Document NeVG8oYeDqpJMQ573YmVnZkeE
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1 there are rase reports of individuals who actually did
1
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We also know that Ford maintained a medical
2 not work around asbestos, but were wives who washed 2 library and that is interesting, too, since 1928, and
3 their husbands' clothing that had asbestos on it that
3 Ford knew that the first case report that was
4 developed this rare disease.
4 associating asbestos exposure with asbestosis, another
5 There are also rases of individuals who
5 disease caused by asbestos, was published in 1907.
6 lived near plants, who lived near asbestos plants. 6 However, knowing that, no warnings were
7 Never worked in the plants.
7 placed on any Ford brake products until 1980, which is
8
Just lived nearby, and those individuals as
8 just a little too late for Mr. Wood and Mr. Grewe.
9 a result of that small dose of asbestos developed this 9
We also know Ford prior to Mr. Wood going to
10 rare and terrible cancer.
10 work at the United States Post Office garage knew in
11 By a preponderance of the evidence, which is 11 1948 there was an article entitled. Asbestos Used in
12 a standard that we have to meet in this rase as the
12 the Ford Relation of Brake Lining is a Potential
13 plaintiffs, we have the burden of proof in this case.
13 Harmful Compound, and this is before Mr. Wood worked
14 We have to prove our case.
14 at the garage.
15
What that standard means is that we have to 15
Again, from 1949 to 1974, Ford Motor Company
16 tip the scales ever so slightly in our favor to meet
16 was a member of the Industrial Hygiene Foundation, and
17 the burden.
17 you will hear more about that organization throughout
18 If my hands were a scale and they are evenly 18 this trial.
19 weighed, all that we have to do is just tip the scales 19
The defense will also have some witnesses,
20 ever so slightly in our favor.
20 and I would like to speak briefly to you about those
21
I contend we will do more than that, but we
21 when you hear those witnesses come in.
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1 will meet the burden of proof, and in Mr. Wood's rase, 1
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Those witnesses are going to tell you that
i
2 as in Mr. Grewe's rase, prove to you that the asbestos 2 you cannot get this asbestos cancer from brake
3 exposure that he had from Ford brakes is what caused 3 material.
4 him to develop his mesothelioma.
4 I would like you to consider several things
5 THE LAW CLERK: 10 minutes, counsel.
5 when you hear some of those witnesses that will
6 MS. HINES: Thank you.
6 testify for you on behalf of these asbestos companies
7 At this time I would like to talk to you a
7 or on behalf of Ford.
8 little bit about Ford Motor Company which has already 8
One witness is a witness by the name of Dr.
9 been discussed somewhat with you.
9 Otto Wong.
10 Ford Motor Company is a company that made 10 When you hear Dr. Wong testify, I want you
11 these brakes with the asbestos -- excuse me, with the 11 to consider and the evidence will show that Dr. Wong
12 asbestos in them, and I believe it has already been
12 has spent his entire life defending the chemical and
13 stated that the asbestos content that was in the Ford 13 asbestos industry.
14 brakes that had been in those brake linings ever since 14
You will also hear probably from a Dr. John
15 they first started manufacturing cars, which was as
15 Craighead and when you hear Dr. John Craighead tell
16 far back as 1909, that those brakes contained 40 to 60 16 you that asbestos from brakes does not cause asbestos
17 percent asbestos by weight.
17 cancer, the evidence will show pointed out on cross-
18
So what that means, if there is one brake
18 examination that Dr. John Craighead has spent the last
19 lining, and there are four on a car, that contains
19 10 years of his life testifying for these asbestos
20 four pounds or 16 pounds of brake linings on a
20 companies and in the course of that time he has made
21 vehicle, then half of that weight is asbestos.
21 somewhere between 1 to $2 million doing so.
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