Document RaXy0KR8mYy7v0ENQrmpqx6dX

Page 130 1 Q Now have you asked Ford or General Motors or 2 Chrysler how many prior claims they have had where 3 individuals with mesothelioma with no other known 4 exposure to asbestos brought lawsuits against them? 5 A I've not asked that question. 6 Q Why not? 7 MR. LANKFORD: Calls for speculation. 8 JUDGE KLINE: If he knows why not. 9 BY MR. RUCKDESCHEL: 10 Q No, I'm just asking why he hasn't asked. 11 A Well, what you're asking is why haven't I asked 3 i 1 12 them to do some sort of mini epi study to refute what 13 Lemen and Engleman claim must be occurring because they 14 think that there are too many meso cases for the number 15 of brake mechanics that are alive. And if you add up i 3 16 all the plaintiffs' cases they believe that the math 17 doesn't work. That's really what you're asking me. 18 Q Well, that is sort of the substance of what 19 I'm getting at, is one could go back and look through j 20 the materials that were collected in litigation from 21 prior cases. 22 A That's right, you could. 23 Q And there's recent paper that was published 24 regarding household mesothelioma where the author, j j j 25 Albert Miller -- and I'll mark it as Exhibit 8 since | | ESQUIRE DEPOSITION SERVICES (415) 288-4280 -4