Document MMje69zb0g0E0jmGpXX25L59j

258 260 1 Sayers 1 Sayers 2 MR. BROWNSON: Do you have any 2 A. Yes. 3 objection if 1 move the introduction of the 3 Q. All right? 4 exhibits I just read, 12, 13, 16, 17, 18, 4 A. Yes, sir. 5 I8A, 19 and 20? 5 Q. First of all may I please take a look at 6 MR. WILL: Well, I don't think he's 6 your report, at least I think that's the report you 7 the right witness to authenticate -- hang 7 have in front of you. That's your original; is 8 on. Some of them -- 8 that correct? 9 MR. BROWNSON: He was for everything 9 A. Yes (handing). 10 but 20. 10 Q. Thank you. 11 MR. WILL: Some of them 1 have no 11 (Pause.) 12 objection to. He doesn't know 20. He 12 Q. Is the report that you have before you 13 doesn't know 23. 13 something that you kept in your attic? 14 MR. BROWNSON: 1 was talking about 12, 14 A. Yes, it is. 15 13, 16, 17, 18, I8A and 19 and 20. 15 Q. Apparently there were other documents 16 MR. WILL: 12, 13, 16, 17, 18, 18A and 16 that you kept in your attic but you apparently 17 19,1 have no objection to those documents. 17 discarded at some point; is that correct? 18 MR. BROWNSON: Very good. Thank you. 18 A. The call reports, the handwritten call 19 MR. WILL: As long as we're on that 19 reports, which there were three or four files, 20 topic, I had offered 1 through 8 this 20 thick files, they were discarded, yes. 21 morning. We talked about those. 1 don't 21 Q. Tell me, what, if anything, caused you 22 think there was any objection; if there was. 22 to keep the report that you have sitting in front 23 1 would offer them now. If there was. 23 of you? 24 MR. POLK. I don't recall. I'll 24 A. It was -- for a young gentleman, it was 25 reserve any objections 1 have. 25 a large and major work. 259 1 Sayers 2 MR. BROWNSON: 1 didn't have any 3 objection, but 1 also wanted to make sure 4 that there was no objection to 9, 10 and 11. 5 MR. WILL: 9, 10 and 11 are -- well. 6 he was not familiar with any of those, so I 7 don't -- he had never seen any of them. I 8 don't think there's any basis for admitting 9 them at this point for this witness. Those 10 are all documents he had never seen before. II THE V1DEOGRAPHER: The time is 3:36 12 p.m. We're back on the record. 13 EXAMINATION BY 14 MR. POLK: 15 Q. Mr. Sayers, it is now 3:36 p.m. 16 You've been at it all day. I'm going to do my best 17 not to be repetitious from the questions that were 18 asked to you by Mr. Lanier and Mr. Brownson. 19 A. Thank you. 20 Q. My name is Mike Polk -- it's spelled 21 P-O-L-K -- and 1 represent a whole lot of people in 22 Minnesota that work in a ceiling tile plant called 23 the Conwed plant where Union Carbide asbestos was 24 used as an ingredient in producing ceiling tile and 25 ceiling board. 261 1 Sayers 2 Q. And 1 take it il was a work that you > J were proud of? 4 A. To a degree, yes. 5 Q. And as 1 gathered it from just reading 6 the report, you took a substantial amount of time 7 in preparing it; is that correct? 8 A. Overall, yes. 9 Q. And you intended that report to be as 10 informative for your superiors as possible; is that 11 correct? 12 A. That is so. 13 Q. Did the London office maintain records 14 in the normal course and scope of the business when 15 you were in London? 16 A. Yes, they did. 17 Q. And did the office that was in Brussels 18 that you worked at also maintain records in the 19 general and normal course of business? 20 A. Yes, they did. 21 Q. Would those be the typical 22 corporate-type documents that literally any 23 business in today's world or in the world in the 24 1960s would have maintained? 25 A. Yes. SPHERION DEPOSITION SERVICES (212)490-3430 66 (Pages 258 to 261)