10,12,18 shown 50:23 resin 45:24 sign 28:3 respects 51:6 signature 51:9 respirators 32:14 significant 26:10 response 48:13 signs 9:25; 27:3 results 13:12 similar 6:14 retire 25:2 single 25:23 retired 24:17; 25:1 six 18:10 retyped 38:4 six-month 22:6 review 42:9 sixties 28:13 reviewed 24:11; 25:13; 40:16 , skin 18:5; 22:23,25; 1 26:1, 16 right 7:13; 8:7; 12:22; 13:15; 23:20; 25:2; 35:23; 40:22; 41:8 right-hand 38:8, 10 ring 31:17; 37:10 Rochester 8:9,10; 11:20; 12:23 room 33:10,15; 34:1 routes 18:1; 25:24 slightly 23:4 small 33:19 so-called 30:10; 32:25 solely 28:20 somebody 25:25; 26:17; 37:23; 41:4; 48:2, 8 someone 27:21, 23 something 20:13, run 10:16; 13:13; 14; 24:6; 26:5; 27:25; 14:1,17; 20:6,11,19; 28:1,1; 30:19; 31.20; 35:16 39:2 s sorry 24:23 sort 11:22; 12:18 sound 50:18 same 8:20; 21:20, 21; 30:1; 40:18 samples 30:7 sounds 32:4 span 23:12 speak 15:16; 29:18 saying 9:15; 11:2; 13:20; 47:11 school 7:15,17; 8:8; 11:19; 16:15, 16, 24 science 8:25; 24:17 specific 30:23;39:3; 48:13 specifically 17:3; 18:22; 41:2, 7; 44:7, 14 sciences 11:18, 22 spectrum 10:11 scientific 12:19; 13:11; 24:4; 25:6 scientist 13:18 Scott 6:15; 24:11 seal 51:15 second 40:19 section 42:3 seeing 39:13; 40:3 SEM 39:23; 42:5 SEM76859 39:11 sentinel 28:2 Separate 8:13,14 September 25:3 series 16:22, 23 sessions 12:4 set 10:3; 33:1; 51:1 speculate 11:2,4; 15:6; 16:3; 24:20; 29:24 speculating 23-14 spent 18:11 SS 50:2 St 50:3,11, 15; 51:16 stamp 38:6,9; 39:11, 22 standard 10:16; 11:25 standardization 14:14 standards 11:8 started 10:9; 45:3 State 50:1, 5,11,15; 51:21 sets 40:15 stated 30:19 several 16:23; 18:11 statement 32:8; 40:9 short 18:9 statements 30:3 shorten 6:24 still 23:3; 24:25; shorter-lived 23:18 35:12; 38:19; 43:1 stop 27:22 temperature 33:11; straight 8:5 34:1 strains 23:5 strength 45:24 strictly 32:12 strike 44:25 students 11:18 temperatures 32:10,18; 33:2,15, 24 tendency 10:10 term 14:11; 18:10; 20:21; 21:13,14,20, studies 8:2; 11:16; 21; 47:6 12:22; 13:19, 21,21, 23, 24; 14:9,16,17, 24; 15:9,18, 25; 16:9; 18:23; 20:11,19; 21:6, 23; 22:3,11,13, 15, 16, 18, 25; 26:20; 29:11, 12,18; 35:17; 36:12; 40:19; 41:19; terminology 15:6; 40:20 terms 10:14; 22:1; 25:14,23 test 18:12; 19:21; 21:11; 45:19 tested 45:22; 46:6 43:17,18; 44:3, 5; testified 14:5; 50:22 45:4, 5; 46:22; 47:7, 16,19; 48:5 study 8:25; 9:2; 11:12; 14:11; 18:10; 20:24; 21:4; 22:7; 23:9,11,17; 34:25; 35'19; 360, 11,14, 14, 22; 43:10,11,14 studying 10:1 subacute 21:14,19 testify 6:3, 20; 50:20 testimony 6:18; 19:6; 24:8,11; 25:13; 28:7;40:23; 50:24; 51:2 testing 11:9; 12:1,9; 13:6; 19:18, 21; 48:8, !11 tests 10:11,16; 11:24, 25; 12:5,18; subchronic 21:1, 14:13; 17:21; 18:8; 13, 17; 22:9,10 46:3, 4, 6, 15 subject 9:6; 41:7 textbooks 13:1 subjects 11:21 themselves 29:19 subsequent 24:2 therefore 33:12 Subsequently 28:12 thereto 51:5 substantiated 15:17 thereupon 50:22 suggestion 41:21 thinking 13:9 suit 51:13 Suite 50:14 third 19:25 thirties 28:14 supplied 40:16 supply 17:20 sure 15:23; 23:25; 24:18; 29:23; 32:1; 37:25; 38:21; 43:23; though 22:8,11; 48:7 thought 31:21 thoughts 12:16 three 31:24; 40:18 44:13 threshold 32:25 swallowed 26:2 throughout 30:24 sworn 6:2; 50:20 symptoms 27:7 thrust 11:15; 18:16; 24:3 tissues 10:2 T ta!k7:13;13:14; 21:25; 23:20; 25:14; 26:4,11; 29:1; 32:19; 33:10; 41:7 talked 28:6; 47:7 talking 10:14,20; 13:12,21; 14:21,23; 15:12; 16:6; 22:23; 26:16; 27:6; 29:11; 35:18 talks 26:15:32:18; 37:5; 43:10 teaching 16:17,19, 20 Technology 8:11 to-wit 6:6 today 6:11, 25; 9:8, 18; 10:13; 24:17; 25:15 together 51:3 took8:2; 11:17,18; 43:14; 44:1 topic 17:2 towards 17.16 toxic 9:25; 10:17; 12:2; 13:19; 25:15 Toxicity 14:9,11; 25:23; 45:5 toxicological 9:11; 19:7; 20:10 toxicology 8:1; 9:8, 10; 16:22; 35:11 trade 30:11; 31:24, 25 transcribed 50:25 transcript 50:23; 51:7 treat 17:14 trial 50:12 Tricker 29:11 tried 6:16; 47:10 triggers 27:25; 28:1, 2 true 23:17,18; 29:4; 46:14; 51:6 truth 6:3, 3, 4; 50:20, 21, 21 try 6:22, 23; 13:19; 17:22; 23:11 trying 41:4,12 tube 18:12 tumoragenic 40:8 twenties 28:14 twice 47:11 two 9:22; 10:12; 15:3; 21:12,16; 22:12; 23:3, 4; 33:4; 40:15 Two-year 14:10,16; 15:13 type 11:14; 17:21; 19:10; 22:15; 32:5 typed 38:11 types 48:12 typewriting 50:25 u uncover 13:4 Under 22:8 undergraduate 7:14, 17; 8:2 undetermined 50:10 University 7:18; 8:9; 11:19,20; 12:23; 16:13; 18:13; 19:1 unless 24:21; 27.T1 unusual 20:14,17 up 6:24; 20:6; 25:5, 8; 28:23; 40:13 upper 38:9 use 12:25; 13:18; 15:6,21; 21:17,18; 22:3,18; 23:9; 47:14 used 10:11; 11:24; 13:1; 14:12; 21:13, 14; 23:2, 7; 30:7,15; 45:24; 46:8,10; 47:6; 50:11 uses 16:10,10; 47:11 using 17:12; 23:6; 32:13; 43:11 usually 13:14 Rats - usually Min-U-S cript Gore & Perry 800 878-6750 WATER PCB-SD0000048361 Judith Bechtold, et aL v. Monsanto Company, et aL Y vague 32:17 valid 9:19 validity 30:5 values 33:1 vapor 34:2 vapors 32:11,12 variables 32:21 variety 19:22 various 6:12; 18:1; 19:13; 23:22 ventilation 32:13,20 versus 6:15; 29:3 via 32:10 Victoria 50:4 visit 44:21 visits 39:1 voice 24:14 volumes 34:6 year 7:24; 8:15; 20:7 year's 20:25 years 15:3; 18:15; 21:12; 22:12,14; 23:3, 4; 28:13; 29:22; 30:24; 31:6 young 35:25 Z Zack 36:2,3,7,11 w Wagener 42:23; 43:2 waived 51:9 wants 43:13 warning 28:3 Warren 38:15 Washington 38:18, 24; 39:1 way 7:13; 9:15; 13:8; 30:20 week41:l6 welding 32:10 Wesleyan 7:18 Westinghouse 37:11,21, 24; 44:22 wet 45:24 ... . what's 14:4 whenever 7:9 whole 6:3; 18:12; 33:9; 50:21 whose 41:20 Wide 19:12 Wilson 50:4 without 18:12 witness 10:23; 24:10,15;50:16,18; 51:3,8,15 witness's 29:20 words 27:23 work 10:15; 21:5; 30:4; 33:17; 36:21; 44:9, 15, 18; 45:1 working 18:11; 23:19; 25:25; 26:13; 33:6 writing 13:13 wrote 34:13; 40:14 WSJ 39:18_____________ ____________ _ Gore & Perry 800 878-6750 Min-U-S cript George Levinskas, Ph.D June 7, 1994 vague - Zack WATER PCB-SD0000048362