Document MGzQLJry5OvoZN2r61e832Nnz

1 1 SUPERIOR COURT FOR THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 2 SOUTHEAST DISTRICT 3 --- 4 DAVID GERCHMAN and : CASE NUMBER 5 THERESA GERCHMAN, : VC 060 106 Plaintiffs, : 6: vs. : Assigned to: 7 : Hon. Raul A. BERRYMAN PRODUCTS, INC.; : Sahagun 8 CRC INDUSTRIES, INC., : which will do business : Dept. SE "F" 9 in California as : Pennsylvania CRC : Complaint 10 INDUSTRIES, INC.; : Filed: December (Continued) : 12, 2012 11 : 12 - - - 13 Thursday, July 26, 2012 14 - - - Oral deposition of GREGORY SARNA, M.D., 15 taken pursuant to Notice at the offices of Hogan Lovells, 1999 Avenue of the Stars, 16 Suite 1400, Los Angeles, California beginning at ^10:00 a.m., Pacific Time, before Brigitte 17 A. Strain, a Federally Certified Registered Professional Reporter and Notary Public. 18 --- 19 20 21 22 23 VERITEXT NATIONAL COURT REPORTING COMPANY 24 MID-ATLANTIC REGION 1801 Market Street - Suite 1800 25 Philadelphia, Pennsylvania 19103 1 Continued: 2 FORD MOTOR COMPANY; : LOCTITE CORPORATION : 3 n/k/a HENKEL CORPORATION : ILLINOIS TOOL WORKS, INC. : 4 Solely as successor-in-interest : to Permatex, Inc. : 5 RADIATOR SPECIALTY COMPANY : UNITED STATES STEEL CORPORATION : 6 SAFETY-KLEEN CORP. : SAFETY-KLEEN SYSTEMS, INC. : 7 3M COMPANY : E.I. DUPONT DE NEMOURS & COMPANY : 8 SEA FOAM SALES COMPANY : JUSTICE BROTHERS, INC. : 9 HANSON MERRILL CORPORATION : a/k/a ERNIE'S AUTO PARTS : 10 HENKEL CORPORATION : Individually and as : 11 Successor-in-Interest to : LOCTITE CORPORATION and : 12 HENKEL LOCTITE CORPORATION : and DOES I THROUGH 100 : 13 Inclusive : Defendants : 14 15 16 17 18 19 20 21 22 23 24 25 2 1 APPEARANCES: 2 LOCKS LAW FIRM 3 BY: ANDREW J. DuPONT, ESQUIRE The Curtis Center, Suite 720E 4 601 Walnut Street Philadelphia, Pennsylvania 19103 5 (215) 893-0100 Adupont@lockslaw.com 6 Representing the Plaintiffs (Via Mobile Depo and Teleconference) 7 8 HOGAN LOVELLS BY: BARRY THOMPSON^, ESQUIRE 9 1999 Avenue of the Stars Suite 1400 10 Los Angeles, California 90067 (310) 785-4600 11 Barry.thompson@hoganlovells.com Representing the Defendant, 3M Company 12 13 JONES CARR McGOLDRICK 14 BY: CHRISTOPHER CARR^, ESQUIRE Premier Place 15 5910 N. Central Expressway Suite 1700 16 Dallas, Texas 75206 (214) 828-9200 17 christopher.carr@JCMFirm.com Representing the Defendant, Safety-Kleen 18 Systems, Inc. 19 20 21 22 23 24 25 3 4 1 APPEARANCES (continued) 2 LEWIS BRISBOIS BISGAARD & SMITH LLP 3 BY: JAMES D. FRASER, ESQUIRE 221 N. Figueroa Street 4 Suite 1200 Los Angeles, California 90012 5 (213) 250-1800 Fraser@lbbslaw.com 6 Representing the Defendants, Henkel Corp. And Illinois Tool Works, Inc. 7 8 McGUIRE WOODS LLP BY: KEN ABRAMS^ ESQUIRE 9 One James Center 901 East Cary Street 10 Richmond, Virginia 23219-4030 (804) 775-1000 11 Kabrams@mcguirewoods.com Representing the Defendant, Ford Motor 12 Company 13 SHANNON, GRACEY, RATLIFF & MILLER LLP 14 BY: JEFFREY ALLEN, ESQUIRE 1000 Ballpark Way, Suite 300 15 Arlington, Texas 76011 (817) 877-8144 16 Jallen@shannongracey.com Representing the Defendant, Berryman 17 Products, Inc. (Via Teleconference) 18 19 STEPTOE & JOHNSON, LLP BY: JENNIFER BONNEVILLE, ESQUIRE 20 633 West Fifth Street Suite 700 21 Los Angeles, CA 90071 (213) 439-9494 22 JBonneville@steptoe.com Representing the Defendant, CRC Industries, 23 Inc. 24 25 5 1 APPEARANCES (Continued): 2 ^WALSWORTH, FRANKLIN, BEVINS & MCCALL LLP 3 BY: STACEY DIPPONG, ESQUIRE One City Boulevard West, 5th Floor 4 Orange, California 92868 (714) 634-2522 5 sdippong@wfbm.com Representing the Defendants, United States 6 Steel Corporation and Justice Brothers, Inc. 7 8 KATZ & ASSOCIATES BY: DOUGLAS C. LeCRONE, ESQUIRE 9 21500 Oxnard Street Suite 450 10 Woodland Hills, California 91367 (818) 716-6110 11 Rob@robkatzlaw.com Representing the Defendant, Hanson Merrill 12 a/k/a Ernie's Auto Parts 13 14 15 16 17 18 19 20 21 22 23 24 25 6 1 INDEX --- 2 Testimony of: Gregory Sarna 3 By Mr. DuPont.................. 4 --- 5 EXHIBITS 6 --- 7 EXHIBIT NUMBER DESCRIPTION PAGE MARKED 8 Sarna-1 Invoices of Dr. Sarna 9 Sarna-2 E-mail from Mr. Skaar 10 To Dr. Sarna 11 Sarna-3 12 Sarna-4 Notes and Comments of Dr. Sarna 13 Sarna-5 Scientific Articles 14 Sarna-6 Article - Chelghoum, Kane 15 Sarna-7 Article - Scarselli 16 Sarna-8 Articles - Pukkala, Ji, Guo, 17 Costantini, Hotz, McLean 18 Sarna-9 Articles - Pedersen-Bjergaard, Mauritzson, Sonali Smith, Martyn 19 Smith, Mitelman, Brownson, Doll, Adami, Thomas, Chelghoum, 20 Kane, Sandler 21 22 23 24 25 7 1 Exhibits (continued): 2 EXHIBIT NUMBER DESCRIPTION PAGE MARKED 3 Sarna-10 Article - Triebig, McLean 4 Sarna-11 Article - Wester and Abstract 5 Sarna-12 Article - Miller 6 Sarna-13 Research Report, Miller 7 Article - Williams 8 Sarna-14 Article - Glass - Health Watch Exposure Estimates 9 Sarna-15 Article - Glass - Leukemia Risk 10 Sarna-16 Article - Hayes 11 Sarna-17 Article - Ward 12 Sarna-18 Article - Qing Lan, Polymorphisms 13 Sarna-19 Article - Qing Lan, Hematotoxicity 14 In Workers Exposed to Low Levels Of Benzene 15 Sarna-20 Chemico-Biological Interactions 16 Sarna-21 Article - Collins 17 Sarna-22 Article, Martyn Smith 18 Sarna-23 Legal pad of handwritten notes 19 20 21 22 23 24 25 1 DEPOSITION SUPPORT INDEX 2 DIRECTION TO WITNESS NOT TO ANSWER 3 Page Line 4 5 REQUEST FOR PRODUCTION OF DOCUMENTS 6 Page Line Description 7 8 9 STIPULATIONS 10 Page Line 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 8 9 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 --3 GREGORY PAUL SARNA, M.D., after 4 having been first duly sworn, was 5 examined and testified as follows: 6 --7 BY MR. DuPONT: 8 Q. Good morning, Doctor. How are 9 you? 10 A. I'm doing well, thank you. 11 Q. My name is Andrew DuPont. You 12 understand I'm an attorney for David Gerchman 13 and Theresa Gerchman. Is that correct? 14 A. I understand that, yes. 15 Q. All right. And I know you have 16 given depositions before, so I'll briefly 17 review the format that we use here. I don't 18 know if you have done one by phone and a 19 little mobile hook up in the past, but for 20 that reason in particular, if I ask you a 21 question, sir, that you do not understand, 22 will you please let me know that? 23 A. Yes, I will. 24 Q. Can we have an agreement that 25 if you do answer a question that I ask you 10 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 it's because you have understood the question 3 and you have answered the question that I 4 asked? 5 A. Well, certainly I'll -- it will 6 be because I believe I understood the 7 question. If I have not understand the 8 question -- understood it, I expect that will 9 become evident subsequently. 10 Q. All right. If you -- well, I 11 need to understand, as we're going forward 12 today, that if you answer one of my questions 13 it's because you understood it. I won't have 14 the opportunity to re-ask my question based 15 on your claim that you didn't understand it 16 unless you tell me that. Do you understand 17 that? 18 A. Sure. I will answer your 19 questions as I understand them. 20 Q. All right. Will you agree to 21 answer my questions here today, as opposed to 22 giving information that I'm not asking for? 23 A. Oftentimes there are gray zones 24 in terms of answering questions, I try to be 25 complete and educate. I'll ask you to stop 11 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 me if you think I'm going off track. But 3 it's usually not black and white when an 4 answer stops and when explaining an answer 5 goes on. 6 Q. Okay. Have you reviewed your 7 Notice of Deposition? 8 A. I never got a Notice of 9 Deposition personally. 10 Q. Okay. Have you brought 11 documents with you here today? 12 A. I have six boxes of materials 13 and records that I reviewed behind me. I've 14 got a copy of my notes in front of me. I 15 have some copies of the billing e-mails in 16 front of me. And I have a pile of references 17 that are pertinent, although I don't have 18 every reference in my report, nor every 19 reference from your experts' depositions or 20 reports. 21 Q. Okay. Do you have with you the 22 references that you're relying upon for your 23 opinions in this case? 24 A. I have many to most of them. 25 There may be other ones that I don't have. I 12 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 would not limit myself to these. I generally 3 would say that these reinforce the body of 4 knowledge and will be able to give me precise 5 data in terms of that body of knowledge. But 6 I will be answering based upon my general 7 knowledge, not limited to these reports. 8 Q. Are you going to be able to 9 identify for me today, whether you have the 10 documents here or not, each study that you 11 relied upon for your opinion? 12 A. Probably, yes. I'll do my 13 best. 14 Q. So I understood you to say that 15 you have six boxes of materials that you 16 reviewed. Are those materials that you 17 received from the lawyers for the defendants 18 in this case? 19 A. Yes. That's what I'm talking 20 about, six boxes of material from the 21 lawyers, which include some disks as well as 22 paper. 23 Q. Okay. And you have, did I hear 24 you say, e-mails with billing information? 25 A. I have copies of that, yes. 13 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Did you bring your references? 3 A. I have my report and most of 4 the references referred to in my report in 5 front of me. And some that may not be in the 6 report that are relevant as well. 7 Q. Does that cover all the 8 documents you brought here with you today? 9 A. Pretty much. 10 Q. Do you have a copy of your CV 11 with you? 12 A. ^I did not bring a copy of my 13 CV. Certainly that can be e-mailed to you by 14 counsel or by myself. 15 Q. Okay. I have a copy that was 16 provided to me earlier in the case. The most 17 recent publication I see on it appears to be 18 an abstract, and it looks like it is dated 19 2011. The primary author was Jahanzeb, 20 ^J-A-H-A-N-Z-E-B? 21 A. That would be a current CV. 22 Q. So this CV that was provided to 23 me contains all of the publications that you 24 have authored or co-authored? 25 A. To my knowledge, yes. 14 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. I've seen where you testified 3 before that you have never published a 4 peer-reviewed article or a textbook chapter 5 concerning the causes of leukemia. Is that 6 still correct? 7 A. I have had peer-reviewed 8 articles on treatment of leukemia from my 9 early days from UCLA, but not on causes of 10 leukemia. 11 Q. And is it also correct that you 12 have never published on the subject of 13 benzene? 14 A. It depends, I suppose, upon 15 your definition of published. I presented 16 lectures at the benzene legal conferences and 17 there have been handouts that have material 18 from me. If that's a publication, then that 19 would count. I would not consider that a 20 publication, but I am bringing that up to be 21 complete. 22 Q. Okay. These were lectures at 23 benzene legal conferences, is that what you 24 said? 25 A. Yes. 15 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Which conferences were they? 3 A. They were a series of 4 conferences. One in -- first one maybe seven 5 years ago in, I think, Marina Del Mar. A 6 couple -- one was in Las Vegas. I'm blocking 7 the name of the law firm -- the firm that put 8 on the conferences, but I gave lectures on 9 lymphoma twice, on RARS^ once, and I think 10 MDS another time in general, although I'm not 11 positive of that. 12 Q. Have you spoken at Defense 13 Research Institute conferences? 14 A. Defense Research Institute? 15 No. 16 Q. I would like you to grab your 17 billing e-mails, if you could, and tell me 18 what period of time do they pertain to and 19 what is the total billed amount? 20 A. Not a billing e-mail, but you 21 probably will ask regardless, so I'll bring 22 it up proactively. The first communication I 23 have regarding this case was on April 26th, 24 in an e-mail from Mr. Skaar, Hogan Lovells, 25 saying that they are including medical 16 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 records for my review. And that was based 3 upon a phone call that day, and the medical 4 records were by e-mail. 5 Then there -- in terms of 6 billing, on May 4th there was a bill for 7 $7,375. On June 9th there was a bill for 8 $3,250. On July 4th, there was a bill for 9 $3,625. 10 Q. What is your billing rate for 11 the work that's reflected in those invoices? 12 A. $500 an hour. 13 Q. What is your rate for 14 deposition testimony? 15 A. Deposition testimony, at my 16 office in Cedars, is $600 an hour. Away from 17 my office is $1,000 an hour. 18 Q. And which rate are you charging 19 today? 20 A. I'm away from my office. 21 Q. All right. Is that something 22 new? 23 A. No. That was as of 2009, I 24 believe. 25 Q. So since 2009, you have charged 17 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 $1,000 an hour for a deposition away from 3 your office? 4 A. It's a hardship for me to leave 5 my office. I can't handle patient materials. 6 I have to cancel patients. I have travel 7 time. So all that is incorporated in the 8 increased rate. Generally people are 9 informed ahead of time of the difference in 10 rate, and if they wish to have it in my 11 office we accommodate. 12 Q. Okay. But that wasn't my 13 question. My question was, is it your 14 testimony that since 2009 you have charged 15 $1,000 per hour for depositions outside of 16 your office? 17 A. It's my testimony that I 18 recollect that, but that recollection may be 19 wrong. I don't have the date of the billing 20 sheet in front of me, so that may be an 21 error. But it's certainly been almost for 22 two years. 23 Q. All right. Let's go to your 24 references. I'm sorry, let's take your three 25 billing e-mails and mark them as Exhibit 1, 18 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 please. 3 --4 (Whereupon the documents were 5 marked, for identification purposes, 6 as Sarna Exhibit Number 1.) 7 --8 BY MR. DuPONT: 9 Q. And then I would like to take 10 your April 26, 2012, e-mail and mark that as 11 Exhibit 2, please. 12 - - 13 (Whereupon the document was 14 marked, for identification purposes, 15 as Sarna Exhibit Number 2.) 16 - - 17 BY MR. DuPONT: 18 Q. Do you call that your 19 engagement e-mail? 20 MR. THOMPSON: Is that what you 21 would call it, Doctor? 22 THE WITNESS: Probably not 23 engagement, but good enough. 24 BY MR. DuPONT: 25 Q. Do you have a separate 19 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 correspondence that's your engagement in this 3 case? 4 A. No. I just -- the term 5 engagement has many meanings, so I wouldn't 6 have chosen that term, but that's fine. 7 Q. Do you have any separate 8 correspondence that deals with your being 9 hired to work on this case? 10 A. No. 11 Q. Is April 26, 2012 the earliest 12 date of your work on this case? 13 A. Yes. 14 Q. Have you ever worked with Mr. 15 Barry Thompson's office before? 16 A. When he was at Reed Smith, yes. 17 Q. On how many occasions? 18 A. Frankly, I don't know. Part of 19 the issue is, often there are multiple 20 defendants who as a group have gone together. 21 And one of the lawyers may be a lead lawyer, 22 but there are many other firms involved and 23 lawyers involved. So I really don't have the 24 answer to that question. 25 Q. Your prior work with Barry 20 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Thompson and his office, has that been in 3 benzene litigation? 4 A. Yes. 5 Q. Am I correct that you never 6 testified on behalf of a plaintiff in benzene 7 litigation? 8 A. Not in a benzene litigation. 9 Q. Have you ever testified on 10 behalf of a plaintiff in any toxic tort 11 exposure case? 12 A. Yes. 13 Q. Which type of case was that? 14 A. Richard Burton versus one of 15 the tobacco companies. And I have been 16 retained and not testified in a case 17 regarding contaminated heparin. 18 Q. I'm sorry, contaminated? 19 A. Heparin. 20 Q. Did you provide a causation 21 opinion in the tobacco case? 22 A. I was a treating physician, but 23 I was also used for expert, and did provide a 24 causation opinion. 25 Q. Was it a specific causation 21 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 opinion? In other words, that your patient's 3 injury was caused by tobacco, or was it a 4 general causation opinion? 5 A. Both. 6 Q. Tobacco and how it causes 7 certain conditions? 8 A. Both specifically and general. 9 Q. How long have you been 10 testifying as an expert on behalf of 11 defendants in benzene litigation? 12 A. After the first benzene 13 conference, probably six or seven years ago, 14 I had my first benzene case, I think. So the 15 answer would be six or seven years. That may 16 be wrong, but that would be my best answer at 17 this time. 18 Q. Do you have a list of your 19 cases that you have testified in with you? 20 A. No. 21 Q. Do you have an up-to-date list 22 that you keep at your office or otherwise? 23 A. No. 24 Q. I'm sorry, I didn't hear your 25 response. 22 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. I have a list of depositions 3 and testimony and my cases for that. I don't 4 have a list of cases that I have been 5 retained in or consulted on. 6 Q. Can you provide that list of 7 depositions and testimony to your counsel, so 8 that we can mark that as Exhibit 3 please? 9 A. I will provide it at a later 10 date, yes. 11 - - 12 ^^(whereupon the document was 13 identified to be marked as Sarna 14 Exhibit Number 3.) 15 - - 16 BY MR. DuPONT: 17 Q. In how many cases per year have 18 you been retained by defendants in benzene 19 litigation in those six or seven years? 20 A. I haven't counted. Probably, 21 if I had to make a guesstimate, which is 22 better than a guess, but it's not necessarily 23 correct, it would be somewhere between four 24 and seven a year. 25 Q. And how much have you earned 23 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 per year in your work in benzene exposure 3 cases? 4 A. I haven't kept track of that. 5 Q. How much time have you spent on 6 this case from July 4th to the present? 7 A. May I see my exhibit -- first 8 exhibit of billing records, please? 9 Q. Yes. 10 MR. THOMPSON: Andrew, you're 11 talking about since that invoice was 12 issued. 13 MR. DuPONT: Yes, from July 4th, 14 2012 to the present. 15 THE WITNESS: I don't have that 16 figure in front of me. I expect it's 17 at least 25 to 30 hours, and maybe 18 more. 19 BY MR. DuPONT: 20 Q. So altogether you're looking at 21 about $30,000 billed from the time you were 22 engaged in this case to the start of your 23 deposition here today? 24 A. That probably is a fair rough 25 figure. It could be more or less. 24 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Is that an average amount that 3 you bill for your testimony on behalf of 4 defendants in benzene cases? 5 A. No. 6 Q. Is it more or less? 7 A. More. 8 Q. More? 9 A. More. 10 Q. How much have you typically 11 billed per case? 12 A. There isn't a typical, but some 13 cases are initial consult only, which is 14 $1,500. Some cases are quickly settled and 15 don't require reviewing six boxes of records. 16 Some cases require an extensive detailed 17 report. So it will vary tremendously. 18 A case that goes to court where 19 I have to testify in trial, and has a 30 or 20 40 or 50 page report, is going to be a lot 21 more expensive and a lot more work than a 22 case where I give an initial consultation and 23 nothing more. It all ranges between those. 24 Q. How many toxic tort exposure 25 cases do you handle on behalf of defendants 25 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 outside of the benzene litigation realm? 3 A. I haven't counted them. There 4 have been others. There have been three or 5 four ^hexavalent chromium cases. I can 6 recall a ^creosote case. There was an 7 asbestos case. That's probably five or six. 8 There may be some more, but that's five or 9 six over seven to 10 years. 10 Q. When did you begin to practice 11 medicine? 12 A. When did I begin to practice 13 medicine, was that the question? 14 Q. Yes, sir. 15 A. 1970 was my internship. So if 16 by practicing medicine you mean internship, 17 the answer is 1970. 18 Q. So in your 42 years of 19 practicing medicine, have you ever had a 20 patient which you have concluded contracted 21 leukemia as a result of exposure to benzene? 22 A. I don't recall such a patient. 23 Q. Have you ever had a patient 24 where you determined that their illness, no 25 matter what the type of illness was, was 26 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 caused by exposure to any chemical product? 3 A. Certainly I have seen patients 4 with mesothelioma and patients with lung 5 cancer, both of whose illnesses were related 6 to chemical products. 7 Furthermore, leukemics who 8 smoke may have been related to tobacco. 9 Tobacco is, behind chemotherapy and 10 radiation, the number one attributable cause 11 of acute myelogenous leukemia with a relative 12 risk of 1.3 or so. So I have certainly seen 13 heavy smokers who have had AML. And there 14 would have been a statistical possibility 15 that they were caused by chemicals. 16 Q. When you determined that these 17 individuals with leukemia who had been 18 smokers, that the cause of leukemia was 19 cigarette smoking, did you have any type of 20 quantification of how much of a ^leukemogen 21 they were exposed to? 22 A. I didn't determine whether it 23 was a cause or not in the individual cases. 24 The amount of exposure would only have been a 25 question of a history of how many pack years 27 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 of smoking. 3 Q. Have you ever had a patient 4 that you concluded they had a disease that 5 was caused by exposure to solvents? 6 A. I can't recall such. 7 Q. Have you ever conducted any 8 studies concerning the ability of benzene to 9 cause leukemia or any other hematopoietic 10 disease? 11 A. No. 12 Q. Have you ever been involved in 13 any epidemiology study? 14 A. I can't recall publishing one 15 as a first author. And if you mean -- well, 16 the answer to your question is no. Certainly 17 I have written chapters in books on a variety 18 of diseases where epidemiology is discussed. 19 So I have written on epidemiology, but I have 20 not been involved in a study. 21 Q. Have you written on the 22 epidemiology of benzene? 23 A. Generally one would talk about 24 the epidemiology of a disease rather than the 25 epidemiology of a chemical compound, but 28 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 taking the gist of your question and 3 answering that, the answer is, I have not 4 published on benzene's role as a leukemogen 5 or carcinogen or inducer of other 6 malignancies. 7 Q. Are there oncology and 8 hematology textbooks that you believe are 9 authoritative in your field? 10 A. Authoritative is a broad word. 11 Certainly the DaVita^ textbook is the 12 oncology textbook I would tend to use. And 13 there are a variety of hematologic textbooks 14 that are used. 15 The issue of authoritative is a 16 relative issue. In most chapters there are 17 things that may be clearly true and there may 18 be things that may be authors' opinions or 19 nebulous types of statements, particularly 20 dealing with epidemiology. So I do not in 21 general go to the textbooks of hematology and 22 oncology to answer epidemiology questions. 23 They're often useful to answer therapeutic -24 give information on therapeutic issues, but 25 even then the time -- 29 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Doctor, my question is, are 3 there any hematology textbooks that you 4 consider authoritative? 5 A. For what purpose? 6 Q. For any purpose. 7 A. Yes. ^daVita's Oncology 8 textbook is one that's authoritative for 9 guiding clinical practice. In hematology, 10 probably Williams and ^Winthrop are useful 11 textbooks. 12 Q. I have been provided with a 25 13 page report. Would you call this your -- a 14 25 page document? 15 A. It's a document. I wouldn't 16 call it a report, although it has aspects of 17 a report. If it were a report, it would have 18 been polished. It's not polished. It's a 19 stream of -20 Q. What can we refer to this as? 21 A. Notes with comments. 22 Q. Okay. Let's mark your notes 23 with comments as Exhibit 4, please. 24 - - 25 (Whereupon the document was 30 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 marked, for identification purposes, 3 as Sarna Exhibit Number 4.) 4 --5 BY MR. DuPONT: 6 Q. Have you ever been hired to 7 consult on issues concerning benzene causing 8 disease outside of the context of defending 9 defendants in litigation? 10 MR. THOMPSON: Do you understand 11 the question? 12 THE WITNESS: To my knowledge -13 may I have the question again, please? 14 BY MR. DuPONT: 15 Q. Have you ever been hired to 16 consult on the issue of benzene causing 17 disease outside the context of defending 18 corporations in benzene litigation? 19 MR. THOMPSON: If you agree with 20 that characterization. 21 THE WITNESS: Yes. I have been 22 hired for -- on Workmen's Comp cases 23 regarding benzene causing disease, 24 which is not the same as the -25 defending a corporation. But in 31 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 principle it's the issue of whether 3 benzene caused the disease. So the 4 strict answer to your question is, 5 yes. And the explanation is in 6 Workers' Compensation cases. 7 --8 (Discussion held off the 9 record.) 10 - - 11 BY MR. DuPONT: 12 Q. Doctor, you were discussing 13 Workers' Compensation being your total 14 Workers' Compensation matters. Was that 15 always on behalf of the defendants in the 16 Workers' Compensation matters? 17 A. Yes. 18 Q. Have you ever been retained by 19 a government agency or a non-government 20 agency, such as the World Health Organization 21 or IARC, to consult on matters of a chemical 22 causing a disease? 23 A. Yes. 24 Q. Yes? 25 A. Yes. 32 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. In what respect? 3 A. The United States government 4 asked me to consult on an issue of chemical 5 exposure at Camp ^LeJeune and I did so. 6 Q. And was the United States 7 government a defendant in that litigation 8 concerning chemical exposures at Camp 9 LeJeune? 10 A. I don't recall whether they 11 were a defendant or a potential defendant. I 12 consulted, I did not testify or provide 13 further information after consulting. 14 Q. When did that occur? 15 MR. THOMPSON: Did you say when? 16 MR. DuPONT: Yes. 17 THE WITNESS: Probably four 18 years ago, but I may be off. 19 BY MR. DuPONT: 20 Q. Is that the only work you have 21 done on behalf of a government agency or a 22 non-government agency that relates to the 23 issue of chemical exposure causing a disease? 24 A. To my knowledge, that's the 25 only government agency that I have worked 33 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 with in such a matter. 3 Q. Was it the Department of 4 Defense that hired you? 5 A. No. 6 Q. Which agency? 7 A. I'm not sure, but it wasn't the 8 Department of Defense. 9 Q. Do you have a file for your 10 correspondence in this case? 11 A. The billing information I have 12 given you. There have been a bunch of 13 e-mails saying, here are records, which I 14 have not given you. 15 Q. Do you have a list of all 16 documents you have received and reviewed in 17 this case? 18 A. No. 19 Q. How many articles have you 20 brought with you today? 21 A. Would you like me to count 22 them? 23 MR. THOMPSON: Maybe you can 24 estimate. 25 THE WITNESS: I'll count. A 34 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 quick estimate is 44, plus there are 3 some other things that are not 4 articles that are relevant. One is a 5 little thing on benzene toxicity 6 standards and regulations from ATSDR. 7 One is the letter that came out of Dr. 8 Shadduck's deposition from Shell. 9 Another is Dr. Harrison's addendum to 10 his deposition or report, whatever it 11 was, review of records and opinions. 12 BY MR. DuPONT: 13 Q. Okay. Are you qualified to 14 provide an opinion regarding industrial 15 hygiene? 16 A. Can you define industrial 17 hygiene? 18 Q. Do you consider yourself an 19 industrial hygienist? 20 A. No. 21 Q. Did you hear my question? 22 A. Yes. My answer was no. 23 Q. I'm sorry, I didn't hear your 24 response. 25 A. I'm sorry, I mumble at times. 35 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Are you qualified to provide an 3 opinion as an industrial hygienist? 4 A. Again, I need a definition as 5 to what sort of opinion. There are overlaps 6 in areas between a variety of disciplines. 7 And to the degree that they overlap in my 8 area of expertise the answer is, yes. But 9 I'm not making estimates of exposure, if 10 that's what you mean. Quantitative experts 11 -- I'm not making quantitative estimates of 12 exposure. Qualitative, yes. 13 Q. Okay. So to make sure I 14 understand, you're not qualified to provide a 15 quantitative exposure assessment? 16 A. Correct. 17 Q. Correct. Do you feel that you 18 could provide a qualitative exposure 19 assessment? 20 A. Yes. 21 Q. Do you feel that an 22 oncologist/hematologist can make an opinion 23 on benzene causing a disease, including AML, 24 make qualitative exposure assessment? 25 A. I think that's one portion -- 36 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 piece of information that goes into a 3 conclusion or decision. I don't think it's 4 the sum of information or the totality. I 5 think that it's part of the equation. 6 Q. If all you had was a 7 qualitative exposure assessment, could you 8 provide an opinion regarding benzene causing 9 a particular disease, including AML? 10 A. If that qualitative exposure is 11 minuscule, then the answer is yes. 12 Q. What do you consider minuscule? 13 A. That's a complex answer. I'm 14 not going to give you just a simple answer, 15 it will require discussion. Do you want 16 that? 17 Q. How do you define it? Do you 18 define it by years, do you define it -- how 19 do you qualitatively define minuscule 20 exposure? 21 A. Both in terms of the cumulative 22 exposure and in terms of the exposure on a 23 daily basis. Particularly relevant to me is 24 the exposure over the preceding ten years. 25 Q. How do you used the term 37 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 cumulative exposure on a qualitative basis? 3 A. You say there was a lot, there 4 was a little, there was minuscule, there was 5 something intermediate. You say that it is 6 contaminant level only, or you say that it is 7 more than that. You say that it is something 8 that according to the literature had very low 9 exposure, or something that according to the 10 literature has had high exposure. So those 11 are the types of things that one could do 12 qualitatively. 13 Q. When you say according to the 14 literature, do you feel that you're qualified 15 as a hematologist to look at the literature 16 on benzene exposed workers and compare that 17 to a worker and determine whether or not 18 their exposure was low or high? 19 A. The literature I'm familiar 20 with is both from the point of view of 21 measuring exposure, and I quote for you the 22 Scarselli and Williams articles as to 23 moderate exposure. And the literature as to 24 reverse engineering, the issue of exposure by 25 whether or not there is an increased risk of 38 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 leukemia in that profession. And I would 3 believe that I am qualified as a 4 hematologist/oncologist to look at that 5 literature and come to a conclusion. 6 Q. What's your opinion as to the 7 specific form of leukemia David Gerchman has 8 been diagnosed with? 9 A. Let me find my notes. The 10 broad diagnosis would be AML, or acute 11 myelogenous leukemia. The more specific by 12 FAB^ classification would M5B monocytic 13 leukemia. By World Health criteria it would 14 be AML not otherwise specified, subgroup 15 acute monoblastic and monocytic leukemia. 16 Q. Have you derived any opinions 17 on David Gerchman's life expectancy 18 considering his diagnosis with AML and his 19 medical course of treatment and progression 20 of his AML? 21 A. Yes. 22 Q. I'm sorry? 23 A. Yes. 24 Q. What is your opinion? 25 A. If one puts aside his current 39 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 condition, which I do not have up-to-date 3 information on, but if one puts that issue 4 aside and just deals with the issue of 5 prognosis for someone who has had a second 6 stem cell transplant from an unrelated donor 7 for acute myelogenous leukemia that has 8 relapsed after a first transplant, the 9 figures that his physicians support him have 10 been a 20 to 30 percent success rate and a 11 comparable risk of dying due to the 12 procedure, and I would agree with those 13 figures. 14 The information I most recently 15 had was that he was critically ill with 16 complications of severe graft versus host 17 disease, and that there was some concern 18 about whether he would survive the 19 hospitalization. If he has rallied and is 20 much better, that is one thing. If he has 21 continued critically ill, that is another. 22 Based upon the information I would have, my 23 expectation is that he would not survive and 24 not be cured. But certainly there would be 25 the possibility that he's improved, and both 40 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 the reality and my expectation would change 3 if I had such data. 4 Q. Do you have any opinions 5 concerning the appropriateness of the 6 treatment that was provided to David Gerchman 7 for his AML? 8 A. I'm sorry, was the question 9 opinion or concern? 10 Q. Do you have any opinion? 11 A. I think he was well treated. 12 Q. Do you have any concern? 13 A. No. 14 Q. I'm sorry, I did not hear your 15 response. 16 A. No, I have no concern. I 17 believe his treatment has been excellent. 18 Q. Okay. Do you have any opinion 19 as to what David Gerchman's life expectancy 20 was prior to the time he was diagnosed with 21 AML? 22 A. Not a formal opinion. 23 Q. Do you have an opinion? 24 A. He had obesity, which had 25 improved somewhat with treatment for obesity. 41 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 He had psoriasis. He was otherwise 3 reasonably healthy. He was at the time of 4 the diagnosis, I think, 51, if I recall 5 correctly. And the average life expectancy 6 for someone in good health at 51 is probably 7 to about 85. Morbid obesity would probably 8 lower that to about 75 to 80. He had a 9 history of smoking, but it was distant. So 10 probably if I had to opine at this point, off 11 the top of my head, it would have been a 25 12 to 30 year estimate of survival. 13 Q. Okay. Have you reviewed any 14 medical bills for David Gerchman's treatment? 15 A. I believe that I was sent in 16 the six boxes medical bills, but I frankly 17 did not review them. 18 Q. So you have no opinion as to 19 the reasonable and appropriate nature of 20 those charges? 21 A. I have an opinion, even though 22 I have not reviewed them. 23 MR. THOMPSON: Let's not put 24 your opinions out there on things you 25 have noT reviewed, Greg. 42 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 BY MR. DuPONT: 3 Q. What's your opinion? 4 A. That medical care in the United 5 States is too expensive. 6 Q. Do you have an opinion as to 7 the reasonable and appropriate nature of the 8 charges for David Gerchman's medical care? 9 A. I have the opinion that his 10 care was reasonable and appropriate. The 11 charges I have not looked at, other than 12 giving you my general statement about the 13 cost of healthcare in the United States. 14 Q. All right. So let's turn to 15 what your opinions are in this case. 16 Are all of your opinions 17 contained within your notes and observations 18 that were marked as Exhibit 4? 19 MR. THOMPSON: Notes and 20 comments. 21 MR. DuPONT: Notes and comments. 22 THE WITNESS: I expect that they 23 are. I will give you the caveat that 24 there's material that I have not seen 25 yet in terms of other people's reports 43 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 or depositions. And they may have 3 opinions that come as a result of 4 doing -- reviewing that material. So 5 if there is given further material, 6 either in terms of Mr. Gerchman's 7 clinical course or other people's 8 opinions or other people's reports or 9 other people's depositions, that may 10 require new work and may or may not 11 evoke new opinions. 12 BY MR. DuPONT: 13 Q. Where in your notes and 14 comments are your opinions set forth? 15 A. They're sort of scattered, but 16 let me say on page two there are opinions on 17 risk factors for AML. That's page two to 18 three. On page seven there's some comments 19 on exposure. And on seven, eight there's 20 comments on the risk of AML and leukemia in 21 general in mechanics. And on page nine 22 there's some information or discussion in 23 terms of chromosomal abnormalities. And 24 there's a summary of opinions on page 10. 25 Then there are other opinions buried in 44 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 review of Dr. Shadduck's deposition and Dr. 3 Harrison's handout. And also there's some 4 comments on Dr. Petty's and Dr. Williams' 5 assessments of exposure. 6 Q. What is your experience in 7 industrial hygiene? 8 A. I am not an industrial 9 hygienist. 10 Q. So do you have no experience in 11 industrial hygiene? 12 A. Hands-on experience, no. 13 Q. Any experience whatsoever, not 14 limited to hands-on experience. 15 A. No. 16 Q. All right. Do you have a pen 17 there? 18 A. Hold on. Yes, I do. 19 Q. I would like to number your own 20 opinions so that I'm not guessing on what is 21 and is not an opinion. So let's turn to page 22 two of the first page you indicated where you 23 have an opinion. 24 MR. THOMPSON: Andrew, Andrew, I 25 don't think that's going to cut it. 45 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Because as he's said, he's got 3 opinions scattered throughout the 4 thing. So I'm certainly not going to 5 want to limit him to only the ones he 6 just identified in a cursory manner by 7 leafing through the thing. I mean, we 8 can use that as a starting point. But 9 I'm just telling you now, this is the 10 -- as with the other experts, those 11 who have provided some kind of report 12 or notes or whatever, like Harrison 13 did, you know we had to go through and 14 kind of suss^ it out, and the same is 15 probably going to be the case here. 16 BY MR. DuPONT: 17 Q. All right. Well, let's start 18 on the first page. Do you have any opinions 19 on page one? 20 A. Page one is limited to the 21 clinical summary of what is going on. So 22 there are no opinions as to causation on page 23 one. 24 There is a statement relevant 25 to causation that his BMI when he weighed 46 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 290 pounds was 41.6, which would be morbidly 3 obese. And that on March 7th, which was -4 March 7, 2011, he weighed 220 pounds and was 5 still obese. Although with his bariatric 6 surgery he had lost 70 pounds over two years. 7 But he still was obese. 8 Q. Let me stop you there. Why 9 don't you point out for me in your report the 10 opinions that you hold that are relative to 11 causation? 12 MR. THOMPSON: Take your time, 13 Greg. 14 THE WITNESS: I believe that 15 obesity was a risk factor for him. I 16 do not believe that it was a direct 17 cause of his leukemia. But I quoted 18 data, two ^META analyses, one by 19 Larson and one by ^Castillo, both of 20 which show a risk of about 1.5 for AML 21 with obesity. So I believe that that 22 belongs in the discussion of causation 23 as a risk factor. 24 I also discussed the smoking 25 issue. I discussed that smoking, as I 47 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 mentioned before in my deposition, is 3 a risk factor for leukemia. But I 4 also said that given the lag time from 5 when he stopped smoking, I did not 6 believe it was a cause of Mr. 7 Gerchman's leukemia. 8 BY MR. DuPONT: 9 Q. Okay. Is your obesity opinion 10 set for on a particular page in your report? 11 A. Well, part of it is on page two 12 and there are parts elsewhere. Again, it's 13 not a report. 14 Q. All right. 15 A. In terms of the issues of 16 psoriasis, I have quoted data saying that it 17 is a risk factor. I do not consider it a 18 cause. Whether it is a risk factor, here it 19 is based on much less robust data than 20 obesity or tobacco. Here I just had two case 21 control studies with non-significant 22 increase. So I would not find that 23 compelling, but as part of the discussion. 24 I also discussed his age. His 25 age is not the average age of someone with 48 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 AML. But a third of the patients are less 3 than 54 years of age at diagnosis by ^SEIR 4 data, so it is certainly quite consistent 5 with de novo AML. De novo meaning without an 6 identifiable cause. 7 Then relevant to my opinion is, 8 I discussed on page seven that published data 9 on auto mechanics do not show high benzene 10 exposure. Putting aside the experts' 11 opinions in this case, talking about auto 12 mechanics in general, Scarselli from Italy 13 published a geometric mean exposure of 0.02 14 ppm benzene with an arithmatic mean of 0.05 15 ppm, based upon 234 measurements of time 16 weighted average exposure. 17 And Williams, which I didn't 18 quote in my report -- which I did quote in my 19 report, found TWAs, time weighted averages in 20 the breathing zone ranging from 0.01 to 0.3 21 with a variety of products that are present 22 since the seventies, late seventies; paint 23 solvents, printing solvents, inks, cutting 24 and coating oils, adhesives, mineral spirits, 25 degreasers and jet fuel. So that to me is a 49 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 relevant issue in terms of the discussion of 3 causation. 4 Q. What is your next opinion? 5 A. The next opinion is that 6 literature on mechanics show they do not have 7 an increased risk of leukemia and AML in 8 specifically. And I start with quoting the 9 review from 1997 by ^Houtz and Lowries. They 10 found 17 studies of AML at that time with 11 data from 1955 to 1991. The overall pattern 12 was negative. There were occasional studies 13 which suggest -14 Q. Doctor, let me cut you off. I 15 would like to review this in a little 16 different way by getting your opinions first 17 and then we'll go through the basis for them. 18 Okay? 19 A. Okay. Then do you want me to 20 tell you the other articles that support the 21 premise that mechanics in the reasonable 22 modern day are not at increased risk of 23 leukemia, or do you want to delay that till 24 later. 25 Q. We will get to that, but the 50 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 way I'm trying to organize this, I would like 3 to first ask what your opinions are. 4 MR. THOMPSON: So he wants to 5 round up all your opinions and then 6 he'll go back. 7 Andrew, is that what you have in 8 mind? 9 MR. DuPONT: I want the list of 10 opinions and then we'll go through the 11 basis for each of them. 12 THE WITNESS: Yes. So that 13 broad opinion is, mechanics in the 14 modern era are not at increased risk 15 for AML. 16 The next would be the presence 17 of the normal karyotype and the 18 absence of a karyotype which is 19 typical of benzene argues against AML 20 being caused by benzene. 21 Somewhere in here, and I'm not 22 sure where, would be the issue of what 23 I consider latency, but it -- the word 24 latency is used in different ways in 25 the literature, and I'm not defining 51 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 latency from the time of first 3 exposure to the time of development of 4 leukemia. In the first place, that 5 presupposes that exposure was the 6 cause. And then it presupposes that 7 if exposure were a cause, that it was 8 caused by the first drop of exposure 9 on the first day, both of which are 10 premises that I do not accept. 11 I would define latency, or one 12 may use the term lag time, as the time 13 from the causative occurrence of 14 leukemia till it is diagnosed. And 15 typically -16 BY MR. DuPONT: 17 Q. Doctor -18 A. I'm sorry. 19 Q. What is that time period, in 20 your opinion? 21 A. Based -- well, I won't give you 22 what it's based upon, I'll just give you the 23 opinion. The average would be four to five 24 years, and generally it would be 10 years or 25 less. 52 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 So the opinion would be, in 3 terms of Mr. Gerchman, that his leukemia 4 arose within the ten years -- likely within 5 the ten year frame prior to his diagnosis. 6 Now, I say arose rather than 7 use the word caused because it is not 8 necessary for there to be an external cause 9 of malignancy. We have spontaneous mutations 10 all the time, which certainly can cause 11 malignancy. And so I would not say -- use 12 the term when the leukemia was caused. I 13 would use the term when the leukemia arose 14 genetically. 15 Q. All right. What is your next 16 opinion? 17 MR. THOMPSON: Keep looking. 18 THE WITNESS: In terms of broad 19 opinions on causation that is all that 20 comes to mind. However, I do not want 21 to be limited to this. My report 22 should stand by itself, or my notes 23 should stand by themselves. And if I 24 -- there's a lot of information in 25 here. And some information that 53 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 doesn't fit under the umbrella as I 3 see it may still be relevant. So I do 4 not want to be restricted to only what 5 I just listed as opposed to what's in 6 my notes. 7 BY MR. DuPONT: 8 Q. Well, Doctor, I'm not going to 9 guess as to what your opinions are going to 10 be at the time of trial, and this is my 11 opportunity to ask you what your opinions 12 are. So if you have any opinions beyond 13 those, I think you've listed eight opinions, 14 could you tell me what they are? 15 MR. THOMPSON: Greg, I think the 16 only safe way to do this is for you to 17 literally go through and see where you 18 have an opinion beyond -- described 19 beyond what we have already talked 20 about. And if it takes a while, it's 21 okay. Go through each page and see if 22 there's anything you can add to these 23 eight -- I actually have nine, but it 24 kind of depends on how you write them 25 down. 54 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 So why don't we -- if you don't 3 mind, Andrew, why don't we go off the 4 record, and he can look at his report 5 and see if there's anything else. And 6 then he can update that list and let 7 you know if there's anything more. Is 8 that okay with you? 9 MR. DuPONT: Well, I would 10 prefer to stay on the record. 11 THE WITNESS: Well, could you 12 read back for me, or can the reporter 13 back to me what the list you have of 14 my opinions is? 15 BY MR. DuPONT: 16 Q. Well, I'll read what the list 17 is and then you can agree with me or not. 18 Number one, obesity, a risk 19 factor, but not a cause. 20 A. Go ahead. 21 Q. Agreed? 22 A. Yes. 23 Q. Do you agree with that? 24 A. Yes. 25 Q. Number two, smoking, a risk 55 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 factor, but not a cause of David Gerchman's 3 AML. Do you agree with that? 4 A. Yes. It's a cause of leukemia 5 in some cases, but not in this case. 6 Q. Okay. That's your second 7 opinion. Third opinion, psoriasis is a risk 8 factor for leukemia, but not a cause of David 9 Gerchman's AML? 10 A. Yes. 11 Q. Number four, David Gerchman's 12 age was not average. And by that I assume 13 you mean he was below average for the age of 14 being diagnosed with AML. And one-third of 15 the AMLs reported in the SEIR data are below 16 the age of 54? 17 A. Yes. So it's not average, but 18 it's well consistent with de novo AML. That 19 should be clear. But my point is that 20 there's nothing unusual about this age, even 21 though it's not average. 22 Q. Okay. And you agree that it's 23 below average, David Gerchman's age of 24 diagnosis with AML? 25 A. Very few people are going to 56 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 have the average. Half will be above and 3 half will be below. It's a median rather 4 than an average. And use the average -5 Q. Doctor, I asked you, was David 6 Gerchman's age at diagnosis below average? 7 MR. THOMPSON: Andrew, just let 8 him finish his answer, okay? And, 9 Greg, insist that you finish your 10 answer. 11 MR. DuPONT: Well, the Doctor 12 told me to cut him off if he was 13 rambling. 14 MR. THOMPSON: Well, I think he 15 had a different view of that than you 16 did. 17 BY MR. DuPONT: 18 Q. Okay. Fifth opinion, published 19 data on automotive mechanics in the modern 20 era do not show high benzene exposures. 21 Agreed? 22 A. Yes. 23 Q. That's your fifth opinion? 24 A. Yes. 25 Q. Sixth opinion, the literature 57 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 on mechanics do not show in the -- in the 3 modern era do not show an increased risk of 4 leukemia or AML? 5 A. I'm going to clarify that. Not 6 only do they not show an increased risk, they 7 show there is no increased risk. 8 Q. Okay. Your seventh opinion is 9 that the normal karyotype and absence of a 10 typical karyotype found in David Gerchman 11 argues against benzene as a cause of his AML? 12 A. Yes. 13 Q. Your eighth opinion is that the 14 -- on the subject of what some folks refer to 15 as latency, but you used a different term. 16 You would expect that the diagnosis of 17 leukemia would come within on average four to 18 five years and generally less than 10 years 19 of the date that the leukemia -- the date of 20 the causative event? 21 A. The date that the leukemia 22 arose with or without an extrinsic cause. 23 Q. Okay. So from point A, 24 leukemia arose, to point B, AML diagnosis 25 occurs within 10 years, average four to 58 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 five years? 3 A. Yes. 4 Q. Opinion number nine -- well, 5 that was -- okay. So that was your eighth 6 opinion. Okay? 7 A. Yes. 8 Q. And those were the opinions 9 that you have given me so far; correct? 10 A. Yes. Now if I may take some 11 time to look through this to see if there's 12 anything else that should be added. 13 MR. THOMPSON: You left out his 14 reference to spontaneous mutations. 15 He's going to be offering an opinion 16 on that too. 17 MR. DuPONT: Well, okay, if 18 that's your opinion, or the opinion 19 you want him to add, okay, but he 20 didn't say that. 21 MR. THOMPSON: Yeah, he said 22 that. If you want to look back on the 23 transcript we can do that. But he is 24 going to comment on whether 25 spontaneous mutation -- 59 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. DuPONT: I would like to 3 have the doctor provide his opinions. 4 MR. THOMPSON: He already did 5 provide that opinion. You may 6 disagree or maybe you didn't write it 7 down, but he did provide that opinion. 8 THE WITNESS: You may not have 9 caught it, but when I talked about the 10 lag time I said -- took care to say 11 whether the leukemia arose rather than 12 was caused. And I talked about 13 spontaneous mutations happening all 14 the time and being a cause of 15 malignancy without an external source. 16 BY MR. DuPONT: 17 Q. Okay. So do you have a ninth 18 opinion that AML can be caused by 19 spontaneously, or mutations, AML mutations? 20 A. Spontaneous mutation, yes. 21 Q. Now, you're going to look 22 through your report and tell me what your 23 10th opinion is. 24 A. Will do. 25 One of the issues that may not 60 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 have been implicit in the previous relative 3 to Mr. Gerchman was that his exposure was 4 qualitatively small over the ten years 5 preceding his diagnosis. 6 Another opinion that may not 7 have been clear is the issue of looking at 8 part per million year to try to determine 9 which group of benzene exposed people are at 10 increased risk of leukemia. And one uses 11 that metric to determine risk. I would say 12 40 to 60 part per million year would be the 13 low range for an increased risk. 14 The corollary to that statement 15 would be that low dose exposure in the two 16 part per million year range is not an 17 increased -- does not confer an increased 18 risk for leukemia de novo. 19 And then a minor point, but one 20 that would refer to Dr. Shadduck's opinions, 21 I would say that the fact that Mr. Gerchman's 22 sister did not have leukemia is irrelevant. 23 I'm hoping I'm not missing 24 anything. Again, my notes should stand for 25 themselves, but that's what I find in terms 61 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 of opinions. 3 MR. THOMPSON: Well, I'm going 4 to add a couple of topic areas that 5 we're going to ask you about because 6 this is kind of a weird process. 7 You're going to be asked whether 8 you agree or disagree with the general 9 and specific causation opinions of Dr. 10 Shadduck and Harrison. So now is the 11 time that you -- if Andrew wants to 12 ask you about that, he should ask you 13 about that. 14 We're also going to ask if you 15 have an opinion on whether the dose 16 that Mr. Gerchman had was sufficient 17 to induce AML and whether it did in 18 him. And whether you believe this was 19 a primary or secondary de novo or 20 secondary AML in Mr. Gerchman and 21 whether you have an opinion 22 concerning -23 MR. DuPONT: Well -24 MR. THOMPSON: Hey, I'm just 25 telling you, these are topic areas 62 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 he's going to be testifying about. 3 You asked what he's going to testify 4 about and I'm telling you. 5 MR. DuPONT: No. I asked what 6 his opinions are. 7 MR. THOMPSON: Excuse me? 8 MR. DuPONT: I asked what his 9 opinions are. 10 MR. THOMPSON: Right. 11 MR. DuPONT: And if he's told me 12 what his opinions are, then I need to 13 know that that's what his opinions 14 are. 15 MR. THOMPSON: Then ask him if 16 he has opinions on those topics 17 because he's going to be asked those 18 questions. I'm telling you, at the 19 time of trial he's going to be asked 20 those questions and he's prepared to 21 offer opinions on those things, all of 22 which are touched on in his report, 23 albeit he didn't spot them in the 10 24 minutes he had to review his 26 page 25 report just now. All of those things 63 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 are in there. So we told you at the 3 start that his report contains all the 4 information and opinions, either 5 direct or indirect, and they're all in 6 there. And I'm telling you now, 7 putting you on notice, those are going 8 to be topic areas he's going to cover. 9 So feel free to ask about them 10 or not, this is your shot. 11 BY MR. DuPONT: 12 Q. Doctor, do you have an opinion 13 after what you said regarding David 14 Gerchman's sister not having leukemia being 15 irrelevant? 16 A. I'm sorry, you want me to 17 elaborate on that statement? 18 Q. No. Do you have an opinion, in 19 addition to the opinions that you listed for 20 me? 21 A. I have opinions on all of the 22 issues that Mr. Thompson raised. 23 Q. Okay. What is your next 24 opinion then after David Gerchman's sister 25 not having leukemia is irrelevant? 64 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. THOMPSON: Let's go ahead 3 and have my response read back so that 4 Greg can tick those off and address 5 each one of those. 6 THE WITNESS: One by one, 7 please. 8 MR. DuPONT: Okay. So we'll 9 start with the lawyer opinions that 10 you're going to address? 11 MR. THOMPSON: Excuse me? Don't 12 answer that question, Greg. Greg, 13 don't answer that question. You can 14 re-ask your question if you want and 15 he'll be happy to answer a proper 16 question, but don't answer that, Greg. 17 BY MR. DuPONT: 18 Q. Okay. 19 MR. THOMPSON: Andrew, I know 20 you're not a California lawyer, and 21 you're getting to know the system and 22 you're a smart guy, you'll get it, but 23 the purpose of the deposition in 24 California is for him to disclose the 25 topic areas and his opinions. We 65 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 don't have reports out here, he told 3 you his notes -4 MR. DuPONT: I understand that 5 and I thank you for your discussion. 6 However -7 MR. THOMPSON: Don't suggest 8 that those are lawyer opinions. Those 9 are topic areas that he's going to 10 talk about. 11 BY MR. DuPONT: 12 Q. ^okay. What are the topic 13 areas that your counsel has indicated he 14 wants you to discuss that are not your 15 opinions here that you have listed so far? 16 MR. THOMPSON: Don't answer 17 that, Greg. Don't answer that 18 question. Go ahead ask a question. 19 And he'll -- if you give him a proper 20 question, he'll give you an answer. 21 BY MR. DuPONT: 22 Q. Have you listed all the 23 opinions you have? 24 A. I have opinions about the 25 issues that Mr. Thompson has raised. My 66 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 expectation is, should this come to trial, I 3 will be asked a variety of questions by both 4 yourself and Mr. Thompson, and unless there 5 is an objection to my answering the question 6 which is sustained, I will answer those 7 questions. The questions which he's raised 8 are relevant and I have opinions. Those 9 opinions are intrinsic to some of the 10 opinions and overlapping the opinions I've -11 Q. What are those opinions? 12 A. I would like a list one by one 13 of Mr. Thompson's comments, and I will give 14 you the opinions on those issues. 15 Q. Okay. What is the list of Mr. 16 Thompson's comments? 17 A. Can the court reporter give us 18 back? 19 - - 20 (Whereupon the court reporter 21 read back the pertinent testimony.) 22 - - 23 THE WITNESS: The first one was 24 whether I agree with the general and 25 specific causation of Dr. Shadduck and 67 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Dr. Harrison. And my answer is that I 3 do not believe in the general 4 causation belief that low level 5 exposures of benzene is the cause of 6 leukemia. And I do not believe in the 7 specific causation that Mr. Gerchman's 8 cause -- leukemia was caused by 9 benzene exposure. 10 BY MR. DuPONT: 11 Q. Okay. What is the next topic 12 that your attorney wants you to address? 13 MR. THOMPSON: I can just tell 14 you if you want me to. He's going to 15 be asked to address whether or not he 16 thinks the dose was sufficient in this 17 case to induce AML, and whether it did 18 in this person, Mr. Gerchman. 19 THE WITNESS: My belief is the 20 dose was not sufficient. As a matter 21 of conclusion based upon other 22 factors, the dose did not induce AML 23 in Mr. Gerchman. 24 BY MR. DuPONT: 25 Q. Okay. Are we done with your 68 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 opinions? 3 MR. THOMPSON: No, we're not. 4 THE WITNESS: Third issue? 5 MR. THOMPSON: You'll be asked 6 to describe and comment on de novo AML 7 generally and specifically. 8 THE WITNESS: De novo AML makes 9 up 80 percent of AML. It is usually a 10 normal ^karyotype, but not always. It 11 can arise as a spontaneous event. It 12 has been postulated by one author that 13 there are 10 to the 27th, which is a 14 huge number, spontaneous mutations 15 that occur in the lifetime. And that 16 spontaneous mutations cause far more 17 cancers than external events causing 18 mutations. And it should be no 19 surprise that we have spontaneous 20 mutations as they are a normal part of 21 evolution. They're the reason we are 22 not amoebae or chimaera^, because of 23 evolution. So these things occur and 24 are a common cause of malignancy. 25 MR. THOMPSON: And you will also 69 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 be asked whether that can be ruled in 3 or ruled out in Mr. Gerchman's case. 4 THE WITNESS: You can't rule it 5 in or rule it out specifically. 6 MR. THOMPSON: Okay. 7 MR. DuPONT: Now are we done? 8 MR. THOMPSON: That's all I can 9 think of right now. If I come up with 10 any other issues, I'll let you know 11 though before the deposition is done. 12 MR. DuPONT: Gee, thanks. 13 MR. CARR: And, for the record, 14 if it's in his report it's fair game 15 in our views. 16 MR. THOMPSON: Right. 17 MR. DuPONT: I would like to 18 know what his opinions are because 19 something can be in the report and not 20 be an opinion. 21 MR. CARR: Let me restate my 22 comment. If it's in his report and 23 admissible, we're reserving the right 24 to have him talk about it at trial. 25 MR. THOMPSON: Correct. 70 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. DuPONT: Okay. 3 BY MR. DuPONT: 4 Q. In terms of your opinions, have 5 we exhausted the list of your opinions in 6 this case? 7 A. To my knowledge, which is 8 sometimes imperfect, yes. 9 Q. All right. Let's start from 10 the top. Opinion number one, obesity is a 11 risk factor, but did not cause David 12 Gerchman's AML. You gave me two articles, 13 Larson and Castillo, that you cited as 14 supporting your opinion. And you said that 15 they indicate that there is a 1.5 risk of 16 leukemia from obesity. Is that correct? 17 A. Yes. Those are both two 18 different META analyses; one published 2008, 19 one published electronically this year. 20 Q. Which was 2008 and which was 21 this year? 22 A. ^Larson was in the 23 International Journal of Cancer, volume 122 24 pages 1418 through 1421, 2008. Castillo -25 Q. So Larson was 2008. And 71 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Castillo was 2011. 3 A. 2012. 4 Q. 2012. Is the cite for Castillo 5 contained in your report, or your notes and 6 comments? 7 A. The DOI is listed, and it's 8 available on the Internet. And it may or may 9 not be in the pile I have here. 10 Q. Okay. Are there any other 11 pieces of literature, publications, that you 12 rely upon for opinion one, obesity is a risk 13 factor, but not the cause of David Gerchman's 14 AML? 15 A. Those are the two that I pulled 16 because they're META analyses, they have more 17 weight than individual studies. There 18 certainly are other studies that are listed 19 in those META analyses, so this is not the 20 extent of the world's literature on that 21 issue. But I believe that one can get a 22 reasonable estimate of what the literature 23 says by looking at META analyses. And when 24 two of them give the same result, I expect 25 that that tells you something. 72 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. THOMPSON: Andrew, just to 3 clarify, Dr. Sarna will be asked 4 whether he can rule in or out obesity 5 as a contributing factor relative to 6 Mr. Gerchman. 7 MR. DuPONT: You know, I have a 8 concern that the doctor has stated his 9 opinion, and now there are comments 10 being made by counsel that are 11 intending to change that opinion. And 12 I don't think that's proper. 13 BY MR. DuPONT: 14 Q. So, Doctor, do you have the 15 Larson and Castillo articles that are your 16 literature references for your opinions that 17 obesity is a risk factor, but was not a cause 18 of David Gerchman's AML? 19 A. I'm sorry, what is the 20 question? 21 Q. Do you have with you your 22 articles that you rely upon as your 23 literature references for your opinion that 24 obesity is a risk factor, but not the cause 25 of David Gerchman's AML? 73 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. I'll need to look through the 3 pile to answer that question. 4 Yes. 5 Q. Let's mark those as the next 6 exhibit, which I believe to be Exhibit 5. 7 --8 (Whereupon the document was 9 marked, for identification purposes, 10 as Sarna Exhibit Number 5.) 11 - - 12 BY MR. DuPONT: 13 Q. Okay. Two, smoking is a risk 14 factor, but did not cause David Gerchman's 15 AML. What literature references did you rely 16 upon for that? 17 A. I'll need my report back, hold 18 on. There's one listed in my report and 19 there are three others that I brought with 20 me. 21 The one listed in my report is 22 by Doll, D-O-L-L, 2005. I have also brought 23 a report by ^Brownson. And a report by 24 ^Adame. And a report by Thomas. These are 25 all pertinent. The Adame one is not -- 74 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. The Adame one is not? 3 A. Just a second. I have to look 4 at that. 5 The Adame one is not a 6 causative study. The others I believe are. 7 Q. Okay. Are those all of the 8 literature references that you rely upon for 9 your opinion that smoking is a risk factor, 10 but did not cause David Gerchman's AML? 11 A. There are other articles that 12 talked about the risk disappearing later on. 13 And that's why I say that it was not a cause, 14 in addition to my opinion on lag time. I'm 15 not sure what those other articles are, but 16 I've seen them. 17 Q. Okay. Can you cite for me any 18 articles, other than the four that you 19 listed? 20 A. Let me see whether I have it 21 with me or not, or whether it's cited in 22 this. Hold on. 23 MR. THOMPSON: While he's 24 looking at that, Andrew, have you paid 25 any our experts yet? 75 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. DuPONT: We are getting 3 those checks ready and we're sending 4 them out. 5 MR. THOMPSON: When are they 6 going to be here? Because these guys 7 are supposed to be paid on the spot, 8 frankly. Like I did with your expert, 9 Dr. Shadduck and like we did with Dr. 10 Harrison. 11 MR. DuPONT: I understand that, 12 I apologize. 13 THE WITNESS: Okay. I've got 14 three other articles, although one of 15 them might be a duplicate. Let me see 16 whether it's a duplicate or not. No. 17 An article by ^King. An article by 18 Sandler. An article that's in the 19 pile, but not relevant because it 20 really talks about course of AML, not 21 the incidence. But it's in the pile, 22 by ^Chelghoum. 23 So do you want all of these 24 wrapped into an exhibit, or no? 25 BY MR. DuPONT: 76 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Yes, I would like to make that 3 our next exhibit. Thank you. 4 --5 (Whereupon the document was 6 marked, for identification purposes, 7 as Sarna Exhibit Number 6.) 8 --9 BY MR. DuPONT: 10 Q. Do you have an opinion on what 11 the relevant risk of AML specifically from 12 smoking is? 13 A. Yes. Approximately 1.3. 14 Q. Three, psoriasis is a risk 15 factor, but was not a cause of David 16 Gerchman's AML. What is your basis for that 17 opinion? 18 A. Well, I quoted in my notes the 19 article by ^Cooper and Soderburg, and there 20 was also an article I think by Zheng, if I'm 21 remembering correctly, that either Dr. 22 Shadduck or Dr. Harrison provided. Probably 23 Dr. Shadduck, but let me see what I have 24 here. 25 MR. THOMPSON: Andrew, this is 77 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 the last time I'll bring it up, but 3 when can we expect those checks for 4 the three experts? 5 MR. DuPONT: I don't have them 6 in my hand right now, but I will 7 confer with our accounting department. 8 MR. THOMPSON: Because I don't 9 think we're going to be able to 10 produce any more experts until we get 11 these three paid, because they're 12 supposed to be paid. 13 THE WITNESS: I don't have those 14 articles with me. Certainly the 15 references to the two that I noted 16 from Cooper and Soderburg are in my 17 notes. And I'll try to find you in a 18 moment which was the article quoted by 19 Dr. Shadduck that Dr. Harrison -- Dr. 20 Shadduck quoted an article by Zheng, 21 Z-H-E-N-G, which I believe is in 22 Cancer Causes Control, Volume Four, 23 page 361, 1993, which showed an odds 24 ratio for leukemia in Chinese people 25 with psoriasis of 5.5, based upon 10 78 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 cases. That's your expert's article. 3 I expect he could provide it for you, 4 but that's the reference. 5 BY MR. DuPONT: 6 Q. All right. Are those the two 7 references that you have for the issue of 8 psoriasis being a risk factor, but did not 9 cause David Gerchman's AML? 10 A. In the primary portion of my 11 report, meaning page two, I quote Cooper and 12 Soderburg. On page 19 I refer to Zheng. 13 Q. So those are the two articles 14 that you have cited for me -15 A. There are three articles that I 16 just mentioned. 17 Q. Okay. So Cooper and Soderburg 18 are two separate articles? 19 A. Correct. 20 Q. Do you have Cooper and 21 Soderburg with you here today? 22 A. No. 23 Q. Do you have any of the 24 psoriasis articles with you today? 25 A. None of those three. I have 79 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 other psoriasis articles which deal with the 3 issue of barrier and absorption. Which adds 4 another opinion. That is, the presence of 5 psoriasis did not increase dermal absorption 6 of benzene. And that -- that will be enough 7 for that. 8 Q. All right. Is it your opinion 9 that psoriasis is a risk factor for AML 10 specifically, or the general category of 11 leukemia? 12 A. It's my opinion that it may be 13 a risk factor for AML. I would not go so 14 strongly as to say it is a risk factor for 15 AML. 16 Q. Is it your opinion that 17 psoriasis is a risk factor of leukemia or it 18 may be a risk factor for leukemia? 19 A. May be. 20 Q. And when you say it may be a 21 risk factor for leukemia, AML, are you 22 indicating that you do not have any degree of 23 confidence that, in fact, it is a risk 24 factor? 25 A. There are two issues. One is 80 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 do people with psoriasis have an increased 3 risk of AML? And as for that, my answer is 4 there are the three studies that are quoted, 5 but they're not sufficiently robust to make 6 me conclude that it's real. It could be 7 real. 8 The second is, assuming that it 9 is real, which it may or may not be, does 10 that mean that the psoriasis is the cause, 11 because these people may have been treated 12 with Imuran^ or ^methotrexate, which could 13 have been the cause. Or in modern day, with 14 TNF inhibitors which could have been a cause 15 rather than the psoriasis. In which case 16 psoriasis is a risk factor, but the cause was 17 the therapy that was given. 18 Q. At this point you don't know 19 whether it's the medication taken by the 20 subject in those three studies or the 21 psoriasis in and of itself that resulted in 22 the increased risk of psoriasis that was 23 found -- I'm sorry, the increased risk of AML 24 that was found? 25 A. The data are too scanty for me 81 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 to reach a firm conclusion about whether 3 people with psoriasis are at risk for AML. 4 They may be, based upon the articles that 5 have been quoted. If they are, which may or 6 may not be the case, that may be related to 7 methotrexate, Imuran or other types of 8 issues, and that's not analyzed in these 9 studies. 10 Q. But as we sit here today, 11 you're not able to say whether the psoriasis 12 in and of itself or the medication that 13 resulted in increased risk in those three 14 studies? 15 A. In those three studies, I'm not 16 able to tell you that. 17 Q. Four, David Gerchman's age at 18 diagnosis with AML was below average, but in 19 your opinion was consistent with de novo AML? 20 MR. THOMPSON: Just make sure, 21 Greg, that these are the opinions that 22 you have. 23 THE WITNESS: Yes. Do you want 24 me to expand on that? 25 BY MR. DuPONT: 82 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. I'm going to ask you some 3 questions about that. First of all, what do 4 define de novo AML to be? 5 A. De novo is AML is AML without 6 an appreciable cause. 80 percent of AML in 7 the United States or so is de novo. The next 8 major cause would be chemotherapy and 9 radiation. 10 MR. THOMPSON: Just answer his 11 question as to de novo AML, Greg. 12 THE WITNESS: Okay. 13 BY MR. DuPONT: 14 Q. Your definition of de novo AML 15 is AML without an appreciable cause? 16 A. Correct. 17 Q. What do you mean by an 18 appreciable cause? 19 A. Without a cause that can be 20 identified as a cause. Let me try to clarify 21 that. There are people who are exposed to 22 benzene. Everyone in this room is exposed to 23 benzene. If you pump gas you have had higher 24 exposure than just by sitting in this room. 25 If there's not adequate exposure and not a 83 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 pattern of chromosomes that suggest benzene, 3 no reason to think that benzene is in the 4 discussion of such a situation for sitting in 5 this room or pumping gasoline for your car. 6 So there's no appreciable cause for leukemia 7 in that setting and that would be considered 8 de novo. 9 I think Martyn Smith, who is 10 often a plaintiff expert and has written a 11 variety of things, blaming benzene for a 12 variety of things, has in one of his articles 13 said that AML is 80 percent de novo. He says 14 one percent is due to benzene. I think that 15 figure is high because I think he's not 16 making the distinction between people who 17 said that they've never been exposed to 18 benzene and people who actually have a bona 19 fide benzene caused leukemia. This was not 20 always the case. Obviously in the time of 21 Vigliani and Aksoy^ and the CAPM study and 22 Rinsky's pliofilm study, there is much higher 23 exposure and benzene caused leukemia was more 24 frequent. And data from the sixties would 25 argue that perhaps at that time 15 percent of 84 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 studies could have been related to benzene. 3 But that was the data from the sixties, 4 that's not current situation. 5 Q. What are the studies in the 6 sixties, 15 percent of the AMLs were caused 7 by benzene exposure? 8 A. It's hard to determine that 9 because someone who's exposed may not have 10 been caused. But when I look at Mitelman's 11 chromosomal data, he had something like 12 20 percent of people had a history of 13 solvents. And some of those had normal 14 karyotypes and certainly not all of them were 15 caused. So that would be about 15 percent 16 from that figure. 17 MR. THOMPSON: Whenever you get 18 a chance, Andrew, I want to take a 19 break because we have been going for 20 about an hour and a half or more. 21 MR. DuPONT: Okay. Let me ask 22 one question, if that's all right with 23 you, Doctor. Or you tell me if you 24 prefer to take a break right away. 25 THE WITNESS: I'm okay, but 85 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 other people may need a break in the 3 room. 4 MR. THOMPSON: Go ahead, Andrew. 5 MR. DuPONT: Sorry, why don't we 6 go ahead and take a break. 7 --8 (Whereupon there was a recess in 9 the proceeding from 12:34 p.m. to 1:12 10 p.m.) 11 - - 12 MR. THOMPSON: Okay. 13 BY MR. DuPONT: 14 Q. All right, Doctor, did you have 15 your lunch? 16 A. Yes, I did, thank you. 17 Q. Good. All right. When we were 18 talking before the break, we were on the 19 issue of age of diagnosis being below average 20 for David Gerchman, but consistent with de 21 novo AML. That was your fourth opinion. 22 A. Yes. 23 Q. All right. Do you have any 24 literature references for the comment you 25 gave that less than one percent of AMLs are 86 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 caused by benzene exposure? 3 A. There's an article by Martyn 4 Smith, let me see if I can find the reference 5 to that, which says one percent. Where he 6 gets that figure is unclear. My expectation 7 is that's his estimate for benzene, people 8 who have had a history of some benzene 9 exposure. I don't believe that everybody who 10 claims they have pumped gasoline or have some 11 evidence of benzene exposure necessarily has 12 a benzene caused leukemia, so I think that 13 one percent figure is inflated. But that's 14 the figure I can find from the literature, 15 and what it's based upon is totally unclear. 16 Let me see if I can find you 17 the article. 18 I do not have a printout of the 19 article, but the reference is, "^Benzene, The 20 Exosome and Future Investigations of Leukemia 21 Etiology", published in ^Chembile 22 Interactions, Volume 192, pages 155 through 23 159, 2011. And that information is in Table 24 1. And where he gets that figure is totally 25 unclear to me. 87 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Is Martyn Smith the lead author 3 of that 2011 article? 4 A. Yes. 5 Q. And that's your only citation 6 for your comment that less than one percent 7 of AMLs are benzene induced? 8 A. My expectation in modern day is 9 that it's fewer than one percent. And while 10 I have given you Smith as something that says 11 one percent, and given you the caveat that I 12 think that's benzene associated, not benzene 13 caused. The other piece of information is 14 the lack of increased leukemia in benzene 15 exposed professions these days where they're 16 exposed to contaminant level of benzene. And 17 based upon that lack, I think that benzene 18 leukemia is quite rare these days, and would 19 estimate it to be less than one percent. 20 Q. And do those articles 21 concerning benzene exposed professions these 22 days tell you that less than one percent of 23 the AMLs that are diagnosed are associated 24 with benzene exposure? 25 A. They tell us that -- 88 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Do they give you that figure? 3 A. They don't tell you that 4 directly. They tell you that in these people 5 who worked with contaminant level benzene, 6 there is no increase in AML. 7 Q. And it's your interpretation of 8 those studies, therefore, that less than one 9 percent of AMLs diagnosed are associated with 10 benzene exposure? 11 A. If you assume that the people 12 who work with contaminant level benzene do 13 not get increased leukemia, then I would say 14 that they're not getting leukemia that's 15 caused by the contaminant level of benzene. 16 Whether there are pockets in the world that 17 still use benzene, high concentration, not 18 contaminant level, but pure benzene, 70 19 percent benzene, something like that, in 20 those areas there might be leukemia. I can't 21 speak to what's happening in parts of China, 22 but in the United States I don't think it's 23 an issue. 24 Q. Okay. So it's your opinion 25 that you can -- or your comment that you can 89 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 conclude that less than one percent of AMLs 3 are caused by, or associated with benzene 4 exposure these days is your interpretation of 5 the low dose benzene exposure studies. Those 6 studies don't specifically say that less than 7 one percent of AMLs are associated with 8 benzene exposure? 9 A. I think that's an inference you 10 can draw from that data. 11 Q. Okay. And it's your 12 interpretation, it's nothing that's set forth 13 or specifically stated in any of those 14 articles? 15 A. Correct. 16 Q. What is the average age of 17 diagnosis of AML in the United States? 18 A. I don't have the SEIR data in 19 front of me, but roughly 65 years of age. 20 Q. What percentage of AMLs are 21 diagnosed at age 51 or older? 22 A. Well, at age 54 or younger it's 23 about 30 percent. So 55 or older, which is 24 not what you asked, but what the SEIR data 25 suggests it would be, about 70 percent. 90 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Do you know the percentage for 3 51 and older? 4 A. No. 5 Q. Does every 6 oncologist/hematologist conduct exposure 7 assessment when a person with leukemia is 8 seen by them? 9 A. I don't think everybody does 10 anything, but I can't speak for other 11 oncologists. 12 Q. You don't know what percentage 13 of other oncologists conduct exposure 14 assessments when they diagnose or treat 15 somebody with leukemia? 16 A. I can't answer that question. 17 I don't know that. 18 Q. Does every oncologist and 19 hematologist know that solvents, such as 20 carburetor cleaners, brake cleaners, contain 21 benzene? 22 A. I don't know what other -23 every oncologist and hematologist knows. 24 Q. Is it generally known in your 25 field that brake cleaners and carburetor 91 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 cleaners and parts washing solvents contain 3 benzene? 4 A. I don't know whether that's 5 generally known in my field or not. 6 Q. Is it generally known in your 7 field that paints contain benzene? 8 A. I don't know whether it's 9 generally known. And I would wonder whether 10 you're talking about water based paints. 11 Q. Is it generally known that oil 12 based paints contain benzene? 13 A. I don't know what's generally 14 known in the oncologic community. 15 Q. Would you agree that amongst 16 the 80 percent of individuals that you say 17 are de novo leukemia, there's people whose 18 leukemia could have been caused by exposure 19 to benzene, but nobody investigated that? 20 A. I think the answer to that is 21 unknowable. If they're not investigated, I 22 have no data to answer that question. 23 Q. What are your references for 24 the statement that 80 percent of -- is it 80 25 percent of AML specifically, or leukemia 92 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 generally that you're saying are de novo? 3 A. AML. 4 Q. What are your literature 5 references for the position that 80 percent 6 of AMLs are de novo? And is that figure 7 limited to the United States or is this a 8 worldwide figure? 9 A. It's the Smith article that I 10 quoted. And I don't recall any restriction 11 on that table telling me whether it was 12 United States or world. 13 Q. Okay. So that's the 2011 14 Martyn Smith article, that's your basis for 15 the statement? 16 A. Yes. And I have told you that 17 I have no idea where he got that information. 18 That's not described. 19 Q. Okay. Let's go to your fifth 20 opinion. You say that published data on 21 automotive mechanics do not show high benzene 22 exposures. And you cited two articles for 23 me. The first was Scarselli. The second was 24 the other defense witness, Pamela Williams? 25 A. Yes. 93 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Is that correct? 3 A. Yes. 4 Q. Are those the only two 5 references that you rely upon for your 6 opinion that published data on automotive 7 mechanics do not show high benzene exposures? 8 A. Yes. 9 Q. And are those the only two 10 articles that you considered on that subject? 11 A. Yes. 12 Q. How did you come across those 13 articles? 14 A. PubMed, ^E-Med, electronic 15 record search. 16 Q. Do you have those two articles 17 with you? 18 A. I believe I do. Let me check. 19 Yes, I have them. 20 Q. Okay. Let's go ahead and mark 21 them as the next exhibit, please. 22 - - 23 (Whereupon the document was 24 marked, for identification purposes, 25 as Sarna Exhibit Number 7.) 94 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 --3 BY MR. DuPONT: 4 Q. Do those articles report the 5 amount of benzene exposure caused through 6 dermal contact with materials containing 7 benzene? 8 A. I'll have to look at the 9 articles. 10 (Reviewing articles.) 11 I don't see that dermal is 12 included in this. 13 Q. Okay. Have you ever studied a 14 group of mechanics specifically to determine 15 their risk of leukemia, or any other benzene 16 induced disease? 17 A. No. 18 Q. Can an oncologist/hematologist 19 derive an opinion on the ability of benzene 20 to cause cancer based upon their observations 21 of their patients over the course of treating 22 patients in their career? 23 A. People can derive opinions 24 based upon anything. The question is, what's 25 the validity of the opinion. 95 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Would you think it valid for an 3 oncologist/hematologist to say, I have seen 4 patients over my career and I have been able 5 to conclude that benzene is not a cause of 6 AML, or is not a prevalent cause of AML 7 because of what I have seen in my patients? 8 MR. THOMPSON: I'm sorry, could 9 we have that question back? I 10 couldn't hear the first part of it. 11 - - 12 (Whereupon the court reporter 13 read back the pertinent testimony.) 14 - - 15 THE WITNESS: I think someone 16 who has conducted a study of their 17 patients and recorded whether or not 18 -- made a list of the patients and 19 recorded whether or not there was any 20 history of benzene exposure and finds 21 no history of exposure can say in the 22 patient population that he or she 23 serves that that's not prevalent. The 24 ability to generalize from one patient 25 population to another may vary, 96 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 depending upon the details. 3 BY MR. DuPONT: 4 Q. Okay. If the doctor hasn't 5 recorded their findings in writing and 6 compared them to another group of non-exposed 7 or exposed individuals, would you think that 8 that is a valid thing to do? 9 MR. THOMPSON: Objection, 10 incomplete hypothetical. 11 THE WITNESS: Valid for what 12 purpose? 13 BY MR. DuPONT: 14 Q. Valid scientific basis for 15 drawing a conclusion as to whether or not 16 benzene causes AML in any one individual. 17 MR. THOMPSON: Same objection. 18 THE WITNESS: It would not be 19 valid to the point of publishable 20 paper. 21 ^MR. CARR: Andrew, this is 22 Chris. May we have an agreement that 23 an objection for one will be good for 24 all. 25 MR. DuPONT: Yes. 97 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. CARR: Will you agree that 3 that applies to the last two 4 objections made by Barry? 5 MR. DuPONT: Yes. 6 MR. CARR: Thank you. 7 BY MR. DuPONT: 8 Q. All right. If it's not the 9 type of opinion that you think is worthy to 10 be published, would you rely on that type of 11 opinion in providing an expert opinion in a 12 case? 13 MR. THOMPSON: Objection, vague 14 and ambiguous. Incomplete 15 hypothetical. 16 THE WITNESS: I have not cited 17 such data in my comments. So I have 18 not relied on such data. 19 BY MR. DuPONT: 20 Q. If you found that that type of 21 opinion would not be sufficiently valid to 22 publish in the literature, would you rely 23 upon it in reaching your opinions as to the 24 cause of an individual's AML as a defense 25 expert in benzene litigation? 98 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. THOMPSON: Objection. Same 3 objections. 4 Do you understand the question, 5 Dr. Sarna. 6 THE WITNESS: The cause of an 7 individual patient's AML would be best 8 judged by the details of the case 9 rather than on the basis of anecdotal 10 information about other patients. 11 BY MR. DuPONT: 12 Q. So you wouldn't rely on that 13 type of anecdotal information, as you 14 characterized it? 15 A. That would not be what I would 16 reach a decision based upon. 17 Q. Would you consider that at all 18 in your decision making process? 19 MR. THOMPSON: What do you mean 20 by "that"? 21 MR. DuPONT: The anecdotal 22 information that he characterized. 23 MR. THOMPSON: The anecdotal 24 information that an oncologist gathers 25 over the course of their practice? 99 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. DuPONT: Correct. 3 THE WITNESS: If leukemia doctor 4 A had said that when I practiced in 5 the fifties I used to see people who 6 not I attributed leukemia to benzene 7 frequently and I don't see it anymore. 8 That would be useful information to 9 me. It would not rise to the level of 10 published information which is 11 statistically analyzed and 12 peer-reviewed. But it would be useful 13 information, saying that there's been 14 a change in the doctor's practice. 15 That doctor had very large numbers 16 that he is seeing and that suggests a 17 change in the pattern of leukemia 18 etiology. That would be suggestive. 19 I wouldn't say it rises to the level 20 of proof, but it would be suggestive. 21 BY MR. DuPONT: 22 Q. Would you consider the bias of 23 that doctor in determining whether or not you 24 would rely upon the information? 25 MR. THOMPSON: Do you know what 100 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 he means by bias of the doctor? 3 THE WITNESS: I'm not sure why I 4 would ascribe bias to a physician 5 making such a conclusion. If I had 6 reason to ascribe bias, I would 7 consider it, but it's not clear to me 8 that a person -- a hypothetical person 9 making such a hypothetical claim would 10 have a bias. 11 BY MR. DuPONT: 12 Q. All right. Let's go to your 13 opinion number six. Literature on modern 14 mechanics do not show an increased risk of 15 leukemia or AML, they show no increased risk. 16 A. Yes. 17 Q. And you cited an article Hotz 18 and Lauwerys, H-O-T-Z and L-A-U-W-E-R-Y-S? 19 A. Yes. 20 Q. And that's a 1994 article? 21 A. 1997. 22 Q. '97, I'm sorry. I misread 23 that. 24 I'm looking at your opinion, 25 your page five -- excuse me, page eight 101 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 through nine of your notes and comments. And 3 this is a section where you address this 4 opinion. And there are -- the articles your 5 cite are Hotz and Lauwerys, McLean, it's 6 dated 2009. ^Costantini, dated 2001, Guo, 7 G-U-O, dated 2004, Ji, J-I, dated 2005, and 8 Pukkala, P-U-K-K-A-L-A, dated 2009. Are 9 those all of the references that you rely 10 upon for the opinions that the literature on 11 modern mechanics do not show an increased 12 risk of leukemia or AML, they show no 13 increased risk? 14 A. Yes. 15 Q. Let's gather those references, 16 all of your bases for that opinion, and mark 17 that as Exhibit 8. 18 - - 19 (Whereupon the document was 20 marked, for identification purposes, 21 as Sarna Exhibit Number 8.) 22 - - 23 THE WITNESS: I'll take a moment 24 to gather what I have. Hopefully I 25 have them all. I will tell you that I 102 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 did not printout the entire Pukkala 3 article because it's roughly a 150 4 pages. And I also printed out 5 material which was relevant that was 6 from the material on the Internet part 7 of the article, but an appendix or an 8 addendum to the article which was 9 relevant to AML. So of the pages that 10 I will provide are the pertinent 11 pages, but not all 150 pages, plus 12 everything else in the addendum. So 13 hold on, let me see what I can get. 14 Let me take another look I'm not 15 seeing McLean and Costantini. Maybe I 16 don't have them, but I'll take another 17 look. I have McLean. Okay. I have 18 them. 19 BY MR. DuPONT: 20 Q. All right. We'll mark those as 21 Exhibit 8. 22 Are those the articles that we 23 listed, and that are cited at pages eight and 24 nine of your notes and comments, all of the 25 articles you considered in forming this 103 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 opinion? 3 A. I have first cited Hotz, which 4 I have. I have next cited McLean, which I 5 have. I next cited Costantini, which I have. 6 I next cited Guo, which I have. I next cited 7 Ji, which I have. And then I cited Pukkala, 8 which I have the pertinent pages of. 9 Q. Okay. My question was, those 10 are all the articles that you considered in 11 forming this opinion that literature on 12 mechanics in the modern day do not show an 13 increased risk of leukemia or AML? 14 A. Correct. 15 Q. Do any of those articles set 16 forth the dose of exposure that mechanics 17 sustained, either on a cumulative basis or a 18 time weighted average? 19 A. To my recollection, no. 20 Q. Do those articles provide 21 details as to the type of personal protective 22 equipment that the mechanics that were the 23 subjects of these studies used? 24 A. To my knowledge, no. 25 Q. Do those articles provide 104 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 information as to the types of engineering 3 controls that were available and used by the 4 mechanics in the course of their work that 5 were the subjects of these studies? 6 A. May I hear that question again, 7 please? 8 Q. Sure. Do these articles that 9 you have cited and relied upon provide 10 information on the type of local exhaust or 11 other mechanical controls used by and around 12 the mechanics that were the subjects of these 13 studies? 14 A. No. 15 Q. Do these articles that you have 16 cited provide information on the brand names 17 of the products that were used by the 18 mechanics? 19 A. No. 20 Q. Do they provide information on 21 the categories of products used by the 22 mechanics? 23 A. To my knowledge, no. 24 Q. Opinion number seven, which 25 was, as you said, David Gerchman had a normal 105 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 karyotype and the absence of what you called 3 typical benzene induced karyotype, which 4 argues against benzene being the cause of his 5 AML. 6 MR. THOMPSON: If you said that, 7 Greg. Just listen carefully to what 8 he said. 9 THE WITNESS: Run that by me 10 again, please. 11 BY MR. DuPONT: 12 Q. Okay. David Gerchman had a 13 normal karyotype. And the absence of a 14 karyotype typical for someone exposed to 15 benzene argues against benzene being the 16 cause of his AML. 17 A. Both of those factors, which 18 are obviously interrelated, argue against it, 19 yes. 20 MR. THOMPSON: Just to make 21 clear, he read it differently the 22 second time, Greg, so you should pay 23 close attention. 24 THE WITNESS: Okay. 25 BY MR. DuPONT: 106 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Okay. What are the references 3 and bases for that opinion? 4 A. The reference that I think most 5 useful is an article by Mitelman. Let me 6 pull it. There are a variety of articles 7 that I haven't pulled based upon my general 8 knowledge. These include a whole series of 9 chromosomal abnormalities in normal people 10 exposed to benzene by Zheng's group up at 11 UCSF, as well in vitro studies on lymphocytes 12 and other studies with benzene metabolites by 13 that same group. 14 There are also a variety of 15 others, which I'll discuss, but let me give 16 you Mitelman first. 17 Mitelman is, "Chromosome 18 Pattern, Occupation, and Clinical Features in 19 Patients With Acute Nonlymphocytic Leukemia" 20 published in 1981 in "Cancer Genetics and 21 Cytogenetics." Do you want me to discuss 22 this, or did you just want that information? 23 Q. What I would like to do is 24 first get the list of the articles that 25 you're relying up, and then we'll have some 107 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 discussion about that. 3 A. I also found useful Dr. 4 Shadduck's literature by Dr. Smith, "Advances 5 in Understanding Benzene Health Effects and 6 Susceptibility", in reviews in advance of 7 "The Annual Review of Public Health". That 8 was useful as well. 9 But here I think there's a 10 broad area of literature that is generally 11 accepted that chromosomal abnormalities that 12 are benzene associated are benzene associated 13 to make a ^totalogy. And I have not quoted 14 every -- this is not a formal report, so I 15 have not gone to quote every article. The 16 Mitelman article, the Smith article was 17 supported in the broad sense, as well as the 18 body of work by Zheng and her group. 19 Q. That would be part of it. 20 So if you were to testify at 21 trial and you were asked what literature do 22 you rely upon for this opinion, your response 23 would be the Mitelman 1981 article, the 24 articles from Zheng and her group out of 25 University of California, Berkeley, and the 108 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Smith article cited by Dr. Shadduck? 3 A. And the variety of other 4 articles which don't come to mind 5 specifically at this time. 6 Q. All right. Can you cite me any 7 other articles that I can have an opportunity 8 to add -9 A. Off the top of my head, no. 10 MR. THOMPSON: Do those articles 11 you just cited have references in 12 them? 13 THE WITNESS: I expect they do. 14 Let me go on further -15 BY MR. DuPONT: 16 Q. Do you know -17 A. May I correct my answer to your 18 question? 19 Relating to the article by 20 Smith, there are articles that are pertinent 21 by Mauritzon, as one, and by a different 22 Smith, S. Smith, as opposed to Martyn Smith, 23 as another. And those I can provide you. 24 Q. Do you have those with you here 25 today? 109 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. I believe so. Let me get 3 those. 4 I can also give a reference by 5 Pedersen-Bjergaard as well. So, yes, I 6 pulled those as well. 7 Q. So then let's mark your 8 reliance materials, your articles for your 9 opinion on the normal karyotype in absence of 10 a karyotype typical for benzene exposure as 11 Exhibit 9. 12 - - 13 (Whereupon the articles were 14 marked, for identification purposes, 15 as Sarna Exhibit Number 9.) 16 - - 17 THE WITNESS: Let me also 18 clarify that I'm using those articles 19 to draw data. I'm not using articles 20 to quote statements. 21 BY MR. DuPONT: 22 Q. Okay. Well, do any of those 23 articles make the conclusion that the absence 24 of an abnormal karyotype excludes benzene as 25 a cause of AML? 110 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. Not specifically, no. 3 Q. Is there any author you can 4 cite for the proposition and the conclusion 5 that the absence of an abnormal karyotype 6 excludes benzene as the cause of AML? 7 A. Absolutely excludes it, no. 8 Argues against it, there's an article, and 9 I'm sorry I'm blocking the author, something, 10 a physician's view of AML, something like, a 11 fellow who published on ^RARS as well, that 12 argued about the chromosomal abnormalities, 13 as I recall. And I'm sorry, I'm blocking his 14 name. 15 Q. Would that be ^Ethan Natelson, 16 one of the other defense experts in this 17 case? 18 A. This would be Dr. Natelson, 19 yes. 20 Q. Are you able to cite me any 21 other articles, besides the one from Dr. 22 Natelson, who has also been hired by 23 defendants in this case? 24 MR. THOMPSON: Do you know if 25 Dr. Natelson has been hired by the 111 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 defense, as he says? Do you know 3 anything about that, Dr. Sarna? 4 THE WITNESS: This is the first 5 I have ever heard of it. 6 MR. THOMPSON: So just ask him a 7 question that he knows all the 8 information for and he'll be happy to 9 answer it. 10 MR. DuPONT: I'll ask him a 11 question as I see fit. 12 MR. THOMPSON: Okay. Hold on a 13 sec. Greg, if there is any part of 14 what he puts into his question that 15 you don't have information for, stop 16 him and either ask for it or ask for 17 clarification. Because he just told 18 you he's going to ask you misleading 19 questions, basically. So I'm just 20 telling you now, make sure that if he 21 puts something in the question you 22 either know it or don't know it or 23 stop him. 24 BY MR. DuPONT: 25 Q. Dr. Sarna, following your 112 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 attorney's instructions on how you can answer 3 questions, can you tell me -4 MR. THOMPSON: Don't answer that 5 question, Greg. With that preference, 6 don't answer that question. Wait 7 until he asks a standalone question. 8 BY MR. DuPONT: 9 Q. Can you cite for me any 10 article, beyond the one you cited by Ethan 11 Natelson, who has been hired by the 12 defendants in this case, which you claim 13 argues against benzene exposure being the 14 cause of AML if there is an absence of an 15 abnormal karyotype? 16 A. The data from the -17 MR. THOMPSON: Objection, 18 assumes facts not in evidence. Calls 19 for speculation by this witness. And 20 please listen to my instruction, Dr. 21 Sarna. If he puts stuff in there that 22 you don't have information about, you 23 have to tell him or he's going to 24 assume you agree with him. 25 THE WITNESS: May I have the 113 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 question again, please? 3 --4 (Whereupon the court reporter 5 read back the pertinent testimony.) 6 --7 THE WITNESS: The data from the 8 articles that I have previously 9 discussed, as well as data from 10 articles which I don't have with me, 11 argue against it. 12 BY MR. DuPONT: 13 Q. My question though is about the 14 conclusion actually drawn by the author of 15 the study. And can you cite for me an 16 article where the author has drawn a 17 conclusion that the absence of an abnormal 18 karyotype argues against benzene being the 19 cause of the AML, other than the one by Ethan 20 Natelson, who has been hired as a defendant 21 in this case? 22 MR. THOMPSON: Same objections. 23 THE WITNESS: There may or may 24 not be such an article, but I can't 25 cite one at this time. 114 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 BY MR. DuPONT: 3 Q. All right. Let's talk about 4 the Mitelman 1991 article. 5 A. May I have that back, please? 6 MR. THOMPSON: '81. 7 BY MR. DuPONT: 8 Q. Excuse me, '81. 9 A. Mitelman is 1981. Go ahead. 10 Q. Did that article -- first of 11 all, does that relate to the individuals that 12 have been diagnosed with AML? 13 A. This results with individuals 14 who have been diagnosed with what is termed 15 acute nonlymphocytic leukemia, which would 16 generally be AML. 17 Q. Okay. What are the findings of 18 that study? 19 A. They looked at the chromosome 20 genetics, meaning karyotype, on 110 subjects 21 with no history of exposure to solvents or 22 pesticides or petrol products. Of these 110, 23 75 had normal karyotypes. They also looked 24 at, it looks like 28 -- 27 subjects who had a 25 history of solvent exposure. 115 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Now, these people were from the 3 seventies, '72 through '70 -- from the early 4 seventies, it appears. And likely their 5 exposure was in the fifties, sixties and 6 seventies, but it's not detailed. But it's 7 reasonable to assume that the exposure was in 8 that period of time. 9 Of the 27 subjects who were 10 solvent exposed, three had normal karyotypes. 11 So there is quite a difference there. 24 of 12 27 had abnormal karyotypes, as opposed to I 13 think it was like 30 percent or so of the 14 people who were not exposed, which is a 15 rather dramatic difference. When you look at 16 the karyotype abnormalities, they tend to 17 have repetitive themes; minus five, 5q minus, 18 minus seven, 7q minus. To some degree 19 trisomy 8, and complex karyotypes meaning 20 three or more different abnormalities. 21 Those types of abnormalities 22 have also been seen in the in vitro studies 23 and the normal exposed without leukemia 24 studies by Zheng, and have also been seen in 25 the alkylating agent associated leukemias 116 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 that are a subset of the therapy related 3 leukemias. 4 One of your experts, I think 5 Shadduck -6 MR. THOMPSON: Greg, he just 7 asked what the findings were. 8 THE WITNESS: Fine. 9 BY MR. DuPONT: 10 Q. Is there anything that you 11 wanted to add? 12 A. That will do it. 13 Q. All right. So it's your 14 opinion that the subjects in Mitelman were 15 benzene exposed workers? 16 A. They were described as solvent 17 exposed workers, and their professions were 18 listed and they varied. Metal industry 19 worker, chemical industry worker, machine 20 cleaner, bookbinder, printer, painter, 21 firemen, et cetera. There were a variety of 22 different ones. And, again, these were 23 people who were living in a different era 24 when there was more benzene exposure than 25 there is in the modern era. 117 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Well, the articles state that 3 they were benzene exposed workers. 4 A. The article states they were 5 solvent exposed workers. 6 Q. All right. And does the 7 article provide data to establish that the 8 workers had benzene exposure? 9 A. It lists their professions, it 10 does not go beyond that. 11 Q. Have you seen any data outside 12 of this article that establishes whether 13 these subjects had exposure to benzene? In 14 other words, data for these subjects in this 15 study? 16 A. No. 17 Q. And it's your assumption that 18 they did have benzene exposure? 19 A. Given the chromosomal pattern 20 being so different in this group than the 21 chromosomal pattern in the nonexposed group, 22 I am assuming that a substantial number of 23 them had benzene exposure and benzene 24 associated leukemia. Not necessarily all of 25 them. In fact, there were I think three 118 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 normal karyotypes in this group. And perhaps 3 those three did not have benzene associated 4 leukemia -- benzene caused leukemia. But I 5 think there is a dramatic difference in 6 karyotype, which tells me that something is 7 different between these two. And what I'm 8 told is different is solvents. 9 Q. Do you know, does that article 10 or any other article on these workers tell us 11 the time period during which -- in other 12 words, the latency period or the period prior 13 to diagnosis with AML that these individuals 14 had exposure? 15 A. The timeframe of exposure is 16 not defined. 17 Q. All right. Let's go to the 18 next article that you have with you, what is 19 that? The next article in Exhibit 9 would be 20 normal karyotype, absence of the karyotype 21 typical for benzene exposure. 22 A. May I have Exhibit 9 back. 23 The article by Mauritzson, 24 M-A-U-R-I-T-Z-S-O-N, published in Leukemia, 25 2002. 119 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. All right. Does that article 3 address individuals who have been diagnosed 4 with AML? 5 A. Yes. And myelodysplasia as 6 well. 7 Q. What are the findings of that 8 article? 9 A. They looked at the chromosomal 10 abnormalities in people with de novo AML and 11 de novo MDS, and compared it with those who 12 had treatment related AML and treatment 13 related MDS. And they found that chromosomal 14 abnormalities in treatment AML and in 15 treatment MDS was much more frequent than in 16 de novo. 17 Q. And these were not benzene 18 exposed individuals? 19 A. No, these were treatment 20 related. 21 Q. Do we know exactly how benzene 22 causes AML? 23 A. No. 24 Q. Do we know exactly how 25 chemotherapeutic agents cause AML? 120 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. For both of these questions the 3 answer is no, but we do know that the process 4 commonly with both of these, if you're 5 talking about alkylating agents as 6 chemotherapy, involves abnormalities of 5 and 7 7, with partial deletions or full deletions 8 as a critical event. 9 Q. Do we know exactly how 10 alkylating agents cause partial or full 11 deletions of the fifth and seventh 12 chromosome? 13 A. Well, they alkylate DNA, but 14 beyond that I don't have a specific answer. 15 Q. All right. What's the next 16 article you have in your pile that's marked 17 as Exhibit Number 9? 18 A. Sonali Smith, 19 "Clinical-cytogenetic associations in 306 20 patients with therapy-related myelodysplasia 21 and myeloid leukemia: The University of 22 Chicago series." 23 Q. What's the date of that 24 article? 25 A. 2003. 121 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. This is another study of 3 therapy related, in other words, chemotherapy 4 caused AML and MDS? 5 A. Yes. 6 Q. It's not a study of benzene 7 exposed workers? 8 A. Correct. 9 Q. What do you take from this 10 article? 11 A. Because of the same chromosomal 12 pattern, because both benzene leukemia and 13 alkylating leukemia commonly involves 14 pre-existing MDS, I take it that alkylating 15 agent induced chemotherapy and 16 treatment-related chemotherapy in general, 17 although I would separate out the Topo II 18 inhibitors because that doesn't fit, but 19 putting that issue aside, it is a reasonable 20 model for benzene. They have the same 21 chromosomal abnormalities and they seem to 22 have the same frequency of myelodysplasia 23 beforehand, both caused myelodysplasia and 24 AML, in contradistinction to the Topo 25 inhibitors. So I think this is a valid 122 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 model. And as a valid model I think that it 3 is appropriate to look at it and understand 4 the difference in chromosomal patterns. 5 Q. Has there been any epidemiology 6 study that has used chromosome damage as a 7 basis for determining whether benzene 8 exposure was or was not the cause of AML? 9 MR. THOMPSON: Objection, form, 10 foundation. Do you understand the 11 question? 12 THE WITNESS: There are the 13 types of studies by Mitelman which 14 point to it, but that is looking at 15 solvent exposed first, rather than 16 looking backwards and then seeing if 17 there's a history of solvents. So the 18 answer to the question I have is no. 19 BY MR. DuPONT: 20 Q. Has there been any government 21 or non-government agencies that have 22 concluded that the presence of chromosome 23 damage for an abnormal karyotype is necessary 24 to draw a causal association between benzene 25 exposure and AML in an individual? 123 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. I'm unaware of any such 3 occurrence. 4 Q. What's the next article that 5 you have in Exhibit 9? 6 A. Dr. Shadduck's Exhibit 12 I 7 think it was, by Martyn Smith, "Advances in 8 Understanding Benzene Health Effects and 9 Susceptibility." 10 Q. What do you take from that 11 article? 12 A. Dr. Shadduck took from that 13 article that -14 Q. Sir, I didn't ask you about Dr. 15 Shadduck took, I asked what you took from 16 that article. 17 MR. THOMPSON: Greg, go ahead 18 and answer it however you want. 19 THE WITNESS: Dr. Shadduck took 20 from that article that you could see 21 the same type of chromosomal 22 abnormalities in benzene related and 23 unrelated cases based upon Smith's use 24 of treatment related therapy. I take 25 from it that treatment related therapy 124 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 is a valid model, just as Dr. Shadduck 3 apparently accepted from Dr. Smith. 4 But my take on it is that you look at 5 the frequency, not whether it shows up 6 ever. And there is a marked 7 difference in frequency from the data 8 that I have shown you. 9 BY MR. DuPONT: 10 Q. Okay. So I'm going to ask the 11 question again because my question is what do 12 you take from it? What do you take from this 13 article? 14 A. My take is that there are 15 differences in frequency between the 5, 7 and 16 8 abnormalities. I also take from it that 17 Dr. Smith believes, based upon the models 18 that he uses, which are labeled in Figure 1 19 through 8, that benzene causes leukemia 20 through chromosomal abnormalities of 5 and 7 21 particularly. And that de novo cases 22 typically have a normal karyotype. 23 If you look at his Figure 1, he 24 has alkylating agents and he says benzene 25 works along with fast life, which is loss of 125 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 7, deletion 7q, loss of 5, deletion 5q, and 3 then at the bottom he has de novo cases which 4 are listed as de novo, meaning no cause. So 5 they start with the normal karyotype. 6 Q. Do you consider Dr. Smith's 7 opinions authoritative? 8 A. These particular opinions, yes. 9 There are other opinions he's had that I have 10 disagreement with. 11 Q. Because they don't favor your 12 side of the case? 13 MR. THOMPSON: Objection. 14 THE WITNESS: Because I have 15 looked at his opinions and the data on 16 which they're based and I find they're 17 fallacious. 18 BY MR. DuPONT: 19 Q. What opinions would those be? 20 MR. THOMPSON: Are we talking 21 about an AML case or are we talking 22 about an NHL case, or something else? 23 MR. DuPONT: I don't know, the 24 doctor can answer my question. 25 THE WITNESS: He's published a 126 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Meta-analysis on lymphoma, or what 3 he's called a Meta-analysis. The 4 first part of that is a listing of 5 anecdotal positive odds ratios out of 6 studies. These include studies that 7 may have 10 different odds ratios, 8 some of which are positive, some of 9 which are negative. 10 When you look case by case at 11 the studies that he calls positive and 12 look at the breadth of what the 13 conclusion is, which I have done for 14 either the first five or 10 cases that 15 he cites, they don't, in my judgment, 16 support the concept. 17 I think you can cherry pick 18 positive results or negative results 19 and cherry picking is not the way to 20 reach a conclusion. 21 The second part of that article 22 deals with cohort studies. He agrees 23 that the cohort studies don't show an 24 increase in lymphoma, but attributes 25 this to a healthy worker effect. In 127 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 my judgment, healthy worker effect 3 does not decrease the risk of 4 lymphoma. A healthy worker effect is 5 largely due to people who have smoking 6 and other types of problems being 7 excluded and I don't -8 BY MR. DuPONT: 9 Q. All right. Let's move beyond 10 the Smith article and now let's talk about -11 MR. THOMPSON: Hold on. You're 12 the one who -13 BY MR. DuPONT: 14 Q. I want other opinions that 15 Smith has that you disagree with. 16 MR. THOMPSON: Say that again? 17 He's not done with his answer. 18 BY MR. DuPONT: 19 Q. I said, let's move beyond the 20 Smith article and the Meta-analysis on 21 non-Hodgkin's lymphoma and ask, are there 22 other opinions that Smith holds that you 23 disagree with? 24 MR. CARR: No, I'm going to ask 25 that you withdraw the question, if 128 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 that's what you want to do. Because 3 we're not on the video record, the 4 record would reflect that he's been 5 interrupted and cut off before his 6 answer is complete. So the record is 7 going to look like that's all he had 8 to say, and it's not. So I think you 9 either need to withdraw the question 10 or do something else other than cut 11 him off and tell him to do something 12 else. 13 MR. DuPONT: Well, I would like 14 to move beyond the Smith article and 15 the Meta-analysis of NHL. Because 16 when I asked him what opinions he had, 17 I didn't ask him for a dissertation on 18 this one article. 19 MR. CARR: You asked him -20 BY MR. DuPONT: 21 Q. Doctor, what opinions did Dr. 22 Smith hold that you disagree with beyond his 23 conclusions and his analysis in the 24 Meta-analysis -25 MR. CARR: Andrew, I'm okay with 129 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 that, so long as you make the record 3 clear that you stopped him in his last 4 answer. 5 THE WITNESS: I did not expect 6 to be asked about Dr. Smith's opinions 7 in other areas. 8 MR. THOMPSON: Hang on a second, 9 Dr. Sarna. Andrew, can you make clear 10 on the record that you stopped his 11 last answer and you're now moving on? 12 BY MR. DuPONT: 13 Q. I want like to ask Dr. Sarna 14 about opinions that Dr. Smith holds beyond 15 the subject of the NHL Meta-analysis article. 16 MR. CARR: And would you agree 17 that he was answering that question 18 and you stopped him? 19 MR. DuPONT: As he advised that 20 I should do. 21 MR. CARR: That's a yes, right? 22 You stopped him before he was 23 finished. 24 MR. DuPONT: I stopped him 25 before he was finished because he was 130 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 going off on a tangent that had 3 nothing to do with the question. 4 MR. THOMPSON: Okay. So, no, we 5 don't have an agreement now. Andrew, 6 remember, I warned you at the start of 7 your question if you really wanted to 8 answer this. So now we've gone on for 9 five minutes on something that I 10 prepared you for. 11 MR. DuPONT: Barry, would you 12 please stop it. 13 MR. THOMPSON: Stop what? 14 BY MR. DuPONT: 15 Q. What opinions, beyond Dr. 16 Smith's non-Hodgkin's lymphoma Meta-analysis 17 that he holds, do you disagree with? 18 MR. THOMPSON: If you formed 19 those opinions at that present time. 20 Because we haven't asked you to look 21 at those. 22 THE WITNESS: I disagree with 23 his participation in the ^Stimus 24 article. But I'm not prepared to 25 discuss those areas of disagreement 131 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 today as it was not part of my charge. 3 In terms of other areas, there 4 may or may not other areas of 5 disagreement, I have not looked into 6 that. It was not expected to be part 7 of my charge, I'm not prepared to give 8 you an answer to that today. 9 BY MR. DuPONT: 10 Q. All right. What's the next 11 article in your pile of Exhibit 9? 12 A. Pedersen-Bjergaard, "Genetics 13 of therapy-related myelodysplasia and acute 14 myeloid leukemia" talks again about 5q minus 15 and 5 minus, 7q minus and 7 minus in 16 treatment related AML and MDS. 17 Q. Again, these are not benzene 18 exposed workers? 19 A. Correct. 20 Q. Does that exhaust the list of 21 articles that you have with you here today on 22 the subject -- that we have attached as 23 Exhibit 9, the subject of the normal 24 karyotype and absence of an abnormal 25 karyotype typical for benzene exposure? 132 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. I believe so, but it's 3 conceivable that I missed an article in my 4 pile. 5 Q. Well, I would like to make sure 6 we have everything. So why don't you take a 7 look and see if you missed anything. 8 A. Okay. That appears to be all. 9 Q. Doctor, your next opinion is 10 number eight on the latency issue, which I 11 understand you used a different word than 12 latency. Your opinion that AML arises 13 generally within ten years, on average four 14 to five years prior to diagnosis of AML. 15 Correct? 16 MR. THOMPSON: Do you agree with 17 that restatement of your opinions? 18 THE WITNESS: Say it again, 19 please? 20 BY MR. DuPONT: 21 Q. The time that AML arises from a 22 causative exposure is typically less than ten 23 years, and on average four to five years 24 prior to diagnosis of AML? 25 A. Yes. 133 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Okay. And you disagree with 3 the use of the first date of exposure as a 4 basis for determining latency? 5 A. I don't think the first date of 6 exposure is when a disease was caused, if one 7 even assumes that it was caused. And, 8 therefore, if latency is defined as time from 9 cause to presentation, that doesn't work for 10 me. 11 Q. What if latency is not defined 12 as time from cause to presentation? 13 A. If you define latency as time 14 from first exposure to occurrence in the 15 situation where there may have not been any 16 causation, then I'll accept that. But that 17 definition to me doesn't mean much. 18 Q. What articles do you rely upon 19 and what is the basis for your opinion number 20 eight regarding the lag time from causative 21 exposure being generally less than ten years, 22 on average four to five years from diagnosis? 23 A. Those figures are well known 24 for alkylating agents. And I did not cite 25 specific references, but there are multiple 134 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 references that come to that conclusion. 3 Series of alkylating agent related 4 chemotherapy -- alkylating agent related 5 leukemias. 6 Topoisomerase inhibitor related 7 leukemias come a bit earlier than four to 8 five years. They come about three years and 9 they don't have the MDS beforehand. So 10 that's different. That would be by analogy. 11 In terms of specifics, there's 12 an article by Triebig, which I'll pull. 13 Implications of Latency Period 14 Between Benzene Exposure and Development of 15 Leukemia, a Synopsis of Literature," by 16 Gerhardt Triebig, published in 2010, 17 Chemico-Biological Interactions, Volume 184, 18 pages 26 through 29. 19 Q. And is that the only article 20 for this opinion that you cite? 21 A. That is the only article that 22 talks directly about benzene exposure and 23 benzene associated leukemias. There is also 24 the data which I talked about generically in 25 terms of alkylating agent leukemia. And 135 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 there is one of the articles that I gave you 3 on smoking that talked about the risk of 4 smoking related leukemia disappeared after 5 about five years, which implies that the 6 latency period for smoking related leukemia 7 is five years or less. So you would still 8 have a continued increased risk. 9 Q. What articles do you cite for 10 the alkylating agent inducing AML as it 11 relates to your latency opinion? 12 A. That is so well established and 13 generally known that I did not cite articles. 14 Q. Okay. What articles do you 15 cite for the smoking risk that hereinafter 16 five years as being relevant to the question 17 of latency? 18 A. I need to have the exhibit 19 dealing with smoking and leukemia handed back 20 to me to give you the precise reference. If 21 I may have that exhibit. 22 Q. I believe it's Number 6. 23 A. (Reviewing document.) 24 The article by Kane in that 25 exhibit talks about the relative risk for 136 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 acute leukemia in smokers. Current smokers 3 have a relevant risk of 1.4. Ex-smokers, who 4 have stopped smoking within one to ten years, 5 have a relative risk of 1.1. So that would 6 be the article. 7 Q. All right. Is the benzene the 8 culprit in cigarette smoke that causes AML? 9 A. There are thousands of other 10 contenders for that. It is not known, or at 11 least I don't know that. 12 Q. All right. Let's talk about 13 the one study you're able to cite that 14 relates to benzene exposure, and that's 15 Triebig. What type of study was Triebig? 16 A. They were -- they looked at 17 cases in Germany and looked at people who had 18 a history of benzene exposure. Such cases, 19 and what their relative risk of leukemia was 20 after they stopped being exposed to benzene. 21 And found that -- and I'll pull it from the 22 abstract, "It is concluded that the 23 epidemiologic findings are consistent and 24 demonstrate a smaller or even absent risk of 25 leukemia 10 to 15 years after exposure to 137 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 benzene has been stopped." So basically they 3 looked at people who were benzene exposed and 4 looked at what their risk was after they 5 stopped the exposure. And by 10 to 15 years 6 it was probably gone. 7 Q. Sorry, you were cutting out 8 there. Is this an actual epidemiology study 9 or is this a review of other literature? 10 - - 11 (Whereupon the court reporter 12 read back the pertinent testimony.) 13 - - 14 THE WITNESS: It's a review of 15 other epidemiologic studies. 16 BY MR. DuPONT: 17 Q. Do you know anything about Dr. 18 Triebig's background? 19 A. I know that he is at the 20 Institute and Outpatient Clinic for 21 Occupational and Social Medicine at the 22 University of Heidelberg. Beyond that I do 23 not know. 24 Q. Do you consider yourself to be 25 an epidemiologist? 138 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. By trade, no. 3 Q. I believe we have already 4 covered, you have never conducted any 5 epidemiology study, have you? 6 A. That is correct. 7 Q. You have never peer-reviewed 8 any epidemiological papers? 9 A. I don't recall doing so. 10 Q. You have certainly never 11 published any epidemiological papers; 12 correct? 13 A. I have published book chapters 14 on malignancies which cover the epidemiology. 15 They are not restricted to epidemiology. And 16 they are not original work. But I have 17 published with epidemiology as part of those 18 publications. 19 Q. And that was not benzene 20 epidemiology; correct? 21 A. It was disease -22 Q. Epidemiology of benzene induced 23 malignancies -24 A. It was disease focused 25 etiology. And my expectation is that I did 139 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 not conclude that benzene was a cause of 3 lymphoma when I discussed the epidemiology of 4 lymphoma in chapters. 5 Q. Do you generally defer to an 6 epidemiologist when it comes to opinions on 7 epidemiology? 8 A. No. 9 Q. No, you do not? 10 A. No, I do not. 11 Q. You think you're more qualified 12 than an epidemiologist in order to interpret 13 epidemiology studies? 14 A. I think in every trial I have 15 been involved in, there has been an 16 epidemiologist on both sides who have 17 diverging opinions. And it would be naive to 18 consider that one -- if the opinions are 19 different, that they're both right. 20 Q. That wasn't my question. 21 My question is, do you consider 22 yourself to be more qualified than an 23 epidemiologist to interpret epidemiological 24 studies? 25 A. Under some circumstances, yes. 140 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Certainly I have seen problems with 3 epidemiologic research that other people have 4 not, or that were not being aware of at the 5 time of publication. 6 Q. How do we know leukemia 7 actually arises in a person? Is there any 8 article that has said, well, I've 9 scientifically proven the precise time that 10 leukemia has arisen in a person prior to 11 their diagnosis of leukemia? 12 MR. THOMPSON: Andrew, can you 13 just re-ask that? 14 BY MR. DuPONT: 15 Q. Okay. 16 Has any scientist been able to 17 define the precise moment in an individual 18 when that individual's leukemia arose prior 19 to diagnosis of leukemia? 20 A. Are you talking about to the 21 second? 22 Q. Any metric. Year? 23 MR. THOMPSON: With reasonable 24 precision. 25 THE WITNESS: Yes. The answer 141 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 is, yes. 3 BY MR. DuPONT: 4 Q. Okay. And who has done that? 5 A. I don't know the author. But 6 the studies are the studies of chemotherapy 7 and radiation induced leukemia. 8 Q. Okay. 9 A. When someone -10 Q. Has anyone done that -11 A. When someone was exposed at 12 Hiroshima and Nagasaki, you have a period of 13 time of perhaps an hour when their leukemia 14 was caused. When someone has had three 15 cycles of chemotherapy over a nine week 16 period, you have a nine week window when that 17 was caused. 18 Q. So is it your opinion that 19 somebody receiving chemotherapy is caused to 20 contract leukemia when they're actually 21 receiving the chemotherapy? 22 A. That's when the genetic insults 23 occurred. Chemotherapy is a excreted from 24 the body rather rapidly and it may not have 25 been the moment it went into the IV line, but 142 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 it was still in the body for two or three 3 days and that's when the genetic insult 4 occurred, or else you would not have had 5 leukemia. 6 Q. Does every genetic insult lead 7 to leukemia? 8 A. As I mentioned before, we have 9 perhaps 10 to the 27th mutations in our 10 lifetime. So the answer is, no. 11 Q. Does every genetic insult by a 12 chemotherapeutic agent lead to leukemia? 13 A. The risk of leukemia in 14 alkylating agent therapy is probably one 15 percent or less. So the answer is no. 16 Q. Does every person respond the 17 same way to chemotherapy in terms of how 18 their genes are affected? 19 A. If only one percent of people 20 who get alkylating agents contract leukemia, 21 then obviously 99 percent didn't. 22 Q. Before we take a break, do you 23 have the Hiroshima studies as part of your 24 basis for saying -- as part of your basis for 25 the latency opinion? 143 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. I don't have as clear data on 3 that in terms of time. So, no, I'm basing it 4 on chemotherapy. But as a model, most of the 5 radiation induced ones are within ten years, 6 but I have not pulled literature on that. 7 Q. But the Hiroshima studies 8 informed your analysis on the issue of 9 latency? 10 A. Not so much on 5 minus, 7 minus 11 and the fact of chromosomal abnormalities 12 that are shared by alkylating agents, that's 13 a better marker because the chromosomal 14 abnormalities with radiation may be 15 different. 16 Q. But generally with respect to a 17 mutagen causing leukemia, the Hiroshima 18 studies form your analysis? 19 A. It's part of the body of 20 evidence, just like topoisomerase inhibitors 21 which causes much -- in a shorter period of 22 time, that I have quoted and are part of the 23 body of evidence. But I am not hanging my 24 hat on radiation because that does not have 25 the same chromosomal pattern that benzene 144 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 has. 3 Q. All right. Let's take the 4 break. 5 MR. THOMPSON: Okay. 6 --7 (Whereupon there was a recess in 8 the proceeding from 2:36 p.m. to 2:46 9 p.m.) 10 - - 11 BY MR. DuPONT: 12 Q. Doctor, would you agree with me 13 that there are literally hundreds of 14 epidemiological studies that use the first 15 period of exposure as the basis for defining 16 latency? 17 A. For using the word, that 18 definition? I don't know if there are 19 hundreds, there are certain many. 20 Q. Would you agree that the vast 21 majority of epidemiology studies use the 22 first day of exposure as the metric for the 23 time of latency? 24 MR. THOMPSON: If you know. 25 THE WITNESS: My belief is that 145 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 most of them who use the word latency 3 use that, but a rose is a rose is a 4 rose. 5 BY MR. DuPONT: 6 Q. Is it your assumption that the 7 leukemias caused by chemotherapy arose during 8 the time period of exposure to 9 chemotherapeutic agents, as opposed to some 10 time after the chemotherapy was stopped and 11 the chemotherapeutic agents left the body? 12 A. The answer to the question is 13 yes. But if I accept that it was later, that 14 would even shorten the latency. 15 Q. Well, I guess what I'm getting 16 though is, do we know that it is the mutation 17 that takes place after the exposure to 18 chemotherapy, as opposed to during the 19 chemotherapy exposure that caused the 20 leukemia? 21 A. I cannot distinguish whether it 22 is during the actual infusion or afterwards, 23 but the chemotherapy stays in the body 24 generally for a couple of days afterwards. 25 So statistically it is much more likely to be 146 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 after the five minute infusion rather than 3 during the five minute infusion. 4 Q. Can you rule out exposures to 5 patients that occur after the chemotherapy 6 has left the body as the cause of the 7 leukemia? 8 MR. THOMPSON: Mutations from 9 the chemotherapy or just mutations? 10 MR. DuPONT: Mutations that were 11 put into place by the chemotherapy. 12 THE WITNESS: Again, it would 13 shorten the latency, not lengthen it. 14 But the answer to the question is, 15 there could be a -- no. Causes five, 16 causes seven, those are direct effects 17 of some agents and the agents is 18 given. So, no, I don't think it would 19 be a delayed effect. 20 BY MR. DuPONT: 21 Q. Okay. The studies on 22 alkylating agents that you rely upon for your 23 latency/arose opinion, did they study whether 24 the individuals who are subjects of those 25 studies had exposure to any mutagenic agent 147 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 prior to their chemotherapy? 3 A. I don't recall a study doing 4 that, but when you have a 30 year old who 5 gets leukemia with 5 and 7 three years after 6 or five years after alkylating agent therapy 7 and you see that pattern over and over again 8 with the same timeframe in someone who is 30 9 or 20, one reaches then a reasonable 10 conclusion that it's causal. 11 Q. But you don't know what portion 12 of those 30 year olds worked at a gas station 13 in high school? 14 A. No, I don't know that. 15 Q. All right. Let me change the 16 analysis a little bit. If you had somebody 17 who is exposed to benzene for a 40 year 18 period of time, is it your opinion that the 19 exposures occurring more than ten years prior 20 to the diagnosis with AML played absolutely 21 no role in causing the AML, even if there 22 were exposures within ten years of diagnosis? 23 A. I think if there was an -- if 24 you postulate that someone had a benzene 25 caused AML, then it would be caused on an 148 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 average of five years prior to diagnosis, and 3 the great majority within ten years. There 4 might be some that are 11 years or 12 years. 5 I don't think there would be any that would 6 be 20 years. 7 Q. What I'm asking is, if you have 8 a continuous 40 year period of exposure, that 9 ends less than five years before the 10 diagnosis with AML, at what point in time do 11 you say, we can affirmatively cut off the 12 exposures as playing any causative role in 13 causing AML? 14 A. I think you look at exposures 15 within ten years of diagnosis as being 16 relevant. 17 Q. And you would say that no 18 exposure that occurred more than ten years 19 before diagnosis, even if there was a 20 cumulative and ongoing exposure over 21 40 years, that ends within five years from 22 diagnosis, you would say that none of the 23 exposures more than ten years prior to 24 diagnosis played any role in causing the AML? 25 A. I think cumulative exposure as 149 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 a metric can predict who's at risk for 3 benzene related to acute leukemia. But 4 largely that's because the risk goes up with 5 age and because the risk normally occurs at 6 the tail end of a high -- long career of 7 exposure rather than someone who's only had 8 brief exposure. 9 However, I think what's 10 relevant to causation is what's in the first 11 -- what's in ten years preceding it. Because 12 if it were caused 15 or 20 years, it would 13 have shown up sooner. 14 Q. Well, my question was 15 different. Do you completely rule out 16 exposure that occurred more than ten years 17 before the date of diagnosis, even if the 18 person had a 40 year exposure history that 19 ended within five years of the date of 20 diagnosis? 21 A. I would -22 MR. THOMPSON: Do you have 23 anything to add your answer? 24 THE WITNESS: I would completely 25 rule out 20 years or more. I think it 150 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 exceedingly unlikely 15 years or more. 3 I think it very unlikely 10 years or 4 more. 5 BY MR. DuPONT: 6 Q. Is there any author that has 7 ascribed to that conclusion in the 8 peer-reviewed literature? 9 A. Spoken in the way that I have 10 spoken it, I can't say that I know of someone 11 who has done that. Again, Triebig came to 12 his conclusion. The alkylating agent data 13 are what they are. 14 Q. All right. 15 A. And whether Natelson dealt with 16 this I don't remember. 17 Q. What role, if any, does 18 intensity of exposure play in the latency 19 question? 20 A. I think that latency is not a 21 relevant issue if there is inadequate 22 exposure to be causal. The latency issue 23 assumes that there is adequate exposure to be 24 causal. 25 Q. Well, if the exposures are more 151 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 intense, is the latency period likely to be 3 shorter or longer? 4 A. No. 5 Q. So the intensity of exposure, 6 in your opinion, has no effect on the latency 7 period? 8 A. If there is a causal event, 9 which is a function of intensity, but if you 10 posit there is a causal event, then it 11 doesn't matter whether there was a lot of 12 exposure or little exposure. The causal of 13 event occurs and it's going to take its time 14 course as it will. That doesn't mean that 15 low dose exposure causes leukemia. It means 16 that if you are assuming that benzene caused 17 leukemia, it doesn't matter what the setting 18 of exposure was. 19 Q. All right. Let's move to your 20 opinion number nine, spontaneous mutation 21 causes AML. What is a spontaneous mutation? 22 A. One that occurs normally, 23 naturally, without an existing cause. 24 External cause. 25 Q. Has anybody studied the issue 152 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 and determined that there are spontaneous 3 AMLs amongst somebody who has never been 4 exposed to any leukemogenic agent? 5 A. Well, I would say de novo was 6 spontaneous, and the literature is replete 7 with distinction between de novo acute 8 leukemia and treatment related acute 9 leukemia. 10 Q. And it's your position that 11 people who have de novo leukemia never had 12 any exposure to leukemogenic, including 13 benzene? 14 A. It's my opinion that people 15 with de novo leukemia cannot have their 16 leukemia ascribed to any external factor. 17 The issue is one of statistics. That is, if 18 you have a hundred million mutations that are 19 spontaneous, and if you, because you have 20 pumped gasoline for your car, get an 21 additional hundred mutations, it's not very 22 likely that a hundred mutations is relevant, 23 given the hundred thousand spontaneous 24 mutations. Sort of like -25 Q. Doctor, my question was 153 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 different. My question was, is it your 3 opinion that people who have de novo leukemia 4 never had any exposure to leukemogens? 5 MR. THOMPSON: Any exposure to 6 any leukemogen at any time in their 7 life? 8 MR. DuPONT: Yes. 9 THE WITNESS: Every person in 10 the civilized world has had exposure 11 to benzene in the ambient air. 12 BY MR. DuPONT: 13 Q. So is there any study that has 14 looked at individuals that have never been 15 exposed to a leukemogen and found that they 16 had a spontaneous mutation that caused AML? 17 A. Everyone in the world has been 18 exposed to a leukemogen. So it's an 19 impossible study to do. 20 Q. So what references do you rely 21 upon for your opinions that there are 22 spontaneous mutations that cause AML? 23 A. There was an article in 24 Science, which was written the year that DNA 25 was the molecule of the year, I believe. Or 154 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 maybe it was not DNA molecule, maybe it was 3 DNA repair enzymes were the molecule of the 4 year. And at that time there was a 5 measurement of spontaneous mutations 6 occurring within the genome. And the author 7 concluded that there was something like ten 8 to the 27th, which is 10 with 27 zeros after 9 it, spontaneous mutations. And made the 10 point that these are much more dangerous than 11 causing cancer than any external carcinogen. 12 I do not off the top of my head 13 have the specific reference. I probably can 14 find it, although it may take some work. But 15 the point remains, spontaneous mutations are 16 normal and ubiquitous and multiple. And 17 again, this is the nature of evolution. 18 Without spontaneous mutations we would all be 19 one cell organisms. 20 Q. All right. Did that article 21 that you reference without being able to 22 cite, conclude that spontaneous mutations 23 cause AML specifically? 24 A. Cancer, yes. AML specifically, 25 no. To my knowledge. 155 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Does that article say what 3 percentage of the spontaneous mutations 4 actually lead to cancer? 5 A. Yes. Very few. Since there 6 are 10 with 27 zeros after it and most people 7 get three or four cancers, you're not going 8 to be getting the majority. The majority of 9 them are either in areas that don't cause 10 cancer or are repaired. It's the ones that 11 get through that cause cancer. 12 Q. You said that most people get 13 three or four cancers? 14 A. No, I said most people get at 15 most three or four cancers. 40 percent of 16 people will get cancer in their lifetime 17 currently. If you're cured of cancer one, 18 you're certainly at risk for getting cancer 19 two. 20 Q. So do you know what percentage 21 of these spontaneous mutations that can lead 22 to cancer? 23 A. You can say that for a patient 24 what got cancer and who lived till age 60, it 25 was probably one over 10 to the 26th or 156 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 something like that. One over 10 to the 25th 3 maybe. 4 Q. Is that something that was 5 published in this article or something that 6 you are concluding on your own? 7 A. I am concluding it based upon 8 there being, to my recollection, 10 to the 9 27th spontaneous mutations in normal 10 lifetime. I may be off on my number, but 11 it's a big number, whatever it is. 12 Q. Your 10th opinion that Mr. 13 Gerchman's exposures were qualitatively small 14 over the 10 years preceding his diagnosis, 15 what is your basis for that opinion? 16 A. Deposition said that he worked 17 roughly half time, some said 60 percent, some 18 said 40 percent, at GnG doing mechanic's 19 work. And over that period of time that he 20 only did light mechanic's work. So that 21 would be for eight of the ten years or so. 22 Over that period of time, he would be working 23 with contaminant level benzene, which 24 generally would be very low. 25 So based upon that, and based 157 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 upon the fact that the typical mechanic's 3 exposure based upon Scarselli's article is 4 small. And the typical exposure based on 5 Williams' article in terms of modern 6 chemicals is small. I think that it was 7 small exposure. 8 Q. Okay. That's the only exposure 9 assessment that you performed for David 10 Gerchman for those 10 years? 11 MR. THOMPSON: I'm sorry, are we 12 on the opinion where he says he thinks 13 that the exposure was qualitatively 14 small over ten years? 15 MR. DuPONT: Yes. 16 THE WITNESS: Just asked me 17 about ten years. 18 BY MR. DuPONT: 19 Q. That's the only thing that you 20 gave me. 21 MR. THOMPSON: Did you also look 22 at Petty and Williams' reports in this 23 case, Doctor? 24 THE WITNESS: The reports from 25 Dr. Petty and Williams are very 158 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 different. Dr. Petty's report claims 3 a lot of dermal exposure, which is, to 4 my knowledge, largely unprecedented in 5 the literature. Doctor Williams 6 differs. 7 BY MR. DuPONT: 8 Q. Dermal exposure is 9 unprecedented in the literature? 10 A. To be as large a function of 11 the benzene load. I will let Dr. Williams 12 and Dr. Petty deal with the details. I'm 13 talking qualitatively, not quantitatively. 14 But it seems to me that Dr. Williams' 15 analysis is more in the main stream, and that 16 that would be consistent with a low exposure. 17 If Dr. Petty's analysis, which I could view 18 as not in the main stream, happens to be 19 correct, then I would say that one would have 20 to take a look at the exposure data claimed 21 in the Health Watch study and the pliofilm 22 study and the other studies, and recalibrate, 23 using Dr. Petty's method. And I expect at 24 that point the benzene associated ppm years 25 or other markers of concentration would have 159 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 to be in association -- those associated with 3 leukemia would have to be revised 4 considerably upward based upon new exposure 5 analysis. 6 Q. Doctor, I would like you to 7 answer my question, as you agreed that you 8 would do at the beginning of the deposition. 9 A. What is your question? 10 Q. Did you qualitatively assess 11 Mr. Gerchman's exposure more than ten years 12 before his diagnosis, or did you just rely on 13 the report of Pamela Williams and Stephen 14 Petty for that information? 15 A. I qualitatively assessed it as 16 more than in the last ten years, but still 17 modest. 18 Q. Is it your opinion that David 19 Gerchman's benzene exposures were consistent 20 throughout his career as a mechanic? In 21 other words, there was no period of time 22 where his exposures were higher or lower? 23 A. I expect that his experience in 24 the last ten years was lower than in the 25 preceding years. 160 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. All right. And what was the 3 difference? How much greater was his 4 exposures on an eight hour time weighted 5 average or a peak level in the ten years 6 before his diagnosis versus the period of 7 time more than ten years before his 8 diagnosis? 9 A. You're asking a quantitative 10 question, and I did not make a quantitative 11 analysis. 12 Q. Okay. Qualitatively, what was 13 the difference in the exposures? How much 14 greater was the exposures in the period more 15 than ten years before diagnosis than the 16 period of time roughly 10 years before 17 diagnosis? 18 A. A bit better. A bit greater. 19 Q. A bit greater? 20 A. Yes. 21 Q. How do his exposures vary from 22 date of 1970s to the 1980s? 23 MR. THOMPSON: If you formed an 24 opinion on that. 25 THE WITNESS: I don't have a 161 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 quantitative analysis. I have 3 qualitative. And I can say it's a bit 4 greater, but that's where it ends. 5 BY MR. DuPONT: 6 Q. A bit greater in the seventies 7 than the eighties. A bit greater in the 8 eighties than the nineties. Is that correct? 9 A. I have not made a specific 10 analysis decade by decade. 11 Q. Okay. 12 A. Other than saying that ten 13 years prior was slight and less. 14 Q. All right. It's your opinion 15 that 40 to 60 part per million years of 16 benzene exposure will cause AML; is that 17 correct? 18 A. It's my opinion that people who 19 have had 40 to 60 years part per million 20 exposure are at an increased risk for AML. 21 Q. How much of an increased risk? 22 A. It depends upon the exposure. 23 Q. 40 part per million years, how 24 much of an increased risk? 25 A. As a rough estimate, 50 to 100 162 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 percent increased risk. 3 Q. That's 1.5 -- a relative risk 4 of 1.5 to 2? 5 A. That's between 40 and 60 part 6 per million years, yes. 7 Q. The question was 40 part 8 million years. 9 A. Well, I'm answering between 40 10 to 60. I can't give you a precise answer for 11 40 exactly. 12 Q. All right. How about for 60, 13 can you give me a precise answer for 60? 14 A. 40 to 60 would include that 15 range. 16 Q. 61 part per million years, 17 what's the relative risk of AML? 18 A. A tiny bit higher than 40 to 19 60. 20 Q. So more than two -- relative 21 risk is more than two at 61 part per million 22 years? 23 A. If it was 1.5 to 2 before, and 24 if you ask me to pick a number, I'll pick 1.6 25 to 2.1. 163 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. How about 80 part per million 3 years -4 A. Probably -5 Q. -- what's the relative risk of 6 AML causing -- of benzene causing AML at 80 7 part per million years cumulative risk? 8 A. Two to threefold. I'm sorry, 9 relative risk of two to three. 10 Q. Does benzene increase the risk 11 of AML at exposure levels cumulative that are 12 less than 30 to 40 part per million years? 13 A. Cumulative exposure of less 14 than 30 is not a marker, in my judgment, for 15 increased risk of AML. 16 Q. Less than 40 part per million 17 year cumulative dose of exposure, does 18 benzene increase the risk for AML? 19 A. It's not a marker for increased 20 risk at that cumulative exposure. 21 Q. What do you mean by a marker? 22 A. The disease, I believe, is not 23 caused by exposure 20 to 30 years ago. I 24 believe I have said it's caused by exposure 25 in the ten years prior to diagnosis. So to 164 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 some degree the earlier exposure is a marker 3 of risk, rather than a determinant of risk. 4 People who have enough exposure in the ten 5 years prior to it generally have a long 6 history of exposure because exposure is less 7 now than it used to be. And so that is a 8 marker of risk. 9 Q. How likely is it that somebody 10 today will get 40 part per million years 11 cumulative dose of exposure in ten years? 12 A. In the United States it's 13 unlikely. 14 Q. Is it possible? 15 A. I suppose if someone chooses to 16 distill pure benzene and inhale it in a 17 suicidal attempt, then it's possible. But in 18 terms of modern work spaces, I would not 19 expect it to occur. 20 Q. So, in your opinion, no one in 21 modern day America will get benzene induced 22 AML in, let's say, a suicidal manner 23 intentionally inhaled benzene? 24 MR. THOMPSON: Put it in your 25 own words, Dr. Sarna. 165 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 THE WITNESS: The Pukkala 3 article, which was not yet discussed, 4 shows that in mechanics, painters, 5 other professions that have 6 contaminant benzene exposure there's 7 no increased risk of AML. 8 BY MR. DuPONT: 9 Q. Doctor, that's not my question. 10 A. That's my answer. 11 Q. My question was: In your 12 opinion, the only way that someone in modern 13 day America can get a benzene induced AML, if 14 they intentionally expose themselves to pure 15 benzene? 16 MR. THOMPSON: Is that the only 17 way, that's what he's asking you. 18 THE WITNESS: I don't believe 19 that with exposure under current 20 contaminant level conditions that 21 people are getting benzene induced 22 leukemia, not today. Whether there's 23 some way they can get it other than 24 intentionally, I suppose someone could 25 try to poison someone. I can think of 166 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 other scenarios, so I won't say that's 3 the only way. But in the modern 4 workplace, the evidence is, there's no 5 increase of leukemia and my 6 expectation is that it doesn't occur. 7 BY MR. DuPONT: 8 Q. So according to Dr. Sarna, we 9 will not see any future cases of benzene 10 induced AML in the American workplace without 11 there being intentional exposures? 12 MR. THOMPSON: Is that what you 13 said, Dr. Sarna? 14 THE WITNESS: I said that with 15 modern exposure limits, assuming that 16 they are followed and not egregiously 17 done, you will not be seeing it. If 18 there exceptions to that, for whatever 19 reason, you may see it. 20 BY MR. DuPONT: 21 Q. Which exposure limits are you 22 referring to, the OSHA permissible exposure 23 limit? 24 A. OSHA I believe is one par part 25 per million and Stella, five part per million 167 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 and that would be consistent, yes. I think 3 that if I recall correctly -4 Q. Are the -5 MR. THOMPSON: That's okay. You 6 have answered his question. 7 BY MR. DuPONT: 8 Q. Are the most up-to-date 9 conclusions of the United States government 10 on the dose of benzene exposure that is 11 creating a risk for leukemia those which are 12 set forth in the OSHA PELs and STELs? 13 MR. THOMPSON: If you know, Dr. 14 Sarna. 15 THE WITNESS: I believe NIOSH 16 may have different numbers. Let me 17 double-check. NIOSH has lower numbers 18 than OSHA. 19 BY MR. DuPONT: 20 Q. Okay. And NIOSH's numbers are 21 important to consider as well; correct? 22 MR. THOMPSON: In what regard? 23 BY MR. DuPONT: 24 Q. NIOSH's numbers are important 25 to consider as well when we're concerned with 168 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 whether or not benzene exposure will cause 3 leukemia; correct? 4 MR. THOMPSON: If you agree with 5 that. 6 THE WITNESS: What numbers are 7 chosen to maximize safety are 8 different from what numbers actually 9 cause disease. When you get in an 10 elevator, they tell you you may not 11 have over 2000 pounds, but that 12 doesn't mean if you have 2001 it's 13 going to crash. 14 MR. DuPONT: Counsel, I think 15 the doctor can determine whether or 16 not he himself agrees with the 17 statement. So if you want to make an 18 objection, you can make an objection. 19 But I object to your interfering with 20 my deposition and suggesting answers 21 to the witness. 22 MR. THOMPSON: I didn't suggest 23 any answer to him. Where did I 24 suggest an answer to him right there? 25 MR. DuPONT: Whether you agree 169 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 with that or not, okay. 3 MR. THOMPSON: What's wrong with 4 that? 5 MR. DuPONT: It's not an 6 objection. It's a speaking objection, 7 it's improper and I would ask you to 8 stop. 9 MR. THOMPSON: Just go ahead and 10 ask your next question. 11 BY MR. DuPONT: 12 Q. What literature sources and 13 bases do you rely upon for your opinion that 14 low dose two part per million year exposures 15 do not increase the risk of leukemia? 16 A. The literature would be based 17 upon the absence of leukemia increase in 18 modern day in people who have contaminant 19 level exposure, and that's the Pukkala 20 article. The evidence for 40, 60, whatever, 21 would be depending upon which interpretation 22 of the pliofilm article you choose. There 23 are vary -- maybe five or six different 24 interpretations of that data that I think 25 range from 40 to 200 part per million years 170 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 as a marker or a risk factor. 3 Q. I was asking for the name of 4 the article. 5 A. ^Rinsky is one. 6 Q. Give me the names of the 7 articles that you rely upon for the position 8 that low dose exposures at two part per 9 million years cumulative dose do not increase 10 the risk of leukemia. 11 MR. THOMPSON: Just go ahead and 12 give him the names of the articles you 13 recall. 14 THE WITNESS: The Rinsky 15 article. The Wong analysis of the 16 pliofilm cohort. There are several 17 other analyses of the pliofilm cohort. 18 The Pukkala article. The article by 19 Glass is worth discussion because it 20 is the only one that I know of that 21 claims two part per million as a cause 22 and because there are serious problems 23 with that article that make it not 24 credible. 25 BY MR. DuPONT: 171 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. So Glass 2003, Pukkala, the 3 pliofilm studies are the articles you rely 4 upon for that opinion? 5 A. Yes. 6 Q. And those are the articles that 7 you considered for that opinion in this case? 8 A. Those are the article I brought 9 with me. On all of my opinions I'm 10 considering the body of information I have, 11 which may not be linked to a specific 12 article, but linked to what I have read in 13 general. 14 I would also add Wong and 15 Rothman's Meta-analysis on petroleum 16 industry. Brown and ^Steinman's various 17 articles on painters. There's a 18 Meta-analysis on diesel exposed workers. All 19 of which show no increased risk of leukemia. 20 Q. Okay. What is the diesel 21 exposed worker study you're referring to? 22 A. I don't have the author off the 23 top of my head. 24 Q. Do you have that article with 25 you? 172 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. No. 3 Q. What's your basis for your 4 disagreement with Dr. Shadduck and Harrison 5 on their opinions on general causation of AML 6 and specific causation in David Gerchman? 7 A. You're going to have to tell me 8 specifically what you want me to opine on. 9 Q. I don't know, your attorney 10 says you're going to opine on that, so I want 11 to know what you're going to say. If you 12 don't have an opinion on that, then tell me 13 you don't have an opinion on that. 14 A. In terms of general -15 MR. THOMPSON: Hold on a second, 16 Doctor. Take a look at your notes, 17 where you made some notes about 18 Harrison and Shadduck. 19 MR. DuPONT: Counsel, please do 20 not direct the witness how to answer 21 my question. 22 MR. THOMPSON: I'm just telling 23 you, he's going to be asked questions 24 on -25 MR. DuPONT: No. No. It's not 173 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 your place to tell me anything. 3 MR. THOMPSON: Whatever. 4 MR. DuPONT: It's not your place 5 to coach the witness how to answer 6 questions. I'm entitled to get an 7 answer from the witness, not an 8 attorney for the witness. 9 MR. THOMPSON: Fine. 10 THE WITNESS: Okay. Regarding 11 Dr. Shadduck. 12 MR. THOMPSON: Andrew, you're 13 ignoring the fact that the guy made 25 14 pages of notes in preparation for 15 coming here and giving his opinions. 16 And you haven't looked through them 17 once. All right? And so he is going 18 to rely on those notes for his 19 opinions in this case. The facts that 20 he wrote down there were those that he 21 found to be salient, as he told you 22 earlier. So I'm telling you now, he's 23 going to be asked questions about 24 Shadduck and Harrison. He made 25 notations there that were important to 174 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 him that he doesn't have committed to 3 memory. So we're going to go through 4 those now so you have a chance to ask 5 the questions about the things he 6 might comment on. So, go ahead, 7 Doctor. 8 THE WITNESS: In terms of Dr. 9 Shadduck, he cited the threshold for 10 AML was 4.5 to 45 part per million 11 year. That was based on the letter 12 from Shell Oil to EPA regarding the 13 pooled analysis of the Canadian, UK 14 and Australian nested case control 15 studies. And that draft report said, 16 "Preliminary analyses indicate that 17 the risk of MDS was statistically 18 significant at cumulative exposure 19 levels, i.e., 4.5 to less than 45 part 20 per million years, below that 21 previously reported in the literature. 22 Number one is the preliminary 23 analysis. Number two is unpublished. 24 Number three is not -25 BY MR. DuPONT: 175 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Doctor, are you basically going 3 to read your -- however this report was 4 written, are you just going to read this in 5 response to my question about your opinions 6 on Dr. Shadduck and Harrison? 7 A. Parts of it will be taken from 8 that, parts of it will be elaborated on and 9 expanded. 10 Do you want me to continue my 11 answer? 12 Q. All right. 13 A. It's also -14 MR. THOMPSON: Do you want him 15 to keep going? 16 BY MR. DuPONT: 17 Q. Is it your understanding that 18 it was Dr. Shadduck's opinion that the 19 threshold is 4.5 part per million years? 20 MR. CARR: Hang on a second, 21 he's in the middle of an answer again 22 and you've cut him off. So you either 23 need to withdraw the question, make 24 clear on the record that you stopped 25 him, or let him finish his answer. 176 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 BY MR. DuPONT: 3 Q. Doctor, my question is: Is it 4 your understanding that it was Dr. Shadduck's 5 opinion that the threshold for AML being 6 caused by benzene exposure is 4.5 part per 7 million years? 8 MR. CARR: Okay. I'm going to 9 object to you cutting off the witness 10 again when he's in the middle of an 11 answer. And I want the record to be 12 clear that if you take the position at 13 trial that his concerns with Dr. 14 Shadduck's opinions or Dr. Harrison's 15 opinions were not disclosed to you in 16 this deposition, that he was in the 17 middle of telling you what they were 18 and you stopped him. 19 BY MR. DuPONT: 20 Q. Doctor, can you please answer 21 my question? Is it your understanding that 22 it's Dr. Shadduck's opinion that 4.5 part per 23 million years is the lowest dose, or a 24 threshold above which benzene causes AML? 25 A. In the course of his 177 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 deposition, one of the things he cited for 3 exposure was the threshold for AML in 4.5 to 4 45 ppm per million year range based upon the 5 letter from Shell. That's my understanding. 6 I believe he also cited different data as 7 well. 8 Q. And is your analysis concerning 9 Dr. Shadduck's opinion based on the letter 10 from Shell to the EPA that which are set 11 forth in these comments and notes? 12 A. There may be beyond that. I 13 have not read to see whether he has done 14 anything else. I can certainly go over it 15 verbally, but I expect most of it is in the 16 notes. 17 Q. All right. Well, why don't you 18 read it to yourself and then tell me if there 19 is anything in addition. 20 A. Comments one and two and three 21 and four on page 60 would encompass my 22 comments on the Shell letter being cited by 23 Dr. Shadduck. 24 Q. All right. Do you have any 25 other criticism of Dr. Shadduck that is not 178 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 set forth in writing in your notes and 3 comments that we have attached as Exhibit 4? 4 A. My notes and comments would 5 encompass my comments on which would include 6 at times criticisms of Dr. Shadduck's 7 opinions. 8 Q. Okay. Are your comments and 9 criticisms of Dr. Shadduck's opinions fully 10 set forth in this writing? 11 A. Fully? They're not have full 12 elaborations, no. They're set forth in 13 principle. 14 Q. Okay. Is there anything that 15 you want to add that is not written in this 16 notes and comments regarding Dr. Shadduck? 17 MR. THOMPSON: Remembering that 18 you're going to be asked about whether 19 you agree with their opinions on 20 general and specific causation. 21 MR. DuPONT: Counsel. 22 MR. THOMPSON: Andrew, this 23 isn't a federal court report, man. 24 This isn't how we do it in California. 25 We come here and this is the time when 179 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 he discloses his opinions. 3 MR. DuPONT: I don't care what 4 state it's in. I'm entitled to get an 5 answer from the witness, not the 6 attorney. 7 MR. THOMPSON: That's not an 8 answer. I'm telling you, he's going 9 to be asked that series of questions. 10 I'm not giving him any answer. I'm 11 telling him he's going to be asked to 12 comment on that. 13 THE WITNESS: I disagree with 14 Dr. Shadduck's conclusion that low 15 dose benzene causes leukemia. And I 16 disagree with the specific causation 17 opinion that Mr. Gerchman's leukemia 18 was caused by benzene exposure in the 19 workplace. 20 The reasons for that are all 21 elaborated in my notes and in my 22 deposition. But as a blanket answer 23 to the question, do I agree or 24 disagree with this general or specific 25 causation, I disagree with both. 180 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 BY MR. DuPONT: 3 Q. All right. And if I want to 4 know why you disagree with it, it's set forth 5 in this written report and this written notes 6 and comments? 7 A. Certainly there are additional 8 materials that I haven't documented that 9 bolster the opinions, but the crux of my 10 opinions are in this report. I'm not sure 11 whether I have all the issues about psoriasis 12 in here or not, but I mentioned that before 13 as one of the opinions and I expect we'll get 14 to that. 15 MR. THOMPSON: And we have been 16 here talking for five hours. 17 BY MR. DuPONT: 18 Q. And are you able to add 19 anything, as we sit here today, right now, 20 that bolsters your opinions, as you said, 21 that bolsters your comments and criticisms? 22 A. On Dr. Shadduck? 23 Q. Correct. 24 A. I don't have anything at this 25 point to add. 181 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Now, moving on to Dr. Harrison. 3 Are all of your points of disagreement and 4 criticism with Dr. Harrison's opinions and 5 testimony set forth in this written notes and 6 comments? 7 MR. THOMPSON: Andrew, let me 8 just clarify. He doesn't have the 9 deposition transcript. Did you have 10 Harrison's deposition transcript? 11 THE WITNESS: The only thing I 12 had was his handout. 13 MR. THOMPSON: So he had only 14 his report, so that's all he can 15 comment on at this time. 16 MR. DuPONT: Okay. 17 BY MR. DuPONT: 18 Q. You have criticized and 19 critiqued Dr. Harrison without reading his 20 deposition testimony? 21 MR. THOMPSON: He hasn't gotten 22 -- we don't have Dr. Harrison's 23 deposition yet, buddy. 24 MR. DuPONT: I'm asking a 25 question, Barry, okay. 182 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 BY MR. DuPONT: 3 Q. ^am I correct that you 4 criticized and critiqued Dr. Harrison's 5 opinions without reading the deposition 6 testimony? 7 MR. THOMPSON: That is just such 8 an unfair question, I can't believe 9 it. We don't have his deposition yet. 10 MR. DuPONT: I didn't suggest 11 you did. Okay. I'm entitled to ask 12 what he did. If you would stop 13 interrupting and stop interfering, I 14 would appreciate it. Stop it. 15 MR. THOMPSON: Don't answer that 16 question, Dr. Sarna. That's an 17 unfair, ridiculous, argumentative 18 question. He knows we don't have the 19 transcript yet and we have told him 20 you're going to read the transcripts 21 of any witness testifying on 22 causation. So don't answer that 23 question, that's a terrible question. 24 BY MR. DuPONT: 25 Q. Doctor, are your critiques and 183 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 and criticism of Dr. Harrison and his 3 opinions based only on his written report and 4 not what he stated during his testimony? 5 A. My written comments in my notes 6 are based upon the roughly 10 page report 7 that I got. 8 Q. Okay. 9 MR. THOMPSON: He is going to 10 read the doctor's testimony and 11 comment, just so you know. Because -12 BY MR. DuPONT: 13 Q. And are all of your opinions 14 and criticisms in this written report, as 15 they relate to Dr. Harrison? 16 A. What I did was, I commented on 17 what was written there. That does not 18 include all my proactive comments, but it 19 includes all my reactive comments. 20 Q. Okay. Are there any comments 21 or opinions or analyses that you need to add 22 to your review of Dr. Harrison's report and 23 opinions that are not set forth in here, 24 including the basis for them? 25 MR. THOMPSON: I guess we're 184 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 going to go through the same exercise, 3 in that he's going to be asked to 4 comment on, agree with, disagree with, 5 or expand on Dr. Harrison's opinions 6 on general and specific causation. So 7 you are going to be asked that, Dr. 8 Sarna. 9 THE WITNESS: I expect to see 10 his deposition. I expect I will react 11 to that deposition. There may be 12 things that I agree with or disagree 13 with. There may be things to change 14 what I have written, or there may be 15 things to add to what I've written. 16 BY MR. DuPONT: 17 Q. Okay. Based on information you 18 have from Dr. Harrison at this point in time, 19 is there anything you have to add to your 20 opinions, your analysis and your criticism of 21 Dr. Harrison, beyond what's stated in your 22 written notes and comments? 23 A. My written notes and comments 24 reactive to the handout. It was not a 25 criticism of Dr. Harrison, it was -- it may 185 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 be a criticism of his comments, but it was 3 not criticism of him personally. 4 There may -- that was reactive 5 comments, not proactive comments. And so 6 it's reactively reasonably complete. 7 Proactively there may be things lacking 8 because this is not a formal report. And 9 it's incomplete from the point of view of 10 evaluating his opinions because I haven't 11 seen his deposition. 12 Q. Do you have anything to add to 13 your analysis, your criticisms or your 14 opinions pertaining to Dr. Harrison's written 15 report? 16 A. Not at this time. 17 Q. Or written notes? 18 A. Not at this time. 19 Q. Have you reviewed the most 20 recent Tran group studies? 21 A. I think it's 2010 or 2011. 22 Q. How many cases of AML were 23 found in the most recent Tran group study? 24 A. It was either three or four. I 25 believe three. 186 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. And have you discussed with any 3 of the other doctors hired by defendants in 4 this case what their views on the Tran group 5 study are? 6 A. No. 7 Q. All right. Do you have an 8 opinion that you cannot rule in or rule out 9 de novo AML? First of all, is de novo a 10 cause of AML or is it just the absence of 11 knowledge of what caused AML? 12 A. Leukemia -- an AML would be 13 considered a de novo in the absence of a 14 known cause. 15 Q. Okay. So de novo in and of 16 itself is not a cause of leukemia; correct? 17 A. De novo means it occurred 18 without a known cause. It is not a cause. 19 Q. Okay. Without a known cause; 20 correct? 21 A. Yes. 22 Q. There could be a cause, but we 23 just don't know what it is; correct? 24 A. Everything has a cause. Most 25 of these presumably are spontaneous 187 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 mutations. 3 Q. But when we talk about de novo 4 and idiopathic we're talking about something 5 that we just don't know what caused it? 6 A. Idiopathic certainly means we 7 don't know. De novo means it occurred 8 without a known cause. And we can surmise 9 that most of those are spontaneous mutations, 10 but that's a surmisal. There's no way of 11 proving or disproving it. 12 - - 13 (Discussion held off the 14 record.) 15 - - 16 (Whereupon there was a recess in 17 the proceeding from 3:34 p.m. to 3:41 18 p.m.) 19 - - 20 BY MR. DuPONT: 21 Q. Doctor, do you hold the opinion 22 that you cannot rule in or out de novo AML? 23 A. There is no specific test to 24 prove that something is from a spontaneous 25 mutation. De novo simply is a term meaning 188 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 you don't know the cause and it appears to be 3 without a cause. So you can rule that in or 4 rule that out by saying there's no known 5 cause. 6 Q. So your basis -- have you ruled 7 in de novo leukemia? 8 A. In the absence of a known 9 cause, I can consider this de novo. 10 Q. Okay. So you're going to tell 11 the jury that it's more likely that David 12 Gerchman's AML arose for no reason whatsoever 13 than it is that his 40 year history of 14 exposure to benzene caused his AML? 15 A. I'm going to say that David 16 Gerchman's AML falls in the 80 percent of 17 AMLs with no identifiable cause. 18 Q. And is it your opinion that 19 that 80 percent of AMLs had a 40 year 20 exposure history with benzene? 21 MR. THOMPSON: Objection, vague 22 and ambiguous. 23 THE WITNESS: You're asking 24 whether everybody in that 80 percent 25 has had 40 years of benzene? The 189 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 answer to that is, no. 3 BY MR. DuPONT: 4 Q. Is it your opinion that anyone 5 within those 80 percent of de novo leukemias 6 has a 40 year occupational history of 7 exposure to benzene? 8 A. There are many, many, many 9 people who work with contaminant level 10 benzene. These people are not immune to 11 de novo leukemia. And I'm sure there are 12 plenty of people who have a history of 13 contaminant level of benzene who have 14 developed de novo leukemia. 15 Q. So you would include people 16 with a history of almost 40 years of exposure 17 to a known leukemia causing agent -18 A. The people who -19 MR. THOMPSON: Let him finish 20 his question, Doctor. 21 BY MR. DuPONT: 22 Q. Let me finish my question, 23 Doctor. 24 You would consider people with 25 a 40 year occupational exposure history of 190 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 exposure to an agent known to cause AML as 3 being within the 80 percent of individuals 4 who you claim develop AML as a result of no 5 known cause? 6 MR. THOMPSON: Objection, 7 incomplete hypothetical. 8 THE WITNESS: The people who 9 have a history of benzene exposure who 10 get de novo leukemia will generally 11 get it at an average age of about 65, 12 and will generally have started having 13 their contaminant level exposure 14 40 years, 45 years earlier. And they 15 will all have that history. They are 16 not immune to getting de novo 17 leukemia. 18 If these people all were having 19 leukemia due to benzene, you would see 20 a marked increase in leukemia. But 21 you do not. The studies that I have 22 shown to mechanics show that there is 23 no increase in AML. Therefore, the 24 cases that occur are spontaneous and 25 de novo rather than benzene caused. 191 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 These people are not immune to de novo 3 leukemias. They will get it just like 4 anybody else. 5 BY MR. DuPONT: 6 Q. But in your opinion you can get 7 leukemia from no known cause, even though you 8 have exposure to a known cause of leukemia? 9 That's your opinion? 10 A. Of course. 11 Q. Okay. And it's your opinion 12 that you can get leukemia from no known cause 13 even though you have an occupational exposure 14 for 40 years to a known cause of leukemia? 15 A. Of course. 16 Q. And it's your opinion that some 17 of those 80 percent of the individuals with 18 AML that you attribute to no known cause 19 leukemia had 40 year occupational exposure 20 history to benzene? 21 A. Yes. 22 Q. Have you now described for me 23 your opinions on de novo AML generally and 24 specifically? 25 A. Yes. With the understanding 192 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 that I have already previously discussed the 3 genetic differences between de novo AML and 4 solvent related AML, and that plays into the 5 -- my overall opinions. 6 Q. All right. Are there any 7 articles that conclude or state or opine that 8 you cannot rule in or out de novo leukemia as 9 a cause of AML? 10 A. I know of no article that has a 11 test for de novo leukemia. It's a diagnosis 12 of exclusion. That rules it in or out. You 13 rule it out if you have another cause. So 14 someone who has chemotherapy with Cytoxan at 15 age 18 and two years later gets a 5 minus, 7 16 minus leukemia, you've ruled out de novo 17 leukemia. 18 Q. You rule out de novo leukemia 19 if you have a 40 part per million cumulative 20 dose of exposure to benzene? 21 A. If you had 40 part per million 22 chemo dose exposure to benzene that ended 23 20 years ago and you have chromosomes that 24 are normal now, I would rule out that 25 benzene, yes. 193 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. If you have a 40 part per 3 million cumulative dose of exposure to 4 benzene that ended less than 20 years ago, 20 5 years from diagnosis, do you rule de novo 6 leukemia as the cause of the AML, you rule 7 that out? 8 A. No, I don't rule out de novo 9 leukemia. I look at the chromosomes, I look 10 at the exposure in the last 10 years and I 11 would reach a judgment. 12 Q. Can you opine that somebody's 13 leukemia and AML specifically was caused by 14 benzene exposure solely based on their 15 chromosomes? 16 A. No. 17 Q. All right. Your last opinion 18 is that the presence of psoriasis did not 19 increase David Gerchman's dermal absorption 20 of benzene. Is that correct? 21 A. Yes. 22 Q. Do you hold that opinion? 23 A. Yes. 24 Q. Let me back up. I don't think 25 I got an answer. Are there any articles that 194 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 conclude or opine that you cannot rule in or 3 out de novo AML as a cause of AML? 4 A. Every article that has an 5 article about AML with a known cause opines 6 inferentially that de novo leukemia was ruled 7 out in that particular case. 8 Q. Well, inferentially, that's 9 your interpretation of the article. Are 10 there any articles where the authors have 11 written that you can or you cannot rule in or 12 out de novo AML? 13 A. I have no -- know of no article 14 that says, in this case of leukemia which was 15 caused by Cytoxan, we have ruled out de novo 16 AML. 17 Q. Has anyone written an article 18 that says that there is a method for ruling 19 in or out de novo leukemia as a cause of AML? 20 A. I don't know whether someone 21 has said that it's a diagnosis of exclusion, 22 but it's relatively obvious. 23 Q. Is there any article that you 24 can point me to that shares the opinion that 25 you cannot rule in or out de novo AML? 195 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. I have answered the question. 3 Q. Can you cite for me an article 4 that says you can or cannot rule in or out de 5 novo AML? 6 A. I know of no specific article 7 to tell you. 8 Q. Okay. Presence of psoriasis 9 did not increase dermal absorption. What's 10 your basis for that opinion? 11 A. I think it likely that his 12 psoriasis was plaque psoriasis, chronic 13 plaque. I don't have pictures. But the fact 14 that he was self managing and presumably able 15 to have skin exposed to solvents or chemicals 16 argues against having ulcers or other types 17 of psoriasis. 18 Assuming it is chronic plaque, 19 that is thickened skin, which in principle 20 should be a variable to absorption rather 21 than. There are studies that have looked at 22 absorption of steroids and salicylates when 23 applied topically to psoriasis and shown no 24 increased absorption or evidence of 25 substantial absorption. And it is relevant 196 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 that there is a long history of treating 3 people with psoriasis topically with coal 4 tar, which has contaminant level benzene in 5 it. And that coal tar is not known or felt 6 to be a carcinogen or leukemogen and is still 7 approved by FDA for use in psoriasis. 8 Q. And how long has coal tar been 9 approved by the FDA for use in psoriasis? 10 A. I don't know. 30, 40 years 11 maybe. 12 Q. And is it still approved by the 13 FDA for use in psoriasis? 14 A. As far as I know, yes. 15 Q. Do doctors still prescribe coal 16 tar for use in treating psoriasis? 17 A. I'm not a dermatologist, I 18 can't answer how often it's still prescribed. 19 Q. I didn't ask how often, I just 20 asked is it still prescribed? 21 A. To my knowledge, the answer is 22 yes, but I'm not a dermatologist. 23 Q. Have you looked at any articles 24 that addressed the rate or amount or manner 25 of benzene exposure through the skin in 197 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 individuals with psoriasis? 3 A. No. I have not been able to 4 find such articles. 5 Q. What articles do you rely upon 6 for your opinions that the presence of 7 psoriasis did not increase dermal exposure of 8 David Gerchman to benzene? 9 A. I have the article by Wester, 10 which was previously discussed, that talks 11 about plaque having very little effect, but 12 some, on water loss, which is not the same as 13 absorption. In terms of absorption, there is 14 a -- sorry, the Wester article talks about -15 I misspoke. The Wester talks about 16 absorption of hydrocortisone and there is no 17 difference in absorption when they applied 18 hydrocortisone to a psoriatic area versus a 19 normal area. 20 And there is an article I have 21 only in an abstract by Gip that talks about 22 absorption of betamethasone and salicylic 23 acid and found that there was no change in 24 plasma cortisol levels, which argues against 25 any absorption of betamethasone. And there 198 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 was no detectable salicylate levels in the 3 plasma, which tells you that that was not 4 absorbed. So those are the two articles. 5 Q. Is it your opinion that 6 hydrocortisone and benzene are absorbed 7 through the human skin the same way and at 8 the same rate? 9 A. I don't know whether that's 10 true or false. I have no data to answer that 11 question. 12 Q. Is it your opinion that benzene 13 and betamethasone are absorbed through the 14 human skin in the same way and at the same 15 rate? 16 A. I have no data to answer that 17 question. 18 Q. Is it your opinion that 19 salicylic -20 A. Salicylic, like aspirin, but 21 it's not acetylsalicylic acid, it's just 22 salicylic acid. 23 Q. Okay. Salicylic acid, is it 24 your opinion that salicylic acid and benzene 25 are absorbed through the human skin in the 199 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 same way and at the same rate? 3 A. I have no data to answer that 4 question. 5 Q. Have you seen any testimony 6 that there were, in fact, open sores on David 7 Gerchman's skin from his psoriasis -8 A. No. 9 Q. -- or is it your assumption -10 I'm sorry, you have not seen that testimony? 11 A. I have not seen testimony about 12 open sores. I have seen testimony about 13 discolored lesions which sound like plaque, 14 but I have not seen open sores. 15 Q. If there were open sores on 16 David Gerchman's skin from psoriasis, would 17 that change your opinion that the psoriasis 18 did not increase his dermal absorption of 19 benzene? 20 A. If there were open, weeping 21 ulcers, what I said would not apply. That 22 would not mean that absorption was increased. 23 It would mean that it would not apply. 24 Q. If there were open sores on 25 David Gerchman's skin from psoriasis, would 200 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 his dermal absorption to benzene have been 3 increased? 4 A. Unknown. 5 Q. Unknown? 6 A. Unknown to me. 7 Q. Okay. Do you agree that 8 benzene has the same capability of causing 9 AML if it is absorbed through the human skin 10 as it does as if it's inhaled through the 11 lungs? 12 MR. THOMPSON: Hold on a second. 13 Objection, form and foundation. 14 THE WITNESS: I think if a 15 benzene molecule gets to the bone 16 marrow, it doesn't matter how it was 17 absorbed. Whether or not there is a 18 different handling of benzene that 19 goes -- comes from the skin, 20 putatively absorbed from the skin as 21 opposed to benzene that's inhaled, I 22 don't know. 23 BY MR. DuPONT: 24 Q. Okay. Will you take your 25 articles on psoriasis and we will mark those 201 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 as Exhibit 11, I think. Triebig should have 3 been 10. I want to mark your latency 4 article, if it's not already marked, as 5 Exhibit 10. 6 --7 (Whereupon the documents were 8 marked, for identification purposes, 9 as Sarna Exhibit Numbers 10 and 11.) 10 - - 11 BY MR. DuPONT: 12 Q. Exhibit Number 11 should be the 13 Wester and Gip, which are all the articles 14 that you relied upon and considered for your 15 opinions that the presence of psoriasis did 16 not increase the dermal absorption of benzene 17 by David Gerchman. Is that fair? 18 A. The articles, yes, but I did 19 comment on the coal tar issue. 20 Q. Have you brought any articles 21 with you that we have not marked as exhibits? 22 A. Yes, but I'm not sure they're 23 relevant. Some of them were dealing with the 24 comments of your other doctors. Some of them 25 were dealing with the issue of low level 202 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 exposure. There is Hayes from the CAPM 3 study. There's the Collins article. There's 4 some articles on autoimmune diseases, which I 5 guess relate to psoriasis that I can pull. 6 There's an IOM report by Miller and a letter 7 by Miller regarding the three case controlled 8 studies which are going to be nested on dose. 9 There's some articles that -10 Q. Let me ask you this: Have we 11 marked as exhibits all the articles you are 12 relying upon for your opinions? 13 A. Yes. But some of them are 14 relevant to the comments on Dr. Shadduck or 15 Dr. Harrison in terms of dose response. So 16 some of these are issues in terms of the 17 question of dose level. And I'm not citing 18 them to support me, but if someone cites them 19 to reach another conclusion I have them for 20 discussion. 21 Q. Okay. 22 A. So I'm not citing CAPM data, 23 but if someone wants to discuss why CAPM data 24 is not a valid tool to say that low level 25 benzene exposure causes leukemia, I have such 203 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 data available. 3 Q. All right. So what articles 4 did you bring with you on the CAPM issue and 5 what are your opinions on the CAPM study? 6 A. I brought with me Hayes, but 7 the opinions depends upon more than Hayes. 8 The Hayes article would claim, I think, less 9 than 10 part per million year and it has an 10 increased risk. But the Hayes article in the 11 control group does not consider leukemia NOS, 12 or not otherwise specified. And that makes 13 the control group very uncertain. And the 14 numbers are small enough that that could make 15 a difference. And the Hayes group is not 16 properly controlled for age. When you take a 17 look at Yin's article about the breakdown of 18 CAPM, those people who are over 30 and entry 19 on the study make up 16 percent of the 20 exposed group rather than 10 percent of the 21 control group. So one has to correct for 22 that, not just the size of the control group 23 in general and the size of the overall group. 24 And that means that the overall risk factors 25 that they come up with are inflated. And how 204 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 those risk factors fit into the dose 3 dependent risk is uncertain. 4 MR. CARR: Andrew, this is Carr, 5 just for the record. Some of the 6 studies that he brought with him have 7 some relevance to Glass and some other 8 issues. I do intend to ask him 9 questions about those studies in this 10 case. I would get copies -11 BY MR. DuPONT: 12 Q. Have we exhausted your comments 13 on the CAPM data? And for CAPM, we're going 14 to abbreviate that C-A-P-M, and that stands 15 for the Chinese Academy of Preventative 16 Medicine. 17 A. Yes. It's actually CAPM NCI, 18 but that's fine. 19 Q. Right. Have you given us all 20 of your analysis on the CAPM data that you 21 find relevant to this case? 22 A. Well, certainly I have not 23 given the details, but I have given you the 24 framework. 25 Q. Okay. Where do we find the 205 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 details? 3 A. I would have to generate them. 4 Q. Can you tell me what the 5 details are now? 6 A. No. Because they are the 7 specific numbers. Taking a look at the 8 specific numbers of people in each group with 9 specific odds ratios they came to. What the 10 odds ratio is grossly, just taking 75,000 and 11 35,000, or whatever the numbers are for the 12 two groups. How they allegedly controlled 13 for age, but came out with a higher odds 14 ratio rather than a lower one. Looking at 15 the age distribution of the leukemic patients 16 that are described by Travis in a different 17 population, where something like 80 percent 18 of them were in their forties or older, 19 meaning that they were entered in the cohort 20 in their thirties. And that's where the 21 leukemia linked. So it would require going 22 through those details, which I don't have in 23 front of me. But that's the framework. 24 Q. Okay. So anything beyond that, 25 you're not able to provide me at this time? 206 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. I have told you those -- I 3 don't have the details to provide you at this 4 time. I have the framework, which I have 5 provided you. 6 Q. Okay. And do you have all the 7 articles with you that you used for your 8 analysis on the -9 A. No, I didn't bring every CAPM 10 article with me. You have to go to the 11 Travis article, and one of the Yin articles. 12 You have to break down by age. And the 13 Travis article, to get the break down of the 14 age of the leukemic patients, they weren't 15 analyzed. It's not all in one article. You 16 have to look widely. 17 Q. So I can't discuss those 18 articles with you in detail today? 19 A. I did not provide a detailed 20 part of that. Again, that's more of a 21 rebuttal issue than a proactive issue. I 22 don't claim to support that, it's not a 23 proactive statement that tells me that the 24 risk is only at high levels. It is a 25 reactive statement that tells me if your 207 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 experts argue the CAPM data, and I did not 3 see that argued by them in their deposition 4 or sheets. So I did not provide that 5 rebuttal data. But should they make that 6 argument beyond that, I have those comments. 7 Q. All right. What are the 8 comments you can give me today on the Health 9 Watch study series? 10 A. Glass in 2003 and then 2005 11 came out with a nested case control of 12 something like 32 or 33 leukemics. Something 13 like 11 of which were AML. As to relative 14 risk function of exposure, it came to the 15 conclusion that at two parts per million 16 exposure and higher there is increased risk. 17 At face value, when you look at 18 how many people have that exposure, this 19 would suggest that the relative risk as 20 compared to a control group, SIR or SMR, 21 should be roughly three. But the Gunn 22 article shows that there's no increase in 23 leukemia and in AML there's no increase in 24 SMR or SIR in leukemia. So that at face 25 value doesn't make any sense. 208 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Then when you go on to look at 3 how many people who got leukemia had all time 4 high exposure with greater than 32 part per 5 million years, an exposure of concentrated 6 benzene, they had -- were in the highest 7 exposure group, and the odds ratio was 8 something like eight or nine to one or 9 higher. And there was something like nine 10 patients in that group where one was 11 expected. 12 That means in the lower group, 13 which is everything below the high exposure 14 group, there was 23 patients expected. And 15 based upon the odds ratios, that was double 16 or triple what you expected, but that has to 17 be less than what you expected because there 18 was no increased risk. 19 So the whole thing makes no 20 sense unless the control group, which is low 21 exposure, had much fewer cases. 22 Apparently in the Millers 23 article, IOM report of the plans for the 24 pooled article between the Canadian, UK and 25 Australian case control studies, the authors 209 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 of the Australian study, which I presume are 3 Deborah Glass and others, admit there's a 4 problem with their data and it is uncertain. 5 Q. Is it your understanding that 6 the Gunn study that you referred to and the 7 Glass 2005 were nested case control studies, 8 the same nested case control study as the 9 Glass 2003? 10 A. Gunn is a cohort study. I 11 never said it was a nested case control. It 12 gives you SMR and SIR. It's the same Health 13 Watch population, but it's the cohort study. 14 Q. All right. And the Glass 2005, 15 the cohort study, is a nested case control 16 study? 17 A. Nested case control. The major 18 publication is 2003, but in 2005, they go 19 into the high exposure group. 20 Q. Have you seen any data or 21 information concerning the study that 22 combined the three petroleum distribution 23 cohorts -24 A. Only the Shell Oil letter -25 Q. I haven't finished my question. 210 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 -- beyond the letter that Shell 3 sent to the EPA reporting statistically 4 significant increased risks of MDS at 5 cumulative doses of 4.5 to 45 part per 6 million years? Have you seen any data or 7 commentary for inclusions from that study 8 beyond the letter that was sent to the EPA? 9 A. No. Although I will comment 10 that had there been a low risk of leukemia, I 11 would have expected that they would have been 12 duty bound to report that. And the absence 13 of such a statement makes me wonder whether 14 no such finding occurred. 15 Q. Do you know if they looked at 16 the risk of leukemia? 17 A. Well, the original case 18 controls, as far as I know, looked only at 19 leukemia and didn't look at MDS. So I was 20 surprised to see information come out on MDS. 21 If they did not look at leukemia, they failed 22 the intent of pulling the data. 23 Q. Okay. So my question to you 24 was, do you know if they looked at leukemia? 25 A. I know they were supposed to 211 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 look at leukemia. I don't know whether they 3 did what they were supposed to do. 4 Q. Okay. So you don't know if 5 they looked at leukemia; correct? 6 A. As a matter of fact I do not 7 know. As a matter of conjecture, I would be 8 shocked if they didn't do it. 9 Q. Have you seen any document that 10 sets forth the intent or the goal or the 11 design of that study? 12 A. Yes. 13 Q. What document is that? 14 A. An article by Miller I believe 15 talks about that. 16 Q. So you believe Miller's IOM 17 report sets forth the objectives and the 18 study design of that combined cohort study 19 that Shell reported to the EPA? 20 A. There was an article by Miller 21 separate from the IOM report too that was 22 shorter. 23 Q. Okay. So which article do you 24 contend provided the goal and the design for 25 the combined petroleum distribution marker 212 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 cohort study that was reported to Shell? 3 A. There's more than one, but the 4 information I have now is published, Miller, 5 et al., International Archives, Occupational 6 and Environmental Health, 2010, Volume 83, 7 page 69 through 76. 8 Q. All right. Let's make that the 9 next exhibit, please. 10 - - 11 (Whereupon the document was 12 marked, for identification purposes, 13 as Sarna Exhibit Number 12.) 14 - - 15 THE WITNESS: This was talking 16 about the exposure assessments, which 17 were a prelude to that. There may be 18 another article that talks about the 19 plan that I don't have with me. But 20 this talks about the visits to the 21 assure exposure measurements were the 22 same in preparation for that study. 23 Let me take a look at the IOM 24 report. 25 (Reviewing document.) 213 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 The IOM report talks about the 3 advantages of a pooled analysis. It 4 talks about how it should be done and 5 talks about pathology review. I'm not 6 sure it exactly sets out what it is, 7 but it's preliminary to it and fairly 8 talks about leukemia. 9 --10 (Whereupon the document was 11 marked, for identification purposes, 12 as Sarna Exhibit Number 13.) 13 - - 14 BY MR. DuPONT: 15 Q. Is it your opinion that 16 Exhibit 13, the IOM report, sets forth the 17 study design and objectives for the combined 18 case control study that Shell reported to the 19 EPA? 20 A. The IOM report audited the 21 three in preparation for the study. 22 Q. So it does not set forth the 23 plan or the design of the objectives? 24 A. I don't see a clear distinct 25 plan. I believe there is another article, 214 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 which I did not bring, that has that. But 3 the IOM report and the Miller report 4 elsewhere talk about preparation for this 5 article rather than the specific study. 6 Q. Can you identify for me any 7 other article in which you believe the plan 8 and the objective and the goal of the 9 combined case control study of petroleum 10 distribution workers at Shell published to 11 the EPA has set forth? 12 A. I can tell you I believe there 13 is such an article, but I can't give you the 14 details of it now. 15 Q. Are there any other articles 16 that you brought with you that are relevant 17 to your opinions in this case, including your 18 analysis of Dr. Shadduck, Dr. Harrison and 19 Mr. Petty, that we have not marked as 20 exhibits? 21 A. Did you want the Glass exhibit 22 marked? 23 Q. Glass 2003? 24 A. Yeah. 25 Q. Okay. 215 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. And do you want Glass 2005 3 marked? 4 Q. Might as well. 5 --6 (Whereupon the documents were 7 marked, for identification purposes, 8 as Sarna Exhibit Numbers 14 and 15.) 9 --10 THE WITNESS: And did you want 11 Hayes marked? 12 BY MR. DuPONT: 13 Q. Yes. 14 - - 15 (Whereupon the document was 16 marked, for identification purposes, 17 as Sarna Exhibit Number 16.) 18 - - 19 THE WITNESS: The other issue as 20 long as I'm -- well, one of the issues 21 that we have not discussed that you 22 asked about my comments on your other 23 experts would be the issue of 24 hematoxicity at low dose benzene. 25 These were cited as some as if they 216 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 indicated a low dose benzene caused 3 leukemia. There were -- article by 4 Ward that was cited I think by Dr. 5 Harrison in this regard. Ward was the 6 pliofilm study and did show that 7 people with low exposure may have some 8 changes in their blood counts. But 9 those people did not get leukemia. 10 We know from the pliofilm study 11 that however you want to use the 12 metric, at least it was 40 part per 13 million years, if not 200 part per 14 million years, that in that study the 15 threshold -- so, yes, there was 16 hematologic toxicity, but that doesn't 17 mean that there was leukemogenesis. 18 That's a totally separate issue. One 19 does not relate to the other. 20 And there was articles by I 21 think Land, which were quoted as 22 showing hematoxicity at low levels of 23 benzene. And I would just point out 24 that those were in the later article 25 by Land, found to be dependent upon 217 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 specific genotypes. And this is 3 limited to people who are Chinese. So 4 how that applies here is unclear. 5 And, again, that doesn't mean 6 that there was an increased risk of 7 leukemia. If you choose to use 8 abnormal blood counts as a marker of 9 benzene exposure, it should be noted 10 that there was no abnormal blood count 11 in June of 2007 when Mr. Gerchman had 12 a blood count. 13 Then there was something else 14 that I wanted to discuss. Yes. The 15 Iron study was quoted as evidence that 16 only 24 percent of patients with 17 benzene associated -- benzene caused 18 leukemias have chromosomal 19 abnormalities. This was, one, 20 myelodysplasia, not leukemia. Two, 21 the people with high benzene exposure 22 had abnormal eosinophil precursors, 23 which are not normally found. And if 24 that is a unique syndrome to China 25 with a specific genetic abnormality 218 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 that doesn't show up on a karyotype, 3 that's fine. If I see someone with 4 MDS, and abnormal eosinophils, I would 5 not think that abnormal karyotype in 6 that particular syndrome is necessary. 7 But that syndrome is not relevant 8 here. 9 The people with lower exposure 10 may or may not have benzene caused 11 MDS. We have no information on 12 whether this population was at 13 increased risk or not. So as we 14 discussed before, people who have been 15 exposed to benzene don't mean that 16 their leukemia was caused by benzene. 17 But let me take my -18 - - 19 (Discussion held off the 20 record.) 21 - - 22 BY MR. DuPONT: 23 Q. Are all of the studies that you 24 rely upon for your own opinions, as opposed 25 to your analysis of the opinions of Dr. 219 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Shadduck and Dr. Harrison, the ones you 3 already identified for us when I asked you 4 about your opinions? Are the remaining 5 articles that you have with you those which 6 are -- those that are identified in your 7 critique of Dr. Harrison and Dr. Shadduck? 8 A. There's the Collins article, 9 which deals with peak exposure, so I don't 10 know whether you want to consider that. I 11 have the Gunn article which you haven't 12 marked. I don't know whether you want to 13 mark Gunn. 14 Q. Can you answer my question, 15 please. Are the articles that you have left 16 in your stack that we have not marked as 17 exhibits, articles that you have brought 18 because of your critique of Doctors Harrison 19 and Shadduck, or articles that you are 20 relying upon for your primary opinions in the 21 case? 22 A. I would say Collins would be 23 supportive of my primary opinions since it 24 showed little increased risk of leukemia with 25 cumulative dose. 220 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. CARR: Dr. Sarna, and I hate 3 to interrupt. I think he's asking you 4 a more basic question, and that is, 5 you have a stack left. Do you either 6 rely on everything in the stack for 7 the criticisms of his experts or are 8 you relying on it in your opinions in 9 this case? He just wants to know 10 whether -11 THE WITNESS: Criticism of your 12 experts. 13 MR. CARR: Okay. For everything 14 in the -15 BY MR. DuPONT: 16 Q. And those criticisms and your 17 analysis of those articles are set forth in 18 your notes and comments that we have marked 19 as Exhibit 4; correct? 20 A. If -- my expectation is that 21 the articles that I cited and for my position 22 are in the notes and comments. Again, I will 23 report, this was not a report and thus it is 24 not complete with every article that supports 25 my opinion. There are general articles that 221 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 may support my opinion that I have not 3 provided. But these are the ones that I felt 4 were appropriate to provide with my notes. 5 But it is not a report. 6 MR. CARR: Andrew, can I take a 7 shot at this? 8 BY MR. DuPONT: 9 Q. All I want to know, Doctor, is: 10 Have you told me about all the articles that 11 you're relying upon in support of your 12 primary opinions in this case? 13 A. My best answer is, yes. I'm 14 not sure that every article -15 Q. Okay. Thank you. 16 MR. CARR: Wait a minute, you 17 cut him off. 18 MR. THOMPSON: He's got a 19 qualifier there, sorry. 20 THE WITNESS: I'm not sure that 21 every article has been provided you 22 and there are some times that I have 23 discussed things that I don't have the 24 reference for, but are in my general 25 knowledge. But I have discussed them. 222 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 BY MR. DuPONT: 3 Q. All right. To the extent that 4 you have been able to identify an article 5 that has not been provided, you have 6 identified it for me; correct? 7 A. Yes. 8 MR. THOMPSON: Other than that 9 he has a whole stack right here, dude. 10 MR. DuPONT: No, no, no, no. 11 MR. THOMPSON: These are 12 articles you looked at. What do you 13 mean, no? You know, Andrew, the 14 problem is, like I said, you're in 15 Philly and we are here. And he has a 16 stack of stuff -17 MR. DuPONT: The problem is I 18 have spent five and a half -- five 19 hours and 45 minutes going through the 20 Doctor's opinion, having the doctor 21 identify what he relies upon for those 22 opinions. And now I have an attorney 23 saying, oh, by the way, let's add 24 these other articles which the doctor 25 on his couldn't identify and now I as 223 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 the attorney want to identify and help 3 him. That's the problem. 4 MR. THOMPSON: That's just a 5 bunch of crap. 6 MR. DuPONT: That's why I'm 7 saying that -8 MR. THOMPSON: If you were in 9 the room with us, which most lawyers 10 are for most depositions, you would 11 see the stack that's sitting to his 12 immediate right and you could ask him. 13 The complication is, you're trying to 14 take this remotely, man. And he's 15 also got six boxes -16 MR. DuPONT: That's not a 17 complication. He's already given his 18 opinions. 19 MR. THOMPSON: It is. 20 MR. DuPONT: Now you're changing 21 them. 22 MR. THOMPSON: It is a 23 complication. They're sitting right 24 here. Do you want him to identify 25 them or not? 224 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. DuPONT: He just answered 3 the question. He just answered the 4 question again. 5 MR. THOMPSON: All right. Well, 6 I'm telling you, there's a stack of 7 articles right here that you need to 8 go through if you want to fully 9 explore the doctor's opinions. 10 There's also six boxes of stuff behind 11 him that he's read and you're not 12 touching any of that, so do whatever 13 you want to do. But I'm telling you 14 right now, we're prepared to continue 15 to let you ask questions. If you 16 don't want to, no problem. Go for it. 17 BY MR. DuPONT: 18 Q. Doctor, you have identified for 19 me and marked as exhibits all of the 20 documents and articles that you have relied 21 upon for your opinions, your primary opinions 22 in this case -23 MR. CARR: No, because he's got 24 -25 BY MR. DuPONT: 225 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. As opposed to your analysis of 3 the plaintiffs' experts; correct? 4 A. I can't limit myself to the 5 things that I brought because this is not a 6 formal report. And there are articles that 7 are in my reasonable background. I have told 8 you about a bunch of CAPM articles that I 9 have not done. There may be other articles 10 in other areas that I have not brought. So I 11 don't want to be limited to the articles that 12 I have brought. But I brought those articles 13 that support that. I can tell you that these 14 -15 Q. And to the extent that the -16 MR. CARR: I'm sorry, I'm not 17 going to allow you to cut this one 18 off. Doctor, please finish your 19 answer. 20 BY MR. DuPONT: 21 Q. To the extent -22 MR. CARR: Doctor, please finish 23 your answer. 24 BY MR. DuPONT: 25 Q. To the extent that you -- 226 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 MR. CARR: The witness is 3 talking, Andrew. 4 THE WITNESS: Of the pile that I 5 have, I believe I have given you the 6 ones that I would consider proactive 7 rather than reactive. However, I 8 would reserve the right to be reactive 9 with the others. And I have 10 brought -11 BY MR. DuPONT: 12 Q. That's what I'm trying to sort 13 out. 14 A. I have not brought all the 15 articles that would be in the background of 16 my opinions. 17 MR. THOMPSON: You also -18 BY MR. DuPONT: 19 Q. That's what I'm trying to sort 20 out. To the extent there's an article that 21 supports and you rely upon for your opinions, 22 your primary opinions, your affirmative 23 opinion, we have marked them as exhibits. Or 24 if you haven't brought it with you, you have 25 identified it to the best of your ability; 227 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 correct? 3 A. May I have that again, please? 4 Q. To the extent that there is an 5 article that you rely upon for support of 6 your affirmative opinion, this would be your 7 critique of the plaintiffs' experts, we have 8 marked those as exhibits. Or to the extent 9 you can identify the article and have not 10 brought it with you, you have identified it 11 for me to the best of your ability. Correct? 12 A. Yes. But I reserve the right 13 to have other articles, which are the basis 14 of my opinion that I have not presented to 15 you because I have not filed a formal report. 16 I have talked generally, I have done my best 17 to quote the articles as specifically as I 18 can. But there may be things that I have 19 missed and if I'm able to identify them and 20 they're part of the body of literature and 21 they're a background to my opinion, I would 22 want to be able to bring them forth. 23 Q. You understand that this is my 24 opportunity to ask you what those articles 25 are. 228 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. And I'm doing my best to 3 answer. That's why I brought the pile and 4 that's why I have answered the best that I 5 can. 6 Q. Okay. And what you have with 7 you in your pile of articles that has not yet 8 been marked as an exhibit, or you did not 9 identify when I asked you what your primary 10 opinions are, that pile of articles are 11 articles that you're using to address the 12 plaintiffs' expert's opinion? 13 A. They would be reactive to the 14 plaintiffs' opinion or to issues that could 15 be brought up whether the plaintiffs' experts 16 brought them up or not. 17 Q. Okay. And are your comments on 18 those articles that you have brought with you 19 and have not been marked yet, and what you 20 are terming reactive or reactive opinions, 21 are your comments on those articles set forth 22 in your written notes and comments? 23 A. Not entirely, no. 24 Q. How many articles do you have 25 left that we haven't discussed? 229 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. We have discussed Gunn, but it 3 has not been made an exhibit. I have two 4 articles that Dr. Williams quoted. Or one 5 article that she quoted regarding psoriasis 6 by ^Godelli. I've got a couple of articles 7 on autoimmune disease related to psoriasis 8 that I don't need. I've got statements as to 9 OSHA and NIOSH levels, which are not 10 important. 11 I've got an NPM1^ article, 12 which is reactive to a comment by Dr. 13 Shadduck, but not of critical value. It's 14 just I disagree with him about an unrelated 15 point. 16 I've got the original case 17 control study by Rushton and by Schnatter. 18 That would be the two other nested case 19 control studies that will be part of the 20 pooled analysis. 21 I've got Trangch^ report by 22 Talbot. I've got ^Wynell report, which is 23 reactive to a comment I think by Dr. 24 Harrison. I've got the Zheng article, which 25 is relevant to the psoriasis I believe and 230 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 was quoted by one of your doctors regarding 3 obesity, but it doesn't talk about obesity. 4 I've got an article about DNA 5 damage, DNA repair, which isn't directly 6 related to it. But it talks about why you 7 may have increased risk of leukemia with age 8 because of decrease in DNA repair. I've got 9 a ^Nielson article which I pulled because I 10 thought that was the article your author went 11 -- Dr. Harrison was referring to, but it 12 wasn't. So it's not relevant. I've got 13 another copy of Rushton. I've got Bonds 14 because your author -- one of your experts 15 pulled it, I think Harrison. I've got Klu^ 16 because I think Harrison quote that in terms 17 of effects on the --the only one that is 18 worth discussing at least briefly would be 19 Collins. Dr. Petty I think talked about peak 20 levels that were low, but what he called 21 peak. And I just pointed out that the only 22 relationship that Collins found with peak 23 levels was greater than 100 parts per million 24 times 40 days, which certainly doesn't apply 25 here. 231 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Q. Okay. So out of those articles 3 you just went through, the only ones you feel 4 worth commenting on is Collins? 5 A. Right. I also got Irons in my 6 pile. Another article that was quoted 7 regarding psoriasis, but not relevant, and 8 the Shell letter. And Dr. Harrison's notes. 9 That's what I've got. 10 Q. Okay. The Irons study is the 11 study you already told me about. Again, in 12 the 24 percent of patients with benzene? 13 A. Yes. Those haven't been 14 admitted, but some of them have discussed. 15 The only one that hadn't been discussed that 16 I would consider relevant was Collins, which 17 I just told you about. 18 Q. So the ones you consider 19 relevant are Ward, Lan, Irons and Collins? 20 A. Yes. But Ward is -- Ward is 21 relevant, Lan -- yes, those are relevant. 22 Q. Okay. Let's mark Ward. And 23 you have given me your comments on Ward; 24 correct? 25 A. I have given you my comments on 232 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 Ward, yes. And two articles by Lan. 3 --4 (Whereupon the documents were 5 marked, for identification purposes, 6 as Sarna Exhibit Numbers 18, 19, 20 7 and 21.) 8 --9 THE WITNESS: I don't know 10 whether we ever marked the Martyn 11 Smith article as one. I don't know 12 whether you want that marked. 13 BY MR. DuPONT: 14 Q. All right, we'll mark Martyn 15 Smith's article as 22. And you have given me 16 your comments on that; correct? 17 A. Yes. 18 - - 19 (Whereupon the document was 20 marked, for identification purposes, 21 as Sarna Exhibit Number 22.) 22 - - 23 BY MR. DuPONT: 24 Q. Does that exhaust the list of 25 articles that you think are relevant and 233 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 worthy of discussing? 3 A. You had Triebig, we gave you 4 that, I got a second copy of that, yes, in my 5 pile. That would be it. 6 Q. The Triebig we'll make sure 7 that's been marked, and if it hasn't been 8 marked already we'll mark it. 9 Are we now done with the 10 articles in your comments and articles that 11 you believe are relevant and worthy of 12 discussing? 13 A. Certainly we're done with the 14 articles that I have identified to bring with 15 me. 16 Q. Okay. How long does the 17 hematotoxic effect of benzene exposure in the 18 blood remain? In other words, how long do 19 blood counts remain depressed after benzene 20 exposure? 21 A. I don't have an answer from the 22 literature on that. My expectation is that 23 it lasts no more than several days to a week 24 or two, but I don't know that. 25 Q. All right. You don't know one 234 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 way or the other? 3 A. I have not seen a study that 4 defines it. 5 Q. All right. Those are all the 6 questions I have. 7 I'm sorry, the boxes of 8 documents that you have, are those discovery 9 materials? In other words, deposition 10 transcripts and documents from the 11 defendants? 12 A. Largely they're medical records 13 and transcripts. There are some gas 14 chromatographs which I frankly didn't look 15 at. And there are some benzene content 16 measurements for various products that are 17 there. Certificates of Analysis, and what I 18 gleaned from them is in my written report. 19 But those are there. 20 Q. Have all of your observations 21 based on the defendant documents, I'll call 22 them, the documents that are not transcripts 23 and not medical records and not the articles 24 that we have been going through, have all of 25 your observations based on the defendant 235 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 documents been set forth in your notes and 3 comments? 4 A. Well, I think the -- I did not 5 mention when you asked me about my 6 qualitative view of exposure, that the 7 Certificates of Analysis showed low levels of 8 contaminant level benzene. And that would be 9 supportive that my exposure was -- that 10 exposure particularly in the last 10 years 11 was trivial. 12 Q. Do you have separated the 13 documents from the defendants that you have 14 reviewed and considered in coming to your 15 opinion? 16 A. Have separated as to how or 17 what? 18 Q. In other words, do you have the 19 documents that you have reviewed and relied 20 upon in coming to your opinions that have 21 come from the defendants, that are not 22 transcripts and are not medical records and 23 are not articles, do you have them in one 24 location, one folder, one stack that we can 25 easily identify? 236 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. No. They're scattered to the 3 winds, as all of my articles were. I got six 4 boxes that are full of stuff in no particular 5 order. 6 Q. Okay. To the extent that you 7 considered information from the documents 8 provided to you by the defendants, have you 9 identified those documents in your report? 10 A. My document, as I mentioned, 11 was notes with comments. And I took notes as 12 I evaluated things. So if they were 13 important to me or relevant that I thought 14 they should have been put on paper they're in 15 my notes. A lot of the things are not 16 important, but were just relevant as note 17 taking as I reviewed things. 18 Q. Okay. I'm not really concerned 19 about whether we characterize Exhibit 4 as 20 your report or your notes and comments. I 21 just want to make sure that if you reviewed 22 and relied upon and found important a 23 document from one of the defendants, did you 24 identify that document in your notes and 25 comments? 237 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 A. Yes. 3 Q. Do you have any notes that you 4 have made concerning this case that are not 5 set forth in your notes and comments? 6 A. Again, I didn't -- I've quoted 7 to you some articles that may not be listed 8 in my notes. So those I have discussed with 9 you, but they may not be in my notes. Other 10 than that -- and articles that I have not 11 been able to identify, my answer would be, 12 no. 13 Q. Okay. So there's no other 14 document where you have written down 15 observations or made notes as you were going 16 through transcripts or other documents? 17 A. I have some handwritten notes 18 behind me that are chicken scratch and 19 illegible and largely led to them being in my 20 report if they were relevant. I think the 21 accurate answer is that it would be a waste 22 of your time to go through them. But if you 23 want to try to decipher my handwriting, 24 you're welcome to. 25 Q. Well, let's attach them as an 238 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 exhibit anyway. 3 --4 (Whereupon the document was 5 marked, for identification purposes, 6 as Sarna Exhibit Number 23.) 7 --8 BY MR. DuPONT: 9 Q. Have those handwritten notes 10 been transcribed into your notes and comments 11 that's Exhibit 4? 12 A. Anything that's important, yes. 13 Q. Those are all the questions I 14 have. 15 (Discussion held off the 16 record.) 17 MR. THOMPSON: I propose that we 18 stipulate to relieve the court 19 reporter of duties and 20 responsibilities under the California 21 Code. 22 The original of the transcript 23 will be sent to Dr. Sarna as early as 24 possible, early next week, Monday or 25 Tuesday is the target. Dr. Sarna will 239 1 GREGORY PAUL SARNA, M.D. - ROUGH 2 have until the 9th of August to read 3 and sign, and we'll alert counsel by 4 letter or notification of any changes 5 that are made. 6 If either that does not happen 7 or the transcript is unavailable at 8 the time of trial, a certified copy 9 can be used for any and all purposes. 10 MR. CARR: So stipulated. 11 MS. DIPPONG: So stipulated. 12 MR. DuPONT: So stipulated. 13 14 15 16 17 18 19 20 21 22 23 24 25 240 $ $1,000 [3] - 16:17, 17:2, 17:15 $1,500 [1] - 24:14 $3,250 [1] - 16:8 $3,625 [1] - 16:9 $30,000 [1] - 23:21 $500 [1] - 16:12 $600 [1] - 16:16 $7,375 [1] - 16:7 ' '70 [1] - 115:3 '72 [1] - 115:3 '81 [2] - 114:6, 114:8 '97 [1] - 100:22 0 0.01 [1] - 48:20 0.02 [1] - 48:13 0.05 [1] - 48:14 0.3 [1] - 48:20 060 [1] - 1:5 1 1 [5] - 17:25, 18:6, 86:24, 124:18, 124:23 1.1 [1] - 136:5 1.3 [2] - 26:12, 76:13 1.4 [1] - 136:3 1.5 [5] - 46:20, 70:15, 162:3, 162:4, 162:23 1.6 [1] - 162:24 10 [30] - 25:9, 43:24, 51:24, 57:18, 57:25, 62:23, 68:13, 77:25, 126:7, 126:14, 136:25, 137:5, 142:9, 150:3, 154:8, 155:6, 155:25, 156:2, 156:8, 156:14, 157:10, 160:16, 183:6, 193:10, 201:3, 201:5, 201:9, 203:9, 203:20, 235:10 100 [3] - 2:12, 161:25, 230:23 1000 [1] - 4:14 106 [1] - 1:5 10:00 [1] - 1:16 10th [2] - 59:23, 156:12 11 [5] - 148:4, 201:2, 201:9, 201:12, 207:13 110 [2] - 114:20, 114:22 12 [4] - 1:10, 123:6, 148:4, 212:13 1200 [1] - 4:4 122 [1] - 70:23 12:34 [1] - 85:9 13 [2] - 213:12, 213:16 14 [1] - 215:8 1400 [2] - 1:16, 3:9 1418 [1] - 70:24 1421 [1] - 70:24 15 [8] - 83:25, 84:6, 84:15, 136:25, 137:5, 149:12, 150:2, 215:8 150 [2] - 102:3, 102:11 155 [1] - 86:22 159 [1] - 86:23 16 [2] - 203:19, 215:17 17 [1] - 49:10 1700 [1] - 3:15 18 [2] - 192:15, 232:6 1800 [1] - 1:24 1801 [1] - 1:24 184 [1] - 134:17 19 [2] - 78:12, 232:6 19103 [2] - 1:25, 3:4 192 [1] - 86:22 1955 [1] - 49:11 1970 [2] - 25:15, 25:17 1970s [1] - 160:22 1980s [1] - 160:22 1981 [3] - 106:20, 107:23, 114:9 1991 [2] - 49:11, 114:4 1993 [1] - 77:23 1994 [1] - 100:20 1997 [2] - 49:9, 100:21 1999 [2] - 1:15, 3:9 1:12 [1] - 85:9 2 2 [4] - 18:11, 18:15, 162:4, 162:23 2.1 [1] - 162:25 20 [11] - 39:10, 84:12, 147:9, 148:6, 149:12, 149:25, 163:23, 192:23, 193:4, 232:6 200 [2] - 169:25, 216:13 2000 [1] - 168:11 2001 [2] - 101:6, 168:12 2002 [1] - 118:25 2003 [6] - 120:25, 171:2, 207:10, 209:9, 209:18, 214:23 2004 [1] - 101:7 2005 [7] - 73:22, 101:7, 207:10, 209:7, 209:14, 209:18, 215:2 2007 [1] - 217:11 2008 [4] - 70:18, 70:20, 70:24, 70:25 2009 [5] - 16:23, 16:25, 17:14, 101:6, 101:8 2010 [3] - 134:16, 185:21, 212:6 2011 [7] - 13:19, 46:4, 71:2, 86:23, 87:3, 92:13, 185:21 2012 [7] - 1:10, 1:13, 18:10, 19:11, 23:14, 71:3, 71:4 21 [1] - 232:7 213 [2] - 4:5, 4:21 214 [1] - 3:16 215 [1] - 3:5 21500 [1] - 5:9 22 [2] - 232:15, 232:21 220 [1] - 46:4 221 [1] - 4:3 23 [2] - 208:14, 238:6 23219-4030 [1] - 4:10 234 [1] - 48:15 24 [3] - 115:11, 217:16, 231:12 25 [5] - 23:17, 29:12, 29:14, 41:11, 173:13 250-1800 [1] - 4:5 25th [1] - 156:2 26 [5] - 1:13, 18:10, 19:11, 62:24, 134:18 26th [2] - 15:23, 155:25 27 [5] - 114:24, 115:9, 115:12, 154:8, 155:6 27th [4] - 68:13, 142:9, 154:8, 156:9 28 [1] - 114:24 29 [1] - 134:18 290 [1] - 46:2 2:36 [1] - 144:8 2:46 [1] - 144:8 3 3 [2] - 22:8, 22:14 30 [14] - 23:17, 24:19, 39:10, 41:12, 89:23, 115:13, 147:4, 147:8, 147:12, 163:12, 163:14, 163:23, 196:10, 203:18 300 [1] - 4:14 306 [1] - 120:19 310 [1] - 3:10 32 [2] - 207:12, 208:4 33 [1] - 207:12 35,000 [1] - 205:11 361 [1] - 77:23 3:34 [1] - 187:17 3:41 [1] - 187:17 3M [2] - 2:7, 3:11 4 4 [7] - 29:23, 30:3, 42:18, 178:3, 220:19, 236:19, 238:11 4.5 [7] - 174:10, 174:19, 175:19, 176:6, 176:22, 177:3, 210:5 40 [37] - 24:20, 60:12, 147:17, 148:8, 148:21, 149:18, 155:15, 156:18, 161:15, 161:19, 161:23, 162:5, 162:7, 162:9, 162:11, 162:14, 162:18, 163:12, 163:16, 164:10, 169:20, 169:25, 188:13, 188:19, 188:25, 189:6, 189:16, 189:25, 190:14, 191:14, 191:19, 192:19, 192:21, 193:2, 196:10, 216:12, 230:24 41.6 [1] - 46:2 42 [1] - 25:18 439-9494 [1] - 4:21 44 [1] - 34:2 45 [6] - 174:10, 174:19, 177:4, 190:14, 210:5, 222:19 450 [1] - 5:9 4th [4] - 16:6, 16:8, 23:6, 23:13 5 5 [10] - 73:6, 73:10, 120:6, 124:15, 124:20, 125:2, 131:15, 143:10, 147:5, 192:15 5.5 [1] - 77:25 50 [2] - 24:20, 161:25 51 [4] - 41:4, 41:6, 89:21, 90:3 54 [3] - 48:3, 55:16, 89:22 55 [1] - 89:23 5910 [1] - 3:15 5q [3] - 115:17, 125:2, 131:14 5th [1] - 5:3 6 6 [2] - 76:7, 135:22 60 [13] - 60:12, 155:24, 156:17, 161:15, 161:19, 162:5, 162:10, 162:12, 162:13, 162:14, 162:19, 169:20, 177:21 601 [1] - 3:4 61 [2] - 162:16, 162:21 633 [1] - 4:20 634-2522 [1] - 5:4 65 [2] - 89:19, 190:11 69 [1] - 212:7 7 7 [10] - 46:4, 93:25, 120:7, 124:15, 124:20, 125:2, 131:15, 143:10, 147:5, 192:15 70 [3] - 46:6, 88:18, 89:25 700 [1] - 4:20 714 [1] - 5:4 716-6110 [1] - 5:10 720E [1] - 3:3 75 [2] - 41:8, 114:23 75,000 [1] - 205:10 75206 [1] - 3:16 76 [1] - 212:7 76011 [1] - 4:15 775-1000 [1] - 4:10 241 785-4600 [1] - 3:10 7q [3] - 115:18, 125:2, 131:15 7th [1] - 46:3 8 8 [6] - 101:17, 101:21, 102:21, 115:19, 124:16, 124:19 80 [17] - 41:8, 68:9, 82:6, 83:13, 91:16, 91:24, 92:5, 163:2, 163:6, 188:16, 188:19, 188:24, 189:5, 190:3, 191:17, 205:17 804 [1] - 4:10 817 [1] - 4:15 818 [1] - 5:10 828-9200 [1] - 3:16 83 [1] - 212:6 85 [1] - 41:7 877-8144 [1] - 4:15 893-0100 [1] - 3:5 9 9 [8] - 109:11, 109:15, 118:19, 118:22, 120:17, 123:5, 131:11, 131:23 90012 [1] - 4:4 90067 [1] - 3:10 90071 [1] - 4:21 901 [1] - 4:9 91367 [1] - 5:10 92868 [1] - 5:4 99 [1] - 142:21 9th [2] - 16:7, 239:2 A a.m [1] - 1:16 a/k/a [2] - 2:9, 5:12 abbreviate [1] - 204:14 ability [5] - 27:8, 94:19, 95:24, 226:25, 227:11 able [18] - 12:4, 12:8, 77:9, 81:11, 81:16, 95:4, 110:20, 136:13, 140:16, 154:21, 180:18, 195:14, 197:3, 205:25, 222:4, 227:19, 227:22, 237:11 abnormal [12] - 109:24, 110:5, 112:15, 113:17, 115:12, 122:23, 131:24, 217:8, 217:10, 217:22, 218:4, 218:5 abnormalities [17] 43:23, 106:9, 107:11, 110:12, 115:16, 115:20, 115:21, 119:10, 119:14, 120:6, 121:21, 123:22, 124:16, 124:20, 143:11, 143:14, 217:19 abnormality [1] 217:25 ABRAMS [1] - 4:8 absence [16] - 50:18, 57:9, 105:2, 105:13, 109:9, 109:23, 110:5, 112:14, 113:17, 118:20, 131:24, 169:17, 186:10, 186:13, 188:8, 210:12 absent [1] - 136:24 absolutely [2] - 110:7, 147:20 absorbed [7] - 198:4, 198:6, 198:13, 198:25, 200:9, 200:17, 200:20 absorption [18] - 79:3, 79:5, 193:19, 195:9, 195:20, 195:22, 195:24, 195:25, 197:13, 197:16, 197:17, 197:22, 197:25, 199:18, 199:22, 200:2, 201:16 abstract [3] - 13:18, 136:22, 197:21 Abstract [1] - 7:4 Academy [1] - 204:15 accept [3] - 51:10, 133:16, 145:13 accepted [2] - 107:11, 124:3 accommodate [1] 17:11 according [4] - 37:8, 37:9, 37:13, 166:8 accounting [1] - 77:7 accurate [1] - 237:21 acetylsalicylic [1] - 198:21 acid [5] - 197:23, 198:21, 198:22, 198:23, 198:24 actual [2] - 137:8, 145:22 acute [10] - 26:11, 38:10, 38:15, 39:7, 114:15, 131:13, 136:2, 149:3, 152:7, 152:8 Acute [1] - 106:19 Adame [4] - 73:24, 73:25, 74:2, 74:5 Adami [1] - 6:19 add [15] - 53:22, 58:19, 61:4, 108:8, 116:11, 149:23, 171:14, 178:15, 180:18, 180:25, 183:21, 184:15, 184:19, 185:12, 222:23 added [1] - 58:12 addendum [3] - 34:9, 102:8, 102:12 addition [3] - 63:19, 74:14, 177:19 additional [2] 152:21, 180:7 address [7] - 64:4, 64:10, 67:12, 67:15, 101:3, 119:3, 228:11 addressed [1] 196:24 adds [1] - 79:3 adequate [2] - 82:25, 150:23 adhesives [1] - 48:24 admissible [1] - 69:23 admit [1] - 209:3 admitted [1] - 231:14 Adupont@lockslaw. com [1] - 3:5 advance [1] - 107:6 Advances [2] - 107:4, 123:7 advantages [1] 213:3 advised [1] - 129:19 affected [1] - 142:18 affirmatively [1] 148:11 afterwards [2] 145:22, 145:24 age [26] - 47:24, 47:25, 48:3, 55:12, 55:13, 55:16, 55:20, 55:23, 56:6, 81:17, 85:19, 89:16, 89:19, 89:21, 89:22, 149:5, 155:24, 190:11, 192:15, 203:16, 205:13, 205:15, 206:12, 206:14, 230:7 agencies [1] - 122:21 agency [6] - 31:19, 31:20, 32:21, 32:22, 32:25, 33:6 agent [14] - 115:25, 121:15, 134:3, 134:4, 134:25, 135:10, 142:12, 142:14, 146:25, 147:6, 150:12, 152:4, 189:17, 190:2 agents [12] - 119:25, 120:5, 120:10, 124:24, 133:24, 142:20, 143:12, 145:9, 145:11, 146:17, 146:22 ago [6] - 15:5, 21:13, 32:18, 163:23, 192:23, 193:4 agree [23] - 10:20, 30:19, 39:12, 54:17, 54:23, 55:3, 55:22, 61:8, 66:24, 91:15, 97:2, 112:24, 129:16, 132:16, 144:12, 144:20, 168:4, 168:25, 178:19, 179:23, 184:4, 184:12, 200:7 agreed [2] - 54:21, 159:7 Agreed [1] - 56:21 agreement [3] - 9:24, 96:22, 130:5 agrees [2] - 126:22, 168:16 ahead [12] - 17:9, 54:20, 64:2, 65:18, 85:4, 85:6, 93:20, 114:9, 123:17, 169:9, 170:11, 174:6 air [1] - 153:11 Aksoy [1] - 83:21 al [1] - 212:5 albeit [1] - 62:23 alert [1] - 239:3 alkylate [1] - 120:13 alkylating [17] 115:25, 120:5, 120:10, 121:13, 121:14, 124:24, 133:24, 134:3, 134:4, 134:25, 135:10, 142:14, 142:20, 143:12, 146:22, 147:6, 150:12 allegedly [1] - 205:12 ALLEN [1] - 4:14 allow [1] - 225:17 almost [2] - 17:21, 189:16 altogether [1] - 23:20 ambient [1] - 153:11 ambiguous [2] 97:14, 188:22 America [2] - 164:21, 165:13 American [1] - 166:10 AML [162] - 26:13, 35:23, 36:9, 38:10, 38:14, 38:18, 38:20, 40:7, 40:21, 43:17, 43:20, 46:20, 48:2, 48:5, 49:7, 49:10, 50:15, 50:19, 55:3, 55:9, 55:14, 55:18, 55:24, 57:4, 57:11, 57:24, 59:18, 59:19, 61:17, 61:20, 67:17, 67:22, 68:6, 68:8, 68:9, 70:12, 71:14, 72:18, 72:25, 73:15, 74:10, 75:20, 76:11, 76:16, 78:9, 79:9, 79:13, 79:15, 79:21, 80:3, 80:23, 81:3, 81:18, 81:19, 82:4, 82:5, 82:6, 82:11, 82:14, 82:15, 83:13, 85:21, 88:6, 89:17, 91:25, 92:3, 95:6, 96:16, 97:24, 98:7, 100:15, 101:12, 102:9, 103:13, 105:5, 105:16, 109:25, 110:6, 110:10, 112:14, 113:19, 114:12, 114:16, 118:13, 119:4, 119:10, 119:12, 119:14, 119:22, 119:25, 121:4, 121:24, 122:8, 122:25, 125:21, 131:16, 132:12, 132:14, 132:21, 132:24, 135:10, 136:8, 147:20, 147:21, 147:25, 148:10, 148:13, 148:24, 151:21, 153:16, 242 153:22, 154:23, 154:24, 161:16, 161:20, 162:17, 163:6, 163:11, 163:15, 163:18, 164:22, 165:7, 165:13, 166:10, 172:5, 174:10, 176:5, 176:24, 177:3, 185:22, 186:9, 186:10, 186:11, 186:12, 187:22, 188:12, 188:14, 188:16, 190:2, 190:4, 190:23, 191:18, 191:23, 192:3, 192:4, 192:9, 193:6, 193:13, 194:3, 194:5, 194:12, 194:16, 194:19, 194:25, 195:5, 200:9, 207:13, 207:23 AMLs [13] - 55:15, 84:6, 85:25, 87:7, 87:23, 88:9, 89:2, 89:7, 89:20, 92:6, 152:3, 188:17, 188:19 amoebae [1] - 68:22 amount [5] - 15:19, 24:2, 26:24, 94:5, 196:24 analogy [1] - 134:10 analyses [8] - 46:18, 70:18, 71:16, 71:19, 71:23, 170:17, 174:16, 183:21 analysis [33] - 126:2, 126:3, 127:20, 128:15, 128:23, 128:24, 129:15, 130:16, 143:8, 143:18, 147:16, 158:15, 158:17, 159:5, 160:11, 161:2, 161:10, 170:15, 171:15, 171:18, 174:13, 174:23, 177:8, 184:20, 185:13, 204:20, 206:8, 213:3, 214:18, 218:25, 220:17, 225:2, 229:20 Analysis [2] - 234:17, 235:7 analyzed [3] - 81:8, 99:11, 206:15 andrew [13] - 23:10, 44:24, 50:7, 64:19, 72:2, 76:25, 96:21, 128:25, 129:9, 140:12, 173:12, 178:22, 221:6 ANDREW [1] - 3:3 Andrew [13] - 9:11, 44:24, 54:3, 56:7, 61:11, 74:24, 84:18, 85:4, 130:5, 181:7, 204:4, 222:13, 226:3 anecdotal [5] - 98:9, 98:13, 98:21, 98:23, 126:5 ANGELES [1] - 1:1 Angeles [4] - 1:16, 3:10, 4:4, 4:21 Annual [1] - 107:7 ANSWER [1] - 8:2 answer [94] - 9:25, 10:12, 10:18, 10:21, 11:4, 19:24, 21:15, 21:16, 25:17, 27:16, 28:3, 28:22, 28:23, 31:4, 34:22, 35:8, 36:11, 36:13, 36:14, 56:8, 56:10, 64:12, 64:13, 64:15, 64:16, 65:16, 65:17, 65:20, 66:6, 67:2, 73:3, 80:3, 82:10, 90:16, 91:20, 91:22, 108:17, 111:9, 112:2, 112:4, 112:6, 120:3, 120:14, 122:18, 123:18, 125:24, 127:17, 128:6, 129:4, 129:11, 130:8, 131:8, 140:25, 142:10, 142:15, 145:12, 146:14, 149:23, 159:7, 162:10, 162:13, 165:10, 168:23, 168:24, 172:20, 173:5, 173:7, 175:11, 175:21, 175:25, 176:11, 176:20, 179:5, 179:8, 179:10, 179:22, 182:15, 182:22, 189:2, 193:25, 196:18, 196:21, 198:10, 198:16, 199:3, 219:14, 221:13, 225:19, 225:23, 228:3, 233:21, 237:11, 237:21 answered [6] - 10:3, 167:6, 195:2, 224:2, 224:3, 228:4 answering [6] - 10:24, 12:6, 28:3, 66:5, 129:17, 162:9 answers [1] - 168:20 anyway [1] - 238:2 apologize [1] - 75:12 APPEARANCES [1] 5:1 aPPEARANCES [1] 4:1 appendix [1] - 102:7 applied [2] - 195:23, 197:17 applies [2] - 97:3, 217:4 apply [3] - 199:21, 199:23, 230:24 appreciable [4] - 82:6, 82:15, 82:18, 83:6 appreciate [1] 182:14 appropriate [5] 41:19, 42:7, 42:10, 122:3, 221:4 appropriateness [1] 40:5 approved [3] - 196:7, 196:9, 196:12 April [3] - 15:23, 18:10, 19:11 Archives [1] - 212:5 area [4] - 35:8, 107:10, 197:18, 197:19 areas [14] - 35:6, 61:4, 61:25, 63:8, 64:25, 65:9, 65:13, 88:20, 129:7, 130:25, 131:3, 131:4, 155:9, 225:10 argue [4] - 83:25, 105:18, 113:11, 207:2 argued [2] - 110:12, 207:3 argues [9] - 50:19, 57:11, 105:4, 105:15, 110:8, 112:13, 113:18, 195:16, 197:24 argument [1] - 207:6 argumentative [1] 182:17 arise [1] - 68:11 arisen [1] - 140:10 arises [3] - 132:12, 132:21, 140:7 arithmatic [1] - 48:14 Arlington [1] - 4:15 arose [9] - 52:4, 52:6, 52:13, 57:22, 57:24, 59:11, 140:18, 145:7, 188:12 article [136] - 14:4, 75:17, 75:18, 76:19, 76:20, 77:18, 77:20, 78:2, 86:3, 86:17, 86:19, 87:3, 92:9, 92:14, 100:17, 100:20, 102:3, 102:7, 102:8, 106:5, 107:15, 107:16, 107:23, 108:2, 108:19, 110:8, 112:10, 113:16, 113:24, 114:4, 114:10, 117:4, 117:7, 117:12, 118:9, 118:10, 118:18, 118:19, 118:23, 119:2, 119:8, 120:16, 120:24, 121:10, 123:4, 123:11, 123:13, 123:16, 123:20, 124:13, 126:21, 127:10, 127:20, 128:14, 128:18, 129:15, 130:24, 131:11, 132:3, 134:12, 134:19, 134:21, 135:24, 136:6, 140:8, 153:23, 154:20, 155:2, 156:5, 157:3, 157:5, 165:3, 169:20, 169:22, 170:4, 170:15, 170:18, 170:23, 171:8, 171:12, 171:24, 192:10, 194:4, 194:5, 194:9, 194:13, 194:17, 194:23, 195:3, 195:6, 197:9, 197:14, 197:20, 201:4, 202:3, 203:8, 203:10, 203:17, 206:10, 206:11, 206:13, 206:15, 207:22, 208:23, 208:24, 211:14, 211:20, 211:23, 212:18, 213:25, 214:5, 214:7, 214:13, 216:3, 216:24, 219:8, 219:11, 220:24, 221:14, 221:21, 222:4, 226:20, 227:5, 227:9, 229:5, 229:11, 229:24, 230:4, 230:9, 230:10, 231:6, 232:11, 232:15 Article [14] - 6:14, 6:15, 7:3, 7:4, 7:5, 7:7, 7:8, 7:9, 7:10, 7:11, 7:12, 7:13, 7:16, 7:17 articles [125] - 14:8, 33:19, 34:4, 37:22, 49:20, 70:12, 72:15, 72:22, 74:11, 74:15, 74:18, 75:14, 77:14, 78:13, 78:15, 78:18, 78:24, 79:2, 81:4, 83:12, 87:20, 89:14, 92:22, 93:10, 93:13, 93:16, 94:4, 94:9, 94:10, 101:4, 102:22, 102:25, 103:10, 103:15, 103:20, 103:25, 104:8, 104:15, 106:6, 106:24, 107:24, 108:4, 108:7, 108:10, 108:20, 109:8, 109:13, 109:18, 109:19, 109:23, 110:21, 113:8, 113:10, 117:2, 131:21, 133:18, 135:2, 135:9, 135:13, 135:14, 170:7, 170:12, 171:3, 171:6, 171:17, 192:7, 193:25, 194:10, 196:23, 197:4, 197:5, 198:4, 200:25, 201:13, 201:18, 201:20, 202:4, 202:9, 202:11, 203:3, 206:7, 206:11, 206:18, 214:15, 216:20, 219:5, 219:15, 219:17, 219:19, 220:17, 220:21, 220:25, 221:10, 222:12, 222:24, 224:7, 224:20, 225:6, 225:8, 225:9, 225:11, 225:12, 226:15, 227:13, 243 227:17, 227:24, 228:7, 228:10, 228:11, 228:18, 228:21, 228:24, 229:4, 229:6, 231:2, 232:2, 232:25, 233:10, 233:14, 234:23, 235:23, 236:3, 237:7, 237:10 Articles [3] - 6:13, 6:16, 6:18 asbestos [1] - 25:7 ascribe [2] - 100:4, 100:6 ascribed [2] - 150:7, 152:16 aside [4] - 38:25, 39:4, 48:10, 121:19 aspects [1] - 29:16 aspirin [1] - 198:20 assess [1] - 159:10 assessed [1] - 159:15 assessment [6] 35:15, 35:19, 35:24, 36:7, 90:7, 157:9 assessments [3] 44:5, 90:14, 212:16 assigned [1] - 1:6 associated [14] 87:12, 87:23, 88:9, 89:3, 89:7, 107:12, 115:25, 117:24, 118:3, 134:23, 158:24, 159:2, 217:17 ASSOCIATES [1] - 5:8 association [2] 122:24, 159:2 associations [1] 120:19 assume [4] - 55:12, 88:11, 112:24, 115:7 assumes [3] - 112:18, 133:7, 150:23 assuming [5] - 80:8, 117:22, 151:16, 166:15, 195:18 assumption [3] 117:17, 145:6, 199:9 assure [1] - 212:21 ATLANTIC [1] - 1:24 ATSDR [1] - 34:6 attach [1] - 237:25 attached [2] - 131:22, 178:3 attempt [1] - 164:17 attention [1] - 105:23 attorney [7] - 9:12, 67:12, 172:9, 173:8, 179:6, 222:22, 223:2 attorney's [1] - 112:2 attributable [1] - 26:10 attribute [1] - 191:18 attributed [1] - 99:6 attributes [1] - 126:24 audited [1] - 213:20 August [1] - 239:2 Australian [3] - 174:14, 208:25, 209:2 author [14] - 13:19, 27:15, 68:12, 87:2, 110:3, 110:9, 113:14, 113:16, 141:5, 150:6, 154:6, 171:22, 230:10, 230:14 authored [2] - 13:24 authoritative [6] 28:9, 28:10, 28:15, 29:4, 29:8, 125:7 authors [2] - 194:10, 208:25 authors' [1] - 28:18 auto [2] - 48:9, 48:11 AUTO [1] - 2:9 Auto [1] - 5:12 autoimmune [2] 202:4, 229:7 automotive [3] 56:19, 92:21, 93:6 available [3] - 71:8, 104:3, 203:2 Avenue [2] - 1:15, 3:9 average [26] - 24:2, 41:5, 47:25, 48:16, 51:23, 55:12, 55:13, 55:17, 55:21, 55:23, 56:2, 56:4, 56:6, 57:17, 57:25, 81:18, 85:19, 89:16, 103:18, 132:13, 132:23, 133:22, 148:2, 160:5, 190:11 averages [1] - 48:19 aware [1] - 140:4 B background [4] 137:18, 225:7, 226:15, 227:21 backwards [1] 122:16 Ballpark [1] - 4:14 bariatric [1] - 46:5 barrier [1] - 79:3 Barry [5] - 19:15, 19:25, 97:4, 130:11, 181:25 BARRY [1] - 3:8 barry.thompson@ hoganlovells.com [1] - 3:11 based [39] - 10:14, 12:6, 16:2, 39:22, 47:19, 48:15, 51:21, 51:22, 67:21, 77:25, 81:4, 86:15, 87:17, 91:10, 91:12, 94:20, 94:24, 98:16, 106:7, 123:23, 124:17, 125:16, 156:7, 156:25, 157:3, 157:4, 159:4, 169:16, 174:11, 177:4, 177:9, 183:3, 183:6, 184:17, 193:14, 208:15, 234:21, 234:25 bases [3] - 101:16, 106:3, 169:13 basic [1] - 220:4 basing [1] - 143:3 basis [21] - 36:23, 37:2, 49:17, 50:11, 76:16, 92:14, 96:14, 98:9, 103:17, 122:7, 133:4, 133:19, 142:24, 144:15, 156:15, 172:3, 183:24, 188:6, 195:10, 227:13 become [1] - 10:9 beforehand [2] 121:23, 134:9 begin [2] - 25:10, 25:12 beginning [2] - 1:16, 159:8 behalf [7] - 20:6, 20:10, 21:10, 24:3, 24:25, 31:15, 32:21 behind [4] - 11:13, 26:9, 224:10, 237:18 belief [3] - 67:4, 67:19, 144:25 believes [1] - 124:17 belongs [1] - 46:22 below [9] - 55:13, 55:15, 55:23, 56:3, 56:6, 81:18, 85:19, 174:20, 208:13 Benzene [5] - 7:14, 86:19, 107:5, 123:8, 134:14 benzene [207] - 14:13, 14:16, 14:23, 20:3, 20:6, 20:8, 21:11, 21:12, 21:14, 22:18, 23:2, 24:4, 25:2, 25:21, 27:8, 27:22, 30:7, 30:16, 30:18, 30:23, 31:3, 34:5, 35:23, 36:8, 37:16, 48:9, 48:14, 50:19, 50:20, 56:20, 57:11, 60:9, 67:5, 67:9, 79:6, 82:22, 82:23, 83:2, 83:3, 83:11, 83:14, 83:18, 83:19, 83:23, 84:2, 84:7, 86:2, 86:7, 86:8, 86:11, 86:12, 87:7, 87:12, 87:14, 87:16, 87:17, 87:21, 87:24, 88:5, 88:10, 88:12, 88:15, 88:17, 88:18, 88:19, 89:3, 89:5, 89:8, 90:21, 91:3, 91:7, 91:12, 91:19, 92:21, 93:7, 94:5, 94:7, 94:15, 94:19, 95:5, 95:20, 96:16, 97:25, 99:6, 105:3, 105:4, 105:15, 106:10, 106:12, 107:12, 109:10, 109:24, 110:6, 112:13, 113:18, 116:15, 116:24, 117:3, 117:8, 117:13, 117:18, 117:23, 118:3, 118:4, 118:21, 119:17, 119:21, 121:6, 121:12, 121:20, 122:7, 122:24, 123:22, 124:19, 124:24, 131:17, 131:25, 134:22, 134:23, 136:7, 136:14, 136:18, 136:20, 137:2, 137:3, 138:19, 138:22, 139:2, 143:25, 147:17, 147:24, 149:3, 151:16, 152:13, 153:11, 156:23, 158:11, 158:24, 159:19, 161:16, 163:6, 163:10, 163:18, 164:16, 164:21, 164:23, 165:6, 165:13, 165:15, 165:21, 166:9, 167:10, 168:2, 176:6, 176:24, 179:15, 179:18, 188:14, 188:20, 188:25, 189:7, 189:10, 189:13, 190:9, 190:19, 190:25, 191:20, 192:20, 192:22, 192:25, 193:4, 193:14, 193:20, 196:4, 196:25, 197:8, 198:6, 198:12, 198:24, 199:19, 200:2, 200:8, 200:15, 200:18, 200:21, 201:16, 202:25, 208:6, 215:24, 216:2, 216:23, 217:9, 217:17, 217:21, 218:10, 218:15, 218:16, 231:12, 233:17, 233:19, 234:15, 235:8 benzene's [1] - 28:4 Berkeley [1] - 107:25 BERRYMAN [1] - 1:7 Berryman [1] - 4:16 best [9] - 12:13, 21:16, 98:7, 221:13, 226:25, 227:11, 227:16, 228:2, 228:4 betamethasone [3] 197:22, 197:25, 198:13 better [4] - 22:22, 39:20, 143:13, 160:18 Between [1] - 134:14 between [12] - 22:23, 24:23, 35:6, 83:16, 118:7, 122:24, 124:15, 152:7, 162:5, 162:9, 192:3, 208:24 BEVINS [1] - 5:2 beyond [19] - 53:12, 53:18, 53:19, 112:10, 117:10, 120:14, 127:9, 127:19, 128:14, 128:22, 129:14, 130:15, 137:22, 177:12, 184:21, 205:24, 207:6, 210:2, 210:8 bias [5] - 99:22, 100:2, 100:4, 100:6, 100:10 big [1] - 156:11 244 bill [4] - 16:6, 16:7, 16:8, 24:3 billed [3] - 15:19, 23:21, 24:11 billing [10] - 11:15, 12:24, 15:17, 15:20, 16:6, 16:10, 17:19, 17:25, 23:8, 33:11 bills [2] - 41:14, 41:16 Biological [2] - 7:15, 134:17 BISGAARD [1] - 4:2 bit [9] - 134:7, 147:16, 160:18, 160:19, 161:3, 161:6, 161:7, 162:18 Bjergaard [3] - 6:18, 109:5, 131:12 black [1] - 11:3 blaming [1] - 83:11 blanket [1] - 179:22 blocking [3] - 15:6, 110:9, 110:13 blood [6] - 216:8, 217:8, 217:10, 217:12, 233:18, 233:19 BMI [1] - 45:25 body [12] - 12:3, 12:5, 107:18, 141:24, 142:2, 143:19, 143:23, 145:11, 145:23, 146:6, 171:10, 227:20 bolster [1] - 180:9 bolsters [2] - 180:20, 180:21 bona [1] - 83:18 Bonds [1] - 230:13 bone [1] - 200:15 BONNEVILLE [1] 4:19 book [1] - 138:13 bookbinder [1] 116:20 books [1] - 27:17 bottom [1] - 125:3 Boulevard [1] - 5:3 bound [1] - 210:12 boxes [9] - 11:12, 12:15, 12:20, 24:15, 41:16, 223:15, 224:10, 234:7, 236:4 brake [2] - 90:20, 90:25 brand [1] - 104:16 breadth [1] - 126:12 break [9] - 84:19, 84:24, 85:2, 85:6, 85:18, 142:22, 144:4, 206:12, 206:13 breakdown [1] 203:17 breathing [1] - 48:20 brief [1] - 149:8 briefly [2] - 9:16, 230:18 Brigitte [1] - 1:16 bring [9] - 13:2, 13:12, 15:21, 77:2, 203:4, 206:9, 214:2, 227:22, 233:14 bringing [1] - 14:20 BRISBOIS [1] - 4:2 broad [6] - 28:10, 38:10, 50:13, 52:18, 107:10, 107:17 Brothers [1] - 5:6 BROTHERS [1] - 2:8 brought [23] - 11:10, 13:8, 33:20, 73:19, 73:22, 171:8, 201:20, 203:6, 204:6, 214:16, 219:17, 225:5, 225:10, 225:12, 226:10, 226:14, 226:24, 227:10, 228:3, 228:15, 228:16, 228:18 brown [1] - 171:16 Brownson [2] - 6:19, 73:23 buddy [1] - 181:23 bunch [3] - 33:12, 223:5, 225:8 buried [1] - 43:25 Burton [1] - 20:14 business [1] - 1:8 BY [126] - 3:3, 3:8, 3:14, 4:3, 4:8, 4:14, 4:19, 5:3, 5:8, 9:7, 18:8, 18:17, 18:24, 22:16, 23:19, 30:5, 30:14, 31:11, 32:19, 34:12, 42:2, 43:12, 45:16, 47:8, 51:16, 53:7, 54:15, 56:17, 59:16, 63:11, 64:17, 65:11, 65:21, 67:10, 67:24, 70:3, 72:13, 73:12, 75:25, 76:9, 78:5, 81:25, 82:13, 85:13, 94:3, 96:3, 96:13, 97:7, 97:19, 98:11, 99:21, 100:11, 102:19, 105:11, 105:25, 108:15, 109:21, 111:24, 112:8, 113:12, 114:2, 114:7, 116:9, 122:19, 124:9, 125:18, 127:8, 127:13, 127:18, 128:20, 129:12, 130:14, 131:9, 132:20, 137:16, 140:14, 141:3, 144:11, 145:5, 146:20, 150:5, 153:12, 157:18, 158:7, 161:5, 165:8, 166:7, 166:20, 167:7, 167:19, 167:23, 169:11, 170:25, 174:25, 175:16, 176:2, 176:19, 180:2, 180:17, 181:17, 182:2, 182:24, 183:12, 184:16, 187:20, 189:3, 189:21, 191:5, 200:23, 201:11, 204:11, 213:14, 215:12, 218:22, 220:15, 221:8, 222:2, 224:17, 224:25, 225:20, 225:24, 226:11, 226:18, 232:13, 232:23, 238:8 C CA [1] - 4:21 CALIFORNIA [1] - 1:1 California [11] - 1:9, 1:16, 3:10, 4:4, 5:4, 5:10, 64:20, 64:24, 107:25, 178:24, 238:20 Camp [2] - 32:5, 32:8 Canadian [2] - 174:13, 208:24 cancel [1] - 17:6 Cancer [3] - 70:23, 77:22, 106:20 cancer [12] - 26:5, 94:20, 154:11, 154:24, 155:4, 155:10, 155:11, 155:16, 155:17, 155:18, 155:22, 155:24 cancers [4] - 68:17, 155:7, 155:13, 155:15 cannot [9] - 145:21, 152:15, 186:8, 187:22, 192:8, 194:2, 194:11, 194:25, 195:4 capability [1] - 200:8 CAPM [15] - 83:21, 202:2, 202:22, 202:23, 203:4, 203:5, 203:18, 204:13, 204:14, 204:17, 204:20, 206:9, 207:2, 225:8 car [2] - 83:5, 152:20 carburetor [2] - 90:20, 90:25 carcinogen [3] - 28:5, 154:11, 196:6 care [5] - 42:4, 42:8, 42:10, 59:10, 179:3 career [4] - 94:22, 95:4, 149:6, 159:20 carefully [1] - 105:7 CARR [24] - 3:13, 3:14, 69:13, 69:21, 96:21, 97:2, 97:6, 127:24, 128:19, 128:25, 129:16, 129:21, 175:20, 176:8, 204:4, 220:2, 220:13, 221:6, 221:16, 224:23, 225:16, 225:22, 226:2, 239:10 Carr [1] - 204:4 Cary [1] - 4:9 CASE [1] - 1:4 case [71] - 11:23, 12:18, 13:16, 15:23, 19:3, 19:9, 19:12, 20:11, 20:13, 20:16, 20:21, 21:14, 23:6, 23:22, 24:11, 24:18, 24:22, 25:6, 25:7, 33:10, 33:17, 42:15, 45:15, 47:20, 48:11, 55:5, 67:17, 69:3, 70:6, 80:15, 81:6, 83:20, 97:12, 98:8, 110:17, 110:23, 112:12, 113:21, 125:12, 125:21, 125:22, 126:10, 157:23, 171:7, 173:19, 174:14, 186:4, 194:7, 194:14, 202:7, 204:10, 204:21, 207:11, 208:25, 209:7, 209:8, 209:11, 209:15, 209:17, 210:17, 213:18, 214:9, 214:17, 219:21, 220:9, 221:12, 224:22, 229:16, 229:18, 237:4 cases [26] - 21:19, 22:3, 22:4, 22:17, 23:3, 24:4, 24:13, 24:14, 24:16, 24:25, 25:5, 26:23, 30:22, 31:6, 55:5, 78:2, 123:23, 124:21, 125:3, 126:14, 136:17, 136:18, 166:9, 185:22, 190:24, 208:21 Castillo [6] - 46:19, 70:13, 70:24, 71:2, 71:4, 72:15 categories [1] 104:21 category [1] - 79:10 caught [1] - 59:9 causal [7] - 122:24, 147:10, 150:22, 150:24, 151:8, 151:10, 151:12 causation [23] - 20:20, 20:24, 20:25, 21:4, 45:22, 45:25, 46:11, 46:22, 49:3, 52:19, 61:9, 66:25, 67:4, 67:7, 133:16, 149:10, 172:5, 172:6, 178:20, 179:16, 179:25, 182:22, 184:6 causative [6] - 51:13, 57:20, 74:6, 132:22, 133:20, 148:12 caused [53] - 21:3, 26:2, 26:15, 27:5, 31:3, 50:20, 51:8, 52:7, 52:12, 59:12, 59:18, 67:8, 83:19, 83:23, 84:6, 84:10, 84:15, 86:2, 86:12, 87:13, 88:15, 89:3, 91:18, 94:5, 118:4, 121:4, 121:23, 133:6, 133:7, 141:14, 141:17, 141:19, 145:7, 145:19, 147:25, 149:12, 151:16, 153:16, 163:23, 163:24, 176:6, 179:18, 186:11, 245 187:5, 188:14, 190:25, 193:13, 194:15, 216:2, 217:17, 218:10, 218:16 causes [15] - 14:5, 14:9, 21:6, 96:16, 119:22, 124:19, 136:8, 143:21, 146:15, 146:16, 151:15, 151:21, 176:24, 179:15, 202:25 Causes [1] - 77:22 causing [17] - 30:7, 30:16, 30:23, 31:22, 32:23, 35:23, 36:8, 68:17, 143:17, 147:21, 148:13, 148:24, 154:11, 163:6, 189:17, 200:8 caveat [2] - 42:23, 87:11 Cedars [1] - 16:16 cell [2] - 39:6, 154:19 Center [2] - 3:3, 4:9 Central [1] - 3:15 certain [2] - 21:7, 144:19 certainly [23] - 10:5, 13:13, 17:21, 26:3, 26:12, 27:16, 28:11, 39:24, 45:4, 48:4, 52:10, 71:18, 77:14, 84:14, 138:10, 140:2, 155:18, 177:14, 180:7, 187:6, 204:22, 230:24, 233:13 Certificates [2] 234:17, 235:7 Certified [1] - 1:17 certified [1] - 239:8 cetera [1] - 116:21 chance [2] - 84:18, 174:4 change [8] - 40:2, 72:11, 99:14, 99:17, 147:15, 184:13, 197:23, 199:17 changes [2] - 216:8, 239:4 changing [1] - 223:20 chapter [1] - 14:4 chapters [4] - 27:17, 28:16, 138:13, 139:4 characterization [1] 30:20 characterize [1] 236:19 characterized [2] 98:14, 98:22 charge [2] - 131:2, 131:7 charged [2] - 16:25, 17:14 charges [3] - 41:20, 42:8, 42:11 charging [1] - 16:18 check [2] - 93:18, 167:17 checks [2] - 75:3, 77:3 Chelghoum [3] - 6:14, 6:19, 75:22 Chembile [1] - 86:21 chemical [8] - 26:2, 26:6, 27:25, 31:21, 32:4, 32:8, 32:23, 116:19 chemicals [3] - 26:15, 157:6, 195:15 Chemico [2] - 7:15, 134:17 Chemico-Biological [2] - 7:15, 134:17 chemo [1] - 192:22 chemotherapeutic [4] - 119:25, 142:12, 145:9, 145:11 chemotherapy [24] 26:9, 82:8, 120:6, 121:3, 121:15, 121:16, 134:4, 141:6, 141:15, 141:19, 141:21, 141:23, 142:17, 143:4, 145:7, 145:10, 145:18, 145:19, 145:23, 146:5, 146:9, 146:11, 147:2, 192:14 cherry [2] - 126:17, 126:19 Chicago [1] - 120:22 chicken [1] - 237:18 chimaera [1] - 68:22 China [2] - 88:21, 217:24 Chinese [3] - 77:24, 204:15, 217:3 choose [2] - 169:22, 217:7 chooses [1] - 164:15 chosen [2] - 19:6, 168:7 Chris [1] - 96:22 CHRISTOPHER [1] 3:14 christopher.carr@ JCMFirm.com [1] 3:17 chromatographs [1] 234:14 chromium [1] - 25:5 chromosomal [18] 43:23, 84:11, 106:9, 107:11, 110:12, 117:19, 117:21, 119:9, 119:13, 121:11, 121:21, 122:4, 123:21, 124:20, 143:11, 143:13, 143:25, 217:18 chromosome [4] 114:19, 120:12, 122:6, 122:22 Chromosome [1] 106:17 chromosomes [4] 83:2, 192:23, 193:9, 193:15 chronic [2] - 195:12, 195:18 cigarette [2] - 26:19, 136:8 circumstances [1] 139:25 citation [1] - 87:5 cite [17] - 71:4, 74:17, 101:5, 108:6, 110:4, 110:20, 112:9, 113:15, 113:25, 133:24, 134:20, 135:9, 135:13, 135:15, 136:13, 154:22, 195:3 cited [25] - 70:13, 74:21, 78:14, 92:22, 97:16, 100:17, 102:23, 103:3, 103:4, 103:5, 103:6, 103:7, 104:9, 104:16, 108:2, 108:11, 112:10, 174:9, 177:2, 177:6, 177:22, 215:25, 216:4, 220:21 cites [2] - 126:15, 202:18 citing [2] - 202:17, 202:22 City [1] - 5:3 civilized [1] - 153:10 claim [6] - 10:15, 100:9, 112:12, 190:4, 203:8, 206:22 claimed [1] - 158:20 claims [3] - 86:10, 158:2, 170:21 clarification [1] - 111:17 clarify [5] - 57:5, 72:3, 82:20, 109:18, 181:8 classification [1] - 38:12 cleaner [1] - 116:20 cleaners [4] - 90:20, 90:25, 91:2 clear [10] - 55:19, 60:7, 100:7, 105:21, 129:3, 129:9, 143:2, 175:24, 176:12, 213:24 clearly [1] - 28:17 Clinic [1] - 137:20 clinical [3] - 29:9, 43:7, 45:21 Clinical [2] - 106:18, 120:19 Clinical-cytogenetic [1] - 120:19 close [1] - 105:23 co [1] - 13:24 co-authored [1] 13:24 coach [1] - 173:5 coal [5] - 196:3, 196:5, 196:8, 196:15, 201:19 coating [1] - 48:24 Code [1] - 238:21 cohort [10] - 126:22, 126:23, 170:16, 170:17, 205:19, 209:10, 209:13, 209:15, 211:18, 212:2 cohorts [1] - 209:23 Collins [9] - 7:16, 202:3, 219:8, 219:22, 230:19, 230:22, 231:4, 231:16, 231:19 combined [5] 209:22, 211:18, 211:25, 213:17, 214:9 coming [3] - 173:15, 235:14, 235:20 comment [15] - 58:24, 68:6, 69:22, 85:24, 87:6, 88:25, 174:6, 179:12, 181:15, 183:11, 184:4, 201:19, 210:9, 229:12, 229:23 commentary [1] 210:7 commented [1] 183:16 commenting [1] 231:4 comments [56] 29:21, 29:23, 42:20, 42:21, 43:14, 43:18, 43:20, 44:4, 66:13, 66:16, 71:6, 72:9, 97:17, 101:2, 102:24, 177:11, 177:20, 177:22, 178:3, 178:4, 178:5, 178:8, 178:16, 180:6, 180:21, 181:6, 183:5, 183:18, 183:19, 183:20, 184:22, 184:23, 185:2, 185:5, 201:24, 202:14, 204:12, 207:6, 207:8, 215:22, 220:18, 220:22, 228:17, 228:21, 228:22, 231:23, 231:25, 232:16, 233:10, 235:3, 236:11, 236:20, 236:25, 237:5, 238:10 Comments [1] - 6:12 committed [1] - 174:2 common [1] - 68:24 commonly [2] - 120:4, 121:13 communication [1] - 15:22 community [1] - 91:14 Comp [1] - 30:22 companies [1] - 20:15 Company [2] - 3:11, 4:12 COMPANY [6] - 1:23, 2:2, 2:5, 2:7, 2:7, 2:8 comparable [1] - 39:11 compare [1] - 37:16 compared [3] - 96:6, 119:11, 207:20 compelling [1] - 47:23 Compensation [4] - 31:6, 31:13, 31:14, 31:16 Complaint [1] - 1:9 complete [5] - 10:25, 14:21, 128:6, 185:6, 220:24 completely [2] 149:15, 149:24 complex [2] - 36:13, 246 115:19 complication [3] - 223:13, 223:17, 223:23 complications [1] 39:16 compound [1] - 27:25 conceivable [1] 132:3 concentrated [1] 208:5 concentration [2] 88:17, 158:25 concept [1] - 126:16 concern [5] - 39:17, 40:9, 40:12, 40:16, 72:8 concerned [2] 167:25, 236:18 concerning [10] 14:5, 27:8, 30:7, 32:8, 40:5, 61:22, 87:21, 177:8, 209:21, 237:4 concerns [1] - 176:13 conclude [7] - 80:6, 89:2, 95:5, 139:2, 154:22, 192:7, 194:2 concluded [5] - 25:20, 27:4, 122:22, 136:22, 154:7 concluding [2] 156:6, 156:7 conclusion [19] 36:3, 38:5, 67:21, 81:2, 96:15, 100:5, 109:23, 110:4, 113:14, 113:17, 126:13, 126:20, 134:2, 147:10, 150:7, 150:12, 179:14, 202:19, 207:15 conclusions [2] 128:23, 167:9 condition [1] - 39:2 conditions [2] - 21:7, 165:20 conduct [2] - 90:6, 90:13 conducted [3] - 27:7, 95:16, 138:4 confer [2] - 60:17, 77:7 conference [1] - 21:13 conferences [6] 14:16, 14:23, 15:2, 15:4, 15:8, 15:13 confidence [1] - 79:23 conjecture [1] - 211:7 consider [22] - 14:19, 29:4, 34:18, 36:12, 47:17, 50:23, 98:17, 99:22, 100:7, 125:6, 137:24, 139:18, 139:21, 167:21, 167:25, 188:9, 189:24, 203:11, 219:10, 226:6, 231:16, 231:18 considerably [1] 159:4 considered [9] - 83:7, 93:10, 102:25, 103:10, 171:7, 186:13, 201:14, 235:14, 236:7 considering [2] 38:18, 171:10 consistent [8] - 48:4, 55:18, 81:19, 85:20, 136:23, 158:16, 159:19, 167:2 consult [5] - 24:13, 30:7, 30:16, 31:21, 32:4 consultation [1] 24:22 consulted [2] - 22:5, 32:12 consulting [1] - 32:13 contact [1] - 94:6 contain [4] - 90:20, 91:2, 91:7, 91:12 contained [2] - 42:17, 71:5 containing [1] - 94:6 contains [2] - 13:23, 63:3 contaminant [15] - 37:6, 87:16, 88:5, 88:12, 88:15, 88:18, 156:23, 165:6, 165:20, 169:18, 189:9, 189:13, 190:13, 196:4, 235:8 contaminated [2] 20:17, 20:18 contend [1] - 211:24 contenders [1] 136:10 content [1] - 234:15 context [2] - 30:8, 30:17 continue [2] - 175:10, 224:14 Continued [3] - 1:10, 2:1, 5:1 continued [4] - 4:1, 7:1, 39:21, 135:8 continuous [1] - 148:8 contract [2] - 141:20, 142:20 contracted [1] - 25:20 contradistinction [1] - 121:24 contributing [1] - 72:5 Control [1] - 77:22 control [19] - 47:21, 174:14, 203:11, 203:13, 203:21, 203:22, 207:11, 207:20, 208:20, 208:25, 209:7, 209:8, 209:11, 209:15, 209:17, 213:18, 214:9, 229:17, 229:19 controlled [3] - 202:7, 203:16, 205:12 controls [3] - 104:3, 104:11, 210:18 Cooper [5] - 76:19, 77:16, 78:11, 78:17, 78:20 copies [3] - 11:15, 12:25, 204:10 copy [7] - 11:14, 13:10, 13:12, 13:15, 230:13, 233:4, 239:8 corollary [1] - 60:14 Corp [1] - 4:6 CORP [1] - 2:6 Corporation [1] - 5:6 corporation [1] 30:25 CORPORATION [7] 2:2, 2:3, 2:5, 2:9, 2:10, 2:11, 2:12 corporations [1] 30:18 correct [43] - 9:13, 14:6, 14:11, 20:5, 22:23, 35:16, 35:17, 58:9, 69:25, 70:16, 78:19, 82:16, 89:15, 93:2, 99:2, 103:14, 108:17, 121:8, 131:19, 132:15, 138:6, 138:12, 138:20, 158:19, 161:8, 161:17, 167:21, 168:3, 180:23, 182:3, 186:16, 186:20, 186:23, 193:20, 203:21, 211:5, 220:19, 222:6, 225:3, 227:2, 227:11, 231:24, 232:16 correctly [3] - 41:5, 76:21, 167:3 correspondence [3] - 19:2, 19:8, 33:10 cortisol [1] - 197:24 cost [1] - 42:13 Costantini [4] - 6:17, 101:6, 102:15, 103:5 counsel [8] - 13:14, 22:7, 65:13, 72:10, 168:14, 172:19, 178:21, 239:3 count [5] - 14:19, 33:21, 33:25, 217:10, 217:12 counted [2] - 22:20, 25:3 counts [3] - 216:8, 217:8, 233:19 COUNTY [1] - 1:1 couple [4] - 15:6, 61:4, 145:24, 229:6 course [10] - 38:19, 43:7, 75:20, 94:21, 98:25, 104:4, 151:14, 176:25, 191:10, 191:15 court [8] - 24:18, 66:17, 66:20, 95:12, 113:4, 137:11, 178:23, 238:18 COURT [2] - 1:1, 1:23 cover [3] - 13:7, 63:8, 138:14 covered [1] - 138:4 crap [1] - 223:5 crash [1] - 168:13 CRC [3] - 1:8, 1:9, 4:22 creating [1] - 167:11 credible [1] - 170:24 creosote [1] - 25:6 criteria [1] - 38:13 critical [2] - 120:8, 229:13 critically [2] - 39:15, 39:21 criticism [8] - 177:25, 181:4, 183:2, 184:20, 184:25, 185:2, 185:3, 220:11 criticisms [7] - 178:6, 178:9, 180:21, 183:14, 185:13, 220:7, 220:16 criticized [2] - 181:18, 182:4 critique [3] - 219:7, 219:18, 227:7 critiqued [2] - 181:19, 182:4 critiques [1] - 182:25 crux [1] - 180:9 culprit [1] - 136:8 cumulative [17] - 36:21, 37:2, 103:17, 148:20, 148:25, 163:7, 163:11, 163:13, 163:17, 163:20, 164:11, 170:9, 174:18, 192:19, 193:3, 210:5, 219:25 cured [2] - 39:24, 155:17 current [5] - 13:21, 38:25, 84:4, 136:2, 165:19 cursory [1] - 45:6 Curtis [1] - 3:3 cut [9] - 44:25, 49:14, 56:12, 128:5, 128:10, 148:11, 175:22, 221:17, 225:17 cutting [3] - 48:23, 137:7, 176:9 CV [4] - 13:10, 13:13, 13:21, 13:22 cycles [1] - 141:15 cytogenetic [1] 120:19 Cytogenetics [1] 106:21 Cytoxan [2] - 192:14, 194:15 D daily [1] - 36:23 Dallas [1] - 3:16 damage [3] - 122:6, 122:23, 230:5 dangerous [1] - 154:10 data [51] - 12:5, 40:3, 46:18, 47:16, 47:19, 48:4, 48:8, 49:11, 55:15, 56:19, 80:25, 83:24, 84:3, 84:11, 89:10, 89:18, 89:24, 91:22, 92:20, 93:6, 97:17, 97:18, 109:19, 112:16, 113:7, 113:9, 117:7, 117:11, 117:14, 124:7, 125:15, 134:24, 143:2, 247 150:12, 158:20, 169:24, 177:6, 198:10, 198:16, 199:3, 202:22, 202:23, 203:2, 204:13, 204:20, 207:2, 207:5, 209:4, 209:20, 210:6, 210:22 date [15] - 17:19, 19:12, 21:21, 22:10, 39:2, 57:19, 57:21, 120:23, 133:3, 133:5, 149:17, 149:19, 160:22, 167:8 dated [6] - 13:18, 101:6, 101:7, 101:8 DAVID [1] - 1:4 David [38] - 9:12, 38:7, 38:17, 40:6, 40:19, 41:14, 42:8, 55:2, 55:8, 55:11, 55:23, 56:5, 57:10, 63:13, 63:24, 70:11, 71:13, 72:18, 72:25, 73:14, 74:10, 76:15, 78:9, 81:17, 85:20, 104:25, 105:12, 157:9, 159:18, 172:6, 188:11, 188:15, 193:19, 197:8, 199:6, 199:16, 199:25, 201:17 DaVita [1] - 28:11 daVita's [1] - 29:7 days [9] - 14:9, 87:15, 87:18, 87:22, 89:4, 142:3, 145:24, 230:24, 233:23 DE [1] - 2:7 de [63] - 48:5, 55:18, 60:18, 61:19, 68:6, 68:8, 81:19, 82:4, 82:5, 82:7, 82:11, 82:14, 83:8, 83:13, 85:20, 91:17, 92:2, 92:6, 119:10, 119:11, 119:16, 124:21, 125:3, 125:4, 152:5, 152:7, 152:11, 152:15, 153:3, 186:9, 186:13, 186:15, 186:17, 187:3, 187:7, 187:22, 187:25, 188:7, 188:9, 189:5, 189:11, 189:14, 190:10, 190:16, 190:25, 191:2, 191:23, 192:3, 192:8, 192:11, 192:16, 192:18, 193:5, 193:8, 194:3, 194:6, 194:12, 194:15, 194:19, 194:25, 195:4 deal [2] - 79:2, 158:12 dealing [4] - 28:20, 135:19, 201:23, 201:25 deals [4] - 19:8, 39:4, 126:22, 219:9 dealt [1] - 150:15 Deborah [1] - 209:3 decade [2] - 161:10 December [1] - 1:10 decipher [1] - 237:23 decision [3] - 36:3, 98:16, 98:18 decrease [2] - 127:3, 230:8 defendant [6] - 32:7, 32:11, 113:20, 234:21, 234:25 Defendant [6] - 3:11, 3:17, 4:11, 4:16, 4:22, 5:11 defendants [16] 12:17, 19:20, 21:11, 22:18, 24:4, 24:25, 30:9, 31:15, 110:23, 112:12, 186:3, 234:11, 235:13, 235:21, 236:8, 236:23 Defendants [3] - 2:13, 4:6, 5:5 defending [3] - 30:8, 30:17, 30:25 Defense [3] - 15:12, 33:4, 33:8 defense [5] - 15:14, 92:24, 97:24, 110:16, 111:2 defer [1] - 139:5 define [9] - 34:16, 36:17, 36:18, 36:19, 51:11, 82:4, 133:13, 140:17 defined [3] - 118:16, 133:8, 133:11 defines [1] - 234:4 defining [2] - 50:25, 144:15 definition [5] - 14:15, 35:4, 82:14, 133:17, 144:18 degreasers [1] - 48:25 degree [4] - 35:7, 79:22, 115:18, 164:2 Del [1] - 15:5 delay [1] - 49:23 delayed [1] - 146:19 deletion [2] - 125:2 deletions [3] - 120:7, 120:11 demonstrate [1] - 136:24 Department [2] - 33:3, 33:8 department [1] - 77:7 dependent [2] - 204:3, 216:25 Depo [1] - 3:6 deposition [28] - 1:14, 16:14, 16:15, 17:2, 23:23, 34:8, 34:10, 44:2, 47:2, 64:23, 69:11, 156:16, 159:8, 168:20, 176:16, 177:2, 179:22, 181:9, 181:10, 181:20, 181:23, 182:5, 182:9, 184:10, 184:11, 185:11, 207:3, 234:9 Deposition [2] - 11:7, 11:9 DEPOSITION [1] - 8:1 depositions [8] - 9:16, 11:19, 17:15, 22:2, 22:7, 43:2, 43:9, 223:10 depressed [1] 233:19 Dept [1] - 1:8 derive [2] - 94:19, 94:23 derived [1] - 38:16 dermal [11] - 79:5, 94:6, 94:11, 158:3, 158:8, 193:19, 195:9, 197:7, 199:18, 200:2, 201:16 dermatologist [2] 196:17, 196:22 describe [1] - 68:6 described [5] - 53:18, 92:18, 116:16, 191:22, 205:16 DESCRIPTION [2] 6:7, 7:2 Description [1] - 8:6 design [5] - 211:11, 211:18, 211:24, 213:17, 213:23 detail [1] - 206:18 detailed [3] - 24:16, 115:6, 206:19 details [10] - 96:2, 98:8, 103:21, 158:12, 204:23, 205:2, 205:5, 205:22, 206:3, 214:14 detectable [1] - 198:2 determinant [1] 164:3 determine [7] - 26:22, 37:17, 60:8, 60:11, 84:8, 94:14, 168:15 determined [3] 25:24, 26:16, 152:2 determining [3] 99:23, 122:7, 133:4 develop [1] - 190:4 developed [1] 189:14 Development [1] 134:14 development [1] 51:3 diagnose [1] - 90:14 diagnosed [10] - 38:8, 40:20, 51:14, 55:14, 87:23, 88:9, 89:21, 114:12, 114:14, 119:3 diagnosis [39] - 38:10, 38:18, 41:4, 48:3, 52:5, 55:24, 56:6, 57:16, 57:24, 60:5, 81:18, 85:19, 89:17, 118:13, 132:14, 132:24, 133:22, 140:11, 140:19, 147:20, 147:22, 148:2, 148:10, 148:15, 148:19, 148:22, 148:24, 149:17, 149:20, 156:14, 159:12, 160:6, 160:8, 160:15, 160:17, 163:25, 192:11, 193:5, 194:21 diesel [2] - 171:18, 171:20 difference [10] - 17:9, 115:11, 115:15, 118:5, 122:4, 124:7, 160:3, 160:13, 197:17, 203:15 differences [2] 124:15, 192:3 different [26] - 49:16, 50:24, 56:15, 57:15, 70:18, 108:21, 115:20, 116:22, 116:23, 117:20, 118:7, 118:8, 126:7, 132:11, 134:10, 139:19, 143:15, 149:15, 153:2, 158:2, 167:16, 168:8, 169:23, 177:6, 200:18, 205:16 differently [1] - 105:21 differs [1] - 158:6 DIPPONG [2] - 5:3, 239:11 direct [4] - 46:16, 63:5, 146:16, 172:20 DIRECTION [1] - 8:2 directly [3] - 88:4, 134:22, 230:5 disagree [16] - 59:6, 61:8, 127:15, 127:23, 128:22, 130:17, 130:22, 133:2, 179:13, 179:16, 179:24, 179:25, 180:4, 184:4, 184:12, 229:14 disagreement [5] 125:10, 130:25, 131:5, 172:4, 181:3 disappeared [1] 135:4 disappearing [1] 74:12 disciplines [1] - 35:6 disclose [1] - 64:24 disclosed [1] - 176:15 discloses [1] - 179:2 discolored [1] 199:13 discovery [1] - 234:8 discuss [7] - 65:14, 106:15, 106:21, 130:25, 202:23, 206:17, 217:14 discussed [20] 27:18, 46:24, 46:25, 47:24, 48:8, 113:9, 139:3, 165:3, 186:2, 192:2, 197:10, 215:21, 218:14, 221:23, 221:25, 228:25, 229:2, 231:14, 231:15, 237:8 discussing [4] - 248 31:12, 230:18, 233:2, 233:12 discussion [11] 36:15, 43:22, 46:22, 47:23, 49:2, 65:5, 83:4, 107:2, 170:19, 202:20, 218:19 Discussion [3] - 31:8, 187:13, 238:15 disease [19] - 27:4, 27:10, 27:24, 30:8, 30:17, 30:23, 31:3, 31:22, 32:23, 35:23, 36:9, 39:17, 94:16, 133:6, 138:21, 138:24, 163:22, 168:9, 229:7 diseases [2] - 27:18, 202:4 disks [1] - 12:21 disproving [1] 187:11 dissertation [1] 128:17 distant [1] - 41:9 distill [1] - 164:16 distinct [1] - 213:24 distinction [2] - 83:16, 152:7 distinguish [1] 145:21 distribution [4] 205:15, 209:22, 211:25, 214:10 DISTRICT [1] - 1:2 diverging [1] - 139:17 DNA [7] - 120:13, 153:24, 154:2, 154:3, 230:4, 230:5, 230:8 Doctor [14] - 9:8, 18:21, 49:14, 53:8, 56:11, 72:14, 84:23, 85:14, 157:23, 172:16, 174:7, 189:20, 189:23, 221:9 doctor [31] - 29:2, 31:12, 51:17, 56:5, 59:3, 63:12, 72:8, 96:4, 99:3, 99:15, 99:23, 100:2, 125:24, 128:21, 132:9, 144:12, 152:25, 158:5, 159:6, 165:9, 168:15, 175:2, 176:3, 176:20, 182:25, 187:21, 222:20, 222:24, 224:18, 225:18, 225:22 Doctor's [1] - 222:20 doctor's [3] - 99:14, 183:10, 224:9 doctors [4] - 186:3, 196:15, 201:24, 230:2 Doctors [1] - 219:18 document [22] 18:13, 22:12, 29:14, 29:15, 29:25, 73:8, 76:5, 93:23, 101:19, 135:23, 211:9, 211:13, 212:11, 212:25, 213:10, 215:15, 232:19, 236:10, 236:23, 236:24, 237:14, 238:4 documented [1] 180:8 DOCUMENTS [1] - 8:5 documents [19] 11:11, 12:10, 13:8, 18:4, 33:16, 201:7, 215:6, 224:20, 232:4, 234:8, 234:10, 234:21, 234:22, 235:2, 235:13, 235:19, 236:7, 236:9, 237:16 DOES [1] - 2:12 DOI [1] - 71:7 Doll [2] - 6:19, 73:22 DOLL [1] - 73:22 done [17] - 9:18, 32:21, 67:25, 69:7, 69:11, 126:13, 127:17, 141:4, 141:10, 150:11, 166:17, 177:13, 213:4, 225:9, 227:16, 233:9, 233:13 donor [1] - 39:6 dose [26] - 60:15, 61:15, 67:16, 67:20, 67:22, 89:5, 103:16, 151:15, 163:17, 164:11, 167:10, 169:14, 170:8, 170:9, 176:23, 179:15, 192:20, 192:22, 193:3, 202:8, 202:15, 202:17, 204:2, 215:24, 216:2, 219:25 doses [1] - 210:5 double [2] - 167:17, 208:15 double-check [1] 167:17 DOUGLAS [1] - 5:8 down [6] - 53:25, 59:7, 173:20, 206:12, 206:13, 237:14 Dr [108] - 6:8, 6:10, 6:12, 34:7, 34:9, 44:2, 44:4, 60:20, 61:9, 66:25, 67:2, 72:3, 75:9, 76:21, 76:22, 76:23, 77:19, 98:5, 107:3, 107:4, 108:2, 110:18, 110:21, 110:25, 111:3, 111:25, 112:20, 123:6, 123:12, 123:14, 123:19, 124:2, 124:3, 124:17, 125:6, 128:21, 129:6, 129:9, 129:13, 129:14, 130:15, 137:17, 157:25, 158:2, 158:11, 158:12, 158:14, 158:17, 158:23, 164:25, 166:8, 166:13, 167:13, 172:4, 173:11, 174:8, 175:6, 175:18, 176:4, 176:13, 176:14, 176:22, 177:9, 177:23, 177:25, 178:6, 178:9, 178:16, 179:14, 180:22, 181:2, 181:4, 181:19, 181:22, 182:4, 182:16, 183:2, 183:15, 183:22, 184:5, 184:7, 184:18, 184:21, 184:25, 185:14, 202:14, 202:15, 214:18, 216:4, 218:25, 219:2, 219:7, 220:2, 229:4, 229:12, 229:23, 230:11, 230:19, 231:8, 238:23, 238:25 draft [1] - 174:15 dramatic [2] - 115:15, 118:5 draw [3] - 89:10, 109:19, 122:24 drawing [1] - 96:15 drawn [2] - 113:14, 113:16 drop [1] - 51:8 dude [1] - 222:9 due [4] - 39:11, 83:14, 127:5, 190:19 duly [1] - 9:4 duplicate [2] - 75:15, 75:16 DuPont [110] - 3:3, 9:7, 9:11, 18:8, 18:17, 18:24, 22:16, 23:19, 30:5, 30:14, 31:11, 32:16, 32:19, 34:12, 42:2, 43:12, 45:16, 47:8, 51:16, 53:7, 54:9, 54:15, 56:17, 58:17, 59:2, 59:16, 62:5, 62:11, 63:11, 64:8, 64:17, 65:11, 65:21, 67:10, 67:24, 69:7, 69:12, 69:17, 70:2, 70:3, 72:7, 72:13, 73:12, 75:11, 75:25, 76:9, 77:5, 78:5, 81:25, 82:13, 84:21, 85:5, 85:13, 94:3, 96:3, 96:13, 96:25, 97:7, 97:19, 98:11, 98:21, 99:2, 99:21, 100:11, 102:19, 105:11, 105:25, 108:15, 109:21, 111:24, 112:8, 113:12, 114:2, 114:7, 116:9, 122:19, 125:23, 128:13, 129:19, 140:14, 141:3, 144:11, 153:8, 172:19, 173:4, 178:21, 182:24, 189:3, 189:21, 191:5, 200:23, 201:11, 204:11, 213:14, 215:12, 218:22, 220:15, 221:8, 222:2, 223:6, 224:2, 224:17, 224:25, 225:20, 225:24, 226:11, 226:18, 232:13, 232:23, 238:8 DUPONT [1] - 2:7 duPONT [64] - 23:13, 42:21, 50:9, 56:11, 61:23, 62:8, 65:4, 75:2, 97:5, 111:10, 124:9, 125:18, 127:8, 127:13, 127:18, 128:20, 129:12, 129:24, 130:11, 130:14, 131:9, 132:20, 137:16, 145:5, 146:10, 146:20, 150:5, 153:12, 157:15, 157:18, 158:7, 161:5, 165:8, 166:7, 166:20, 167:7, 167:19, 167:23, 168:14, 168:25, 169:5, 169:11, 170:25, 172:25, 174:25, 175:16, 176:2, 176:19, 179:3, 180:2, 180:17, 181:16, 181:17, 181:24, 182:2, 182:10, 183:12, 184:16, 187:20, 222:10, 222:17, 223:16, 223:20, 239:12 DuPont................. [1] - 6:3 during [6] - 118:11, 145:7, 145:18, 145:22, 146:3, 183:4 duties [1] - 238:19 duty [1] - 210:12 dying [1] - 39:11 E E-mail [1] - 6:9 e-mail [5] - 15:20, 15:24, 16:4, 18:10, 18:19 e-mailed [1] - 13:13 e-mails [5] - 11:15, 12:24, 15:17, 17:25, 33:13 E-Med [1] - 93:14 E.I [1] - 2:7 earliest [1] - 19:11 early [4] - 14:9, 115:3, 238:23, 238:24 earned [1] - 22:25 easily [1] - 235:25 East [1] - 4:9 educate [1] - 10:25 effect [7] - 126:25, 127:2, 127:4, 146:19, 151:6, 197:11, 233:17 effects [2] - 146:16, 249 230:17 Effects [2] - 107:5, 123:8 egregiously [1] - 166:16 eight [10] - 43:19, 53:13, 53:23, 100:25, 102:23, 132:10, 133:20, 156:21, 160:4, 208:8 eighth [2] - 57:13, 58:5 eighties [2] - 161:7, 161:8 either [13] - 43:6, 63:4, 76:21, 103:17, 111:16, 111:22, 126:14, 128:9, 155:9, 175:22, 185:24, 220:5, 239:6 elaborate [1] - 63:17 elaborated [2] - 175:8, 179:21 elaborations [1] 178:12 electronic [1] - 93:14 electronically [1] 70:19 elevator [1] - 168:10 elsewhere [2] - 47:12, 214:4 encompass [2] 177:21, 178:5 end [1] - 149:6 ended [3] - 149:19, 192:22, 193:4 ends [3] - 148:9, 148:21, 161:4 engaged [1] - 23:22 engagement [4] 18:19, 18:23, 19:2, 19:5 engineering [2] 37:24, 104:2 entered [1] - 205:19 entire [1] - 102:2 entirely [1] - 228:23 entitled [3] - 173:6, 179:4, 182:11 entry [1] - 203:18 Environmental [1] 212:6 enzymes [1] - 154:3 eosinophil [1] 217:22 eosinophils [1] 218:4 EPA [7] - 174:12, 177:10, 210:3, 210:8, 211:19, 213:19, 214:11 epidemiologic [3] - 136:23, 137:15, 140:3 epidemiological [4] 138:8, 138:11, 139:23, 144:14 epidemiologist [5] 137:25, 139:6, 139:12, 139:16, 139:23 epidemiology [20] 27:13, 27:18, 27:19, 27:22, 27:24, 27:25, 28:20, 28:22, 122:5, 137:8, 138:5, 138:14, 138:15, 138:17, 138:20, 138:22, 139:3, 139:7, 139:13, 144:21 equation [1] - 36:5 equipment [1] 103:22 era [5] - 50:14, 56:20, 57:3, 116:23, 116:25 Ernie's [1] - 5:12 ERNIE'S [1] - 2:9 error [1] - 17:21 ESQUIRE [9] - 3:3, 3:8, 3:14, 4:3, 4:8, 4:14, 4:19, 5:3, 5:8 establish [1] - 117:7 established [1] 135:12 establishes [1] 117:12 estimate [7] - 33:24, 34:2, 41:12, 71:22, 86:7, 87:19, 161:25 estimates [2] - 35:9, 35:11 Estimates [1] - 7:8 et [2] - 116:21, 212:5 Ethan [3] - 110:15, 112:10, 113:19 etiology [2] - 99:18, 138:25 Etiology [1] - 86:21 evaluated [1] - 236:12 evaluating [1] 185:10 event [6] - 57:20, 68:11, 120:8, 151:8, 151:10, 151:13 events [1] - 68:17 evidence [8] - 86:11, 112:18, 143:20, 143:23, 166:4, 169:20, 195:24, 217:15 evident [1] - 10:9 evoke [1] - 43:11 evolution [3] - 68:21, 68:23, 154:17 ex [1] - 136:3 ex-smokers [1] - 136:3 exactly [5] - 119:21, 119:24, 120:9, 162:11, 213:6 examined [1] - 9:5 exceedingly [1] 150:2 excellent [1] - 40:17 exceptions [1] 166:18 excluded [1] - 127:7 excludes [3] - 109:24, 110:6, 110:7 exclusion [2] 192:12, 194:21 excreted [1] - 141:23 excuse [4] - 62:7, 64:11, 100:25, 114:8 exercise [1] - 184:2 exhaust [3] - 104:10, 131:20, 232:24 exhausted [2] - 70:5, 204:12 exhibit [14] - 23:7, 23:8, 73:6, 75:24, 76:3, 93:21, 135:18, 135:21, 135:25, 212:9, 214:21, 228:8, 229:3, 238:2 Exhibit [41] - 17:25, 18:6, 18:11, 18:15, 22:8, 22:14, 29:23, 30:3, 42:18, 73:6, 73:10, 76:7, 93:25, 101:17, 101:21, 102:21, 109:11, 109:15, 118:19, 118:22, 120:17, 123:5, 123:6, 131:11, 131:23, 178:3, 201:2, 201:5, 201:9, 201:12, 212:13, 213:12, 213:16, 215:8, 215:17, 220:19, 232:6, 232:21, 236:19, 238:6, 238:11 EXHIBIT [2] - 6:7, 7:2 Exhibits [1] - 7:1 exhibits [7] - 201:21, 202:11, 214:20, 219:17, 224:19, 226:23, 227:8 existing [2] - 121:14, 151:23 Exosome [1] - 86:20 expand [2] - 81:24, 184:5 expanded [1] - 175:9 expect [16] - 10:8, 23:16, 42:22, 57:16, 71:24, 77:3, 78:3, 108:13, 129:5, 158:23, 159:23, 164:19, 177:15, 180:13, 184:9, 184:10 expectancy [3] 38:17, 40:19, 41:5 expectation [9] 39:23, 40:2, 66:2, 86:6, 87:8, 138:25, 166:6, 220:20, 233:22 expected [6] - 131:6, 208:11, 208:14, 208:16, 208:17, 210:11 expensive [2] - 24:21, 42:5 experience [6] - 44:6, 44:10, 44:12, 44:13, 44:14, 159:23 expert [6] - 20:23, 21:10, 75:8, 83:10, 97:11, 97:25 expert's [2] - 78:2, 228:12 expertise [1] - 35:8 experts [15] - 35:10, 45:10, 74:25, 77:4, 77:10, 110:16, 116:4, 207:2, 215:23, 220:7, 220:12, 225:3, 227:7, 228:15, 230:14 experts' [2] - 11:19, 48:10 explaining [1] - 11:4 explanation [1] - 31:5 explore [1] - 224:9 expose [1] - 165:14 exposed [37] - 26:21, 37:16, 60:9, 82:21, 82:22, 83:17, 84:9, 87:15, 87:16, 87:21, 96:6, 96:7, 105:14, 106:10, 115:10, 115:14, 115:23, 116:15, 116:17, 117:3, 117:5, 119:18, 121:7, 122:15, 131:18, 136:20, 137:3, 141:11, 147:17, 152:4, 153:15, 153:18, 171:18, 171:21, 195:15, 203:20, 218:15 Exposed [1] - 7:14 exposure [189] 20:11, 23:2, 24:24, 25:21, 26:2, 26:24, 27:5, 32:5, 32:23, 35:9, 35:12, 35:15, 35:18, 35:24, 36:7, 36:10, 36:20, 36:22, 36:24, 37:2, 37:9, 37:10, 37:18, 37:21, 37:23, 37:24, 43:19, 44:5, 48:10, 48:13, 48:16, 51:3, 51:5, 51:7, 51:8, 60:3, 60:15, 67:9, 82:24, 82:25, 83:23, 84:7, 86:2, 86:9, 86:11, 87:24, 88:10, 89:4, 89:5, 89:8, 90:6, 90:13, 91:18, 94:5, 95:20, 95:21, 103:16, 109:10, 112:13, 114:21, 114:25, 115:5, 115:7, 116:24, 117:8, 117:13, 117:18, 117:23, 118:14, 118:15, 118:21, 122:8, 122:25, 131:25, 132:22, 133:3, 133:6, 133:14, 133:21, 134:22, 136:14, 136:18, 136:25, 137:5, 144:15, 144:22, 145:8, 145:17, 145:19, 146:25, 148:8, 148:18, 148:20, 148:25, 149:7, 149:8, 149:16, 149:18, 150:18, 150:22, 150:23, 151:5, 151:12, 151:15, 151:18, 152:12, 153:4, 153:5, 153:10, 157:3, 157:4, 157:7, 157:8, 157:13, 158:3, 158:8, 158:16, 158:20, 159:4, 159:11, 161:16, 250 161:20, 161:22, 163:11, 163:13, 163:17, 163:20, 163:23, 163:24, 164:2, 164:4, 164:6, 164:11, 165:6, 165:19, 166:15, 166:21, 166:22, 167:10, 168:2, 169:19, 174:18, 176:6, 177:3, 179:18, 188:14, 188:20, 189:7, 189:16, 189:25, 190:2, 190:9, 190:13, 191:8, 191:13, 191:19, 192:20, 192:22, 193:3, 193:10, 193:14, 196:25, 197:7, 202:2, 202:25, 207:14, 207:16, 207:18, 208:4, 208:5, 208:7, 208:13, 208:21, 209:19, 212:16, 212:21, 216:7, 217:9, 217:21, 218:9, 219:9, 233:17, 233:20, 235:6, 235:9, 235:10 Exposure [2] - 7:8, 134:14 exposures [22] - 32:8, 56:20, 67:5, 92:22, 93:7, 146:4, 147:19, 147:22, 148:12, 148:14, 148:23, 150:25, 156:13, 159:19, 159:22, 160:4, 160:13, 160:14, 160:21, 166:11, 169:14, 170:8 Expressway [1] - 3:15 extensive [1] - 24:16 extent [9] - 71:20, 222:3, 225:15, 225:21, 225:25, 226:20, 227:4, 227:8, 236:6 external [6] - 52:8, 59:15, 68:17, 151:24, 152:16, 154:11 extrinsic [1] - 57:22 F FAB [1] - 38:12 face [2] - 207:17, 207:24 fact [9] - 60:21, 79:23, 117:25, 143:11, 157:2, 173:13, 195:13, 199:6, 211:6 factor [27] - 46:15, 46:23, 47:3, 47:17, 47:18, 54:19, 55:2, 55:8, 70:11, 71:13, 72:5, 72:17, 72:24, 73:14, 74:9, 76:15, 78:8, 79:9, 79:13, 79:14, 79:17, 79:18, 79:21, 79:24, 80:16, 152:16, 170:2 factors [5] - 43:17, 67:22, 105:17, 203:24, 204:2 facts [2] - 112:18, 173:19 failed [1] - 210:21 fair [3] - 23:24, 69:14, 201:17 fairly [1] - 213:7 fallacious [1] - 125:17 falls [1] - 188:16 false [1] - 198:10 familiar [1] - 37:19 far [5] - 58:9, 65:15, 68:16, 196:14, 210:18 fast [1] - 124:25 favor [1] - 125:11 FDA [3] - 196:7, 196:9, 196:13 Features [1] - 106:18 federal [1] - 178:23 Federally [1] - 1:17 fellow [1] - 110:11 felt [2] - 196:5, 221:3 few [2] - 55:25, 155:5 fewer [2] - 87:9, 208:21 fide [1] - 83:19 field [4] - 28:9, 90:25, 91:5, 91:7 Fifth [1] - 4:20 fifth [4] - 56:18, 56:23, 92:19, 120:11 fifties [2] - 99:5, 115:5 Figueroa [1] - 4:3 figure [11] - 23:16, 23:25, 83:15, 84:16, 86:6, 86:13, 86:14, 86:24, 88:2, 92:6, 92:8 Figure [2] - 124:18, 124:23 figures [3] - 39:9, 39:13, 133:23 file [1] - 33:9 Filed [1] - 1:10 filed [1] - 227:15 findings [5] - 96:5, 114:17, 116:7, 119:7, 136:23 fine [5] - 19:6, 116:8, 173:9, 204:18, 218:3 finish [7] - 56:8, 56:9, 175:25, 189:19, 189:22, 225:18, 225:22 finished [3] - 129:23, 129:25, 209:25 firemen [1] - 116:21 firm [3] - 15:7, 81:2 FIRM [1] - 3:2 firms [1] - 19:22 first [35] - 9:4, 15:4, 15:22, 21:12, 21:14, 23:7, 27:15, 39:8, 44:22, 45:18, 49:16, 50:3, 51:2, 51:4, 51:8, 51:9, 66:23, 82:3, 92:23, 95:10, 103:3, 106:16, 106:24, 111:4, 114:10, 122:15, 126:4, 126:14, 133:3, 133:5, 133:14, 144:14, 144:22, 149:10, 186:9 fit [4] - 53:2, 111:11, 121:18, 204:2 five [29] - 25:7, 25:8, 51:23, 57:18, 58:2, 100:25, 115:17, 126:14, 130:9, 132:14, 132:23, 133:22, 134:8, 135:5, 135:7, 135:16, 146:2, 146:3, 146:15, 147:6, 148:2, 148:9, 148:21, 149:19, 166:25, 169:23, 180:16, 222:18 Floor [1] - 5:3 FOAM [1] - 2:8 focused [1] - 138:24 folder [1] - 235:24 folks [1] - 57:14 followed [1] - 166:16 following [1] - 111:25 follows [1] - 9:5 FOR [3] - 1:1, 1:1, 8:5 Ford [1] - 4:11 FORD [1] - 2:2 form [4] - 38:7, 122:9, 143:18, 200:13 formal [5] - 40:22, 107:14, 185:8, 225:6, 227:15 format [1] - 9:17 formed [2] - 130:18, 160:23 forming [2] - 102:25, 103:11 forth [21] - 43:14, 89:12, 103:16, 167:12, 177:11, 178:2, 178:10, 178:12, 180:4, 181:5, 183:23, 211:10, 211:17, 213:16, 213:22, 214:11, 220:17, 227:22, 228:21, 235:2, 237:5 forties [1] - 205:18 forward [1] - 10:11 foundation [2] 122:10, 200:13 Four [1] - 77:22 four [18] - 22:23, 25:5, 32:17, 51:23, 55:11, 57:17, 57:25, 74:18, 81:17, 132:13, 132:23, 133:22, 134:7, 155:7, 155:13, 155:15, 177:21, 185:24 fourth [1] - 85:21 frame [1] - 52:5 framework [3] 204:24, 205:23, 206:4 FRANKLIN [1] - 5:2 frankly [4] - 19:18, 41:16, 75:8, 234:14 FRASER [1] - 4:3 fraser@lbbslaw.com [1] - 4:5 free [1] - 63:9 frequency [4] 121:22, 124:5, 124:7, 124:15 frequent [2] - 83:24, 119:15 frequently [1] - 99:7 front [7] - 11:14, 11:16, 13:5, 17:20, 23:16, 89:19, 205:23 fuel [1] - 48:25 full [4] - 120:7, 120:10, 178:11, 236:4 fully [3] - 178:9, 178:11, 224:8 function [3] - 151:9, 158:10, 207:14 furthermore [1] - 26:7 future [1] - 166:9 Future [1] - 86:20 G game [1] - 69:14 gas [3] - 82:23, 147:12, 234:13 gasoline [3] - 83:5, 86:10, 152:20 gather [2] - 101:15, 101:24 gathers [1] - 98:24 gee [1] - 69:12 general [23] - 12:6, 15:10, 21:4, 21:8, 28:21, 42:12, 43:21, 48:12, 61:8, 66:24, 67:3, 79:10, 106:7, 121:16, 171:13, 172:5, 172:14, 178:20, 179:24, 184:6, 203:23, 220:25, 221:24 generalize [1] - 95:24 generally [27] - 12:2, 17:8, 27:23, 51:24, 57:18, 68:7, 90:24, 91:5, 91:6, 91:9, 91:11, 91:13, 92:2, 107:10, 114:16, 132:13, 133:21, 135:13, 139:5, 143:16, 145:24, 156:24, 164:5, 190:10, 190:12, 191:23, 227:16 generate [1] - 205:3 generically [1] 134:24 genes [1] - 142:18 genetic [6] - 141:22, 142:3, 142:6, 142:11, 192:3, 217:25 genetically [1] - 52:14 genetics [1] - 114:20 Genetics [2] - 106:20, 131:12 genome [1] - 154:6 genotypes [1] - 217:2 geometric [1] - 48:13 GERCHMAN [2] - 1:4, 1:5 Gerchman [19] - 9:12, 9:13, 38:7, 40:6, 251 52:3, 57:10, 61:16, 61:20, 67:18, 67:23, 72:6, 85:20, 104:25, 105:12, 157:10, 172:6, 197:8, 201:17, 217:11 gerchman [1] - 60:3 Gerchman's [35] 38:17, 40:19, 41:14, 42:8, 43:6, 47:7, 55:2, 55:9, 55:11, 55:23, 56:6, 60:21, 63:14, 63:24, 67:7, 69:3, 70:12, 71:13, 72:18, 72:25, 73:14, 74:10, 76:16, 78:9, 81:17, 156:13, 159:11, 159:19, 179:17, 188:12, 188:16, 193:19, 199:7, 199:16, 199:25 Gerhardt [1] - 134:16 Germany [1] - 136:17 Gip [2] - 197:21, 201:13 gist [1] - 28:2 given [20] - 9:16, 33:12, 33:14, 43:5, 47:4, 58:9, 80:17, 87:10, 87:11, 117:19, 146:18, 152:23, 204:19, 204:23, 223:17, 226:5, 231:23, 231:25, 232:15 glass [1] - 207:10 Glass [12] - 7:8, 7:9, 170:19, 171:2, 204:7, 209:3, 209:7, 209:9, 209:14, 214:21, 214:23, 215:2 gleaned [1] - 234:18 GnG [1] - 156:18 goal [3] - 211:10, 211:24, 214:8 Godelli [1] - 229:6 government [10] 31:19, 32:3, 32:7, 32:21, 32:22, 32:25, 122:20, 122:21, 167:9 grab [1] - 15:16 GRACEY [1] - 4:13 graft [1] - 39:16 gray [1] - 10:23 great [1] - 148:3 greater [9] - 160:3, 160:14, 160:18, 160:19, 161:4, 161:6, 161:7, 208:4, 230:23 greg [2] - 53:15, 111:13 Greg [15] - 41:25, 46:13, 56:9, 64:4, 64:12, 64:16, 65:17, 81:21, 82:11, 105:7, 105:22, 112:5, 116:6, 123:17 Gregory [1] - 6:2 GREGORY [2] - 1:14, 9:3 grossly [1] - 205:10 group [29] - 19:20, 60:9, 94:14, 96:6, 106:10, 106:13, 107:18, 107:24, 117:20, 117:21, 118:2, 185:20, 185:23, 186:4, 203:11, 203:13, 203:15, 203:20, 203:21, 203:22, 203:23, 205:8, 207:20, 208:7, 208:10, 208:12, 208:14, 208:20, 209:19 groups [1] - 205:12 guess [5] - 22:22, 53:9, 145:15, 183:25, 202:5 guessing [1] - 44:20 guesstimate [1] 22:21 guiding [1] - 29:9 Gunn [6] - 207:21, 209:6, 209:10, 219:11, 219:13, 229:2 Guo [3] - 6:16, 101:6, 103:6 GUO [1] - 101:7 guy [2] - 64:22, 173:13 guys [1] - 75:6 H half [5] - 56:2, 56:3, 84:20, 156:17, 222:18 hand [1] - 77:6 handed [1] - 135:19 handle [2] - 17:5, 24:25 handling [1] - 200:18 handout [3] - 44:3, 181:12, 184:24 handouts [1] - 14:17 hands [2] - 44:12, 44:14 hands-on [2] - 44:12, 44:14 handwriting [1] - 237:23 handwritten [3] - 7:18, 237:17, 238:9 hang [2] - 129:8, 175:20 hanging [1] - 143:23 Hanson [1] - 5:11 HANSON [1] - 2:9 happy [2] - 64:15, 111:8 hard [1] - 84:8 hardship [1] - 17:4 harrison [1] - 184:25 Harrison [26] - 45:12, 61:10, 67:2, 75:10, 76:22, 77:19, 172:4, 172:18, 173:24, 175:6, 181:2, 181:19, 183:2, 183:15, 184:18, 184:21, 202:15, 214:18, 216:5, 219:2, 219:7, 219:18, 229:24, 230:11, 230:15, 230:16 Harrison's [11] - 34:9, 44:3, 176:14, 181:4, 181:10, 181:22, 182:4, 183:22, 184:5, 185:14, 231:8 hat [1] - 143:24 hate [1] - 220:2 Hayes [8] - 7:10, 202:2, 203:6, 203:7, 203:8, 203:10, 203:15, 215:11 head [4] - 41:11, 108:9, 154:12, 171:23 Health [9] - 7:8, 31:20, 38:13, 107:5, 123:8, 158:21, 207:8, 209:12, 212:6 health [1] - 41:6 Health" [1] - 107:7 healthcare [1] - 42:13 healthy [4] - 41:3, 126:25, 127:2, 127:4 hear [7] - 12:23, 21:24, 34:21, 34:23, 40:14, 95:10, 104:6 heard [1] - 111:5 heavy [1] - 26:13 Heidelberg [1] - 137:22 held [4] - 31:8, 187:13, 218:19, 238:15 help [1] - 223:2 hematologic [2] - 28:13, 216:16 hematologist [3] - 37:15, 90:19, 90:23 hematologist/ oncologist [1] - 38:4 hematology [4] - 28:8, 28:21, 29:3, 29:9 hematopoietic [1] - 27:9 hematotoxic [1] - 233:17 Hematotoxicity [1] - 7:13 hematoxicity [2] - 215:24, 216:22 HENKEL [3] - 2:3, 2:10, 2:12 Henkel [1] - 4:6 heparin [2] - 20:17, 20:19 hereinafter [1] - 135:15 hexavalent [1] - 25:5 high [15] - 37:10, 37:18, 48:9, 56:20, 83:15, 88:17, 92:21, 93:7, 147:13, 149:6, 206:24, 208:4, 208:13, 209:19, 217:21 higher [7] - 82:23, 83:22, 159:22, 162:18, 205:13, 207:16, 208:9 highest [1] - 208:6 Hills [1] - 5:10 himself [1] - 168:16 hired [10] - 19:9, 30:6, 30:15, 30:22, 33:4, 110:22, 110:25, 112:11, 113:20, 186:3 Hiroshima [4] 141:12, 142:23, 143:7, 143:17 history [22] - 26:25, 41:9, 84:12, 86:8, 95:20, 95:21, 114:21, 114:25, 122:17, 136:18, 149:18, 164:6, 188:13, 188:20, 189:6, 189:12, 189:16, 189:25, 190:9, 190:15, 191:20, 196:2 Hodgkin's [2] 127:21, 130:16 HOGAN [1] - 3:8 Hogan [2] - 1:15, 15:24 hold [12] - 44:18, 46:10, 73:17, 74:22, 102:13, 111:12, 127:11, 128:22, 172:15, 187:21, 193:22, 200:12 holds [3] - 127:22, 129:14, 130:17 Hon [1] - 1:7 hook [1] - 9:19 hopefully [1] - 101:24 hoping [1] - 60:23 hospitalization [1] 39:19 host [1] - 39:16 HOTZ [1] - 100:18 Hotz [4] - 6:17, 100:17, 101:5, 103:3 hour [8] - 16:12, 16:16, 16:17, 17:2, 17:15, 84:20, 141:13, 160:4 hours [3] - 23:17, 180:16, 222:19 Houtz [1] - 49:9 huge [1] - 68:14 human [4] - 198:7, 198:14, 198:25, 200:9 hundred [4] - 152:18, 152:21, 152:22, 152:23 hundreds [2] - 144:13, 144:19 hydrocortisone [3] 197:16, 197:18, 198:6 hygiene [4] - 34:15, 34:17, 44:7, 44:11 hygienist [3] - 34:19, 35:3, 44:9 hypothetical [5] 96:10, 97:15, 100:8, 100:9, 190:7 I i.e [1] - 174:19 IARC [1] - 31:21 idea [1] - 92:17 identifiable [2] - 48:6, 252 188:17 identification [16] - 18:5, 18:14, 30:2, 73:9, 76:6, 93:24, 101:20, 109:14, 201:8, 212:12, 213:11, 215:7, 215:16, 232:5, 232:20, 238:5 identified [11] - 22:13, 45:6, 82:20, 219:3, 219:6, 222:6, 224:18, 226:25, 227:10, 233:14, 236:9 identify [13] - 12:9, 214:6, 222:4, 222:21, 222:25, 223:2, 223:24, 227:9, 227:19, 228:9, 235:25, 236:24, 237:11 idiopathic [2] - 187:4, 187:6 ignoring [1] - 173:13 II [1] - 121:17 ill [2] - 39:15, 39:21 illegible [1] - 237:19 ILLINOIS [1] - 2:3 Illinois [1] - 4:6 illness [2] - 25:24, 25:25 illnesses [1] - 26:5 immediate [1] 223:12 immune [3] - 189:10, 190:16, 191:2 imperfect [1] - 70:8 Implications [1] 134:13 implicit [1] - 60:2 implies [1] - 135:5 important [8] 167:21, 167:24, 173:25, 229:10, 236:13, 236:16, 236:22, 238:12 impossible [1] 153:19 improper [1] - 169:7 improved [2] - 39:25, 40:25 Imuran [2] - 80:12, 81:7 inadequate [1] 150:21 INC [6] - 1:7, 1:8, 1:10, 2:3, 2:6, 2:8 Inc [6] - 2:4, 3:18, 4:6, 4:17, 4:23, 5:6 incidence [1] - 75:21 include [7] - 12:21, 106:8, 126:6, 162:14, 178:5, 183:18, 189:15 included [1] - 94:12 includes [1] - 183:19 including [6] - 15:25, 35:23, 36:9, 152:12, 183:24, 214:17 inclusions [1] - 210:7 inclusive [1] - 2:13 incomplete [4] 96:10, 97:14, 185:9, 190:7 incorporated [1] 17:7 increase [19] - 47:22, 79:5, 88:6, 126:24, 163:10, 163:18, 166:5, 169:15, 169:17, 170:9, 190:20, 190:23, 193:19, 195:9, 197:7, 199:18, 201:16, 207:22, 207:23 increased [43] - 17:8, 37:25, 49:7, 49:22, 50:14, 57:3, 57:6, 57:7, 60:10, 60:13, 60:17, 80:2, 80:22, 80:23, 81:13, 87:14, 88:13, 100:14, 100:15, 101:11, 101:13, 103:13, 135:8, 161:20, 161:21, 161:24, 162:2, 163:15, 163:19, 165:7, 171:19, 195:24, 199:22, 200:3, 203:10, 207:16, 208:18, 210:4, 217:6, 218:13, 219:24, 230:7 INDEX [1] - 8:1 indicate [2] - 70:15, 174:16 indicated [3] - 44:22, 65:13, 216:2 indicating [1] - 79:22 indirect [1] - 63:5 individual [6] - 26:23, 71:17, 96:16, 98:7, 122:25, 140:17 individual's [2] 97:24, 140:18 Individually [1] - 2:10 individuals [13] - 26:17, 91:16, 96:7, 114:11, 114:13, 118:13, 119:3, 119:18, 146:24, 153:14, 190:3, 191:17, 197:2 induce [3] - 61:17, 67:17, 67:22 induced [11] - 87:7, 94:16, 105:3, 121:15, 138:22, 141:7, 143:5, 164:21, 165:13, 165:21, 166:10 inducer [1] - 28:5 inducing [1] - 135:10 industrial [7] - 34:14, 34:16, 34:19, 35:3, 44:7, 44:8, 44:11 Industries [1] - 4:22 INDUSTRIES [2] - 1:8, 1:10 industry [3] - 116:18, 116:19, 171:16 inference [1] - 89:9 inferentially [2] 194:6, 194:8 inflated [2] - 86:13, 203:25 information [41] 10:22, 12:24, 28:24, 32:13, 33:11, 36:2, 36:4, 39:3, 39:14, 39:22, 43:22, 52:24, 52:25, 63:4, 86:23, 87:13, 92:17, 98:10, 98:13, 98:22, 98:24, 99:8, 99:10, 99:13, 99:24, 104:2, 104:10, 104:16, 104:20, 106:22, 111:8, 111:15, 112:22, 159:14, 171:10, 184:17, 209:21, 210:20, 212:4, 218:11, 236:7 informed [2] - 17:9, 143:8 infusion [3] - 145:22, 146:2, 146:3 inhale [1] - 164:16 inhaled [3] - 164:23, 200:10, 200:21 inhibitor [1] - 134:6 inhibitors [4] - 80:14, 121:18, 121:25, 143:20 initial [2] - 24:13, 24:22 injury [1] - 21:3 inks [1] - 48:23 insist [1] - 56:9 Institute [3] - 15:13, 15:14, 137:20 instruction [1] - 112:20 instructions [1] - 112:2 insult [3] - 142:3, 142:6, 142:11 insults [1] - 141:22 intend [1] - 204:8 intending [1] - 72:11 intense [1] - 151:2 intensity [3] - 150:18, 151:5, 151:9 intent [2] - 210:22, 211:10 intentional [1] - 166:11 intentionally [3] - 164:23, 165:14, 165:24 Interactions [3] - 7:15, 86:22, 134:17 Interest [1] - 2:11 interest [1] - 2:4 interfering [2] 168:19, 182:13 intermediate [1] - 37:5 International [2] 70:23, 212:5 Internet [2] - 71:8, 102:6 internship [2] - 25:15, 25:16 interpret [2] - 139:12, 139:23 interpretation [5] 88:7, 89:4, 89:12, 169:21, 194:9 interpretations [1] 169:24 interrelated [1] 105:18 interrupt [1] - 220:3 interrupted [1] - 128:5 interrupting [1] 182:13 intrinsic [1] - 66:9 investigated [2] 91:19, 91:21 Investigations [1] 86:20 invoice [1] - 23:11 invoices [1] - 16:11 Invoices [1] - 6:8 involved [5] - 19:22, 19:23, 27:12, 27:20, 139:15 involves [2] - 120:6, 121:13 IOM [9] - 202:6, 208:23, 211:16, 211:21, 212:23, 213:2, 213:16, 213:20, 214:3 Iron [1] - 217:15 Irons [3] - 231:5, 231:10, 231:19 irrelevant [3] - 60:22, 63:15, 63:25 issue [35] - 19:19, 28:15, 28:16, 30:16, 31:2, 32:4, 32:23, 37:24, 39:3, 39:4, 46:25, 49:2, 50:22, 60:7, 68:4, 71:21, 78:7, 79:3, 85:19, 88:23, 121:19, 132:10, 143:8, 150:21, 150:22, 151:25, 152:17, 201:19, 201:25, 203:4, 206:21, 215:19, 215:23, 216:18 issued [1] - 23:12 issues [15] - 28:24, 30:7, 47:15, 59:25, 63:22, 65:25, 66:14, 69:10, 79:25, 81:8, 180:11, 202:16, 204:8, 215:20, 228:14 Italy [1] - 48:12 itself [4] - 52:22, 80:21, 81:12, 186:16 IV [1] - 141:25 J Jahanzeb [1] - 13:19 JAHANZEB [1] - 13:20 jallen@ shannongracey. com [1] - 4:16 JAMES [1] - 4:3 James [1] - 4:9 JBonneville@ steptoe.com [1] 4:22 JEFFREY [1] - 4:14 JENNIFER [1] - 4:19 jet [1] - 48:25 JI [1] - 101:7 Ji [3] - 6:16, 101:7, 103:7 JOHNSON [1] - 4:19 253 JONES [1] - 3:13 Journal [1] - 70:23 judged [1] - 98:8 judgment [4] - 126:15, 127:2, 163:14, 193:11 July [4] - 1:13, 16:8, 23:6, 23:13 June [2] - 16:7, 217:11 jury [1] - 188:11 JUSTICE [1] - 2:8 Justice [1] - 5:6 K Kabrams@ mcguirewoods. com [1] - 4:11 Kane [3] - 6:14, 6:20, 135:24 karyotype [27] - 50:17, 50:18, 57:9, 57:10, 68:10, 105:2, 105:3, 105:13, 105:14, 109:9, 109:10, 109:24, 110:5, 112:15, 113:18, 114:20, 115:16, 118:6, 118:20, 122:23, 124:22, 125:5, 131:24, 131:25, 218:2, 218:5 karyotypes [6] 84:14, 114:23, 115:10, 115:12, 115:19, 118:2 KATZ [1] - 5:8 keep [3] - 21:22, 52:17, 175:15 KEN [1] - 4:8 kept [1] - 23:4 kind [4] - 45:11, 45:14, 53:24, 61:6 King [1] - 75:17 Kleen [1] - 3:17 KLEEN [2] - 2:6, 2:6 Klu [1] - 230:15 knowledge [15] - 12:4, 12:5, 12:7, 13:25, 30:12, 32:24, 70:7, 103:24, 104:23, 106:8, 154:25, 158:4, 186:11, 196:21, 221:25 known [25] - 90:24, 91:5, 91:6, 91:9, 91:11, 91:14, 133:23, 135:13, 136:10, 186:14, 186:18, 186:19, 187:8, 188:4, 188:8, 189:17, 190:2, 190:5, 191:7, 191:8, 191:12, 191:14, 191:18, 194:5, 196:5 knows [3] - 90:23, 111:7, 182:18 L labeled [1] - 124:18 lack [2] - 87:14, 87:17 lacking [1] - 185:7 lag [5] - 47:4, 51:12, 59:10, 74:14, 133:20 Lan [5] - 7:12, 7:13, 231:19, 231:21, 232:2 Land [2] - 216:21, 216:25 large [2] - 99:15, 158:10 largely [5] - 127:5, 149:4, 158:4, 234:12, 237:19 Larson [5] - 46:19, 70:13, 70:22, 70:25, 72:15 Las [1] - 15:6 last [9] - 77:2, 97:3, 129:3, 129:11, 159:16, 159:24, 193:10, 193:17, 235:10 lasts [1] - 233:23 late [1] - 48:22 Latency [1] - 134:13 latency [28] - 50:23, 50:24, 51:2, 51:11, 57:15, 118:12, 132:10, 132:12, 133:4, 133:8, 133:11, 133:13, 135:6, 135:11, 135:17, 142:25, 143:9, 144:16, 144:23, 145:2, 145:14, 146:13, 150:18, 150:20, 150:22, 151:2, 151:6, 201:3 latency/arose [1] 146:23 Lauwerys [2] - 100:18, 101:5 LAUWERYS [1] 100:18 law [1] - 15:7 LAW [1] - 3:2 lawyer [4] - 19:21, 64:9, 64:20, 65:8 lawyers [5] - 12:17, 12:21, 19:21, 19:23, 223:9 lead [6] - 19:21, 87:2, 142:6, 142:12, 155:4, 155:21 leafing [1] - 45:7 least [4] - 23:17, 136:11, 216:12, 230:18 leave [1] - 17:4 leCRONE [1] - 5:8 lectures [3] - 14:16, 14:22, 15:8 led [1] - 237:19 left [6] - 58:13, 145:11, 146:6, 219:15, 220:5, 228:25 Legal [1] - 7:18 legal [2] - 14:16, 14:23 LeJeune [2] - 32:5, 32:9 lengthen [1] - 146:13 lesions [1] - 199:13 less [27] - 23:25, 24:6, 47:19, 48:2, 51:25, 57:18, 85:25, 87:6, 87:19, 87:22, 88:8, 89:2, 89:6, 132:22, 133:21, 135:7, 142:15, 148:9, 161:13, 163:12, 163:13, 163:16, 164:6, 174:19, 193:4, 203:8, 208:17 letter [11] - 34:7, 174:11, 177:5, 177:9, 177:22, 202:6, 209:24, 210:2, 210:8, 231:8, 239:4 leukemia [168] - 14:5, 14:8, 14:10, 25:21, 26:11, 26:17, 26:18, 27:9, 38:2, 38:7, 38:11, 38:13, 38:15, 39:7, 43:20, 46:17, 47:3, 47:7, 49:7, 49:23, 51:4, 51:14, 52:3, 52:12, 52:13, 55:4, 55:8, 57:4, 57:17, 57:19, 57:21, 57:24, 59:11, 60:10, 60:18, 60:22, 63:14, 63:25, 67:6, 67:8, 70:16, 77:24, 79:11, 79:17, 79:18, 79:21, 83:6, 83:19, 83:23, 86:12, 87:14, 87:18, 88:13, 88:14, 88:20, 90:7, 90:15, 91:17, 91:18, 91:25, 94:15, 99:3, 99:6, 99:17, 100:15, 101:12, 103:13, 114:15, 115:23, 117:24, 118:4, 120:21, 121:12, 121:13, 124:19, 131:14, 134:25, 135:4, 135:6, 135:19, 136:2, 136:19, 136:25, 140:6, 140:10, 140:11, 140:18, 140:19, 141:7, 141:13, 141:20, 142:5, 142:7, 142:12, 142:13, 142:20, 143:17, 145:20, 146:7, 147:5, 149:3, 151:15, 151:17, 152:8, 152:9, 152:11, 152:15, 152:16, 153:3, 159:3, 165:22, 166:5, 167:11, 168:3, 169:15, 169:17, 170:10, 171:19, 179:15, 179:17, 186:12, 186:16, 188:7, 189:11, 189:14, 189:17, 190:10, 190:17, 190:19, 190:20, 191:7, 191:8, 191:12, 191:14, 191:19, 192:8, 192:11, 192:16, 192:17, 192:18, 193:6, 193:9, 193:13, 194:6, 194:14, 194:19, 202:25, 203:11, 205:21, 207:23, 207:24, 208:3, 210:10, 210:16, 210:19, 210:21, 210:24, 211:2, 211:5, 213:8, 216:3, 216:9, 217:7, 217:20, 218:16, 219:24, 230:7 Leukemia [5] - 7:9, 86:20, 106:19, 118:24, 134:15 leukemias [9] 115:25, 116:3, 134:5, 134:7, 134:23, 145:7, 189:5, 191:3, 217:18 leukemic [2] - 205:15, 206:14 leukemics [2] - 26:7, 207:12 leukemogen [6] 26:20, 28:4, 153:6, 153:15, 153:18, 196:6 leukemogenesis [1] 216:17 leukemogenic [2] 152:4, 152:12 leukemogens [1] 153:4 level [21] - 37:6, 67:4, 87:16, 88:5, 88:12, 88:15, 88:18, 99:9, 99:19, 156:23, 160:5, 165:20, 169:19, 189:9, 189:13, 190:13, 196:4, 201:25, 202:17, 202:24, 235:8 Levels [1] - 7:14 levels [10] - 163:11, 174:19, 197:24, 198:2, 206:24, 216:22, 229:9, 230:20, 230:23, 235:7 LEWIS [1] - 4:2 life [5] - 38:17, 40:19, 41:5, 124:25, 153:7 lifetime [4] - 68:15, 142:10, 155:16, 156:10 light [1] - 156:20 likely [8] - 52:4, 115:4, 145:25, 151:2, 152:22, 164:9, 188:11, 195:11 limit [4] - 12:2, 45:5, 166:23, 225:4 limited [7] - 12:7, 44:14, 45:20, 52:21, 92:7, 217:3, 225:11 limits [2] - 166:15, 166:21 line [1] - 141:25 Line [3] - 8:3, 8:6, 8:10 linked [3] - 171:11, 171:12, 205:21 list [17] - 21:18, 21:21, 22:2, 22:4, 22:6, 33:15, 50:9, 54:6, 54:13, 54:16, 66:12, 254 66:15, 70:5, 95:18, 106:24, 131:20, 232:24 listed [14] - 53:5, 53:13, 63:19, 65:15, 65:22, 71:7, 71:18, 73:18, 73:21, 74:19, 102:23, 116:18, 125:4, 237:7 listen [2] - 105:7, 112:20 listing [1] - 126:4 lists [1] - 117:9 literally [2] - 53:17, 144:13 literature [38] - 37:8, 37:10, 37:14, 37:15, 37:19, 37:23, 38:5, 49:6, 50:25, 56:25, 71:11, 71:20, 71:22, 72:16, 72:23, 73:15, 74:8, 85:24, 86:14, 92:4, 97:22, 100:13, 101:10, 103:11, 107:4, 107:10, 107:21, 137:9, 143:6, 150:8, 152:6, 158:5, 158:9, 169:12, 169:16, 174:21, 227:20, 233:22 Literature [1] - 134:15 litigation [10] - 20:3, 20:7, 20:8, 21:11, 22:19, 25:2, 30:9, 30:18, 32:7, 97:25 lived [1] - 155:24 living [1] - 116:23 LLP [5] - 4:2, 4:8, 4:13, 4:19, 5:2 load [1] - 158:11 local [1] - 104:10 location [1] - 235:24 LOCKS [1] - 3:2 LOCTITE [3] - 2:2, 2:11, 2:12 look [37] - 37:15, 38:4, 54:4, 58:11, 58:22, 59:21, 73:2, 74:3, 84:10, 94:8, 102:14, 102:17, 115:15, 122:3, 124:4, 124:23, 126:10, 126:12, 128:7, 130:20, 132:7, 148:14, 157:21, 158:20, 172:16, 193:9, 203:17, 205:7, 206:16, 207:17, 208:2, 210:19, 210:21, 211:2, 212:23, 234:14 looked [19] - 42:11, 114:19, 114:23, 119:9, 125:15, 131:5, 136:16, 136:17, 137:3, 137:4, 153:14, 173:16, 195:21, 196:23, 210:15, 210:18, 210:24, 211:5, 222:12 looking [9] - 23:20, 52:17, 60:7, 71:23, 74:24, 100:24, 122:14, 122:16, 205:14 looks [2] - 13:18, 114:24 LOS [1] - 1:1 Los [4] - 1:16, 3:10, 4:4, 4:21 loss [3] - 124:25, 125:2, 197:12 lost [1] - 46:6 LOVELLS [1] - 3:8 Lovells [2] - 1:15, 15:24 low [22] - 37:8, 37:18, 60:13, 60:15, 67:4, 89:5, 151:15, 156:24, 158:16, 169:14, 170:8, 179:14, 201:25, 202:24, 208:20, 210:10, 215:24, 216:2, 216:7, 216:22, 230:20, 235:7 Low [1] - 7:14 lower [7] - 41:8, 159:22, 159:24, 167:17, 205:14, 208:12, 218:9 lowest [1] - 176:23 Lowries [1] - 49:9 lunch [1] - 85:15 lung [1] - 26:4 lungs [1] - 200:11 lymphocytes [1] 106:11 lymphoma [8] - 15:9, 126:2, 126:24, 127:4, 127:21, 130:16, 139:3, 139:4 M M.D [2] - 1:14, 9:3 M5B [1] - 38:12 machine [1] - 116:19 mail [6] - 6:9, 15:20, 15:24, 16:4, 18:10, 18:19 mailed [1] - 13:13 mails [5] - 11:15, 12:24, 15:17, 17:25, 33:13 main [2] - 158:15, 158:18 major [2] - 82:8, 209:17 majority [4] - 144:21, 148:3, 155:8 malignancies [3] 28:6, 138:14, 138:23 malignancy [4] - 52:9, 52:11, 59:15, 68:24 man [2] - 178:23, 223:14 managing [1] - 195:14 manner [3] - 45:6, 164:22, 196:24 Mar [1] - 15:5 March [2] - 46:3, 46:4 Marina [1] - 15:5 mark [15] - 17:25, 18:10, 22:8, 29:22, 73:5, 93:20, 101:16, 102:20, 109:7, 200:25, 201:3, 219:13, 231:22, 232:14, 233:8 MARKED [2] - 6:7, 7:2 marked [40] - 18:5, 18:14, 22:13, 30:2, 42:18, 73:9, 76:6, 93:24, 101:20, 109:14, 120:16, 124:6, 190:20, 201:4, 201:8, 201:21, 202:11, 212:12, 213:11, 214:19, 214:22, 215:3, 215:7, 215:11, 215:16, 219:12, 219:16, 220:18, 224:19, 226:23, 227:8, 228:8, 228:19, 232:5, 232:10, 232:12, 232:20, 233:7, 233:8, 238:5 marker [9] - 143:13, 163:14, 163:19, 163:21, 164:2, 164:8, 170:2, 211:25, 217:8 markers [1] - 158:25 Market [1] - 1:24 marrow [1] - 200:16 Martyn [10] - 6:18, 7:17, 83:9, 86:3, 87:2, 92:14, 108:22, 123:7, 232:10, 232:14 material [7] - 12:20, 14:17, 42:24, 43:4, 43:5, 102:5, 102:6 materials [8] - 11:12, 12:15, 12:16, 17:5, 94:6, 109:8, 180:8, 234:9 matter [8] - 25:25, 33:2, 67:20, 151:11, 151:17, 200:16, 211:6, 211:7 matters [3] - 31:14, 31:16, 31:21 Mauritzon [1] - 108:21 Mauritzson [2] - 6:18, 118:23 MAURITZSON [1] 118:24 maximize [1] - 168:7 MCCALL [1] - 5:2 McGOLDRICK [1] 3:13 McGUIRE [1] - 4:8 McLean [6] - 6:17, 7:3, 101:5, 102:15, 102:17, 103:4 MDS [14] - 15:10, 119:11, 119:13, 119:15, 121:4, 121:14, 131:16, 134:9, 174:17, 210:4, 210:19, 210:20, 218:4, 218:11 mean [20] - 25:16, 27:15, 35:10, 45:7, 48:13, 48:14, 55:13, 80:10, 82:17, 98:19, 133:17, 151:14, 163:21, 168:12, 199:22, 199:23, 216:17, 217:5, 218:15, 222:13 meaning [7] - 48:5, 78:11, 114:20, 115:19, 125:4, 187:25, 205:19 meanings [1] - 19:5 means [7] - 100:2, 151:15, 186:17, 187:6, 187:7, 203:24, 208:12 measurement [1] 154:5 measurements [3] 48:15, 212:21, 234:16 measuring [1] - 37:21 mechanic [1] - 159:20 mechanic's [3] 156:18, 156:20, 157:2 mechanical [1] 104:11 mechanics [22] 43:21, 48:9, 48:12, 49:6, 49:21, 50:13, 56:19, 57:2, 92:21, 93:7, 94:14, 100:14, 101:11, 103:12, 103:16, 103:22, 104:4, 104:12, 104:18, 104:22, 165:4, 190:22 Med [1] - 93:14 median [1] - 56:3 medical [10] - 15:25, 16:3, 38:19, 41:14, 41:16, 42:4, 42:8, 234:12, 234:23, 235:22 medication [2] 80:19, 81:12 Medicine [2] - 137:21, 204:16 medicine [4] - 25:11, 25:13, 25:16, 25:19 memory [1] - 174:3 mention [1] - 235:5 mentioned [5] - 47:2, 78:16, 142:8, 180:12, 236:10 MERRILL [1] - 2:9 Merrill [1] - 5:11 mesothelioma [1] 26:4 Meta [9] - 126:2, 126:3, 127:20, 128:15, 128:24, 129:15, 130:16, 171:15, 171:18 META [5] - 46:18, 70:18, 71:16, 71:19, 71:23 Meta-analysis [9] 126:2, 126:3, 127:20, 128:15, 128:24, 129:15, 130:16, 171:15, 255 171:18 metabolites [1] - 106:12 metal [1] - 116:18 method [2] - 158:23, 194:18 methotrexate [2] - 80:12, 81:7 metric [5] - 60:11, 140:22, 144:22, 149:2, 216:12 MID [1] - 1:24 MID-ATLANTIC [1] 1:24 middle [3] - 175:21, 176:10, 176:17 might [5] - 75:15, 88:20, 148:4, 174:6, 215:4 Miller [8] - 7:5, 7:6, 202:6, 202:7, 211:14, 211:20, 212:4, 214:3 MILLER [1] - 4:13 Miller's [1] - 211:16 Millers [1] - 208:22 million [38] - 60:8, 60:12, 60:16, 152:18, 161:15, 161:19, 161:23, 162:6, 162:8, 162:16, 162:21, 163:2, 163:7, 163:12, 163:16, 164:10, 166:25, 169:14, 169:25, 170:9, 170:21, 174:10, 174:20, 175:19, 176:7, 176:23, 177:4, 192:19, 192:21, 193:3, 203:9, 207:15, 208:5, 210:6, 216:13, 216:14, 230:23 mind [4] - 50:8, 52:20, 54:3, 108:4 mineral [1] - 48:24 minor [1] - 60:19 minus [12] - 115:17, 115:18, 131:14, 131:15, 143:10, 192:15, 192:16 minuscule [4] - 36:11, 36:12, 36:19, 37:4 minute [3] - 146:2, 146:3, 221:16 minutes [3] - 62:24, 130:9, 222:19 misleading [1] - 111:18 misread [1] - 100:22 missed [3] - 132:3, 132:7, 227:19 missing [1] - 60:23 misspoke [1] - 197:15 Mitelman [10] - 6:19, 106:5, 106:16, 106:17, 107:16, 107:23, 114:4, 114:9, 116:14, 122:13 Mitelman's [1] - 84:10 Mobile [1] - 3:6 mobile [1] - 9:19 model [5] - 121:20, 122:2, 124:2, 143:4 models [1] - 124:17 moderate [1] - 37:23 modern [17] - 49:22, 50:14, 56:19, 57:3, 80:13, 87:8, 100:13, 101:11, 103:12, 116:25, 157:5, 164:18, 164:21, 165:12, 166:3, 166:15, 169:18 modest [1] - 159:17 molecule [4] - 153:25, 154:2, 154:3, 200:15 moment [4] - 77:18, 101:23, 140:17, 141:25 Monday [1] - 238:24 monoblastic [1] 38:15 monocytic [2] - 38:12, 38:15 morbid [1] - 41:7 morbidly [1] - 46:2 morning [1] - 9:8 most [20] - 11:24, 13:3, 13:16, 28:16, 39:14, 106:4, 143:4, 145:2, 155:6, 155:12, 155:14, 155:15, 167:8, 177:15, 185:19, 185:23, 186:24, 187:9, 223:9, 223:10 Motor [1] - 4:11 MOTOR [1] - 2:2 move [4] - 127:9, 127:19, 128:14, 151:19 moving [2] - 129:11, 181:2 MR [318] - 9:7, 18:8, 18:17, 18:20, 18:24, 22:16, 23:10, 23:19, 30:5, 30:10, 30:14, 30:19, 31:11, 32:15, 32:16, 32:19, 33:23, 34:12, 41:23, 42:2, 42:19, 42:21, 43:12, 44:24, 45:16, 46:12, 47:8, 50:4, 50:9, 51:16, 52:17, 53:7, 53:15, 54:9, 54:15, 56:7, 56:11, 56:14, 56:17, 58:13, 58:17, 58:21, 59:2, 59:4, 59:16, 61:3, 61:23, 61:24, 62:5, 62:7, 62:8, 62:10, 62:11, 62:15, 63:11, 64:2, 64:8, 64:11, 64:17, 64:19, 65:4, 65:7, 65:11, 65:16, 65:21, 67:10, 67:13, 67:24, 68:3, 68:5, 68:25, 69:6, 69:7, 69:8, 69:12, 69:13, 69:16, 69:17, 69:21, 69:25, 70:2, 70:3, 72:2, 72:7, 72:13, 73:12, 74:23, 75:2, 75:5, 75:11, 75:25, 76:9, 76:25, 77:5, 77:8, 78:5, 81:20, 81:25, 82:10, 82:13, 84:17, 84:21, 85:4, 85:5, 85:12, 85:13, 94:3, 95:8, 96:3, 96:9, 96:13, 96:17, 96:21, 96:25, 97:2, 97:5, 97:7, 97:13, 97:19, 98:2, 98:11, 98:19, 98:21, 98:23, 99:2, 99:21, 99:25, 100:11, 102:19, 105:6, 105:11, 105:20, 105:25, 108:10, 108:15, 109:21, 110:24, 111:6, 111:10, 111:12, 111:24, 112:4, 112:8, 112:17, 113:12, 113:22, 114:2, 114:6, 114:7, 116:6, 116:9, 122:9, 122:19, 123:17, 124:9, 125:13, 125:18, 125:20, 125:23, 127:8, 127:11, 127:13, 127:16, 127:18, 127:24, 128:13, 128:19, 128:20, 128:25, 129:8, 129:12, 129:16, 129:19, 129:21, 129:24, 130:4, 130:11, 130:13, 130:14, 130:18, 131:9, 132:16, 132:20, 137:16, 140:12, 140:14, 140:23, 141:3, 144:5, 144:11, 144:24, 145:5, 146:8, 146:20, 149:22, 150:5, 153:5, 153:8, 153:12, 157:11, 157:15, 157:18, 157:21, 158:7, 160:23, 161:5, 164:24, 165:8, 165:16, 166:7, 166:12, 166:20, 167:5, 167:7, 167:13, 167:19, 167:22, 167:23, 168:4, 168:14, 168:22, 168:25, 169:3, 169:5, 169:9, 169:11, 170:11, 170:25, 172:15, 172:19, 172:22, 172:25, 173:3, 173:4, 173:9, 173:12, 174:25, 175:14, 175:16, 175:20, 176:2, 176:8, 176:19, 178:17, 178:21, 178:22, 179:3, 179:7, 180:2, 180:15, 180:17, 181:7, 181:13, 181:16, 181:17, 181:21, 181:24, 182:2, 182:7, 182:10, 182:15, 182:24, 183:9, 183:12, 183:25, 184:16, 187:20, 188:21, 189:3, 189:19, 189:21, 190:6, 191:5, 200:12, 200:23, 201:11, 204:4, 204:11, 213:14, 215:12, 218:22, 220:2, 220:13, 220:15, 221:6, 221:8, 221:16, 221:18, 222:2, 222:8, 222:10, 222:17, 223:4, 223:6, 223:8, 223:16, 223:19, 223:20, 223:22, 224:2, 224:5, 224:17, 224:23, 224:25, 225:16, 225:20, 225:22, 225:24, 226:2, 226:11, 226:17, 226:18, 232:13, 232:23, 238:8, 238:17, 239:10, 239:12 MS [1] - 239:11 multiple [3] - 19:19, 133:25, 154:16 mumble [1] - 34:25 mutagen [1] - 143:17 mutagenic [1] 146:25 mutation [7] - 58:25, 59:20, 145:16, 151:20, 151:21, 153:16, 187:25 mutations [28] - 52:9, 58:14, 59:13, 59:19, 68:14, 68:16, 68:18, 68:20, 142:9, 146:8, 146:9, 146:10, 152:18, 152:21, 152:22, 152:24, 153:22, 154:5, 154:9, 154:15, 154:18, 154:22, 155:3, 155:21, 156:9, 187:2, 187:9 myelodysplasia [6] 119:5, 120:20, 121:22, 121:23, 131:13, 217:20 myelogenous [3] 26:11, 38:11, 39:7 myeloid [2] - 120:21, 131:14 N n/k/a [1] - 2:3 Nagasaki [1] - 141:12 naive [1] - 139:17 name [4] - 9:11, 15:7, 110:14, 170:3 names [3] - 104:16, 170:6, 170:12 Natelson [7] - 110:15, 110:18, 110:22, 110:25, 112:11, 113:20, 150:15 NATIONAL [1] - 1:23 256 naturally [1] - 151:23 nature [3] - 41:19, 42:7, 154:17 NCI [1] - 204:17 nebulous [1] - 28:19 necessarily [3] - 22:22, 86:11, 117:24 necessary [3] - 52:8, 122:23, 218:6 need [12] - 10:11, 35:4, 62:12, 73:2, 73:17, 85:2, 128:9, 135:18, 175:23, 183:21, 224:7, 229:8 negative [3] - 49:12, 126:9, 126:18 NEMOURS [1] - 2:7 nested [9] - 174:14, 202:8, 207:11, 209:7, 209:8, 209:11, 209:15, 209:17, 229:18 never [13] - 11:8, 14:3, 14:12, 20:5, 83:17, 138:4, 138:7, 138:10, 152:3, 152:11, 153:4, 153:14, 209:11 new [4] - 16:22, 43:10, 43:11, 159:4 next [23] - 49:4, 49:5, 50:16, 52:15, 63:23, 67:11, 73:5, 76:3, 82:7, 93:21, 103:4, 103:5, 103:6, 118:18, 118:19, 120:15, 123:4, 131:10, 132:9, 169:10, 212:9, 238:24 NHL [3] - 125:22, 128:15, 129:15 Nielson [1] - 230:9 nine [10] - 43:21, 53:23, 58:4, 101:2, 102:24, 141:15, 141:16, 151:20, 208:8, 208:9 nineties [1] - 161:8 ninth [1] - 59:17 NIOSH [3] - 167:15, 167:17, 229:9 NIOSH's [2] - 167:20, 167:24 nobody [1] - 91:19 non [7] - 31:19, 32:22, 47:21, 96:6, 122:21, 127:21, 130:16 non-exposed [1] 96:6 non-government [3] 31:19, 32:22, 122:21 non-Hodgkin's [2] 127:21, 130:16 non-significant [1] 47:21 none [2] - 78:25, 148:22 nonexposed [1] 117:21 Nonlymphocytic [1] 106:19 nonlymphocytic [1] 114:15 normal [21] - 50:17, 57:9, 68:10, 68:20, 84:13, 104:25, 105:13, 106:9, 109:9, 114:23, 115:10, 115:23, 118:2, 118:20, 124:22, 125:5, 131:23, 154:16, 156:9, 192:24, 197:19 normally [3] - 149:5, 151:22, 217:23 NOS [1] - 203:11 NOT [1] - 8:2 Notary [1] - 1:17 notations [1] - 173:25 note [1] - 236:16 noted [2] - 77:15, 217:9 notes [54] - 7:18, 11:14, 29:21, 29:22, 38:9, 42:17, 42:19, 42:21, 43:13, 45:12, 52:22, 53:6, 60:24, 65:3, 71:5, 76:18, 77:17, 101:2, 102:24, 172:16, 172:17, 173:14, 173:18, 177:11, 177:16, 178:2, 178:4, 178:16, 179:21, 180:5, 181:5, 183:5, 184:22, 184:23, 185:17, 220:18, 220:22, 221:4, 228:22, 231:8, 235:2, 236:11, 236:15, 236:20, 236:24, 237:3, 237:5, 237:8, 237:9, 237:15, 237:17, 238:9, 238:10 Notes [1] - 6:12 nothing [4] - 24:23, 55:20, 89:12, 130:3 Notice [3] - 1:15, 11:7, 11:8 notice [1] - 63:7 notification [1] - 239:4 novo [63] - 48:5, 55:18, 60:18, 61:19, 68:6, 68:8, 81:19, 82:4, 82:5, 82:7, 82:11, 82:14, 83:8, 83:13, 85:21, 91:17, 92:2, 92:6, 119:10, 119:11, 119:16, 124:21, 125:3, 125:4, 152:5, 152:7, 152:11, 152:15, 153:3, 186:9, 186:13, 186:15, 186:17, 187:3, 187:7, 187:22, 187:25, 188:7, 188:9, 189:5, 189:11, 189:14, 190:10, 190:16, 190:25, 191:2, 191:23, 192:3, 192:8, 192:11, 192:16, 192:18, 193:5, 193:8, 194:3, 194:6, 194:12, 194:15, 194:19, 194:25, 195:5 NPM1 [1] - 229:11 Number [17] - 18:6, 18:15, 22:14, 30:3, 73:10, 76:7, 93:25, 101:21, 109:15, 120:17, 135:22, 201:12, 212:13, 213:12, 215:17, 232:21, 238:6 number [20] - 26:10, 44:19, 54:18, 54:25, 55:11, 58:4, 68:14, 70:10, 100:13, 104:24, 117:22, 132:10, 133:19, 151:20, 156:10, 156:11, 162:24, 174:22, 174:23, 174:24 NUMBER [3] - 1:4, 6:7, 7:2 numbers [11] - 99:15, 167:16, 167:17, 167:20, 167:24, 168:6, 168:8, 203:14, 205:7, 205:8, 205:11 Numbers [3] - 201:9, 215:8, 232:6 O obese [3] - 46:3, 46:5, 46:7 obesity [16] - 40:24, 40:25, 41:7, 46:15, 46:21, 47:9, 47:20, 54:18, 70:10, 70:16, 71:12, 72:4, 72:17, 72:24, 230:3 object [2] - 168:19, 176:9 objection [16] - 66:5, 96:9, 96:17, 96:23, 97:13, 98:2, 112:17, 122:9, 125:13, 168:18, 169:6, 188:21, 190:6, 200:13 objections [3] - 97:4, 98:3, 113:22 objective [1] - 214:8 objectives [3] - 211:17, 213:17, 213:23 observations [5] 42:17, 94:20, 234:20, 234:25, 237:15 obvious [1] - 194:22 obviously [3] - 83:20, 105:18, 142:21 occasional [1] - 49:12 occasions [1] - 19:17 Occupation [1] 106:18 occupational [4] 189:6, 189:25, 191:13, 191:19 Occupational [2] 137:21, 212:5 occur [7] - 32:14, 68:15, 68:23, 146:5, 164:19, 166:6, 190:24 occurred [7] - 141:23, 142:4, 148:18, 149:16, 186:17, 187:7, 210:14 occurrence [3] 51:13, 123:3, 133:14 occurring [2] 147:19, 154:6 occurs [4] - 57:25, 149:5, 151:13, 151:22 odds [8] - 77:23, 126:5, 126:7, 205:9, 205:10, 205:13, 208:7, 208:15 OF [3] - 1:1, 1:1, 8:5 offer [1] - 62:21 offering [1] - 58:15 office [10] - 16:16, 16:17, 16:20, 17:3, 17:5, 17:11, 17:16, 19:15, 20:2, 21:22 offices [1] - 1:15 often [5] - 19:19, 28:23, 83:10, 196:18, 196:19 oftentimes [1] - 10:23 oil [1] - 91:11 Oil [2] - 174:12, 209:24 oils [1] - 48:24 old [1] - 147:4 older [4] - 89:21, 89:23, 90:3, 205:18 olds [1] - 147:12 once [2] - 15:9, 173:17 oncologic [1] - 91:14 oncologist [3] - 90:18, 90:23, 98:24 oncologist/ hematologist [4] 35:22, 90:6, 94:18, 95:3 oncologists [2] 90:11, 90:13 Oncology [1] - 29:7 oncology [3] - 28:7, 28:12, 28:22 one [119] - 9:18, 10:12, 15:4, 15:6, 19:21, 20:14, 26:10, 27:14, 27:23, 29:8, 34:4, 34:7, 35:25, 37:11, 38:25, 39:3, 39:20, 45:19, 45:20, 45:23, 46:18, 46:19, 51:11, 54:18, 55:14, 59:25, 60:10, 60:19, 64:5, 64:6, 66:12, 66:23, 68:12, 70:10, 70:18, 70:19, 71:12, 71:21, 73:18, 73:21, 73:25, 74:2, 74:5, 75:14, 79:25, 83:12, 83:14, 84:22, 85:25, 86:5, 86:13, 87:6, 87:9, 87:11, 87:19, 87:22, 88:8, 89:2, 89:7, 95:24, 96:16, 96:23, 108:21, 110:16, 110:21, 112:10, 113:19, 113:25, 257 116:4, 127:12, 128:18, 133:6, 135:2, 136:4, 136:13, 139:18, 142:14, 142:19, 147:9, 151:22, 152:17, 154:19, 155:17, 155:25, 156:2, 158:19, 164:20, 166:24, 170:5, 170:20, 174:22, 177:2, 177:20, 180:13, 203:21, 205:14, 206:11, 206:15, 208:8, 208:10, 212:3, 215:20, 216:18, 217:19, 225:17, 229:4, 230:2, 230:14, 230:17, 231:15, 232:11, 233:25, 235:23, 235:24, 236:23 One [2] - 4:9, 5:3 one-third [1] - 55:14 ones [10] - 11:25, 45:5, 116:22, 143:5, 155:10, 219:2, 221:3, 226:6, 231:3, 231:18 ongoing [1] - 148:20 open [6] - 199:6, 199:12, 199:14, 199:15, 199:20, 199:24 opine [6] - 41:10, 172:8, 172:10, 192:7, 193:12, 194:2 opines [1] - 194:5 opinion [153] - 12:11, 20:21, 20:24, 21:2, 21:4, 34:14, 35:3, 35:5, 35:22, 36:8, 38:6, 38:24, 40:9, 40:10, 40:18, 40:22, 40:23, 41:18, 41:21, 42:3, 42:6, 42:9, 44:21, 44:23, 47:9, 48:7, 49:4, 49:5, 50:13, 51:20, 51:23, 52:2, 52:16, 53:18, 55:7, 56:18, 56:23, 56:25, 57:8, 57:13, 58:4, 58:6, 58:15, 58:18, 59:5, 59:7, 59:18, 59:23, 60:6, 61:15, 61:21, 63:12, 63:18, 63:24, 69:20, 70:10, 70:14, 71:12, 72:9, 72:11, 72:23, 74:9, 74:14, 76:10, 76:17, 79:4, 79:8, 79:12, 79:16, 81:19, 85:21, 88:24, 92:20, 93:6, 94:19, 94:25, 97:9, 97:11, 97:21, 100:13, 100:24, 101:4, 101:16, 103:2, 103:11, 104:24, 106:3, 107:22, 109:9, 116:14, 132:9, 132:12, 133:19, 134:20, 135:11, 141:18, 142:25, 146:23, 147:18, 151:6, 151:20, 152:14, 153:3, 156:12, 156:15, 157:12, 159:18, 160:24, 161:14, 161:18, 164:20, 165:12, 169:13, 171:4, 171:7, 172:12, 172:13, 175:18, 176:5, 176:22, 177:9, 179:17, 186:8, 187:21, 188:18, 189:4, 191:6, 191:9, 191:11, 191:16, 193:17, 193:22, 194:24, 195:10, 198:5, 198:12, 198:18, 198:24, 199:17, 213:15, 220:25, 221:2, 222:20, 226:23, 227:6, 227:14, 227:21, 228:12, 228:14, 235:15 opinions [135] - 11:23, 28:18, 34:11, 38:16, 40:4, 41:24, 42:15, 42:16, 43:3, 43:8, 43:11, 43:14, 43:16, 43:24, 43:25, 44:20, 45:3, 45:18, 45:22, 46:10, 48:11, 49:16, 50:3, 50:5, 50:10, 52:19, 53:9, 53:11, 53:12, 53:13, 54:14, 58:8, 59:3, 60:20, 61:2, 61:9, 62:6, 62:9, 62:12, 62:13, 62:16, 62:21, 63:4, 63:19, 63:21, 64:9, 64:25, 65:8, 65:15, 65:23, 65:24, 66:8, 66:9, 66:10, 66:11, 66:14, 68:2, 69:18, 70:4, 70:5, 72:16, 81:21, 94:23, 97:23, 101:10, 125:7, 125:8, 125:9, 125:15, 125:19, 127:14, 127:22, 128:16, 128:21, 129:6, 129:14, 130:15, 130:19, 132:17, 139:6, 139:17, 139:18, 153:21, 171:9, 172:5, 173:15, 173:19, 175:5, 176:14, 176:15, 178:7, 178:9, 178:19, 179:2, 180:9, 180:10, 180:13, 180:20, 181:4, 182:5, 183:3, 183:13, 183:21, 183:23, 184:5, 184:20, 185:10, 185:14, 191:23, 192:5, 197:6, 201:15, 202:12, 203:5, 203:7, 214:17, 218:24, 218:25, 219:4, 219:20, 219:23, 220:8, 221:12, 222:22, 223:18, 224:9, 224:21, 226:16, 226:21, 226:22, 228:10, 228:20, 235:20 opportunity [4] 10:14, 53:11, 108:7, 227:24 opposed [9] - 10:21, 53:5, 108:22, 115:12, 145:9, 145:18, 200:21, 218:24, 225:2 Oral [1] - 1:14 Orange [1] - 5:4 order [2] - 139:12, 236:5 organisms [1] 154:19 Organization [1] 31:20 organize [1] - 50:2 original [4] - 138:16, 210:17, 229:16, 238:22 OSHA [5] - 166:22, 166:24, 167:12, 167:18, 229:9 otherwise [4] - 21:22, 38:14, 41:2, 203:12 Outpatient [1] 137:20 outside [5] - 17:15, 25:2, 30:8, 30:17, 117:11 overall [4] - 49:11, 192:5, 203:23, 203:24 overlap [1] - 35:7 overlapping [1] - 66:10 overlaps [1] - 35:5 own [4] - 44:19, 156:6, 164:25, 218:24 Oxnard [1] - 5:9 P p.m [6] - 85:9, 85:10, 144:8, 144:9, 187:17, 187:18 Pacific [1] - 1:16 pack [1] - 26:25 pad [1] - 7:18 page [27] - 24:20, 29:13, 29:14, 43:16, 43:17, 43:18, 43:21, 43:24, 44:21, 44:22, 45:18, 45:19, 45:20, 45:22, 47:10, 47:11, 48:8, 53:21, 62:24, 77:23, 78:11, 78:12, 100:25, 177:21, 183:6, 212:7 Page [3] - 8:3, 8:6, 8:10 PAGE [2] - 6:7, 7:2 pages [10] - 70:24, 86:22, 102:4, 102:9, 102:11, 102:23, 103:8, 134:18, 173:14 paid [4] - 74:24, 75:7, 77:11, 77:12 paint [1] - 48:22 painter [1] - 116:20 painters [2] - 165:4, 171:17 paints [3] - 91:7, 91:10, 91:12 Pamela [2] - 92:24, 159:13 paper [3] - 12:22, 96:20, 236:14 papers [2] - 138:8, 138:11 par [1] - 166:24 part [55] - 19:18, 36:5, 47:11, 47:23, 60:8, 60:12, 60:16, 68:20, 95:10, 102:6, 107:19, 111:13, 126:4, 126:21, 131:2, 131:6, 138:17, 142:23, 142:24, 143:19, 143:22, 161:15, 161:19, 161:23, 162:5, 162:7, 162:16, 162:21, 163:2, 163:7, 163:12, 163:16, 164:10, 166:24, 166:25, 169:14, 169:25, 170:8, 170:21, 174:10, 174:19, 175:19, 176:6, 176:22, 192:19, 192:21, 193:2, 203:9, 206:20, 208:4, 210:5, 216:12, 216:13, 227:20, 229:19 partial [2] - 120:7, 120:10 participation [1] 130:23 particular [7] - 9:20, 36:9, 47:10, 125:8, 194:7, 218:6, 236:4 particularly [4] 28:19, 36:23, 124:21, 235:10 Parts [1] - 5:12 parts [7] - 47:12, 88:21, 91:2, 175:7, 175:8, 207:15, 230:23 PARTS [1] - 2:9 past [1] - 9:19 pathology [1] - 213:5 patient [8] - 17:5, 25:20, 25:22, 25:23, 27:3, 95:22, 95:24, 155:23 patient's [2] - 21:2, 98:7 Patients [1] - 106:19 patients [19] - 17:6, 26:3, 26:4, 48:2, 94:21, 94:22, 95:4, 95:7, 95:17, 95:18, 98:10, 120:20, 146:5, 205:15, 206:14, 208:10, 208:14, 217:16, 258 231:12 pattern [8] - 49:11, 83:2, 99:17, 117:19, 117:21, 121:12, 143:25, 147:7 Pattern [1] - 106:18 patterns [1] - 122:4 PAUL [1] - 9:3 pay [1] - 105:22 peak [5] - 160:5, 219:9, 230:19, 230:21, 230:22 Pedersen [3] - 6:18, 109:5, 131:12 Pedersen-Bjergaard [3] - 6:18, 109:5, 131:12 peer [5] - 14:4, 14:7, 99:12, 138:7, 150:8 peer-reviewed [5] 14:4, 14:7, 99:12, 138:7, 150:8 PELs [1] - 167:12 pen [1] - 44:16 Pennsylvania [3] 1:9, 1:25, 3:4 people [59] - 17:8, 55:25, 60:9, 77:24, 80:2, 80:11, 81:3, 82:21, 83:16, 83:18, 84:12, 85:2, 86:7, 88:4, 88:11, 91:17, 94:23, 99:5, 106:9, 115:2, 115:14, 116:23, 119:10, 127:5, 136:17, 137:3, 140:3, 142:19, 152:11, 152:14, 153:3, 155:6, 155:12, 155:14, 155:16, 161:18, 164:4, 165:21, 169:18, 189:9, 189:10, 189:12, 189:15, 189:18, 189:24, 190:8, 190:18, 191:2, 196:3, 203:18, 205:8, 207:18, 208:3, 216:7, 216:9, 217:3, 217:21, 218:9, 218:14 people's [4] - 42:25, 43:7, 43:8, 43:9 per [40] - 17:15, 22:17, 23:2, 24:11, 60:8, 60:12, 60:16, 161:15, 161:19, 161:23, 162:6, 162:16, 162:21, 163:2, 163:7, 163:12, 163:16, 164:10, 166:25, 169:14, 169:25, 170:8, 170:21, 174:10, 174:20, 175:19, 176:6, 176:22, 177:4, 192:19, 192:21, 193:2, 203:9, 207:15, 208:4, 210:5, 216:12, 216:13, 230:23 percent [46] - 39:10, 68:9, 82:6, 83:13, 83:14, 83:25, 84:6, 84:12, 84:15, 85:25, 86:5, 86:13, 87:6, 87:9, 87:11, 87:19, 87:22, 88:9, 88:19, 89:2, 89:7, 89:23, 89:25, 91:16, 91:24, 91:25, 92:5, 115:13, 142:15, 142:19, 142:21, 155:15, 156:17, 156:18, 162:2, 188:16, 188:19, 188:24, 189:5, 190:3, 191:17, 203:19, 203:20, 205:17, 217:16, 231:12 percentage [5] 89:20, 90:2, 90:12, 155:3, 155:20 performed [1] - 157:9 perhaps [4] - 83:25, 118:2, 141:13, 142:9 period [22] - 15:18, 51:19, 115:8, 118:11, 118:12, 135:6, 141:12, 141:16, 143:21, 144:15, 145:8, 147:18, 148:8, 151:2, 151:7, 156:19, 156:22, 159:21, 160:6, 160:14, 160:16 Period [1] - 134:13 Permatex [1] - 2:4 permissible [1] 166:22 person [9] - 67:18, 90:7, 100:8, 140:7, 140:10, 142:16, 149:18, 153:9 personal [1] - 103:21 personally [2] - 11:9, 185:3 pertain [1] - 15:18 pertaining [1] - 185:14 pertinent [9] - 11:17, 66:21, 73:25, 95:13, 102:10, 103:8, 108:20, 113:5, 137:12 pesticides [1] 114:22 petrol [1] - 114:22 petroleum [4] 171:15, 209:22, 211:25, 214:9 Petty [6] - 157:22, 157:25, 158:12, 159:14, 214:19, 230:19 Petty's [4] - 44:4, 158:2, 158:17, 158:23 Philadelphia [2] 1:25, 3:4 Philly [1] - 222:15 phone [2] - 9:18, 16:3 physician [2] - 20:22, 100:4 physician's [1] 110:10 physicians [1] - 39:9 pick [3] - 126:17, 162:24 picking [1] - 126:19 pictures [1] - 195:13 piece [2] - 36:2, 87:13 pieces [1] - 71:11 pile [14] - 11:16, 71:9, 73:3, 75:19, 75:21, 120:16, 131:11, 132:4, 226:4, 228:3, 228:7, 228:10, 231:6, 233:5 place [5] - 51:4, 145:17, 146:11, 173:2, 173:4 Place [1] - 3:14 plaintiff [3] - 20:6, 20:10, 83:10 Plaintiffs [2] - 1:5, 3:6 plaintiffs' [5] - 225:3, 227:7, 228:12, 228:14, 228:15 plan [4] - 212:19, 213:23, 213:25, 214:7 plans [1] - 208:23 plaque [5] - 195:12, 195:13, 195:18, 197:11, 199:13 plasma [2] - 197:24, 198:3 play [1] - 150:18 played [2] - 147:20, 148:24 playing [1] - 148:12 plays [1] - 192:4 plenty [1] - 189:12 pliofilm [8] - 83:22, 158:21, 169:22, 170:16, 170:17, 171:3, 216:6, 216:10 plus [2] - 34:2, 102:11 pockets [1] - 88:16 point [21] - 37:20, 41:10, 45:8, 46:9, 55:19, 57:23, 57:24, 60:19, 80:18, 96:19, 122:14, 148:10, 154:10, 154:15, 158:24, 180:25, 184:18, 185:9, 194:24, 216:23, 229:15 pointed [1] - 230:21 points [1] - 181:3 poison [1] - 165:25 polished [2] - 29:18 Polymorphisms [1] 7:12 pooled [4] - 174:13, 208:24, 213:3, 229:20 population [5] - 95:22, 95:25, 205:17, 209:13, 218:12 portion [3] - 35:25, 78:10, 147:11 posit [1] - 151:10 position [5] - 92:5, 152:10, 170:7, 176:12, 220:21 positive [5] - 15:11, 126:5, 126:8, 126:11, 126:18 possibility [2] - 26:14, 39:25 possible [3] - 164:14, 164:17, 238:24 postulate [1] - 147:24 postulated [1] - 68:12 potential [1] - 32:11 pounds [4] - 46:2, 46:4, 46:6, 168:11 ppm [4] - 48:14, 48:15, 158:24, 177:4 practice [5] - 25:10, 25:12, 29:9, 98:25, 99:14 practiced [1] - 99:4 practicing [2] - 25:16, 25:19 pre [1] - 121:14 pre-existing [1] - 121:14 preceding [5] - 36:24, 60:5, 149:11, 156:14, 159:25 precise [6] - 12:4, 135:20, 140:9, 140:17, 162:10, 162:13 precision [1] - 140:24 precursors [1] 217:22 predict [1] - 149:2 prefer [2] - 54:10, 84:24 preference [1] - 112:5 Preliminary [1] 174:16 preliminary [2] 174:22, 213:7 prelude [1] - 212:17 Premier [1] - 3:14 premise [1] - 49:21 premises [1] - 51:10 preparation [4] 173:14, 212:22, 213:21, 214:4 prepared [5] - 62:20, 130:10, 130:24, 131:7, 224:14 prescribe [1] - 196:15 prescribed [2] 196:18, 196:20 presence [7] - 50:16, 79:4, 122:22, 193:18, 195:8, 197:6, 201:15 present [4] - 23:6, 23:14, 48:21, 130:19 presentation [2] 133:9, 133:12 presented [2] - 14:15, 227:14 presumably [2] 186:25, 195:14 presume [1] - 209:2 presupposes [2] 51:5, 51:6 pretty [1] - 13:9 prevalent [2] - 95:6, 95:23 Preventative [1] 204:15 previous [1] - 60:2 previously [4] - 113:8, 174:21, 192:2, 197:10 primary [9] - 13:19, 259 61:19, 78:10, 219:20, 219:23, 221:12, 224:21, 226:22, 228:9 principle [3] - 31:2, 178:13, 195:19 printed [1] - 102:4 printer [1] - 116:20 printing [1] - 48:23 printout [2] - 86:18, 102:2 proactive [5] - 183:18, 185:5, 206:21, 206:23, 226:6 proactively [2] 15:22, 185:7 problem [5] - 209:4, 222:14, 222:17, 223:3, 224:16 problems [3] - 127:6, 140:2, 170:22 procedure [1] - 39:12 proceeding [3] - 85:9, 144:8, 187:17 process [3] - 61:6, 98:18, 120:3 produce [1] - 77:10 product [1] - 26:2 PRODUCTION [1] 8:5 PRODUCTS [1] - 1:7 Products [1] - 4:17 products [6] - 26:6, 48:21, 104:17, 104:21, 114:22, 234:16 profession [1] - 38:2 Professional [1] 1:17 professions [5] 87:15, 87:21, 116:17, 117:9, 165:5 prognosis [1] - 39:5 progression [1] 38:19 proof [1] - 99:20 proper [3] - 64:15, 65:19, 72:12 properly [1] - 203:16 propose [1] - 238:17 proposition [1] 110:4 protective [1] - 103:21 prove [1] - 187:24 proven [1] - 140:9 provide [27] - 20:20, 20:23, 22:6, 22:9, 32:12, 34:14, 35:2, 35:14, 35:18, 36:8, 59:3, 59:5, 59:7, 78:3, 102:10, 103:20, 103:25, 104:9, 104:16, 104:20, 108:23, 117:7, 205:25, 206:3, 206:19, 207:4, 221:4 provided [12] - 13:16, 13:22, 29:12, 40:6, 45:11, 76:22, 206:5, 211:24, 221:3, 221:21, 222:5, 236:8 providing [1] - 97:11 proving [1] - 187:11 psoriasis [44] - 41:2, 47:16, 55:7, 76:14, 77:25, 78:8, 78:24, 79:2, 79:5, 79:9, 79:17, 80:2, 80:10, 80:15, 80:16, 80:21, 80:22, 81:3, 81:11, 180:11, 193:18, 195:8, 195:12, 195:17, 195:23, 196:3, 196:7, 196:9, 196:13, 196:16, 197:2, 197:7, 199:7, 199:16, 199:17, 199:25, 200:25, 201:15, 202:5, 229:5, 229:7, 229:25, 231:7 psoriatic [1] - 197:18 Public [2] - 1:17, 107:7 publication [5] 13:17, 14:18, 14:20, 140:5, 209:18 publications [3] 13:23, 71:11, 138:18 publish [1] - 97:22 publishable [1] 96:19 published [25] - 14:3, 14:12, 14:15, 28:4, 48:8, 48:13, 56:18, 70:18, 70:19, 86:21, 92:20, 93:6, 97:10, 99:10, 106:20, 110:11, 118:24, 125:25, 134:16, 138:11, 138:13, 138:17, 156:5, 212:4, 214:10 publishing [1] - 27:14 pubMed [1] - 93:14 PUKKALA [1] - 101:8 Pukkala [8] - 6:16, 101:8, 102:2, 103:7, 165:2, 169:19, 170:18, 171:2 pull [4] - 106:6, 134:12, 136:21, 202:5 pulled [6] - 71:15, 106:7, 109:6, 143:6, 230:9, 230:15 pulling [1] - 210:22 pump [1] - 82:23 pumped [2] - 86:10, 152:20 pumping [1] - 83:5 pure [3] - 88:18, 164:16, 165:14 purpose [4] - 29:5, 29:6, 64:23, 96:12 purposes [17] - 18:5, 18:14, 30:2, 73:9, 76:6, 93:24, 101:20, 109:14, 201:8, 212:12, 213:11, 215:7, 215:16, 232:5, 232:20, 238:5, 239:9 pursuant [1] - 1:15 put [5] - 15:7, 41:23, 146:11, 164:24, 236:14 putatively [1] - 200:20 puts [5] - 38:25, 39:3, 111:14, 111:21, 112:21 putting [3] - 48:10, 63:7, 121:19 Q Qing [2] - 7:12, 7:13 qualified [7] - 34:13, 35:2, 35:14, 37:14, 38:3, 139:11, 139:22 qualifier [1] - 221:19 qualitative [8] - 35:12, 35:18, 35:24, 36:7, 36:10, 37:2, 161:3, 235:6 qualitatively [9] 36:19, 37:12, 60:4, 156:13, 157:13, 158:13, 159:10, 159:15, 160:12 quantification [1] 26:20 quantitative [6] 35:10, 35:11, 35:15, 160:9, 160:10, 161:2 quantitatively [1] 158:13 questions [23] - 10:12, 10:19, 10:21, 10:24, 28:22, 62:18, 62:20, 66:3, 66:7, 82:3, 111:19, 112:3, 120:2, 172:23, 173:6, 173:23, 174:5, 179:9, 204:9, 224:15, 234:6, 238:13 quick [1] - 34:2 quickly [1] - 24:14 quite [3] - 48:4, 87:18, 115:11 quote [8] - 37:21, 48:18, 78:11, 107:15, 109:20, 227:17, 230:16 quoted [17] - 46:17, 47:16, 76:18, 77:18, 77:20, 80:4, 81:5, 92:10, 107:13, 143:22, 216:21, 217:15, 229:4, 229:5, 230:2, 231:6, 237:6 quoting [1] - 49:8 R radiation [6] - 26:10, 82:9, 141:7, 143:5, 143:14, 143:24 RADIATOR [1] - 2:5 raised [3] - 63:22, 65:25, 66:7 rallied [1] - 39:19 rambling [1] - 56:13 range [5] - 60:13, 60:16, 162:15, 169:25, 177:4 ranges [1] - 24:23 ranging [1] - 48:20 rapidly [1] - 141:24 rare [1] - 87:18 RARS [2] - 15:9, 110:11 rate [10] - 16:10, 16:13, 16:18, 17:8, 17:10, 39:10, 196:24, 198:8, 198:15, 199:2 rather [18] - 27:24, 52:6, 56:3, 59:11, 80:15, 98:9, 115:15, 122:15, 141:24, 146:2, 149:7, 164:3, 190:25, 195:20, 203:20, 205:14, 214:5, 226:7 ratio [4] - 77:24, 205:10, 205:14, 208:7 ratios [4] - 126:5, 126:7, 205:9, 208:15 RATLIFF [1] - 4:13 Raul [1] - 1:7 re [3] - 10:14, 64:14, 140:13 re-ask [3] - 10:14, 64:14, 140:13 reach [5] - 81:2, 98:16, 126:20, 193:11, 202:19 reaches [1] - 147:9 reaching [1] - 97:23 react [1] - 184:10 reactive [11] - 183:19, 184:24, 185:4, 206:25, 226:7, 226:8, 228:13, 228:20, 229:12, 229:23 reactively [1] - 185:6 read [17] - 54:12, 54:16, 64:3, 66:21, 95:13, 105:21, 113:5, 137:12, 171:12, 175:3, 175:4, 177:13, 177:18, 182:20, 183:10, 224:11, 239:2 reading [2] - 181:19, 182:5 ready [1] - 75:3 real [3] - 80:6, 80:7, 80:9 reality [1] - 40:2 really [4] - 19:23, 75:20, 130:7, 236:18 realm [1] - 25:2 reason [6] - 9:20, 68:21, 83:3, 100:6, 166:19, 188:12 reasonable [10] 41:19, 42:7, 42:10, 49:21, 71:22, 115:7, 121:19, 140:23, 147:9, 225:7 reasonably [2] - 41:3, 185:6 reasons [1] - 179:20 rebuttal [2] - 206:21, 207:5 recalibrate [1] 158:22 received [2] - 12:17, 33:16 receiving [2] - 141:19, 260 141:21 recent [3] - 13:17, 185:20, 185:23 recently [1] - 39:14 recess [3] - 85:8, 144:7, 187:16 recollect [1] - 17:18 recollection [3] - 17:18, 103:19, 156:8 record [16] - 31:9, 54:4, 54:10, 69:13, 93:15, 128:3, 128:4, 128:6, 129:2, 129:10, 175:24, 176:11, 187:14, 204:5, 218:20, 238:16 recorded [3] - 95:17, 95:19, 96:5 records [10] - 11:13, 16:2, 16:4, 23:8, 24:15, 33:13, 34:11, 234:12, 234:23, 235:22 Reed [1] - 19:16 refer [4] - 29:20, 57:14, 60:20, 78:12 reference [12] - 11:18, 11:19, 58:14, 78:4, 86:4, 86:19, 106:4, 109:4, 135:20, 154:13, 154:21, 221:24 references [22] 11:16, 11:22, 13:2, 13:4, 17:24, 72:16, 72:23, 73:15, 74:8, 77:15, 78:7, 85:24, 91:23, 92:5, 93:5, 101:9, 101:15, 106:2, 108:11, 133:25, 134:2, 153:20 referred [2] - 13:4, 209:6 referring [3] - 166:22, 171:21, 230:11 reflect [1] - 128:4 reflected [1] - 16:11 regard [2] - 167:22, 216:5 regarding [14] - 15:23, 20:17, 30:23, 34:14, 36:8, 63:13, 133:20, 173:10, 174:12, 178:16, 202:7, 229:5, 230:2, 231:7 regardless [1] - 15:21 REGION [1] - 1:24 Registered [1] - 1:17 regulations [1] - 34:6 reinforce [1] - 12:3 relapsed [1] - 39:8 relate [4] - 114:11, 183:15, 202:5, 216:19 related [26] - 26:5, 26:8, 81:6, 84:2, 116:2, 119:12, 119:13, 119:20, 120:20, 121:3, 121:16, 123:22, 123:24, 123:25, 131:13, 131:16, 134:3, 134:4, 134:6, 135:4, 135:6, 149:3, 152:8, 192:4, 229:7, 230:6 relates [3] - 32:22, 135:11, 136:14 relating [1] - 108:19 relationship [1] 230:22 relative [15] - 26:11, 28:16, 46:10, 60:2, 72:5, 135:25, 136:5, 136:19, 162:3, 162:17, 162:20, 163:5, 163:9, 207:13, 207:19 relatively [1] - 194:22 relevance [1] - 204:7 relevant [36] - 13:6, 34:4, 36:23, 45:24, 48:7, 49:2, 53:3, 66:8, 75:19, 76:11, 102:5, 102:9, 135:16, 136:3, 148:16, 149:10, 150:21, 152:22, 195:25, 201:23, 202:14, 204:21, 214:16, 218:7, 229:25, 230:12, 231:7, 231:16, 231:19, 231:21, 232:25, 233:11, 236:13, 236:16, 237:20 reliance [1] - 109:8 relied [7] - 12:11, 97:18, 104:9, 201:14, 224:20, 235:19, 236:22 relies [1] - 222:21 relieve [1] - 238:18 rely [24] - 71:12, 72:22, 73:15, 74:8, 93:5, 97:10, 97:22, 98:12, 99:24, 101:9, 107:22, 133:18, 146:22, 153:20, 159:12, 169:13, 170:7, 171:3, 173:18, 197:5, 218:24, 220:6, 226:21, 227:5 relying [6] - 11:22, 106:25, 202:12, 219:20, 220:8, 221:11 remain [2] - 233:18, 233:19 remaining [1] - 219:4 remains [1] - 154:15 remember [2] - 130:6, 150:16 remembering [2] 76:21, 178:17 remotely [1] - 223:14 repair [3] - 154:3, 230:5, 230:8 repaired [1] - 155:10 repetitive [1] - 115:17 replete [1] - 152:6 Report [1] - 7:6 report [72] - 11:18, 13:3, 13:4, 13:6, 24:17, 24:20, 29:13, 29:16, 29:17, 34:10, 45:11, 46:9, 47:10, 47:13, 48:18, 48:19, 52:21, 54:4, 59:22, 62:22, 62:25, 63:3, 69:14, 69:19, 69:22, 71:5, 73:17, 73:18, 73:21, 73:23, 73:24, 78:11, 94:4, 107:14, 158:2, 159:13, 174:15, 175:3, 178:23, 180:5, 180:10, 181:14, 183:3, 183:6, 183:14, 183:22, 185:8, 185:15, 202:6, 208:23, 210:12, 211:17, 211:21, 212:24, 213:2, 213:16, 213:20, 214:3, 220:23, 221:5, 225:6, 227:15, 229:21, 229:22, 234:18, 236:9, 236:20, 237:20 reported [5] - 55:15, 174:21, 211:19, 212:2, 213:18 Reporter [1] - 1:17 reporter [7] - 54:12, 66:17, 66:20, 95:12, 113:4, 137:11, 238:19 reporting [1] - 210:3 REPORTING [1] - 1:23 reports [7] - 11:20, 12:7, 42:25, 43:8, 65:2, 157:22, 157:24 Representing [9] 3:6, 3:11, 3:17, 4:6, 4:11, 4:16, 4:22, 5:5, 5:11 REQUEST [1] - 8:5 require [5] - 24:15, 24:16, 36:15, 43:10, 205:21 research [1] - 140:3 Research [3] - 7:6, 15:13, 15:14 reserve [2] - 226:8, 227:12 reserving [1] - 69:23 respect [2] - 32:2, 143:16 respond [1] - 142:16 response [7] - 21:25, 34:24, 40:15, 64:3, 107:22, 175:5, 202:15 responsibilities [1] 238:20 restate [1] - 69:21 restatement [1] 132:17 restricted [2] - 53:4, 138:15 restriction [1] - 92:10 result [4] - 25:21, 43:3, 71:24, 190:4 resulted [2] - 80:21, 81:13 results [3] - 114:13, 126:18 retained [4] - 20:16, 22:5, 22:18, 31:18 reverse [1] - 37:24 Review [1] - 107:7 review [12] - 9:17, 16:2, 34:11, 41:17, 44:2, 49:9, 49:15, 62:24, 137:9, 137:14, 183:22, 213:5 reviewed [17] - 11:6, 11:13, 12:16, 14:4, 14:7, 33:16, 41:13, 41:22, 41:25, 99:12, 138:7, 150:8, 185:19, 235:14, 235:19, 236:17, 236:21 reviewing [5] - 24:15, 43:4, 94:10, 135:23, 212:25 reviews [1] - 107:6 revised [1] - 159:3 Richard [1] - 20:14 Richmond [1] - 4:10 ridiculous [1] - 182:17 Rinsky [2] - 170:5, 170:14 Rinsky's [1] - 83:22 rise [1] - 99:9 rises [1] - 99:19 risk [108] - 26:12, 37:25, 39:11, 43:17, 43:20, 46:15, 46:20, 46:23, 47:3, 47:17, 47:18, 49:7, 49:22, 50:14, 54:18, 54:25, 55:7, 57:3, 57:6, 57:7, 60:10, 60:11, 60:13, 60:18, 70:11, 70:15, 71:12, 72:17, 72:24, 73:13, 74:9, 74:12, 76:11, 76:14, 78:8, 79:9, 79:13, 79:14, 79:17, 79:18, 79:21, 79:23, 80:3, 80:16, 80:22, 80:23, 81:3, 81:13, 94:15, 100:14, 100:15, 101:12, 101:13, 103:13, 127:3, 135:3, 135:8, 135:15, 135:25, 136:3, 136:5, 136:19, 136:24, 137:4, 142:13, 149:2, 149:4, 149:5, 155:18, 161:20, 161:21, 161:24, 162:2, 162:3, 162:17, 162:21, 163:5, 163:7, 163:9, 163:10, 163:15, 163:18, 163:20, 164:3, 164:8, 165:7, 167:11, 169:15, 170:2, 170:10, 171:19, 174:17, 203:10, 203:24, 204:2, 204:3, 206:24, 207:14, 207:16, 207:19, 208:18, 210:10, 210:16, 217:6, 218:13, 219:24, 230:7 Risk [1] - 7:9 261 risks [1] - 210:4 Rob@robkatzlaw. com [1] - 5:11 robust [2] - 47:19, 80:5 role [5] - 28:4, 147:21, 148:12, 148:24, 150:17 room [5] - 82:22, 82:24, 83:5, 85:3, 223:9 rose [3] - 145:3, 145:4 Rothman's [1] 171:15 rough [2] - 23:24, 161:25 roughly [6] - 89:19, 102:3, 156:17, 160:16, 183:6, 207:21 round [1] - 50:5 rule [22] - 69:4, 69:5, 72:4, 146:4, 149:15, 149:25, 186:8, 187:22, 188:3, 188:4, 192:8, 192:13, 192:18, 192:24, 193:5, 193:6, 193:8, 194:2, 194:11, 194:25, 195:4 ruled [6] - 69:2, 69:3, 188:6, 192:16, 194:6, 194:15 rules [1] - 192:12 ruling [1] - 194:18 run [1] - 105:9 Rushton [2] - 229:17, 230:13 S safe [1] - 53:16 SAFETY [2] - 2:6, 2:6 Safety [1] - 3:17 safety [1] - 168:7 SAFETY-KLEEN [2] - 2:6, 2:6 Safety-Kleen [1] - 3:17 Sahagun [1] - 1:7 SALES [1] - 2:8 salicylate [1] - 198:2 salicylates [1] - 195:22 salicylic [6] - 197:22, 198:19, 198:20, 198:22, 198:23, 198:24 salient [1] - 173:21 Sandler [2] - 6:20, 75:18 Sarna [37] - 6:2, 6:8, 6:10, 6:12, 18:6, 18:15, 22:13, 30:3, 72:3, 73:10, 76:7, 93:25, 98:5, 101:21, 109:15, 111:3, 111:25, 112:21, 129:9, 129:13, 164:25, 166:8, 166:13, 167:14, 182:16, 184:8, 201:9, 212:13, 213:12, 215:8, 215:17, 220:2, 232:6, 232:21, 238:6, 238:23, 238:25 SARNA [2] - 1:14, 9:3 Sarna-1 [1] - 6:8 Sarna-10 [1] - 7:3 Sarna-11 [1] - 7:4 Sarna-12 [1] - 7:5 Sarna-13 [1] - 7:6 Sarna-14 [1] - 7:8 Sarna-15 [1] - 7:9 Sarna-16 [1] - 7:10 Sarna-17 [1] - 7:11 Sarna-18 [1] - 7:12 Sarna-19 [1] - 7:13 Sarna-2 [1] - 6:9 Sarna-20 [1] - 7:15 Sarna-21 [1] - 7:16 Sarna-22 [1] - 7:17 Sarna-23 [1] - 7:18 Sarna-3 [1] - 6:11 Sarna-4 [1] - 6:12 Sarna-5 [1] - 6:13 Sarna-6 [1] - 6:14 Sarna-7 [1] - 6:15 Sarna-8 [1] - 6:16 Sarna-9 [1] - 6:18 scanty [1] - 80:25 Scarselli [4] - 6:15, 37:22, 48:12, 92:23 Scarselli's [1] - 157:3 scattered [3] - 43:15, 45:3, 236:2 scenarios [1] - 166:2 Schnatter [1] - 229:17 school [1] - 147:13 Science [1] - 153:24 Scientific [1] - 6:13 scientific [1] - 96:14 scientifically [1] 140:9 scientist [1] - 140:16 scratch [1] - 237:18 sdippong@wfbm. com [1] - 5:5 SE [1] - 1:8 SEA [1] - 2:8 search [1] - 93:15 sec [1] - 111:13 second [13] - 39:5, 55:6, 74:3, 80:8, 92:23, 105:22, 126:21, 129:8, 140:21, 172:15, 175:20, 200:12, 233:4 secondary [2] - 61:19, 61:20 section [1] - 101:3 see [30] - 13:17, 23:7, 53:3, 53:17, 53:21, 54:5, 58:11, 74:20, 75:15, 76:23, 86:4, 86:16, 94:11, 99:5, 99:7, 102:13, 111:11, 123:20, 132:7, 147:7, 166:9, 166:19, 177:13, 184:9, 190:19, 207:3, 210:20, 213:24, 218:3, 223:11 seeing [4] - 99:16, 102:15, 122:16, 166:17 seem [1] - 121:21 SEIR [4] - 48:3, 55:15, 89:18, 89:24 self [1] - 195:14 sending [1] - 75:3 sense [3] - 107:17, 207:25, 208:20 sent [4] - 41:15, 210:3, 210:8, 238:23 separate [6] - 18:25, 19:7, 78:18, 121:17, 211:21, 216:18 separated [2] 235:12, 235:16 series [6] - 15:3, 106:8, 120:22, 134:3, 179:9, 207:9 serious [1] - 170:22 serves [1] - 95:23 set [18] - 43:14, 47:10, 89:12, 103:15, 167:12, 177:10, 178:2, 178:10, 178:12, 180:4, 181:5, 183:23, 213:22, 214:11, 220:17, 228:21, 235:2, 237:5 sets [4] - 211:10, 211:17, 213:6, 213:16 setting [2] - 83:7, 151:17 settled [1] - 24:14 seven [12] - 15:4, 21:13, 21:15, 22:19, 22:24, 25:9, 43:18, 43:19, 48:8, 104:24, 115:18, 146:16 seventh [2] - 57:8, 120:11 seventies [6] - 48:22, 115:3, 115:4, 115:6, 161:6 several [2] - 170:16, 233:23 severe [1] - 39:16 Shadduck [29] 61:10, 66:25, 75:9, 76:22, 76:23, 77:19, 77:20, 108:2, 116:5, 123:12, 123:15, 123:19, 124:2, 172:4, 172:18, 173:11, 173:24, 174:9, 175:6, 177:23, 177:25, 178:16, 180:22, 202:14, 214:18, 219:2, 219:7, 219:19, 229:13 Shadduck's [13] 34:8, 44:2, 60:20, 107:4, 123:6, 175:18, 176:4, 176:14, 176:22, 177:9, 178:6, 178:9, 179:14 SHANNON [1] - 4:13 shared [1] - 143:12 shares [1] - 194:24 sheet [1] - 17:20 sheets [1] - 207:4 Shell [12] - 34:8, 174:12, 177:5, 177:10, 177:22, 209:24, 210:2, 211:19, 212:2, 213:18, 214:10, 231:8 shocked [1] - 211:8 shorten [2] - 145:14, 146:13 shorter [3] - 143:21, 151:3, 211:22 shot [2] - 63:10, 221:7 show [20] - 46:20, 48:9, 49:6, 56:20, 57:2, 57:3, 57:6, 57:7, 92:21, 93:7, 100:14, 100:15, 101:11, 101:12, 103:12, 126:23, 171:19, 190:22, 216:6, 218:2 showed [3] - 77:23, 219:24, 235:7 showing [1] - 216:22 shown [4] - 124:8, 149:13, 190:22, 195:23 shows [3] - 124:5, 165:4, 207:22 side [1] - 125:12 sides [1] - 139:16 sign [1] - 239:3 significant [3] - 47:21, 174:18, 210:4 simple [1] - 36:14 simply [1] - 187:25 SIR [3] - 207:20, 207:24, 209:12 sister [3] - 60:22, 63:14, 63:24 sit [2] - 81:10, 180:19 sitting [4] - 82:24, 83:4, 223:11, 223:23 situation [3] - 83:4, 84:4, 133:15 six [15] - 11:12, 12:15, 12:20, 21:13, 21:15, 22:19, 24:15, 25:7, 25:9, 41:16, 100:13, 169:23, 223:15, 224:10, 236:3 sixth [1] - 56:25 sixties [4] - 83:24, 84:3, 84:6, 115:5 size [2] - 203:22, 203:23 Skaar [2] - 6:9, 15:24 skin [12] - 195:15, 195:19, 196:25, 198:7, 198:14, 198:25, 199:7, 199:16, 199:25, 200:9, 200:19, 200:20 slight [1] - 161:13 small [7] - 60:4, 156:13, 157:4, 157:6, 157:7, 157:14, 203:14 smaller [1] - 136:24 smart [1] - 64:22 SMITH [1] - 4:2 Smith [29] - 6:18, 6:19, 7:17, 19:16, 83:9, 262 86:4, 87:2, 87:10, 92:9, 92:14, 107:4, 107:16, 108:2, 108:20, 108:22, 120:18, 123:7, 124:3, 124:17, 127:10, 127:15, 127:20, 127:22, 128:14, 128:22, 129:14, 232:11 Smith's [5] - 123:23, 125:6, 129:6, 130:16, 232:15 smoke [2] - 26:8, 136:8 smokers [5] - 26:13, 26:18, 136:2, 136:3 smoking [17] - 26:19, 27:2, 41:9, 46:24, 46:25, 47:5, 54:25, 73:13, 74:9, 76:12, 127:5, 135:3, 135:4, 135:6, 135:15, 135:19, 136:4 SMR [3] - 207:20, 207:24, 209:12 Social [1] - 137:21 Soderburg [5] - 76:19, 77:16, 78:12, 78:17, 78:21 solely [2] - 2:4, 193:14 solvent [6] - 114:25, 115:10, 116:16, 117:5, 122:15, 192:4 solvents [10] - 27:5, 48:23, 84:13, 90:19, 91:2, 114:21, 118:8, 122:17, 195:15 someone [22] - 39:5, 41:6, 47:25, 84:9, 95:15, 105:14, 141:9, 141:11, 141:14, 147:8, 147:24, 149:7, 150:10, 164:15, 165:12, 165:24, 165:25, 192:14, 194:20, 202:18, 202:23, 218:3 sometimes [1] - 70:8 somewhat [1] - 40:25 somewhere [2] 22:23, 50:21 Sonali [2] - 6:18, 120:18 sooner [1] - 149:13 sores [5] - 199:6, 199:12, 199:14, 199:15, 199:24 sorry [25] - 17:24, 20:18, 21:24, 34:23, 34:25, 38:22, 40:8, 40:14, 51:18, 63:16, 72:19, 80:23, 85:5, 95:8, 100:22, 110:9, 110:13, 137:7, 157:11, 163:8, 197:14, 199:10, 221:19, 225:16, 234:7 sort [5] - 35:5, 43:15, 152:24, 226:12, 226:19 sound [1] - 199:13 source [1] - 59:15 sources [1] - 169:12 SOUTHEAST [1] - 1:2 spaces [1] - 164:18 speaking [1] - 169:6 SPECIALTY [1] - 2:5 specific [24] - 20:25, 38:7, 38:11, 61:9, 66:25, 67:7, 120:14, 133:25, 154:13, 161:9, 171:11, 172:6, 178:20, 179:16, 179:24, 184:6, 187:23, 195:6, 205:7, 205:8, 205:9, 214:5, 217:2, 217:25 specifically [18] 21:8, 49:8, 68:7, 69:5, 76:11, 79:10, 89:6, 89:13, 91:25, 94:14, 108:5, 110:2, 154:23, 154:24, 172:8, 191:24, 193:13, 227:17 specifics [1] - 134:11 specified [2] - 38:14, 203:12 speculation [1] 112:19 spent [2] - 23:5, 222:18 spirits [1] - 48:24 spoken [3] - 15:12, 150:9, 150:10 spontaneous [29] 52:9, 58:14, 58:25, 59:13, 59:20, 68:11, 68:14, 68:16, 68:19, 151:20, 151:21, 152:2, 152:6, 152:19, 152:23, 153:16, 153:22, 154:5, 154:9, 154:15, 154:18, 154:22, 155:3, 155:21, 156:9, 186:25, 187:9, 187:24, 190:24 spontaneously [1] 59:19 spot [2] - 62:23, 75:7 STACEY [1] - 5:3 stack [8] - 219:16, 220:5, 220:6, 222:9, 222:16, 223:11, 224:6, 235:24 stand [3] - 52:22, 52:23, 60:24 standalone [1] - 112:7 standards [1] - 34:6 stands [1] - 204:14 Stars [2] - 1:15, 3:9 start [8] - 23:22, 45:17, 49:8, 63:3, 64:9, 70:9, 125:5, 130:6 started [1] - 190:12 starting [1] - 45:8 state [3] - 117:2, 179:4, 192:7 STATE [1] - 1:1 statement [10] - 42:12, 45:24, 60:14, 63:17, 91:24, 92:15, 168:17, 206:23, 206:25, 210:13 statements [3] 28:19, 109:20, 229:8 States [12] - 5:5, 32:3, 32:6, 42:5, 42:13, 82:7, 88:22, 89:17, 92:7, 92:12, 164:12, 167:9 STATES [1] - 2:5 states [1] - 117:4 station [1] - 147:12 statistical [1] - 26:14 statistically [4] 99:11, 145:25, 174:17, 210:3 statistics [1] - 152:17 stay [1] - 54:10 stays [1] - 145:23 Steel [1] - 5:6 STEEL [1] - 2:5 Steinman's [1] 171:16 Stella [1] - 166:25 STELs [1] - 167:12 stem [1] - 39:6 Stephen [1] - 159:13 STEPTOE [1] - 4:19 steroids [1] - 195:22 still [13] - 14:6, 46:5, 46:7, 53:3, 88:17, 135:7, 142:2, 159:16, 196:6, 196:12, 196:15, 196:18, 196:20 Stimus [1] - 130:23 stipulate [1] - 238:18 stipulated [3] 239:10, 239:11, 239:12 STIPULATIONS [1] 8:9 stop [10] - 10:25, 46:8, 111:15, 111:23, 130:12, 130:13, 169:8, 182:12, 182:13, 182:14 stopped [13] - 47:5, 129:3, 129:10, 129:18, 129:22, 129:24, 136:4, 136:20, 137:2, 137:5, 145:10, 175:24, 176:18 stops [1] - 11:4 Strain [1] - 1:17 stream [3] - 29:19, 158:15, 158:18 Street [6] - 1:24, 3:4, 4:3, 4:9, 4:20, 5:9 strict [1] - 31:4 strongly [1] - 79:14 studied [2] - 94:13, 151:25 studies [54] - 27:8, 47:21, 49:10, 49:12, 71:17, 71:18, 80:4, 80:20, 81:9, 81:14, 81:15, 84:2, 84:5, 88:8, 89:5, 89:6, 103:23, 104:5, 104:13, 106:11, 106:12, 115:22, 115:24, 122:13, 126:6, 126:11, 126:22, 126:23, 137:15, 139:13, 139:24, 141:6, 142:23, 143:7, 143:18, 144:14, 144:21, 146:21, 146:25, 158:22, 171:3, 174:15, 185:20, 190:21, 195:21, 202:8, 204:6, 204:9, 208:25, 209:7, 218:23, 229:19 study [57] - 12:10, 27:13, 27:20, 74:6, 83:21, 83:22, 95:16, 113:15, 114:18, 117:15, 121:2, 121:6, 122:6, 136:13, 136:15, 137:8, 138:5, 146:23, 147:3, 153:13, 153:19, 158:21, 158:22, 171:21, 185:23, 186:5, 202:3, 203:5, 203:19, 207:9, 209:2, 209:6, 209:8, 209:10, 209:13, 209:15, 209:16, 209:21, 210:7, 211:11, 211:18, 212:2, 212:22, 213:17, 213:18, 213:21, 214:5, 214:9, 216:6, 216:10, 216:14, 217:15, 229:17, 231:10, 231:11, 234:3 stuff [4] - 112:21, 222:16, 224:10, 236:4 subgroup [1] - 38:14 subject [7] - 14:12, 57:14, 80:20, 93:10, 129:15, 131:22, 131:23 subjects [10] - 103:23, 104:5, 104:12, 114:20, 114:24, 115:9, 116:14, 117:13, 117:14, 146:24 subsequently [1] 10:9 subset [1] - 116:2 substantial [2] 117:22, 195:25 success [1] - 39:10 successor [1] - 2:4 Successor [1] - 2:11 successor-ininterest [1] - 2:4 Successor-inInterest [1] - 2:11 sufficient [3] - 61:16, 67:16, 67:20 sufficiently [2] - 80:5, 97:21 suggest [7] - 49:13, 65:7, 83:2, 168:22, 168:24, 182:10, 207:19 suggesting [1] 168:20 263 suggestive [2] 99:18, 99:20 suggests [2] - 89:25, 99:16 suicidal [2] - 164:17, 164:22 Suite [9] - 1:16, 1:24, 3:3, 3:9, 3:15, 4:4, 4:14, 4:20, 5:9 sum [1] - 36:4 summary [2] - 43:24, 45:21 SUPERIOR [1] - 1:1 support [9] - 39:9, 49:20, 126:16, 202:18, 206:22, 221:2, 221:11, 225:13, 227:5 SUPPORT [1] - 8:1 supported [1] 107:17 supporting [1] - 70:14 supportive [2] 219:23, 235:9 supports [2] - 220:24, 226:21 suppose [3] - 14:14, 164:15, 165:24 supposed [4] - 75:7, 77:12, 210:25, 211:3 surgery [1] - 46:6 surmisal [1] - 187:10 surmise [1] - 187:8 surprise [1] - 68:19 surprised [1] - 210:20 survival [1] - 41:12 survive [2] - 39:18, 39:23 Susceptibility [2] 107:6, 123:9 suss [1] - 45:14 sustained [2] - 66:6, 103:17 sworn [1] - 9:4 syndrome [3] 217:24, 218:6, 218:7 Synopsis [1] - 134:15 system [1] - 64:21 Systems [1] - 3:18 SYSTEMS [1] - 2:6 T table [1] - 92:11 Table [1] - 86:23 tail [1] - 149:6 Talbot [1] - 229:22 talks [16] - 75:20, 131:14, 134:22, 135:25, 197:10, 197:14, 197:15, 197:21, 211:15, 212:18, 212:20, 213:2, 213:4, 213:5, 213:8, 230:6 tangent [1] - 130:2 tar [5] - 196:4, 196:5, 196:8, 196:16, 201:19 target [1] - 238:25 Teleconference [2] 3:6, 4:17 ten [31] - 36:24, 52:4, 52:5, 60:4, 132:13, 132:22, 133:21, 136:4, 143:5, 147:19, 147:22, 148:3, 148:15, 148:18, 148:23, 149:11, 149:16, 154:7, 156:21, 157:14, 157:17, 159:11, 159:16, 159:24, 160:5, 160:7, 160:15, 161:12, 163:25, 164:4, 164:11 tend [2] - 28:12, 115:16 term [8] - 19:4, 19:6, 36:25, 51:12, 52:12, 52:13, 57:15, 187:25 termed [1] - 114:14 terming [1] - 228:20 terms [27] - 10:24, 12:5, 16:5, 36:21, 36:22, 42:25, 43:6, 43:23, 47:15, 49:2, 52:3, 52:18, 60:25, 70:4, 131:3, 134:11, 134:25, 142:17, 143:3, 157:5, 164:18, 172:14, 174:8, 197:13, 202:15, 202:16, 230:16 terrible [1] - 182:23 test [2] - 187:23, 192:11 testified [6] - 9:5, 14:2, 20:6, 20:9, 20:16, 21:19 testify [4] - 24:19, 32:12, 62:3, 107:20 testifying [3] - 21:10, 62:2, 182:21 testimony [20] - 16:14, 16:15, 17:14, 17:17, 22:3, 22:7, 24:3, 66:21, 95:13, 113:5, 137:12, 181:5, 181:20, 182:6, 183:4, 183:10, 199:5, 199:10, 199:11, 199:12 Testimony [1] - 6:2 Texas [2] - 3:16, 4:15 textbook [4] - 14:4, 28:11, 28:12, 29:8 textbooks [5] - 28:8, 28:13, 28:21, 29:3, 29:11 THE [78] - 1:1, 1:1, 18:22, 23:15, 30:12, 30:21, 32:17, 33:25, 42:22, 46:14, 50:12, 52:18, 54:11, 59:8, 64:6, 66:23, 67:19, 68:4, 68:8, 69:4, 75:13, 77:13, 81:23, 82:12, 84:25, 95:15, 96:11, 96:18, 97:16, 98:6, 99:3, 101:23, 105:9, 105:24, 108:13, 109:17, 111:4, 112:25, 113:7, 113:23, 116:8, 122:12, 123:19, 125:14, 125:25, 129:5, 130:22, 132:18, 137:14, 140:25, 144:25, 146:12, 149:24, 153:9, 157:16, 157:24, 160:25, 165:2, 165:18, 166:14, 167:15, 168:6, 170:14, 173:10, 174:8, 179:13, 181:11, 184:9, 188:23, 190:8, 200:14, 212:15, 215:10, 215:19, 220:11, 221:20, 226:4, 232:9 themes [1] - 115:17 themselves [3] 52:23, 60:25, 165:14 therapeutic [2] 28:23, 28:24 therapy [9] - 80:17, 116:2, 120:20, 121:3, 123:24, 123:25, 131:13, 142:14, 147:6 therapy-related [2] 120:20, 131:13 therefore [3] - 88:8, 133:8, 190:23 Theresa [1] - 9:13 THERESA [1] - 1:5 they've [1] - 83:17 thickened [1] - 195:19 thinks [2] - 67:16, 157:12 third [4] - 48:2, 55:7, 55:14, 68:4 thirties [1] - 205:20 Thomas [2] - 6:19, 73:24 THOMPSON [125] - 3:8, 18:20, 23:10, 30:10, 30:19, 32:15, 33:23, 41:23, 42:19, 44:24, 46:12, 50:4, 52:17, 53:15, 56:7, 56:14, 58:13, 58:21, 59:4, 61:3, 61:24, 62:7, 62:10, 62:15, 64:2, 64:11, 64:19, 65:16, 67:13, 68:3, 68:5, 68:25, 69:6, 69:8, 69:16, 69:25, 72:2, 74:23, 75:5, 76:25, 77:8, 81:20, 82:10, 84:17, 85:4, 85:12, 95:8, 96:9, 96:17, 97:13, 98:2, 98:19, 98:23, 99:25, 105:6, 105:20, 108:10, 110:24, 111:6, 111:12, 112:4, 112:17, 113:22, 114:6, 116:6, 122:9, 123:17, 125:13, 125:20, 127:11, 127:16, 129:8, 130:4, 130:13, 130:18, 132:16, 140:12, 140:23, 144:5, 144:24, 149:22, 153:5, 157:11, 160:23, 164:24, 165:16, 166:12, 167:5, 167:13, 167:22, 168:4, 168:22, 169:3, 169:9, 170:11, 172:15, 172:22, 173:3, 173:9, 173:12, 175:14, 178:17, 178:22, 179:7, 180:15, 181:7, 181:13, 181:21, 182:7, 182:15, 183:9, 183:25, 188:21, 189:19, 190:6, 200:12, 221:18, 222:8, 223:4, 223:8, 223:19, 223:22, 224:5, 226:17, 238:17 tHOMPSON [4] - 65:7, 146:8, 157:21, 222:11 Thompson [4] - 20:2, 63:22, 65:25, 66:4 Thompson's [3] 19:15, 66:13, 66:16 thousand [1] - 152:23 thousands [1] - 136:9 three [34] - 17:24, 25:4, 43:18, 73:19, 75:14, 76:14, 77:4, 77:11, 78:15, 78:25, 80:4, 80:20, 81:13, 81:15, 115:10, 115:20, 117:25, 118:3, 134:8, 141:14, 142:2, 147:5, 155:7, 155:13, 155:15, 163:9, 174:24, 177:20, 185:24, 185:25, 202:7, 207:21, 209:22, 213:21 threefold [1] - 163:8 threshold [6] - 174:9, 175:19, 176:5, 176:24, 177:3, 216:15 THROUGH [1] - 2:12 throughout [2] - 45:3, 159:20 Thursday [1] - 1:13 tick [1] - 64:4 timeframe [2] 118:15, 147:8 tiny [1] - 162:18 TNF [1] - 80:14 TO [2] - 8:2 tobacco [7] - 20:15, 20:21, 21:3, 21:6, 26:8, 26:9, 47:20 today [20] - 10:12, 10:21, 11:11, 12:9, 13:8, 16:19, 23:23, 33:20, 78:21, 78:24, 81:10, 108:25, 131:2, 131:8, 131:21, 164:10, 165:22, 180:19, 206:18, 207:8 together [1] - 19:20 264 took [6] - 59:10, 123:12, 123:15, 123:19, 236:11 Tool [1] - 4:6 TOOL [1] - 2:3 tool [1] - 202:24 top [5] - 41:11, 70:10, 108:9, 154:12, 171:23 topic [7] - 61:4, 61:25, 63:8, 64:25, 65:9, 65:12, 67:11 topically [2] - 195:23, 196:3 topics [1] - 62:16 Topo [2] - 121:17, 121:24 topoisomerase [2] 134:6, 143:20 tort [2] - 20:10, 24:24 total [2] - 15:19, 31:13 totality [1] - 36:4 totally [3] - 86:15, 86:24, 216:18 totalogy [1] - 107:13 touched [1] - 62:22 touching [1] - 224:12 toxic [2] - 20:10, 24:24 toxicity [2] - 34:5, 216:16 track [2] - 11:2, 23:4 trade [1] - 138:2 Tran [3] - 185:20, 185:23, 186:4 Trangch [1] - 229:21 transcribed [1] 238:10 transcript [6] - 58:23, 181:9, 181:10, 182:19, 238:22, 239:7 transcripts [6] 182:20, 234:10, 234:13, 234:22, 235:22, 237:16 transplant [2] - 39:6, 39:8 travel [1] - 17:6 Travis [3] - 205:16, 206:11, 206:13 treat [1] - 90:14 treated [2] - 40:11, 80:11 treating [4] - 20:22, 94:21, 196:2, 196:16 treatment [16] - 14:8, 38:19, 40:6, 40:17, 40:25, 41:14, 119:12, 119:14, 119:15, 119:19, 121:16, 123:24, 123:25, 131:16, 152:8 treatment-related [1] 121:16 tremendously [1] 24:17 trial [9] - 24:19, 53:10, 62:19, 66:2, 69:24, 107:21, 139:14, 176:13, 239:8 Triebig [9] - 7:3, 134:12, 134:16, 136:15, 150:11, 201:2, 233:3, 233:6 Triebig's [1] - 137:18 triple [1] - 208:16 trisomy [1] - 115:19 trivial [1] - 235:11 true [2] - 28:17, 198:10 try [6] - 10:24, 60:8, 77:17, 82:20, 165:25, 237:23 trying [4] - 50:2, 223:13, 226:12, 226:19 Tuesday [1] - 238:25 turn [2] - 42:14, 44:21 TWAs [1] - 48:19 twice [1] - 15:9 two [47] - 17:22, 43:16, 43:17, 44:22, 46:6, 46:18, 47:11, 47:20, 54:25, 60:15, 70:12, 70:17, 71:15, 71:24, 73:13, 77:15, 78:6, 78:11, 78:13, 78:18, 79:25, 92:22, 93:4, 93:9, 93:16, 97:3, 118:7, 142:2, 155:19, 162:20, 162:21, 163:8, 163:9, 169:14, 170:8, 170:21, 174:23, 177:20, 192:15, 198:4, 205:12, 207:15, 217:20, 229:3, 229:18, 232:2, 233:24 type [11] - 20:13, 25:25, 26:19, 97:9, 97:10, 97:20, 98:13, 103:21, 104:10, 123:21, 136:15 types [8] - 28:19, 37:11, 81:7, 104:2, 115:21, 122:13, 127:6, 195:16 typical [10] - 24:12, 50:19, 57:10, 105:3, 105:14, 109:10, 118:21, 131:25, 157:2, 157:4 typically [4] - 24:10, 51:15, 124:22, 132:22 U ubiquitous [1] 154:16 UCLA [1] - 14:9 UCSF [1] - 106:11 UK [2] - 174:13, 208:24 ulcers [2] - 195:16, 199:21 umbrella [1] - 53:2 unavailable [1] - 239:7 unaware [1] - 123:2 uncertain [3] - 203:13, 204:3, 209:4 unclear [4] - 86:6, 86:15, 86:25, 217:4 under [4] - 53:2, 139:25, 165:19, 238:20 understood [5] - 10:2, 10:6, 10:8, 10:13, 12:14 unfair [2] - 182:8, 182:17 unique [1] - 217:24 United [12] - 5:5, 32:3, 32:6, 42:4, 42:13, 82:7, 88:22, 89:17, 92:7, 92:12, 164:12, 167:9 UNITED [1] - 2:5 University [3] 107:25, 120:21, 137:22 unknowable [1] 91:21 unknown [3] - 200:4, 200:5, 200:6 unless [3] - 10:16, 66:4, 208:20 unlikely [3] - 150:2, 150:3, 164:13 unprecedented [2] 158:4, 158:9 unpublished [1] 174:23 unrelated [3] - 39:6, 123:23, 229:14 unusual [1] - 55:20 up [21] - 9:19, 14:20, 15:22, 21:21, 39:2, 50:5, 68:9, 69:9, 77:2, 106:10, 106:25, 124:5, 149:4, 149:13, 167:8, 193:24, 203:19, 203:25, 218:2, 228:15, 228:16 up-to-date [3] - 21:21, 39:2, 167:8 update [1] - 54:6 upward [1] - 159:4 useful [7] - 28:23, 29:10, 99:8, 99:12, 106:5, 107:3, 107:8 uses [2] - 60:10, 124:18 V vague [2] - 97:13, 188:21 valid [10] - 95:2, 96:8, 96:11, 96:14, 96:19, 97:21, 121:25, 122:2, 124:2, 202:24 validity [1] - 94:25 value [3] - 207:17, 207:25, 229:13 variable [1] - 195:20 varied [1] - 116:18 variety [11] - 27:17, 28:13, 35:6, 48:21, 66:3, 83:11, 83:12, 106:6, 106:14, 108:3, 116:21 various [2] - 171:16, 234:16 vary [4] - 24:17, 95:25, 160:21, 169:23 vast [1] - 144:20 VC [1] - 1:5 Vegas [1] - 15:6 verbally [1] - 177:15 VERITEXT [1] - 1:23 versus [4] - 20:14, 39:16, 160:6, 197:18 via [2] - 3:6, 4:17 video [1] - 128:3 view [6] - 37:20, 56:15, 110:10, 158:17, 185:9, 235:6 views [2] - 69:15, 186:4 Vigliani [1] - 83:21 Virginia [1] - 4:10 visits [1] - 212:20 vitro [2] - 106:11, 115:22 Volume [4] - 77:22, 86:22, 134:17, 212:6 volume [1] - 70:23 vs [1] - 1:6 W wait [2] - 112:6, 221:16 Walnut [1] - 3:4 WALSWORTH [1] - 5:2 wants [6] - 50:4, 61:11, 65:14, 67:12, 202:23, 220:9 Ward [9] - 7:11, 216:4, 216:5, 231:19, 231:20, 231:22, 231:23, 232:2 warned [1] - 130:6 washing [1] - 91:2 waste [1] - 237:21 Watch [4] - 7:8, 158:21, 207:9, 209:13 water [2] - 91:10, 197:12 ways [1] - 50:24 week [4] - 141:15, 141:16, 233:23, 238:24 weeping [1] - 199:20 weighed [2] - 45:25, 46:4 weight [1] - 71:17 weighted [4] - 48:16, 48:19, 103:18, 160:4 weird [1] - 61:6 welcome [1] - 237:24 West [2] - 4:20, 5:3 Wester [5] - 7:4, 197:9, 197:14, 197:15, 201:13 whatsoever [2] 44:13, 188:12 white [1] - 11:3 whole [3] - 106:8, 208:19, 222:9 widely [1] - 206:16 Williams [10] - 7:7, 29:10, 37:22, 48:17, 92:24, 157:25, 158:5, 158:11, 159:13, 229:4 Williams' [4] - 44:4, 157:5, 157:22, 158:14 window [1] - 141:16 winds [1] - 236:3 Winthrop [1] - 29:10 wish [1] - 17:10 withdraw [3] - 127:25, 128:9, 175:23 witness [11] - 92:24, 112:19, 168:21, 172:20, 173:5, 173:7, 173:8, 176:9, 179:5, 182:21, 226:2 WITNESS [78] - 8:2, 18:22, 23:15, 30:12, 30:21, 32:17, 33:25, 42:22, 46:14, 50:12, 52:18, 54:11, 59:8, 64:6, 66:23, 67:19, 68:4, 68:8, 69:4, 75:13, 77:13, 81:23, 82:12, 84:25, 95:15, 96:11, 96:18, 97:16, 98:6, 99:3, 100:3, 101:23, 105:9, 105:24, 108:13, 109:17, 111:4, 112:25, 113:7, 113:23, 116:8, 122:12, 123:19, 125:14, 125:25, 129:5, 130:22, 132:18, 137:14, 140:25, 144:25, 146:12, 149:24, 153:9, 157:16, 157:24, 160:25, 165:2, 165:18, 166:14, 167:15, 168:6, 170:14, 173:10, 174:8, 179:13, 181:11, 184:9, 188:23, 190:8, 200:14, 212:15, 215:10, 215:19, 220:11, 221:20, 226:4, 232:9 wonder [2] - 91:9, 210:13 Wong [2] - 170:15, 171:14 Woodland [1] - 5:10 WOODS [1] - 4:8 word [6] - 28:10, 50:23, 52:7, 132:11, 144:17, 145:2 words [9] - 21:2, 117:14, 118:12, 121:3, 159:21, 164:25, 233:18, 234:9, 235:18 worker [7] - 37:17, 116:19, 126:25, 127:2, 127:4, 171:21 Workers [1] - 7:14 workers [11] - 37:16, 116:15, 116:17, 117:3, 117:5, 117:8, 118:10, 121:7, 131:18, 171:18, 214:10 Workers' [4] - 31:6, 31:13, 31:14, 31:16 Workmen's [1] - 30:22 workplace [3] - 166:4, 166:10, 179:19 WORKS [1] - 2:3 Works [1] - 4:6 works [1] - 124:25 world [4] - 88:16, 92:12, 153:10, 153:17 World [2] - 31:20, 38:13 world's [1] - 71:20 worldwide [1] - 92:8 worth [3] - 170:19, 230:18, 231:4 worthy [3] - 97:9, 233:2, 233:11 wrapped [1] - 75:24 write [2] - 53:24, 59:6 writing [3] - 96:5, 178:2, 178:10 written [25] - 27:17, 27:19, 27:21, 83:10, 153:24, 175:4, 178:15, 180:5, 181:5, 183:3, 183:5, 183:14, 183:17, 184:14, 184:15, 184:22, 184:23, 185:14, 185:17, 194:11, 194:17, 228:22, 234:18, 237:14 wrote [1] - 173:20 Wynell [1] - 229:22 Y year [29] - 22:17, 22:24, 23:2, 41:12, 52:5, 60:8, 60:12, 60:16, 70:19, 70:21, 140:22, 147:4, 147:12, 147:17, 148:8, 149:18, 153:24, 153:25, 154:4, 163:17, 169:14, 174:11, 177:4, 188:13, 188:19, 189:6, 189:25, 191:19, 203:9 years [111] - 15:5, 17:22, 21:13, 21:15, 22:19, 25:9, 25:18, 26:25, 32:18, 36:18, 36:24, 46:6, 48:3, 51:24, 52:4, 57:18, 57:25, 58:2, 60:4, 89:19, 132:13, 132:14, 132:23, 133:21, 133:22, 134:8, 135:5, 135:7, 135:16, 136:4, 136:25, 137:5, 143:5, 147:5, 147:6, 147:19, 147:22, 148:2, 148:3, 148:4, 148:6, 148:9, 148:15, 148:18, 148:21, 148:23, 149:11, 149:12, 149:16, 149:19, 149:25, 150:2, 150:3, 156:14, 156:21, 157:10, 157:14, 157:17, 158:24, 159:11, 159:16, 159:24, 159:25, 160:5, 160:7, 160:15, 160:16, 161:13, 161:15, 161:19, 161:23, 162:6, 162:8, 162:16, 162:22, 163:3, 163:7, 163:12, 163:23, 163:25, 164:5, 164:10, 164:11, 169:25, 170:9, 174:20, 175:19, 176:7, 176:23, 188:25, 189:16, 190:14, 191:14, 192:15, 192:23, 193:4, 193:5, 193:10, 196:10, 208:5, 210:6, 216:13, 216:14, 235:10 Yin [1] - 206:11 Yin's [1] - 203:17 younger [1] - 89:22 yourself [5] - 34:18, 66:4, 137:24, 139:22, 177:18 Z zeros [2] - 154:8, 155:6 ZHENG [1] - 77:21 Zheng [7] - 76:20, 77:20, 78:12, 107:18, 107:24, 115:24, 229:24 Zheng's [1] - 106:10 zone [1] - 48:20 zones [1] - 10:23 265