Document MoByNjQmMo4edwaQOJmLB4vrL

30 1 Sayers 2 A. It's a top person's broad sheet on 3 Sunday. 4 Q. Is it somewhat similar to, say, The New 5 York Times in the United States? 6 A. 1 would imagine so, yes. 7 Q. It's a respected paper? 8 A. It is. 9 MR. LANIER: Objection, form. 10 Q. That's fine. You can put that down. II Thank you, Mr. Sayers. 12 Did you receive -- during this time 13 period 1967 after the BBC broadcast, did you 14 receive questions from customers about asbestos and 15 health? 16 MR. POLK: 1 object to the form of the 17 question. 18 MR. BROWNSON: 1 object as leading. 19 MR. LANIER: Objection, form. 20 Q. Mr. Sayers, after January of 1967 did 21 you receive any comments or inquiries from 22 customers about issues of asbestos and health? 23 A. As 1 was doing my technical rounds, 24 people did raise the issue, that is true. 25- Q. Did you see any evidence or have any 32 1 Sayers 2 mills, were you aware of any other workers that had 3 exhibited some awareness of asbestos and health? 4 A. Clearly the dockers must have been aware 5 because they were refusing to handle the product. 6 Q. Asbestos? 7 A. Yes, all asbestos. 8 Q. Did you then begin to gather some 9 information that you used to prepare this report. 10 Exhibit 1? II A. Yes, 1 did. 12 Q. And in the report at page 8, paragraph 13 3.3, you mentioned literature surveys; is that 14 correct? 15 A. Yes. 16 Q. Was that one of the things that you did 17 to get information? 18 A. Yes. 19 Q. What was involved in the literature 20 surveys? 21 A. Well, you've got to bear in mind that I 22 was traveling the country at the time, so the 23 surveys were somewhat intermittent. By good 24 fortunate in London we had the best technical 25 library available to us at the Patents Office, 31 1 Sayers 2 information as you were doing your rounds that 3 ordinary workers had become aware of this publicity 4 about asbestos and health? 5 A. Yes. When 1 visited paper mills that 6 were using our product, 1 was alarmed to see 7 cuttings from not that newspaper but other 8 newspapers actually stuck onto the hydropulper 9 which was a point of entry for the asbestos into 10 the slurry system. 11 MR. LANIER: Excuse me for interrupting. 12 sir. 1 apologize to you. 13 The article that you've handed me I'm 14 reading and it says "continued on page 3," 15 and 1 don't think 1 have page 3. 16 MR. WILL: We'll give you page 3. 17 MR. LANIER: Can I have that, please? 18 Thank you. 1 apologize for interrupting. 19 Q. Before the interruption, Mr. Sayers, 1 20 think you were mentioning the articles you've seen 21 workers post on the hydropulper -- 22 A. Yes. 23 Q. -- in paper mills; is that correct? 24 A. That is correct. 25 Q. In addition to the workers in the paper 33 1 Sayers 2 Chancery Lane. 1 spent several evenings and some 3 portion of days going through the available 4 literature at that time. 5 Q. Did you make any copies of anything you 6 found? 7 A. Yes. It was just possible in those 8 days. 9 Q. Other than you, was anybody else 10 involved in the literature survey? II A. It was primarily myself. 12 Q. You mentioned in your article. Exhibit 13 1, at page 7 some medical authorities that you 14 spoke with; is that correct? 15 A. Yes, that is so. 16 Q. Before we get on to the medical 17 authorities, let me ask you this: Were the 18 articles that you collected, were they something 19 that were publicly available? 20 A. Oh, yes, in a public library. 21 Q. Was any of this a secret or concealed 22 information? 23 A. In no way whatsoever. 24 Q. Turning now to the three individuals 25 you've listed on page 7, how was it that you SPHERION DEPOSITION SERVICES (212) 490-3430 9 (Pages 30 to 33)