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TO: File
MEMORANDUM I
FROM: Deborah Mailander
R E : Attached documents
DATE: February 17, 1993
During the deposition of Gene Miller, Monsanto introduced
I
these documents, apparently to show they told GE to Warn the
buyers. Paul Merrell got Gene Miller to agree that Westinghouse
I .I
knew by 1971 that PCB were hazardous to lifeforms and the
environment.
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Names^ (last, first) Miller, Gene
Witness Type: (fact or expert) Fact
Employer: Westinghouse
Position: Marketing Manager
Address : unknown
Phone:
unknown at this time
Summary of Testimony: There is no doubt Westinghouse knew PCBs were deliterious to life forms and the environment in general by October 971.
Depositions to Date: (date taken, whether summarized) February 16, 1993, not summarized yet
Open
Trial Exhibits for this Witness: (Exhibit number, bates number, title, and author)
Other Documents: Monsanto introduced exhibits against Westinghouse which show both parties knew of dangers and Monsanto attempted to shift duty to warn to Westinghouse
Trial Notebook Section Completed: (yes or no) no
Contacts made: (Willing to testify at trial, dat, and summary)
Follow-up required: Summarize deposition, Holl^ needs to ensure documents from deposition are bates numbered ana put into trial notebook. Need to add phone number and address above.
***ifc**********0 ]ici Rscord*****************************
Name: (last, first) Jones, Jane
Witness Type: (fact or expert) Expert
Employer: Knowitall Inc.
Position: Toxicology of PCBs
Address: 101 1st st
Phone:
(101) lll-llll
Summary of Testimony: PCBs are bad
Depositions to Date: (date taken, whether summarized) none
Open
Trial Exhibits for this Witness: (Exhibit number, bates number,
title, and author) none to -date
Other Documents: none to date
Trial Notebook Section Completed: (yes or no) no
Contacts made: (Willing to testify at trial, date ; and summary) yes, Debbie called on January 1st. Jones is probably willing to testify.
Follow-up required: Contact Jones by letter describing basics of case and asking what her rates are and what documents she needs. Follup up with phone call and set date to int erview
************** end Record* ****************************
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Name: i_last> first) 1-
Witness Type: (fact or expert)
Employer: 3-
Position: 4-
Address: 5-
Phone:
6-
2-
Summary of Testimony: 7-
Depositions to Date: (date taken, whether summarized) 8~
0pen9~
Trial Exhibits for this Witness: (Exhibit number, bates number, title, and author) 10-
Other Documents: 11
Trial Notebook Section Completed: (yes or no) 12-
Contacts made: (Willing to testify at trial, date, and summary) 13-
Follow-up required: 14-
**************end Record*****************************
^ U U*PUy j
Name:
(last,
first)-Witness
Type:
(fact
or
exper-t).~Employer~Position or expertise-Address-Phone-Summary of
Testimony-Depositions to Date (date, whether summarized)-Open-Trial
Exhibits (exhibit number, bates number, title, and author)-Other
documents-Trial Notebook section completed: (yes or no)-Contact
made (date, summary, willingness to testify at trial)-Follow-up
required:~~
Miller, Gene Fact __ Westinghouse Marketing Manager unknown unknown at this time There is no doubt Westinghouse knew PCBs were deliterious to life forms and the environment in general by October 1971. February 16, 1993, not summarized yet
Monsanto introduced exhibits against Westinghouse which show both parties knew of dangers and Monsanto attempted to shift duty to warn to Westinghouse no
Summarize deposition, Holly needs to ensure documents from deposition are bates numbered and put into trial notebook. Need to add phone number and address above.
Jones, Jane Expert__ Knowitall Inc. Toxicology of PCBs 1 0 1 1 st st C101) 111-1111 PCBs are bad none
none to date none to date no yes, Debbie called on January 1st. Jones is probably willing to testify. Contact Jones by letter describing basics of case and asking what her rates are and what documents she needs, Follup up with phone call and set date to interview