Document NGDjGX75jXJ3wRa4RKe93E1ky

FILE NAME: Asbestos Corp Ltd (ACL) DATE: 2000 DOC#: ACL021 DOCUMENT DESCRIPTION: Legal - Plaintiff's List of Fact Witnesses By: L ip s it z & Ponterio, LLC; 716 849 0706; A p r - 1 2 - 0 0 10 : 45AIWJ Page 2/3 <7 E. FACT WITNESS DISCLOSURE RELATING TO PUNITIVE DAMAGES CASE AGAINST ASBESTOS CORPORATION, LTD. Witnesses with Knowledge of Asbestos Corporation, L td.'s Worldwide Sales and Marketing Activities. 1. Jpan DupcrC, the majority owner of LAB Chrysotile, rnc., concerning his remarks published in an article in the Toronto Star on March 21, 1999, regarding the sale of Canadian asbestos to third world countries, and the likelihood that "Canadian asbestos...will kill foreign workers in Algeria, a developing country." 2- Dr. Julian Peto. Department of Epidemiology, University of London, Institute of Cancer Research, concerning his remarks published in articles in the Toronto Star on March 20, 1999 and March 21, 1999, regarding the unsafe use of asbestos by workers in the construction industry in third world countries, which will likely result in an epidemic of asbestos-related cancers in the developing world. 3. Michael J. Messel. 49 Cherrywood Drive* Nepean, Ontario. Canada, live or by deposition transcript taken on January 15, 1987 in. Clavton Brass, et al vs. Asbestos Corporation Limited, et al. Province of Quebec, District of Montreal, Superior Court Case No. 500-05 011589-867, concerning knowledge gained by attendance at a conference in Antigua in the mid1960's concerning the relationship between asbestos exposure and lung cancer, and between asbestos exposure and mesothelioma. 4. Michel Camus. Ph.D.. regarding findings published in the New England Journal of Medicine, May 28, 1998. 5. Jack Siemiatvcki. Ph.D .. regarding findings published in the New England Journal of Medicine, May 28, 1998. 6- Bette Meek, M.Sc., regarding findings published in the New England Journal of Medicine, May 28, 1998. 7. Dr. Philip Landrigan, New York, Mt. Sinai School of Medicine, concerning his remarks published in an article in the Toronto Star on March 20, 1999, regarding his belief that studies being done in Quebec regarding the effect of asbestos exposure are being misinterpreted, and that rates of pleural cancer in Quebec arc "in fact 763 percent higher" than normal. 8. Dr. Barry Castleman. Ph.D., 2412 Pickwick Road, Baltimore, Maryland 21207, concerning his remarks published in an article in the Toronto Star on March 20, 1999, regarding his belief that the consequences for poor and developing nations using Canadian asbestos could be deadly. 9. Dr. William Nicholson. Mt. Sinai School of Medicine 04/12/00 10:48 TX/RX NO.5404 P.002 snt By: L ip s it z & P o n terio , LLC; 716 849 0708; A p r - 1 2 - 0 0 10:45AIW; Page 3/3 10. Harsh Jaitli, Director, Occupational and Environmental Health Clinic, New Delhi, n ` t . Oprdon MeVie, Director, Cancer Research Campaign, United Kingdom, concerning his remarks published in an article in the Toronto Star on March 20, 1999, warning that the CRC's study into the European epidemic of asbestos exposure should "sound alarm bells everywhere," especially in the developing world where uncontrolled asbestos use is still very common. 12` E>f- Joseph f^Dou, University of California Medical School, Editor International Journal of Occupational and Environmental Health, concerning his remarks published in an article in the Toronto Star on March 20, 1999, condemning Canada's promotion of asbestos use in the developing w orld , and its "exploitation o f ifm oranee arid poverty " in Asia, Africa and Latin -- ------ ~-------- ----~ Michael Grattpn, former Director, Asbestos Institute, concerning his remarks published in an article in the Toronto Star on March 20, 1999, regarding his belief that the Asbestos Institute cannot ensure Canadian asbestos is being safely handled abroad, and that the industry was more interested in "the almighty dollar." 04/12/00 10:48 TX/RX NO.5404 P.003