Document J357NMxdpBgdJ24Ya0Y501jx2

lit 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 Min-U-Script STLCOPCB4027356 Judith Bechtold, et al v. Monsanto Company, et aL IN THE CIRCUIT COURT - CITY OF ST. LOUIS STATE OF MISSOURI JUDITH BECHTOLD, wife of/and STEPHEN E. BECHTOLD, ELIZABETH TAMEWITZ, as Personal Representative of her deceased husband, Kenneth F. Tamewrtz, 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 WESTINGHOUSE ELECTRIC CORPORATION, Defendants. Deposition of GEORGE LEVINSKAS, Ph.D. Taken on June 7, 1994 Page 1 . IN THE CIRCUIT COURT - CITY OF ST. LOUIS STATE OF MISSOURI JUDITH BECHTOLD, wife of/and STEPHEN E. BECHTOLD, ELIZABETH TAMEWITZ, as Persona! Representative of her deceased husband, Kenneth F, Taitfevrilz, 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 WESTINGHOUSE ELECTRIC CORPORATION, Defendants. Page 2 Deposition of GEORGE LEVINSKAS, Ph.D., taken on behaH of the Plaintiffs, at the law offices of Husch & Eppenberger, 100 North Broadway, Suite 1300, in the City of St. Louis, State of Missouri, on the 7th day of June, 1994, 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, Suite 1300 St. Louis, Missouri S3102 FOR THE DEFENDANT WESTINGHOUSE ELECTRIC: MS. JEANA D. McFERRON Lewis, Rice & Fingersh 8182 Maryland Avenue, Suite 400 St. Lows, Missouri 63105 INDEX PAGE Examination by Mr. Murray Examination by Mr. Camey Examination by Mr. Murray EXHIBITS (None marked) 6 45 46 Page 5 Page 6 ill GEORGE LEVINSKAS, Ph.D. [2] of law ful age, having been first duly sworn to [31 testify the truth, the whole truth, and 14) nothing but the truth in the case aforesaid, |5i deposes and says in reply to oral [6] interrogatories propounded as follows, to-wit: Gore & Perry 800 878-6750 George Levinskas, PhJD June 7,1994 PI EXAMINATION [si QUESTIONS BY MR. MURRAY: [91 Q: Good morning, Dr. Levinskas. My name tioj is Joe Murray. I represent the plaintiffs in [in this case and I'm here today to ask you [12] various questions about some of the issues [131 involved in the case. Most of the issues in [Hi this case are similar, ifnot identical, to psithe issues involved in the Cecil Scon versus [16] Monsanto case which was tried back in 1987 or [i7] '88, as I remember it, and I believe you gave [isi testimony in that case, as well as a [i9i deposition; is that correct? [201 A: I was deposed. 1 did not testify. [2i] Q: Okay. I have got your deposition [221 here and I'm going to try not to repeat what [231 was asked in that depo sition to try and [24] shorten this up as much as possible. So most [251 of the questions I will be asking you today Page 7 ID will relate to the time period after 1987, [2i okay? 131 A: 1987? Hi Q: '87 when you were deposed, yes, sir. [si I say most, not all. [6] Now, as you know from being de posed pi before, this lady is going to be taking down tsi everything that's said so it is necessary for [9] you to answer out loud whenever a question is 1101 ad dressed to you, okay? HU A: Yes. ini Q: Okay. Now, Dr. Levinskas, I want to [13] go way back with you right now and talk about [14] your education, both undergraduate and [i5] graduate school, okay? Give me the name of [16] the col lege that you graduated from in [i7j un dergraduate school. [18] A: Wesleyan University. [191 Q: And as I understand it, that was a [20] degree in chemistry? [21] A: It was a major in chemistry, yes. [22] Q: BS? [231 A: BA,AB. [24] Q: What year was that? [251 A: 1949. Page 8 HI Q: Were there any toxicology courses 12] that you took in your under graduate studies? [31 A: None. [4] Q: And as I understand it, you did not 15] receive a Master's but went straight to a [6j Ph.D., correct? PI A: Right. [8i Q: And what school was that from? 19] A: University' of Rochester. [io] Q: Is that different than Rochester Hi] Institute of Technology? [12] A: Yes, sir, it is. [131 Q: Separate college completely? [14] A: Completely separate. [151 Q: What year did you receive your Ph.D.? 116] A: 1953- ' [i7i Q: And in what field was that Ph.D. [is] awarded? [191 A: Pharmacology. [20] Q: Would that be the same course that I [2i] would take if I wanted to be a pharmacist? [22] A: No. [231 Q: Pharmacology relates to what? Tell [24] me generally what that is. [25] A: It is the study of the science of Page 9 ID drugs, their effects. 121 Q: Does it include the study of the (31 effects of chemicals that are not consid ered [4i as drugs? [5] A: It covers some but it is not [6] pri marily directed to that subject. PI Q: Tell me -- can I make a distinction [8] for our purposes today between tox icology and [9] pharmacology, meaning the -- for our purposes uoj "toxicology" referring to health effects or [111 toxico logical effects of chemicals and [12] "pharmacology" would be the effects of drugs? [131 MR. CARNEY: Let me object. Are you [14] asking him if it is okay if you do that or are [15] you saying is that a fair way to do it? [i6] MR. MURRAY: I'm asking him if we can [i7j agree on that definition forthese purposes [i8] today. [19] A: I don't think it would be a valid [20] definition. [21] Q: Tell me how we can distinguish [22] between those two fields, if you can. [23] A: I think the nature -- the intent of [24] the chemicals differs. Any drug given in [25] excess dose will produce toxic signs so you Page 10 m 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 [4] 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 -- PI A: I would say at the present time that [8] the procedures are probably [9] indis tinguishable. Back when I started out, [io] there was a tendency to be more -- different un spectrum of tests being used with some overlap 112] in each of these two fields. Min-U-S cript Page 1 - Page 10 STLCOPCB4027357 George Levinskas, PtuD June 7,1994 Judith Bechtold, et aL v. Monsanto Company, et aL 113) Q: That's what I want to get into today in) and I'm talking now in terms of back when you U5) were doing your graduate work in the early [16] fifties. What were the standard tests run on [i7j industrial chemicals to determine the toxic [is] effects on humans, if there were any? [19] MR. CARNEY: In the fifties? [20] MR. MURRAY: Yes, I'm talking about j2i) 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 HI MR. CARNEY: '53. You know, all I'm [2] saying is don't speculate. If you know how to [3] 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 [8] standards or reference points or defined, [9] agreed-upon procedures for doing the testing, [io] either in drugs, that I am aware of, or in [ii] industrial chem icals. H2] Q: Okay. Tell me, then, what the study [13] of pharmacology was all about during that time [i4] period. What type of courses is did you [15] take? What was the general thrust of your [i6] studies? [17] A: Itookmoreorlessthepre-clinical [is] sciences that the medical students took at the 119] university -- the medical school at the [20] University of Rochester -- physiology, [21] biochemistry,pharma cology -- subjects of that [22] sort, the pre-clinical sciences. [23] 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 [l] potential, the possible testing that could [2] occur to determine the toxic effects of either [3] drugs or chemicals on humans? [4] 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 [io] about finding the ad verse effects of [ii] chemicals. [12] Q: Well, how were they determined back [13] then? [14] A: Largely through the efforts of [15] individual investigators and their own Ii6] thoughts. U7] Q: And they would, I assume, de velop 118] tests or experiments or some sort of [19] scientific procedure to deter mine what the 120] adverse effects might be? [21] A: Yes. [22] Q: All right. And during your studies [23] at the University of Rochester, were you made [24] aware of the procedures that these individuals [25] would use? Page 13 [1] 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 [5] biological effect of drugs. To that extent, [6] we were exposed to testing procedures which [7] was a recital of an individual investigator's [8] efforts and hopefully some exposure to his way [9] of thinking. [10] Q: So back even in the early fifties [11] when an article, scientific article, was [i2] published talking about the re sults of an [13] experiment that was run, the person writing [14] that article would usually talk about what he [15] did in order to reach his conclusions, right? [16] A: That would be common practice, yes. [17] Q: In the early fifties, did it ever [is] occur that a scientist would use feeding [19] studies to try and determine the toxic effects 120] of drugs? And when I am saying, "feeding [21] studies, " I'm talk ing about animal studies. [22] A: There are published reports of animal [23] studies that predate the fifties, yes. [24] Q: And did those studies have a [25] generally accepted length of time that they Page 14 [1] would run? [2] A: I have -- 13] MR. CARNEY: I'm going to object to [4] 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 [7] during that time. [8] A: I have seen reports labeled, "The 19] Chronic One-month Toxicity Studies in Rats," [io] and I have seen reports, "Chronic Two-year [iij 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 standardization. [15] Q: There were, during the early fif ties [16] and possibly before then, twoyear studies [17] that were run, feeding studies? [18] A: Yes. [19] Q: Do you remember during that time [20] period -- [21] MR. CARNEY: Are you talking about [22] for industrial chemicals or drugs or anything? [23] MR. MURRAY: No, I'm just talking [24] about feeding studies. [25] MR. CARNEY: Okay. Page 15 HI 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 [9] feeding studies only done with regard to [io] pharmaceutical drugs as opposed to industrial [11] chemicals? [12] MR. CARNEY: Are you talking about H3] the two-year ones? [14] MR. MURRAY: Yes. [15] A: I wouldn't profess to be able to [16] 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 [19] 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 under standing [25] that the long-term studies were being done on Page 16 [1] the industrial chemicals? [2] MR. CARNEY: Let me object. Again, 13]don't speculate. If you know -- [4] Q: I'm only asking for your [5j recol lection. [6] MR. CARNEY: But if he is talking [7] about in the fifties, now -- [8] A: I would say in the fifties that there [9] were probably more long-term stud ies done on [io] non-drug uses of materi als than on drug uses. [ii] Q: Now, when you graduated in 1953, what [12] did you do? [13] A: I went to the University of 114] Pittsburgh to the department of occupa tional [15] health in the school of public health, [16] graduate school of public health, to do [17] teaching and research, [is] Q: What fields were you -- first of all, [i9] let's go with teaching.What fields were you [20] 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 STLCOPCB4027358 Judith Bechtold, 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 m A: We had contracts with the govern ment [2] and the general topic was health hazards of 13] military chemicals and, most specifically, a hj class of com pounds called boron hydrides. 15] Q: Boron hydrides? |6] A: Hydrides. [7] Q: And what were you attempting to learn [8] from your research? [9] A: We wanted to improve our [ioj un derstanding of what effects these chem icals [ii] would produce in military per sonnel who were [12] using them and also to get some idea of how [13] they produce these effects and what we might [14] do to protea or to treat indi viduals who [15] might be exposed. [16] Q: Were your efforts directed to wards [17] acute effeas or chronic ef fects or was any usj distinction made.? 119] 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 123] chemicals? [24] A: We did what many other people have [25] done; we would take animals, expose them to Page 18 HI the chemicals by the various routes of [2] exposure that people would be exposed if they [3] handle them. 14] Q: And that would either be injec tion, [5] inhalation or skin absorption? [6] A: Correa. [7] Q: And what were the durations of the [8] tests that you ran? 19] A: As I indicated, most were short [ioj term. We did one inhalation study for six iii] months and I spent several months working with ti2] test tube experiments without whole animals. [13] 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 [24] during that fiveyear period? [25] A: No. Page 19 U) Q: Where did you go after the Univer sity^] 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 [7] toxicological lab and you were the direaor of [8] it; is that correct? 191 A: That's correa. [ioj Q: What type of chemicals was American [ii] Cyanamid producing dur ing that time period? [12] A: At that time they had a rather wide [i3] range -- agricultural chemi cals, various dyes, [14] polymers, organic chemicals -- general all- [15] around chemical producer. [16] Q: Did American Cyanamid have a policy in] when you went with them with regard to the [i8] testing of its prod ucts? 119) A; I am not aware of any formal pol icy. [20] Q: How did you determine what products m; to test and which ones didn't need testing? [22] A: There would be a variety of rea sons. [23] 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 HI interest of the people who were manufaauring [2] the produa wanted to know more about it. 13] Q: You first went with American Cyanamid [4] in 1958? 15] A: That's correa. [6] Q: Did you run -- let me back up. You [7] left them in what year? !8] A: 1971. [9] Q: During the time period between 1958 [ ioj and 1971, did that toxicological laboratory [ii] run any chronic feeding studies? [12] A: Yes. [13] Q: Was that something that was done on a [i4] regular basis or was it something unusual? [15] MR. CARNEY: I'm going to objea to [16] what you mean by "regular basis" or what you [17] mean by "unusual." [is] Q: How often did it occur that you would 119] run chronic studies? [20] A: First, I guess we would have to 1211 define the term "chronic." [22] Q: Okay.What was your definition of [23] "chronic"? [24] A: I would regard any study of less than [25] a year's duration as either being acute or Page 21 [1] 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? [8] A: There was one that was just being [9] finished when 1 joined them. [10] Q: Do you remember the duration of that [ii] test? [12] A: Two years. U3] Q: You used the term "subchronic." I [i4] have also heard the term "subacute" used. [15] What would be the distinction between those [16] two? [i7] A: Those of us who use "subchro nic" are [is] older in the field than those who use U9] "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 [1] about just in general terms, not just at [2] 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. I8j Q: Under your definition, though, that [9] would be subchronic? [io] A: That would be subchronic.That's my [ 11 ] definition, though. I am not aware of studies 112) that would last two years other than the [13] feeding studies at that time. [14] Q: Has that changed over the years? Are [15] there any of those type of studies other than 116) feeding studies done now adays? [17] A: Yes. [is] Q: Okay. And would those studies use [19] both inhalation and absorption or only [20j absorption or only inhala tion? [21] A: Well, absorption is the process of [22] the chemical getting into the animal. [23! Q: I guess I'm talking about skin [24] absorption. [25] A: Skin studies are done; inhalation are Page 23 HI done; feeding are done. [2] 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 [7] used to. Gore & Perry 800 878-6750 Min-U-Script Page 17 - Page 23 STLCOPCB4027359 George Levinskas, Ph.D June 7,1994 Judith Bechtold, et al v. Monsanto Company, et al 18] Q: Basically, when you do a long-term 191 chronic study,you want to use the -- well, [ioi let me ask you that. Is the gen eral intent mi when doing a long-term study to try and do it [12J over the life span of the animal? H3! MR. CARNEY: Object to him [i4] speculating asto what other people's [i5] intentions are. [16] A: It depends on the purpose of the U7] study and it would be true only for the [is] shorter-lived animals; it would not be true if [19] we were working with elephants. [20] Q: All right. Let's talk about the time [21] period now, Dr. Levinskas, of 1987 and [22] beyond.You were asked various questions in [23i 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 [1] orfind out if that general opinion has 12] changed in the period subsequent to 1987.1 [3] guess the thrust of my question is has any new [4] scientific evidence come out that makes you 15] think that exposure to PCB's might cause [6] some thing other than the chloracne liver [7] effects and the dermal effects that you 18) described in your previous testi mony? 19] MR. CARNEY: Well, let me object. I no] don't think the witness -- he may have mi reviewed his testimony in Scott but I'm not 112] 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 ini on in science today. He is re tired, as I [18] 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 [21] 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? Page 25 HI A: No, I'm retired. [2] Q: All right. When did you retire? 13] A: September '91. [4] Q: During the period between '87 and [5] '91, did you attempt to keep up with the [6] scientific literature concern ing PCB's? [7j 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? [11] A: Less concerted. [12] Q: In order to be fair to you, since you [13] really -- you haven't reviewed your testimony, [14] let me talk just in general terms now about [is; your opin ion today with regard to the toxic [16] effects of exposure to PCB's and let's first [17] take what I would describe as the acute us] effects of exposure to PCB's. In your [19] opinion, are there any acute effects of [20] exposure to PCB's? [2i]A: I would say as a class of com pounds, [22] they are relatively non-toxic, rather low in [23] toxicity in terms of single exposures by 124] essentially all routes of exposure. [25] Q: So ifsomebody was working with the Page 26 [i] material for a day and got some on their skin [2] and maybe even swallowed a little bit, that (31 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. [7] A: As I indicated, other than the [8] messiness of the ones that may be oily, I [9] don't anticipate that there would be any [10] significant adverse health ef fects. Hi] Q: Now, I would like to talk to you, [i2] 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 [15] question that talks about, you know, if he got [16] this on his skin every day, I'm talking about in] the potential effect if some body was really [is] messy with it, what could be the potential [19] 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. [25] Q: In your opinion, is that the only Page 27 [1] organ they would attack? [2] A: I think that's the first thing that [3] one would see signs of, liver injury, liver 14] 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. [10] A: I guess my position would be I think [ii] that unless you can get enough to produce [12] liver damage, I don't think you are going to [13] see anything else. [14] Q: Okay. I understand that but -- [15] A: Yes. [16] Q: But let's go beyond that. Let's [i7] assume that you have got enough to produce [is] liver damage. Are there any other potential H9) effects that might occur? 120] A: I guess my difficulty here is that if [21] one got liver damage, I would expect someone [22] to notice this and the ex posures would stop. [23] In other words, I can't conceive of someone [24] having bad liver damage and continuing to be [25] exposed until something else trig gers and Page 28 in something else triggers and some thing else [2] triggers and so I think that the sentinel 13] warning sign would be the liver injury and [4] then that would cease or cause the exposures [5] to cease. [6j Q: Let me ask you this: You talked u\ 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 s 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, U5] they found that there probably were mix tures [16] of biphenyls with what they the halo axis [i7j axis, the chlorinated axis, and that the [is] chloracne may be due to chlorinated paraffins, [19] so I really -- I'm not aware of any repons [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 HI 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 m that is causing it as opposed to that one? [8] Are you aware of any that have? [9] MR. CARNEY: I'm going to object. I [10] think it is a little -- I assume you are [i i] 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 [14] them that have definitively attributed the [i5] chloracne to one chemical as opposed to [16] 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 STLCOPCB4027360 Judith Bechtold, et aL v. Monsanto Company, et aL George Levinskas, Pli.D June 7,1994 would be the best evidence [2oj of what they say rather than this witness's (2ij recollection of what they say and he might not (22] have seen those for a number of years. 123] But if you know for sure -- but I [24j just caution you not to speculate on what they [25] said. Page 30 U ] A: My comment is, 1 think in this same 12] direction, that these published papers make 13] 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 18] 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 uu axis, as a trade name, particularly, are f 123 notori ous chloracne producers.I mean that [13] much is known. But some of those early [14] compounds, there is difficulty iden tifying ns) with certainty what was used and it makes it [ 16] difficult to draw con clusions. 117] Q: Okay. And that's my understand ing of us] the literature, as well. I mean it is not |i9] something that can be defin itively stated one [203 way or another, is it? 121] A: No. [22] Q: Now, with regard -- well, let's be [233 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 HI carcinogen? [2] MR. CARNEY: In humans? 133 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 19] don't have your name anywhere on them and my [ioj intent in asking you about these documents is uij just to see ifyou recognize them and can tell ]i2] me what they are. I'm going to first show you 113] a document which has been marked as [i4j MONS040440. [15] A: I really don't recall having seen [16] this document before. 1 may have but I really ti7j don't -- I really don't -- it doesn't ring a 118] bell. [19] MR. CARNEY: It looks like it is out 120] 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. Gore & Perry 800 878-6750 [24] A: it has three other trade names. I [25] don't think those are Monsanto trade names. Page 32 HI 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)Q: Letmeaskyou,then,Dr.Levinskas, 18] if you would agree with the statement that [9] when dealing with PCB's at ele vated no] temperatures via hot ovens, welding, et [ii] 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? ii6] MR. CARNEY: I'm going to object to ii?] the question because I think it is vague and [is] 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 121] might be. There are a lot of variables there [22] that I didn't recall in your read ing it that [23] might be necessary to really definitively [24] answer that ques tion. [25] A: There are so-called threshold limit Page 33 ID 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 [5] advise people to take extra precautions if [6] they are working in a heated atmo sphere [7] because it just makes the air concentrations [8] that much higher. 19} Q: I guess I should have read that whole [io] paragraph and it does talk about at room un temperature PCB's give off negligible fumes [12] and are, therefore, harmless to breathing. 113] Would you agree with that? [i4] A: I would say yes. H5] Q: At room temperatures, do PCB's give [16] off an odor? [17] A: I haven't really looked at large work [18] places. I'm not conscious of any appreciable [19] odor from the small quantities that I have [20] 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.lt is my Min-U-S cript Page 34 [l] understanding that at room tempera ture the [2] vapor pressure which would indicate the ease bi 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,you know, 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? [ioj 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? [153 This is, for the record, labeled MONS030773 U6] and when I say, "labeled," that's just the in] Bates number on the first page of the ns] document. [19] MR. CARNEY: Did you say his name is [20] on here? I2i] MR. MURRAY: Not on that page, on the [22] next page. [23] MR. CARNEY: Okay. 124] A: This is an apparent epidemiology [25] study done on Monsanto employees. The primary Page 35 ID investigator is -- [2j 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? [10] A: At that time he was the manager of [ii] toxicology reporting to me. ii2] Q: Do you know if he is still em ployed [13] by Monsanto? [14] A: Yes. [15] Q: Let me ask you this: During your 116) 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? [24] A: This would be one of them, in August [25] '75. We had a young ladyjudy -- did another Page 36 ID study, I think, and then Bill Gaff)' may have [2] done some lateron --Judy Zack, I think. I [3] think Judy Zack did one. She Page 30 - Page 36 STLCOPCB4027361 George Levinskas, Pli.D June 7,1994 Judith Bechtold, et ai. v. Monsanto Company, et al. was in the 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. f7j Q: Judy Zack. Bill Gaffy. And this one 18) was apparently done by -- is it Doctor or [91 MisterJohanson? no] A: Doctor. No, let me take it back. I HU don't know whetherJudy Zack did a PCB study. [12] She did some studies but I don't recall [13] whether it was PCB's. [Hi Q: Was any study, epidemiological study, [is] on PCB's done in-house by Monsanto ever 116] published? [i7] 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 [21] he did some prelim inary epidemiological work [22] dealing with a mortality study, correct? [23] A: I would have to reread the letter. 1 [24] don't recall. I was not involved in it and 1125] don't recall. Page 37 ID 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. 15] 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. HD 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 -- [is] 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 [21] industrial hygienist at Wes tinghouse. The ]22) reason I know that is I was just looking at a [23] letter, a 1947 letter, from Barnes to somebody [24] 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. [5] 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 corner there is another Bates [9] stamp number 745090 and at the upper [io] right-hand comer there is an HD000133and [ii] then there is a --the typed copy of this [12] letter has a HD000135. [13] MR. MURRAY: Can I go on? [Hi MR. CARNEY: Yes. [15] Q: Dr. Levinskas, who is K. Warren [16] Easely? [17] A: He is a Monsanto employee who was in [is] ourWashington office in some aspects. [19] 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. (231 Q: What was his job description when he [24] was employed at the Wash ington office? [25] A: Iamnotawareofit.Whenlwould Page 39 [l] 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 (4i description. [5] Q: Do you know if he was a lawyer or [6] not? [7j 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 [in which has Bates stamp number SEM76859 and ask [i2j you if you have ever seen that. [13] A: I don't really recall seeing this ]i4] document. [15] Q: Don't recognize the handwrit ing? [16] A: Other than to say it is not mine. [17] Q: Okay.Do you know anybody with the [18] initials "WSJ"? [19] A: I can't think of anybody with those [2oj initials. [2i] MR. CARNEY: Did you read the Bates [22] stamp numbers in? [23] MR. MURRAY: Yes.IreadtheSEM[24j number, anyway. 125) MR. CARNEY: Okay. Page 40 ID 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. [5] 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 [10] it's got in parentheses, "(How justified?)" [ii] Do you remember anybody at Monsanto ever [121 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 usj 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 ID remember any particularperson 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 [ioj con versations with lawyers. HU MR. MURRAY: Obviously.Obviously. [12] A: So that's what I was trying to refer [131 to. [Hi Q: That's the only reason I was ask ing. [15] Again, I don't want to go back into all these [16] other issues. We might be here for a week if [i7] 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 [21 ] suggestion they were done? [22] A: No, I do not know. [23] Q: You were not pan of that process as [24] to making that decision to go ahead and do it [25] or not? Page 42 ID A: I was not involved in that. 12] 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, [12] I did not meet -- I did not attend this [13] meeting with NIOSH. [Hi 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-Script Gore & Perry 800 878-6750 1 ] ] ] ] STLCOPCB4027362 Judith Bechtold, et aL v. Monsanto Company, et aL George revmsKas, rn.ix June 7,1994 present at the [17] meeting and your name is present along with iisj others for Monsanto Company; is that correct? U9) A: Yes. 120] Q: That doesn't help you remember the [2i] meeting, huh? Or do you think that that's [22] inaccurate? [23] A: Iknow 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 [i] 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? m A: So I don't recall having been at that [8] meeting. 19] Q: Well, let me ask you this: This memo no] talks about a possible study with -- an in; epidemiological study with using Monsanto |i2] employees and, as best I can tell from this, U3) it appears that NIOSH wants to do it. Do you [H] know whether or not such a study ever took [i5] place? [16] A: I -- I really don't know anything [17] about the epidemiological studies, [is] Q: Okay. Are you aware of the stud ies H9] that were done in-house by Monsanto on certain [20] Aroclors to de termine dibenzol furan [2ij contamina tion and dibenzol dioxin [22] contamina tion? 123] A: I'm not sure of what, if anything, [24] was done for analysis. 125] 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 m guess specif ically I'm more interested in the [8] time period after 1987. Axe you aware of any [9] 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 [i2] of any analysis. U3] Q: Okay. Let me just make sure I cover |i4] all bases and ask you specific ally if you are |i5] aware of any work that has been done on any [16] Inerteen prod ucts with regard to furan or [17] dioxin contamination? [is] A: 1 have no knowledge of work done on [i9] Inerteens. [20] Q: Okay. Let me ask you -- I don't [21] remember this -- did you ever visit Gore & Perry 800 878-6750 the [22] Westinghouse Bloomington plant? 123) A: No. [24] Q: During your time at Monsanto, were [25] you ever asked -- strike that. Page 45 [1] You didn't go to work for Monsanto [2] until after 71? 13) A: July 71 I started. [4] Q: Other than the IBT studies, are you [5] aware of any other chronic toxicity studies [6] that were done by Monsanto on any aroclor [7] product? [8j A: I'm not aware of any others done by [9] Monsanto. no] Q: Were you aware of any others done at tiij the request of Monsanto? [12] A: No. U3] MR. MURRAY: Thank you, [i4] Dr. Levinskas. That's all I have. [i5] MR. CARNEY: Let me just ask you a life) couple of questions. Ii7] EXAMINATION [is] QUESTIONS BY MR. CARNEY: 119! Q: You mentioned a long-term test that [20] was being done at American Cyanamid when you [2i] got there.What kind of material was being [22] tested? [231 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 ID Q: You mentioned, 1 think, that dur ing [2] the time you were at American Cyanamid there [3] were approximately a dozen tests, long-term [4] tests, that were done. Can you tell me what [5] kind of materials, just generically, 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 [io] likelihood of a residue, if used according to mi direc tions. [12] Q: Residue on the food? [13] A: On the food. [14] 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 [17] food contact materials or pesticides where [18] 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 fifues 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 ID MR. CARNEY: Okay. I don't have [2] anything else. [3] EXAMINATION I4j QUESTIONS BY MR. MURRAY: [5] Q: Dr. Levinskas, wasn't "industrial [6] chemicals" the term we used earlier when you m talked about that the long term studies that [8] were done were being done on industrial [9] chemicals? no] A: I tried to make the comment once or [id twice of saying, "non-drug uses," and a food [i2] packaging material is or isn't an industrial [i3] chemical, depends on how you want to classify [i4] it but it is certainly not a drug use. [15] Q: There was certainly no prohibi tion [i6] against doing those long-term studies on [i7] industrial chemicals, was there? [18] A: I'm not aware there has ever been ' a [19] prohibition against doing studies on a [20] chemical. [21] 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 [25J have contact with food? Page 48 ID A: Probably.Themotivatingforce,I[2] guess, in doing them was somebody had to [3] perceive a need for it and it was not a [4] 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 [io] certainly could have done it and, in fact, |ii] chronic testing was being done during that 112] 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 it 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 [51 and forthe State of Missouri, duly [6] commissioned, qualified and au- Min-U-Script Page 43 - Page 50 STLCOPCB4027363 Lawyer's Notes STLCOPCB4027364 Judith Bechtold, et aL v. Monsanto Company, et aL lieorge Levuiaiuia, ray 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 6:16; 7:1,3; 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 wj 71 45:2,3 745090 38:9 75 35:25 7th 50:17 87 7:4; 25:4; 30:24 88 6:17 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 acute 17:17,19; 20:25; 25:17, 19; 26:3 addressed 7:10 administer 50:7 adverse 12:10,20; 26:10 advise 33:5 aforementioned 51:2 aforesaid 6:4; 50:16, 16, 22 Again 16:2; 41:15 against 47:16,19 age 6:2 agencies 39:2 agree 9:17; 32:8; 33:13 agreed-upon 11:9 agreement 51:10 agricultural 19:13 ahead 41:24 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 analysis 43:24; 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; 37:16; 38:4; 42:7 appear 34:13; 40:8 appears 43:13 Applied 16:22 appreciable 33:18 approximately 46:3 area 11:6 aroclor 45:6 Aroclors 33:1; 43:20 around 19:15 article 13:11,11,14 articles 28:25; 29:5 aspects 38:18 associated 10:4,5; 23:24; 28:9; 34:7 assume 12:17; 27:17; 29:10; 37:25 assumption 38:1 atmosphere 33:6 attack 26:24; 27:1 attempt 25:5 attempting 17:7 attend 42:12 attended 50:13 attention 42:15; 44:10 attorney 51:12 attorneys 50:17; 51:14 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 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 basis 20:14,16 Bates 34:17; 38:6,8; 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 bit 23:6; 26:2, 4 Bloomington 44:22 boron 17:4,5; 18:18; 22:7 both 7:14; 10:1; 15:4; 22:19 breathing 33:12 Broadway 50:14 brought 40:13 BS 7:22 C C 37:9, 20,25 Cafandra 40:7 call 26:22; 46:7 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, 17, 20; 38:5,14; 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 Cecil 6:15 certain 43:19 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 chemicals 9:3,11, 24; 10:1, 3,17; 11:11; 12:3,6,11; 14:22; 15:11,20,21; 16:1; 17:3,10, 23; 18:1,18, 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 chloracne 24:6; 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, 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; 47:10 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 concerted 25:8,11 conclude 14:13 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 context 40:17 continuing 27:24 contracts 17:1 conversations 41:10 copy 35:5:38:11 corner 38:8,10 ' correctly 51:1 couldn't 31:22; 37:19 counsel 51:4,5,10, 12 couple 45:16 course 8:20; 16:21 courses 8:l;ll:l4, 23; 16:24 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;_ 51:16 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 deponent 51:9 deposed 6:20; 7:4, 6 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 desk 35:5 details 37:4 Gore & Perry 800 878-6750 Mim-U-S cript 052789 - details STLCOPCB4027365 George Levinskas, Ph-B June 7, 1994 Judith Bechtoid, et ai. v. Monsanto Company, et aL determine 10:17; 12:2,19; 13:19; 19:20; 43:20 t* 'mined 12:12 c lop 12:17; 17:22 developed 16:21 during 11:13; 12:22; 14:7,15,19,18:17, 24; 19:11; 20:9; 25:4; 35:15; 41:2; 44:24; 46:1; 48:11 dyes 19:13 EXAMINATION 6:7; 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 experiment 13:13 E experiments 12:18; differs 9:24 difficult 28:22; 30:16 difficulty 27:20; 30:14 dioxin 43:21; 44:17 direct 42:14 directed 9:6; 17:16 direction 30:2 directions 46:11 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 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; director 19:7 discover 13:4 discussed 40:22 discussing 40:12 distinction 9:7; 10:6; 17:18; 21:15; 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, 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 29:6; 30:9 10, 20; 13:19; 17:10, 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; 42:23; 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; 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 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 U.22; 15:10 28:18 duly 6:2; 50:5, 19 even 13:10; 15:5; 26:2 event 28:25 follows 6:6 food 45:25; 46:7,8, 12, 13, 17; 47:11, 25 duration 14:13; every 26:16 force 48:1 20:25;21:10 everything 7:8 foregoing 50:23; durations 18:7 I evidence 24:4; 29:19 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 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 genericaiiy 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 Good 6:9; 10:2 government 17:1 graduate 7:15; 10:15, 24; 16:16 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 hazard 34:4 hazards 17:2; 23:24 HD000133 38:10 HD000135 38:12 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 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 hereby 50:8 interrogatories 6:6 higher 33:8 interrupt 40:21 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; 41:15; 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 IJ 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; 36:15; 41:19; 43:19 inaccurate 42:22 include 9:2 increase 33:3, 25 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 initials 39:18, 20 injection 18:4 injury 27:3; 28:3 Insofar 12:7 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 July 45:3 June 50:17 justified?) 40:10 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 lady 7:7; 35:25 language 40:7 large 33:17; 34:6 Largely 12:14 determine - Largely MLn-U-Script Gore & Perry 800 878-6750 STLCOPCB4027366 Judith Bechtold, et aL v. Monsanto Company, et aL George Levinskas, pill? June 7,1994 last 22:12; 42:25 later 30:4; 36:2,4 lawful 6:2 lawyer 39:5 lawyers 41:20 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 1516; 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; 46:3,6,1*3. 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 many 17:24; 26:21 March 51:18 marked 31:13 Master's 8:5 material 26:1; 45:21; 47:12 materials 15:19; 16:10; 17:20; 46:5, 17 may 23:4;24:10; 26:8; 28:18; 29:1; 31:16; 36:1,6; 40:1, 2; 41:4; 44:5; 47:24 maybe 26:2 mean 20:16,17; 28:12; 30:12,18; 35:18; 40:21 meaning 9:9 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 mentioned 45:19; 46:1 mentions 37:1 messiness 26:8 messy 26:18 met 42:24; 43:1 method 22:4 might 11:5; 12:20; 15:2,3:17:13,15; 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; 24:25; 31:25; 34:25; 35:13,16,16,19; 36:15; 38:17,20; 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 18:11,11 more 10:4,5,10; 11:17; 16:9; 20:2; 33:22; 44:7 morning 6:9 mortality 36:22 Most 6:13,24; 7:5; 15:18; 17:3; 18:9; 48:4 motivating 48:1 mouth 26:6 much 6:24; 30:13; 33:8; 34:4; 44:10 MURRAY 6:8,10; 9:16,10:20; 14:23, 15:14; 31:21; 34:21; 37:13,16,18:38:3, 13; 39:23:41:11; 45:13; 47:4; 48:14 must 32:12 N name6:9;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 needs 48:13 negligible 33:11 new 24:3 next 34:22 NIOSH 42:7,13; 43:13 non-drug 15:19; 16:10; 47:11 non-toxic 25:22 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 o oaths 50:7 object 9:13; 10:22; 14:3; 16:2; 20:15; 23:13; 24:9; 29:9,17; 32:16 objection 15:8; 24:14,15 objections 51:5 obstruction 47:23 Obviously 41:11,11 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 packaging 45:25; 46:8; 47:12 page 34:17,21,22; 42:15 pages 51:1 papers 30:2 paraffins 28:18; 30:10 paragraph 33:10 parentheses 40:10 part 41:23 particular 34:7; 41:1 particularly 30:11 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 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 places 33:18 plaintiffs 6:10 plans 12:5 plant 44:22 point 44:1;47:21; 48:7 points 11:8 policy 19:16,19 polymer 45:23 polymers 19:14 position 27:10; 30:8 possible 6:24; 12:1; 28:8; 43:10 possibly 14:16 potential 12:1; 26:12,17,18; 27:18; 30:25; 31:5 practice 13:16 pre-clinical 11:17, 22 precautions 33:5 predate 13:23 - % Predominantly 17:19 preliminary 36:21 present 10:7; 42:16, 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 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 published 13:12, 22; 28:10; 30:2; 36:16 purpose 23:16 purposes 9:8,9,17 pursuant 50:8 Q qualified 24:18; 50:6 quantities 33:19 questioning 24:13 ran 18:8; 21:4 range 19:13 rather 19:12; 25:22; 29:20 Gore & Perry 800 878-6750 Min-U-S cript last - rather STLCOPCB4027367 George Levinskas, Ph.D June 7,1994 Juditii Becntoio, ei au v. Monsanto Company, et aL Rats 14:9,11; 23:5 reach 13:15 read 30:23; 33:9; r 39:21,23 _.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;4l: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 ... ''r 13:2; 41:12 ;rencell: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 35:6,11 '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 research 16:17,25; 17:8; 18:16, 20 researchers 13:3 residue 46:10,12,18 resin 45:24 respects 51:6 respirators 32:14 response 48.13 results 13:12 retire 25:2 retired 24:17; 25:1 retyped 38:4 review 42:9 reviewed 24:11; 25:13; 40:16 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 run 10:16; 13:13; 14:1,17; 20:6,11,19; 35:16 s same 8:20; 21:20, 21; 30:1; 40:18 samples 30:7 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 sciences 11:18, 22 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 sets 40:15 several 16:23; 18:11 short 18:9 shorten 6:24 shorter-lived 23:18 shorthand 50:24 shot 31:23; 39:9 show 31:12; 39:10; 42:8 shown 50:23 sign 28:3 signature 51:9 significant 26:10 signs 9:25; 27:3 similar 6:14 single 25:23 six 18:10 six-month 22:6 sixties 28:13 skin 18:5; 22:23,25; 26:1, 16 slightly 23:4 small 33:19 so-called 30:10; 32:25 solely 28:20 somebody 25:25; 26: i7; 37:23; 41.-4; 48:2, 8 someone 27:21, 23 something 20:13, 14; 24:6; 26:5; 27:25; 28:1, 1; 30:19:31:20; 39:2 sorry 24:23 sort 11:22; 12:18 sound 50:18 sounds 32:4 span 23:12 speak 15:16; 29:18 specific 30:23; 39:3; 48:13 specifically 17:3; 18:22; 41:2,7; 44:7, 14 spectrum 10:11 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 stated 30:19 statement 32:8; 40:9 statements 30:3 still 23:3; 24:25; 35:12; 38:19; 43:1 Stop 27:22 straight 8:5 strains 23:5 strength 45:24 strictly 32:12 strike 44:25 students 11:18 studies 8:2; 11:16; 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; 43:17,18; 44:3, 5; 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; 36:1,11,14. 14, 22; 43:10, 11,14 studying 10:1 subacute 21:14,19 subchronic 21:1, 13, 17; 22:9,10 temperature 33:11; 34:1 temperatures 32:10,18; 33:2,15, 24 tendency 10:10 term 14:11,18:10; 20:21; 21:13,14,20, 21; 47:6 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 testified 14:5; 50:22 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; 14:13; 17:21; 18:8; 46:3,4,6,15 subject 9:6; 41:7 subjects 11:21 subsequent 24:2 Subsequently 28:12 substantiated 15:17 suggestion 41:21 suit 51:13 Suite 50:14 supplied 40:16 supply 17:20 sure 15:23; 23:25; 24:18; 29:23; 32:1; 37:25; 38:21; 43:23; 44:13 textbooks 13:1 themselves 29:19 therefore 33:12 thereto 51:5 thereupon 50:22 thinking 13:9 third 19:25 thirties 28:14 though 22:8,11; 48:7 thought 31:21 thoughts 12:16 three 31:24; 40:18 threshold 32:25 swallowed 26:2 throughout 30:24 sworn 6:2; 50:20 thrust 11:15; 18:16; symptoms 27:7 - 24:3 tissues 10:2 to-wit 6:6 today 6:11,25; 9:8, talk 7:13; 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, 18; 10:13; 24:17; 25:15 together 51:3 took 8:2; 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 20 Technology 8:11 toxicology 8:1;9:8, I 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 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; 27:11 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-TJ-S cript Gore & Perry 800 878-6750 STLCOPCB4027368 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 % 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 week 41:16 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, ptLD June 7,1994 vague - Zack STLCOPCB4027369