Document N2EnnOO0GNo4dk8mavLaKj9Xp
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1 Sayers
1 Sayers
2 permit him to make any statements he wishes 2
MR. WILL: I'll make a record, but
3 to make about that later.
this is something that Mr. Sayers had in his
4 As long as we're off the record, then. 4 personal possession. It wasn't in the
5 1 understand what we're going to do when we 5 possession of Union Carbide. We'll lay that
6 go back on the record is have the
6 foundation.
7 videographer make a zoom-in of the card and 7
MR. POLK: Okay.
8 the bag. We're not going to ask any
8 (Sayers Exhibit 8, photocopy of bag
9 questions.
9 and card of RG-144, marked for
10 Then after the videographer has zoomed 10 identification, as of this date.)
11 in on the bag, then we're going to put that
II
MR. WILL: I'm going to indicate for the
12 back in the envelope, we'll go off the
12 record that I have now placed the card, the
13 record, and then we'll resume the
13 original card, in an envelope, as requested
14 questioning.
14 by Mr. Lanier. I'm going to take that out
15 MR. LANIER: Nothing is going on 15 of the room. And we have marked as Exhibit
16 questioning-wise. We're going to step up.
16 8 photocopies of the card with the bag down
17 and you get your close up.
17 and then a photocopy of -- the second page
18 MR. WILL: That's what I just said.
18 is a copy of the card with the bag up so you
19 We have to go back on the record for the
19 can read all of the writing.
20 videotape.
20 MR. LANIER: At this point in time I'm
21
MR. LANIER: Right. But you're not
21 walking back in the room. I'm a little bit
22 going to be questioning him. You're just
22 amazed to see there's typing going on, which
23 going to get a close-up. Then you will put
23 means it looks like there was some kind of
24 it in a sealed envelope. You tell us, and
24 statements and speeches being made while 1
25 we'll come back in.
25 was gone. So I would ask the court reporter
107 109
1 Sayers
1 Sayers
2 MR. WILL: Yeah.
2 to pause for a minute so I can read the
3
THE VIDEOGRAPHER: The time is 11:43 3
record and see what happened while I left.
4 a.m. We're back on the record.
4 MR. WILL: There was colloquy among
5
MR. WILL: That's fine. We can go off
5 the Minnesota counsel that relates only to
6 the record.
6 the Minnesota cases, and there was nothing
7
THE VIDEOGRAPHER: The time is 11:43 7
that 1 think affected what your concerns
8 a.m. We're going off the record.
8 were.
9 MR. BROWNSON: On the record, I would 9 MR. LANIER: 1 appreciate that legal
10 just like to say that we object to Exhibit 8
10 advice from you, but unless you're going to
II because it was not previously disclosed.
11 be my lawyer, I'm going to go back and read
12 MR. WILL: And for the record, there
12 the record.
13 was no obligation to disclose it, no request 13 MR. WILL: That's fine. I was just
14 or anything else.
14 trying to give you a sense of what had
15
MR. POLK: I disagree with that. Mike
15 transpired. You can ask Mr. Brownson or
16 Polk on behalf of Minnesota asbestos injury
16 Mr. Polk since they're the ones who were
17 plaintiffs. That's never been discussed.
17 here.
18 In 15 years of litigation -- 1 believe that
18 MR. LANIER: It's on the record. 1
19 that document is, in fact, responsive to
19 can read it.
20 numerous requests, including various
20 (Recess taken from 11:45 to 11:55.)
21 requests for production of documents and
21 THE VIDEOGRAPHER: The time is 11:55
22 samples specifically requested in the
22 a.m. We're back on the record.
23 uniform request for production of documents
23 Q. Mr. Sayers, have we marked now as
24 that governed the conduct of asbestos
24 Exhibit 8 a photocopy of the card and the plastic
25 litigation in Minnesota.
25 bag that you showed earlier on the video?
SPHERION DEPOSITION SERVICES PI 71490-3430
28 (Pages 106 to 109)