Document RJG0wBzqVadZynzVyEN0w0vXn

Page 135 1 THE WITNESS: I'm not aware of significant 2 alternative exposure. 3 BY MR. RUCKDESCHEL: 4 Q And the adversarial process of these lawsuits 5 is such that in the Hicks case this previously 6 undisclosed exposure was revealed prior to trial? 7 MR. LANKFORD: Objection, -- what is the 8 question if I could have it read back? 9 JUDGE KLINE: You want to repeat the question? 10 BY MR. RUCKDESCHEL: 11 Q Sure. I'll repeat it. In the Hicks case, the 12 adversarial process and the discovery process of the 13 litigation revealed this previously unknown crocidolite 14 exposure before trial, correct? 15 A Yes. 16 Q And in fact the information that you receive 17 in cases like this case, and I've read your report, and 18 it lists all the information that you've gotten, is 19 more comprehensive than the information that, for 20 example, Ms. Teta had in her study from the 1980s 21 regarding the subjects of that study? 22 A It's an apples-and-oranges comparison. I can't 23 answer your question that way. 24 MR. RUCKDESCHEL: Okay. Let's take our lunch 25 break. ESQUIRE DEPOSITION SERVICES (415) 288-4280