Document MRnN82YVLZGr8eZbb8EzLyr9

10 1 2 sent? 2 3 MR. SHIPLEY: A copy of the notice was 4 sent. 4 5 MR. LANIER: No copy of the other 5 6 notice was sent to him? 6 7 MR. SHIPLEY: Not that I'm aware of. 7 8 THE VIDEOGRAPHER: This is tape number 8 9 one of the videotaped deposition of Mr. Ian 9 10 Sayers in the matter of In Re: Minnesota 10 II Personal Injury Asbestos Cases, in the State II 12 of Minnesota District Court, County of 12 13 Ramsey; and Conwed versus Union Carbide 13 14 Chemical and Plastics Company, Inc., in the 14 13 United States District Court, Fifth 15 16 Division. District of Minnesota; and 16 17 Kelly-Moore versus The Dow Chemical Company, 17 18 et al.. in the United States Court for the 18 19 Southern District of Texas. Galveston 19 20 Division, Number 02-CV-00477-G. 20 21 The deposition is being held at the 21 22 law offices of Orrick, Harrington & 22 23 Sutcliffe. LLP. 666 Fifth Avenue. New York. 23 24 New York, on August 2nd, 2002. at 24 25 approximately 9:31 a.m. 25 12 cross-noticed this. I'm going to attach a copy of this deposition notice because it wasn't read in the style, but it's number 15507. It's in the District Court of Brazoria County, Texas, the 23rd Judicial District, Judge Ben Hardin presiding. He's also been notified that this deposition is going on and is prepared to deal with matters pertaining to his court today. MR. SHIPLEY: Just for the record. Union Carbide is not a party to the lawsuit that Mr. Lanier has just referenced, and we're not voluntarily making any appearance in that case. MR. BICKS: My name is Peter Bicks. I'm from Orrick, Herrington, and we're here on behalf of Union Carbide and Mr. Sayers. Just for the record, Mr. Lanier, can we have the folks who are with you identify themselves or would you please be kind enough to identify them so we know who's here for purposes for the record? It 13 11 2 My name is Jorge Munoz, and with me is 2 MR. LANIER: Sure. 3 Gary Delgado. We are legal video 3 That's David Egilman. He is an expert 4 specialists from the firm of Spherion Court 4 witness of mine, and he's a doctor. He 5 Reporting Corporation. The court reporter 5 spells his name E-G-l-L-M-A-N. I thought 6 is Laurie Collins, in association with 6 everybody knew David, but they may not have. 7 Spherion Court Reporting Corporation at 545 7 Next to him is Will Lanier. He's my 8 Fifth Avenue, New York, New York. 8 son, who's up here looking at colleges and 9 For the record will counsel please 9 looked at Columbia. And I assume, since he 10 introduce themselves. 10 does work also for my office, that no one II MR. WILL; My name is Trevor Will. 1 II will have an objection to him being up here. 12 appear for Union Carbide in the Minnesota 12 And 1 expect y'all to be on your best 13 Personal Injury Asbestos Cases and in the 13 behavior because he's learning how lawyers 14 Conwed Corporation versus Union Carbide 14 behave. 15 case. 15 Next to him is Kevin Parker. Kevin 16 MR. BROWNSON: Bob Brownson 16 Parker is a lawyer from Houston, Texas. He 17 representing Conwed. 17 is board-certified in appellate law, has 18 MR. POLK: Michael S. Polk, P-O-L-K, 18 been my best friend since like ninth grade. 19 representing the Minnesota asbestos 19 Next to him is Dara Hegar, H-E-G-A-R. 20 plaintiffs. 20 She's a real nice lady. She's a lawyer down 21 MR. LANIER: My name is Mark Lanier. 21 in Houston, Texas, and also works for my 22 I've got some people with my office with me. 22 firm. 23 1 represent Glenda Allphin individually and 23 This is Arnie Levinson. Arnie is fast 24 a personal representative of the heirs and 24 becoming a good friend of mine. He's from 25 estate of James Allphin in a court that has 25 San Francisco. He's a named partner with a SPHERION DEPOSITION SERVICES (212)490-3430 4 (Pages 10 to 13) 4 1