Document M4d6vQO5ovM53mvVvQGx8kzka
STATE OP FLORIDA COUNTY OP
AFFIDAVIT OF PHILIP E. ENTERLINE
PHILIP E. ENTERLINE being duly sworn deposes and says: 1. I reside at 37 St. Clair Drive, Pittsburgh,
Pennsylvania 15228. 2. I am a Professor Emeritus of biostatistics at the
University of Pittsburgh. 3. My field of specialty is biostatistics. 4. I have reviewed all the medical literature published
on asbestos and cancer during the period 1934-1964. 5. In 1978, I prepared a book entitled Asbestos and
Cancer which summarized that review. 6. That book was updated in 1980. 7. The review was conducted at the request of the
Asbestos Information Association ("A.I.A."). 8. As part of this review, I read an article entitled
"Experimental Studies of Asbestosis" published in the Archives of Industrial Hygiene and Occupational Medicine, Volume 3, dated 1951.
9. ' This article was authored by A. J. Vorwald, T.M. Durkin and P.C. Pratt ("Vorwald Article").
10. As c result of my review of the published literature, I concluded that in the United States there was a twenty-year lag in the acceptance of the causal connection
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between asbestos exposure and cancer. 11. I have recently reviewed a document entitled
"Outline of Proposed Monograph on Asbestosis" written by Dr. Leroy Gardner ("Monograph Outline"). (A copy of which is attached as Exhibit 1.)
12. This Monograph Outline contained information not contained in the Vorwald article.