Document NEV90y2JY90g9YLbD2Jq8Q9ky

S Ci M D D C u m 6 S'pKfrCt/i Vt> ht d:a>raKd loi dt,f*, h j q { y y h) y- r y t b 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. ^ /7/^. %k\jxAj 30 0 &Znc DNM:bms ^o 9- n < c U ; h <s r A / & uS c C'hon ~J Hr ofco*,^ ^uUJCn oUfffs.. ( 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* **************************** - .> ~> \ i /'\r~i ijs1 e - /v ' k I 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