Document JvK7g9r9NX6nykQpQKNN5dYwK
FILE NAME: Metropolitan Life (ML)
DATE:
DOC#: ML
DOCUMENT DESCRIPTION:>ZZ dZZ^ZDdE
l' ~
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ORIGINAL 1
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
THE PRUDENTIAL INSURANCE )
COMPANY OF AMERICA,
)
Plaintiff
)
vs
)
TURNER and NEWALL, PLC. , )
et al. ,
)
Defendants
)
CIV IL ACTION NO. 85-2179-6
VIDEO TAPE DEPOSITION UNDER ORAL EXAMINATION
OF WILLIAM EDGAR SMITH, M.D.
-~~-----------------------
, UNITED STATES COURT
SOUTHERN DISTRICT OF NEW YORK
THE CHASE MANHATTAN BANK, N.A.,
Plaintiff
87 Civ. 4436 (VLB)
-against-
TURNER and NEWALL, PLC., and
TURNER and NEWALL, LTD.,
Defendants
BRODY & GEISER
Certified Shorthand Reporters
698 King Georges Road
Fords, New Jersey 08863
JOB t 801253
(201) 738-8555
Brody & Geiser (201) 738-8555 or (212) 732-0644
, .
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
I
23 24 25
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letter that you received. Is that correct?
A
Correct.
Q
Is that an accurate photocopy of the
letter?
A
Yes.
Q
Attac~ed to that letter was the report of
Dr. Knox and Dr. Doll. Correct?
A
Yes.
Q
What" if anything, did you do with that
paper strike that.
Did you read the paper when you received
it?
A
Yes.
Q
Was it of any significance to you?
A
Yes. It seemed to be presenting the first
really impressive evidence for an association between
lung cancer and . asbestosis, because it had, as I
recall, age-adjusted studies.
Q
Did you have occasion thereafter to share
the Knox/Doll paper with Dr. Lanza?
A
Yes.
Q
What was his reaction to the paper?
A
His reaction to this paper was very much the
same as his rea6tion to when I gave ,him the letter that
I had gotten from Dr. Knox back in December of '53. I
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1
remember taking it in thinking that this was
2
scientifically interesting information, and I remember
3
Dr. Lanza became very red in the face, slammed his fist
4
down on the table and said, nyOu know, you cancer
5
investigators are troublemakers. You are trying to pin
6
this whole cancer p'roblem on industry.n
7
And he was very -- I thought he was going
8
to have a stroke. He was very indignant about it.
9
o
Is your letter of transmittal to Dr. Lanza
10
what has been marked as Exhibit IS?
11
A
12
Yes.
MR. HANLY:
,
If I could just have a minute
13
to see that, please?
14
MR. ENSLEIN: Sure.
15
MR. HANLY: Off the record.
16
(Discussion off record.)
17
BY MR. ENSLEIN:
18
o
So that the record is clear, Exhibit 15 is
19
dated what, Doctor?
20
A
10, December ' 53
21
0
And is this the transmittal letter for
22
Dr. Knox's December 3, 1953 letter?
23
A
That's r~ght.
24
0
So you gave Dr. -- you initially gave
25
Dr. Lanza the letter from Dr. Knox dated December 3,
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1953?
2
A
That's right.
3
O And then you subsequently gave Dr. Lanz a
4
the later correspondence in '54 from Dr. Knox enclosing
5
his report?
6
A
Yes.
7
MR. HANLY: Referring to Exhibit l4?
8
MR. ENSLEIN: Yes.
9
o
Yes, that's Exhibit 14?
10
A
Correct.
11
o
Thank you, Doctor. What subsequently
12
occurred in your career, Doctor, at NYU after sharing
13
this information with Dr. Lanza?
14
A
I was told that my appointment there would not
15
be renewed.
16
o
Did you have an understanding as to why
17
that occurred, sir?
12
18
A
He never told me why it occurred, no.
19
Q
Did you form a belief as to why it
20
occurred, that your position was terminated?
21
MR. HANLY: I object to the form and
22
substance.
23
MR. ENSLEIN: All right. Let me rephrase
24
it.
25
o
Did you have an understanding or did you
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form a gelief as to why your position was not renewed?
2
A
I did.
3
o
What did you come to believe, sir?
4
A
Well, Dr. Lanza had told ~e after this, and a
5
number of times before, that cancer investigators had
6
no idea of the pro~lems that they were creating for
7
compensation practice and for insurance companies by
8
making claims or reporting ~ata that would associate
9
cancer with occupational exposures.
10
MR. HANLY: May I have that answer read
11
back, please?
12
(Read back).
13
MR. HANLY: Thank you.
14
o
Doctor, if I could hand you what has been
15
marked earlier in your deposition as Exhibit 7, your
16
letter to Dr. Armstrong of June 12, 1956, what was the
17
purpose of that letter, sir?
18
A
This was to request a hearing at NYU, a hearing
19
on the on my being fired.
20
o
Were you able to attend that hearing,
21
Doctor?
22
A
No.
23
o
Did you ever have occasion to discuss with
24
Dr. Lanza what role, if any, he played in Dr. Vorwald
25
leaving the employment of Saranac Lake laboratory?
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1
A
Dr. Lanza described that to me. I remember when
2
he came back from a meeting at Saranac Laboratory he
3
had been very -- let1s see, there were several of us
4
there. I believe that Dr. Nelson and also a
5
Dr. Goldstein were present when Dr. Lanza carne back,
6
and he was telling us that Dr. Vorwald had been doing
7
studies exposing animals to some beryllium compounds
8
and he had gotten -- found s~me cancers of the lungs in
9
some. of these animals, and he was going to report that,
10
and that in Dr. Lanza1s opinion the Saranac Laboratory
11
was not set up for cancer research, it was set up for a
,
12
study of pneumoconiosis, and that he had seen to it
13
that Dr. Vorwald would have his service there
14
terminated and that he would -- he had applied for --
15
Vorwald had applied for grants of further studies of
16
cancer effects of beryllium compounds, I believe,
.~
,.t; .
17
applied to the Damon Runyon Fund for that, and Lanza
18
said he was on the board of that fund and he was going
19
to see to it that Vorwald didn1t get that grant also.
20
He told me he had personally gone to see
21
the dean of a medical school in California where
22
Vorwald had applied for a position or was bein9 offered
23
or bein9 considered for a position, and was 90in9 to
24
see to it that he didn't -- didn't ~et that position.
25
Whether this was related to another
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problem in California that had to do with diatomaceous
2
earth, I don't know. But I remember separately that
3
Dr. Lanza told me that he had to handle a problem
4
for -- that had come up in connection with diatomaceous
5
earth exposures in California and that that -- and a
6
Dr. Abrams, who was causing trouble for them out there
7
and -- by wanting to study men exposed to diatomaceous
8
earth dust, and Dr. Lanza had gone out there.
9
I don't know whether he had gone out
10
there, but he told me that he had to do something about
11
this and bring to the attention of this Dr. Abrams that
12
the State Health Department, which was Abrams'
13
organization, would need th~ agreement of industry to
14
make this study, and that he was going to see to it
15
that this effort would be contained, I think was the
16
word that he used.
17
Now, he -- I have a letter from -- I have
18
an article from Abrams which is published in the
19
American Journal of Public Health that that problem has
20
been -- that dragged along for twen~y years as a result
21
of which Abrams died, and that also I have a letter
22
from someone at Metropolitan Life asking Dr. Lanza to
23
do something about the trouble that Abrams was causing
24
out there by wanting to get into this.
25
o
Do you have your correspondence from your
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days at New York University with you here today?
2
A
I do.
3
4
A
5
Q
Can you share that with us, please?
Urn-hum.
MR. ENSLEIN: Perhaps we can go off the
6
record while we gather these materials.
7
(Off the record.)
8
(Exhibit Smith ~6 is marked for
9
Identification.)
10
MR. HANLY: Mr. Enslein provided to me
11
through Dr. Smith an opportunity to review a
12
folder of approximately one Inch in thickness
13
which is marked as Exhibit 16.
14
I have had an opportunity to briefly
15
look through this material. I think I spent
16 13
17
about twenty minutes doing so. I believe there is a lot of material in there which might
18
provide to T&N an opportunity to ask Dr. Smith a
19
number of questions about the events in issue
20
in this raised by Mr. Enslein,in this
21
deposition, and therefore at the conclusion of
22
the proceedings here today my position is going
23
to be that the deposition is not concluded and I
24
reserve my right, upon review,of that
25
material in more detail, to reconvene a
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deposition with Dr. Smith's consent to further
2
examine him concerning this fairly voluminous
3
exhibit.
4
MR. ENSLEIN: For the record, the
5
m, aterials in question were handed me only
6
yesterday evening by Dr. Smith, and these are
7
being produced by the doctor in response to
8
subpoenas issued in both cases. I just wanted
9
the record clear on that point.
10
I don't intend to ask the doctor
11
questions about each of these documents, but
12
only relatively few of them ~hat are included.
13
BY MR. ENSLEIN:
14
Q
Doctor, handing you what has been marked
15
as Exhibit 16, does this folder contain your
16
correspondence and other papers related to your tenure
17
at NYU?
18
A
Yes.
19
Q
Doctor, I would like to ask you a few
20
questions concerning a number of th~ documents
21
contained therein.
22
As I hand you these letters would you
23
please identify for the record the date of the letter
24
and the various parties involved and the correspondence
25
as we go, and then identify what the letter concerns,
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if you could? The first letter, Doctor?
2
A
This is a letter of March 22, 1949 to me from
3
Dr. Lanza and it is saying that he will be pleased to
4
become a "member of your group," which means the Cancer
5
Prevention Committee.
6
o
This is a letter that Dr. Lanza wrote in
7
response to your invitation?
8
A
Invitation to join.
9
o
And I hand you what's been marked -- well,
10
excuse me.
11
Could you identify the next document for
12
us?
13
A
This is a letter of January 23, 1950 to
14
Dr. Lanza from me, and it says, nIn view of clinical
15
data associating certain cases of lung cancer with
16
asbestosis, we would like to set up tests for
17
carcinogenicity of asbestos materials for lung tissue
18
utilizing the tissue transplant technique. n
19
And then it asks whether it would be
,":,
20
desirable to contact a manufacturer .and request samples
21
of asbestos, and whether I should do that or whether
22
Dr. Lanza might care to do that.
23
o
The next document, could you identify that
24
and tell us what it is?
25
A
This is simply a letter of appointment in 31,
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January 1950 appointing me as -- let's see -- on the
2
staff of the Postgraduate Medical School of the
3
academic year 1949-1950.
4
o
And that's signed by the vice-chancellor
5
and secretary of New York University?
6
A
Right.
7
0
I'm handing you the next documents which
8
are\clipped together in your file.
9
Could you identify the documents for us?
10
A
Yes. This is a reprint from the American
11
Journal of Public Health, Volume 44, May 1954, an
12
article by Herbert K. Abrams. Titl~ of the article is
13
-Diatomaceous Earth Pneumoconiosis.-
14
Attached to it is a photocopy of a letter
15
of February 7, 1952 addressed to A.J. Lanza and signed
16
by w.P. Shepa~d, the third vice-president, Metropolitan
17
Life Insurance Company.
18.
Q
What does the letter concern?
19
A
Well, this letter concerns let me read it a
20
little bit. It says, -Dear Tony
21
MR. HANLY: Excuse me. I object to the
22
form and the manner of proceeding.
23
o
Doctor, is this letter of significance to
24
you in any way?
25
A
Yes.
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1
o
In what way?
2
A
This letter has to do with the problem that
3
Dr. Lanza had mentioned to me, a problem in connection
4
with exposure of men to diatomaceous earth in a mine in
5
California and the -- Dr. Abrams at that time was with
6
this Bureau of Public Health, I believe it was. He
7
was, I think, the senior officer in one of the
8
departments of that bureau, and he had wanted to do
9
studies of the health of men employed in mining this
10
material.
11
Now, as Dr. Lanza had told me about this,
12
he had been asked as indicated in this letter, he had
13
been asked by the Metropolitan Life Insurance Company
14
to do something about that, and I think the letter and
15
the article probably would speak for themselves.
16
o
Briefly, do you know what, if anything,
17
Dr. Lanza did with regard to that problem?
14
18
A
Well, I remember him telling me about it because
19
it's -- I felt he was giving me sort of a training for
20
how industrial medical problems and compensation
21
problems should be handled, the subtleties of the
22
problems and the complexities of them, and that he was
23
trying to protect the insurer from unjustified claims,
24
and how he was going to go about this.
25
And he was telling me that he had been
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successful in getting the problem resolved in a way
2
that he felt was protecting the insurer from some
3
studies that Dr. Abrams wanted to conduct.
4
o
Do you remember what Dr. Lanza did?
5
MR. HANLY: 11m sorry. With r.spect to
6
what?
7
MR. ENSLEIN: This matter.
8
A
As I remember him telling me about this matter,
9
he was telling me that he had been able to -- as he put
10
it, put the lid on Abrams.
11
o
What did you understand that to mean?
12
A
I understood that to mean that he was -- had
13
done, in some way, protected the Metropolitan Life
14
Insurance Company against some action that this
15
Dr. Abrams was attempting to undertake that would
16
create possible problems for them.
17
And when Abrams sent me a copy of his
18
paper that he wrote some years later about it, he was
19
saying there, in summarizing the situation, as I recall
20
he was saying that he felt that the study of methods
21
for protecting men there had been delayed by some
22
twenty years, and I remember this as something that
23
struck me as the wrong way to be going about industrial
24
hygiene things.
25
It was the first real experience I suppose
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that I had in mind in feeling that well, I could
2
understand the need for study of occupational problems
3
so that there would not be unjustified claims, but on
4
the other hand I felt that it was not right to be
5
delaying investigations and obstructing investigations.
6
Q
Doctor, handing you the next document, can
7
you identify this for us?
8
A
This is a note that I wrote to Dr. Lanza dated
9
December 10, 1953, and it's saying that I just received
10
the attached letter containing comment on lung cancer
11
and asbestosis from John Knox.
12
Q
Is that your .original 'file copy for what
13
was earlier marked as Exhibit l5?
14
A
Yes.
15
Q
Thank you, Doctor.
16
Can you identify the next document for us,
17
please?
18
A
This is a letter dated June 28, 1954 addressed
19
to Professor A.J. Lanza and written by me.
20
Q
What was your purpose ~n sending that
21
letter to Dr. Lanza?
22
A
My purpose was to ask for a board of review
23
having to do with my -- the termination -- his telling
24
me about the termination of my appointment at New York
25
university.
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1
o
Do you recall what Dr. Lanza's reaction
2
was when he received your letter?
3
A
Yes.
4
o
What was his reaction?
5
A
Well, it must have been within a day or two
6
after I handed him ,this letter that he called me and
7
told me that I had no idea of the problems that would
8
be created for industries ana insurance companies by
. -
9
claims that cancers were related to occupational
10
e~posures, and that the people who were putting out so
11
much along that line were troublemakers and were trying
,
12
to pin the blame for the whole cancer problem on
13
industry, and that if I persisted in asking for this
14
hearing or submitted a letter like this to other
15
people, he was going to sue me for libel and this would
16
mean that he would take away my house and everything I
17
had.
18
o
Next appears in your file are two sealed
19
envelopes. What are these?
20
A
Well, I was -- as I was certainly shaken up by
21
his threat to sue me for everything I might have if I
22
distributed this letter to others and went ahead with
23
asking for a board review at the university, and this
24
letter, which I had sent to Dr. Rhoads, the director at
25
Memorial Cancer Center, I don't know that I had
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actually mailed it because it doesnlt have any stamps
2
on it, but I guess I held it and didnlt mail it and I
3
left it here as evidence that I had not sent it out, so
4
that if he did sue me I felt I might have some
5
protection.
6
Now, h~re is a letter addressed to me from
7
Marion Sulzberger, M.D. Dr. Su1zberger was the editor
8
of a book that I contributed ,a chapter to, and I guess
9
I had sent him a copy asking him to help me out at the
10
university in this matter, and I probably asked him to
11
return it because this letter is addressed to me from
12
him.
This
envelope
is
addressed
, to me
from
him,
and
I
13
haven1t opened that.
~
14
Q
Doctor, handing you the next document,
15
could you identify those papers for us?
16
A
This is a letter dated July 25, 1953 addressed
17
to me from Arthur J. Vorwald, M.D., Saranac Lake, New
18
York.
19
Q
And is that letter of significance to you,
20
sir?
21
A
The significant thing to me is that he says,
22
-Dear Bill: On July 14, my resignation as director of
23
the Trudeau Foundation and Saranac Laboratory was
24
forwarded to the president of the board of trustees.
25
It distresses me to inform you of this.n
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The thing that impresses me about this
2
letter is that he is saying that he obviously is
3
unhappy about having to forward his resignation.
4
o
Did you subsequently have a discussion
5
with Dr. Vorwald concerning his termination at Saranac?
6
A
Yes, I did.
7
o
Did you have occasion at the time of that
8
conversation to record or jot down notes concerning
9
that conversation?
10
A
I did.
11
o
And do you have that document with you,
12
sir?
13
A
14
15
A
16
Yes, sir.
o
Where is it?
Here (indicating).
o
It is clipped to the letter?
17
A
18
Yes.
o
Could you identify your handwritten notes,
19
sir?
20
A
Yes.
21
o
What is it?
22
A
Well, these are notes that I made on the date of
23
24, August 1955.
24
o
Why did you find it necessary or decide to
25
record your conversation with Dr. Vorwald in that
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fashion?
2
MR. HANLY: Objection to the form.
3
MR. ENSLEIN: Strike my question. I will
4
rephrase it.
5
o
Why did you record the conversation with
6
Dr. Vorwald?
7
A
I recorded it because I remembered what
8
Dr. Lanza had told me about how he had stopped an
9
investigation that Dr. Abrams wanted to make in
10
California, that he had. told me how he had stopped
11
Dr. Vorwald's studies of cancer by inhalation,
12
experiments with animals, how he haa stopped
13
Dr. Hueper's studies at the National Cancer Institute
14
where they were having problems with occupational
15
cancer, and then he had told me that my studies were
16
going to be stopped and they were going to get rid of
17
me, and I felt I wanted to get information about others
18
other than myself who had met this fate.
o 19
Did you anticipate using this information
;
20
in the hearing?
21
A
Yes.
22
o
What took place during your conversation
23
with Dr. Vorwald?
24
A
Well, my notes tell me what I asked and what he
25
answered.
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1
o
Could you tell us what occurred?
2
MR. HANLY: Well, I'm going to object if
3
Dr. Smith is going to read from the document.
4
If you want to ask him what his
5
independent recollection is, that's fine, but
6
the document speaks for itself.
7
o
I would like, if you could, Doctor, to
8
read your notes, please.
9
MR. ENSLEIN: And I understand your
10
objection.
11
MR. HANLY: I object to that.
12
0
Go ahead, sir. You may go ahead and read
13
your notes.
14
A
Well, the question ~hat I asked was "What was
15
the trouble at Saranac that you are having to leave?"
16
And then it says, "Vorwald"
17
"ANSWER: Tony (Lanza) did many
18
things for his own aggrandizement
19
and for the benefit of the
20
industries he served rather than for
21
the advancement of science."
22
Is that enough? There is a good deal
23
more, but it's all here if anyone wants it.
24
0
If you could, sir, since your handwriting,
25
unlike my own, is somewhat difficult to read, if you
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could read through it.
2
A
Read through it?
3
Q
Yes.
4
A
All right. My next question was,
5
"You mean that you feel that he
6
placed his obligations to firms that
7
had retained him as a consultant
8
ahead of advancement of scientific
go
knowledge?
10
ANSWER: Yes. And another thing I'd
11
like to know is why he brought in
12
foreigners.
13
QQESTION: Who are you thinking of
14
there?
15
ANSWER: Well, Schepers and Ken
16
Smi th.
17
QUESTION: Had Schepers done any
18
cancer research?
19
ANSWER: No. He hadn't done any
20
research.
21
QUESTION: Well, you had developed a
22
lot of experience in research, and
23
particularly in making a fundamental
24
contribution to cancer research. So
25
had I. When a man has developed
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experience and is replaced by an
2
inexperienced man, wouldn't you say
3
that sets back progress?
4
ANSWER: Yes, I certainly would.
5
QUESTION: Would that not be an
6
advantage to interests that wished
7
to impede progress?
8
ANSWER: Yes, it certainly is.
9
QUESTION: Do you feel that
10
Dr. Lanza aided or impeded your
11
efforts to develop your cancer
12
studies?
13 14 15 16 17 18 19 20 16 21
ANSWER: Well, my efforts were certainly blocked and stopped, and my feeling is that Tony was in the background of this. But he is a very slippery fellow and it's awfully hard to pin things down definitely, but I know perfectly well that he got me out." And that's the end of it.
22
Q
Thank you, Doctor. Could you identify the
23
next document for us?
24
A
This is a letter dated August 24, 1955 to me
25
from W.C. Hueper, M.D., Chief of Environmental Cancer
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1
Section, National Cancer Institute.
2
Q
Is that letter of significance to you,
3
Doctor?
4
A
Yes.
5
Q
Why?
6
MR. HANLY: Please note my objection to
7
the form of the question.
S
Q
In what way iS,the letter significant to
9
you, Doctor?
10
A
Here is a central paragraph.
11
MR. HANLY: I'm going to object to the
12
witness reading.
13
Q
Could you paraphrase rather than reading
14
the paragraph, Doctor?
15
Tell us what in that letter is of
16
significance to you?
17
A
The thing that is significant to me here is that
18
Dr. Hueper,'who was at that time chief of the
19
environmental cancer section at the National Cancer
20
Institute, says that his activities on environmental
21
cancer were discontinued in 1951, When I was requested
22
to stop such activities. This event was brought about
23
by a complaint, as I was officially told, and made to
24
my superiors in Washington on behalf of the American
25
Chromate Industry by Dr. Lanza as its medical
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1
representative."
2
o
Did you have an understanding as to what,
3
if anything, occurred with regard to Dr. Hueper's
4
research at the institute at this point in time?
5
A
Yes. His work on environmental cancer was, as
6
he says, going to be discontinued. This means his work
7
on the epidemiological aspect of it. He was able to
8
continue some experimental studies, I believe.
9
o
Doctor, after you left New York University
10
where did you go next?
11
A
To Fairleigh Dickinson University.
12
0
And during your years 'at Fairleigh
13
Dickinson what was -- what kind of work were you
14
involved in?
15
A
Well, half-time teaching of health and education
16
and the rest of the time in research work, laboratory
17
work.
18
Q
Did you continue that work until your
19
retirment?
20
A
Yes.
21
MR. ENSLEIN: Thank you, Doctor. I have
22
no further questions.
23
MR. HANLY: Doctor, I'm going to have a
24
number of questions. I wonder if we could take
25
a three or four-minute break, please.
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