Document MVJbNdObzRdN0aEwqaNNVj1j

T. Mamior Page 273 1 substance. 2 Q. Look beyond 147. What additional 3 documents have you added to this list beyond 4 document nUriiibefi'147'SpecificaHy for. the 5 Madison County litigation? : . . 6 A. The Bellevitle NewSj the Alton 7 Telegraph, The MetroEastToutnal, St. Louis' 8 Post Dispatch because that is the large 9 newspaper in that area.' The Sun-Times: The 10 Globe Democrat. Illinois State.Register. 11 Illinois Labor Bulletin'and Chicago Tribune . 12 would be only-therebecause this is a trialin 13 lIlinois, and just as I did the last time, the 14 question was, is what Dm saying about the 15 availability of^public information, true of this 16 area too?: Was this something thatwas 17 disseminated, publicly available in forms, like 18 the newspaper?- 19 Q. These articles show .in your mind 20 what? ' :.v 21 A.- They showthatthere.were, reports 22 about asbestos-danger and about a variety of. 23 other disputes going on/Smoking, linked . 24 asbestos wotk cancer. Danger in asbestds coats. 25 .A variety*.-r:as ltve said here, they make Page 275 1 MR. GIANARIS: What are those? 2 MS. ROSENBERG: The ones that 3 appear -4 A. From 207 to 216. 5 Q. Tell me about it/Unless you 6 agree not to use them, we're going to go over 7 them. 8 A. I can go over them with you. 207 9 simply establishes that Illinois was employing 10 a threshold .value limit or threshold limit 11 value for:asbestos and thereby that was one 12 source of evidence about availability of 13 knowledge about.asbestos, otherwise you 14 wouldn't have had -- 15 Q. What.was the Illinois threshold 16 limit value for asbestos? 17 A. It was five. 18 Q. You're simply going to use that 19 to illustrate -20 A. It goes.back a long way. That 21 the awareness.of asbestos as a danger from 22 prolonged exposure of a heavy sort was 23 dangerous, which:is exactly the point 24 established earlier in the 1920's, 1930's. 25 Q. What's next? Page 274 1 different, paints^but they.'re ail-about either 2 the natureof the illness or how you can 3 improvethe:health.and safety)or..something.-. 4 about that links between the,environment and 5 cancer between work and. cancer. They wouldn't 6 be here if they, didn't implicate asbestos. 7 Q... You're not going to come to a 8 trial in Madison County and testify.that, any 9 plaintiff ever read tarty d&eum'entonthislist, 10 are you? ;-s! ini 'r> 11 A. AsT said beforej no. :. 12 MS. ROSENBERG? 1 would like to 13 clarify for .theirecord.that there are: 14 exhibits,'other than iSpeoific Madison 15 County: exhibits, after-.1.4:7 other than . , 16 the ones that he just talked about. I 17 mean it doesn't end with the Madison 18 County exhibits. 19 MR. GIANAR1S': Sure. But my 20 question was, documents which are in 21 addition, to documents he testified about 22 in West Virginia.23 MS. ROSENBERG: That's correct. 24 They're also in addition to the ones he 25 testified about in West Virginia. , Page 276 1 A. Contract shipyards: What that 2 shows is an early awareness on the.part of:the 3 Navy about the dangerousness of asbestos?and 4 the need for control. This involves standard 5 set for building of Navy ships by private 6 contractors. That is another indirect piece of 7 evidence about understanding that this was 8 early on a problem to be.paid attention to. 9 Q. 209?. 10 A. 209, 10, 11 and: l'2 are all 11 examples of correspondence by individuals with 12 the Department of Labor that asks them for 13 information about the dangers of asbestos and 14 the ways of combatting it. 15 It's an illustration that 16 ordinary people out in the world would write to 17 the Department of Labor that had been called 18 attention to, in this case the Carswell and 19 Irvan in North Carolina. It's meant to 20 illustrate the range of people who were aware 21 early on. 22 When we first did this, we didn't 23 have access. This involves using archives to 24 get to. We didn't even know that the archives 25 had personal correspondence of the kind. POHLMAN REPORTING COMPANY (314)421-0099 69 (Pages 273 to 276)