Document Ne122bqnDOnMM2roLvdM6RzDD
Page 1
1 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS
2 STATE OF MISSOURI
3 GLENN BROWN, et al.,
4 Plaintiffs,
5 -vs-
# 862-00694
6 MONSANTO COMPANY,
7 Defendant.
8
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12 Volume II
13 DEPOSITION of DR. R. EMMET KELLY
14 On the part of the Defendant
15 June 1,1990
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23 WALLER REPORTING, INC.
24 REGISTERED PROFESSIONAL REPORTERS
25 515 Olive Street, Suite 1506
26 St. Louis, Missouri 63101
27 (314)621-2571
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1 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS
2 STATE OF MISSOURI
3 GLENN BROWN, et at,
4 Plaintiffs,
5 -vs-
Cause # 862-00694
6 MONSANTO COMPANY,
7 Defendant.
8 DEPOSITION OF WITNESS, produced, sworn and examined
9 on June 1, 1990, between 8:00 a.m. and 6:00 p.m. of that
10 day, at the offices of Communitronics Corporation, 1907
11 South Kingshighway, St. Louis, Missouri, before Sheila C.
12 Irvin, a Notary Public within and for the State of
13 Missouri, in a certain cause now pending in the Circuit
14 Court of the City of St. Louis, State of Missouri, wherein
15 GLENN BROWN, et al. are the Plaintiffs, and MONSANTO
16 COMPANY is the Defendant; on behalf of the Defendant.
17 APPEARANCES
18 The Plaintiffs were represented by Mr. David S.
19 McCrea of the law firm of McCrea & McCrea 119, South Walnut
20 Street, Bloomington, Indiana 47402.
21 The Defendant was represented by Mr. Thomas M.
22 Carney of the law firm of Husch, Donohue, Cornfeld &
23 Jenkins, 100 North Broadway, St. Louis, Missouri 63102.
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1 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 1
CONTINUED CROSS EXAMINATION
2 STATE OF MISSOURI
2 QUESTIONS BY MR. McCREA:
3 GLENN BROWN, et at,
4 Plaintiffs,
5 -vs-
Cause # 862-00694
6 MONSANTO COMPANY,
7 Defendant.
8 g ***
10 INDEX
11 WITNESS:
Page:
12 DR. R. EMMET KELLY
13 Continued Cross Examination by Mr. McCrea. ... 4
14
15 EXHIBITS
16 Plaintiffs Deposition Exhibit #1..................... 40
17 Plaintiffs Deposition Exhibit #2...................... 118
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3 Q Dr. Kelly, how are you this morning? 4 A I'm fine, thanks. And yourself? 5 Q Pretty good. Thank you. Dr. Kelly, in 6 preparing for this deposition, did you review any 7 documents? 8 A Yes, 1 did. 9 Q Did you review any documents other than the 10 documents that have been identified as exhibits and which 11 have been displayed to you during direct examination? 12 A No, 1 have not. 13 Q Were you asked to render an opinion in this 14 case? 15 A About what? 16 Q About anything. 17 A 1 was asked to18 MR. CARNEY: Let me object to the question. 1 19 think it's overbroad and 1 think he was, what he was asked 20 is on the record and on the videotape. 21 Q (By Mr. McCrea) Maybe 1 can be more precise. 22 Did the attorneys for Monsanto ask you to provide them with
24 23 an expert opinion on any subjects relating to PCBs?
25 24 MR. CARNEY: I'm going to object to that. 1
26 2
25 don't know what you mean. We asked for various opinions
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 1 - 4
LEXOLDMONOQ6743
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1 that were given. 1 don't know if you're using the word
1 with PCBs.
2 asked for an expert opinion in some technical term or legal
2
Q Was that the first time, Dr. Kelly, that you
3 term. This person isn't an attorney.
3 have met with the attorneys in this case?
4 Q (By Mr. McCrea) You may answer.
4 MR. CARNEY: You talking about me or anybody
5 A Will you ask it again?
5 in my office?
6 Q Did the attorneys for Monsanto ask you to
6 MR. MCCREA: Yes, the attorneys of record in
7 provide them with an expert opinion on the subject of PCBs? 7 this particular case.
8 A Yes, they asked me to provide on expert
8 A 1 certainly have not met with Miss Rutter
9 opinion if PCBs could be used safely in the industrial
9 before, and 1 honestly don't remember if 1 saw Mr. Carney
10 workplace.
10 in any other cases.
11 Q Did they ask you to render any other opinions?
11 Q (By Mr. McCrea) Were there any videotapes of
12 A Yes, they asked me if we had any records,
12 a question and answer session in preparing for this
13 either personally or in the, if 1 had any information from
13 deposition which you reviewed?
14 the Medic Alert literature that's serving the presence or
14 A No.
15 absence of any illness due to PCB outside of acute episodes 15
Q Dr. Kelly, yesterday 1 asked you about testing
16 and chloracne.
16 which Monsanto did regarding the presence of furans in
17 Q Did they ask you for any other opinions?
17 PCBs. Can you tell us what a furan is?
18 MR. CARNEY: I'm going to object. The
18 A Yes. 1 can draw it for you if you want.
19 opinions or the questions that we asked him were on the
19 Q All right, sir. Do we have an extra pad that
20 record, and 1 think what you're doing is asking him to
20 we can provide the doctor?
21 summarize all the answers that he gave yesterday during a 21
A It's two benzenes that are connected by one
22 full day of testimony. 1 don't see any point in this and
22 oxygen.
23 it's - 1 think you can just refer to those answers that he
23 Q What are the chemical elements in a furan?
24 gave yesterday. That's -- Those are the questions we
24 A Carbon. It depends on which furan, which one
25 asked.
25 you're talking about.
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1 Q (By Mr. McCrea) You may answer.
1 Q 1 don't know. Do they differ?
2 A If you will give me the question saying did
2 A Yes, certainly.
3 they ask you for this opinion, 1 can't recall.
3 Q All right.
4 Q Okay.
4 A It all depends on how much chlorine is in
5 A Any myriad of opinions 1 might havegiven
5 there.
6 during a couple hours of discussion 1 had with them. If
6 Q What are the different elements, the different
7 you ask me did they give you, did they ask you for an
7 chemicals in a furan?
8 opinion about this factor concerning PCB, I'll answer you
8 A Hydrogen, carbon, oxygen.
9 yes or no.
9 Q Does it have chlorine?
10 Q Were you asked to review the medical records
10 A You asked furans now.
11 of the plaintiffs in this case?
11 Q Right.
12 A No.
12 A If it's a chlorinated furan it certainly has
13 Q Have you seen the medical records of the
13 chlorine, but you asked about furans.
14 plaintiffs in this case?
14 Q All right. A chlorinated furan would have
15 A No.
15 carbon, hydrogen, oxygen and chlorine?
16
Q As a physician for Monsanto, have you reviewed
16
A That's correct.
17 medical records of workers exposed to PCBs?
17 Q Then there are also furans which are not
18 A Yes.
18 chlorinated?
19 Q In preparing for this deposition, did you get
19 A That's correct.
20 together with the attorneys and review questions that they
20
Q Which would only have carbon, hydrogen and
21 would address to you?
21 oxygen?
22 A They reviewed the general tenure of my
22 A If it's a pure furan you're talking about.
23 deposition. They were asking what they wanted to acquire 23 There are other -- There's a brominated furan, if you want
24 from me. They asked what particular facts and opinions 1
24 to get into that.
25 had about the, my experience with Monsanto, my experience 25
Q And that would have -
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 5 - 8
LEXOLDMONOQ6744
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1 A Bromine instead of chlorine.
1 Q And who was in charge of that laboratory at
2 Q All right. Are there other halogenated
2 that time?
3 chemicals associated with furans?
3 A A Dr. Keller, K-e-l-l-e-r.
4 A Well, there's only one other halogen. That's
4 Q Was he the one who did the testing?
5 iodine, and 1 don't know if there are any iodine furans.
5 A 1 wouldn't know.
6 Q So there are essentially three variables of a
6 Q Were those results discussed with you?
7 furan, and you've described those?
7 A 1 don't have any particular recollection of
8 A No, that's not true.
8 it. Somebody gave me the results. 1 don't know who gave
9 Q 1 mean, three different sets of chemicals in a
9 it to me, but there was no great discussion.
10 furan. One would be carbon, hydrogen and oxygen. A
10 Q You stated that there was a varying amount of
11 chlorinated furan would have those chemicals plus chlorine, 11 furans in the batches of PCBs. Is that a correct
12 and a bromated -- Is that the word?
12 statement?
13 A That's certainly a word, yes.
13 A To the best of my knowledge, there was some
14 Q Would have carbon, hydrogen, oxygen and
14 variation, yes.
15 bromine?
15 Q Was there any explanation as to why they would
16 A That's right.
16 have more furans in one batch of PCBs as opposed to another
17 Q Instead of chlorine?
17 batch of PCBs?
18 A That's right.
18 A No. Whether it was sensitivity to laboratory
19 Q Are there any other combination of chemicals
19 methods or not, 1 don't know. There was no great
20 that make up a furan?
20 discussion because there was no large variation, no large
21 A Now, furans have oxygen, chlorine, hydrogen.
21 amounts of the furans, and they were talking about single
22 There are no changes in a furan. Now, you want to talk
22 digit parts per million.
23 about chlorinated furans?
23 Q Was this testing reduced to writing? Were the
24 Q Well, we have a pure furan. Then we have a
24 results reduced to writing?
25 chlorinated. Then we have a bromated.
25 A I've seen a memorandum about it on one
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1 A That's correct.
1 occasion.
2 Q Are there any others?
2 Q What do you recall about that memorandum?
3 A There may be laboratory curiosities. 1 don't
3 A Just that it had a couple of figures about the
4 know of any.
4 amount of furan, of chlorinated furans in the material.
5 Q Who requested that Monsanto do the testing for
5 That's all 1 remember, and that the figures were under ten
6 furans in the early '70s which you described yesterday?
6 parts per million. 1 don't know how far under.
7 A 1 don't know.
7 Q Were they testing pure PCB?
8 Q Did you know that this testing was going to
8 A They were testing manufactured run PCB.
9 take place?
9 Q Did they test PCBs from Japan?
10 A 1 knew after it was done.
10 A 1 don't know.
11 Q Okay. From whom did you receive the
11 Q You have never heard anyone from Monsanto
12 information that the testing had been done?
12 discuss the relative level of furan contamination of PCBs
13 A Somebody in the analytical laboratory. This
13 comparing Monsanto's PCBs to the Japanese PCBs?
14 was 18 years ago, 20 years ago. 1 don't recall the name. 14 A 1 may have heard it. 1 mean, 1 have some
15 Q What was the purpose of the testing for furans
15 vague recollection that they said we had less than the
16 as you understood it by Monsanto Company in the early '70s? 16 Japanese, but 1 don't have the figures. You must realize
17 A To see if they were there.
17 the Japanese manufacture their PCBs in a different manner
18 Q Where was the testing done?
18 than we do.
19 A 1 would -- To the best of my knowledge, it
19 Q Do you know of any documents in the possession
20 would have been done at the research laboratory in St.
20 of Monsanto which discuss the relative levels of furans in
21 Louis.
21 Monsanto's PCBs compared to Japanese PCBs?
22 Q Is that part of your main office?
22 A 1 don't know if any exist or ever did exist.
23 A That's correct.
23 1 don't know.
24 Q In downtown St. Louis or where is it?
24 Q But you do recall a discussion about the
25 A No, it's out on Lindbergh Boulevard.
25 very --
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 9-12
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1 A Well, there was --
1 A Various publications.
2 Q Just a second, please.
2 Q Can you cite any of them?
3 A Pardon me.
3 A Well, 1 can cite you one in '84.
4 Q You do recall a discussion from people in
4 Q Can you cite any in the late '70s when you
5 Monsanto about the relative levels?
5 gained your knowledge?
6 A Well, 1 do -- I'm telling you that 1 do
6 A No, but this review in 1984 referred to some
7 recall, 1 have some vague recollection of people talking
7 work done previously.
8 over the relative amounts, but 1 don't recall the people
8 Q Did you communicate the information about the
9 and 1 don't have any written data on it.
9 furans being enormously more toxic than PCBs to your board
10 Q Was this data about the furan level in the
10 of directors?
11 PCBs given to the government?
11 MR. CARNEY: Let me object. Since he said he
12 A 1 don't know.
12 learned in the late '70s, that would mean he was retired
13 Q Was it given to your board of directors?
13 from Monsanto. So when you say your board, it doesn't make
14 A 1 don't know that, but 1 would doubt it.
14 much sense.
15 Q Was it given to Westinghouse?
15 Q (By Mr. McCrea) 1 stand corrected. Dr.
16 A 1 don't know.
16 Kelly, based on the number of times that you've served as
17 Q Was it given to any public utilities?
17 an expert fact witness for Monsanto, do you have any
18 A 1 don't know.
18 knowledge of personnel in Monsanto communicating to the
19 Q Was it given to anyone?
19 board of directors that furans were enormously more toxic
20 A 1 don't know.
20 than PCBs?
21 Q Were any tests conducted by Monsanto to test
21
MR. MCCREA: I'm going to object to that. 1
22 the furan level of PCBs after the PCBs had been heated?
22 don't think since Dr. Kelly's retirement there's been any
23 A How do you mean heated?
23 foundation laid that he has any contact with the board of
24 Q Heated as the PCBs were heated in Japan when 24 directors. I'm not sure he had any contact with the board
25 they were used as a heat transfer fluid and escaped into
25 before he was retired, but I'm quite confident he didn't
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1 the rice oil, a similar type elevation of temperature.
1 have any contact with the board, so there's no foundation
2 A 1 don't know.
2 for him having any potential for knowledge about that
3 Q How are furans formed in PCBs?
3 question.
4 A 1 don't know the chemistry of the formation of
4 Q (By Mr. McCrea) You may answer.
5 furans in PCBs.
5 A 1 don't know of anybody who has talked to the
6 Q What is the difference between a chlorinated
6 board of directors about anything since 1 retired from
7 furan and a chlorinated PCB as far as the chemical elements 7 Monsanto.
8 in the two compounds are concerned?
8 Q Do you know of any information which was given
9 A Well, if you are just talking about chemical
9 by Monsanto to the United States Government that reflects
10 elements, there are large varieties in the way these
10 your knowledge that furans are enormously more toxic than
11 chemical elements are mixed up. Here we have two benzene 11 PCBs?
12 rings that are connected by oxygen. That's an entirely
12
MR. CARNEY: I'm going to object to that
13 different compound. The two benzene rings are connected 13 question because it would call for this witness to answer,
14 just by themselves. So you cannot rationalize saying,
14 try to answer a question after he was retired from the
15 "Well, we've got one oxygen and that's furan and we don't
15 company, so there's no foundation that he would know what
16 have an oxygen in the PCB, so they're practically the
16 Monsanto did or didn't do.
17 same." Well, that is nonsense.
17 Q (By Mr. McCrea) You may answer.
18 Q Is a furan more toxic?
18 A No, 1 don't know, but 1 certainly know that
19 A Yes, enormously more.
19 the government read the same articles that Monsanto
20 Q When did you know--
20 scientists did. They read the same ones 1 did, so it
21 A Chlorinated furan, sir.
21 really is, it's an overkill as it were.
22 Q When did you know that a chlorinated furan was 22 Q How do you know that?
23 enormously more toxic than a PCB?
23 A Because 1 know the caliber of the scientists
24 A Late '70s, 1 suppose, sometime in the '70s.
24 in the government. 1 know the people that have been
25 Q How did you learn that?
25 writing on it. You see lots of articles coming out from
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 13-16
LEXOLDMONOQ6746
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1 various divisions of the United States Government.
1 A 1 can't answer that. 1 wasn't connected with
2 Q Can you name one individual?
2 Monsanto at that time.
3 A Sure. I'll give you Kimbrough as a starter.
3 Q But the testing for furans was before your
4 Q Okay. And --
4 retirement and you've described that?
5 A She wrote a book on PCBs and halogenated
5 A That's correct.
6 hydrocarbons. She wrote several articles, review articles
6 Q And Monsanto continued production until some
7 that included information about dibenzofurans and
7 three years after your retirement, 1977?
8 dibenzodioxins.
8 A 1 don't know if it was '77. 1 can't tell you
9 Q Did the government ever ask Monsanto for test
9 that.
10 data as to the amount of furans in its PCBs?
10 Q Was there any effort to reduce the amount of
11 A 1 have no knowledge of any such request up to
11 furans in PCBs after the testing was done by Monsanto and
12 1974. Whether they did after '74 or not, 1 don't know.
12 before they stopped production?
13 Q And you have no knowledge up to'74 of that
13 A 1 don't know if there was or not.
14 data being given to the government?
14 MR. CARNEY: I'm going to object to that
15 A Never been asked. 1 said 1 have no knowledge
15 question. Again there's no foundation that this witness
16 of being asked for it by the government.
16 would be in a position to know that since he retired in
17 Q And also you have no knowledge that Monsanto 17 '74, and anything after that time he wouldn't have been
18 gave that data to the government?
18 involved.
19 A No, 1 have no knowledge of that.
19 Q (By Mr. McCrea) Was there any effort, Dr.
20
Q Can you explain why furans are enormously more
20 Kelly, to reduce the level of furans at Monsanto Company
21 toxic than PCBs from a toxicological standpoint?
21 before your retirement in 1974?
22 A No, 1 cannot, except they are. That's all.
22 A There may or there may have been not. Ido
23 Q To this date, Dr. Kelly, do you know if
23 not know. 1 do not know of any, but at that particular
24 Monsanto has conducted any tests to determine the amount of 24 time it was not critical to us because we knew the toxicity
25 furans in PCBs after they are heated?
25 of our PCBs and that toxicity included the presence of
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1 A 1 do not know if they have or not. They may
1 these furans, and we knew those furans were in that. We
2 have. 1 may have had some recollection in the past. 1 do
2 were manufacturing it the same way for 30 years, so if we
3 not have any recollection at the present time.
3 had furans in 1972, we had the same furans in 1974 and we
4 Q Was there any effort by Monsanto to eliminate
4 knew what the toxicity was, so we were not concerned about
5 furans in its PCBs after the testing was done in the early
5 it as an industrial chemical. There was no problem from
6 '70s and the furans were detected by analytical methods?
6 the toxicity point of view in our minds.
7 A Well, 1 don't know that, but you must
7 Q But you also knew that the episode in Japan
8 remember, by the time that analytical expertise was present 8 involved heating the PCBs; correct?
9 to look for furans, we were phasing out of the business.
9 A Heating and eating, yes.
10 This was -- As 1 said, this was in the late '70s or the mid
10 Q Right. And eating is a means by which PCBs
11 '70s that we're in a position to examine for furans, and we
11 are absorbed into the body; correct?
12 were getting out of the business.
12 A Well, it's one of the ways.
13 Q You retired in'74?
13 Q And they also are absorbed into the body by
14 A That's correct.
14 going directly through the skin; correct?
15 Q This testing took place before your
15 A That's correct.
16 retirement?
16 Q And they also absorb into the body by being
17 A Yes, it did. Well, in the mid'70s, 1 think.
17 breed?
18 Q Well, it took place while you were there?
18 A That's correct.
19 A Yes.
19 Q So they get into the body three ways?
20 Q Monsanto didn't stop manufacturing PCBs until 20 A That's correct.
21 after the Toxic Substances Control Act in 1976; correct? 21 Q And you knew that in Japan the PCBs had been
22 A 1 said they were phasing them out. 1 didn't
22 heated; correct?
23 say they stopped manufacturing them.
23 A Yes.
24 Q All right. 1 understand. What was the month
24 Q And did you ever attempt to duplicate the
25 and year that Monsanto stopped all production of PCBs?
25 toxicity of your PCBs by heating them and then presenting
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 17-20
LEXOLDMONOQ6747
Page 21 1 animal species for absorption of the heated PCBs? 2 MR. CARNEY: Let me object. 1 don't think 3 there's any foundation that Dr. Kelly knew these details at 4 the time of his retirement. There's some question, as you 5 recall yesterday, as to when the Yusho incident was 6 published in the English language, and so 1 think your 7 question is, there's no foundation for it since if he 8 retired and didn't have that information, he wouldn't know 9 what Monsanto did after his retirement. 10 Q (By Mr. McCrea) Dr. Kelly, did you know that 11 the Yusho incident involved PCBs which were heated before 12 your retirement. 13 A Yes, yes, 1 did. 14 Q Did you know that the Yusho incident involved 15 furans as a contaminant before your retirement? 16 A That is hard for me to recall because it was 17 at least one or two years, several years afterwards that 18 the analytical work done by the Japanese was done. There 19 was also then some time after the Japanese work was 20 translated into English or appeared in the English 21 literature and -- Let me finish, please. 22 So 1 have seen numerous documents in these various 23 PCB depositions, and 1 am unable at this time to recall if 24 these documents which reflected the presence of 25 dibenzofurans in heated PCBs were shown to me after 1
Page 23 1 A 1 got that from Masuda, M-a-s-u-d-a, "American 2 Journal of Industrial Medicine", November 1984. He stated 3 that persons consumed between 195 and 3,375 milliliters of 4 rice oil. That translates down to half a pint to three 5 quarts roughly. 6 Q How many ounces, grams or milligrams of PCB 7 were consumed? 8 A During that period of time if you took9 Well, to take a round figure, if you divide 3,375 that's, 10 and there was less than a thousand parts of the PCB in the 11 rice oil, a thousand parts per million, a thousand parts 12 per million, so there would be 1,000. It would be three 13 milliliters. That was a half a teaspoon. It was a 14 teaspoonful. 15 Q How many milligrams would that be? 16 A According to my figures, 3.3. 17 Q 3.3 milligrams? 18 A Milliliters. 1 have to19 Q Why don't you calculate for us the amount of 20 PCB which was ingested by the Japanese at the low range, 21 195 milliliters, and the high range? 22 A You have a calculator here, by the way? 23 Q What? 24 A You have a calculator? 25 Q I'm sorry. They might have one in the
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1 retired in 1974 or whether they were memoranda that 1 saw
1 building. At the low range, 195 milliliters and the high
2 prior to 1974. 1 would believe it's the former because I'm
2 range, 3,375 milliliters?
3 not so, 1 do not believe that 1 saw data concerning the
3 A Well, if you consumed 195--let's make it 200
4 development of furans in the heated Japanese heated
4 -- and if they had 200,000 parts of PP per million, they
5 Kanaclor. 1 just -- 1 can very well be confused with
5 would probably take--unless I've lost a few zeros in here
6 memoranda that 1 had before 1974 or documents that were
6 -- 200, .02 milliliters of PCB the low level, and it's
7 shown to me during these numerous PCB depositions that I've 7 about 16 times that much for the high level.
8 undertaken.
8 Q All right. How many -- How much is that in
9 Q Dr. Kelly, do you know of any other reason why
9 milligrams?
10 the Monsanto people in the analytical laboratory were
10 A Well, it's roughly the same. 1 mean, give or
11 testing for furans in the Monsanto's PCBs other than the
11 take ten percent. 1 don't know the specific gravity of
12 concern of its toxicity as was demonstrated in Japan?
12 PCBs, but it's pretty close.
13 A 1 don't know, and 1 don't know whether they
13 Q All right. So approximately how many
14 did it because of the concern over toxicity.
14 milligrams were ingested at the level of 200 milliliters of
15 Q You know that people were poisoned in Japan? 15 rice oil?
16 A Yes.
16 A 200ths. That would be .02.
17 Q You know that those people consumed PCBs?
17
MR. CARNEY: Would it help you, Doctor, to
18 A They consumed PCBs. They consumed chlorinated 18 have a calculator?
19 benzofurans. They consumed quaterphenyls. They drank 19
A Well, it would be easier.
20 quite a lot of it. You asked me yesterday about the
20 MR. McCREA: Could we take a break and then
21 ballpark figures. They drank from a half a pint to three
21 see if there's a calculator in the building?
22 quarts of the rice oil over the course of the months. Yes,
22
MR. CARNEY: Why don't we do it at the break
23 we knew that.
23 rather than, you know, we'll have a break and -
24 Q Where did you get that information between
24
MR. McCREA: Well, I'd like to stay so that
25 yesterday and today?
25 there's continuity for the jury.
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
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1 A Well, if we have, if the person at the low
1 and their offspring?
2 level consumed 200 milliliters of rice oil, and let's
2 MR. CARNEY: I'm going to object to that. He
3 assume also with an error often percent, that's 200
3 didn't do it in milligrams, but he gave you the information
4 milligrams of rice soil, and if that 200 milligrams of rice
4 in quarts and pints which 1 think the average person
5 oil had 1,000, 1,000 parts per million so that we get 1,000
5 understands a lot more than milliliters or milligrams, and
6 of it, that's .2 milligrams of rice oil. That's correct,
6 1 think he indicated he read that letter back in '84.
7 .2 milligrams of rice oil at the low level and the high
7 A Your answer is completely wrong. Your
8 level 16 times that. That's 3.2 milligrams at the high
8 question's completely wrong. 1 did know it.
9 level of PCB in the rice oil, of PCB that they consumed.
9 Q (By Mr. McCrea) All right. What was the
10 Q So the total amount of PCB that the Japanese
10 amount of PCB consumed by the Japanese which poisoned the
11 consumed which poisoned them was how much in milliliters? 11 people who ingested it and caused birth defects in their
12 A Well, we're not saying that the PCBs poisoned
12 children?
13 them.
13 A Now, just a moment. It was not the PCBs.
14 Q Well --
14 Q Just a second. All right. Let's have three
15 A It was the dibenzofurans that caused that.
15 calculations; all right? Do you know, Dr. Kelly, from your
16 Q We'll get to that, but first 1 want to know
16 knowledge as the former medical director of Monsanto and
17 PCBs. How many milliliters -- how many - Excuse me. How 17 based upon your testimony in numerous cases involving
18 many milligrams?
18 Monsanto and PCBs what the quantity of PCBs was that was
19 A Between 2/10 of a milligram and 3.2
19 ingested, what the quantity of furans was that was ingested
20 milligrams.
20 and what the quantity of quaterphenyls was that was
21 Q And that's based on the information from?
21 ingested by the Japanese which poisoned them and caused
22 A Well, the "Annals of Industrial Medicine",
22 birth defects in their children? If so, would you tell us?
23 November 1984, and if you want to continue in that same
23
MR. CARNEY: I'm going to object to it as a
24 journal, Dr. Kabuto stated it was clear that the PCDFs, the
24 compound question. You've asked three questions. If you
25 dibenzofurans chlorinated were the main causative agent in 25 break it down, what was PCBs and then go on to the rest.
Page 26
Page 28
1 the case of Yusho disease because he gave comparative
1 MR. McCREA: Tom, that would be fine, but
2 amounts of the dibenzofurans to monkeys and he got the skin
2 every time 1 ask him about PCBs he says it's not the PCBs,
3 problems, the thymus atrophy in rats. He got skin problems
3 it's the furans.
4 in the monkeys, thymus atrophy in rats, and he gave the
4 MR. CARNEY: Well, you can ask him what the
5 PCBs to them and he didn't get anything. So he was the one
5 quantity was in PCBs and 1 think he can tell you that.
6 that concluded - That was the basis for his conclusion as
6 A Do you have this article, this series of
7 written in the "American Journal of Industrial Medicine"
7 articles with you with all those exhibits you have? I'll
8 that it was clear that the PCDFs or the chlorinated
8 read them out of there.
9 dibenzofurans were the main causative agent in the Yusho
9 Q (By Mr. McCrea) I'm asking you if you know.
10 poisoning.
10 A Well, 1 know where to get the information.
11 Q What was the quantity of furans ingested?
11 Q No, Doctor. Unfortunately in this situation 1
12 A Much smaller, much, much smaller.
12 ask the questions; all right? Now, if you don't know,
13 Q Can you calculate that for us?
13 we'll get the articles. 1 don't have any trouble with
14 A 1 don't think 1 can. It was much, much
14 that. I'm just asking you if you know.
15 smaller by a couple of magnitudes. It would be ten
15 A Yes. To the best of my knowledge, persons
16 hundred, something like that.
16 consumed 195 to 300, 3,375 milliliters of rice oil which
17 Q Now, you're working through these calculations
17 contained 920 parts per million of PCB.
18 on June 1, 1990 for the first time. Is that correct,
18 Q 920?
19 Doctor?
19 A 920.
20 A That's correct.
20 Q Parts per million PCB?
21 Q And -
21 A That's correct.
22 A Well, not through the calculations. 1 looked
22 Q All right. And what - Okay. Thank you.
23 at the figures. 1 didn't go down to check out the exact -
23 Now, how many parts furan?
24 Q But until this date, you have never known the
24 A Someplace between five and 18 parts per
25 amount of PCBs ingested by the Japanese which poisoned them
25 million of furans.
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 25 - 28
LEXOLDMONOQ6749
Page 29
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1 Q Five and 18 parts per millionfurans?
1 Q Did you know that information before today?
2 A That's correct.
2 A Yes, I've read it, yes. Remember, you also
3 Q All right. And how many for quaterphenyls?
3 have to take this into consideration what is the lethal
4 A 1 don't have those figures.
4 LD50 of PCBs. That's 4,000 milligrams.
5 Q All right. Now, Doctor, without calculating,
5 Q But it only took 1/100 of an ounce and
6 can you give the injury the amount of PCBs ingested? Do
6 1/10,000 of an ounce of this compound to poison these
7 you know that figure?
7 people?
8 A Something between .2 milligrams and 3.2
8 MR. CARNEY: Well, I'm going to object.
9 milligrams.
9 You're mixing apples and oranges. The testimony -- Are you
10 Q And how many milliliters is that?
10 talking about PCBs? Are you talking about furans?
11 A Well, roughly the same depending on the
11 Q (By Mr. McCrea) Tom, if you listen to the
12 specific gravity of PCBs. 1 don't know what that is.
12 question. Doctor, it took 1/100 of an ounce of PCBs and
13 Q .2 milliliters?
13 1/10,000 of an ounce of furans in the PCBs in Japan to
14 A Huh?
14 poison those people?
15 Q .2 milliliters?
15 MR. CARNEY: Let me object to it. You've
16 A Yes, to 3.2 milliliters.
16 asked two questions, and if you want to ask him one at a
17 MR. CARNEY: It might be helpful to the jury
17 time, that's fine, but I'm going to object. It's a
18 to give it in quarts or pints because at least 1 don't, I'm
18 compound question. You're asking two questions in one, and
19 not adapted to milliliters or milligrams. I'm one of these
19 which one do you want him to answer?
20 old fogies that doesn't understand that. That's kind of
20 MR. McCREA: Well -
21 gibberish.
21 MR. CARNEY: If you'd ask them one at a time,
22 Q (By Mr. McCrea) All right. 1 think that's a
22 I'll withdraw my objection. Otherwise, 1 object as
23 good suggestion from Counsel. Can you express the amount
23 compound.
24 of PCBs in quarts or pints that were ingested by the
24 MR. McCREA: 1 have this problem because when
25 Japanese which caused their health problems? Then the same
25 1 ask him about PCBs, he blames it on furans.
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1 question for furans, first as to quarts.
1 MR. CARNEY: That's because that's what the
2 A No, there's an extremely low fraction of a
2 authors in Japan blamed it on. The experts have blamed it
3 quart.
3 on furans. 1 know you don't like that. You would like to
4 Q I'm just taking the suggestion of Counsel.
4 blame PCBs, but the experts disagree with you, Mr. McCrea.
5 A Well, I'd have a decimal point with a bunch
5 MR. McCREA: No, we're satisfied with the
6 of zeros in back of it. 1 don't think that's helping
6 furans in your PCBs.
7 anybody.
7 MR. CARNEY: Well, they were about one
8 Q So it would be less than an ounce?
8 one-hundredth of the number in the Monsanto PCBs as in the
9 A Oh, yes, less than an ounce.
9 Japanese PCBs which you don't like to hear, either.
10 Q Less than half an ounce?
10 MR. McCREA: Where did you get that data?
11 A Yes, less than half an ounce.
11 MR. CARNEY: 1 can supply that data for you
12 Q Less than a quarter of an ounce?
12 later on if you want.
13 A Yes.
13 MR. McCREA: Is that after it was heated? It
14 Q Less than a tenth of an ounce?
14 was in Japan?
15 A Yes, it would be a fraction of an ounce.
15 MR. CARNEY: Do you have a question?
16 Q Less than a hundredth of an ounce?
16 MR. McCREA: I'm just asking you. You're
17 A Around that.
17 volunteering this information.
18 Q Around one-hundredth of an ounce? And can you 18
MR. CARNEY: I'll be glad to give you the
19 tell the jury in quarts or pints what quantity of furans
19 information, but 1 think - I'm not under oath. 1 think
20 was consumed which poisoned the people who ingested it and 20 Dr. Kelly is the one you should be directing your questions
21 caused birth defects in their children?
21 to.
22 A About one-hundredth of that.
22 MR. McCREA: You're supplying information, and
23 Q So that would be a hundred times a hundred,
23 we'll be happy to review it, so if - 1 assume that -- Do
24 1/10,000 of an ounce?
24 you have that with you today.
25 A Something of that order.
25 MR. CARNEY: Why don't you ask another
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 29 - 32
LEXOLDMON006750
Page 33
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1 question.
1 A There are 1,000 people had various symptoms in
2 MR. McCREA: Do you have it with you today? 2 Yusho. 1 do not have the figures for what those 1,000
3 MR. CARNEY: 1 don't have that information
3 people, what the amount of dibenzofurans, the total amount
4 with me. 1 don't carry all the information with me.
4 that those 1,000 people took. That may be someplace. Ido
5 MR. McCREA: But you are volunteering it;
5 not have that.
6 correct? And you will provide it? Thank you.
6 Q (By Mr. McCrea) Well, Doctor, isn't it a fact
7 Q (By Mr. McCrea) Dr. Kelly, there's no dispute
7 that based on the testimony you've give us here this
8 in medical science that the Japanese people were poisoned 8 morning, based on the article that you have read, based on
9 and their offspring suffered birth defects after the women
9 your calculations, that one once of furans is sufficient to
10 consumed one ten-thousandth of an ounce of furans. Is that 10 poison 10,000 people? Isn't that a fact?
11 a fair statement?
11 A No. 1 think, Mr. McCrea, that may very well
12 A 1 think it is because the lethal dose, the
12 be a fact, but 1 would certainly have to have a more
13 lethal dose 50 for furans is in the neighborhood of 1/1,000
13 elaborate set of calculations and have my calculations gone
14 of a milligram. Now, that is pretty small. Now, that's, 1
14 over by a mathematician. So 1 cannot answer that question.
15 have that figured for dioxin, chlorinated dioxin, and furan
15 It is very easy to drop a couple of zeros when you're
16 is somewhat less toxic. 1 don't have the exact figure, but
16 talking about translating from ounces to milligrams to
17 1/10,000 of a milligram per kilo is the lethal dose for
17 parts per million, so that 1 can not be certain of my
18 rats, and if you compare that to the PCB dose is 2,000 to
18 calculations.
19 4,000 milligrams or something like 40 -- well, it's
19 Q Is it probable -- Do you have an opinion based
20 something over -- you take the dose of 2,000 milligrams per 20 upon medical probability as to whether or not one once of
21 kilo and the furan is 0001 milligram. This is ten hundred,
21 furans is sufficient to poison 10,000 people?
22 thousand. That's 1/2,000 roughly. It's less than -- It's
22 A 1 can't be sure. 1 do not have that opinion
23 more than that. 1/20,000 of the lethal dose of PCBs.
23 at present, no.
24 Q Okay.
24 Q Your calculations would indicate that is true?
25 A So we're dealing with two compounds you're
25 A Yes, but 1 mean, I'm doing a hurry-up set of
Page 34
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1 talking about. One has a relatively low toxicity. The
1 calculations and 1 could very easily have misplaced some of
2 other has one of the most extreme toxicities of any
2 the figures. 1 accept the fact that this is an extremely
3 compound since the beginning of chemistry.
3 toxic compound, but...
4 Q One ounce of furans would be enough to poison
4
MR. CARNEY: By it, would you --
5 10,000 people?
5 A It, dibenzofurans. It is an extremely toxic
6 A Yes, 1 think so.
6 compound, but to make that jump from there to one ounce of
7 Q And cause birth defects in their children?
7 the material poisoning 10,000 people, 1 think I'd have to
8 A It could be. 1 do not know what the toxicity
8 be more sure of my calculations and I'd have to know the
9 of the material is as far as humans are concerned. If
9 time these people took this ounce, what part of the ounce
10 we're talking about rats, that's one thing.
10 or else divide among 10,000 people a tenth of an ounce,
11 Q No, I'm talking about Japan. Let's get this
11 10,000 of an ounce in each person over what period of time.
12 clear because you may not be at trial. One once of furans
12 1 would have to do quite a lot more calculations where 1
13 based upon the data that you have given us today in this
13 can't at the present time.
14 deposition would be sufficient to poison 10,000 people and 14
Q (By Mr. McCrea) How many milligrams are there
15 cause birth defects in their children based upon the data
15 in a gram?
16 from Japan which you have given us?
16 A 1,000.
17 A If 1 have -- If 1 have translated these
17 Q How many grams are there in an ounce?
18 figures correctly, that is correct.
18 A 30.
19 MR. CARNEY: I'm going to object to that.
19 Q How many milligrams are there in an ounce
20 You're saying -- are you saying -- 1 think you're
20 then, 30,000?
21 mischaracterizing Yusho, that those, all those mothers have 21
A Yes.
22 birth defects in their children. 1 don't think that's the,
22 Q Thank you. Again, Doctor, you have known that
23 what the literature says and that's kind of a trick
23 furans are extremely toxic for what period of time?
24 question that you've asked, but 1 don't think there's any
24
MR. CARNEY: Now we're getting very
25 support in the literature for that.
25 repetitive. I'm going to object to the repetitive nature
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 33 - 36
LEXOLDMONOQ6751
Page 37
Page 39
1 of these questions, and also we're talking about furans
1 Which depositions did the subject of furans get raised?
2 and --
2 A 1 don't recall, and 1 might add to some--
3
MR. McCREA: Presumably the same furans that
3 Q Just a second. Would you restrict yourself to
4 were found in your PCBs.
4 the question?
5 MR. CARNEY: Well, you're trying -
5 A Okay. Can 1 --
6 MR. McCREA: Just a second, please. By
6 MR. CARNEY: 1 think you have to allow him to
7 Monsanto when they tested in the early '70s.
7 clarify.
8 MR. CARNEY: In under ten parts per million.
8 A Can 1 clarify one of my previous answers or
9 That would be a drop in the, a drop of it in a swimming
9 not?
10 pool. You're talking about an infinitesimal amount and
10 Q (By Mr. McCrea) Yes, sir.
11 you're trying to act like-
11 A You are using the word chlorinated
12 MR. McCREA: How much is 1/10,000 of an ounce? 12 dibenzofurans as a basket term. There are probably 70
13
MR. CARNEY: It's a lot more than a couple of
13 different types of chlorinated dibenzofurans that exist and
14 parts per million if that's --
14 the toxicity varies greatly with how to make chlorine
15 MR. McCREA: It's ten parts per million?
15 atoms, where these chlorine atoms are arranged, and to the
16
MR. CARNEY: That's the maximum he said it
16 best of my knowledge, that information concerning Yusho and
17 was. Ten parts per million was the maximum. He said it
17 furans in either Monsanto or Japanese PCBs has, 1 don't
18 was under ten parts per million. We're talking about one
18 have that information as far as my knowledge is concerned.
19 or two or three parts per million, Mr. McCrea, and we've
19 So that if you make a blanket statement of toxicity
20 tested and you've just heard the testimony that the very,
20 of a dibenzofuran, chlorinated dibenzofuran, 1 think you
21 very infinitesimal amount of furans in the PCBs that
21 would have to limit yourself to is it 3-4-7-8 or any of the
22 Monsanto made did not cause any illnesses and was very, was; 22 other various configurations for the chlorine, of atoms
23 not very toxic at all. So you're confusing furans, or 1
23 hooked on to the molecule.
24 think you're attempting to try to confuse the jury with
24 Q Which of the molecules of furan are most
25 furans which are toxic with PCBs which aren't.
25 toxic?
Page 38
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1
MR. McCREA: You would acknowledge that furans 1
A 1 think 2-3-7-8.
2 are enormously toxic, Mr. Carney?
2 Q Has Monsanto done toxicity testing on the
3 MR. CARNEY: 1 think that's been the
3 various molecules of furans to determine their relative
4 testimony. 1 think that --
4 toxicity?
5 MR. McCREA: Would that be stipulated by
5 A They did not until 1974. 1 do not know what's
6 Monsanto?
6 been done afterwards.
7 MR. CARNEY: I'm not stipulating to anything.
7 MR. McCREA: Okay. Can we take a break now?
8 1 think it's not up to us. The witness here is a
8 Thank you, Dr. Kelly.
9 knowledgeable person and he's testifying and that's what he 9
(Thereupon, a short recess was taken. The reporter
10 said, and I'll stipulate that that's what he's testified
10 marked Plaintiff's Deposition Exhibit One, for
11 to.
11 identification.)
12 Q (By Mr. McCrea) Thank you. Doctor --
12 Q (By Mr. McCrea) Dr. Kelly, the court reporter
13 A 1 will say something, too.
13 has marked an exhibit as Plaintiff's Exhibit One dated
14 Q Dr. Kelly, just a second. If 1 may ask a
14 6-1-90, and 1 will hand you the exhibit and ask you, sir,
15 question, please.
15 if you would first look at the exhibit and see if you can
16 A Yes, you sure may.
16 identify that as having been read by you before today's
17 Q Dr. Kelly, you have been asked, have you not,
17 date?
18 to testify in cases involving furans on behalf of Monsanto?
18
MR. CARNEY: Let me object to the question.
19 A Not involving furans, no, sir.
19 Mr. McCrea, you just tore out a page out of a booklet.
20 Q Is it your testimony today that you have not
20 MR. McCREA: Mr. Carney, if 1 may.
21 testified in any cases involving furan toxicity?
21 MR. CARNEY: Can you - It seems to me it's
22 A Well, that's -- 1 have been asked to testify
22 unfair to tear out a page in a one inch booklet, and 1
23 towards the toxicity of PCBs, and the question of furans
23 don't know that I've ever seen the booklet before. Have 1?
24 came up during the course of those depositions, yes, sir.
24
MR. McCREA: Well, what this booklet has in it
25 Q Okay. And which deposition -- Thank you.
25 is a series of 27 documents. The only page referring to
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 37 - 40
LEXOLDMONOQ6752
Page 41 1 this particular document has been taken from the booklet. 2 1 do not have the remainder of the document. If 1 did, 1 3 would be happy to provide it to Dr. Kelly. 4 MR. CARNEY: Let me just - Could 1 take a 5 look at what the document you gave-- 6 MR. McCREA: Certainly. It's page 13, and at 7 the upper right is the information as to the subject 8 matter, and if he can't identify it, that's fine. 9 MR. CARNEY: All 1 want to point out for the 10 record is that you've handed him one page, a page 13 that 11 you just tore out of this notebook and it doesn't have the 12 -- 1 don't know how many pages were in the document. We 13 know there are at least 12 pages before this page. It 14 starts in the middle of a subject that you don't even have 15 the entire subject that would be on the prior page. Then 16 it breaks off in the middle of a sentence at the last page, 17 so we know there must have been at least one other page. 18 At the bottom it talks about page 291. 1 don't know if 19 this is out of a something that has 291 pages or not, but 1 20 just think it's -- 1 would object to handing out one page 21 of a document that isn't titled or there's no indication of 22 who the author is and there's no indication of what pages 23 came before and after it. So that's my objection for the 24 record. 25 MR. McCREA: And 1 think that's a valid
Page 43 1 Workers," and 1 would like to have seen what these same 2 people found in the capacitor workers, but 1 don't have 3 that. 1 can see where you didn't. 4 Q 1 move to strike the comment of Dr. Kelly. He 5 knows that that's an improper statement. We'll be 6 discussing the capacitor workers later on. 7 A All right. 8 Q All right. Dr. Alexander, Blair Smith and 9 others; all right, sir? 10 A Uh-huh. 11 Q Now, Dr. Kelly, if you would please restrict 12 your answers to my questions and not volunteer information, 13 we'll be out of here much earlier and the jury will get -- 14 A Fine. 15 Q - through this much quicker. 16 A I'm ready for your question. 17 Q All right. Would you read the first two 18 paragraphs on this document and the footnote? 19 MR. CARNEY: To himself? 20 Q (By Mr. McCrea) To himself, and I'll ask you 21 if that data in those paragraphs is consistent with your 22 knowledge on the subject discussed therein. 23 MR. CARNEY: Well, I'm going to object to this 24 format. Again 1 think you asked him originally if he's 25 ever, if he can identify that document and if he can't say
Page 42
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1 objection, but I'm just asking the witness if he's seen
1 that he ever saw that document, you weren't going to go any
2 this data. If he hasn't, he hasn't. If he has, he has.
2 further. Again 1 object as showing one page of a
3
MR. CARNEY: Are you asking if he's seen that
3 multi-page document that is totally incomplete and very
4 particular document?
4 difficult to identify. 1 think the initial question ought
5 MR. McCREA: Correct.
5 to be has he ever seen that particular document before and
6 MR. CARNEY: Okay.
6 if he -- 1 don't think you can cross examine him on
7 MR. McCREA: And 1 think your objection is
7 something or ask him to read something that can't be
8 totally valid, and if he can't identify it, I'm not going
8 identified.
9 to continue with the questioning.
9 Q (By Mr. McCrea) 1 think your objection is
10 A 1 may have seen it, but 1 certainly don't
10 well taken. Dr. Kelly, have you ever seen that page before
11 recognize it in this fashion. Could 1 see what -- Is this
11 to your knowledge?
12 booklet, this book of yours have anything to do with this? 12 A That particular page? 1 do not recall having
13 Q (By Mr. McCrea) No, sir, it does not.
13 seen it.
14 A 1 mean, let me get this clear. This is
14 Q Thank you. See how easy it is? Dr. Kelly,
15 something that was taken out of some publication or
15 have you ever read any information which indicates that the
16 conceivably a publication and put in this booklet of yours
16 toxicity threshold dose for furans which caused the health
17 or this --
17 problems in the Japanese and the birth defects in children
18 Q That's correct, that's correct. This is one
18 was .6 milligrams?
19 page from a document consisting of many more pages.
19
MR. CARNEY: I'm going to object. You're
20 Unfortunately, Dr. Kelly, 1 do not have the remainder of
20 talking about birth defects in children. 1 think that's
21 that document. If 1 did, believe me, 1 would bring it
21 inflammatory, and we're talking about furans. Again you're
22 because it would be much easier to identify. 1 just do not
22 trying to mix up furans with PCBs which is confusing and
23 have it now.
23 inflammatory.
24 A 1 would have some doubts about that because
24 Q (By Mr. McCrea) Doctor, did you not state
25 where it stops it says, "Clinical Studies of Capacitor
25 earlier in your testimony that the children born to the
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 41 - 44
LEXOLDMONOQ6753
Page 45
Page 47
1 mothers who ate the contaminated rice oil had birth defects
1 present time.
2 such as in their teeth, their skin and other problems? Did
2 Q Do you know Walter J. Rogan, National
3 you not state that?
3 Institute of Environmental Health Sciences, Research
4 A 1 didn't say the other problems. 1 do not
4 Triangle Park, North Carolina?
5 know if 1 used the word birth defects, and if 1 did, 1
5 A No, 1 don't.
6 think it ought to be clarified because birth defects means
6 Q So you haven't read his article?
7 a lot different to a lot of different people. So we are
7 A You didn't ask that. You said--
8 talking the Japanese children had pigmentation of their
8 Q Have you read an article?
9 skin. They had premature eruption of the teeth and they
9 A 1 don't know which is the article. You show
10 may have had chloracne. They had skin problems. 1 do not 10 me. I'll tell you whether 1 read it or not.
11 recall any other conditions which could be termed birth
11 Q Fair question. Have you read an article
12 defects.
12 published by Walter J. Rogan concerning "Congenital
13 Q Dr. Kelly, have you read medical literature
13 Poisoning by Polychlorinated Biphenyls and Their
14 which has discussed the health problems of the children
14 Contaminants in Taiwan"?
15 born to the mothers who ate the contaminated rice oil?
15 A 1 may have. If you show me the article, 1 can
16 A Yes, 1 have.
16 tell you if 1 read it. 1 do not recall whether 1 read it
17 Q And can you give us the titles of those
17 or not.
18 articles and the authors and the dates as best you recall?
18
Q Okay. We'll get to that later.
19 1 don't expect you to remember every single word.
19 A That's all right with me.
20 A Yes. 1 think one is a review by Dr. Kimbrough
20 Q Now, my question is, Doctor: How would you
21 in 1987 or'88. The other in the "Journal of Industrial
21 describe the Yusho health problems?
22 Medicine" in 1984. That authors, Dr. Kimbrough obviously 22
A 1 think it was a severe episode of accidental
23 is the United States national, and the authors of the
23 poisoning by eating contaminated industrial fluids.
24 others are Japanese nationals.
24 Q What was the toxicity threshold dose which
25 Q What did Dr. Kimbrough state about the health
25 caused this severe poisoning from the standpoint of furans?
Page 46
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1 problems of the children?
1 A Would you tell me what you mean by toxicity
2 A It was in one of the exhibits, and 1 would
2 threshold dose?
3 rather read it rather than trying to commit it from memory.
3 Q Does that not --
4 Q You do not recall?
4 A It's not a common term.
5 A Yes, 1 recall, but 1 want to be precise, Mr.
5 Q That would be the dose necessary to cause
6 McCrea.
6 health problems as 1 would understand it. Toxicity
7 Q Well, 1 think the document -- Just a second.
7 threshold dose. What minimum amount of furans would cause
8 1 think the document will speak for itself. The fact is
8 the health problems? That's how 1 understand it. Not the
9 you don't recall what was in the article?
9 maximum, but the minimum, the threshold.
10 A Yes, 1 can recall the gist of it, certainly, 1
10 MR. CARNEY: What do you mean by health
11 can recall.
11 problems? Are you talking about any particular type or-
12 Q What was the gist of it?
12 There are all kinds of health problems.
13 A The gist of it was we had 39 or so babies with
13
MR. McCREA: Well, the health problems which
14 pigmentation, some early eruption of the teeth, and after
14 are documented in the literature that were experienced by
15 examining or on reexamination, a large percentage of them 15 the Japanese when they ate the contaminated rice oil which
16 had cleared up.
16 had PCBs and furans. That's what I'm talking about. Is
17 Q Okay. Thank you. Now, what was the other
17 that clear?
18 article?
18 MR. CARNEY: Well, I'm not clear on it, but if
19 A Well, that was an article in the "American
19 the witness is, he can answer.
20 Journal of Industrial Medicine" by some Japanese author.
20
A I'm not too clear on it either because there
21 Q And what was the gist of that article, sir?
21 were various problems. Some --
22 A Well, he described the skin problems with the
22 Q (By Mr. McCrea) All right, Doctor.
23 children.
23 A May 1 finish?
24 Q Anything else?
24 Q The question is: What was the minimum -- What
25 A There may be more. 1 cannot recall it at the
25 was the toxicity threshold dose for furans which caused
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 45 - 48
LEXOLDMONOQ6754
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1 this variety of problems, if you know?
1 one, and I'm following up on that so that the doctor can
2 A Well, you would have a different dose for a
2 put this in terms that the jury will understand.
3 different problems. In other words, you would have a very
3 (By Mr. McCrea) Now, Doctor, if there are 50,000
4 minor problem which would have one threshold limit, as you 4 milligrams in an ounce or if there - Your calculation is
5 phrase it, and you would have another dose for a much more 5 that .6 milligrams goes into an ounce 50,000 times. Is
6 serious symptoms.
6 that correct?
7 Q Okay.
7 A That's correct.
8 A So 1 do not -- To answer your question, 1 do
8 Q So if .6 milligrams is the toxicity threshold
9 not know what was the dose, the minimum dose necessary to 9 dose to induce disease in the Yusho victims that means,
10 cause the most minor of the symptoms and what was the dose 10 does it not, that one ounce of furans would be sufficient
11 necessary to cause the most serious complication in these 11 to induce disease in 50,000 people?
12 people. It is certainly documented someplace. 1 do not
12
MR. CARNEY: Well, let me object.
13 have it at the present time.
13 A No.
14 Q Have you read articles published by the United
14
MR. CARNEY: Let me just make an objection.
15 States Environmental Protection Agency with respect to
15 You're asking him to assume something that he's already
16 Yusho poisoning?
16 indicated he can't assume. You're reading from an article
17 A Yes.
17 obviously. You won't show him what you're reading from
18 Q Have you read articles which indicate that the
18 and-
19 toxicity threshold dose for the induction of disease in the
19
MR. McCREA: He already read it.
20 Yusho incident was .6 milligrams offurans?
20 MR. CARNEY: Well, you haven't been able to
21 A 1 would have to see that to assure myself if
21 identify it as to where did it come from, who's the author,
22 that's what 1 read.
22 how many pages there are in it.
23 Q But you can't state that today?
23 MR. McCREA: It came from the U.S. EPA. The
24 A 1 cannot state that today.
24 title is Health Effects of PCB and PCDF Mixtures", Section
25
Q Would you calculate how many, how many times
25 IV, page 13. There's no secret.
Page 50
Page 52
1 .6 milligrams goes into an ounce?
1 MR. CARNEY: Well, there's a secret as to what
2 A Well, let's see. Again we're having the zeros
2 is on the pages before that and what are the pages, what's
3 problem. There are 30 milligrams in an ounce, 30 grams in
3 on the pages after that, who the author is, what the date
4 an ounce. That means there are 30 times 1,000 milligrams,
4 of the article is. You've ripped out one page of an
5 so that's 30,000 milligrams and 6/10 goes into that 50,000
5 article or a document that we can't identify, the witness
6 times.
6 can't, and now you're asking him to assume something in
7 Q If there is data that indicates the furan
7 this unidentified piece of paper. 1 think it's improper.
8 toxicity threshold dose which induced the disease in Yusho
8 1 object.
9 was .6 milligrams for furans, would that then indicate that
9 Q (By Mr. McCrea) All right. You may answer
10 one ounce of furans would be sufficient to induce the
10 the question.
11 disease in 50,000 people?
11 A Well, 1 said no because you have not included
12 MR. CARNEY: Well, I'm going to object to
12 the chlorinated terphenyls in this. You have not told me
13 that. It's a hypothetical question. You're asking him to
13 which type of chlorinated dibenzofurans there are. You
14 try to do some very complex mathematical equations and 1
14 haven't talked to me about where, what percentage of
15 think, you know, that's something you can calculate. To
15 chlorination these furans have, where these chlorine
16 have him do that in a matter of minutes here, 1 think it's
16 molecules are. The chlorine substitution in various places
17 a waste of time. If you want to make those calculations
17 can account for a toxicity range of a thousand parts, a
18 and do those calculations, 1 just don't think that's the
18 thousand to one.
19 proper place for it.
19 Q Now, of course all that information is
20 MR. McCREA: Tom, I'm just taking your lead 20 interesting to you as the former medical director of
21 because your asked, and 1 think appropriately so, that the
21 Monsanto; correct?
22 doctor express this in quarts and pints, and 1 think most
22 A Well, it's interesting.
23 of the people on the jury understand how many ounces there 23
Q Terphenyls, where the chlorine atoms attach to
24 are in a pint, how many ounces there are in a quart. So 1
24 the molecule, the different types of furan molecules.
25 just quite frankly think that your suggestion was a good
25 That's of interest to you; correct?
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 49 - 52
LEXOLDMONOQ6755
Page 53
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1 A It was interest to me when you were quoting
1 than furans?
2 dibenzofurans and you are not saying which one it is
2 A Yes.
3 because unless I would know which one it is and be able to
3
MR. CARNEY: Which type of furans are you
4 look up the toxicity of the individual isomer, I wouldn't
4 talking about? Again he said there were seven different
5 be able to answer your question.
5 types.
6 Q Have you done any work to determine that very
6 Q (By Mr. McCrea) Golly, this gets confusing,
7 information which you find of interest?
7 doesn't it? How many different types of dioxins are there,
8
MR. CARNEY: In answering your question just a
8 109?
9 few minutes ago?
9 A 125, I think.
10 MR. McCREA: No, before he came to this
10 Q 125. Now, you're not specifyingwhich
11 deposition.
11 congener of dioxin in giving us the answer that dioxins are
12 MR. CARNEY: Well, you asked a specific
12 more toxic than furans. You're stating that dioxins are
13 question and he was trying to answer your question,
13 more toxic than furans; correct?
14 said he needed to know some additional facts in order to 14 A It's a generalrule that dioxinsare more
15 answer your question.
15 toxic than furans, but when you asked me about, talking
16
MR. McCREA: Yeah. I'm just wondering as the
16 about figures as far as the toxicity of a furan of the
17 former medical director and as the individual testifying on
17 chlorinated furans, I'm afraid you'll have to specify the
18 your behalf if this information which he has said he would
18 ones because I cannot answer a blanket question as far as
19 like to know before he can answer the question has been
19 individual ones.
20 studied by him before coming to this deposition and if it
20 If you compare dioxins with dibenzofurans, that's
21 hasn't, it hasn't. If it has, it has.
21 fine, but if you're asking me a question about the toxicity
22 A When you state -- Was that a question? Have
22 of a general class of chlorinated dibenzofurans, it will be
23 you asked me a question?
23 impossible for me to give you the answer unless you give me
24 MR. McCREA: Not really, not really.
24 which one you're talking about.
25 A I'm waiting for the question.
25 Q There are certain dioxin molecules that are
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1 Q (By Mr. McCrea) All right. So Doctor, furans
1 more toxic than other dioxin molecules?
2 are toxic; correct?
2 A That is correct.
3 A Let's be precise. Chlorinated furans are
3 Q There are certain furan molecules that are
4 toxic.
4 more toxic than other furan molecules?
5 Q Are enormously toxic?
5 A That's correct.
6 A Depends again on the substitution, where the
6 Q There are certain polychlorinated biphenyls
7 chlorines are added to the benzene molecule, atom molecule. 7 that are more toxic than other PCB molecules?
8 Q They were toxic in Japan?
8 A Yes. Now, remember you're bringing in PCBs in
9 A The ones that were there, yes. Now, there are
9 the same ballpark as dioxins and dibenzofurans, so...
10 other chlorinated dibenzofurans that can be much less toxic 10
Q PC furans are more toxic than PCBs as a
11 by a factor of a thousand.
11 category?
12 Q What studies did you read that established
12 A Yes, much more.
13 that?
13 Q Much more?
14 A I can't quote them to you right now, but
14 A Yes.
15 they're certainly established in the literature.
15 Q How much more as a category?
16 Q Now, are dioxins more toxic than furans?
16 A 10,000 to pick a figure.
17 A Yes, somewhat more.
17 Q Okay. And dioxins are more toxic than furans
18 Q By a magnitude of what?
18 as a category?
19 A I don't think it's ten times as much. They're
19 A As a what?
20 somewhat more toxic, but not all that much more toxic.
20 Q As a category.
21 Q Approximately what, three to ten times more
21 A Yes.
22 toxic?
22 Q How much more toxic?
23 A I can't answer that because those absolute
23 A I can't answer that. I'd have to assume, but
24 figures have really not been established particularly.
24 it's not 10,000 times or anything like that.
25 Q It is your opinion that dioxins are more toxic
25 Q How many more?
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 53 - 56
LEXOLDMONOQ6756
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1 A I'd have to assume. If you want an
1 the furans are destroyed.
2 assumption, I'll give you an assumption.
2 Q Okay.
3 Q Fair enough.
3 A All fires are not alike obviously. If we're
4 A Ten to a hundred.
4 talking about laboratory combustion, we've got one thing.
5 Q Thank you. Has this relative toxicity ever
5 If we're talking about fire in a building, we've got
6 been expressed in writing by Monsanto?
6 something else.
7 A 1 haven't seen it if it has.
7 Q Why is that?
8 Q Have you had conversations with Monsanto
8 A Because everything changes. There are various
9 personnel in which you informed them of the relative
9 temperatures at various areas of the fire.
10 toxicity of furans to PCBs and dioxins to furans?
10 Q I'm sorry. 1 didn't understand that?
11 MR. CARNEY: You talking about prior to his
11 A Well, there are various temperatures in
12 retirement?
12 various areas of the fire.
13 MR. McCREA: No, up to this date.
13 Q So in a laboratory it would be - What would
14 A I've had times when they informed me about it.
14 the difference be between a laboratory fire and a building
15 Q (By Mr. McCrea) So they know that?
15 fire?
16 A Some people know it, yes.
16 A You can control what temperature range that
17 Q In Monsanto?
17 you want in a laboratory. You cannot control it in a
18 A In Monsanto, yes.
18 building.
19 Q What are the by-products of the combustion of
19 Q Okay. Are there any other by-products from
20 PCBs?
20 the combustion of PCBs other than furans at this window
21 A Chlorine, soot. It depends again. Now, what
21 range of 600 to 900 degrees Fahrenheit?
22 temperature are we talking about.
22 A Oh, yes. As 1 said, there's carbon dioxide.
23 Q Let's have three categories of temperature.
23 There may very well be carbon monoxide. There's carbon.
24 Let's have 240 degrees Fahrenheit, 800 degrees Fahrenheit 24 There's chlorine that's knocked off. Whether thereare
25 and 2,000 degrees Fahrenheit?
25 hydrochloric fumes or not, 1 don't know. I'm not sure.
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1 A Okay. At 2,000 degrees it's all, the material
1 Q What about biphenyls?
2 is burned up.
2 A They may be. 1 don't know.
3 Q It turns into carbon dioxide?
3 Q What about quaterphenyls?
4 A Carbon dioxide, carbon, soot, carbon monoxide.
4 A 1 don't know about that.
5 Q Carbon monoxide?
5 Q Okay. How long have you known that furans are
6 A Could be.
6 produced in the window range of 600 to 900 degrees
7 Q That wouldn't be good for you, would it?
7 Fahrenheit by the combustion of PCBs?
8 A In a fire, 1 don't think anything is good for
8 A Six to eight years, 1 suppose.
9 you at 2,000 degrees.
9 Q How did you learn that?
10 Q All right.
10 A 1 was told by chemists at Monsanto.
11 A There is a window at which dibenzofurans are
11 Q Who was the chemist who told you?
12 formed, and that window is something around six or 700
12 A It may have been Dr. Robert Kaley, K-a-l-e-y.
13 degrees Fahrenheit. 200 degrees higher than that it is,
13 Q What did he tell you?
14 the furans are destroyed. So there's a two or 300 degree
14
A Told me just that. He told me that there is a
15 window at which furans are formed. Getting down to the
15 window that furans are formed, and after you exceed that
16 lower ones, you said a lower temperature?
16 window, a higher temperature, the furans are destroyed.
17 Q 240 degrees Fahrenheit is what 1 picked.
17 Q So you learned that information about 1982 to
18 A Huh?
18 '84?
19 Q Yes, 200 -- All right. Furans are formed from
19 A Well, 1 can't be that precise. I've seen Dr.
20 the combustion of PCBs at 600 to 700 degrees Fahrenheit? 20 Kaley off and on the last ten years, so 1 don't know what
21 A Well, I'm not sure of the exact - It's around
21 he told me.
22 that area, and it might be a larger window. It might be
22 Q Did he prepare a paper on that?
23 700 to 900, 600 to 850. 1 can't tell you, but there's a
23 A 1 don't know.
24 certain time in the combustion that furans are formed and a 24
Q Where does he work now?
25 certain time in the combustion that it gets hot enough that
25
A At Monsanto, St. Louis, Missouri.
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 57 - 60
LEXOLDMONOQ6757
Page 61 1 Q Are you pretty sure it was him? 2 A No, I'm not sure it was him, but it might very 3 well have been him. 4 Q Did he show you a document or did he just 5 verbally communicate? 6 A It was verbally communicated. 7 Q And what did he tell you? 8 A 1 don't have the precise words, but he told me 9 that -- 1 had asked him about combustion products of the 10 PCBs, and he told me. 11 Q Did Monsanto communicate this information to 12 people to whom they had sold PCBs? 13 MR. CARNEY: I'm going to object here. 1 14 think we've established that Dr. Kelly learned this after, 15 long after he's retired from Monsanto, and 1 don't think 16 there's any foundation that he would know that. 17 Q (By Mr. McCrea) There may not be. Do you 18 know if Monsanto communicated the information which you 19 think was given to you by Dr. Robert Kaley that furans are 20 produced by the combustion of PCBs at the window of 600 to 21 900 degrees Fahrenheit, did they give that information to 22 the customers? 23 A 1 don't know. 24 Q Would you have given it to the customers if 25 you'd have been with Monsanto?
Page 63 1 Q Well, that was not something that was tested 2 in a laboratory? 3 A 1 don't know. 4 Q At Monsanto? 5 A 1 don't know, but you asked me how long he 6 worked on it. 7 Q Did he tell you what the source of this 8 information was? 9 A No, he didn't. 10 Q Do you know if there was an experiment done by 11 Monsanto? 12 A 1 don't know. 13 Q So he would be the best one to ask? 14 A You mean ask about-- 15 Q Dr. Kaley? 16 A 1 don't know who else. There may be other 17 people more knowledgeable than he is. You asked me who 18 told me, and 1 said to the best of my recollection it was 19 Dr. Kaley. 20 Q Now, Dr. Kelly, do you know of any other 21 by-products from the burning of PCBs other than furans 22 which are toxic? 23 A Well, chlorine is toxic. 24 Q All right. Any others? 25 A There may be others. 1 mean, 1 don't know at
Page 62
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1 A 1 think that would depend on the customer.
1 the present time. Hydrochloric acid, 1 believe, is
2 That would depend on the knowledge the customer had. That 2 liberated.
3 would depend on the amount of material that was in the
3 Q Have you ever done any studies on the content
4 literature. That would depend upon whether any fires had
4 of by-products in failed capacitors?
5 occurred because --
5 A What do you mean by a study?
6 Q What if fires might occur?
6 Q Laboratory, analytical work measuring the
7 A Well, fires really hadn't occurred until
7 chemicals formed as a result of the failure of the
8 sometime around the mid '70s.
8 capacitor?
9 Q Would there be any reason not to give that to
9 A No, sir, 1 have not.
10 your customers?
10 Q Do you know of any studies at Monsanto?
11 A No, that 1 can think of, unless 1 knew the
11 A 1 do not know.
12 customers knew it themselves.
12 Q Do you know of any studies at Monsanto which
13 Q Do you know of any customers that have
13 have tested the content of transformer fluid in a failed
14 conducted tests determining the production of furans from
14 PCB transformer?
15 the combustion of PCBs?
15 A 1 do not know of any studies. There may be
16 A No, but there have been government
16 some 1 do not know of.
17 publications relative to that.
17 Q When Dr. Kaley had this conversation with you
18 Q Okay. How long did Dr. Robert Kaley work on
18 as you recall, did you communicate that information that he
19 this experiment or scientific test where he determined that
19 gave you to anyone?
20 furans were the by-product of the burning of PCBs at 600
20
A 1 don't know if 1 did or not. You mean did 1
21 and 900 degrees Fahrenheit or whatever?
21 communicate this with anybody at Monsanto? No. 1 think he
22 A 1 never said he worked on it. 1 never said he
22 gave it to me for my own information or 1 asked him for it
23 did any experiments. 1 do not know the basis for his
23 for my own information. 1 don't know how the topic arose.
24 knowledge. 1 never said he worked on it. 1 never said he 24 Q Did you use it in any cases in which you were
25 did experiments.
25 testifying as a fact, as an expert fact witness on behalf
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 61 - 64
LEXOLDMONOQ6758
Page 65
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1 of Monsanto?
1 Q Dr. Kelly, if you learned that a toxicological
2 A 1 don't think so. 1 did not, have not
2 study paid for by Monsanto was false and fraudulent and you
3 testified in any cases where there were fires.
3 were the only person who knew that the toxicological study
4 Q Did you have PCB fires in the plant at Sauget?
4 paid for by Monsanto was false and fraudulent, would you
5 A If they had it, they certainly were not major
5 communicate that information to the United States
6 fires.
6 Government and former customers who've purchased your PCBs?
7 Q Did you have PCB fires in the plant at
7 MR. CARNEY: Let me object to the question. 1
8 Anniston?
8 think it's fraudulent if you don't give a time frame.
9 A 1 never heard of any.
9 You're making this witness speculate about what he might do
10 Q Did you know of any customers who had PCB
10 under some circumstances where there's no foundation.
11 fires within their plants?
11 A Well, in the first place 1 never learned that.
12 A No, 1 did not.
12 Q (By Mr. McCrea) That wasn't the question.
13 Q Do you know of any customers who had fires
13 A Wasn't it?
14 resulting from the heat transfer fluid being underpressure 14 Q The question was - It didn't have anything to
15 and heated and then burning within a plant?
15 do with which you learned. Do you now know there was false
16 A You mean the heat transfer--
16 and fraudulent-
17 Q Therminol.
17 A No.
18 A -- fluid being a PCB.
18 Q I'm just asking you the question.
19 Q Therminol.
19 A Would you repeat the question?
20 A 1 do not know of any. There may have. 1
20 MR. McCREA: Could the court reporter read the
21 don't know of any.
21 question back, please?
22 Q Can you describe for us the manufacturing
22 (Thereupon, the reporter propounded the previous
23 process at Bloomington, Indiana in the Westinghouse
23 question.)
24 capacitor plant?
24 A Are you talking now?
25 A 1 can't at all. 1 have never been in
25 MR. CARNEY: Before you clarify it, let me
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1 Bloomington, in the Westinghouse plant at Bloomington, so 1 1 make a further objection to the question. 1 think you
2 cannot.
2 haven't given enough facts here or hypothetical facts to
3 Q Do you know of any Monsanto personnel who were 3 have anybody give a reasonable answer. If there was a --
4 in that plant?
4 You haven't said what in this fraudulent study was
5 A 1 do not know.
5 fraudulent, whether it would impact anything about the
6 Q And observed the plant operation?
6 study or would it make any difference in the study.
7 A 1 do not know of any.
7 It seems to me if there was some mistake in a study
8 Q Dr. Kelly, if you received information today
8 but it made no difference in the conclusion of the study,
9 at Monsanto that only Monsanto had and that information
9 that might be one thing. If it would impact the toxicity
10 indicated that PCBs caused a particular health problem and 10 of the substance that was being tested and would change the
11 nobody else in the world had that information, would you
11 substance, that might be another. 1 think you've got to
12 give it to the government?
12 give more facts than just there's some study and there's
13 A Yes, 1 would.
13 something fraudulent in a study without identifying more
14 Q Would you give it do the workers?
14 facts so that somebody could answer.
15 A Yes.
15 And also, 1 object that the question is compound.
16 Q Would you give it to your former customers who 16 You asked about would he give this information to the
17 bought PCBs?
17 government, would he give it to customers, and that would
18 A Yes.
18 make a difference as to which you're talking about.
19 Q Why would you do that?
19 Q (By Mr. McCrea) You may answer.
20 A Because if your assumption were true -- we're
20 A Well, would you clarify your last phrase in
21 assuming that this is a fact -- 1 would not want the
21 that when you brought in PCBs? Up to that whole question
22 condition to be repeated. 1 would want to be sure that the
22 you never mentioned PCBs until right at the end, and I'd
23 people were following the safe handling procedures that we 23 like to know are you referring to a toxicological study on
24 had outlined, and we'd want to correct it, correct their
24 PCBs and if that were false? Well, you --
25 method of handling the product.
25 Q Any study.
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 65 - 68
LEXOLDMONOQ6759
Page 69
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1 A Well, you mentioned PCBs in it.
1 or X thousand dollars from this insurance company, X
2 Q Well, let's restrict it to PCBs.
2 thousand dollars. The name of Brown versus Monsanto or
3 A All right. Now --
3 Jones versus Monsanto or Smith versus Monsanto would not be
4
MR. CARNEY: But you haven't -- Would you tell
4 on my tax return.
5 him whether the, in the hypothetical you're giving him
5 MR. McCREA: To save time, Counsel, can we
6 whether the mistake or the fraud had any impact on the
6 have a stipulation that you will provide us the names by
7 state of the knowledge about the toxicity? If it was
7 cause number, plaintiff, defendant, court, city in which
8 irrelevant, then why would you want to tell anybody? If it
8 doctor, in which the doctor has testified so that we don't
9 was material and changed the, materially the information
9 have to pursue this matter and take any more time in this
10 about the toxicity of the PCB, if you're using that in this
10 deposition?
11 instance, that would be another thing.
11 MR. CARNEY: Well, you know, all I'm saying is
12 Q (By Mr. McCrea) Okay. First of all, Dr.
12 1 don't have a list and-
13 Kelly, if the study was false and fraudulent and it had
13 MR. McCREA: Well, Monsanto surely does.
14 absolutely no impact on the toxicity of the chemical and
14
MR. CARNEY: And as far as 1 know Monsanto
15 its impact on the environment or humans, would you give
15 doesn't. I'll can them if they have a list, but Dr. Kelly
16 that information to the United States Government that it
16 said yesterday that he didn't have a list. He's given you
17 was false and fraudulent?
17 in search of his memory yesterday as to all the cases he
18 A Well, that is an impossible question for me to
18 can think of, so 1 don't know that 1 can add anything
19 answer. Here is a study that we are running that is false
19 because 1 don't have any independent knowledge of any cases
20 and fraudulent and has no impact on anything?
20 other than the ones he's mentioned. 1 didn't know most of
21 Q Right.
21 those until he mentioned them.
22 A How do we know it's false and fraudulent then?
22
MR. McCREA: Will you contact Monsanto and ask
23 Why are we running it? If we would be trying to get some
23 them for the names of the cases, cause number, court, city,
24 information, well, if we couldn't depend on the information
24 in which Dr. Kelly has testified and provide that to us so
25 and even if the information were wrong, it would have no
25 we can move on with this deposition?
Page 70
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1 impact on the toxicity. 1 can't answer a question like
1 MR. CARNEY: I'll contact Monsanto. 1 don't
2 that.
2 know that they have the information.
3 Q Now, if the study was false and fraudulent and
3 Q (By Mr. McCrea) Thank you. Dr. Kelly,
4 it did impact on the results, in other words, the falsity
4 yesterday you reviewed a number of animal studies in which
5 and the fraud indicated that it was not toxic and the true
5 the toxicological properties of PCBs and other chemicals
6 test results would show it was highly toxic, would you
6 were investigated. Is that correct?
7 communicate that information to the government and your 7 A That's correct.
8 former customers who bought the product?
8 MR. McCREA: Counsel, do you have those
9 MR. CARNEY: Again we're talking about
9 studies with you today?
10 something hypothetical that has no relationship to facts as
10
MR. CARNEY: I'm sorry. Which studies?
11 they occurred, but you can try to answer.
11 MR. McCREA: The exhibits.
12 A Well, certainly if it impacted on material
12 MR. CARNEY: Yeah, I've got all the exhibits
13 that we had given people before, we would certainly correct 13 that were used yesterday.
14 that.
14 Q (By Mr. McCrea) All right. Now, what 1 would
15 Q (By Mr. McCrea) Okay. Dr. Kelly, yesterday
15 like to ask you, Dr. Kelly, is this: Would you go through
16 you mentioned that you did not recall the names of the
16 those studies and identify all of the studies by exhibit
17 cases in which you had given testimony.
17 number only in which Monsanto paid for the entire study?
18 A All the cases, yes, sir.
18 Just a second.
19 Q 1 understand that. But you also mentioned
19 Then would you go through the studies and identify
20 that that information would be on your tax returns. Is
20 by exhibit number only those studies that Monsanto paid
21 that correct?
21 partially for, and then thirdly, the studies in which
22 A No, it wouldn't be.
22 Monsanto paid no money. And 1 see no reason to continue
23 Q Well, 1 thought that what your testimony.
23 with the video camera while you do that, but what 1 would
24 A 1 guess that was a bit of humor. 1 would
24 like to know, are all of those studies which were paid for
25 write down 1 received X thousand dollars from this lawyer
25 by Monsanto in whole or in part. Fair enough?
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 69 - 72
LEXOLDMON006760
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1 A 1 will tell you and save you a lot of time,
1 Q Would you identify any other articles in the
2 all the studies of Industrial Bio-Test that 1 saw were paid
2 stack that were not Industrial Bio-Test, Younger or
3 for wholly by Monsanto. All the studies at Younger
3 Scientific Associates?
4 Laboratory were paid for by Monsanto. All the studies of
4 A Yes, the von Oettingen which was in
5 Scientific Associates were paid for by Monsanto.
5 the Westinghouse file. 1 don't know who paid for that.
6 Q All right, sir.
6 Monsanto didn't pay it.
7 MR. CARNEY: 1 think the testimony was that
7 Q He was contracted with Westinghouse?
8 Monsanto requested all those studies, as 1 recall, at least
8 A 1 can't answer that.
9 of all those names, and that was the bulk of the studies.
9 Q All right. So you don't know?
10 Q (By Mr. McCrea) All right. Then maybe it
10 A 1 don't know.
11 would be easier to identify the studies that were not paid 11 Q All right, sir. Now, what 1 need, just
12 for by Monsanto. Now, do you know, for instance, if the
12 because it may be six months before we review this
13 study that was carried out on the workers who had chloracne 13 material, 1 need the exhibit numbers if we could.
14 at Anniston, Alabama by Dr. Jones in Atlanta was paid for
14
MR. CARNEY: You want to -- I'll have somebody
15 by Monsanto?
15 find that if you want to go on, and we'll just read it into
16 A Certainly whether it was paid for -- The
16 the record within the next five minutes.
17 treatment of the workers was paid for by either the
17 MR. McCREA: That's fine.
18 insurance, not by Monsanto. It was the insurance company 18
MR. CARNEY: So we can save some time.
19 that insured Swann or the insurance company that, of Swan 19
Q (By Mr. McCrea) That's agreeable. Doctor,
20 Chemical themselves. Writing a paper, the scientific paper 20 you made reference yesterday to the term systemic poison.
21 is never paid for by outside people. The man writes it
21 What do you mean?
22 himself, a scientific medical paper.
22 A Systemic poison is something that affects the
23 Q All right. That answers my question.
23 body metabolism. It is something apart from local action.
24 A Okay.
24 In other words, if you spill an acid on your arm, you will
25 Q So in that situation, as 1 understand it,
25 get an acid burn. That's a local reaction. If you take a
Page 74
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1 these workers who worked for Swann -- Am 1 correct?
1 poison internally, you will get a systemic action. If you
2 A Correct.
2 swallow the acid, you could get a local death of tissue.
3 Q Developed chloracne?
3 That would be local, on the stomach or the esophagus which
4 A Correct.
4 is the gullet.
5 Q They then would have been sent to the doctor
5 Q Are PCBs which get on your skin categorized as
6 at the expense of Swann?
6 something involving local action or something involving the
7 A Yes.
7 body metabolism?
8 Q The doctor then treated them medically. He's
8 A It depends on how much you get on, how often
9 paid for by Swann?
9 you get on, how long you leave it on. It does have a local
10 A That's correct.
10 action on the skin similar to mild paint remover or
11 Q And then ultimately he writes a paper which is
11 something like that. If you get enough of it on your skin
12 on his own time?
12 for a long enough period of time and repeat it enough
13 A That's correct.
13 times, you will get systemic action.
14 Q All right, sir. Now, in that particular
14 Q How do you get systemic action from a PCB
15 situation, was the examination that was carried out by the
15 which makes contact with the outer portion of your skin?
16 two doctors in Atlanta done at a point in time before
16 A It penetrates the skin. It's absorbed.
17 ownership by Monsanto or was the examination after
17 Q How does it penetrate the skin? How does it
18 ownership by Monsanto?
18 get through the skin barrier?
19 A It was before.
19 A It's oil soluble.
20 Q All right. Thank you. Now, are there -- What
20 Q If you had ten milligrams of PCB on your skin
21 1 would like to have at this point since you've saved us a
21 and you left it there for 24 hours, how much of that would
22 lot of time by stating that Industrial Bio-Test, Younger
22 go through your skin?
23 and Scientific Associates were paid for 100 percent by
23 A 1 don't know, but it wouldn't hurt you, not
24 Monsanto.
24 enough to go through to hurt you.
25 A That's correct.
25 Q Okay. You don't know the percentage that goes
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
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LEXOLDMONOQ6761
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1 through?
1 part of your body that is immune from the effects?
2 A No, 1 don't.
2 A Well, certainly. 1 mean, 1 think you have to
3
Q How long have you known that PCBs which come
3 tell me by, what you mean by immune. Do you mean does it
4 in contact with the skin can penetrate the skin and if in
4 affect your eyes and ears, brain, brain?
5 sufficient quantity, can work as a systemic poison?
5 Q Yeah, not subject to injury.
6 A Now, again we have to define systemic
6 A Well, a systemic toxic agent has --
7 poisoning because systemic poisoning means all different
7
MR. CARNEY: We're out of tape, so we'll have
8 things to various people. 1 know that 1 have known for 30
8 to come back to that.
9 years that if you get PCBs on your skin in a sufficient
9 MR. McCREA: We'll come back to that. I'm
10 amount and leave it on there you will get chloracne. 1
10 sorry.
11 have known that. Now, if by --
11 (Thereupon, a short recess was taken.)
12 Q And excuse me, Doctor. Is that the result of
12 Q (By Mr. McCrea) Dr. Kelly, 1 would like to
13 a systemic action?
13 discuss Exhibit K-6 with you.
14 A Yes, chloracne is. It's a skin manifestation
14 A Yes, sir.
15 of a systemic action.
15 Q Do you have a copy of that?
16 Q It's not a local contact dermatitis?
16 A 1 have a copy.
17 A No, it's --
17 Q All right, sir. And that also has on the
18 Q It means that the chloracne problem is caused
18 bottom ofthe page the identifying letters and numbers
19 by something happening within the body?
19 GBRN001998; correct?
20 A That's correct.
20 A Yes, sir.
21 Q Excuse me for interrupting you. If you would
21 Q Did you author this document?
22 continue.
22 A Yes, 1 dictated it.
23 A Where was 1?
23 Q And this is a copy from the files of Monsanto,
24 Q Well, we, you were talking about you have
24 a carbon copy?
25 known for 30 years that if PCBs got on the skin in
25 A Yes.
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1 sufficient quantity, it could cause chloracne, and that's
1 Q It does not have a signature?
2 when 1 asked you if chloracne was a systemic manifestation. 2
A Beg your pardon?
3 We have two minutes left.
3 Q It does not have a signature?
4 A Okay. And 1 know also, I've known for quite
4 A No, it's a carbon copy. 1 only sign the
5 some time that in rabbits, in rats, if you put a sufficient
5 letter that's going out.
6 amount on and repeated it, you can get systemic poisoning
6
Q Did you know Dr. J. Clarence Davies, III,
7 in other parts of the body. You could get liver problems.
7 Senior --
8 That 1 haven't known as long.
8 A No, 1 didn't. 1 did not.
9 Q How long have you known that?
9 Q This letter was written May 10, 1972; correct?
10 A Well, we did that repeated work at Bio-Test in
10 A Yes, sir.
11 1972.
11 Q Did Dr. Davies make inquiry of you before May
12 Q Okay.
12 10, 1972?
13 A In rabbits.
13 A 1 don't know if he did, but somebody must have
14 Q All right, sir. And that showed what?
14 wanted this information. 1 don't know why, the particular
15 A That showed in rabbits that you could get a
15 reason 1 sent it to Davies. Conceivably he talked to me or
16 sufficient amount through. That's not human skin, though.
16 somebody talked to me and said, "Send this to Davies," or 1
17 Q To do what?
17 may have decided on my own and Davies may have had some
18 A To cause liver problems.
18 contact with us. 1 don't know.
19 Q What kind of liver problems?
19 Q Did you have any follow-up communication with
20 A A swelling of the liver and in sufficient
20 Dr. Davies other than the May 10, '72 letter?
21 doses, eventual death ofthe animal.
21 A Not that 1 can recollect.
22 Q One minute. Anything else that you'd like to
22 Q At the top it says, "cc: Dr. Richard Osland."
23 add to the discussion of systemic poisons?
23 Who is that gentlemen?
24 A No, no.
24 A The plant physician at East St. Louis.
25 Q When you have a systemic poison, is there any 25 Q East St. Louis is the same at Sauget?
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
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LEXOLDMONOQ6762
Page 81 1 A Yes. 1 used East St. Louis because very few 2 people know where Sauget is. We had always called it East 3 St. Louis, but Sauget is the technical geographical name. 4 Q In the first paragraph you refer to it as 5 Sauget or Sauget, Illinois plant? 6 A That's correct. 7 Q And whenever you refer to East St. Louis in 8 your testimony, that would be the same as Sauget? 9 A That is correct. 10 Q One and the same? 11 A One and the same. 12 Q Who were the people on your medical staff who 13 examined the hourly and salaried workers? 14 A Myself and the technician 1 took along to draw 15 the blood. 16 Q Just two of you? 17 A Yes. 18 Q Can you give me the technician's name? 19 A Oh, no, 1 can't. 18 years ago? 1 don't 20 remember. 21 Q Can you describe for me the protocol which you 22 use for the examinations? 23 A Yes. 1 call these 27 people in one at a time 24 over a period of -- 1 don't know how many different days 1 25 was there, and sat them down in the examining room and
Page 83 1 write it down here. 2 Q Where are the forms which you used when you 3 conducted these examinations in 1972? 4 A There are the forms we used for the people in 5 the Sauget plant, and they were placed in the Sauget plant 6 file at the end of the examination. 7 Q Where 8 A 1 mean, after 1 received all the bloodwork 9 back. 10 Q Where are they today? 11 A 1 haven't the slightest idea. 12 Q When was the last time you saw the forms in 13 the files relating to these examinations? 14 A 1 don't know if 1 saw them in the files. 1 15 sent them back to East St. Louis after 1 received the 16 laboratory data and the PCB analysis. 1 wrote that on 17 there and sent it back, so it must have been the last time 18 1 saw the forms was sometime in May of'72 or April. It 19 all depends on how fast -- Well, 1 had them, yes. 1 mean, 20 it must have been sometime in May of '72. 21 Q In preparing for this deposition, did you ask 22 Monsanto if they still had those forms on file? 23 A No, 1 did not. 24 Q How many of the 27 were salaried workers? 25 A 1 don't know. 1 don't know for certain, but 1
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1 talked to them, got a medical history from them, got an
1 would probably say no more than three or four.
2 industrial history, industrial history being what they did,
2 Q Did 27 -- Were 27 people the total number of
3 what exposures they had.
3 people involved in the manufacture of PCBs?
4 Then 1 ran through the usual systemic list of
4 A At the Sauget plant, yes. 1 believe 1 got all
5 symptoms, cardiovascular system, the pulmonary symptom, the
5 of them. 1 mean, 1 can't say that there may not have been,
6 neurological system, asked them whether they had been
6 1 missed one or two, but 1 thought 1 got all the people
7 hospitalized, whether they had any recent or not so recent
7 that were working at that time.
8 visits to the doctor, whether they had lost any time.
8 Q 16 had no detectable PCBs; correct?
9 Then 1 proceeded to examine them. 1 carried out a
9 A That's correct.
10 complete examination. The usual clinical examination
10 Q And two -- Let's see -- Six had levels of
11 starts with observing a person when he walks in. Then you
11 200 parts per billion to 500 parts per billion; correct?
12 have him take off his clothes to the waist. You look at
12 A That's correct.
13 his eyes, ears, nose, throat, ears. You look at his skin,
13 Q So you had six people in the range of 200 to
14 especially the face and ears and neck because that's where
14 500 parts per billion?
15 chloracne starts.
15 A That's correct.
16 You examine the heart and the lungs. You have them
16 Q What was the background level at that point in
17 lie down on a table and feel his abdomen to see if there
17 time in the United States?
18 are any enlargement of any of the organs or any tumors or
18 A 1 don't know. 1 don't know if it was
19 any masses. Then you, along the way you've checked his
19 established.
20 blood pressure someplace, listened to his heart, listened
20 Q Did you consider 200 to 500 parts per billion
21 to his lungs.
21 as high?
22 Then you do a neurological examination on him and
22 A No.
23 run a battery of laboratory tests. 1 don't see I've
23 Q Do you consider it as high today?
24 written down anything about the EKG or chest x-ray. 1
24 A Yes. You recognize that 1 had said in my
25 thought 1 did them. 1 may very well have, but 1 didn't
25 testimony yesterday that laboratory sensitivities have
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
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LEXOLDMONOQ6763
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1 changed a great deal from 1972 for the next ten years.
1 Q (By Mr. McCrea) All right. Putting that
2 They were much more precise and much more confident of
2 aside, based on your experience, your reading about PCBs,
3 their results.
3 your knowledge of PCBs, can you tell the jury how, what
4 Q But that wouldn't change the information as to
4 quantity of PCBs you would expect to find in the individual
5 200 to 500 parts per billion being high or low. It would
5 who had 500 parts per billion in his blood, what quantity
6 simply affect the accuracy of the numbers?
6 you would expect to find in his fat?
7 A Well, if the numbers weren't accurate, it
7 A 1 wouldn't be able to tell because it depends
8 would sure change whether it was high or low, 1 mean --
8 whether he had a recent exposure to PCB that gave him in
9 Q But -
9 his blood and had not gone into his fat.
10 A I'm not as confident in the numbers today as 1
10 Q Okay. Now, obviously you had some people here
11 was in 1972. We were doing the best we could at that time, 11 who had PCB exposure.
12 but since then we have found out that we are much more 12 A Yes, 27.
13 precise, much more sensitive and we're much more confident 13
Q Well, by being PCB exposure by indicating the
14 about the results, but it was the best we had in 1972 and 1
14 levels in their blood?
15 found out that 16 didn't have any and two of them had four 15
A Well, they worked around PCBs. They were
16 parts -- 400 parts per billion and one had 500 parts per
16 exposed to them when they were working.
17 billion.
17 Q Did it concern you as the director of medicine
18 Q Six people between two and 500 parts per
18 at Monsanto that PCBs were contaminating these individuals
19 billion?
19 at this level?
20 A That is right.
20 A 1 don't think 1 would have used the word
21 Q But you had no idea as to whether or not that
21 contaminated the people. 1 was not concerned. 1 was
22 was a high number, the 200 to 500 parts per billion?
22 concerned, too, because 1 checked over the individuals.
23 A No, sir, 1 can't say that. 1 may have --
23 That's the reason 1 examined them, and 1 examined them and
24 There may have been some background that 1 knew about. 1 24 found no clinical evidence of any illness, no evidence of
25 don't know. 1 don't know that.
25 any PC poisoning, and 1 found these workers were as healthy
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1 Q Did you have any idea, Dr. Kelly, as to the
1 as the people 1 examined every day when 1 examined people.
2 relative amount of PCBs in fat at that point in time if you
2 Q So it didn't concern you that you found these
3 found 500 parts per billion in the blood?
3 levels in their blood?
4 A Yes.
4 A 1 did not think this was at all an alarming
5
Q How much more would you expect to have found
5 statistic, no, sir.
6 in the fat? You didn't test the fat?
6 Q There were no changes in the plant operation
7 A 1 think in an industrial environment, Mr.
7 to eliminate exposure after you found these levels?
8 McCrea, you do not tell the worker that we are going to
8 A Remember we were not this sure of our results
9 make a two inch incision in your skin and take out a couple
9 on the PCB in blood. You are taking these as gospel, and 1
10 of grams of fat to analyze it. They don't look upon that
10 have said all along that we were not certain about -- This
11 very enthusiastically.
11 was the best we had, but we didn't know if it was good,
12 Q Well, your company's done that to our clients?
12 good enough, but 1 was much more interested in the state of
13 MR. CARNEY: 1 object to that. That's
13 their health, their clinical health, their laboratory
14 incorrect.
14 findings which were all nothing unusual in there. So
15 MR. McCREA: Well, sorry. It's absolutely
15 that's what concerned me rather than these samples 1 took
16 correct.
16 of the blood, of their blood.
17 A Well, 1 am saying--
17 Q Dr. Kelly, after you found these levels in
18 MR. CARNEY: What he just described is
18 their blood did, was there any effort by Monsanto to
19 incorrect. We didn't do that to-
19 eliminate the leaks of PCBs which obviously were getting
20 A -- was my, at present time the analytical
20 into these people?
21 methods are such that you can use a needle puncture and 21
A We always try to tighten up all operations. 1
22 bring out fat. In those days you had to take out at least
22 do not -- Remember you are just -- The answer is 1 do, 1
23 one or two teaspoonfuls of fat, so that necessitated a two
23 think we looked over the housekeeping procedures, but you
24 or two and a half inch incision in the abdomen and 1 didn't
24 are picking on the blood levels which 1 have repeatedly
25 see any reason to do that.
25 said we are not confident that these represent actually
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
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1 what was in the people's blood.
1 be caused by exposure to PCBs. Is that correct?
2 Q It could have been much higher?
2 A No, it isn't. It's a symptom that can occur,
3 A It could have been much lower, too.
3 and then after you find out -- After you examine the man,
4 Q Right. The question is this, and would you
4 you find out what is the cause of it.
5 answer the question, please, and we'll get out of here much
5 Q Doctor --
6 earlier: Did you take any measures following this
6 A Well, now just a moment. There are things
7 collection of data to eliminate leaks of PCBs in the
7 that have occurred in massive exposure to PCBs containing
8 Sauget, Illinois plant?
8 dibenzofurans. 1 am suspicious of what that, those things,
9 A We always -- The answer is we always tried to
9 what symptoms those might be, what symptoms and signs a
10 eliminate leaks. Once we saw a leak, we eliminated it.
10 person might have. 1 have no preformed ideas of anybody,
11 Q Did you have a number of leaks from time to
11 what symptoms an industrial worker in our plant was liable
12 time?
12 to have because 1 have known for 25 years that they didn't
13 A Well, in the chemical plant you do have leaks
13 have any symptoms. So 1 didn't know what to look for
14 certainly.
14 except that 1 looked for all the symptoms that you would
15 Q Doctor, when you examined these people in
15 look for if you were trying to pick up any illness.
16 1972, you knew about Yusho; correct?
16 Q Then, Doctor, it's important that you
17 A Yes, sir.
17 understand my question.
18 Q What health symptoms did you suspicion could
18 A Well, yes,please.
19 be caused by PCBs when you examined these people on May 10,
19
Q If you don't understand my question and you
20 1972? And I'll ask you just to list them.
20 answer it not understanding it, then it's of no value.
21 A Will you repeat that sentence?
21 A All right.
22 Q What health problems did you suspicion could
22 Q All right? On the date of May 10, 1972, you
23 be caused by PCBs when you examined these 27 workers on May 23 have testified about your knowledge of furans.
24 10, in the two months preceding your report on May 10,
24 A Yes, sir.
25 1972? What 1 would like for you to do is simply to list
25 Q Did you have knowledge of furans on that date?
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1 all of those symptoms which you suspicioned might be caused 1
A I'm not sure. I'm really not sure of'72. 1
2 by PCBs?
2 may or not have. I'm not sure.
3 MR. CARNEY: Well, I'm going to object to
3 Q All right. 1 believe your testimony was that
4 having, using the word suspicion. Object to the form of
4 you did.
5 the question, and you changed the question now when you
5
MR. CARNEY: Well, 1 think you're
6 talk about symptoms. I'm not sure what question you're
6 mischaracterizing.
7 asking.
7 Q (By Mr. McCrea) Just a second. And you're
8 Q (By Mr. McCrea) Do you understand the
8 stating now that you may or may not have?
9 question?
9 MR. CARNEY: Well, 1 don't think you're - 1
10 A Well, 1 understand it, 1 believe. 1 will
10 don't think he's been inconsistent on that point.
11 answer it and see if 1 understand it. 1 recognize that if
11 Q (By Mr. McCrea) No, I'm not saying he has,
12 individuals were exposed to PCBs that contained high levels 12 but it's important for me to know what your testimony is
13 of nitrofurans or benzofurans and ate the material, certain
13 and 1 was a little confused; all right?
14 things would occur to them. 1 had no suspicion that we
14 A Well, 1 might very well have. 1 believe 1
15 would have any illnesses occur in our workers because we 15 did, but I'm not certain.
16 had had none for 25 years or my experience was 38, 30
16 Q All right, sir. Now my question is this: Did
17 years. So 1 asked all the questions that you would ask an
17 you formulate as part of your medical protocol a list of
18 individual who walked in. You asked him whether he had
18 symptoms and/or health problems which you felt based upon
19 lost weight, whether he had--
19 the literature, Yusho, whatever, might be caused by PCBs?
20 Q Just a second. Can you go slower?
20 MR. CARNEY: I'll object to the form of the
21 A Yes.
21 question. 1 think it's ambiguous.
22 Q
Lost weight?
22 A Well, I'm trying to understand it, Mr. McCrea.
23 A Yes.
23 When you examine an individual -- Well, 1 have to do that
24 Q All right. Is that -- Now, do we understand
24 because 1 cannot answer your question yes or no. When
25 each other? This is a symptom that you suspicioned might 25 you're carrying out a medical examination, you ask the man
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
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1 for all symptoms he has, all symptoms you think he might
1 didn't have a list, what symptoms -
2 have. During the course of that you say, "Do you have
2 A A written list, please.
3 upset stomachs? Have you lost weight? Have you had any 3
Q Exactly, written list. What symptoms did you
4 skin problems?" 1 did not go in there with a list saying,
4 suspicion that could be caused by PCBs?
5 "Okay, we'll run down these nine things because they were
5
MR. CARNEY: Again I'll object to the form,
6 reported in Yusho."
6 the use of the word suspicion.
7 Q That's exactly my question.
7 Q (By Mr. McCrea) You may answer.
8 A But 1 was knowledgeable about Yusho. 1 was
8 A Well, there it can be caused by PCBs in what
9 knowledgeable about how to carry out a medical examination 9 exposure and in what amount? Here 1 am going over
10 and take a medical history, and that's what 1 did.
10 examining workers and 1 am examining them to see if they
11 Q So 1 think you've answered my question. I'm
11 have any problems, any symptoms that are untoward, but that
12 not sure, and as 1 understand your answer, it is this: You
12 would encompass any of the problems that had occurred in
13 did not prepare a list of symptoms which you then asked
13 the eating episode over in Yusho.
14 these workers if they had, based upon your suspicion that
14
MR. McCREA: Well the court reporter read the
15 those symptoms might be caused by PCBs?
15 question back, and if 1 don't get an answer, I'm going to
16 MR. CARNEY: I'm going to object to that
16 take it to the Court. Now, 1 want an answer, Dr. Kelly.
17 question. It's compound and contains --
17 A All right. Fine.
18 MR. McCREA: It's a little bit long. I'll
18 MR. CARNEY: Let me just object here. You're
19 agree. Let me rephrase it, Tom.
19 insulting this witness totally without cause. He has sat
20 MR. CARNEY: Okay.
20 here for almost, well, a day and a half now asking
21 Q (By Mr. McCrea) Did you prepare a list of
21 questions, answering questions very patiently and he's
22 symptoms which you addressed to the workers?
22 answered, 1 think, every question to the best of his
23
MR. CARNEY: Are you talking about did he have
23 ability including that particular question which is a very
24 it in his head or did he have a list in his -
24 vague and ambiguous question. He did a lot better job of
25 MR. McCREA: No, written down.
25 answering it than 1 think 1 could have done or anybody
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1 A No, 1 didn't go in there with a written down
1 else. He answered the question, and to tell him that
2 list. 1 had a list of symptoms in my head that when 1 go
2 you're going to take it to the Court, go ahead. 1 welcome
3 over a generalized physical examination, you will take a
3 you to take it to the Court because 1 think the Court will
4 history by symptoms, by systems. You ask all the
4 say that this witness has done an exemplary job of
5 circulatory questions. You ask all the gastroenterology
5 answering that question, and to insinuate that he's somehow
6 questions. You ask all the neurological questions, and 1
6 not answered that question is outrageous to me. Sorry to
7 covered all the symptoms that they may have had and that
7 lose my temper a little bit, but 1 --
8 may have been present at Yusho.
8 MR. McCREA: That's all right.
9 Q (By Mr. McCrea) Based on information in your
9
MR. CARNEY: 1 really feel strongly that
10 head, not based upon a list?
10 that's accusing this witness of something that is not true.
11
MR. CARNEY: Well, I've never seen a doctor
11
MR. McCREA: 1 would like the question read
12 that's ever done a physical for me have a list, that since
12 and the answer read so that 1 can be sure that 1 know the
13 they do hundreds of physicals a week, I'm sure they're
13 question which was addressed and the answer. Then 1 will
14 smart enough to have these things in their head, but 1
14 have comments as to whether or not 1 feel the question was
15 guess you're--
15 answered. So could the court reporter-
16 A No, 1 did not.
16 A Well -
17
MR. CARNEY: Well, your point is did he have
17
MR. McCREA: Just a second, please, Doctor.
18 them all written done on a piece of paper, and 1 think he
18 Could the court reporter please read the question and his
19 said no.
19 answer?
20 A No, but I've taken medical histories for 50
20 (Thereupon, the reporter propounded the previous
21 years and 1 have not had a list, but 1 know what to ask
21 question and answer.)
22 people.
22 MR. McCREA: He didn't answer the question. 1
23 Q (By Mr. McCrea) All right. Fine.
23 asked him what symptoms did he suspicion were caused by
24 A Yeah.
24 PCBs. His answer is - 1 would expect the answer to be, "1
25 Q Now, the next question is: Recognizing you
25 didn't suspect any, 1 didn't suspect any or 1 suspected the
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1 following." Now, if he didn't suspect any, that's fine.
1 MR. CARNEY: Same objection. It's got
2 If he did suspect some, 1 would like to know those
2 undefined terms. It's vague.
3 symptoms, he has not answered the question.
3 Q (By Mr. McCrea) In other words, do you know
4
MR. CARNEY: 1 disagree with you, Mr. McCrea.
4 how the PCBs and the contaminant furans caused the changes
5 1 think he did answer the question. 1 just don't think you
5 in the skin in Japan?
6 liked the answer. You have some other answers that you
6
MR. CARNEY: Same objection. 1 don't know
7 would like to give to your questions, but this is the
7 what you mean. 1 don't know what you mean by the question.
8 witness whose answers count, not your answers. So do you 8 It's vague.
9 have another question?
9 A Repeat the question.
10 MR. McCREA: No. I'm going to-
10 Q (By Mr. McCrea) Do you know how the exposure
11 A Repeat that question of yours then that we are
11 to PCBs in the rice oil in Japan induced or caused the
12 discussing.
12 changes in the skin in those people?
13 Q (By Mr. McCrea) I'd be happy to. What
13 MR. CARNEY: Objection. 1 don't know what you
14 symptoms did you suspicion were caused by PCBs when you 14 mean by how. How, that's a vague term to me. How, in what
15 examined these workers before you wrote the letter?
15 way how? Chemically?
16 MR. CARNEY: Same objection.
16 MR. McCREA: Yes, chemically.
17 A My suspicions could vary from no symptoms
17 A Well, first of all, it was swallowed. It goes
18 depending on the exposure of the man to a number of
18 into the stomach and the intestine. It is then absorbed
19 symptoms that were developed after the Yusho incident.
19 and it goes into the liver. There are changes in the
20 Q (By Mr. McCrea) Now, Doctor, describe if you
20 oxidative enzymes of the liver, and somehow this disturbs
21 would the number of symptoms developed after the Yusho
21 the fat metabolism of the hair follicles and the sebaceous
22 experience?
22 glands of the skin. 1 am not familiar with the details of
23 A Yes. Changes in the skin, lassitude, pains in
23 those last two steps.
24 the extremities, loss of weight.
24 Q (By Mr. McCrea) Can you explain how the
25
MR. CARNEY: Is your question asking him for
25 absorption of PCBs into the body chemically caused the
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1 symptoms that showed up in Yusho so I'm clear? 1 think
1 lassitude?
2 that's what he's answering and 1 just want to --
2 MR. CARNEY: Objection. Same objection.
3 Q (By Mr. McCrea) That's exactly correct. Is
3 A You mean that particular --You were using the
4 that the way you understand it, Doctor?
4 word PCBs generally all over. Are we still talking about
5 A Yes, 1 presume, 1 believe so.
5 Yusho?
6 Q Yeah. Okay. Continue.
6 Q (By Mr. McCrea) Yes, we are.
7 MR. CARNEY: Okay.
7 A Okay. So that's -
8 A What have 1 said so far?
8 Q PCBs and furans.
9 Q (By Mr. McCrea) Doctor, you said changes in
9 A Huh?
10 skin, lassitude, pains in extremities, loss of weight?
10 Q PCBs and furans.
11 A Changes in respiratory function such as
11 A Let's say, yes.
12 shortness of breath, tiredness, frequent illnesses,
12 Q Let's call it the Yusho PCBs.
13 irritability, headaches. That's all 1 can think of at the
13 A The Yusho PCBs with its dibenzofurans and its
14 present time.
14 quaterphenyls.
15 Q All right, sir. Doctor, from the standpoint
15 Q Exactly.
16 of your expertise -- just a second here -- can you
16 A Can 1 explain how it did what?
17 explain the mechanisms which were implicated in the
17 Q Caused the lassitude.
18 induction of those toxic effects that you have just cited?
18 A No, sir.
19
MR. CARNEY: 1 would object to the form of the
19 Q Can you explain how the PCB, the Yusho PCBs
20 question. It's vague and ambiguous. 1 don't understand
20 chemically caused the pains in extremities?
21 it.
21 MR. CARNEY: Let me object. Can 1 have a
22 A You'll have to clarify toxic effects. Where?
22 standing objection to the form of the question?
23 Q (By Mr. McCrea) The nine symptoms you
23 MR. McCREA: Yes, you may.
24 described from Yusho, can you explain the mechanism which 24
MR. CARNEY: It's vague and contains undefined
25 is implicated in the induction of changes in the skin?
25 terms.
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 97-100
LEXOLDMONOQ6767
Page 101 1 A Yes, it caused demyelinization of the nerve 2 fibers with peripheral neuritis. 3 Q (By Mr. McCrea) What is meant by the term 4 demyelinization? 5 A Well, myelin is a covering of the material, 6 and the nerve sheath covers the nerves, and you take away 7 the myelin and you leave the nerves bare as it were. 8 Q Sort of like taking insulation off a wire? 9 A Something of that sort. 10 Q Can you explain how the Yusho PCBs chemically 11 caused the loss of weight? 12 A No, except that furans have been -- 13 dibenzofurans have been associated with a wasting 14 illnesses. Whether that mechanism is in the liver or not, 15 1 don't know. 16 Q Can you explain, Doctor, how the Yusho PCBs 17 chemically caused the change in respiratory function and 18 shortness of breath? 19 A No. There's a very large amount of 20 controversy over that, and whether or not those symptoms 21 were real or not has not been established. 22 Q Can you explain how the Yusho PCBs chemically 23 caused the tiredness? 24 A No, sir, 1 cannot. 25 Q Can you explain how the Yusho PCBs chemically
Page 103 1 system. 2 Q What is the immunological system? 3 A That's a very intricate part of a body that 4 shows, that affects how people react to things. In other 5 words, if you have an immune deficiency, you are liable for 6 the sort of illnesses. If you have hyperimmunity, you are 7 liable to other illnesses. 8 Q You mentioned that it's been reported in 9 various places. Can you elaborate on that or describe that 10 for us, please? 11 A Well, 1 don't know what you mean by elaborate. 12 1 don't have the journals right at present, but it has been 13 reported at times and not reported, disputed at times. 14 Q Okay. Can you explain how the Yusho PCBs with 15 furans as the main causative agent chemically caused 16 irritability? 17 A No, 1 cannot. 18 Q Would that relate to the brain? 19 A Well, whether it related to the brain or 20 whether it was because the people were sick, were 21 irritable, whether there was any organic problem there, 22 whether it was a psychic problem, 1 don't know. 23 Q Can you explain how the Yusho PCBs chemically 24 caused headaches? 25 MR. CARNEY: Again the Yusho PCBs with the
Page 102
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1 caused frequent illnesses?
1 furans caused, principally causing the problem?
2 MR. CARNEY: Again you're talking about the
2 MR. McCREA: With furans as the main causative
3 furans in the PCBs?
3 agent.
4
MR. McCREA: Talking about the Yusho PCBs with
4
A Caused headaches?
5 furans and quaterphenyls.
5 Q (By Mr. McCrea) Right.
6 MR. CARNEY: It would be better if you, since
6 A 1 don't think anybody can explain what causes
7 the literature seems to establish it was the furans, the
7 headaches.
8 high concentration of furans that caused these problems,
8 Q Is that neurological?
9 use the word furans rather than PCBs. Otherwise, 1 think
9 A Well, you can have headaches from brain
10 you're confusing the jury.
10 tumors. That's neurological. You can have headaches from
11
MR. McCREA: Would you like to cite me to an
11 migraine which is vascular. You can have headaches from
12 article?
12 emotions which is certainly psychological.
13 MR. CARNEY: 1 could cite you to the same
13 Q Okay.
14 article that Dr. Kelly cited you to about an hour ago.
14 MR. CARNEY: You can have headaches from a
15
MR. McCREA: What's the name of that article?
15 long deposition.
16 A Kumita, K-u-m-i-t-a, in the "American Journal 16 MR. McCREA: You can have headaches from
17 of Industrial Medicine", November 1984 whose statement was, 17 working in PCBs in Bloomington, Indiana, Tom.
18 "It is clear that PCDFs" -- that's dibenzofurans -- "were
18
MR. CARNEY: Well, your experts disagree with
19 the main causative agent in the case of Yusho disease."
19 you on that. They don't think headaches have anything to
20 Q (By Mr. McCrea) Okay. All right, sir. Can
20 do with PCBs.
21 you explain how the Yusho PCBs with furans as the main
21
Q (By Mr. McCrea) Well, you need to read the
22 causative agent chemically caused frequent illnesses?
22 reports. Now, Doctor, you have discussed the symptoms from
23 A Well, first of all, I'm not sure they did.
23 Yusho and you've listed nine which you had in mind when you
24 That's a symptom that has been reported around in various 24 surveyed these people. Is that a fair statement?
25 places, but if it is, it is a change in the immunological
25 A No, it isn't a fair statement because 1 have
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 101 - 104
LEXOLDMONOQ6768
Page 105
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1 these symptoms in mind when 1 examine anybody no matter 1 what problems, headaches, for example, or irritability. 1
2 what they have, what they come in to me for. These
2 would assume everybody has headaches from time to time or
3 symptoms are not diagnostic of PCB or nitrofuran exposure
3 irritability from time to time or these symptoms. You have
4 or intoxication or poisoning. They could occur from a host
4 to be more specific and quantify what you mean by these
5 of conditions.
5 symptoms to make any sense out of it. 1 don't think we're
6 Q Doctor, we're kind of back where we started.
6 getting anywhere.
7 Didn't 1 ask you for a list of symptoms based on the Yusho 7 Q (By Mr. McCrea) I'll try to be more specific,
8 experience, and didn't you give me one through nine based
8 and 1 think that's a good suggestion. Have you read
9 on the Yusho experience?
9 studies by epidemiologists where they determine percentages
10 A Well, no, that is not correct because it's not
10 of people with certain symptoms and determine those to be
11 only based on the Yusho experience. It's based on what
11 significant at a scientifically acceptable standard?
12 other people may have from other illnesses. You can't say 12
A 1 may have. Do you have the studies?
13 that a person comes into me and has a headache and 1 say, 13
Q Is that a recognized area of science?
14 "Have you had headaches in the last year", am 1 asking them 14
A 1 don't think symptoms are relative. 1 think
15 that because 1 think he's exposed to PCB or 1 think he may 15 that -- 1 think they are looking for objective findings
16 have eyestrain. So 1 cannot differentiate my medical
16 rather than something you can see, something that is shown
17 history on the basis of PCB exposure, Yusho publications or 17 by physical examination, laboratory examination or x-rays.
18 the general health or the general medical history of a
18 Symptoms vary all over the place and --
19 person.
19 Q Okay.
20 Q Okay. Doctor, during the time that you worked
20 A Symptoms also are, there are many causes for
21 for Monsanto, did you ever make a tabulation of symptoms 21 it.
22 experienced by your workers? In other words, you have 27 22
Q Did you see a list of symptoms in the studies
23 workers. You have headaches and you have X number with 23 of the people in Japan?
24 headaches. Then you have irritability, X number with
24 A 1 may have. 1 don't know.
25 irritability, frequent illness, X number and so on. Did
25 Q And as 1 understand it, you would consider
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1 you ever do that from 1936 to 1974?
1 objective evidence such as x-rays, EKG, EEG and that type
2 MR. CARNEY: Objection to the question. It's
2 of information as significant to prove epidemiologically if
3 vague and ambiguous. It doesn't define what group you're
3 these workers have suffered a certain set of health
4 talking about.
4 problems. Is that a fair statement?
5 MR. McCREA: PCB workers.
5 A No, it isn't fair because x-rays - It all
6 A No, 1 never did that and you never do that
6 depends on what you're looking for. 1 would say that there
7 with anybody because you are, there are all variations in a
7 are certain physical conditions that you were looking for.
8 person's symptoms. When you say headaches and this
8 If you were talking about PCBs, if 1 saw a group of people
9 tabulation we ought to make, do 1 say eight headaches,
9 with chloracne, 1 would know this, and they worked with
10 headaches four times a day, headaches three times a week. 10 PCB, 1 would be certain that they got their problems from
11 We cannot do that in medical examinations. You have to
11 PCB. 1 if saw a bunch of people with headaches and they
12 take the sum total of a person's history, his medical
12 were working with PCBs and they didn't have chloracne, 1
13 history and then make your diagnosis from that.
13 would not believe that their headaches were coming from
14 Q (By Mr. McCrea) Doctor, 1 appreciate the fact
14 PCBs.
15 that you didn't do that from 1936 do 1974.
15 Q Okay. So unless you see chloracne, it's your
16 A 1 did not make a tabulation, that's correct.
16 determination that there has been no injury by PCBs?
17 Q Right. So you don't know what percentage of
17 A 1 think that's mine and 1 think that's the
18 workers had what problems?
18 feeling of the majority of the writers.
19 MR. CARNEY: Well, I'm going to object to
19 Q Can you name two or three writers who feel
20 that. This question is totally irrelevant.
20 that way?
21 Q (By Mr. McCrea) Well, strike it. Strike the
21 A I'm sure you could start with Kimbrough again.
22 question, Tom. Do you know and do you have any results as 22
Q She feels that if you don't have chloracne,
23 to what percentage of workers had what problems?
23 there have been no injuries by PCBs?
24 MR. CARNEY: Well, I'm going to object here. 24 A That's correct.
25 1 don't know what you mean, what percentage of workers have 25
Q All right. Who else?
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 105 - 108
LEXOLDMONOQ6769
Page 109
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1 A Oh, 1 don't know right off the top of my head,
1 body.
2 but that's, I'm sure they're around because I've seen them.
2
Q Can they alter metabolic processes?
3 Q But you don't remember them?
3 A Beg your pardon?
4 A No, 1 don't remember them.
4 Q Can they alter metabolic processes?
5 Q Okay. Now, Doctor, did you see chloracne in
5 A They may. They may not.
6 any of these people?
6 Q And by metabolic process, you mean what?
7 A Which people?
7 A The chemical reactions that go into the body,
8 Q The 27.
8 into the daily working of the body.
9 A No, none.
9 Q So PCBs, if absorbed in sufficient quantities,
10 Q So that more or less ended your study?
10 can alter the metabolic function and the chemical reactions
11 A No, it didn't.
11 associated therewith?
12 MR. CARNEY: 1 object.
12 A In certain places of the body, yes. Not --
13 Q (By Mr. McCrea) Well, if you didn't see
13 Q Which places?
14 chloracne and your opinion is that if you don't have
14 A The liver.
15 chloracne, there are no health problems, was there any
15 Q What, do they just stay in the liver, the
16 reason to go forward?
16 enzymes?
17 A Oh, 1 was looking for any health problems,
17 A Well, an enzyme, there is specific enzymes for
18 yes, and 1 wanted to reinforce my opinion that chloracne is
18 all -- You don't have one enzyme that goes around working
19 the hallmark of PCB toxicity, and if 1 found no chloracne
19 every place in the body. There are literally hundreds of
20 and 1 found a bunch of liver problems, 1 would have changed 20 thousands of enzymes in the body. Some have to do with
21 my mind.
21 protein metabolism, some fat metabolism, some sugar
22 Q You wanted to reinforce your opinion?
22 metabolism. There's a lot of -- some oxygen metabolism.
23 A That's correct.
23 There are all sorts of enzymes.
24 Q Okay. Did you approach that endeavor with an 24 Q Can PCBs affect more than one enzyme?
25 open mind?
25 A 1 can't answer that.
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1 A Of course 1 did. 1 approached it by examining
1 Q Are the enzymes - Is the enzyme induction
2 the people to see if there was anything wrong with them.
2 caused by absorption of PCBs a factor in chloracne?
3 Q Doctor, can you explain enzyme induction to us 3 A 1 don't believe that's been established.
4 as it is caused -- Well, first of all, let me ask you this.
4 Q Can PCBs, if absorbed into the body in
5 Does PCB exposure cause enzyme induction?
5 sufficient quantity, result in the inhibition of
6 MR. CARNEY: Object to the form. It's vague. 6 mitochondrial respiration?
7 1 don't know what you mean by enzyme induction.
7 A Yes. Well, that's an enzyme function.
8
MR. McCREA: Well, that's why we have a doctor
8
Q And what is the effect of that enzyme function
9 here to explain it, Tom.
9 resulting in the inhibition of mitochondrial respiration on
10
MR. CARNEY: Well, 1 don't know what you mean
10 the individual?
11 by it. If the doctor understands the question, he can
11 A It depends on how much and how many of the
12 answer.
12 mitochondria are affected.
13 MR. McCREA: Okay.
13 Q All right. Now, the low level, at a low
14 A PCB exposure does not cause enzyme induction. 14 level, then a high level.
15 PCB absorption in sufficient amount does cause enzyme
15
MR. CARNEY: Objection to the form of the
16 induction.
16 question. It's vague.
17 Q (By Mr. McCrea) What is enzyme induction?
17 A Low level, it wouldn't make any difference at
18 A Enzyme induction means that you start the
18 all. At a high level we would get some problem with the
19 formation of enzymes in certain parts of the body,
19 liver metabolism.
20 primarily the liver.
20 Q (By Mr. McCrea) Can - And is that related to
21 Q That all?
21 - When it says mitochondrial respiration, are we talking
22 A Well, what else do you want? 1 mean, that's
22 about the liver or are we talking about the lungs?
23 what enzyme induction is.
23 A You have to have oxygen in all the cells in
24 Q What are the functions of enzymes?
24 the body. Mitochondria are part of the cells, usually in
25 A They enter into every metabolic process in the
25 the liver, and the respiration means a transfer of oxygen
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 109 - 112
LEXOLDMON006770
Page 113
Page 115
1 past the cell membrane. The mitochondria are not puffing
1 specifically.
2 up and down like your lungs are.
2 MR. McCREA: Thank you. Time for a break.
3 Q Okay, Doctor. How much time? Doctor, three
3
(Thereupon, a lunch recess was taken.)
4 minutes left on this tape. Can the absorption of PCBs into
4
Q (By Mr. McCrea) Dr. Kelly, 1 think we left off
5 the body in sufficient amounts result in estrogenic effects
5 after your discussion of estrogenic effects on altered
6 in altered steroid metabolism?
6 steroid metabolism. You have an opinion if sufficient
7 A In some species, yes. Some species, no.
7 absorption of PCBs can result in the mobilization and
8 Q What is that?
8 redistribution of stored PCBs?
9 A What is what?
9 A It may and it may not.
10 Q Estrogenic effects in altered steroid
10 Q What is the effect of mobilization and
11 metabolism.
11 redistribution of stored PCBs?
12 A Well, estrogens obviously are sex hormones.
12 A What may be excreted. In other words, the
13 Steroids are also hormones, but have to do with building up 13 PCBs absorbed in the fat and if it's mobilized, it could be
14 the body. That's why weight lifters take them.
14 excreted.
15 Q And what is the effect of the estrogenic
15 Q Are there other --
16 effects on altered steroid metabolism?
16 A It could be metabolized.
17 A You have to tell me how much they have.
17 Q Are there other consequences?
18 Q Well, a lot.
18 A Depends on how much.
19 MR. CARNEY: Well, I'm going to object to a
19 Q Well, assuming there is a sufficient amount.
20 lot.
20 MR. CARNEY: Objection again to the form of
21 A 1 don't know what at lot means.
21 the question.
22 Q (By Mr. McCrea) Well, you'll have to tell me
22 Q (By Mr. McCrea) How much would it take to
23 what you mean by asking me what 1 mean because 1 don't 23 cause other effects?
24 know.
24 A 1 don't know. What species are we talking
25 A Let's run that by again. That's got me
25 about?
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1 confused.
1 Q Humans.
2 MR. CARNEY: It's got me confused.
2 A 1 don't know.
3 MR. McCREA: Well, it's a little bit -
3 Q Can absorption of PCBs into the body result in
4 MR. CARNEY: 1 don't know if he should
4 covalent binding to cellular macromolecules?
5 speculate as to what you mean.
5 A I'm not an enzymatic enzymology chemist. 1
6 Q (By Mr. McCrea) Well, sufficient quantities,
6 cant answer that.
7 sufficient amounts.
7 Q Can absorption of PCBs into the human body
8 A To do what now?
8 result in altered calcium metabolism?
9 Q You're getting me offtrack, Doctor.
9 A 1 don't know if it does in the humans. It
10 A I'm sorry. You want her to read it back?
10 occurs in avian species. That's birds.
11 Q Doctor, can absorption of PCBs into the body
11 Q Did Monsanto rely on animal testing to
12 in sufficient amounts result in estrogenic effects on
12 determine potential health effects to humans?
13 altered steroid metabolism, and if so, what is the effect?
13 A They relied on animal testing. They relied on
14 MR. CARNEY: Objection, compound and vague and 14 experience with their workers. They relied on the public,
15 ambiguous as to what you mean by sufficient.
15 published information concerning PCB.
16 A The answer is yes to the first part of your
16 Q What is altered calcium metabolism?
17 question, and the second is the effect would determine, be 17
A Just what it says. Calcium is an important
18 determined by how much they're altered.
18 ingredient of the body. It takes - It's used at the
19 Q (By Mr. McCrea) And if they're altered a lot,
19 cellular level, and altered means you either get too much
20 what is the effect?
20 or too little.
21 MR. CARNEY: Objection to form.
21 Q Have bone and joint deformities been reported
22 A That again varies with the species. If you're
22 as a result of the ingestion of Yusho PCBs in human beings?
23 a mink, you have one problem. If you're a guinea pig, 23 MR. CARNEY: These again are the PCBs where
24 something else, and if you're a dog or a human, you'll have 24 the furans were the principal cause of the problem.
25 something else. So 1 cannot answer that question
25 MR. McCREA: The literature speaks for itself.
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 113 - 116
LEXOLDMONOQ6771
Page 117
Page 119
1 A Beg you pardon? You talking to me or him?
1 incident?
2 MR. McCREA: Well, I'm talking to him.
2 A '68 or '69.
3 A The question is?
3 Q In what year was the incident in Taiwan?
4
MR. McCREA: Could you repeat the question?
4 A '79.
5
(Thereupon, the reporter propounded the pending
5 Q Are you familiar with any of the authors of
6 question.)
6 this article titled "Congenital Poisoning by
7 A 1 don't recall. 1 do not think it was a very
7 Polychlorinated Biphenyls and Their Contaminants in Taiwan"
8 prominent effect.
8 by reputation or by direct knowledge, and if so, just
9 Q (By Mr. McCrea) Have joint pains been
9 explain to us what you know about the authors?
10 recorded in the children born to the mothers who ingested
10
A Well, 1 don't know anything about the authors.
11 the Yusho PCBs?
11 1 never heard of them.
12 A We're talking now about children? Previously
12 Q Are you familiar with the Triangle Park
13 you talked about joint deformity.
13 Research Laboratory?
14 Q I'm now talking about joint pains.
14 A Yes, 1 am.
15 A 1 think they may have. I'm not certain.
15 Q Does it enjoy a good reputation?
16 Q Doctor, can you explain the mechanism by which 16 A Well, there -- You were talking about the
17 the Yusho PCBs caused joint pain in children born to the
17 research laboratories in the Research Park. There are any
18 mothers who ingested the rice oil contaminants with the
18 number of laboratories in that.
19 PCBs, furans and quaterphenyls?
19 Q Okay.
20 A No, 1 can't.
20 A Some government, some private. So if you're
21 Q You do acknowledge that's documented?
21 asking about do 1 know whether the National Institute of
22
MR. CARNEY: Are you talking about with the
22 Environmental Health Sciences Research, if that's what
23 furans or PCBs?
23 you're asking about, 1 do not believe this is a government
24 A 1 said it may be. 1 haven't seen the
24 agency, and 1 don't know anything about its reputation.
25 documentation lately. I'd be happy to look at it and give
25 Q All right. Now, as the expert witness and a
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1 you a definite opinion.
1 fact witness for Monsanto, you are constantly updating
2 Q (By Mr. McCrea) Talking about the joint pain
2 yourself on the literature, are you not?
3 in children.
3 A As well as 1 could, yes.
4 A That's what you're - Yeah, show me the
4 Q All right. What is the title of this
5 documentation. I'll be happy to talk about it.
5 particular article?
6 MR. McCREA: All right, sir. Can you -- Can
6 A "Congenital Poisoning by Polychlorinated
7 we staple this and mark it is our next exhibit?
7 Biphenyls and their Contaminants in Taiwan."
8 (Thereupon, the reporter marked Plaintiff's
8 Q Explain to the jury what the word congenital
9 Deposition Exhibit Two, for identification.)
9 means.
10 Q (By Mr. McCrea) Doctor, 1 --
10 A Something that exists from birth.
11 MR. CARNEY: May 1 take a look at it?
11 Q All right. Now, Doctor, can you, or let me
12 Q (By Mr. McCrea) Doctor, 1 hand you what the
12 direct your attention if 1 might to the second page of the
13 court reporter has marked as Plaintiffs Exhibit Two dated
13 article.
14 6-1-90, and I'll ask if you will take a look at that
14 A I'm going to read it from the beginning if I'm
15 article. My first question is: Have you read that before
15 going to go to the second page.
16 today?
16 Q All right, sir. 1 agree.
17 A 1 do not recall whether 1 read this before or
17 A In the first place, 1 see none of the
18 not.
18 qualifications or degrees of the authors. There is W. J.
19 Q Are you familiar with the poisoning in Taiwan?
19 Rogan. It doesn't say what he is or who he is. R. C.
20 A Yes, 1 am.
20 Gladen, it doesn't say who he is or what he is. N. B.
21 Q Was it similar to the poisoning in Japan?
21 Ragan, those three. Then we have some other individuals,
22 MR. CARNEY: Objection to the form.
22 but the three people in the lead, 1 do not have their
23 A It was similar to the - yes, it was, to the
23 degrees. They do not say with what establishment they are
24 Yusho incident.
24 attached.
25 Q (By Mr. McCrea) In what year was the Yusho
25
MR. McCREA: Can we shut off the tape while he
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 117-120
LEXOLDMONOQ6772
Page 121 1 reads that? 2 MR. CARNEY: Yeah. 3 (Thereupon, a short recess was taken.) 4 Q (By Mr. McCrea) Dr. Kelly, have you had time 5 to read the article? 6 A Yes, 1 have. 7 Q And does the article compare the condition of 8 health of children born to mothers who ingested the rice 9 oil contaminated with PCBs and its by-products to a control 10 group? 11 A Yes. 12 MR. CARNEY: Let me object here for the 13 record. This is a document that was torn out of a larger 14 document just before it was handed to the doctor. There's 15 no testimony whether it's a complete, self-contained 16 document or a complete document. The -- Dr. Kelly hasn't 17 been able to authenticate it as to its being a reliable 18 document. There's no foundation that these people are 19 qualified to write such an article, so 1 just object for 20 the record to asking questions about an article that hasn't 21 been authenticated in any way. 22 Q (By Mr. McCrea) Dr. Kelly, 1 will represent 23 to you that that is the entire article. Can you determine 24 by looking at the exhibit if it includes all the pages of 25 the article?
Page 123 1 Q All right. Would you refer to table one? 2 A Yes. 3 MR. CARNEY: Just a minute. I'm going to 4 object to - here you have a document that hasn't been, 5 there's been no foundation laid as to where it came from, 6 who the authors are, and now you're blowing it up, and 7 before you show it to anybody, 1 just want to make my 8 objection and that is that it hasn't been authenticated to 9 be introduced into evidence, so it's improper to show it to 10 the jury. Can 1 have a standing objection to that during 11 this line of questioning about this article? 12 Q (By Mr. McCrea) Doctor, are you familiar with 13 the publication? 14 MR. CARNEY: Well15 Q (By Mr. McCrea) In which this article was 16 written? 17 A Yes, 1 am. 18 Q And is that authoritative and relied upon by 19 doctors and scientists? 20 A 1 would say that there's a double question 21 there. It's an excellent article. It's an excellent 22 magazine, an excellent journal. They always usually put in 23 preliminary reports which at some later date may be 24 disputed or changed. 25 Q Yes, sir. Now --
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1 MR. CARNEY: I'm going to object to that. It
1 MR. CARNEY: Can 1 have a standing objection
2 would be pretty hard for the doctor since he doesn't know
2 or should 1 object on each question about this article?
3 if he ever read the article to determine whether there are
3
MR. McCREA: No, 1 agree that you may have a
4 more pages to the article or not, but if he can answer it,
4 standing objection as to all of those objections that you
5 fine.
5 have noted during the entire course of the doctor's
6 A 1 think it appears to be a complete article.
6 testimony.
7 Q (By Mr. McCrea) And then are there blow-ups of
7
MR. CARNEY: Okay.
8 the charts?
8 Q (By Mr. McCrea) Doctor, would you refer to
9 A Well, table one is blown up. Table two and
9 table one? And if the camera could focus on that.
10 table three, yes, sir.
10 A Yes, sir.
11 Q All right, sir. Dr. Kelly, can you recite for
11 Q Will you read the introduction to the table?
12 the jury the findings of the authors of this article with
12 A "Physical signs present at birth and selected
13 respect to the health symptoms of the children born to
13 medical history items as reported by mothers. Frequencies
14 mothers who consumed the contaminated rice oil compared to 14 are those reporting 'yes' or those reporting 'yes' or 'no'.
15 the control group of children whose mothers had no
15 'Don't know' and missing values are not included."
16 exposure?
16 Q On the upper left column it has physical sign
17
MR. CARNEY: Can 1 have a standing objection
17 and then exposed and control. Can you explain that to the
18 to this, any questions about this document with regard to
18 jury?
19 its authenticity, its establishment as a scientific
19 MR. CARNEY: Well, I'm going to object to
20 document and as to whether it's a complete document.
20 this. Dr. Kelly didn't write this article. He doesn't
21 Q (By Mr. McCrea) Yes.Doctor?
21 even know the authors, and I'm going to object to your
22 A What do you want?
22 asking him to speculate what somebody else meant by using
23 Q The blow-ups. Can you read those charts
23 words since he hasn't talked to them. In fact, he doesn't
24 without the blow-ups? Is that fair enough to you?
24 know them. He'd have to speculate inside their minds.
25 A Yes.
25 Q (By Mr. McCrea) Can you explain that to the
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 121-124
LEXOLDMONOQ6773
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1 jury, Dr. Kelly?
1 that secrete, that are fat secreting type of glands, and we
2 A Physical sign is something you see. Exposed
2 know that PCBs with nitrofuran, with benzofurans cause acne
3 is presumably the individuals who were exposed in the
3 which is a disturbance of the fat metabolism in the sweat
4 Taiwan episode, and control is some group. 1 don't know
4 glands, in the hair follicles, and it is no surprise to me
5 where he got this control group. Let's see where he found
5 at all that there would be some eye discharge when you have
6 this control group.
6 a serious condition serious enough to cause chloracne.
7 Q All right, sir.
7 Q The next category is eyelid swelling. Can you
8 A I'm trying to find out where his controls came
8 explain the method by which the PCBs with furans and
9 from. I'm sorry I'm so slow, but...
9 quaterphenyls produce this condition?
10 Q No, that's all right.
10 A Well --
11 A He stated in his summery at the top there were
11
MR. CARNEY: Well, let me object. You're
12 108 unexposed controls were examined and evaluated, but I'm 12 assuming that -- First of all you're saying PCBs cause this
13 going through the body of the report and 1 don't see where
13 condition, and 1 think you're misstating the facts again.
14 he mentions where these nonexposed children came from. 14 You're mixing up the PCBs and the furans.
15 Q What does-
15 MR. McCREA: 1 said PCBs with furans and
16 A You've had this much longer than 1 do. Do you
16 quaterphenyls.
17 want to point it out to me?
17 MR. CARNEY: 1 don't think you said it in that
18 Q Well, 1 assume that by control he means those
18 last question.
19 who were not born to the mothers who ingested the rice oil 19
MR. McCREA: Yes, 1 did.
20 which was contaminated.
20 A The same things 1 said for the discharge. The
21 MR. CARNEY: Well, I'm going to object to -
21 glands that cause the discharge also cause the eyelids to
22 A Oh, yes.
22 swell. That's where the glands are in the eyelids.
23
MR. CARNEY: -- any assumptions here. We're
23 Q (By Mr. McCrea) Teeth present, can you
24 talking about an article that the writers of the article
24 explain the mechanism by which that comes about?
25 are unknown to the witness.
25 MR. CARNEY: Well, I'm going to object to
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1 A 1 think the big point is -- Marie said just a
1 that. 1 don't know what is meant by teeth present.
2 moment.
2 MR. McCREA: Teeth present at birth. When the
3 Q (By Mr. McCrea) Doctor, you're unable to
3 children are born, they're born with teeth.
4 determine what is meant by the word control. Is that
4 MR. CARNEY: 1 don't see that in the, in the
5 right?
5 chart, but at any rate, 1 think the question is vague and 1
6 A Well, 1 know what is meant by the word
6 think you're implying that this is the Yusho incident or 1
7 controls, but 1 do not know where he got his 108 exposed
7 think you mentioned it.
8 controls, and 1 have no way of knowing whether they're 8 MR. McCREA: No, it's Taiwan.
9 really truly controls, whether they came from the same 9 MR. CARNEY: This is Taiwan, not Yusho.
10 economic stratum or not. 1 don't see in the body of this
10 Q (By Mr. McCrea) That's correct. Can you
11 report any mention of where he got his controls. 1 don't
11 explain the mechanism by which that comes about, Doctor?
12 even know if they're the same age. It doesn't mention
12 A No, sir, 1 do not know that, but that has been
13 that, 1 don't think. This -- It doesn't say anything about
13 reported in the Taiwan episode.
14 a control group. He says, "I've got 108 controls," period.
14 Q And Yusho, too?
15 1 don't know what the controls were.
15 A 1 believe so.
16 Q All right. The chart on table one states that
16 Q All right. Irritated or swollen gums, can you
17 the exposed group of children, there were 32 of 108 with
17 explain the mechanism for that?
18 white eye discharge, and in the control group there were 5
18
A Same as teething in babies. The teeth come
19 of 113. Is that a symptom of which you have seen reported 19 out, the gums are irritated or swollen or maybe an added
20 in Yusho?
20 mechanism, but that is certainly a major one.
21 A Yes.
21 Q All right. Hyperpigmentation. What is that,
22
Q Can you explain the method by which the PCBs
22 hyperpigmentation?
23 with the furans and quaterphenyls cause white eye
23 A Pigmentation is coloring. Hyper means more
24 discharge?
24 coloring, excess coloring.
25 A There are -- There are glands in the eyelids
25 Q And can you explain the mechanism by which
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 125 - 128
LEXOLDMONOQ6774
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1 PCBs, furans and quaterphenyls produce that condition?
1 which bronchitis or pneumonia in the first six months is
2 A There is some deformity of the skin
2 produced by the absorption of PCBs, furans and
3 metabolism. There's some derangement of the skin
3 quaterphenyls?
4 metabolism, and some of the melanin in the skin is
4 A Well, first I'm not sure that that's the
5 overdeposited. It's oversecreted or overformed.
5 cause.
6 Q And does that give it a darker coloration?
6 Q Because?
7 A Yes. 1 don't know what happens in an
7 A Because with the absence of what appears to be
8 Oriental, but 1 think it's darker.
8 an adequate control group, 1 just don't know. Certainly
9 Q All right, sir. Deformed or small nails, can
9 babies get bronchitis in their first six months, so 1
10 you explain the mechanism by which that symptom is
10 cannot say whether this is due to PCBs or not, PCBs with
11 produced?
11 their contaminants.
12 A Well, the question of nails, eyelids, teeth,
12 Q There's 30 out of 124 compared to five out of
13 skin all come from the same embryonic layer in the fetus,
13 115?
14 and so presumably -- I'm now assuming things which 1
14 A As 1 said before, I'm not sure what this
15 shouldn't -- there is the same mechanism that causes the
15 control is, if these people--
16 deformity, the deformed, early eruption of the teeth is
16 Q All right, sir.
17 also involved in the deformity of the nails.
17 A - who had the 30 had more children or they
18 Q All right, sir. Acne?
18 were in a poor economic group, then the controls, obviously
19 A Well, that's chloracne. That's a disturbance
19 they'll have more bronchitis and pneumonia.
20 of the fact metabolism in the skin.
20 Q All right, sir. Bronchitis bad enough for two
21 Q Now we go down to the second category. The
21 days in bed, 21 out of 126 to three out of 111. Do you
22 first category was at birth. The second category is
22 find those numbers significant in the exposed group?
23 subsequent history. Is that the way you read the chart?
23 A Not unless 1 know more about the relationship
24 A Yes, it is.
24 of the exposed group to the control group.
25 Q Has bronchitis or pneumonia in first six
25 Q Seizure with fever, 15/127, 5/115. Can you
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1 months. Can you explain the relationship of PCBs, furans
1 explain the relationship of PCBs to seizure with fever?
2 and quaterphenyls to that condition?
2 A 1 can relate the relationship of bronchitis or
3
MR. CARNEY: Again you're lumping PCBs and
3 pneumonia to seizure with fever. Whenever you get an
4 furans and quaterphenyls all in the same category, and 1
4 elevated temperature in a child, you are very likely to
5 think that's an attempt to mislead the jury into thinking
5 have a seizure, but as 1 said before, 1 cannot relate the
6 that they're all the same thing.
6 seizures with fever to PCBs without knowing more about the
7 Q (By Mr. McCrea) What's the title of the
7 control group.
8 article, Doctor?
8 Q Seizure without fever, would you agree that
9 A The title of the article is "Congenital
9 there is no relative difference in those figures?
10 Poisoning by Polychlorinated Biphenyls and their
10 A That's correct.
11 Contaminants in Taiwan."
11 Q Chipped or broken teeth, 38 of 107 to 25 of
12 Q Thank you. Can you explain the method by
12 106. Would you consider that a significant elevation and
13 which the relationship of polychlorinated biphenyls and its
13 something that would concern you as the former doctor of
14 contaminants as noted by the title of the article to that
14 Monsanto or not?
15 condition?
15 A Well, I'd have to have an epidemiologist to
16 MR. CARNEY: Well, the title of the article
16 tell me whether this is statistically valid or not, but
17 doesn't spell out what the contaminants are.
17 anyway, if their teeth came out earlier, they would
18 MR. McCREA: Furans and quaterphenyls.
18 probably got a better chance of getting them chipped or
19 MR. CARNEY: Well, that wasn't in the title.
19 broken.
20 You just read the title.
20 Q 1 see. Hair loss, 14 of 115 compared to two
21 Q (By Mr. McCrea) You may proceed.
21 of 105. Do those figures look significant to you, and if
22 A Say the questionover.
22 so, can you explain the mechanism by which PCBs are related
23 Q All right, sir.
23 to hair loss?
24 A 1 get lost in this.
24 A No, 1 can't, but again hair is in the same
25 Q All right. Can you explain the mechanism by
25 grouping as teeth, skin, nails. It's all part of the
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 129 - 132
LEXOLDMONOQ6775
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1 ectoderm of the body.
1 in loss of muscle strength and if so, the mechanism by
2 Q Acne scars, 11 and 115, 0/106. Do you feel
2 which that -
3 that you've discussed that adequately in the previous
3 A First of all, 1 would have to see more -
4 testimony in this deposition?
4 MR. CARNEY: Objection to the form.
5 A Well, yes, except 1 do not know what they are
5 A 1 would have to see more data than this is
6 calling acne scars because other reports, especially one by
6 here. Secondly, they don't say how much muscle strength it
7 Kimbrough, did not show any acne scars and anything like
7 is, what their perimeters of testing for muscle strength.
8 this, this percentage. In other words, 16 people with acne
8 So 1 would not be in a position to answer that question.
9 and subsequently they had 11 of those had scars. Kimbrough 9
Q (By Mr. McCrea) Joint pain. Do you have an
10 had 39 people with acne and she had very, very few scars. 10 opinion, Dr. Kelly, if exposure to PCBs, just the PCBs can
11 So 1 don't know what that means.
11 result in joint pain?
12 Q What's the date of this article?
12 A No, 1 do not think 1 can.
13 A '88, but 1 don't know what she was, what parts
13 Q Do you have an opinion if exposure to PCBs
14 she referred to.
14 with furans and quaterphenyls with furans at a level of .6
15 Q Loss of muscle strength. Do you have an
15 milligrams can result in joint pain?
16 opinion, Dr. Kelly, if exposure to PCBs, furans and
16 A 1 would have to reference this some more. I'm
17 quaterphenyls can result in loss of muscle strength?
17 not sure whether that was true or not.
18 MR. CARNEY: Are you saying based on this
18 Q Have you ever heard of children being born
19 data?
19 with joint pain?
20 MR. McCREA: No, does he have an opinion. 20 A I'm not a pediatrician. 1 don't know much
21 A 1 don't know, but 1 don't know how -- Oh,
21 about children and joint pains. 1 don't know.
22 sorry.
22 MR. CARNEY: I'm not sure -
23
MR. CARNEY: I'm sorry. Again you're talking
23 A As 1 understand, none of these were born with
24 about the Japanese or the Taiwanese PCBs with the heavy 24 joint pains. They were not at birth. We've seen at the
25 concentrations of furans, or are you talking about the
25 top grouping it says at birth. 1 don't see joint pains up
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1 Monsanto PCBs with very few furans.
1 there. It was all subsequent history.
2 MR. McCREA: I'm talking about if he has--
2 Q (By Mr. McCrea) 1 stand corrected. Have you
3 MR. CARNEY: Which type of furans?
3 ever heard of children having joint pain?
4 MR. McCREA: I'm talking about the PCBs
4 A Lots of them. I've had it myself when 1 was a
5 contaminated with furans and quaterphenyls, if he has an
5 child.
6 opinion if that can result in a loss of muscle strength.
6 Q All right, sir. Generalized itching. Do you
7 MR. CARNEY: Well, I'm going to object. 1
7 have an opinion if PCBs contaminated with furans and
8 don't think you've given him enough information as to what
8 quaterphenyls can result in generalized itching?
9 kind of furans, as to the dose. Obviously you can feed any
9
MR. CARNEY: Same objection.
10 species including a human enough of almost any product and 10
A 1 have no opinion. On the basis of this, 1
11 you can get adverse health effects as you well know, so you 11 would say 1 do not accept this as a valid authority on
12 haven't given him enough information.
12 that.
13
MR. McCREA: Well, at a dose of .6 milligrams
13 Q (By Mr. McCrea) All right. Skin abscesses or
14 to the mother of a furans which would be, if you had one
14 boils.
15 ounce, that would be sufficient to cause toxic effects in
15 A Yes, 1 think that --whether 11 out of 103 or
16 50,000 people, with that dose.
16 26 out of 116 is statistically valid, 1 don't, I'd have to
17
MR. CARNEY: I'm going to object to the form.
17 refer to an epidemiologist, but certainly if they have
18 It's very ambiguous now as to what the question is, but if
18 acne, if they have acne scars, obviously they have a
19 you understand it, you can answer.
19 history of skin abscesses.
20 A Well, I'd like to have it repeated so we'll be
20 Q Warts?
21 sure 1 can understand it. We were talking about loss of
21 A 1 have not seen that as a prominent feature in
22 muscle strains, 1 believe.
22 any of the articles that I've seen about contaminated PCBs
23 Q (By Mr. McCrea) Yes, sir. Do you have an
23 with benzofurans.
24 opinion if exposure to PCBs, furans and quaterphenyls with 24
Q All right, sir. Can you go to the table two?
25 a dose of furans at .6 milligrams to the mother can result
25 A Yes, sir.
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
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LEXOLDMONOQ6776
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1 Q Do you have an opinion, Doctor, if any of the
1 A Well, the genital area is obvious. The
2 physical signs listed in the column on table two can be
2 perineal area is the area between the genitals and the
3 caused by exposure to PCBs contaminated with .6 milligrams 3 rectum.
4 furans and quaterphenyls? And just go down the list and 4 Q All right, sir.
5 give us your opinion. First, gum hypertrophy.
5 A In the skin.
6 A Yes, that could be caused.
6 Q All right. Pigmented or deformed nails?
7 Q Tooth chipping?
7 A Yes, that has occurred in the Yusho incident,
8
MR. CARNEY: Are you asking him whether based
8 also.
9 on this data he comes to the conclusion that that can be
9 Q Fingers?
10 caused because 1 think he's already said that this data,
10 A Yes, sir.
11 there's no control group information to really make this
11 Q Toes?
12 data significant unless he knows what the control group
12 A Yes, sir.
13 was, where, what population was used. Are you just asking 13
MR. CARNEY: 1 think we're not just talking
14 for his opinion?
14 about fingers ands toes, but the nails. Isn't that right?
15 MR. McCREA: No, I'm just asking for his
15 We don't want to confuse the jury.
16 opinion.
16 Q (By Mr. McCrea) It says nails on fingers and
17 MR. CARNEY: Okay.
17 the nails on the toes; correct? Right? Not the skin.
18 Q (By Mr. McCrea) Gum hypertrophy you've
18 Conjunctivitis or cysts?
19 answered. Tooth chipping?
19 A Well, this -- According to this, there is no
20 A 1 don't know about that.
20 difference.
21 Q Intraoral hyperpigmentation?
21 Q All right. Those numbers are just about the
22 A Yes, 1 think that could be associated.
22 same, aren't they?
23 Q Caries?
23 A 1 would say so.
24 A 1 would certainly doubt that.
24 Q All right. Can you pronounce the next one for
25 Q Acne?
25 us and tell us what that is?
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1
MR. CARNEY: Just so -- Why don't you, to help
1 A Lymphadenopathy. That means swollen lymph
2 the jury understand what caries is, you might ask what is
2 glands.
3 it.
3 Q Do you have an opinion if that can be caused
4 Q (By Mr. McCrea) What are caries?
4 by exposure to PCBs contaminated with furans at .6 parts
5 A Holes in your teeth.
5 per milligram?
6 MR. CARNEY: Cavity, 1 think.
6 A It depends on where the lymph glands are that
7 A Cavities in your teeth.
7 are swollen. In other words, if you have infected cysts
8 Q (By Mr. McCrea) Okay. Acne or acne scars?
8 from chloracne in your face, you will have swollen lymph
9 A Here again, this is very confusing because
9 glands in you neck. So I'd have to know -- Those would be
10 subsequent history showed no acne scars in this supposably 10 connected. If only chloracne was on the face and you had
11 control group, and then a selected finding shows ten out of 11 swollen lymph glands in your perineal region or in your
12 106. 1 wonder where those ten came from or when they
12 groin or under your arm, that would not be connected.
13 showed up. As 1 said, no acne scars in the first table and 13 Q Eyebrow flare?
14 ten of them in the second table, so 1 don't know.
14 A That's a physical condition that 1 don't know
15 Q All right, sir. Fair enough.
15 much about. I'll have to read what he means by eyebrow
16 Hyperpigmentation?
16 flare. 1 don't know what he's talking about on eyebrow
17 A Hyperpigmentation of the face or head has
17 flare, so 1 can't comment.
18 occurred in chloracne.
18 Q Lungs not clear to auscultation?
19 Q Okay. What about perineal genital? What is
19 A Auscultation. Well, here again if you have
20 that?
20 bronchitis and you have repeated or pneumonia, your lungs
21 A 1 have not seen it. What did you say? Did
21 would not be clear.
22 you ask a question?
22 Q Do you have an opinion if PCBs contaminated
23 Q Yeah. Right here.
23 with furans and quaterphenyls can produce that condition?
24 A What is what?
24 A I'm not sure that they can.
25 Q What is that?
25 Q Can you pronounce the next one for us?
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 137-140
LEXOLDMONOQ6777
Page 141 1 A Hirsutism. That means excess hair. 2 Q Do you have an opinion if PCBs contaminated 3 with furans and quaterphenyls can produce that condition? 4 A Yes, it can. 5 Q Hyper -- Can you pronounce that? 6 A Telorism. I'm sorry. 1 just can't define 7 that for you. 8 Q All right. And the last one, Doctor? 9 A Clinodactyly. 1 think that is joining 10 together of the fingers of some type, but 1 don't see what 11 he is talking about there. 12 Q All right. Doctor, the last chart is table 13 three which deals with developmental testing and behavioral 14 assessment. Have you ever performed any similar type tests 15 on workers at Monsanto? 16 A No, sir. 17 Q Have you ever read any reports out of Yusho or 18 any other area that discussed these particular testing and 19 behavioral assessments when individuals were exposed to 20 PCBs, furans, quaterphenyls? 21 A If I've read them 1 don't, 1 don't recall 22 them. 23 Q Can you interpret for the jury this 24 information? 25 A Well, 1 can only interpret the center, the
Page 143 1 think we ought to know what these things are. Otherwise,! 2 don't think it helps the jury to know that somebody's 3 slightly higher or slightly lower. 4 Q (By Mr. McCrea) Do you know what those are, 5 Doctor? 6 A 1 have -- No, 1 don't. 7 Q All right, sir. But at any rate, the scores 8 were higher for the control group than the exposed group? 9 MR. CARNEY: I'm going to object. There's no 10 evidence as to whether it's better to have higher or lower. 11 We again have the problem, we don't know what the control 12 group, where they came from, which population, what their 13 educational levels were, what their environment was. So it 14 really -- Just to read off some scores that are very close 15 to the same anyway doesn't really give any relevance to 16 anybody. 17 Q (By Mr. McCrea) Doctor, have PCBs been 18 implicated in the reduction of IQ? 19 A Not to my knowledge, and by the way, if 1 20 could explain that, the difference here, these exposed and 21 controls wasn't very marked, the difference between 100, 22 plus or minus two and a half. That means you could have 23 102.5, 106 plus or minus 2.4 That could mean you could 24 have 103.6, so they're the same, same thing in all three of 25 them. So 1 don't think it shows any difference.
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1 second one which is the WISC. Let's see which one that is.
1
Q Does that - Go ahead.
2 MR. CARNEY: Wechsler.
2 A But 1 think you would want a psychologist who
3 A Wechsler Intelligence Scale for Children.
3 these people are presumably -- 1 mean, 1 don't know who
4 Q (By Mr. McCrea) All right, sir. Can you
4 they are, but it doesn't look like very much difference to
5 interpret --
5 me.
6 A They're all the same. There's no change.
6 Q Okay. All right. And the IQ, 85 to 89;
7 Q All right. No change in what?
7 correct? You're familiar with the Stanford IQ test?
8 A Between the exposed as the control group.
8 A Yes.
9 Q Okay. And the exposed for verbal IQ, that's
9 Q In all instances the exposed group had lower
10 the same; correct? 82 to 82?
10 scores except for verbal IQ which was identical. Is that
11 A 82/82.
11 correct?
12 Q The performance IQ, exposed is 90, control is
12
MR. CARNEY: I'm going to object to that.
13 97, seven points higher?
13 A No, it isn't correct. It isn't correct
14 A Plus or minus 2.7, plus or minus 2.9.
14 because if you have just the fact that you have a lower
15 Q Correct. Full IQ, the exposed, 84; control,
15 score does not mean that's statistically valid. 1 can't
16 88, plus or minus 2.9, plus or minus 2.4?
16 imagine anybody putting this down without having a
17 A That could be explained. 1 don't know how
17 probability factor on these things.
18 long after they did this, whether the children had the same
18
Q (By Mr. McCrea) Well, isn't that discussed in
19 education, whether the children had the same household
19 the article?
20 motivation. 1 just don't know.
20 A 1 don't know. Let's go back to the article.
21 Q And on the Bayley test, the exposed, 100;
21 Q All right. Before we do that, can you also
22 control, 106. Controls tested higher?
22 then go down the last category which is Rutter? Are you
23 MR. CARNEY: Let me object.
23 familiar with that, Doctor?
24 Q (By Mr. McCrea) Is that -
24 A No, 1 am not.
25 MR. CARNEY: What are the Bayley tests? 1
25 Q In this instance the control group, the
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 141-144
LEXOLDMONOQ6778
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1 exposed group had higher scores, more health problems,
1 question. You haven't defined your term. It's vague and
2 habits, behavior than the control group. Is that --Just a
2 ambiguous as to what you mean by significant. What type of
3 second, Tom. Is that a fair analysis of the data?
3 PCBs?
4 MR. CARNEY: No. I'm going to object here
4 A 1 suppose if you did absorb -- Are you talking
5 because first of all, the witness doesn't know what the,
5 about humans now?
6 isn't familiar with that test, and second of all, he's
6 MR. McCREA: Yes.
7 already testified that the control groups, he doesn't know
7
MR. CARNEY: I'm going to object. If it calls
8 what was involved with the control group, where they came
8 for speculation, 1 would object to asking the witness a
9 from. So you're asking him to draw a conclusion that's
9 question that would cause him to have to speculate. If
10 impossible to draw a conclusion on.
10 there's no data on it, 1 would not speculate about
11 A And he's got a different control group down at
11 something.
12 this bottom one. 1 mean, he's got 109 of 120, and he was
12
Q (By Mr. McCrea) You may answer.
13 talking about 113 all the way along or 106, and now he's up 13
A Can significant?
14 to 120. It's got me completely confused, and I'm surprised 14
Q Yes.
15 "Science" published it.
15 A It may, but 1 don't know whetherit would or
16 MR. McCREA: All right, sir.
16 not.
17
MR. CARNEY: Let me just ask you, Mr. McCrea,
17
Q Doctor, can significant absorption of PCBs
18 were those last three pages that you've been putting up
18 result in decreased - and you'll have to help me out a
19 there, were they a part of that article?
19 little bit with these words -- thyroglobulin proteolysis?
20
MR. McCREA: He already explained that, Tom,
20 A That is - Those are enzymes, and 1 don't
21 if you were listening.
21 know. 1 am not an enzymologist. 1 cannot answer that
22 MR. CARNEY: Well, 1 thought you said all
22 question.
23 those pages were a part of that article.
23 Q Can significant absorption of PCBs result in
24
MR. McCREA: They were blow-ups of the chart.
24 metabolism?
25 MR. CARNEY: Okay. Well, when you first
25 A Can they result in metabolism?
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1 showed it to the doctor you said all those pages were a
1 Q Altered metabolism.
2 part of the article, and now it turns out three of them
2 A Altered metabolism? They could result in
3 weren't.
3 altered metabolism of the skin. They could result in
4 MR. McCREA: Well, if you would listen to the
4 altered metabolism of some liver enzymes. Whether that's
5 testimony, 1 asked him if the blow-ups at the back were
5 any particular harm or not to the individual is certainly
6 reflected the charts on page two and he said yes, they did.
6 not definite.
7 Now, if you'd like to look at them, you may.
7 Q All right. Doctor, can you refer to Exhibit
8 MR. CARNEY: No. All I'm saying is that 1
8 K-2?
9 thought this was a six page article. It turns out it was a
9 A If you point it, give it to me.
10 three page.
10 Q Yes, sir, 1 will.
11
MR. McCREA: Well, take your time and look at
11 A 1 have K-6.
12 them.
12 Q I've got this, a copy of K-2.
13 MR. CARNEY: No, 1 already pointed it out to
13 A Yes, sir, I'm referring to K-2.
14 you. You said they were all a part of the article, and it
14 Q Doctor, you discussed this on direct
15 turns out it was just the three pages. You've added three
15 examination at some length, did you not?
16 additional blow-up pages.
16 A Yes, 1 did.
17 Q (By Mr. McCrea) Doctor, did you understand
17 Q And 1 believe these workers, to recap the
18 when you were looking at the charts that the charts up here 18 testimony and we're referring to Exhibit K-2, an article
19 were blow-ups of the charts on page two?
19 title an "An Acneform Dermatergosis"?
20 MR. CARNEY: I'm not disputing that.
20 A Gosis.
21 A Yes, 1 did understand.
21 Q By Jack W. Jones, M.D, and Herbert S. Alden,
22 Q (By Mr. McCrea) Thank you. Doctor, can
22 M.D., Atlanta, Georgia?
23 absorption of significant amount of PCBs result in immune
23
A Yes, sir.
24 suppression?
24 Q Involving workers at the Swann Chemical Plant
25 MR. CARNEY: I'm going to object to the
25 which was purchased in 1933 or'4 by Monsanto?
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 145 - 148
LEXOLDMONOQ6779
Page 149
Page 151
1 A I think it's later than '34. I think it's '34
1 "Two patients whose skins were diffusely pigmented." Can
2 or'35. I'm not sure.
2 PCBs cause skin to be diffusely pigmented?
3 Q All right. And Dr. Jones and Dr. Alden
3 A Then again I don't know what you mean by
4 examined these workers and then wrote this article?
4 diffusely. If you -- It can be pigmented in an area of one
5 A Yes.
5 or two square inches. The ones that I have seen have been,
6 Q You later examined the same workers?
6 have not been pigmented, but it can. I would imagine it
7 A I didn't say I examined them. I said I saw
7 can because chloracne has other things that cause chloracne
8 some of them. I observed some of them. I did not examine 8 and have caused pigmentation.
9 them.
9 Q What do we mean, pigmentation? If you look
10 Q I stand corrected. You observed them and the
10 at --
11 skin conditions had resolved?
11 A It's darker. The skin looks like it's a
12 A That's correct.
12 collection of blackheads.
13 Q So you, you actually talked to the, some of
13 Q Okay. And it says dark, rough and dry, "Whose
14 these workers who Dr. Jones and Dr. Alden wrote about?
14 skins were diffusely pigmented, dark, rough and dry." Can
15 A Yes, that's correct.
15 PCBs cause those symptoms?
16 Q And in this article on page one which I guess
16 A Well, pigmentation is dark. I mean, that's
17 doesn't have a number, but would be, well, for page one?
17 the same thing. Well, rough and dry, I --
18 A 1920, yes, is my number on it.
18 Q All right.
19 Q Okay. It -- In the second paragraph, the
19 A I don't know what the, what he's describing
20 second sentence states, "This term chloracne was first used 20 there because if you put paint remover on your skin, you'll
21 by" - Is that --
21 get rough and dry. I guess you could get it. By the way,
22 A Herxheimer.
22 we are talking now about chlorine compounds that were being
23 Q "Herxheimer in 1899 to describe an eruption
23 used 30 years before PCBs were invented.
24 composed of comedones." What is that, comedones?
24 Q Right.
25 A Comedones is a plugged up sebaceous gland.
25 A Okay.
Page 150
Page 152
1 Q And -
1 Q And my question is not directed to anything
2 A Sebaceous gland is a fatty skin gland.
2 other than PCBs.
3 Q Can PCBs cause that?
3 A Okay.
4 A Yes.
4 Q Fair enough. I understand that. That's a
5 Q "And small sebaceous pustules."
5 good observation. All right. This paragraph is not
6 A That's when the gland gets affected.
6 talking about PCBs.
7 Q Can PCBs cause that?
7 A No, but I wanted the jury to be clear.
8 A Yes.
8 Q And I agree. Now, we've just got one minute.
9 Q What does a comedone like like?
9 Can PCBs cause small tenacious comedones?
10
A It looks like a white head instead of a black 10
A I don't know what he means by tenacious.
11 head.
11 That's -- If he means by that it stays around a long time,
12 Q And what does a small sebaceous pustule look: 12 that could be true, if that's what he means by tenacious.
13 like?
13 Q All right. Can PCBs do that?
14 A A small hickey.
14 A Yes, sometimes.
15 Q Like a little red mark?
15 Q Can PCBs cause follicular abscesses?
16 A Well, a tiny boil.
16 A Well, if any skin lesion gets infected, one
17 Q All right, sir.
17 gets an abscess. Follicular abscess is a hair follicle on
18 A A tiny pimple or it could be larger pimple,
18 the skin.
19 but it looks like a pimple.
19 Q All right. Can PCBs produce that?
20 Q "That occurred on the arms and faces."
20 A Well, if comedone becomes affected, infected,
21 A Yes.
21 yes, it can become a pustular. We're just repeating
22 Q And can PCBs cause those comedones and 22 themselves down the way.
23 pustules on the arms and faces?
23 MR. McCREA: All right. Doctor, we're out of
24 A Yes.
24 time here.
25
Q Going on down in that same paragraph said, 25
(Thereupon, a short colloquy was had between counsel
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 149 - 152
LEXOLDMON006780
Page 153
Page 155
1 and the witness, off the record.)
1 ORIGINAL TRANSCRIPT TAXED IN FAVOR OF:
2
MR. CARNEY: We've been talking off the record
2 Mr. Thomas M. Carney
3 about rescheduling, and Mr. McCrea is not available
3 Husch & Eppenberger
4 tomorrow although everybody else would be tomorrow, but we 4 190 Carondelet Plaza, Suite 600
5 agreed, 1 think, that we would stop at this point because
5 St. Louis, MO 63105
6 the studio needs this room and would like this room for the
6 Total:
7 majority leader of the House of Representatives to give a
7
8 videotape, and so we've agreed to stop now, and the 12th
8 Upon delivery of transcripts, the above
9 which is a Tuesday, the 12th of June at 9:00 the same place 9 charges had not been paid. It is anticipated
10 we will finish up the deposition. Is that all right?
10 that all charges will be paid in the normal course
11 MR. McCREA: That's correct.
11 of business.
12 MR. CARNEY: Okay. 0 ****
12 GORE PERRY GATEWAY & LIPA REPORTING COMPANY 13 515 Olive Street, Suite 700
14 14 St. Louis, Missouri 63101
15 15 IN WITNESS WHEREOF, 1 have hereunto set
16
16 mv hand and seal on this
dav of
17 17 Commission expires
18 18
19 19 Notary Public
20 20
21 21
22 22
23 23
24 24
25 25
Page 154 1 COURT MEMO 2 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 3 STATE OF MISSOURI
A
5 Glenn Brown, et al. vs. Monsanto Company 6 862-00694 / 8 CERTIFICATE OF OFFICER AND 9 STATEMENT OF DEPOSITION CHARGES 10 11 DEPOSITION OF DR. R. EMMET KELLY 12 TAKEN ON BEHALF OF THE DEFENDANT 13 6/1/1990 14 Name and address of person or firm having custody of 15 the original transcript: 16 Mr. Thomas M. Carney 17 Husch & Eppenberger 18 190 Carondelet Plaza, Suite 600 19 St. Louis, MO 63105 20 21 22 23 24 25
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
Pages 153 - 155
LEXOLDMONOQ6781
[& - 515]
Transcript Word Index
&
& 3:19,22 154:17 155:3,12
0
0/106 133:2
0001 33:21
02 24:6,16_________________
1
1 1:15,30 2:16 3:9 26:18
1,000 23:12 25:5,5,5 35:1,2,4 36:16 50:4
1/1,000 33:13
1/10,000 30:24 31:6,13 33:17 37:12
1/100 31:5,12
1/2,000 33:22
1/20,000 33:23
10 80:9,12,20 89:19,24,24 91:22
10,000 34:5,14 35:10,21 36:7,10 36:11 56:16,24
100 3:23 74:23 142:21 143:21
102.5 143:23
103 136:15
103.6 143:24
105 132:21
106 132:12 138:12 142:22 143:23 145:13
107 132:11
108 125:12 126:7,14,17
109 55:8 145:12
11 133:2,9 136:15
111 131:21
113 1976
3
126:19 145:13
18:21
3,375
115 1977
23:3,9 24:2 28:16
131:13 132:20 133:2
19:7
3.2
116 1982
25:8,19 29:8,16
136:16
60:17
3.3
118 1984
23:17
2:17
15:6 23:2 25:23 45:22
3.3.
119
102:17
23:16
3:19 1987
30
12
45:21
20:2 36:18 50:3,3,4 77:8,25
41:13
1990
90:16 131:12,17 151:23
120
1:15 3:9 26:18
30,000
145:12,14
2 36:20 50:5
124 131:12
2 300 2:17,26 25:6,7 29:8,13,15 28:16 58:14
125
148:8,12,13,18
314
55:9,10 126
131:21 12th
153:8,9
2,000 33:18,20 57:25 58:1,9
2.4 142:16 143:23
2.7
1:27 32
126:17 34
149:1,1
13 41:6,10 51:25
14 132:20
15/127
142:14 2.9
142:16 2.9.
142:14
3-4-7-8 39:21
35 149:2
38
131:25
2/10
90:16 132:11
1506 1:25
16 24:7 25:8 84:8 85:15 133:8
18 10:14 28:24 29:1 81:19
1899 149:23
190 154:18 155:4
1907 3:10
1920 149:18
1933
25:19
39
20 46:13 133:10
10:14
4
200 4
24:3,6,14 25:2,3,4 58:13,19 2:13 148:25
84:11,13,20 85:5,22
4,000
200,000
31:4 33:19
24:4 40
200ths
2:16 33:19
24:16
400
21 85:16
131:21
47402
2-3-7-8
3:20
40:1
24 5
148:25 1936
106:1,15 195
23:3,21 24:1,3 28:16
76:21 240
57:24 58:17 25
90:1691:12 132:11
5 126:18
5/115 131:25
50
1972
26
33:13 94:20
20:3 78:11 80:9,12 83:3 85:1,11,14 89:16,20,25
136:16 27
50,000 50:5,11 51:3,5,11 134:16
91:22 1974
17:12 19:21 20:3 22:1,2,6
40:25 81:23 83:24 84:2,2 87:12 89:23 105:22 109:8 291
500 84:11,14,20 85:5,16,18,22 86:3 87:5
40:5 106:1,15
41:18,19
515
1:25 155:13
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6782
[6 - analytical]
44:18 49:20 50:1,9 51:5,8 79:13 134:13,25 135:14 137:3 140:4 148:11 6/1/1990 154:13 6/10 50:5 6:00 3:9 600 58:20,23 59:21 60:6 61:20 62:20 154:18 155:4 6-1-90 40:14 118:14 621-2571 1:27 63101 1:26 155:14 63102 3:23 63105 154:19 155:5 68 119:2 69 119:2___________________
7
70 39:12
700 58:12,20,23 155:13
70s 10:6,16 14:24,24 15:4,12 18:6,10,11,17 37:7 62:8
72 80:20 83:18,20 92:1
74 17:12,13 18:13 19:17
77 19:8
79 119:4___________________
8
8:00 3:9
800 57:24
82 142:10,10
82/82 142:11
84 15:3 27:6 60:18 142:15
85 accidental
144:6
47:22
850 account
58:23
52:17
862-00694
accuracy
1:5 2:5 3:5 154:6
85:6
88 accurate
45:21 133:13 142:16
85:7
89 accusing
144:6
96:10
9
9:00 1539
90 14212
onn
58:23 59:21 60:6 61:21 62:21 920 28:17,18,19 97 142:13
a
acid 64:1 75:24,25 76:2
acknowledge 38:1 117:21
acne 127:2 129:18 133:2,6,7,8 133:10 136:18,18 137:25 138:8,8,10,13
acneform 148:19
acquire 6:23
act 18:21 37:11
a.m.
action
3:9 75:23 76:1,6,10,13,14
abdomen
77:13,15
82:17 86:24
acute
ability
5:15
95:23
adapted
able
29:19
51:20 53:3,5 87:7 121:17 add
abscess
39:2 71:18 78:23
152:17,17
added
abscesses
54:7 128:19 146:15
136:13,19 152:15
additional
absence 5:15 131:7
53:14 146:16 address
absolute
6:21 154:14
54:23
addressed
absolutely
93:22 96:13
69:14 86:15
adequate
absorb
131:8
20:16 147:4
adequately
absorbed
133:3
20:11,1376:1699:18 111:9 adverse
112:4 115:13
134:11
absorption
affect
21:1 99:25 110:15 112:2
79:4 85:6 111:24
113:4 114:11 115:7 116:3,7 afraid
131:2 146:23 147:17,23
55:17
accept
age
36:2 136:11
126:12
acceptable
agency
107:11
49:15 119:24
agent 25:25 26:9 79:6 102:19,22 103:15 104:3
ago 10:14,1453:981:19 102:14
agree 93:19 120:16 124:3 132:8 152:8
agreeable 75:19
agreed 153:5,8
ahead 96:2 144:1
al 1:3 2:3 3:3,15 154:5
alabama 73:14
alarming 88:4
alden 148:21 149:3,14
alert 5:14
alexander 43:8
alike 59:3
allow 39:6
alter 111:2,4,10
altered 113:6,10,16 114:13,18,19 115:5 116:8,16,19 148:1,2 148:3,4
ambiguous 92:21 95:24 98:20 106:3 114:15 134:18 147:2
american 23:1 26:7 46:19 102:16
amount 11:10 12:4 17:10,24 19:10 23:19 25:10 26:25 27:10 29:6,23 35:3,3 37:10,21 48:7 62:3 77:10 78:6,16 86:2 95:9 101:19 110:15 115:19 146:23
amounts 11:21 13:8 26:2 113:5 114:7,12
analysis 83:16 145:3
analytical 10:13 18:6,8 21:1822:10 64:6 86:20
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6783
[analyze - behavioral]
analyze
approximately
associates
86:10
24:13 54:21
73:5 74:23 75:3
ands
april
assume
139:14
83:18
25:3 32:23 51:15,16 52:6
animal
area
56:23 57:1 107:2 125:18
21:1 72:4 78:21 116:11,13 58:22 107:13 139:1,2,2 assuming
annals
141:18 151:4
66:21 115:19 127:12
25:22
areas
129:14
anniston
59:9,12
assumption
65:8 73:14
arm
57:2,2 66:20
answer
75:24 140:12
assumptions
5:46:1,8 7:12 16:4,13,14 arms
125:23
16:17 19:1 27:731:19
150:20,23
assure
35:14 48:19 49:8 52:9 53:5 arose
49:21
53:13,15,19 54:23 55:11,18 64:23
ate
55:23 56:23 68:3,14,19 arranged
45:1,1548:1590:13
69:19 70:1,11 75:8 88:22
39:15
atlanta
89:5,9 90:11 91:20 92:24 article
73:14 74:16 148:22
93:12 95:7,15,16 96:12,13 28:6 35:8 46:9,18,19,21 atom
96:19,21,22,24,24 97:5,6
47:6,8,9,11,15 51:16 52:4,5 54:7
110:12 111:25 114:16,25
102:12,14,15 118:15 119:6 atoms
116:6 122:4 134:19 135:8 120:5,13 121:5,7,19,20,23 39:15,15,22 52:23
147:12,21
121:25 122:3,4,6,12 123:11 atrophy
answered
123:15,21 124:2,20 125:24 26:3,4
93:11 95:22 96:1,6,15 97:3 125:24 130:8,9,14,16
attach
137:19
133:12 144:19,20 145:19
52:23
answering
145:23 146:2,9,14 148:18 attached
53:8 95:21,25 96:5 98:2
149:4,16
120:24
answers
articles
attempt
5:21,23 39:8 43:12 73:23
16:19,25 17:6,6 28:7,13
20:24 130:5
97:6,8,8
45:18 49:14,18 75:1 136:22 attempting
anticipated
aside
37:24
155:9
87:2 attention
anybody
asked
120:12
7:4 16:5 30:7 64:21 68:3
4:13,17,19,25 5:2,8,12,19 attorney
69:8 91:10 95:25 104:6
5:25 6:10,24 7:15 8:10,13 5:3
105:1 106:7 123:7 143:16 17:15,16 22:20 27:24 31:16 attorneys
144:16
34:24 38:17,22 43:24 50:21 4:22 5:6 6:20 7:3,6
anyway
53:12,23 55:15 61:9 63:5 auscultation
132:17 143:15
63:17 64:22 68:16 78:2
140:18,19
apart
82:6 90:17,18 93:13 96:23 authenticate
75:23
146:5
121:17
appeared
asking
authenticated
21:20
5:20 6:23 28:9,14 31:18
121:21 123:8
appears
32:1642:1,3 50:1351:15 authenticity
122:6 131:7
52:6 55:21 67:18 90:7
122:19
apples
95:20 97:25 105:14 113:23 author
31:9
119:21,23 121:20 124:22
41:22 46:20 51:21 52:3
appreciate
137:8,13,15 145:9 147:8
79:21
106:14
assessment
authoritative
approach
141:14
123:18
109:24
assessments
authority
approached
141:19
136:11
110:1
associated
authors
appropriately
9:3 101:13 111:11 137:22 32:2 45:18,22,23 119:5,9
50:21
119:10 120:18 122:12
authors (cont.) 123:6 124:21
available 153:3
average 27:4
avian 116:10___________________
b
babies 46:13 128:18 131:9
back 27:6 30:6 67:21 79:8,9 83:9 83:15,17 95:15 105:6 114:10 144:20 146:5
background 84:16 85:24
bad 131:20
ballpark 22:21 56:9
bare 101:7
barrier 76:18
based 15:16 25:21 27:17 34:13,15 35:7,8,8,19 87:2 92:18 93:14 94:9,10 105:7,8,11 105:11 133:18 137:8
basis 26:6 62:23 105:17 136:10
basket 39:12
batch 11:16,17
batches 11:11
battery 82:23
bay ley 142:21,25
bed 131:21
beg 80:2 111:3 117:1
beginning 34:3 120:14
behalf 3:16 38:18 53:18 64:25 154:12
behavior 145:2
behavioral 141:13,19
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6784
[beings - carondelet]
beings
blood
bring
calling
116:22
81:15 82:20 83:8 86:3 87:5 42:21 86:22
133:6
believe
87:9,14 88:3,9,16,16,18,24 bringing
calls
22:2,3 42:21 64:1 84:4
89:1
56:8
147:7
90:10 92:3,14 98:5 108:13 bloomington
broadway
camera
112:3 119:23 128:15
3:20 65:23 66:1,1 104:17
3:23
72:23 124:9
134:22 148:17
blow
broken
capacitor
benzene
122:7,23,24 145:24 146:5 132:11,19
42:25 43:2,6 64:8 65:24
14:11,13 54:7
146:16,19
bromated
capacitors
benzenes
blowing
9:12,25
64:4
7:21
123:6
brominated
carbon
benzofurans
blown
8:23
7:24 8:8,15,20 9:10,14 58:3
22:19 90:13 127:2 136:23 122:9
bromine
58:4,4,4,5 59:22,23,23
best
board
9:1,15
79:24 80:4
10:19 11:1328:1539:16
13:13 15:9,13,19,23,24 bronchitis
cardiovascular
45:1863:13,18 85:11,14
16:1,6
129:25 131:1,9,19,20 132:2 82:5
88:11 95:22
body
140:20
caries
better
20:11,13,16,19 75:23 76:7 brought
137:23 138:2,4
95:24 102:6 132:18 143:10 77:19 78:7 79:1 99:25
68:21
carney
big
103:3 110:19 111:1,7,8,12 brown
3:22 4:18,24 5:18 7:4,9
126:1
111:19,20 112:4,24 113:5 1:3 2:3 3:3,15 71:2 154:5
15:11 16:12 19:1421:2
billion
113:14 114:11 116:3,7,18 building
24:17,22 27:2,23 28:4
84:11,11,14,20 85:5,16,17 125:13 126:10 133:1
24:1,21 59:5,14,18 113:13 29:17 31:8,15,21 32:1,7,11
85:19,22 86:3 87:5
boil
bulk
32:15,18,25 33:3 34:19
binding
150:16
73:9
36:4,24 37:5,8,13,16 38:2,3
116:4
boils
bunch
38:7 39:6 40:18,20,21 41:4
bio
136:14
30:5 108:11 109:20
41:9 42:3,6 43:19,23 44:19
73:2 74:22 75:2 78:10
bone
burn
48:10,18 50:12 51:12,14,20
biphenyls
116:21
75:25
52:1 53:8,12 55:3 57:11
47:13 56:6 60:1 119:7
book
burned
61:13 67:7,25 69:4 70:9
120:7 130:10,13
17:5 42:12
58:2
71:11,1472:1,10,1273:7
birds
booklet
burning
75:14,18 79:7 86:13,18
116:10
40:19,22,23,24 41:1 42:12 62:20 63:21 65:15
90:3 92:5,9,20 93:16,20,23
birth
42:16
business
94:11,17 95:5,18 96:9 97:4
27:11,22 30:21 33:9 34:7 born
18:9,12 155:11
97:16,25 98:7,19 99:1,6,13
34:15,22 44:17,20 45:1,5,6 44:25 45:15 117:10,17
c
45:11 120:10 124:12 128:2 129:22 135:24,25 bit
121:8 122:13 125:19 128:3 128:3 135:18,23 bottom
calcium 116:8,16,17
calculate
70:24 93:18 96:7 114:3 147:19
41:1879:18 145:12 bought
23:19 26:13 49:25 50:15 calculating
black
66:17 70:8
29:5
150:10 blackheads
151:12 blair
43:8
boulevard 10:25
brain 79:4,4 103:18,19 104:9
break
calculation 51:4
calculations 26:17,22 27:15 35:9,13,13 35:18,24 36:1,8,12 50:17
blame 32:4
blamed 32:2,2
blames
24:20,22,23 27:25 40:7 115:2 breaks 41:16 breath
50:18 calculator
23:22,24 24:18,21 caliber
16:23
31:25
98:12 101:18
call
blanket 39:19 55:18
breed 20:17
16:13 81:23 100:12 called
100:2,21,24 102:2,6,13 103:25 104:14,18 106:2,19 106:24 109:12 110:6,10 112:15 113:19 114:2,4,14 114:21 115:20 116:23 117:22 118:11,22 121:2,12 122:1,17 123:3,14 124:1,7 124:19 125:21,23 127:11 127:17,25 128:4,9 130:3,16 130:19 133:18,23 134:3,7 134:17 135:4,22 136:9 137:8,17 138:1,6 139:13 142:2,23,25 143:9 144:12 145:4,17,22,25 146:8,13,20 146:25 147:7 153:2,12 154:16 155:2 Carolina 47:4 carondelet 154:18 155:4
81:2
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6785
[carried - communicating]
carried
center
chest
class
73:13 74:15 82:9
141:25
82:24
55:22
carry
certain
child
clear
33:4 93:9
3:13 35:17 55:25 56:3,6
132:4 136:5
25:24 26:8 34:12 42:14
carrying
58:24,25 83:25 88:10 90:13 children
48:17,18,20 98:1 102:18
92:25
92:15 107:10 108:3,7,10
27:12,22 30:21 34:7,15,22 140:18,21 152:7
case
110:19 111:12 117:15
44:17,20,25 45:8,14 46:1 cleared
4:146:11,14 7:3,7 26:1
certainly
46:23 117:10,12,17 118:3 46:16
102:19
7:8 8:2,12 9:13 16:18 35:12 121:8 122:13,15 125:14 clients
cases
41:6 42:10 46:10 49:12
126:17 128:3 131:17
86:12
7:10 27:17 38:18,21 64:24 54:15 65:5 70:12,13 73:16 135:18,21 136:3 142:3,18 clinical
65:3 70:17,18 71:17,19,23 79:2 89:14 104:12 128:20 142:19
42:25 82:10 87:24 88:13
categories
131:8 136:17 137:24 148:5 chipped
clinodactyly
57:23
certificate
132:11,18
141:9
categorized
154:8
chipping
close
76:5 chance
137:7,19
24:12 143:14
category
132:18
chloracne
clothes
56:11,15,18,20 127:7
change
5:16 45:10 73:13 74:3
82:12
129:21,22,22 130:4 144:22 68:10 85:4,8 101:17 102:25 77:10,14,18 78:1,2 82:15 collection
causative
142:6,7
108:9,12,15,22 109:5,14,15 89:7 151:12
25:25 26:9 102:19,22
changed
109:18,19 112:2 127:6
colloquy
103:15 104:2
69:9 85:1 90:5 109:20
129:19 138:18 140:8,10
152:25
cause
123:24
149:20 151:7,7
coloration
2:5 3:5,13 34:7,15 37:22 changes
chlorinated
129:6
48:5,7 49:10,11 71:7,23
9:22 59:8 88:6 97:23 98:9 8:12,14,18 9:11,23,25 12:4 coloring
78:1,18 91:4 95:19 110:5
98:11,25 99:4,12,19
14:6,7,21,22 22:18 25:25
128:23,24,24
110:14,15 115:23 116:24 charge
26:8 33:15 39:11,13,20 column
126:23 127:2,6,12,21,21
11:1
52:12,13 54:3,10 55:17,22 124:16 137:2
131:5 134:15 147:9 150:3,7 charges
chlorination
combination
150:22 151:2,7,15 152:9,15 154:9 155:9,10
52:15
9:19
caused
chart
chlorine
combustion
25:15 27:11,21 29:25 30:21 126:16 128:5 129:23
8:4,9,13,159:1,11,17,21
57:19 58:20,24,25 59:4,20
44:16 47:25 48:25 66:10
141:12 145:24
39:14,15,22 52:15,16,23
60:7 61:9,20 62:15
77:18 89:19,23 90:1 91:1 charts
57:21 59:24 63:23 151:22 comedone
92:19 93:15 95:4,8 96:23
122:8,23 146:6,18,18,19 chlorines
150:9 152:20
97:14 99:4,11,25 100:17,20 check
54:7 comedones
101:1,11,17,23 102:1,8,22 26:23
circuit
149:24,24,25 150:22 152:9
103:15,24 104:1,4 110:4 checked
1:1 2:1 3:1,13 154:2
coming
112:2 117:17 137:3,6,10
82:19 87:22
circulatory
16:25 53:20 108:13
140:3 151:8
chemical
94:5
comment
causes
7:23 14:7,9,11 20:5 69:14 circumstances
43:4 140:17
104:6 107:20 129:15
73:20 89:13 111:7,10
67:10
comments
causing
148:24
cite
96:14
104:1
chemically
15:2,3,4 102:11,13
commission
cavities
99:15,16,25 100:20 101:10 cited
155:17
138:7
101:17,22,25 102:22
98:18 102:14
commit
cavity
103:15,23
city
46:3
138:6
chemicals
1:1 2:1 3:1,14 71:7,23
common
cc
8:7 9:3,9,11,19 64:7 72:5
154:2
48:4
80:22
chemist
clarence
communicate
cell
60:11 116:5
80:6
15:8 61:5,11 64:18,21 67:5
113:1
chemistry
clarified
70:7
cells
14:4 34:3
45:6
communicated
112:23,24
chemists
clarify
61:6,18
cellular
60:10
39:7,8 67:25 68:20 98:22 communicating
116:4,19
15:18
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6786
[communication - data]
communication
condition (cont.)
contaminated
correct (cont.)
80:19
141:3
45:1,15 47:23 48:15 87:21 139:17 142:10,15 144:7,11
communitronics
conditions
121:9 122:14 125:20 134:5 144:13,13 149:12,15
3:10
45:11 105:5 108:7 149:11
136:7,22 137:3 140:4,22
153:11
company
conducted
141:2
corrected
1:6 2:6 3:6,16 10:16 16:15 13:21 17:24 62:14 83:3 contaminating
15:15 136:2 149:10
19:20 71:1 73:18,19 154:5 confident
87:18
correctly
155:12
15:25 85:2,10,13 88:25 contamination
34:18
company's
configurations
12:12
counsel
86:12
39:22
content
29:23 30:4 71:5 72:8
comparative
confuse
64:3,13
152:25
26:1
37:24 139:15
continue
count
compare
confused
25:23 42:9 72:22 77:22
97:8
33:18 55:20 121:7
22:5 92:13 114:1,2 145:14 98:6
couple
compared
confusing
continued
6:6 12:3 26:15 35:15 37:13
12:21 122:14 131:12
37:23 44:22 55:6 102:10
2:13 4:1 19:6
86:9
132:20
138:9
continuity
course
comparing
congener
24:25
22:22 38:24 52:19 93:2
12:13
55:11
contracted
110:1 124:5 155:10
complete
congenital
75:7
court
82:10 121:15,16 122:6,20 47:12 119:6 120:6,8 130:9 control
1:1 2:1 3:1,14 40:12 67:20
completely
conjunctivitis
18:21 59:16,17 121:9
71:7,23 95:14,16 96:2,3,3
27:7,8 145:14
139:18
122:15 124:17 125:4,5,6,18 96:15,18 118:13 154:1,2
complex
connected
126:4,14,18 131:8,15,24 covalent
50:14
7:21 14:12,13 19:1 140:10 132:7 137:11,12 138:11
116:4
complication
140:12
142:8,12,15,22 143:8,11 covered
49:11
consequences
144:25 145:2,7,8,11
94:7
composed
115:17
controls
covering
149:24
consider
125:8,12 126:7,8,9,11,14
101:5
compound
84:20,23 107:25 132:12
126:15 131:18 142:22
covers
14:1327:24 31:6,18,23 consideration
143:21
101:6
34:3 36:3,6 68:15 93:17
31:3
controversy
critical
114:14
consistent
101:20
19:24
compounds
43:21
conversation
cross
14:8 33:25 151:22
consisting
64:17
2:13 4:1 44:6
conceivably
42:19
conversations
curiosities
42:16 80:15
constantly
57:8
10:3
concentration
120:1
copy
custody
102:8
consumed
79:15,16,23,24 80:4 148:12 154:14
concentrations
22:17,18,18,19 23:3,7 24:3 cornfeld
customer
133:25
25:2,9,11 27:10 28:16
3:22
62:1,2
concern
30:20 33:10 122:14
corporation
customers
22:12,14 87:17 88:2 132:13 contact
3:10
61:22,24 62:10,12,13 65:10
concerned
15:23,24 16:1 71:22 72:1 correct
65:13 66:16 67:6 68:17
14:8 20:4 34:9 39:18 87:21 76:15 77:4,16 80:18
8:16,19 10:1,23 11:11
70:8
87:22 88:15
contained
18:14,21 19:5 20:8,11,14 cysts
concerning
28:1790:12 121:15
20:15,18,20,22 25:6 26:18 139:18 140:7
6:8 22:3 39:16 47:12 116:15 concluded 26:6 conclusion 26:6 68:8 137:9 145:9,10 condition 66:22 121:7 127:6,9,13 129:1 130:2,15 140:14,23
containing 91:7
contains 93:17 100:24
contaminant 21:15 99:4
contaminants 47:14 117:18 119:7 120:7 130:11,14,17 131:11
26:20 28:21 29:2 33:6
d
34:18 42:5,18,18 51:6,7 52:21,25 54:2 55:13 56:2,5 66:24,24 70:13,21 72:6,7 74:1,2,4,10,13,25 77:20
daily 111:8
dark 151:13,14,16
79:19 80:9 81:6,9 84:8,9,11 darker
84:12,15 86:16 89:16 91:1 98:3 105:10 106:16 108:24 109:23 128:10 132:10
129:6,8 151:11 data
13:9,10 17:10,14,1822:3
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6787
[data - doctor]
data (cont.)
deformity
32:10,11 34:13,15 42:2
117:13 129:2,16,17
43:21 50:7 83:16 89:7
degree
133:19 135:5 137:9,10,12 58:14
145:3 147:10
degrees
date
57:24,24,25 58:1,9,13,13
17:23 26:24 40:17 52:3
58:17,20 59:21 60:6 61:21
57:13 91:22,25 123:23
62:21 120:18,23
133:12
delivery
dated
155:8
40:13 118:13
demonstrated
dates
22:12
45:18
demyelinization
david
101:1,4
3:18 depend
davies
62:1,2,3,4 69:24
80:6,11,15,16,17,20
depending
day 29:11 97:18
3:10 5:22 88:1 95:20
depends
106:10 155:16
7:24 8:4 54:6 57:21 76:8
days
83:19 87:7 108:6 112:11
81:24 86:22 131:21
115:18 140:6
deal
deposition
85:1 1:132:16,173:84:6 6:19
dealing
6:23 7:13 34:14 38:25
33:25
40:10 53:11,20 71:10,25
deals
83:21 104:15 118:9 133:4
141:13
153:10 154:9,11
death
depositions
76:2 78:21
21:23 22:7 38:24 39:1
decided
derangement
80:17
129:3
decimal
dermatergosis
30:5 148:19
decreased
dermatitis
147:18
77:16
defects
describe
27:11,22 30:21 33:9 34:7
47:21 65:22 81:21 97:20
34:15,22 44:17,20 45:1,5,6 103:9 149:23
45:12
described
defendant
9:7 10:6 19:4 46:22 86:18
1:7,14 2:7 3:7,16,16,21
98:24
71:7 154:12
describing
deficiency
151:19
103:5
destroyed
define
58:14 59:1 60:16
77:6 106:3 141:6
details
defined
21:3 99:22
147:1
detectable
definite
84:8
118:1 148:6
detected
deformed
18:6
129:9,16 139:6
determination
deformities
108:16
116:21
determine
17:24 40:3 53:6 107:9,10
determine (cont.)
directed
114:17 116:12 121:23
152:1
122:3 126:4
directing
determined
32:20
62:19 114:18
directly
determining
20:14
62:14
director
developed
27:16 52:20 53:17 87:17
74:3 97:19,21
directors
development
13:13 15:10,19,24 16:6
22:4 disagree
developmental
32:4 97:4 104:18
141:13
discharge
diagnosis
126:18,24 127:5,20,21
106:13
discuss
diagnostic
12:12,20 79:13
105:3
discussed
dibenzodioxins
11:6 43:22 45:14 104:22
17:8 133:3 141:18 144:18
dibenzofuran
148:14
39:20,20
discussing
dibenzofurans
43:6 97:12
17:7 21:25 25:15,25 26:2,9 discussion
35:3 36:5 39:12,13 52:13
6:6 11:9,20 12:24 13:4
53:2 54:10 55:20,22 56:9
78:23 115:5
58:11 91:8 100:13 101:13 disease
102:18
26:1 49:19 50:8,11 51:9,11
dictated
102:19
79:22
displayed
differ
4:11
8:1 dispute
difference
33:7
14:6 59:14 68:6,8,18
disputed
112:17 132:9 139:20
103:13 123:24
143:20,21,25 144:4
disputing
different
146:20
8:6,6 9:9 12:17 14:13 39:13 disturbance
45:7,7 49:2,3 52:24 55:4,7 127:3 129:19
77:7 81:24 145:11
disturbs
differentiate
99:20
105:16
divide
difficult
23:9 36:10
44:4 divisions
diffusely
17:1
151:1,2,4,14
doctor
digit
7:20 24:17 26:19 28:11
11:22
29:5 31:12 35:6 36:22
dioxide
38:12 44:24 47:20 48:22
58:3,4 59:22
50:22 51:1,3 54:1 71:8,8
dioxin
74:5,8 75:19 77:12 82:8
33:15,15 55:11,25 56:1
89:15 91:5,16 94:11 96:17
dioxins
97:20 98:4,9,15 101:16
54:16,25 55:7,11,12,14,20 104:22 105:6,20 106:14
56:9,17 57:10
109:5 110:3,8,11 113:3,3
direct
114:9,11 117:16 118:10,12
4:11 119:8 120:12 148:14 120:11 121:14 122:2,21
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6788
[doctor - eventual]
doctor (cont.)
dr (cont.)
eight
123:12 124:8 126:3 128:11 72:3,15 73:14 79:12 80:6
60:8 106:9
130:8 132:13 137:1 141:8
80:11,20,22 86:1 88:17
either
141:12 143:5,17 144:23
95:16 102:14 115:4 121:4
5:13 32:9 39:17 48:20
146:1,17,22 147:17 148:7
121:16,22 122:11 124:20
73:17 116:19
148:14 152:23
125:1 133:16 135:10 149:3 ekg
doctors
149:3,14,14 154:11
82:24 108:1
74:16 123:19
drank
elaborate
doctor's
22:19,21
35:13 103:9,11
124:5
draw
elements
document
7:1881:14 145:9,10
7:23 8:6 14:7,10,11
41:1,2,5,12,21 42:4,19,21 drop
elevated
43:18,25 44:1,3,5 46:7,8
35:15 37:9,9
132:4
52:5 61:4 79:21 121:13,14 dry
elevation
121:16,16,18 122:18,20,20 151:13,14,17,21
14:1 132:12
123:4
due
eliminate
documentation
5:15 131:10
18:4 88:7,19 89:7,10
117:25 118:5
duplicate
eliminated
documented
20:24
89:10
48:1449:12 117:21
e embryonic
documents
earlier
4:7,9,10 12:19 21:22,24
43:13 44:25 89:6 132:17
22:6 40:25
early
dog 10:6,16 18:5 37:7 46:14
114:24 doing
129:16 68 rs
5:20 35:25 85:11
79:4 82:13,13,14
dollars
easier
70:25 71:1,2 donohue
24:19 42:22 73:11 easily
3:22 dose
36:1 68St
33:12,13,17,18,20,23 44:16 80:24,25 81:1,2,7 83:15
47:24 48:2,5,7,25 49:2,5,9 easy
49:9,10,19 50:8 51:9 134:9 35-15 44-14
134:13,16,25
eating
doses
20:9,10 47:23 95:13
78:21
prnnnmir
129:13 emmet
1:132:12 154:11 emotions
104:12 encompass
95:12 endeavor
109:24 ended
109:10 english
21:6,20,20 enjoy
119:15 enlargement
82:18 enormously
double
126:10 131:18
14:19,23 15:9,19 16:10
123:20 doubt
ectoderm 133:1
17:20 38:2 54:5 enter
13:14 137:24
education
110:25
doubts
14219
enthusiastically
42:24
educational
86:11
downtown
143:13
entire
10:24
eeg
41:15 72:17 121:23 124:5
dr
1081
entirely
1:132:124:3,5 7:2,15 11:3 15:15,22 17:23 19:1921:3
effect 112:8 113:15 114:13,17,20
14:12 environment
21:10 22:9 25:24 27:15 32:20 33:7 38:14,17 40:8
11510 1178 effects
69:15 86:7 143:13 environmental
40:12 41:3 42:20 43:4,8,11 44:10,14 45:13,20,22,25
51:24 79:1 98:18,22 113:5 113:10,16 114:12 115:5,23
47:3 49:15 119:22 enzymatic
60:12,1961:14,1962:18
116:12 134:11,15
116:5
63:15,19,20 64:17 66:8 67:1 69:12 70:15 71:15,24
effort 18:4 19:10,1988:18
enzyme 110:3,5,7,14,15,17,18,23
enzyme (cont.) 111:17,18,24 112:1,7,8
enzymes 99:20 110:19,24 111:16,17 111:20,23 112:1 147:20 148:4
enzymologist 147:21
enzymology 116:5
epa 51:23
epidemiologically 108:2
epidemiologist 132:15 136:17
epidemiologists 107:9
episode 20:7 47:22 95:13 125:4 128:13
episodes 5:15
eppenberger 154:17 155:3
equations 50:14
error 25:3
eruption 45:9 46:14 129:16 149:23
escaped 13:25
esophagus 76:3
especially 82:14 133:6
essentially 9:6
establish 102:7
established 54:12,15,24 61:14 84:19 101:21 112:3
establishment 120:23 122:19
estrogenic 113:5,10,15 114:12 115:5
estrogens 113:12
et 1:3 2:3 3:3,15 154:5
evaluated 125:12
eventual 78:21
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6789
[everybody - firm]
everybody
experienced
eyebrow
fatty
107:2 153:4
48:14 105:22
140:13,15,16
150:2
evidence
experiment
eyelid
favor
87:24,24 108:1 123:9
62:19 63:10
127:7
155:1
143:10
experiments
eyelids
feature
exact
62:23,25
126:25 127:21,22 129:12
136:21
26:23 33:16 58:21
expert
eyes
feed
exactly
4:23 5:2,7,8 15:17 64:25
79:4 82:13
134:9
93:7 95:3 98:3 100:15
119:25
eyestrain
feel
examination
expertise
105:16__________________ 82:17 96:9,14 108:19 133:2
2:134:1,11 74:15,17 82:10 18:8 98:16
f feeling
82:10,22 83:6 92:25 93:9 experts
face
108:18
94:3 107:17,17 148:15
32:2,4 104:18
82:14 138:17 140:8,10
feels
examinations 81:22 83:3,13 106:11
examine 18:11 44:6 82:9,16 91:3 92:23 105:1 149:8
expires 155:17
explain 17:20 98:17,24 99:24 100:16,19 101:10,16,22,25
faces 150:20,23
fact 15:17 35:6,10,12 36:2 46:8 64:25,25 66:21 106:14
108:22 felt
92:18 fetus
129:13
examined
102:21 103:14,23 104:6
120:1 124:23 129:20
fever
3:8 81:13 87:23,23 88:1,1 89:15,19,23 97:15 125:12
110:3,9 117:16 119:9 120:8 124:17,25 126:22 127:8,24
144:14 factor
131:25 132:1,3,6,8 fibers
149:4,6,7
128:11,17,25 129:10 130:1
examining
130:12,25 132:1,22 143:20
46:1581:25 95:10,10 110:1 explained
6:8 54:11 112:2 144:17 facts
6:24 53:14 68:2,2,12,14
101:2 figure
23:9 29:7 33:16 56:16
example 107:1
142:17 145:20 explanation
70:10 127:13 fahrenheit
figured 33:15
exceed 60:15
excellent
11:15 exposed
6:17 87:16 90:12 105:15
57:24,24,25 58:13,17,20 59:21 60:7 61:21 62:21 failed
figures 12:3,5,16 22:21 23:16 26:23 29:4 34:18 35:2 36:2
123:21,21,22 excess
124:17 125:2,3 126:7,17 131:22,24 141:19 142:8,9
64:4,13 failure
54:24 55:16 132:9,21 file
128:24 141:1
142:12,15,21 143:8,20
64:7
75:5 83:6,22
excreted 115:12,14
excuse 25:17 77:12,21
exemplary 96:4
exhibit
144:9 145:1 exposure
87:8,11,13 88:7 91:1,7 95:9 97:18 99:10 105:3,17 110:5 110:14 122:16 133:16 134:24 135:10,13 137:3 140:4
fair 33:11 47:11 57:3 72:25 104:24,25 108:4,5 122:24 138:15 145:3 152:4
false 67:2,4,15 68:24 69:13,17 69:19,22 70:3
files 79:23 83:13,14
find 53:7 75:15 87:4,6 91:3,4 125:8 131:22
finding 138:11
2:16,17 40:10,13,13,14,15 exposures 72:16,20 75:13 79:13 118:7 82:3
falsity 70:4
findings 88:14 107:15 122:12
118:9,13 121:24 148:7,18 express
familiar
fine
exhibits 4:10 28:7 46:2 72:11,12
exist 12:22,22 39:13
exists 120:10
expect 45:19 86:5 87:4,6 96:24
expense 74:6
29:23 50:22 expressed
57:6 extra
7:19 extreme
34:2 extremely
30:2 36:2,5,23 extremities
99:22 118:19 119:5,12 123:12 144:7,23 145:6 far 12:6 14:7 34:9 39:18 55:16 55:18 71:14 98:8
4:4 28:1 31:17 41:8 43:14 55:21 75:17 94:23 95:17 97:1 122:5 fingers 139:9,14,16 141:10
fashion 42:11
fast 83:19
fat
finish 21:21 48:23 153:10
fire 58:8 59:5,9,12,14,15
fires
experience
97:24 98:10 100:20
86:2,6,6,10,22,23 87:6,9
59:3 62:4,6,7 65:3,4,6,7,11
6:25,25 87:2 90:16 97:22 eye
105:8,9,11 116:14
126:18,23 127:5
99:21 111:21 115:13 127:1 127:3
65:13 firm
3:19,22 154:14
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMON006790
[first - gravity]
first
found (cont.)
furans (cont.)
giving
7:2 25:16 26:18 30:1 40:15 109:20 125:5
100:10 101:12 102:3,5,7,8 55:11 69:5
43:1767:11 69:1281:4 foundation
102:9,21 103:15 104:1,2 glad
99:17 102:23 110:4 114:16 15:23 16:1,15 19:1521:3,7 116:24 117:19,23 126:23
32:18
118:15 120:17 127:12
61:1667:10 121:18 123:5 127:8,14,15 129:1 130:1,4 gladen
129:22,25 131:1,4,9 135:3 four
130:18 131:2 133:16,25
120:20
137:5 138:13 145:5,25
84:1 85:15 106:10
134:1,3,5,9,14,24,25
gland
149:20
fraction
135:14,14 136:7 137:4
149:25 150:2,2,6
five
30:2,15
140:4,23 141:3,20
glands
28:24 29:1 75:16 131:12 frame
further
99:22 126:25 127:1,4,21,22
flare
67:8 44:2 68:1________________ 140:2,6,9,11
140:13,16,17 fluid
13:25 64:1365:14,18 fluids
47:23 focus
124:9 fogies
29:20 follicle
152:17 follicles
99:21 127:4 follicular
152:15,17 follow
80:19 following
51:1 66:23 89:6 97:1 footnote
43:18 form
90:4 92:20 95:5 98:19 100:22 110:6 112:15 114:21 115:20 118:22 134:17 135:4 format 43:24 formation 14:4 110:19 formed 14:3 58:12,15,19,24 60:15 64:7 former 22:2 27:16 52:20 53:17 66:16 67:6 70:8 132:13 forms 83:2,4,12,18,22 formulate 92:17 forward 109:16 found 37:4 43:2 85:12,15 86:3,5 87:24,25 88:2,7,17 109:19
frankly
g glenn
50:25
gained
1:3 2:3 3:3,15 154:5
fraud 69:6 70:5
fraudulent 67:2,4,8,16 68:4,5,13 69:13 69:17,20,22 70:3
15:5 gastroenterology
94:5 gateway
155:12
go 26:23 27:25 44:1 72:15,19 75:15 76:22,24 90:20 93:4 94:1,2 96:2 109:16 111:7 120:15 129:21 136:24
frequencies
gbrn001998
137:4 144:1,20,22
124:13 frequent
79:19 general
goes 50:1,5 51:5 76:25 99:17,19
98:12 102:1,22 105:25 full
5:22 142:15
6:22 55:14,22 105:18,18 generalized
94:3 136:6,8
111:18 going
4:24 5:18 10:8 15:21 16:12
fumes 59:25
generally 100:4
19:14 20:14 27:2,23 31:8 31:17 34:19 36:25 42:8
function 98:11 101:17 111:10 112:7 112:8
genital 138:19 139:1
genitals
43:23 44:1,1950:1261:13 80:5 86:8 90:3 93:16 95:9 95:15 96:2 97:10 106:19,24
functions 110:24
139:2 gentlemen
113:19 120:14,15 122:1 123:3 124:19,21 125:13,21
furan
80:23
127:25 134:7,17 143:9
7:17,23,24 8:7,12,14,22,23 9:7,10,11,20,22,24 12:4,12 13:10,22 14:7,15,18,21,22 28:23 33:15,21 38:21 39:24 50:7 52:24 55:16 56:3,4 furans 7:16 8:10,13,17 9:3,5,21,23
geographical 81:3
georgia 148:22
getting 18:12 36:24 107:6 114:9
58:15 88:19 132:18
144:12 145:4 146:25 147:7 150:25 golly 55:6 good 4:5 29:23 50:25 58:7,8 88:11,12 107:8 119:15
10:6,15 11:11,16,21 12:4 12:20 14:3,5 15:9,19 16:10
gibberish 29:21
152:5 gore
17:10,20,25 18:5,6,9,11
gist
155:12
19:3,11,20 20:1,1,3,3 21:15 22:4,11 26:11 27:19 28:3 28:25 29:1 30:1,1931:10 31:13,25 32:3,6 33:10,13 34:4,12 35:9,21 36:23 37:1
46:10,12,13,21 give
6:2,7 17:3 24:10 29:6,18 32:18 35:7 45:17 55:23,23 57:2 61:21 62:9 66:12,14
gosis 148:20
gospel 88:9
government
37:3,21,23,25 38:1,18,19 38:23 39:1,17 40:3 44:16 44:21,22 47:25 48:7,16,25 49:20 50:9,10 51:10 52:15 54:1,3,16 55:1,3,12,13,15
66:1667:868:3,12,16,17 69:15 81:18 97:7 105:8 117:25 129:6 137:5 143:15 148:9 153:7 given
13:11 16:9,19,24 17:1,9,14 17:16,18 62:16 66:12 67:6 68:17 69:16 70:7 119:20,23 gram 36:15
55:17 56:10,17 57:10,10
5:1 6:5 13:11,13,15,17,19 grams
58:14,15,19,24 59:1,20 60:5,15,16 61:19 62:14,20 63:21 91:23,25 99:4 100:8
16:8 17:1434:13,1661:19 61:24 68:2 70:13,1771:16 134:8,12
23:6 36:17 50:3 86:10 gravity
24:11 29:12
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6791
[great - illnesses]
great
happy (cont.)
hickey
hundred
11:9,19 85:1
118:5
150:14
26:16 30:23,23 33:21 57:4
greatly
hard
high
hundreds
39:14
21:16 122:2
23:21 24:1,7 25:7,8 84:21
94:13 111:19
groin
harm
84:23 85:5,8,22 90:12
hundredth
140:12
148:5
102:8 112:14,18
30:16,18,22 32:8
group
head
higher
hurry
106:3 108:8 121:10 122:15 93:24 94:2,10,14 109:1
58:13 60:16 89:2 142:13,22 35:25
125:4,5,6 126:14,17,18
138:17 150:10,11
143:3,8,10 145:1
hurt
131:8,18,22,24,24 132:7 headache
highly
76:23,24
137:11,12 138:11 142:8
105:13
70:6
husch
143:8,8,12 144:9,25 145:1 headaches
hirsutism
3:22 154:17 155:3
145:2,8,11
98:13 103:24 104:4,7,9,10 141:1
hydrocarbons
grouping
104:11,14,16,19 105:14,23 histories
17:6
132:25 135:25
105:24 106:8,9,10,10 107:1 94:20
hydrochloric
groups
107:2 108:11,13
history
59:25 64:1
145:7
health
82:1,2,2 93:10 94:4 105:17 hydrogen
guess
29:25 44:16 45:14,25 47:3 105:18 106:12,13 124:13
8:8,15,20 9:10,14,21
70:24 94:15 149:16 151:21 47:21 48:6,8,10,12,13
129:23 136:1,19 138:10 hyper
guinea
51:24 66:10 88:13,13 89:18 holes
128:23 141:5
114:23
89:22 92:18 105:18 108:3 138:5
hyperimmunity
gullet
109:15,17 116:12 119:22 honestly
103:6
76:4
121:8 122:13 134:11 145:1 7:9
hyperpigmentation
gum
healthy
hooked
128:21,22 137:21 138:16
137:5,18
87:25
39:23
138:17
gums
hear
hormones
hypertrophy
128:16,19
32:9
113:12,13
137:5,18
h
habits 145:2
hair 99:21 127:4 132:20,23,24 141:1 152:17
half 22:21 23:4,13 30:10,11 86:24 95:20 143:22
hallmark 109:19
halogen 9:4
halogenated 9:2 17:5
hand 40:14 118:12 155:16
handed 41:10 121:14
handing 41:20
handling 66:23,25
happening 77:19
happens 129:7
happy 32:23 41:3 97:13 117:25
heard
hospitalized
12:11,1437:20 65:9 119:11 82:7
135:18 136:3
host
heart
105:4
82:16,20
hot
heat
58:25
13:25 65:14,16
hour
heated
102:14
13:22,23,24,24 17:25 20:22 hourly
21:1,11,25 22:4,4 32:13
81:13
65:15
hours
heating
6:6 76:21
20:8,9,25
house
heavy
153:7
133:24
household
help
142:19
24:17 138:1 147:18
housekeeping
helpful
88:23
29:17
huh
helping
29:14 43:10 58:18 100:9
30:6 human
helps
78:16 114:24 116:7,22
143:2
134:10
herbert
humans
148:21
34:9 69:15 116:1,9,12
hereunto
147:5
155:15
humor
herxheimer
70:24
149:22,23
hypothetical 50:13 68:2 69:5 70:10
i
idea 83:11 85:21 86:1
ideas 91:10
identical 144:10
identification 40:11 118:9
identified 4:10 44:8
identify 40:16 41:8 42:8,22 43:25 44:4 51:21 52:5 72:16,19 73:11 75:1
identifying 68:13 79:18
ii 1:12
iii 80:6
illinois 81:5 89:8
illness 5:15 87:24 91:15 105:25
illnesses 37:22 90:15 98:12 101:14
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6792
[illnesses - journals]
illnesses (cont.)
indication
inquiry
102:1,22 103:6,7 105:12
41:21,22
80:11
imagine
individual
inside
144:16 151:6
17:2 53:4,17 55:19 87:4
124:24
immune
90:18 92:23 112:10 148:5 insinuate
79:1,3 103:5 146:23
individuals
96:5
immunological
87:18,22 90:12 120:21
instance
102:25 103:2
125:3 141:19
69:11 73:12 144:25
impact
induce
instances
68:5,9 69:6,14,15,20 70:1,4 50:1051:9,11
144:9
impacted
induced
institute
70:12
50:8 99:11
47:3 119:21
implicated
induction
insulation
98:17,25 143:18
49:19 98:18,25 110:3,5,7
101:8
implying
110:14,16,17,18,23 112:1 insulting
128:6
industrial
95:19
important
5:9 20:5 23:2 25:22 26:7 insurance
91:1692:12 116:17
45:21 46:20 47:23 73:2
71:1 73:18,18,19
impossible
74:22 75:2 82:2,2 86:7
insured
55:23 69:18 145:10
91:11 102:17
73:19
improper
infected
intelligence
43:5 52:7 123:9
140:7 152:16,20
142:3
inch
infinitesimal
interest
40:22 86:9,24
37:10,21
52:25 53:1,7
inches
inflammatory
interested
151:5
44:21,23
88:12
incident
information
interesting
21:5,11,1449:20 97:19
5:13 10:12 15:8 16:8 17:7 52:20,22
118:24 119:1,3 128:6 139:7 21:8 22:24 25:21 27:3
internally
incision
28:10 31:1 32:17,19,22
76:1
86:9,24
33:3,4 39:16,18 41:7 43:12 interpret
included
44:15 52:19 53:7,18 60:17 141:23,25 142:5
17:7 19:25 52:11 124:15
61:11,18,21 63:8 64:18,22 interrupting
includes
64:23 66:8,9,11 67:5 68:16 77:21
121:24
69:9,16,24,24,25 70:7,20 intestine
including
72:2 80:14 85:4 94:9 108:2 99:18
95:23 134:10
116:15 134:8,12 137:11 intoxication
incomplete
141:24
105:4
44:3
informed
intraoral
inconsistent
57:9,14
137:21
92:10
ingested
intricate
incorrect
23:20 24:14 26:11,25 27:11 103:3
86:14,19
27:19,19,21 29:6,24 30:20 introduced
independent
117:10,18 121:8 125:19
123:9
71:19
ingestion
introduction
indiana
116:22
124:11
3:20 65:23 104:17
ingredient
invented
indicate
116:18
151:23
35:24 49:18 50:9
inhibition
investigated
indicated
112:5,9
72:6
27:6 51:16 66:10 70:5
initial
involved
indicates
44:4
19:1820:8 21:11,1484:3
44:15 50:7
injuries
129:17 145:8
indicating
108:23
involving
87:13
injury
27:17 38:18,19,21 76:6,6
29:6 79:5 108:16
148:24
iodine 9:5,5
iq 142:9,12,15 143:18 144:6,7 144:10
irrelevant 69:8 106:20
irritability 98:13 103:16 105:24,25 107:1,3
irritable 103:21
irritated 128:16,19
irvin 3:12
isomer 53:4
itching 136:6,8
items 124:13
iv 51:25
j
jack 14821
japan 12:9 13:24 20:7,21 22:12 2215 3113 32 2 14 34 11 34:16 54:8 99:5,11 107:23 118:21
japanese 12:13,16,17,21 21:18,19 22 4 23 20 25'10 26'25 27:10,21 29:25 32:9 33:8 39:17 44:17 45:8,24 46:20 48 15 13324
jenkins 323
job 95:24 96:4
joining 141 '9
joint 116:21 117:9,13,14,17 118:2 135:9,11,15,19,21,24 135:25 136:3
jones 71 3 73 14 148 21 149 3 14
journal 23:2 25:24 26:7 45:21 46:20 102:16 123:22
journals 103:12
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6793
[jump - liver]
jump
know (cont.)
I
36:6 11:5,8,19 12:6,10,19,22,23 laboratories
june
13:12,14,16,18,20 14:2,4
119:17,18
1:153:9 26:18 153:9
14:20,22 16:5,8,15,18,18 laboratory
jury
16:22,23,24 17:12,23 18:1
10:3,13,20 11:1,1822:10
24:25 29:17 30:19 37:24
18:7 19:8,13,16,23,23 21:8 59:4,13,14,17 63:2 64:6
43:13 50:23 51:2 87:3
21:10,1422:9,13,13,15,17 73:4 82:23 83:16 84:25
102:10 120:8 122:12
24:11,23 25:16 27:8,15
88:13 107:17 119:13
123:10 124:18 125:1 130:5 28:9,10,12,1429:7,1231:1 laid
138:2 139:15 141:23 143:2 32:3 34:8 36:8 40:5,23
15:23 123:5
152:7____________________ 41:12,13,17,1845:547:2,9 language
k
49:1,9 50:15 53:3,14,19
21:6
kabuto
57:15,16 59:25 60:2,4,20 large
25:24 kaley
60:12,20 61:19 62:18 63:15 63:1964:17 kanaclor
60:23 61:16,18,23 62:13,23 11:20,20 14:1046:15
63:3,5,10,12,16,20,25
101:19
64:10,11,12,15,16,20,23 larger
65:10,13,20,21 66:3,5,7
58:22 121:13 150:18
67:15 68:23 69:22 71:11,14 lassitude
22:5
71:18,20 72:2,24 73:12
97:23 98:10 100:1,17
keller 11:3
75:5,9,10 76:23,25 77:8 late 78:4 80:6,13,14,18 81:2,24 14:24 15:4,12 18:10
kelly 1:132:124:3,5 7:2,15 15:16 17:23 19:20 21:3,10
83:14,25,25 84:18,18 85:25 lately
85:25 88:11 91:13 92:12
117:25
94:21 96:12 97:2 99:3,6,7 law
22:9 27:15 32:20 33:7 38:14,17 40:8,12 41:3
99:10,13 101:15 103:11,22 3:19,22 106:17,22,25 107:24 108:9 lawyer
42:20 43:4,11 44:10,14 45:1361:1463:20 66:8 67:1 69:13 70:15 71:15,24
109:1 110:7,10 113:21,24
70:25
114:4 115:24 116:2,9 119:9 layer
119:10,21,24 122:2 124:15 129:13
72:3,15 79:12 86:1 88:17 95:16 102:14 115:4 121:4
124:21,24 125:4 126:6,7,12 Id50
126:15 127:2 128:1,12
31:4
121:16,22 122:11 124:20
129:7 131:8,23 133:5,11,13 lead
125:1 133:16 135:10 154:11 kelly's 15:22 kilo 33:17,21 kimbrough
133:21,21 134:11 135:20
50:20 120:22
135:21 137:20 138:14
leader
140:9,14,16 142:17,20
153:7
143:1,2,4,11 144:3,20
leak
145:5,7 147:15,21 151:3,19 89:10
152:10
leaks
knowing
88:1989:7,10,11,13
17:3 45:20,22,25 108:21 133:7,9
126:8 132:6 knowledge
learn 14:25 60:9
kind
10:19 11:13 15:5,18 16:2 learned
29:20 34:23 78:19 105:6 134:9 kinds 48:12 kingshighway
16:10 17:11,13,15,17,19
15:1260:1761:1467:1,11
27:16 28:15 39:16,18 43:22 67:15
44:11 62:2,24 69:7 71:19 leave
87:3 91:23,25 119:8 143:19 76:9 77:10 101:7
knowledgeable
left
3:11 knew
10:10 19:24 20:1,4,7,21 21:3 22:23 62:11,12 67:3 85:24 89:16
38:9 63:17 93:8,9 known
26:24 36:22 60:5 77:3,8,11 77:25 78:4,8,9 91:12 knows
76:21 78:3 113:4 115:4 124:16 legal 5:2 length
knocked
43:5 137:12
148:15
59:24 know
kumita 102:16
lesion 152:16
4:25 5:1 8:1 9:5 10:4,7,8
lethal 31:3 33:12,13,17,23
letter 27:6 80:5,9,20 97:15
letters 79:18
level 12:12 13:10,22 19:20 24:6 24:7,14 25:2,7,8,9 84:16 87:19 112:13,14,14,17,18 116:19 135:14
levels 12:20 13:5 84:10 87:14 88:3,7,17,24 90:12 143:13
liable 91:11 103:5,7
liberated 64:2
lie 82:17
lifters 113:14
liked 97:6
limit 39:21 49:4
lindbergh 10:25
line 123:11
lipa 155:12
list 71:12,15,16 82:4 89:20,25 92:17 93:4,13,21,24 94:2,2 94:10,12,21 95:1,2,3 105:7 107:22 137:4
listed 104:23 137:2
listen 31:11 146:4
listened 82:20,20
listening 145:21
literally 111:19
literature 5:14 21:21 34:23,25 45:13 48:14 54:15 62:4 92:19 102:7 116:25 120:2
little 92:13 93:18 96:7 114:3 116:20 147:19 150:15
liver 78:7,18,19,20 99:19,20
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6794
[liver - mentions]
liver (cont.)
lungs
material (cont.)
mean (cont.)
101:14 109:20 110:20
82:16,21 112:22 113:2
101:5
110:10,22 111:6 113:23,23
111:14,15 112:19,22,25
140:18,20
materially
114:5,15 143:23 144:3,15
148:4
lymph
69:9
145:12 147:2 151:3,9,16
local
140:1,6,8,11
mathematical
means
75:23,25 76:2,3,6,9 77:16 lymphadenopathy
50:14
20:10 45:6 50:4 51:9 77:7
long
140:1____________________ mathematician
77:18 110:18 112:25
60:5 61:15 62:18 63:5 76:9
m
35:14
113:21 116:19 120:9
76:12 77:3 78:8,9 93:18 m.d
matter
125:18 128:23 133:11
104:15 142:18 152:11 longer
148:21 m.d.
41:8 50:1671:9 105:1 maximum
140:1,15 141:1 143:22 152:10,11,12
125:16
148:22
37:16,17 48:9
meant
look
macromolecules
mccrea
101:3 124:22 126:4,6 128:1
18:9 40:15 41:5 53:4 82:12 116:4
2:13 3:19,19,19 4:2,21 5:4 measures
82:1386:1091:13,15 117:25 118:11,14 132:21 144:4 146:7,11 150:12 151:9 looked 26:22 88:23 91:14 looking
magazine 123:22
magnitude 54:18
magnitudes 26:15
main
6:1 7:6,11 15:15,21 16:4,17 89:6
19:19 21:10 24:20,24 27:9 measuring
28:1,9 29:22 31:11,20,24
64:6
32:4,5,10,13,16,22 33:2,5,7 mechanism
35:6,11 36:14 37:3,6,12,15 98:24 101:14 117:16
37:19 38:1,5,12 39:10 40:7 127:24 128:11,17,20,25
40:12,19,20,24 41:6,25
129:10,15 130:25 132:22
107:15 108:6,7 109:17
10:22 25:25 26:9 102:19,21 42:5,7,13 43:20 44:9,24
135:1
121:24 146:18
103:15 104:2
46:6 48:13,22 50:20 51:3 mechanisms
looks
major
51:19,23 52:9 53:10,16,24 98:17
150:10,19 151:11 lose
65:5 128:20 majority
54:1 55:6 57:13,15 61:17 medic 67:12,20 68:19 69:12 70:15 5:14
96:7
108:18 153:7
71:5,13,22 72:3,8,11,14 medical
loss
making
73:10 75:17,19 79:9,12
6:10,13,1727:1633:8
97:24 98:10 101:11 132:20 67:9
86:8,15 87:1 90:8 92:7,11
35:20 45:13 52:20 53:17
132:23 133:15,17 134:6,21 135:1 lost 24:5 82:8 90:19,22 93:3 130:24 lot 22:20 27:5 36:12 37:13
man 73:21 91:3 92:25 97:18
manifestation 77:14 78:2
manner 12:17
manufacture
92:22 93:18,21,25 94:9,23 73:22 81:12 82:1 92:17,25 95:7,14 96:8,11,17,22 97:4 93:9,10 94:20 105:16,18 97:10,13,20 98:3,9,23 99:3 106:11,12 124:13 99:10,16,24 100:6,23 101:3 medically 102:4,11,15,20 104:2,5,16 74:8 104:21 106:5,14,21 107:7 medicine 109:13 110:8,13,17 112:20 23:2 25:22 26:7 45:22
45:7,7 73:1 74:22 95:24
12:17 84:3
113:22 114:3,6,19 115:2,4 46:20 87:17 102:17
111:22 113:18,20,21
manufactured
115:22 116:25 117:2,4,9 melanin
114:19
12:8
118:2,6,10,12,25 120:25
129:4
lots
manufacturing
121:4,22 122:7,21 123:12 membrane
16:25 136:4
18:20,23 20:2 65:22
123:15 124:3,8,25 126:3
113:1
louis
marie
127:15,19,23 128:2,8,10 memo
1:1,26 2:1 3:1,11,14,23
126:1
130:7,18,21 133:20 134:2,4 154:1
10:21,24 60:25 80:24,25 mark
134:13,23 135:9 136:2,13 memoranda
81:1,3,7 83:15 154:2,19 155:5,14
118:7 150:15 marked
137:15,18 138:4,8 139:16 22:1,6 142:4,24 143:4,17 144:18 memorandum
low
40:10,13 118:8,13 143:21
145:16,17,20,24 146:4,11
11:25 12:2
23:20 24:1,6 25:1,7 30:2 masses
146:17,22 147:6,12 152:23 memory
34:1 85:5,8 112:13,13,17
82:19
153:3,11
46:3 71:17
lower 58:16,16 89:3 143:3,10
massive 91:7
mean
mention
4:25 9:9 12:14 13:23 15:12 126:11,12
144:9,14
masuda
24:10 35:25 42:14 48:1,10 mentioned
lumping
23:1
63:14,25 64:5,20 65:16
68:22 69:1 70:16,19 71:20
130:3
material
75:21 79:2,3,3 83:8,19 84:5 71:21 103:8 128:7
lunch
12:4 34:9 36:7 58:1 62:3
85:8 99:7,7,14 100:3
mentions
115:3
69:9 70:12 75:13 90:13
103:11 106:25 107:4 110:7 125:14
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume
LEXOLDMONOQ6795
[met - number]
met
minute
monsanto (cont.)
nationals
7:3,8
78:22 123:3 152:8
13:5,21 15:13,17,18 16:7,9 45:24
metabolic
minutes
16:16,19 17:9,17,24 18:4 nature
110:25 111:2,4,6,10
50:16 53:9 75:16 78:3
18:20,25 19:2,6,11,20 21:9 36:25
metabolism
113:4
22:10 27:16,18 32:8 37:7 necessary
75:23 76:7 99:21 111:21,21 mischaracterizing
37:22 38:6,18 39:17 40:2
48:5 49:9,11
111:22,22 112:19 113:6,11 34:21 92:6
52:21 57:6,8,17,18 60:10 necessitated
113:16 114:13 115:6 116:8 mislead
60:25 61:11,15,18,25 63:4 86:23
116:16 127:3 129:3,4,20
130:5
63:11 64:10,12,21 65:1
neck
147:24,25 148:1,2,3,4
misplaced
66:3,9,9 67:2,4 71:2,3,3,13 82:14 140:9
metabolized
36:1
71:14,22 72:1,17,20,22,25 need
115:16
missed
73:3,4,5,8,12,15,18 74:17 75:11,13 104:21
method
84:6
74:18,24 75:6 79:23 83:22 needed
66:25 126:22 127:8 130:12 missing
87:18 88:18 105:21 116:11 53:14
methods
124:15
120:1 132:14 134:1 141:15 needle
11:1918:6 86:21
missouri
148:25 154:5
86:21
mid
1:2,26 2:2 3:2,11,13,14,23 monsanto's
needs
18:10,17 62:8
60:25 154:3 155:14
12:13,21 22:11
153:6
middle
misstating
month
neighborhood
41:14,16
127:13
18:24
33:13
migraine
mistake
months
nerve
104:11
68:7 69:6
22:22 75:12 89:24 130:1
101:1,6
mild
mitochondria
131:1,9
nerves
76:10
112:12,24 113:1
morning
101:6,7
milligram
mitochondrial
4:3 35:8
neuritis
25:19 33:14,17,21 140:5
112:6,9,21
mother
101:2
milligrams
mix
134:14,25
neurological
23:6,15,17 24:9,14 25:4,4,6 44:22
mothers
82:6,22 94:6 104:8,10
25:7,8,18,20 27:3,5 29:8,9 mixed
34:21 45:1,15 117:10,18 nine
29:19 31:4 33:19,20 35:16 14:11
121:8 122:14,15 124:13
93:5 98:23 104:23 105:8
36:14,19 44:18 49:20 50:1 mixing
125:19
nitrofuran
50:3,4,5,9 51:4,5,8 76:20
31:9 127:14
motivation
105:3 127:2
134:13,25 135:15 137:3 mixtures
142:20
nitrofurans
milliliters
51:24
move
90:13
23:3,13,18,21 24:1,2,6,14 mo
43:4 71:25
nonexposed
25:2,11,17 27:5 28:16
154:19 155:5
multi
125:14
29:10,13,15,16,19
mobilization
44:3
nonsense
million
115:7,10
muscle
14:17
11:22 12:6 23:11,12 24:4 mobilized
133:15,17 134:6,22 135:1,6 normal
25:5 28:17,20,25 29:1
115:13
135:7
155:10
35:1737:8,14,15,17,18,19 molecule
myelin
north
mind
39:23 52:24 54:7,7
101:5,7
3:23 47:4
104:23 105:1 109:21,25 molecules
myriad
nose
minds
39:24 40:3 52:16,24 55:25 6:5
82:13
20:6 124:24
56:1,3,4,7
n
mine 108:17
moment 27:13 91:6 126:2
nails 129:9,12,17 132:25 139:6
minimum 48:7,9,24 49:9
mink 114:23
minor
money 72:22
monkeys 26:2,4
monoxide
139:14,16,17 name
10:14 17:271:2 81:3,18 102:15 108:19 154:14 names
49:4,10
58:4,5 59:23
70:16 71:6,23 73:9
minus 142:14,14,16,16 143:22,23
monsanto 1:6 2:6 3:6,15 4:22 5:6 6:16 6:25 7:16 10:5,16 12:11,20
national 45:23 47:2
119:21
notary 3:12 155:19
notebook 41:11
noted 124:5 130:14
november 23:2 25:23 102:17
number 15:16 32:8 71:7,23 72:4,17 72:20 84:2 85:22 89:11 97:18,21 105:23,24,25
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6796
[number - parts]
number (cont.)
oettingen
opposed
P
119:18 149:17,18
75:4
11:16
p.m.
numbers
office
oranges
3:9
75:13 79:18 85:6,7,10
7:5 10:22
31:9
pad
131:22 139:21
officer
order
7:19
numerous
154:8
30:25 53:14
page
21:22 22:7 27:17_________ offices
organic
2:11 40:19,22,25 41:6,10
o 3:10
103:21
41:10,13,15,16,17,18,20
oath
offspring
organs
42:19 44:2,3,10,12 51:25
32:19 object
27:1 33:9 oh
82:18 oriental
52:4 79:18 120:12,15 146:6 146:9,10,19 149:16,17
4:18,24 5:18 15:11,21 16:12 19:14 21:2 27:2,23 31:8,15,17,22 34:19 36:25
30:9 59:22 81:19 109:1,17 125:22 133:21 oil
129:8 original
154:15 155:1
pages 41:12,13,19,22 42:1951:22 52:2,2,3 121:24 122:4
40:18 41:20 43:23 44:2,19 50:1251:1252:8 61:13
14:1 22:22 23:4,11 24:15 originally 25:2,5,6,7,9 28:16 45:1,15 43:24
145:18,23 146:1,15,16 paid
67:7 68:15 86:13 90:3,4 92:20 93:16 95:5,18 98:19
48:15 76:19 99:11 117:18 osland
121:9 122:14 125:19
80:22
67:2,4 72:17,20,22,24 73:2 73:4,5,11,14,16,17,21 74:9
100:21 106:19,24 109:12 okay
ought
74:23 75:5 155:9,10
110:6 113:19 121:12,19 122:1 123:4 124:2,19,21 125:21 127:11,25 134:7,17
6:4 10:11 17:4 28:22 33:24 44:4 45:6 106:9 143:1 38:25 39:5 40:7 42:6 46:17 ounce 47:18 49:7 56:17 58:1 59:2 30:8,9,10,11,12,14,15,16
pain 117:17 118:2 135:9,11,15 135:19 136:3
142:23 143:9 144:12 145:4 59:19 60:5 62:18 69:12
30:18,24 31:5,6,12,13
pains
146:25 147:7,8 objection
31:22 41:23 42:1,7 44:9 51:1468:1 97:16 99:1,6,13
70:15 73:24 76:25 78:4,12 33:10 34:4 36:6,9,9,10,11
97:23 98:10 100:20 117:9
87:10 93:5,20 98:6,7 100:7 36:17,19 37:12 50:1,3,4,10 117:14 135:21,24,25
102:20 103:14 104:13
51:4,5,10 134:15
paint
105:20 107:19 108:15
ounces
76:10 151:20
100:2,2,22 106:2 112:15 114:14,21 115:20 118:22 122:17 123:8,10 124:1,4 135:4 136:9
109:5,24 110:13 113:3
23:6 35:16 50:23,24
119:19 124:7 137:17 138:8 outer
138:19 142:9 144:6 145:25 76:15
149:19 151:13,25 152:3 outlined
paper 52:7 60:22 73:20,20,22 74:11 94:18
paragraph
objections
153:12
66:24
81:4 149:19 150:25 152:5
124:4 objective
old 29:20
outrageous 96:6
paragraphs 43:18,21
107:15 108:1 observation
olive 1:25 155:13
outside 5:15 73:21
pardon 13:3 80:2 111:3 117:1
152:5
once
overbroad
park
observed
34:12 35:9,20 89:10
4:19
47:4 119:12,17
66:6 149:8,10 observing
82:11
ones
overdeposited
16:20 54:9 55:18,19 58:16 129:5
71:20 151:5
overformed
part 1:14 10:22 36:9 72:25 79:1 92:17 103:3 112:24 114:16
obvious
open
129:5
132:25 145:19,23 146:2,14
139:1 obviously
109:25 operation
overkill 16:21
partially 72:21
45:22 51:17 59:3 87:10 88:19 113:12 131:18 134:9
66:6 88:6 operations
oversecreted 129:5
particular 6:24 7:7 11:7 19:23 41:1
136:18 occasion
12:1
88:21
ownership
opinion
74:17,18
4:13,23 5:2,7,9 6:3,8 35:19 oxidative
42:4 44:5,12 48:11 66:10 74:14 80:14 95:23 100:3 120:5 141:18 148:5
occur 62:6 90:14,15 91:2 105:4
35:22 54:25 109:14,18,22 99:20
115:6 118:1 133:16,20
oxygen
particularly 54:24
occurred 62:5,7 70:11 91:7 95:12
134:6,24 135:10,13 136:7
7:22 8:8,15,21 9:10,14,21 parts
136:10 137:1,5,14,16 140:3 14:12,15,16 111:22 112:23 11:22 12:6 23:10,11,11
138:18 139:7 150:20
140:22 141:2
112:25
24:4 25:5 28:17,20,23,24
occurs 116:10
opinions 4:255:11,17,196:5,24
29:1 35:17 37:8,14,15,17 37:18,19 52:17 78:7 84:11
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6797
[parts - population]
parts (cont.)
pcbs (cont.)
person
plaintiffs
84:11,14,20 85:5,16,16,16 141:2,20 143:17 146:23
5:3 25:1 27:4 36:11 38:9
1:4 2:43:4,15,186:11,14
85:18,22 86:3 87:5 110:19 147:3,17,23 150:3,7,22
67:3 82:11 91:10 105:13,19 plaintiff's
133:13 140:4
151:2,15,23 152:2,6,9,13
154:14
2:16,1740:10,13 118:8,13
patiently
152:15,19
personally
plant
95:21
pcdf
5:13 65:4,7,15,24 66:1,4,6 80:24
patients
51:24
personnel
81:5 83:5,5 84:4 88:6 89:8
151:1
pcdfs
15:18 57:9 66:3
89:13 91:11 148:24
pay
25:24 26:8 102:18
persons
plants
75:6
pediatrician
23:3 28:15
65:11
pc
135:20
person's
plaza
56:10 87:25
pending
106:8,12
154:18 155:4
pcb
3:13 117:5
phasing
please
5:15 6:8 12:7,8 14:7,16,23 penetrate
18:9,22
13:2 21:21 37:6 38:15
21:23 22:7 23:6,10,20 24:6 76:17 77:4
phrase
43:11 67:21 89:5 91:18
25:9,9,10 27:10 28:17,20 penetrates
49:5 68:20
95:2 96:17,18 103:10
33:18 51:24 56:7 64:14
76:16
physical
plugged
65:4,7,10,18 69:10 76:14 people
94:3,12 107:17 108:7
149:25
76:20 83:16 87:8,11,13
13:4,7,8 16:24 22:10,15,17 124:12,16 125:2 137:2
plus
88:9 100:19 105:3,15,17
27:11 30:20 31:7,14 33:8
140:14
9:11 142:14,14,16,16
106:5 108:10,11 109:19
34:5,14 35:1,3,4,10,21 36:7 physicals
143:22,23
110:5,14,15 116:15
36:9,10 43:2 45:7 49:12
94:13
pneumonia
pcbs
50:11,2351:11 57:1661:12 physician
129:25 131:1,19 132:3
4:23 5:7,9 6:17 7:1,17
63:17 66:23 70:13 73:21
6:16 80:24
140:20
11:11,16,17 12:9,12,13,13 77:8 81:2,12,23 83:4 84:2,3 pick
point
12:17,21,21 13:11,22,22,24 84:6,13 85:18 87:10,21
56:1691:15
5:22 20:6 30:5 41:9 74:16
14:3,5 15:9,20 16:11 17:5 88:1,1,20 89:15,19 94:22 picked
74:21 84:16 86:2 92:10
17:10,21,25 18:5,20,25
99:12 103:4,20 104:24
58:17
94:17 125:17 126:1 148:9
19:11,25 20:8,10,21,25
105:12 107:10,23 108:8,11 picking
153:5
21:1,11,25 22:11,17,18
109:6,7 110:2 120:22
88:24
pointed
24:12 25:12,17 26:5,25
121:18 131:15 133:8,10 piece
146:13
27:13,18,18,25 28:2,2,5
134:16 144:3
52:7 94:18
points
29:6,12,24 31:4,10,12,13 people's 31:25 32:4,6,8,9 33:23 37:4 89:1
pig 114:23
142:13 poison
37:21,25 38:23 39:17 44:22 percent
pigmentation
31:6,14 34:4,14 35:10,21
48:16 56:8,10 57:10,20
24:11 25:3 74:23
45:8 46:14 128:23 151:8,9 75:20,22 76:1 77:5 78:25
58:20 59:20 60:7 61:10,12 percentage
151:16
poisoned
61:20 62:15,20 63:21 66:10 46:15 52:14 76:25 106:17 pigmented
22:15 25:11,12 26:25 27:10
66:17 67:6 68:21,22,24
106:23,25 133:8
139:6 151:1,2,4,6,14
27:21 30:20 33:8
69:1,2 72:5 76:5 77:3,9,25 percentages
pimple
poisoning
84:3,8 86:2 87:2,3,4,15,18 107:9
150:18,18,19
26:10 36:7 47:13,23,25
88:19 89:7,19,23 90:2,12 performance
pint
49:16 77:7,7 78:6 87:25
91:1,7 92:19 93:15 95:4,8 142:12
22:21 23:4 50:24
105:4 118:19,21 119:6
96:24 97:14 99:4,11,25 performed
pints
120:6 130:10
100:4,8,10,12,13,19 101:10 141:14
27:4 29:18,24 30:19 50:22 poisons
101:16,22,25 102:3,4,9,21 perimeters
place
78:23
103:14,23,25 104:17,20
135:7
10:9 18:15,1850:1967:11 polychlorinated
108:8,12,14,16,23 111:9,24 perineal
107:18 111:19 120:17
47:13 56:6 119:7 120:6
112:2,4 113:4 114:11 115:7 138:19 139:2 140:11
153:9
130:10,13
115:8,11,13 116:3,7,22,23 period
placed
pool
117:11,17,19,23 121:9
23:8 36:11,23 76:12 81:24 83:5
37:10
126:22 127:2,8,12,14,15
126:14
places
poor
129:1 130:1,3 131:2,10,10 peripheral
52:16 102:25 103:9 111:12 131:18
132:1,6,22 133:16,24 134:1 101:2
111:13
population
134:4,24 135:10,10,13
perry
plaintiff
137:13 143:12
136:7,22 137:3 140:4,22
155:12
71:7
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6798
[portion - questions]
portion
private
protection
76:15
119:20
49:15
position
probability
protein
18:11 19:16 135:8
35:20 144:17
111:21
possession
probable
proteolysis
12:19
35:19
147:19
potential
probably
protocol
16:2 116:12
24:5 39:12 84:1 132:18
81:21 92:17
PP 24:4
problem
prove
20:5 31:24 49:4 50:3 66:10 108:2
practically
77:18 103:21,22 104:1
provide
14:16
112:18 114:23 116:24
4:22 5:7,8 7:20 33:6 41:3
preceding
143:11
71:6,24
89:24
problems
psychic
precise
26:3,3 29:25 44:17 45:2,4 103:22
4:21 46:5 54:3 60:19 61:8 45:10,14 46:1,22 47:21
psychological
85:2,13
48:6,8,11,12,13,21 49:1,3 104:12
preformed
78:7,18,19 89:22 92:18 psychologist
91:10
93:4 95:11,12 102:8 106:18 144:2
preliminary
106:23 107:1 108:4,10
public
123:23
109:15,17,20 145:1
3:12 13:17 116:14 155:19
premature
procedures
publication
45:9
66:23 88:23
42:15,16 123:13
prepare
proceed
publications
60:22 93:13,21
130:21
15:1 62:17 105:17
preparing
proceeded
published
4:6 6:19 7:12 83:21
82:9
21:6 47:1249:14 116:15
presence
process
145:15
5:14 7:16 19:25 21:24
65:23 110:25 111:6
puffing
present
processes
113:1
18:3,8 35:23 36:13 47:1
111:2,4
pulmonary
49:13 64:1 86:20 94:8
produce
82:5
98:14 103:12 124:12
127:9 129:1 140:23 141:3 puncture
127:23 128:1,2
152:19
86:21
presenting
produced
purchased
20:25
3:8 60:6 61:20 129:11
67:6 148:25
pressure
131:2
pure
65:14 82:20
product
8:22 9:24 12:7
presumably
62:20 66:25 70:8 134:10 purpose
37:3 125:3 129:14 144:3 production
10:15
presume
18:25 19:6,12 62:14
pursue
98:5
products
71:9
pretty
57:19 59:19 61:9 63:21
pustular
4:5 24:12 33:14 61:1 122:2 64:4 121:9
152:21
previous
professional
pustule
39:8 67:22 96:20 133:3
1:24
150:12
previously
prominent
pustules
15:7 117:12
117:8 136:21
150:5,23
primarily
pronounce
put
110:20
139:24 140:25 141:5
42:16 51:2 78:5 123:22
principal
proper
151:20
116:24
50:19
putting
principally
properties
87:1 144:16 145:18
104:1
72:5
prior
propounded
22:2 41:1557:11
67:22 96:20 117:5
q
qualifications 120:18
qualified 121:19
quantify 107:4
quantities 111:9 114:6
quantity 26:11 27:18,19,20 28:5 30:19 77:5 78:1 87:4,5 112:5
quart 30:3 50:24
quarter 30:12
quarts 22:22 23:5 27:4 29:18,24 30:1,19 50:22
quaterphenyls 22:19 27:20 29:3 60:3 100:14 102:5 117:19 126:23 127:9,16 129:1 130:2,4,18 131:3 133:17 134:5,24 135:14 136:8 137:4 140:23 141:3,20
question 4:186:27:1216:3,13,14 19:15 21:4,7 27:24 30:1 31:12,18 32:15 33:1 34:24 35:14 38:15,23 39:4 40:18 43:16 44:4 47:11,20 48:24 49:8 50:13 52:10 53:5,8,13 53:13,15,19,22,23,25 55:18 55:21 67:7,12,14,18,19,21 67:23 68:1,15,21 69:18 70:1 73:23 89:4,5 90:5,5,6 90:9 91:17,19 92:16,21,24 93:7,11,17 94:25 95:15,22 95:23,24 96:1,5,6,11,13,14 96:18,21,22 97:3,5,9,11,25 98:20 99:7,9 100:22 106:2 106:20,22 110:11 112:16 114:17,25 115:21 117:3,4,6 118:15 123:20 124:2 127:18 128:5 129:12 130:22 134:18 135:8 138:22 147:1,9,22 152:1
questioning 42:9 123:11
questions 4:2 5:19,24 6:20 27:24 28:12 31:16,18 32:20 37:1 43:12 90:17 94:5,6,6 95:21 95:21 97:7 121:20 122:18
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOQ6799
[question's - respiration]
question's
real
reduced
remover
27:8
101:21
11:23,24
76:10 151:20
quicker
realize
reduction
render
43:15
12:16
143:18
4:135:11
quite
really
reexamination
repeat
15:25 22:20 36:12 50:25
16:21 53:24,24 54:24 62:7 46:15
67:19 76:12 89:21 97:11
78:4
92:1 96:9 126:9 137:11
refer
99:9 117:4
quote
143:14,15
5:23 81:4,7 123:1 124:8 repeated
54:14
reason
136:17 148:7
66:22 78:6,10 134:20
quoting
22:9 62:9 72:22 80:15
reference
140:20
53:1_____________________ 86:25 87:23 109:16
75:20 135:16
repeatedly
r reasonable
referred
88:24
rabbits
68:3
15:6 133:14
repeating
78:5,13,15 ragan
120:21 raised
39:1
recall
referring
6:3 10:14 12:2,24 13:4,7,8 40:25 68:23 148:13,18
21:5,16,23 39:2 44:12
reflected
45:11,1846:4,5,9,10,11,25 21:24 146:6
47:16 64:18 70:16 73:8 reflects
152:21 repetitive
36:25,25 rephrase
93:19
ran
117:7 118:17 141:21
16:9
report
82:4 range
recap 148:17
regard 122:18
89:24 125:13 126:11 reported
23:20,21 24:1,2 52:17 59:16,21 60:6 84:13 rate
receive 10:11
received
regarding 7:16
region
93:6 102:24 103:8,13,13 116:21 124:13 126:19 128:13
128:5 143:7 rationalize
66:8 70:25 83:8,15 recess
140:11 registered
reporter 40:9,12 67:20,22 95:14
14:14 rats
26:3,4 33:18 34:10 78:5
40:9 79:11 115:3 121:3 recite
122:11
1:24 reinforce
109:18,22
96:15,18,20 117:5 118:8,13 reporters
1:24
ray 82:24
recognize 42:11 84:24 90:11
relate 103:18 132:2,5
reporting 1:23 124:14,14 155:12
rays
recognized
related
reports
107:17 108:1,5 react
103:4 reaction
75:25 reactions
111:7,10
107:13 recognizing
94:25 recollect
80:21 recollection
11:7 12:15 13:7 18:2,3
103:19 112:20 132:22 relating
4:23 83:13 relationship
70:10 130:1,13 131:23 132:1,2 relative
104:22 123:23 133:6 141:17 represent 88:25 121:22 representatives 153:7 represented
read 16:19,20 27:6 28:8 31:2
63:18 record
12:12,20 13:5,8 40:3 57:5,9 3:18,21 62:17 86:2 107:14 132:9 reputation
35:8 40:16 43:17 44:7,15
4:20 5:20 7:6 41:10,24
relatively
119:8,15,24
45:1346:347:6,8,10,11,16 47:1649:14,18,22 51:19 54:12 67:20 75:15 95:14 96:11,12,18 104:21 107:8 114:10 118:15,17 120:14
75:16 121:13,20 153:1,2 recorded
117:10 records
5:126:10,13,17
34:1 relevance
143:15 reliable
121:17
request 17:11
requested 10:5 73:8
rescheduling
121:5 122:3,23 124:11 129:23 130:20 140:15 141:17,21 143:14 reading 51:16,17 87:2
rectum 139:3
red 150:15
redistribution
relied 116:13,13,14 123:18
rely 116:11
remainder
153:3 research
10:20 47:3 119:13,17,17,22 resolved
149:11
reads
115:8,11
41:2 42:20
respect
121:1 ready
43:16
reduce 19:10,20
remember
49:15 122:13
7:9 12:5 18:8 31:2 45:19 respiration
56:8 81:20 88:8,22 109:3,4 112:6,9,21,25
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOO68OO
[respiratory - shortness]
respiratory
right (cont.)
saw (cont.)
seen (cont.)
98:11 101:17
128:21 129:9,18 130:23,25 149:7
117:24 126:19 135:24
rest
131:16,20 136:6,13,24
saying
136:21,22 138:21 151:5
27:25
138:15,23 139:4,6,14,17,21 6:2 14:14 25:12 34:20,20 seizure
restrict
139:24 141:8,12 142:4,7
53:2 71:11 86:17 92:11
131:25 132:1,3,5,8
39:3 43:11 69:2
143:7 144:6,21 145:16
93:4 127:12 133:18 146:8 seizures
result
148:7 149:3 150:17 151:18 says
132:6
64:7 77:12 112:5 113:5
151:24 152:5,13,19,23
28:2 34:23 42:25 80:22 selected
114:12 115:7 116:3,8,22
153:10
112:21 116:17 126:14
124:12 138:11
133:17 134:6,25 135:11,15 rings
135:25 139:16 151:13
self
136:8 146:23 147:18,23,25 14:12,13
scale
121:15
148:2,3
ripped
142:3
send
resulting 52:4 scars
80:16
65:14 112:9
robert
133:2,6,7,9,10 136:18
senior
results
60:1261:1962:18
138:8,10,13
80:7
11:6,8,24 70:4,6 85:3,14 rogan
science
sense
88:8 106:22
47:2,12 120:19
33:8 107:13 145:15
15:14 107:5
retired
room
sciences
sensitive
15:12,25 16:6,14 18:13
81:25 153:6,6
47:3 119:22
85:13
19:1621:8 22:1 61:15
rough
scientific
sensitivities
retirement
151:13,14,17,21
62:19 73:5,20,22 74:23
84:25
15:22 18:16 19:4,7,21 21:4 roughly
75:3 122:19
sensitivity
21:9,12,15 57:12
23:5 24:10 29:11 33:22 scientifically
11:18
return
round
107:11
sent
71:4
23:9
scientists
74:5 80:15 83:15,17
returns
rule
16:20,23 123:19
sentence
70:20
55:14
score
41:16 89:21 149:20
review
run
144:15
series
4:6,9 6:10,20 15:6 17:6
12:8 82:23 93:5 113:25 scores
28:6 40:25
32:23 45:20 75:12
running
143:7,14 144:10 145:1
serious
reviewed
69:19,23
seal
49:6,11 127:6,6
6:16,22 7:13 72:4
rutter
155:16
served
rice
7:8 144:22
search
15:16
14:1 22:22 23:4,11 24:15 25:2,4,4,6,7,9 28:16 45:1 45:1548:1599:11 117:18 121:8 122:14 125:19 richard 80:22 right 7:198:3,11,149:2,16,18 18:24 20:10 24:8,13 27:9 27:14,15 28:12,22 29:3,5
s
safe 66:23
safely 5:9
salaried 81:13 83:24
samples 88:15
71:17
serving
sebaceous
5:14
99:21 149:25 150:2,5,12 session
second
7:12
13:2 27:14 37:6 38:14 39:3 set
46:7 72:18 90:20 92:7
35:13,25 108:3 155:15
96:17 98:16 114:17 120:12 sets
120:15 129:21,22 138:14
9:9
142:1 145:3,6 149:19,20 seven
secondly
55:4 142:13
29:22 41:7 43:7,8,9,17 47:19 48:22 52:9 54:1,14 58:10,19 63:24 68:22 69:3 69:21 72:14 73:6,10,23
81:25 95:19 satisfied
32:5 sauget
74:14,20 75:9,11 78:14 79:17 85:20 87:1 89:4 90:24 91:21,22 92:3,13,16 94:23 95:17 96:8 98:15 102:20 103:12 104:5
65:4 80:25 81:2,3,5,5,8 83:5,5 84:4 89:8 save 71:5 73:1 75:18 saved
106:17 108:25 109:1
74:21
112:13 118:6 119:25 120:4 120:11,16 122:11 123:1 125:7,10 126:5,16 128:16
saw 7:9 22:1,3 44:1 73:2 83:12 83:14,18 89:10 108:8,11
135:6 secret
51:25 52:1 secrete
127:1 secreting
127:1 section
51:24 seen
6:13 11:25 21:22 40:23 42:1,3,10 43:1 44:5,10,13 57:7 60:19 94:11 109:2
severe 47:22,25
sex 113:12
sheath 101:6
sheila 3:11
short 40:9 79:11 121:3 152:25
shortness 98:12 101:18
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOO68OI
[show - stratum]
show
skin (cont.)
speak
starts
47:9,15 51:17 61:4 70:6
76:18,20,22 77:4,4,9,14,25 46:8
41:1482:11,15
118:4 123:7,9 133:7
78:16 82:13 86:9 93:4
speaks
state
showed
97:23 98:10,25 99:5,12,22 116:25
1:2 2:2 3:2,12,14 44:24
78:14,15 98:1 138:10,13
129:2,3,4,13,20 132:25 species
45:3,25 49:23,24 53:22
146:1
136:13,19 139:5,17 148:3 21:1 113:7,7 114:22 115:24 69:7 88:12 154:3
showing
149:11 150:2 151:2,11,20 116:10 134:10
stated
44:2
152:16,18
specific
11:10 23:2 25:24 125:11
shown
skins
24:11 29:12 53:12 107:4,7 statement
21:25 22:7 107:16
151:1,14
111:17
11:1233:11 39:1943:5
shows
slightest
specifically
102:17 104:24,25 108:4
103:4 138:11 143:25
83:11
115:1
154:9
shut
slightly
specify
states
120:25
143:3,3
55:17
16:9 17:1 45:23 49:15 67:5
sick
slow
specifying
69:16 84:17 126:16 149:20
103:20
125:9
55:10
stating
sign
slower
speculate
55:12 74:22 92:8
80:4 124:16 125:2
90:20
67:9 114:5 124:22,24 147:9 statistic
signature
small
147:10
88:5
80:1,3
33:14 129:9 150:5,12,14 speculation
statistically
significant
152:9
147:8
132:16 136:16 144:15
107:11 108:2 131:22
smaller
spell
stay
132:12,21 137:12 146:23
26:12,12,15
130:17
24:24 111:15
147:2,13,17,23
smart
spill
stays
signs
94:14
75:24
152:11
91:9 124:12 137:2
smith
square
steps
similar
43:8 71:3
151:5
99:23
14:1 76:10 118:21,23
soil
St
steroid
141:14
25:4
1:1,26 2:1 3:1,11,14,23
113:6,10,16 114:13 115:6
simply
sold
10:20,24 60:25 80:24,25 steroids
85:6 89:25
61:12
81:1,3,7 83:15 154:2,19
113:13
single
soluble
155:5,14
stipulate
11:21 45:19
76:19
stack
38:10
sir
somebody
75:2
stipulated
7:19 14:21 38:19,24 39:10 10:13 11:8 68:1475:14 staff
38:5
40:14 42:13 43:9 46:21
80:13,16 124:22
81:12
stipulating
64:9 70:18 73:6 74:14
somebody's
stand
38:7
75:11 78:14 79:14,17,20
143:2
15:15 136:2 149:10
stipulation
80:10 85:23 88:5 89:17 someplace
standard
71:6
91:24 92:16 98:15 100:18 28:24 35:4 49:12 82:20
107:11
stomach
101:24 102:20 118:6
somewhat
standing
76:3 99:18
120:16 122:10,11 123:25
33:16 54:17,20
100:22 122:17 123:10
stomachs
124:10 125:7 128:12 129:9 soot
124:1,4
93:3
129:18 130:23 131:16,20
57:21 58:4
standpoint
stop
134:23 136:6,24,25 138:15 sorry
17:21 47:25 98:15
18:20 153:5,8
139:4,10,12 141:16 142:4 23:25 59:10 72:10 79:10 Stanford
stopped
143:7 145:16 148:10,13,23 86:15 96:6 114:10 125:9
144:7
18:23,25 19:12
150:17
133:22,23 141:6
staple
stops
situation
sort
118:7
42:25
28:11 73:25 74:15
101:8,9 103:6
start
stored
six
sorts
108:21 110:18
115:8,11
58:1260:8 75:12 84:10,13 111:23
started
strains
85:18 129:25 131:1,9 146:9 source
105:6
134:22
skin
63:7 starter stratum
20:14 26:2,3 45:2,9,10
south
17:3 126:10
46:22 76:5,10,11,15,16,17 3:11,19
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMON006802
[street - ten]
street
supply
swimming
talking (cont.)
1:25 3:20 155:13
32:11
37:9
117:14,22 118:2 119:16
strength
supplying
swollen
125:24 133:23,25 134:2,4
133:15,17 134:6 135:1,6,7 32:22
128:16,19 140:1,7,8,11
134:21 139:13 140:16
strike
support
sworn
141:11 145:13 147:4
43:4 106:21,21
34:25
3:8
151:22 152:6 153:2
strongly
supposably
symptom
talks
96:9
138:10
82:5 90:25 91:2 102:24
41:18
studied
suppose
126:19 129:10
tape
53:20
14:24 60:8 147:4
symptoms
79:7 113:4 120:25
studies
suppression
35:1 49:6,10 82:5 89:18 tax
42:25 54:12 64:3,10,12,15 146:24
90:1,6 91:9,9,11,13,14
70:20 71:4
72:4,9,10,16,16,19,20,21 sure
92:18 93:1,1,13,15,22 94:2 taxed
72:24 73:2,3,4,8,9,11 107:9 15:24 17:3 35:22 36:8
94:4,7 95:1,3,11 96:23 97:3 155:1
107:12,22
38:16 58:21 59:25 61:1,2
97:14,17,19,21 98:1,23 tear
studio
66:22 85:8 88:8 90:6 92:1,1 101:20 104:22 105:1,3,7,21 40:22
153:6
92:2 93:12 94:13 96:12
106:8 107:3,5,10,14,18,20 teaspoon
study
102:23 108:21 109:2 131:4 107:22 122:13 151:15
23:13
64:5 67:2,3 68:4,6,6,7,8,12 131:14 134:21 135:17,22 system
teaspoonful
68:13,23,25 69:13,19 70:3 140:24 149:2
82:5,6 103:1,2
23:14
72:1773:13 109:10
surely
systemic
teaspoonfuls
subject
71:13
75:20,22 76:1,13,14 77:5,6 86:23
5:7 39:1 41:7,14,15 43:22 surprise
77:7,13,15 78:2,6,23,25 technical
79:5
127:4
79:6 82:4
5:2 81:3
subjects
surprised
systems
technician
4:23
145:14
94:4
81:14
subsequent
surveyed
129:23 136:1 138:10
104:24
subsequently
suspect
133:9
96:25,25 97:1,2
substance
suspected
68:10,11
96:25
substances
suspicion
18:21
89:18,22 90:4,14 93:14
substitution
95:4,6 96:23 97:14
52:16 54:6
suspicioned
suffered
90:1,25
33:9 108:3
suspicions
sufficient
97:17
34:14 35:9,21 50:10 51:10 suspicious
77:5,9 78:1,5,16,20 110:15 91:8
111:9 112:5 113:5 114:6,7 swallow
114:12,15 115:6,19 134:15 76:2
sugar
swallowed
111:21
99:17
suggestion
swan
29:23 30:4 50:25 107:8
73:19
suite
swann
1:25 154:18 155:4,13
73:19 74:1,6,9 148:24
sum
sweat
106:12
127:3
summarize
swell
5:21 127:22
summery
swelling
125:11
78:20 127:7
t technician's
table 82:17 122:9,9,10 123:1
81:18 teeth
124:9,11 126:16 136:24 137:2 138:13,14 141:12
45:2,9 46:14 127:23 128:1 128:2,3,18 129:12,16
tabulation
132:11,17,25 138:5,7
105:21 106:9,16 taiwan
47:14 118:19 119:3,7 120:7 125:4 128:8,9,13 130:11 taiwanese 13324
teething 128:18
tell 7:17 19:8 27:22 28:5 30:19 47:10,16 48:1 58:23 60:13 61:7 63:7 69:4,8 73:1 79:3
taken
86:8 87:3,7 96:1 113:17,22
40:9 41:1 42:15 44:10 79:11 94:20 115:3 121:3
132:16 139:25 telling
154:12
13:6
talk 9:22 90:6 118:5
talked 16:5 52:14 80:15,16 82:1 117:13 124:23 149:13
telorism 141:6
temper 96:7
temperature
talking 7:4,25 8:22 11:21 13:7 14:9 31:10,1034:1,10,11 35:16 37:1,10,18 44:20,21 45:8 48:11,16 55:4,15,24 57:11
14:1 57:22,23 60:16 132:4 temperatures 59:9,11 ten
58:16
59:16
57:22 59:4,5 67:24 68:18
12:5 24:11 25:3 26:15
70:9 77:24 93:23 100:4 102:2,4 106:4 108:8 112:21 112:22 115:24 117:1,2,12
33:10,21 37:8,15,17,18 54:19,21 57:4 60:20 76:20 85:1 138:11,12,14
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMON006803
[tenacious - treated]
tenacious
thing
threshold (cont.)
tomorrow
152:9,10,12
34:10 59:4 68:9 69:11
49:4,19 50:8 51:8
153:4,4
tenth
130:6 143:24 151:17
throat
tooth
30:14 36:10
things
82:13
137:7,19
tenure
77:8 90:14 91:6,8 93:5
thymus
top
6:22
94:14 103:4 127:20 129:14 26:3,4
80:22 109:1 125:11 135:25
term
143:1 144:17 151:7
thyroglobulin
topic
5:2,3 39:12 48:4 75:20
think
147:19
64:23
99:14 101:3 147:1 149:20 4:19,19 5:20,23 15:22
tighten
tore
termed
18:17 21:2,6 26:14 27:4,6 88:21
40:1941:11
45:11
28:5 29:22 30:6 32:19,19 time
torn
terms
33:12 34:6,20,22,24 35:11 7:2 11:2 18:3,8 19:2,17,24 121:13
51:2 99:2 100:25
36:7 37:24 38:3,4,8 39:6,20 21:4,19,23 23:8 26:18 28:2 total
terphenyls
40:1 41:20,25 42:7 43:24
31:17,21 36:9,11,13,23
25:10 35:3 84:2 106:12
52:12,23
44:4,6,9,20 45:6,20 46:7,8 47:1 49:13 50:17 58:24,25 155:6
test 47:22 50:15,16,18,21,22,25 64:1 67:8 71:5,9 73:1 74:12 totally
12:9 13:21 17:9 62:19 70:6 52:7 54:19 55:9 58:8 61:14 74:16,22 75:18 76:12 78:5 42:8 44:3 95:19 106:20
73:2 74:22 75:2 78:10 86:6 61:15,1962:1,11 64:21
81:23 82:8 83:12,17 84:7 toxic
142:21 144:7 145:6
65:2 67:8 68:1,11 71:18
84:17 85:11 86:2,20 89:11 14:18,23 15:9,19 16:10
tested
73:7 79:2 86:7 87:20 88:4 89:12 98:14 105:20 107:2,2 17:21 18:21 33:16 36:3,5
37:7,20 63:1 64:13 68:10
88:23 92:5,9,10,21 93:1,11 107:3,3 113:3 115:2 121:4 36:23 37:23,25 38:2 39:25
142:22
94:18 95:22,25 96:3 97:5,5 146:11 152:11,24
54:2,4,5,8,10,16,20,20,22
testified
98:1,13 102:9 104:6,19 times
54:25 55:12,13,15 56:1,4,7
38:10,21 65:3 71:8,24
105:15,15 107:5,8,14,14,15 15:16 24:7 25:8 30:23
56:10,17,22 63:22,23 70:5
91:23 145:7
108:17,17 115:4 117:7,15 49:25 50:4,6 51:5 54:19,21 70:6 79:6 98:18,22 134:15
testify
122:6 126:1,13 127:13,17 56:24 57:14 76:13 103:13 toxicities
38:18,22
128:5,6,7 129:8 130:5
103:13 106:10,10
34:2
testifying
134:8 135:12 136:15
tiny
toxicity
38:9 53:17 64:25
137:10,22 138:6 139:13
150:16,18
19:24,25 20:4,6,25 22:12
testimony
141:9 143:1,2,25 144:2 tiredness
22:14 34:1,8 38:21,23
5:22 27:17 31:9 35:7 37:20 149:1,1 153:5
98:12 101:23
39:14,19 40:2,4 44:16
38:4,20 44:25 70:17,23 thinking
tissue
47:24 48:1,6,25 49:19 50:8
73:7 81:8 84:25 92:3,12
130:5
76:2
51:8 52:17 53:4 55:16,21
121:15 124:6 133:4 146:5 thirdly
title
57:5,10 68:9 69:7,10,14
148:18
72:21
51:24 120:4 130:7,9,14,16 70:1 109:19
testing
thomas
130:19,20 148:19
toxicological
7:15 10:5,8,12,15,18 11:4 3:21 154:16 155:2
titled
17:21 67:1,3 68:23 72:5
11:23 12:7,8 18:5,15 19:3 thought
41:21 119:6
track
19:11 22:11 40:2 116:11,13 70:23 82:25 84:6 145:22 titles
114:9
135:7 141:13,18
146:9
45:17
transcript
tests
thousand
today
154:15 155:1
13:21 17:24 62:14 82:23
23:10,11,11 33:22 52:17,18 22:25 31:1 32:24 33:2
transcripts
141:14 142:25
54:11 70:25 71:1,2
34:13 38:20 49:23,24 66:8 155:8
thank
thousands
72:9 83:10 84:23 85:10 transfer
4:5 28:22 33:6 36:22 38:12 111:20
118:16
13:25 65:14,16 112:25
38:25 40:8 44:14 46:17 thousandth
today's
transformer
57:5 72:3 74:20 115:2
33:10
40:16
64:13,14
130:12 146:22
three
toes
translated
thanks
9:6,9 19:7 20:19 22:21 23:4 139:11,14,17
21:20 34:17
4:4
23:12 27:14,24 37:19 54:21 told
translates
thereare
57:23 84:1 106:10 108:19 52:1260:10,11,14,14,21
23:4
59:24
113:3 120:21,22 122:10
61:8,1063:18
translating
therewith
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104:17 106:22 110:9 145:3 74:8
65:17,19
44:16 47:24 48:2,7,9,25
145:20
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMON006804
[treatment - withdraw]
treatment
understands
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73:17
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wire 101:8
wise 142:1
withdraw 31:22
Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMON006805
[witness - zeros]
witness
wrote
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38:8 42:1 48:19 52:5 64:25 149:14__________________
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13:9 26:7 80:9 82:24 93:25
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Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 2
LEXOLDMONOO68O6