Document RpRY69RZMBoEy71Vo7j5nrrkv

In The Matter Of: Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 Concannon & Jaeger General Court Reporters 705 Olive Street Suite 604 St. Louis, MO 63101 (314) 421-1000 Original File roushl.dep, 121 Pages Word Index included with this Min-U-Script WATER PCB-SD0000022914 WATER PCB-SD0000022915 Nevada Power Company v. Monsanto Company, et aL George Roush, Jr. March 17,1993 Page 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA NEVADA POWER COMPANY, ) Plaintiff, ) -vs- ) # CV-89-555-LDG (LRL) MONSANTO COMPANY, GENERAL ) ELECTRIC CORPORATION, et ai., ) Defendants.) INDEX WITNESS: Page: GEORGE ROUSH, JR. Direct Examination by Mr. Bradley 4 EXHIBITS Roush Deposition Exhibit Number 1 ... 20 Roush Deposition Exhibit Number 2 ... 22 Deposition Exhibit Number 979 ......... 71 Deposition Exhibit Number 1251 .... 103 Deposition Exhibit Number 1421 .... 106 Deposition Exhibit Number 367 ......... 107 Deposition Exhibit Number 350 ......... 108 Deposition Exhibit Number 424 ......... 110 Deposition Exhibit Number 1154 .... 111 Deposition Exhibit Number 1425 & 428 .112 Deposition Exhibit Number 517, 422 & 709 . 113 Deposition Exhibit Number 359 &. 340 ..114 Page 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA NEVADA POWER COMPANY, ) Plaintiff, ) -vs- ) # CV-89-555-LDG (LRL) MONSANTO COMPANY, GENERAL) ELECTRIC CORPORATION, et al., ) Defendants.) DISCOVERY DEPOSiTlON OF WITNESS, to be Used in an action pending in the District Court of the United States, for the District of Nevada, wherein NEVADA POWER COM PANY is Plaintiff, and MONSANTO COMPANY, etal. are Defendants, pursuant to Notice, under the provisions of Rule 26 of the Rules of Civii Procedure, taken on March 17, 1993, at the law offices of Messrs. Husch & Eppenberger, 100 North Broadway, St. Louis, Missouri, before John T. Concannon, a Notary Public within and for the State of Missouri. APPEARANCES The Plaintiff was represented by Mr. Ralph A. Bradley, of (he law firm of Bradley & Merrell, c/o Jones, Jones, Close & Brown, 300 South Fourth Street, Ste. 700, Las Vegas, Nevada, 89101. The Defendant, Monsanto Company, was represented by Mr. Bruce A. Featherstone, of the iaw firm of Kirkland & Ellis, 1999 Broadway, Ste. 4000, Denver Colorado, 80202. The Defendant, Westinghouse Corporation, was represented by Ms. Laurie Basch, of the iaw firm of Weil, Gotshai & Manges, 767 Fifth Avenue, New York, New York, 10153. Page 4 Page 4 ID GEORGE ROUSHJR., (2) of lawful age, being first duly sworn to tell the truth, [3] the whole truth, and nothing but the truth, deposes and [4] says on behalf of the Plaintiff, as follows: [5] DIRECT EXAMINATION [6] QUESTIONS BY MR. BRADLEY: [7] Q: Dr. Roush, my name the Ralph Bradley, and you [8] and I were intro duced to one another just a few mo ments [9] ago. Is that true? [10] A: Yes, sir. [11] Q: I represent Nevada Power Com pany in this [12] lawsuit that they have brought against Monsanto, [131 Westin ghouse and General Electric; you under stand that, [14] don't you? [is] A: Yes. [i6] Q: Are you here, today, represented by an [i7j attorney? [18] A: Yes. [19] Q: If, during the course of the deposition, I ask 120] a question that's not clear, will you tell me? [21] A: Yes. [22] Q: And if you give an answer to a question, I'm [23] going to assume that you understood the question. Fair [24] enough? [25] A: Yes. Page 5 [ l] Q: All right. And if, at any time during this [2] afternoon, you want to take a break, you just let us know [3] and we'll accomodate you, all right? [4] A: Yes. , [5] Q: What is your residential address? [6] A: 10 Babler Lane, B-a-b-l-e-r, St. Louis, 63124. [7] Q: Are you presently employed? [8] A: Retired. [9] Q: When did you retire? [10] A: 1988. [U] Q: Let's start this deposition by having you [i2j describe your education al background, beginning with [i3i col lege. Where did you attend college? [14] A; University of Wisconsin. [15] Q: Did you receive a Bachelor's De gree from the [i6] University of Wiscon sin? [17] A: My education was interrupted by the war. [is] Q: All right. So you began college at the [19] University ofWisconsin and then went into the military? [20] A: Yes. [21] Q: What branch of the military? [22] A: Signal Corp. [23] Q: And what was your rank when you got out of the [24] military? [25] A: First Lieutenant. Page 6 HI Q: Did you return to college when you got out of [2] the military? 131 A: Yes. 1946. [4] Q: Where did you go to college in 1946? [5] A: Wisconsin. [6] Q: Did you receive a degree from the University [7] of Wisconsin? [8] A: I didn't take the degree right away. [9] Q: Okay. Did you ultimately get a de gree? [10] A: Yes. [11] Q: What degree did you get? [12] A: Washington University Medical School. H3] Q: And you got that degree when? [14] A: 1951. ______________ [15] Q: And I take it, your degree was as a medical [16] doctor? [17] A: Yes. In that interim, I went back and got my (is] degree from Wisconsin. Just had to write and get it. U9] Q: All right. So you received a Bachelors Degree [20] from Wisconsin? [21] A: Yes. [22] Q: Did you intern? [23] A: Yes. [24] Q: Where did you intern? [25] A: In Milwaukee. Milwaukee County Hospital. Page 7 [1] That's a teaching hospital of Mar quette. [2] Q: Did you obtain a specialty when you went [3] through your medical train ing? [4] THE WITNESS: Will you ask the ques tion again? [5] Q: (By Mr. Bradley) Yes. Do you have a [6] specialty in any area of medicine? [7] A: Yes. [8] Q: What is your specialty? [9] A: Occupational Medicine. [10] Q: Describe for me the training you have had in [iij occupational medicine? [12]A: In 1951, went to the University of Pittsburgh [13] and have a degree from the School of Public Health. It's [i4] called a Masters in Public Health in Oc cupational Medicine. [15] Q: Was the Masters through any medical school? [16] A: It was at the University of Pit tsburgh School [17] of Public Health. [is] Q: All right. But the School of Public Health [193 wasn't part of the School of Medicine? [20] A: No. It's--They're both part of the [21] University of Pittsburgh. [22] Q: All right. And do you have any other degrees [23] from any other institu tions? [24] A: No. [25] Q: I take it, you became licensed as a medical Page 8 Ii] doctor at some point? [2] A: In 1957. [3] Q: How long did you attend the University of [4] Pittsburgh in their School of Public Health? [5] A: Two years. [6] Q: You graduated in 1953 from the University of [7] Pittsburgh? [8] A: In 1952. [9] Q: All right. [10] A: That was a post-graduate fellow ship I had. Concannon & Jaeger (314) 421-1000 Min-U-Script Page 2 - Page 8 WATER PCB-SD0000022916 George Roush, Jr. March 17, 1993 Nevada Power Company v. Monsanto Company, et aL Hi] Q: Upon graduation from the University of [i2j Pittsburgh, did you ob tain employment? [13] A: I went to the National Cancer In stitute at [14] Bethesda. [15] Q: And that was in 1952? [16] A: Yes. [17] Q: What did you do at the National Cancer [is] Institute in 1952? [19] A: I had a clinical fellowship in can cer therapy. [20] Q: Did the fellowship relate to your Masters [2i] Degree in Public Health and Occupational Medicine? [22] A: Not directly, but it was my pur pose. [23] Q: All right. [24] A; It was chemotherapy. understanding [25] Q: How long was the fellowship at the National Page 9 [1] Cancer Institute? [2] A: One year. [3] Q: What did you do when the fellow ship ended? [4] A: Went to the Stanton Island Marine Hospital, [5] residency in medicine. [6] Q: How long were you at Stanton Is land Marine [7] Hospital? [8] A: One year. [9] Q: What kind of medicine did you practice in your [io] residency? [11] A: Internal medicine. [12] Q: What did you do at the end of your residency? [13] A: I'm not finished yet. [14] Q: All right. Go ahead. [15] A: I went back to the University of Pittsburgh. [16] Q: And why did you do that? [17] A: I finished my residency in internal medicine. [18] Q: When did you finish your residen cy in internal [19] medicine? [20] A: That year. One year. [21] Q: In -- [22] A: '57. [23] Q: Help me for a moment. I have you at the [24] National Cancer Institute for one year beginning in 1952; [25] is that correct? [1] A: Yes, sir. Page 10 [2] Q: In 1953, you went to Stanton Is land Marine [3] Hospital for one year? [4] A: Yes. [5] Q: So that's 1954.1954, went back to the [6] University of Pittsburgh to finish your residency? [7] A: Yes. [8] Q: And you finished that in 1957? 19] A: Yes. [io] Q: When you obtained your residen cy, was it [ii] common to have a four year residency? [12] A: No. [13] Q: Why did you have a four year residency? [14] A: Because mine was mixed up by spending the time [15] at NIH. [16] Q: What did you do when you finished your [17] residency in 1957? [18] A: Became part of the faculty at the School of [19] Public Health, University of Pittsburgh. [20] Q: What is the field ofpublic health? [21] A: Mine was not in public health, my was [22] occupational medicine. [23] Q: What did you teach, then, as part of the [24] faculty of the School of Public Health at the University of [25] Pittsburgh in 1957? Page 11 [i] A: I taught students coming there for a degree in [2] occupational medicine. [3] Q: What did you teach? [4] A: Occupational medicine. [5] Q: What is occupational medicine? [6] A: Understanding of the needs of in dustry in [7] occupational medicine.That included understanding of a [8] man's ability to work, the hazards associated with work, [9] responsibilities of occupa tional medicine to the company [io] with whom we are working. [ii] Q: What responsibilities are there of someone [12] practicing occupational medicine to the company with whom [13] they are working? [14] A: Helping them to understand what the workers in [15] that plant have in the way of problems associated with [16] their work. If the man has any injury or disability [17] associated with his work, that has to be communicated to [is] the management of the company. [19] Q:, How long were you at the faculty of the School [20] of Public Health at the University of Pittsburgh? [2i] A: During that time I was there, I was Assistant [22] Professor of Occupational Medicine. [23] Q: How long were you there? [24] A: Two years. [25] Q: And during the two-year time, was the subject . Page 12 [1] that you taught only occupational medicine? [2] A: No. [3] Q: What else did you teach? [4] A: I also taught internal medicine. I was [5] Instructor of Medicine. [6] Q: And then in 1957, you obtained a license to be [7] a medical doctor? [8] A: No, [9] Q: No. When were you licensed as a medical [10] doctor? [11] A: I'm not there yet. [12] Q: All right. [13] MR. FEATHERSTONE: You mean in terms of your [14] history; is that what you're saying? [15] A: Yes. I'm not there yet. [16] Q: (By Mr. Bradley) Okay. What did you do [17] following -- [is] A: I was still essentially in training. [19] Q: All right. [20] A: I went to University of Louisville. [21] Q: Was this in 1959? [22] A: '57/58.1 may be off a year. I can't tell. [23] Q: And what did you do at the University of [24] Louisville? [25] A: Had a fellowship in cardiology, one year. Page 13 [i] Q: What did you do in your fellow ship in [2] cardiology at the University of Louisville? 131 A: Became a cardiac consultant. [4] Q: How did you become a cardiac -- [5] Q: I became a cardiac consultant. I did cardiac [6] catheterizations. [7] Q: You received training to do that? [8] A: Yes. [9] Q: While at the University of Louis ville? [10] A: Yes.That's what I did. I did cardiac [11] catheterization. [12] Q: What is a cardiac catheterization? [13] A: Got a heart, and the question whether there is [i4] something wrong with one of the valves. Whether the heart, [15] the two sides of the heart are functioning; and you put a [16] catheter in one of the major veins in the forearm and go up [17] and you put it into the heart and then you measure the [is] pres sure inside the - outside the heart be tween the valves; [19] put another catheter in the major artery in the leg that [20] goes up on the other side of the heart and you study those [21] two parts of the heart's function. [22] Q: What did you do when you left the University [23] of Louisville? [24] A: Went to University of Cincinnati. [25] Q: What did you do at the University of Page 14 [i] Cincinnati? Page 9 - Page l4 Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022917 Nevada Power Company v. Monsanto Company, et aL George Roush, Jr. March 17, 1993 [2] A: I was Associate Professor of Oc cupational [31 Medicine. [4] Q: How long were you at the Univer sity of [5] Cincinnati? [6] A: Until 72. [7] Q: What did you do as Associate Professor of (sj Occupational Medicine? [91 A: Taught occupational medicine to physicians. [10] Q: Did you teach any courses, other than [it] occupational medicine while at the University of [12] Cincinnati? U3] A: No. [14] Q: When did you become licensed as a medical [153 doctor? [16] A: Didn't get licensed yet. [17] Q: All right. What did you do in 19 following [is] -- What did you do after the University of Cincinnati? [19] A: Went to Tulane Medical School in New Orleans. [20] Q: Why did you go the Tulane Medi cal School? [21] A: They built me a toxicology laboratory. [22] Q: What was your job title when you went to [23] Tuland Medical School? [24] A: Professor of Medicine. [25] Q: What did you do while you were at Tulane Page 15 [1] Medical School? [2] A: Ran that toxicology laboratory. [3] Q: How long did you run the toxicol ogy lab? [4] A: I've forgotten where I am in years. [5] MR. FEATHERSTONE: 1972. [6] MR. BRADLEY: I have that you went to Tulane m Medical School in 1972. [8] A: I was there for two years. [9] Q: (By Mr.Bradley) All right.What did you do [io] when you left Tulane Medical School? [11] A: I went to Monsanto Company. [12] Q: What -- [13] A: And got my license in medicine here. [14] Q: Does your license entitle you to practice in a [15] specialty? [16] A: Just medicine. [17] Q: What work were you doing at the toxicology lab [is] at Tulane Medical School? [19] A: We did toxicology. [20] Q: Well, on what kind of chemicals or products? [21] A: Whatever would be coming to us. [22] Q: All right. While at Tulane Medical School, [23] did you do toxicology on products manufactured by Monsanto? [24] A: No. That was before I knew Mon santo. [25] Q: During the two years you were at Tulane Page 16 [i] Medical School, did you do toxicol ogy workups on any 121 products con taining PCBs? [3] A: No. [4] Q: While at the Tulane Medical School, did you do [5] any toxicological workups on chemicals? [6] A: Yes. [7] Q: Which chemicals, do you recall? [8] A: On a number of chemicals. [9] Q: Any of the chlorinated aromatic hydrocarbons? [10] A: I don't think so. We did a number of them, [ii] The toxicologists did this short-term. Do it in a couple [12] of days so you could turn them over. We did no chronic [13] studies but we would have if I had stayed there. [14] Q: Doing all acute studies? [15] A: Yes. [16] Q: Were you working with animals? [17] A: Yes. [is] Q: Rats? [19] A: Yes. [20] Q: Mice? [21] A: Yes. [22] Q: Any other animals? [23] A: Not on any continuing basis. [24] Q: Why was it that you left the lab to go to work [25] for Monsanto? Page 17 [i] A: They were going to built me a toxicology [2] laboratory that would be more to my needs than the one I [3] had at Tulane. [4] Q: Who, at Monsanto, indicated to you that they [5] would build you a toxicology lab more suited to your needs? [6] A: Man who became my boss. 17] Q: Dr. Kelly? [8] A: No. [9] Q: Who? [10] A: Mr. Throtall, vice-president. [ii] Q: When you -- You went to Mon santo, then, in [12] 1974? [13] A: 1973. [14] Q: '3. When you went to Monsanto in 1973, had [15] Monsanto, in fact, built a toxicology lab? [16] A: No. [17] Q: For your use? [18] A: No, they had not. [19] Q: Did you say "No. They have now?" [20] A: They had not. [21] Q: All right. Did they eventually build a [22] toxicology lab for you? [23] A: Yes. [24] Q: When was that built? [25] A: I can't be sure. 1975 about. Page 18 [1] Q: What was your job title when you began work at [2] Monsanto? [3] A: Associate Medical Director. [4] Q: Who was the medical director when you began [5] your work at Mon santo? [6] A: Dr. Kelly. [7] Q: Was Dr. Kelly your boss when you began your [8] work at Monsanto? [9] A: Yes. [10] Q: Do you have an office in the medical area of [ii] Monsanto? [12] A: Yes. [13] Q: Describe for me the physical layout of the [i4] medical department at Monsanto when you went to work there [15] in 1973. [16] A: We had a clinical section, and we had one [17] physician, one physician working in that clinical section [is] and Dr. Kelly and I substituted and supple mented in the [19] clinical practice at Monsanto. That's one section. [20] Q: What other sections were there? [21] A: We had an industrial hygiene sec tion, headed [22] by Mr. Wheeler, and he had one or two industrial hygienists [23] working with him. I can't tell you when they came. [24] Q: What other sections were there? [25] A: Then there was a section on toxicology.* 2 * 4 * * 7 * 9 10 * 12 * * * 16 17 * 19 Page 19 HI A: Who ran that? [2] A: George Levinskas. [31 Q: What other sections were there? [4]A: That's it. We had -- What I was thinking [5] about is, we had a library and I'm not sure where that fit [6] into this. [7]Q: Were all of the sections housed in the same [8] building? [9] A: Yes. [10] Q: Were there other departments than the medical [ii] department in this one, in this building? [12]A: Yes. H3) Q: What other departments were in the building [14] that housed the medical department when you began work [15] there in 73? [16] A: An overseas operation. [17] Q: Did the medical department have one floor of a [is] building? [19] A: It had half of that first floor. Concannon & Jaeger (314)421-1000 Min-U-Script Page 15 - Page 19 WATER PCB-SD0000022918 George Roush, Jr. March 17, 1993 [20] Q: I'm going to hand you a piece of paper and ask [2i] you, if you would, to diagram for me the first floor of the [22] building that the medical department was in in 1973 and [23] indicate which part ofthe first floor was the medical [24] department. [25] A: I'm not sure how accurate. It was a long time Page 20 Hi ago and it was changed many times subsequent to this. [2] MR. BRADLEY: Let's have this marked as, I (3) guess, Roush Deposition Exhibit One. [4] (Whereupon, the reporter marked Roush Deposition Exhibit [5] Number One, for identification.) [6] Q: (By Mr. Bradley) All right. You've drawn [7] here your best estimate of the physical layout of the [8] medical depart ment when you began work with Mon santo in [9] 1973. [io] A: When I started. Hi] Q: And you've made some drawings that appear to [12] be rooms and you have some names, or other identifying [13] A: Yes. [i4[ Q: Explain to me, then, what you've done with [15] Exhibit One? [16] A: The entry hall into the building. [17] Q: What building is this? [18] A: A building. [19] Q: A building. All right. It's on what's called [20] the Monsanto Campus? [21] A: Yes. [22] Q: Go ahead. [23] A: And so as you come in, there's a receptionist [24] there. [25] Q: All right. And you've written "receptionist?" Page 21 [1] A: Yes. And next to her was a secretary. [2] Q: All right. Secretary had his or her own room5 13] A: No. It was open. [4] Q: Okay. [5] A: And next to her was Dr. Kelly. [6] Q: All right. Dr. Kelly was where? Would you [7] point? [8] A: Right here. [9] Q: All right. And you wrote "Dr.Kelly" there? [10] A: Yes. [11] Q: All right. [12] A: Then I was next to him. U3] Q: All right. [14] A: And we had an opening for another doctor that [15] was not there. [16] Q: All right. Page 20 - Page 25 Nevada Power Company v. Monsanto Company, et al. [17] A: And on the other side, we had examination tisj rooms and we had a section on toxicology and there were [19] three people. I'm not sure how they were situated. [20] Q: All right. [21] A: Then we had the industrial hygiene section. [22] Q: All right, And when you went to work for [23] Monsanto in 1973, was there a medical department library? [24] A: I'm not sure how formal it was. [25] Q: Was there an area that was referred to as the Page 22 [1] library? [2] A: Yes. [3] Q: Would you draw that? [4] A: I can't tell you where it is. [5] Q: Why is it that you can't tell me where it is? [6] A: Because we left there quite soon and went to [7] another building. [8] Q: I see. All right. And you don't recall where [9) the library was when you began your work there? [10] A: Right. [11] Q: All right. Would you draw for me now the [12] physical layout of the medi cal department when you moved [13] from what's referenced by Exhibit One? [14] (Whereupon, the reporter marked Plaintiff's Roush [15] Deposition Exhibit Number Two, for identification.) [16] Q: (By Mr. Bradley) We've now marked your [17] diagram that you have just prepared as Plaintiff's Roush [is] Deposition Exhibit Two. Can you tell me what that is? [19] A: We moved to another building. This is moving [20] over to G Building. [21] Q: All right. [22] A: And we were down in the base ment area there. [23] We had windows around the side but we were below ground. [24] Q: And what year did you move to G Building? [25] A: '78.[i] * 3 4 5 * * * 9 ' Page 23 [i]Q: And you have some markings on this Exhibit, as [2] well. Would you ex plain those to me? [3] A: This is the entry. [4] Q: All right. [5] A: Because we were a basement, we came directly, [6] right into my door, and my office was right adjacent to [7] there. So I was one of the few people who had windows on [8] both sides. My secretary was there. [9] Q: Uh-huh. [io] A: And we had the toxicology group right next to [in that, and we had in dustrial hygiene next, with Jack Garrett [12] as the head of it. [13] Q: All right. [14] A: And we had a library, and I'm not sure just [15] how it was located with respect to this, and Dr. Degarmo, [16] D-e-g-a-r-m-o, was our administrator. And on our other [17] side we had the physicians and industrial hygiene. [18] Q: Did you have any examining rooms? [19] A: No. The examining rooms were still back in A [20] Building and we had to hire an extra physician to take the [21] place of what we had been doing. [22] Q: So when you moved to G Building from A [23] Building in '78, the medical department still maintained [24] examin ing rooms in A Building? [25] A: Yes.The clinical facility remained there. Page 24 ID Q: What were your job respon sibilities as [2] Associate MedicalDirector in 1973? 13] A: To do the clinical examinations that this, the [4] full-time man was unable to do. [5] Q: Did you have other job respon sibilities as [6] Associate MedicalDirector in '73? [7] A: Yes. [8] Q: What else? [9] A: Visited plants to understand what kind of [io] operations, what they were doing. pi] Q: What other job responsibilities, if any? [12] THE WITNESS: Besides that? [13] MR. BRADLEY: Yes. I want you to tell me all [14] your job responsibilities in '73. [15] THE WITNESS: This was before, while -- [16] MR. BRADLEY: This is when you first began [i7] working there in 1973- [is] A: As I said, we had visited plants and worked [19] with the toxicologists, talked about their organization, [20] how they functioned and their respon sibilities. [21] Q: (By Mr. Bradley) All right. And when you [22] began work in 1973, who were the toxicologists with [23] Monsan to? [24] A: George Levinskas was in charge. [25] Q: Was the toxicology section under your Page 25 [i] authority as Associate Medical Direc tor? Mim-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022919 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 [2] A: It was under Levinskas'. [3] Q: Who did Levinskas report to? 14] A: He reported to Kelly. [5] Q: As the Associate Director, or As sociate [6] Medical Director, was your primary responsibility working i7j with the clinical section? [8] A: They were both major functions. [9] Q: All right. What kind of work did you do with [ioj the toxicologists in 1973? (ii) A: Participated with them with the definition of [12] what studies needed to be done and understand and interpret [13] the findings of their studies that were completed. [14] Q: When you began work in 1973, did Monsanto have [is] its own toxicol ogy lab? [16] A: No. [17] Q: And when did it have a toxicol ogy lab? Is [is] that the lab you indicated earlier was built for you around [i9] 1975? [20] A: Yes. [21] Q: In 1973, did Dr. Levinskas report at all to [22] you? [23] A: It was more functional than ad ministratively [24] so. [25] Q: What do you mean by that? Page 26 [i] A: Well, if he had a question about what he [2] should do next or whether we should do something, he came [3] to me directly. He didn't have to go through anyone else. [4] Q: Would he -- Do you know whether he would [5] normally go to you with questions about toxicology as [6] opposed to going to Dr, Kelly? [7] A: No. Levinskas is a nationally recog nized [8] toxicologist, and so what he did toxicologically was his [9] determina tion, but we would discuss what he was going to [io] do. HU Q: Was there a point in time when your title [12] changed at Monsanto? [13] A: The day Dr. Kelly retired. [14] Q: When was that? [15] A: December of '74. [16] Q: And you then became Director of the Medical [17] Department at Monsan to? [18] A: Yes. [19] Q: When you became Medical Department Director po] was Dr. Levinskas still in charge of the toxicol ogy [2i] section? [22] A: Yes. [23] Q: As Director of the Medical Department, did Dr. [24] Levinskas report to you? [25] A: Yes. Page 27 [i] MR. FEATHERSTONE: Would you read that [2] question back, please? [22] Q: Tell me what you remember about those five [23] depositions. When did they occur, who was there? [24] A: I can't. [31 (Whereupon, the reporter propounded the previous question.) [4] Q: (By Mr. Bradley) Who did you report to as [5] Medical Department Director in 1974? [6] A: I reported to Mr. Bible for a very short [7] period of time. [8] Q: What was his job title when you reported to [9] him? [ioj A: He was vice-president, and some administrative [ii] title. [12] Q: After you no longer reported to Dr. Bible, who (13] did you report to? [14] A: Mr.Throtall. [25] Q: Can you tell me the last time you had your Page 29 [i] deposition taken where the subject matter was, at least in [2] part, polychlorinated biphenyls? 13] Q: I don't know the name of it. This one was in [4] Houston. [5] Q: Do you recall roughly the year that you had [6] your deposition taken? [7] A: Five years ago. [8] Q: Do you know what the reason was why you had [9] your deposition taken in that case? [15] MR. FEATHERSTONE: Is it Dr.Bible? [io] A: There was concern for con [16] A: No. tamination. [17] Q: (By Mr.Bradley) And when you -- Do you [18] recall the date that you began reporting to Mr.Throtall? [ii] Q: Of- [12] A: By Monsanto. Three or four dif ferent [13] companies were involved. [19] A: No, sir. No, sir. [20] Q: Do you -- [21] A: But it was very short. [22] Q: Do you recall his job title when you began (23] reporting to him? [14] Q: And the contamination was of PCBs? [15] A: All chemicals. [16] Q: All right. Including PCBs? [17] A: I can't answer that. [24] A: He was Vice-President in Charge [18] Q: Well, at least PCBs came up as a of Research, subject [19] matter in your deposition? [25] Q: Was Mr.Throtall involved at all in [20] A: I can't even answer that. the[l] * 3 4 * * 7 * 9 * [ii] * 13 14 * * 17 * * 20 21 [21] Q: Do you maintain copies of the Page 28 [l] decisions to undertake various toxicological studies [2] regarding Mon santo products? [3] A: No. [4] Q: Those decisions, while you were medical [5] department director, were made by the head of the [6] toxicology department with your consultation? [7] A: Yes. And possibly informing transcripts of [22] any depositions where you've given testimony? [23] A: No. [24] Q: Do you know if those are kept anywhere? [25] A: No. Page 30 [i] Q: Did you review any ofyour deposi tion [2] testimony prior to appearing here, today? Throtall. Not [8] participating but more [3] A: No. informing. [4] Q: Do you recall which attorney rep [9] Q: Have you had your deposition taken before? [to] A: Yes. [ii] Q: How many times have you had your deposition [12] taken? [13] A: Ten to twenty. [14] Q: During the times you had your deposition taken [15] on previous oc casions, did you give information regard ing [16] polychlorinated biphenyls? [17] A: Yes. resented -- [5] Were you represented by an attorney when you had your [6] deposition taken in Houston? [7] A: I'm sure I was, but I shouldn't be that sure. [8] I think I was. [9] Q: Do you remember the names of any of the [ioj attorneys? [ii] A: No. [12] Q: Do you remember the names of the Plaintiffs? [13] A: No. [is] Q: Out of the ten to twenty times you had your [19] deposition taken, what's your estimate of how many times [20] you addressed the topic of polychlorinated biphenyls? [14] Q: Do you remember the names of the other three [i5j or four different com panies? [16] A: No. [17] Q: And other than the deposition in [21] A: Five. Houston, do [18] you recall anything at all Concannon & Jaeger (314) 421-1000 Min-U-Script Page 26 - Page 30 WATER PCB-SD0000022920 George Roush, Jr. March 17, 1993 Nevada Power Company v. Monsanto Company, et al about the other roughly four [191 times you gave depositions covering the topic of PCBs? [20] A: There was a deposition out in San Francisco. [21] Q: Is that in the early 1980s? [22[ A: Late '80s, I would think. [23] Q: Was that in a case called One Market Place? [24] A: Yes. [25] Q: Do you recall whether your deposition was Page 31 m transcribed, the one that you gave in the One Market Place [2] case? [31 A: No, I don't know. [4] Q: Do you recall whether you read the words - the [51 questions you were asked during that deposition and answers [6] that you gave? [7] A: I usually corrected all of those. [8] Q: All right. Did you correct the deposition [9] that you gave in Houston, as well? You reviewed it and [to] made whatever corrections you needed? [ill A: I'm sure I did. [12] Q: All right. Do you recall the subject matter [13] of the testimony of your deposition in the One Market Place [i4[ case? [15] MR. FEATHERSTONE: Well, Mr. Bradley, I think [16] that's the case that's governed by the confidentiality [173 order that I referenced several weeks ago in another [is] deposition. So you can answer that question generally. [19] A: That's about all I know, my par ticipation. [20] They would say, "You're going to give a deposition," and [21] that's all the direction I would be given. [22] Q: (By Mr, Bradley) All right. Do you recall, [23] though, giving testimony about PCBs? [24] THE WITNESS: Where? [25] MR. BRADLEY: In San Francisco. Page 32 m A: Yes. [2] Q: (By Mr. Bradley) Do you recall any other [31 occasions where you gave depositions regarding PCBs? [4] A: No, I do not. [5] Q: Okay. What materials, if any, did you review [6] to prepare for today's deposition? [7] THE WITNESS: What? [8) Q: (By Mr. Bradley) What materials, if any, did [9] you review to prepare for today's deposition? [io[ A: PCBs. [ii] Q: What materials did you review? Did you review [12] letters, studies? Page 31 - Page 36 [13] A: No. I have a toxicology book at home. [14] Q: Did you review the toxicology book to prepare [i5] for today's deposi tion? [16] A: Yes. [17] Q: What's the name of the toxicol ogy book? [is] A: It's called Pattey, P-a-t-t-e-y. [19] Q: Pattey? [20] A: P-a-t-t-e-y, Pattey. [21] Q: Is Pattey the author of it? [22] A: Yes. [23] Q: What's the title of the volume? [24] A: Toxicology. It's a standard refer ence book. [25] Q: What else did you review in preperation for Page 33 [1] today's deposition? [2] A: Nothing particularly. [3] Q: Well, did you review any of the documents that [4] you generated while you were medical director at Monsanto? [5] A: We talked about the subject yesterday with [6[ counsel. [7] Q: I don't want to know what you talked about but [8] I'm interested, though, in knowing what documents you [9] reviewed. [io] A: I can't recall them. I can't do that because [in we just took things out. [12] Q: You don't remember anything at all, whether [13] they were studies or -- [14] A: Well, we talked about the IBT study. [15] Q: Did you review some documents relating to the (i6[ IBT studies? [17] A: No. Well, there was some cor respondence. [18] Q: All right. Other than the cor respondence [i9] regarding IBT, what do you recall about the documents that [20] you reviewed? pi] MR. FEATHERSTONE: Dr. Roush, just so you [22] know, Mr. Bradley already told you he doesn't want to know [23] what you talked about with counsel but you can, if you [24] recall it, identify for him the documents you were shown [25] yesterday for this deposition. Page 34 [1] A: I can't recall them. [2] Q: (By Mr. Bradley) Do you recall whether you [3] reviewed any studies? [4] A: The IBT study was the one that -- [5] Q: All right. [6] A: - that really is the crux. [7] Q: All right. [8] MR. FEATHERSTONE: When you get to an [9] appropriate point, Mr. Bradley, I need to find out about [101 Mr, McNicholas. [ii] MR. BRADLEY: This is an ap propriate point. [12] (Whereupon, a fif teen minute recess was taken.) [13] Q: (By Mr. Bradley) Dr. Roush, I as sume that [14] you've heard the term polychlorinated biphenyls? [15] A: Yes. [16] Q: Also known as PCBs? [17] A: Yes. [is] Q: Also known as chlorinated biphenyls? [19] A: Yes. [20] Q: Also known as chlorinated diphenyls? [21] A: Yes. Not the same. [22] Q: Chlorinated biphenyls are not the same as [23] chlorinated diphenyls? [24] A: Yes, they are. [25] Q: What's not the same? Page 35 [i] A: What you had said. I thought there was a [2] difference in that last one. You say it again. [3] Q: Are PCBs also known as chlorinated diphenyls? [4] A: Yes. [5] Q: And are PCBs also known as chlorinated [6] biphenyls? [7] A: Yes. [8] Q: Are chlorinated biphenyls and chlorinated [9] diphenyls the same? [io] A: Yes. [ii] Q: When did you first hear the term PCBs? [12] A: When I came to Monsanto. [13] Q: Who, at Monsanto, first told you about PCBs? [14] A: First? [15] MR. BRADLEY: Yes. [16] A: I don't remember. [17] Q: (By Mr.Bradley) All right. Did you have a [is] discussion when you first went to Monsanto regarding PCBs? [19] THE WITNESS: Will you say that again? [20] MR. BRADLEY: Yes. [21] Q: (By Mr. Bradley) When you first went to [22] Monsanto, did you meet with anyone to discuss [23] polychlorinated biphenyls? [24] A: No. [25] Q: Tell me, then, how it was that you came to Page 36 [i] first hearabout the term PCBs, in what context? Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022921 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 [2] A: Mr. Wheeler took me over to his office and 13] said, ``I want to tell you what I'm working on." [4] Q: And what was he working on? [5] A: On PCBs. [6j Q: What work was he doing on PCBs when you met [7] with him? [8] A: Environmental contamination. [9] Q: What environmental contamina tion work was he [ioj doing on PCBs? Hi] A: It was related to the finding in Sweden, I [12] think it was, that PCBs were present in the environment. U3] Q: What specifically was Mr. Wheeler doing [i4j regarding environ mental contamination of PCBs when you met [i5] with him? [i6] A: Keeping up-to-date to what con tamination there [17] was, or whatever he found in the literature, but he was [is] keeping up-to-date. [19] Q: Did he tell you how he was keep ing up-to-date? [20] A: Literature primarily but also from other [2i] companies. [22] Q: Did he tell you what he was doing to keep [23] up-to-date in the literature? [24] A: No. [25] Q: Did he show you any library ac quisitions that Page 37 [i] he had that addressed the topic of environmental [2] contamination by PCBs? [3] A: No. [4] Q: Did you discuss with him at all what he was [5] doing to keep up-to-date with the literature on PCBs? [6] A: No. [7] Q: Was there ever a point in time where you [8] discussed with Mr. Wheeler what he was doing, if anything, [9] to keep up-to-date on the literature in the field of PCBs? [10] THE WITNESS: Ask that again. in] Q: (By Mr. Bradley) Yes. Was there ever a time [12] that you spoke with Mr. Wheeler regarding what he was doing [13] to keep up-to-date on the subject of PCBs in the [i4] literature? [15] A: To a degree, yes. [16] Q: When did that occur? [17] A: I can't answer that. [18] Q: What did he indicate to you he was doing to [ 193 keep up-to-date regard ing PCBs in the literature? [20] A: I think you just asked that ques tion. [21] Q: Well, and do you have any more information, [22] other than what you've given me? [23] A: No. He had a file and he would take it out [24] and we would talk from his accumulated file. [25] Q: When you met -- Was it Mr. Wheeler or Dr. Page 38 [l! Wheeler? [2] A: Mr. Wheeler. [3] Q: What was his title when you first met with him [4] to discuss PCBs? [5] A: I don't recall. [6] Q: Was he within the medical depart ment? [7] A: Yes. [8] Q: Was he within the toxicology sec tion? [9] A: No. [10] Q: What section was he in? Hi] A: He was head of the industrial hygiene. [12] Q: You indicated that he had a file cabinet in [13] which he kept materials relating to PCBs? U4] A: Yes. [15] Q: And was that a two orfour drawer file [16] cabinet? U7] A: I don't recall. [is] Q: Do you recall whether it was more than one [19] file cabinet? [20] A: About where I was when you asked me the other [21] time. [22] Q: So you don't know? [23] A: No. [24] Q: All right. [25] A: He had taken that seriously. Page 39 [i] Q: Well, what does that mean about the number of [2] file cabinets that he had? [3] A: I can't answer.That's unrelated. [4] Q: All right. And over what period of time did [5] you have discussions with Mr. Wheeler regarding his work on [6] environmental contamination of PCBs? [7] A: I can't answer that. [8] Q: Do you recall whether your con versations with [9] him began in 1973? [io] A: Yes. No, sir, I can't answer that. I think [ii] so. [12] Q: All right. Do you know whether you stopped [13] having discussions with Mr. Wheeler about environmental [14] contamination of PCBs before you retired? [15] THE WITNESS: Before he retired? [16] MR. FEATHERSTONE: Before you retired. U7] A: He was retired long before me. [18] Q: (By Mr. Bradley) All right. When did he [19] retire? [20] A: 74 or 75. [21] Q: Did you have those discussions with him about [22] environmental con tamination of PCBs up to the time he [23! retired? [24] A: Yes. [25] Q: What responsibilities, if any, did Mr. Wheeler Page 40 [i] have regarding environmental con tamination of PCBs between [2] the time you began working at Monsanto and the time that he [3] retired? [4] THE WITNESS: Can you read that, give me that [5] question again? [6] (Whereupon, the reporter propounded the previous question.) [7] A: I don't know. [8] Q: (By Mr. Bradley) At the time you became [9] medical director in Decem ber of 1974, who, if anyone within [10] the medical department, had any responsibility relating to [in the subject matter of PCBs? [12] A: Mr. Wheeler. [13] Q: And what responsibilities did he have when you [i4] became medical director regarding PCBs? [15] A: He continued on that same assign ment. [16] Q: All right. What responsibilities did he have [i7] regarding PCBs? You said he was head of the industrial [18] hygiene section. [19] A: Yes. [20] Q: He worked on environmental contamination of [21] PCBs? [22] A: Yes. [23] Q: I'm trying to figure out what that means. [24] What did he do as head of the industrial hygiene section [25] relating to PCBs? Page 41 [i] A: Nothing. He didn't do anything.He kept [2] up-to-date. [3] Q: And he was the only one who had [4] responsibilities in the medical depart ment relating to [5] PCBs? [6] A: Yes. [7] Q: At least up until his retirement? [8] A: Yes. [9] MR. FEATHERSTONE: Off the record, [ioj (Whereupon, a discussion was held between Counsel, off the [ii] record.) [12] Q: (By Mr. Bradley) During the time that you [13] were medical director, did you ever prepare a summary of [Mi data on the toxicity of Aroclor? [15] A: No. [16] Q: During the time that you were in the medical [i7] department as associate director and director, up to the [is] time of your retirement, did the medical Concannon & Jaeger (314) 421-1000 Min-U-S cript Page 37 - Page 4l WATER PCB-SD0000022922 George Roush, Jr. March 17, 1993 department ever [19] prepare a summary of data on the toxicity of Aroclor? 120] A: Yes. [21] Q: Who prepared that? [22] A: Levinskas. 123] Q: Did you review it? 124] A: Yes. [25] Q: What did you do, if anything, prior to [1] reviewing that summary? [2] A: It was after I retired. Page 42 [3] Q: You prepared the summary after you retired? 14] A: Yes. [5] Q: Why is it, then, that you reviewed it if you [6] were retired? [7] A: I do work for Monsanto. [8] Q: You still do consulting work for Monsanto? 19] A: Yes. no] Q: Do you recall the year that you reviewed the [ii] summary prepared by Dr. Levinskas? (12) A: No. [131 Q: Help me again. What year did you retire? (14) A: '88. [15] Q: Do you know whether, between 1973, the month [i6] that you began your employment in the medical department, [17] and the time of your retirement, whether the medical [is] department prepared a document or a summary on the data of U9] the toxicity of Aroclor? [20] A: No. [21] Q: No, you don't know or -- [22] A: We did not. [23] Q: You did not. When you did review the summary [24] that was prepared after your retirement, what, if anything, 125] did you do prior to the review? Page 43 [1] A: I don't know what you mean by the question. [2] Q: Well, did you review any toxicol ogy standard [3] textbooks or any studies? Did you do anything at all to [4] prepare you to review a document which was a summary of [5] data on the toxicity ofAroclor? [6] A: No. [7] Q: Did you write a -- Excuse me.Did you [8] provide something written as part of your review of the [9] summary of data on the toxicity of Aroclor? [io]A: No. (in Q: Okay. Did you orally give some one your [12] impressions of the sum mary? [13] A: Levinskas. Page 42 - Page 47 Nevada Power Company v. Monsanto Company, et al. [i4] Q: All right. So after he gave you the summary, [15) you met with him or you spoke with him and told him what [16] you thought of the summary? Yes? [17] A: Yes. [is] Q: And do you recall what you told him regarding 119] the summary? [20] A: I thought he did a good job. [21] Q: Did you indicate to him whether there were any [22] areas that he had omitted from the summary that perhaps he [23] shouldn't - perhaps should be included? [24] MR. FEATHERSTONE: Let me hear that question [25] back now, please. Page 44 [1] (Whereupon, the reporter propounded the previous question.) [2] A: No. [3] MR. FEATHERSTONE: Object to the form. [4] Q: (By Mr. Bradley) My question is, did you [5] indicate to Dr. Levinskas any areas that you thought he [6] should include in the summary that he hadn't included? 17] A: No. [8] Q: In your estimation, it was a thorough review [9] of the summary of the toxicity of Aroclor? [10] MR. FEATHERSTONE: Object to the form. [11] Q: (By Mr. Bradley) In your opinion, it was a [12) thorough review on the data on the toxicity of Aroclor? U3) A: I can't answer the question. [14] Q: Did you view it as a comprehen sive review of [15] the data on the toxicity of Aroclor? 116] A: I can't answer that question. [17] Q: All right. Is my question not clear? [is] A: Yes. The question you asked me, I can't [i9] answer. [20] Q: Why can't you answer it? [21] A: Because you're asking more out of me than I [22] have to give. [23] Q: All right. You didn't know whether it was a [24] comprehensive review? [25] A: When you do a comprehensive review, do you Page 45 [l] look at just this, or do yougo back and read other things [2] to make sure it's complete? Is that what you do? The [3] answer is no. [4] Q: All right. I take it, you didn't do anything [5] to determine whether it was a comprehensive -- [6] A: I didn't do anymore than read what he had [7] done. [8] Q: All right. Describe for me, if you will, what [9] documents you reviewed between 1973 and the time you [io] reviewed the summary prepared by Dr. Levinskas on the [ii] subject of PCBs.Can you do that? [12] THE WITNESS: What did you say I would do? [13] Say it again. [14] Q: (By Mr.Bradley) I'm interested in knowing [15] what documents, if any, you reviewed over the fifteen or (16) sixteen years you were employed at Monsanto regarding the [17] subject matter of PCBs. [is] A: That's a tough -- I can give some but don't [19] ask me to say what I did. [20] MR. BRADLEY: All right. Go ahead and give me [21] what you can. [22] A: Patty's got a good section on that. [23] Q: All right. [24] A: Kimbrell has written on the sub ject, on [25] dioxins and furans and things like that. Page 46 [i] MR. FEATHERSTONE: He's talking about PCBs, Dr. [2] Roush. 13] A: I'm talking about the book. That's the title [4] of the book. [5] MR. FEATHERSTONE: All right. [6] MR. BRADLEY: Okay. [7] A: There's a National Research Coun cil article on [8] PCBs, good one. (9) Q: (By Mr. Bradley) All right. Did you review [101 any of the articles that were in Mr. Wheeler's file tin regarding PCBs? [12] A: No. [13] Q: Did you review any articles, if there were [i4] any, in the library of Monsanto's medical department on [15] PCBs? [16) A: Yes. [17] Q: What do you recall about the ar ticles that you [is] reviewed? [19] MR. FEATHERSTONE: Object to the form. [20] Q: (By Mr. Bradley) Do you recall why you [21) reviewed articles on PCBs in Monsanto's medical department [22] library? [23] A: An internal discussion. [24] Q: Do you recall which studies you reviewed? [25] A: No. Page 47 [1] Q: Do you recall how many studies you reviewed? [2] A: No. [3] Q: Do you recall whether there were more than [4] five? [5] A: Oh, yes. [6] Q: Do you recall whether there were more than [7] ten? [8] A: No. [9] THE WITNESS: You mean in all that time, from [ioj the beginning to the end? ! I \ i Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022923 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 [ill MR. BRADLEY: Yes. [12] MR. FEATHERSTONE: Fifteen years, Dr. Roush. [13] MR. BRADLEY: From the time you began your [i4] employment to the time you retired from Monsanto. [15] A: I don't know. [16] Q: (By Mr. Bradley) Did you ever at tempt to [17] comprehensively review all the literature that had been [is] written on the subject matter of PCBs during the period of (19) time you worked at Mon santo? [20] MR. FEATHERSTONE: Object to the form. [21] A: No. [22] Q: (By Mr. Bradley) When you began your work at [23] Monsanto, did you have any discussions with Dr.Kelly [24] regard ing the subject matter of PCBs? [25] A: No. Page 48 [1] Q: When you began your work at Monsanto, did the [2] medical depart ment have any responsibility for prepar ing [3] any materials regarding the sub ject matter of PCBs? [4] A: They participated in the safety data sheets. [5] Q: Anything else? [6] A: No. [7] Q: Do you know whether, by review ing documents or [8] by talking with other people within the medical depart ment [9] during the time you were employed with Monsanto, do you [ioj know whether the medical department participated in the uu preparation of any materials on PCBs prior to the time you [12] were a Monsanto employee? [13] A: No. [14] Q: I take it, you heard of the term furan? [15] A: Yes. [16] Q: Do you recall when you first -- Well, let me [17] ask it this way. Do you recall whether you heard that term [is] for the first time before or after you began your [19] employment with Mon santo? [20] A: After. [21] Q: Okay. Do you recall how it was that you heard [22] the term for the first time? [23] A: First episode of chloracne. [24] Q: When was the first episode of chloracne? [25] A: Long before I joined Monsanto. Page 49 HI Q: How did you learn about that first episode? [2] THE WITNESS: Talking chloracne? about [3] Q: (By Mr. Bradley) Was the first episode of [4] chloracne a Monsanto employee; is that what you meant? [5] A: Yes. [6] Q: And do you recall who told you about the [7] Monsanto employee who had the first episode of chloracne? [8] A: No. [9] Q: And what were you told, if any thing, about the [ioj relationship of that first episode and furans? [ill MR. FEATHERSTONE: Object to the form of the [i2j questioning. [13] A: We had an episode of chloracne and we didn't [i4] know what caused it. [15] Q: (By Mr. Bradley) Did somebody indicate to you [16] that it might have been caused by furans? [17] A: Didn't know there was such a term as furans. [is] Q: You indicated that you heard the term furan in [19] regards to this first episode of chloracne. What did you [20] hear? [2i] MR. FEATHERSTONE: Object to the form of the [22] questioning. [23] Q: (ByMr.Bradley)Didyouhearanything at all [24] regarding furans in relationship to this first episode of [25] chloracne while you were employed at Monsanto? Page 50 [1] A: Yes. [2] Q: What did you hear? 13] MR. FEATHERSTONE: Same objec tion to the form [4] of the question. [5] A: This requires -- We had an episode of [6] chloracne and we always said we had one case, one instance. [7] Q: And did somebody -- [8] A: Then as time went on, then we learned how to [9] do furans and then they said that was a furan that did it. [10] Q: Do you recall what date it was, or -- Let me [i i] ask it this way. Was it in the 1970s that Monsanto had its [12] first episode of chloracne? [13] A: I don't know when it was. It was before me. [14] Q: You wouldn't know, then, whether it was the [15] '60s, '50s, '40s? [16] A: No, sir. [17] Q: When did you first hear that the first episode [18] of chloracne might have been caused by furans? [19] A: Recently. [20] Q: And who told you that? [21] A: I don't remember. [22] Q: Was it someone with Monsanto? [23] A: Yes. [24j Q: Someone within the medical department? [25] A: Yes. Page 51 [i] Q: Had you heard about furans before this medical [2] department employee suggested to you that Monsanto's first [3] episode of chloracne might have been caused by furans? [4] THE WITNESS: Can you ask that question again? [5] MR. BRADLEY: Yes. [6] Q: (By Mr. Bradley) I'm interested in knowing [7] whether you heard about furans before you had this [8] conversa tion relating furans to the first episode of [9] chloracne. [ioj A: Came in before I knew that there were furans in [ii] our PCBs, and that means trace levels. [12] Q: When did you know that your PCBs had trace [13] levels of furans? [14] A: I don't know. It's recent though, and I can't [i5j tell you what "recent" means. [16] Q: Can you tell me whether it was before you [17] retired? [is] A: Yes. Well, about the time I retired. H9] "Recently," that means after that. I don't know. [20] Q: When did you first hear about the Yusho [2i] episode? [22] A: At the time of the Chicago sym posium. [23] Q: Was that in 1975? [24] A: 74, 75. [25] Q: The Chicago symposium was - or do you recall Page 52 [1] who sponsored the Chicago sym posium? [2] A: I think it was EPA. [3] Q: Did you speak at that symposium? [4] A: No. [5] Q: You must -- I take it, you attended it? [6] A: Yes. [7] Q: Do you recall what sessions of the symposium [8] you attended that ad dressed the subject matter of PCBs? [9] A: The whole meeting was PCBs. do] Q: All right. Do you recall which ses sions you [in attended that addressed the subject matter of furans? [12] A: I think it was part of the general program. [13] Q: Why was it that you attended that symposium? [14] A: The IBT results were published, were given out [i5] at that time. [16] Q: And what was it about the IBT results that led [i7] you to attend the Chicago symposium? [is] A: Monsanto paid for the IBT study. Concannon & Jaeger (314) 421-1000 Min-U-Script Page 48 - Page 52 WATER PCB-SD0000022924 George Roush, Jr. March 17, 1993 Nevada Power Company v. Monsanto Company, et al. [19] Q: Okay. Why did completion of the study mean poj that you attended the Chicago symposium? pi] A: Why did that mean I attended? We had an [221 Investment in it. [23] Q: Did you attend the Chicago sym posium, at least [24] in part, then, to help protect your investment? [25] MR. FEATHERSTONE: Object to the form. Page 53 [i] A: Primarily to learn all I could learn about [2] PCBs. [3] Q: (By Mr. Bradley) Well, did you at tend the [4] Chicago symposium, in part, to help protect Monsanto's [5j invest ment in PCBs? [6] MR. FEATHERSTONE: Object to the form. [7] A: I can't answer it in that form. [8] Q: (By Mr. Bradley) Have you heard the term [9] polychlorinated dibenzylfuran? [io] A: Yes. [ill Q: What is a polychlorinated dibenzylfuran? [12] A: It's a diphenyl in which the two rings are [i3j joined by an oxygen, one of the two. [14] Q: Do you recall when the first time was that you [15] heard the term polychlorinated dibenzylfuran? [16] A: No. [171 Q: Do you know whether it's ever been claimed [i8[ that polychlorinated dibenzylfurans are chemical [19] con taminants of PCBs? [20] A: Yes. [21] Q: Did you learn that during the time that you [22] were employed at Monsan to? [23] A: Yes. [24] Q: Did you learn that at least by the time the [25] Chicago symposium was completed? Page 54 [1] MR. FEATHERSTONE: That it was claimed? [2] MR. BRADLEY: Yes. [3] A: I joined Monsanto in '73. It was two years [4] after that, that that sym posium took place. [5] MR. BRADLEY: Right. [6] A: Now, everything I learned there was new to me [7] because I was new on PCBs. [8] Q: (By Mr. Bradley) Well, my -- I'm interested [9j in knowing whether you ever learned that polychlorinated [io] dibenzylfurans are, in fact, chemical con taminants of PCBs? Hi] A: I'm not sure when, but the first thing we [12] learned about furans was USHA, and USHA was presented there [131 and I can't tell you whether it was then or shortly [i4j thereafter. [15] Q: But you do agree that polychlorinated [16] dibenzylfurans are chemical contaminants of PCBs? [17] MR. FEATHERSTONE: Object to the lack of [is] foundation. [19J A: My impression is, it is a little bit. [20] Q: (By Mr. Bradley) Okay. Can you compare the [21] toxicity of PCBs to polychlorinated dibenzylfurans? [22] A: No. Nor can anyone else. [23] Q: Do you know wheather or not polychlorinated [24) dibenzylfurans are considered more toxic than PCBs? [25] A: I don't know. Page 55 [11 Q: During the time that you worked at Monsanto, [2] did you ever speak with anyone from Nevada Power Company? [3J A: No. [4] Q: During the time you were employed at Monsanto, [5j did you ever speak with any electric utility company [6] regarding PCBs? [7] A: Not to my knowledge. [8] Q: During the time you were employed at Monsanto, [9] did you speak with anyone from General Electric regarding [toj PCB? [U] A: Not that I recall. [12] Q: During the time you were employed at Monsanto, [13] did you speak with anyone from Westinghouse regarding PCBs? [14] A: Same answer. [15] Q: During the period of time you were employed at [i6j Monsanto, do you know whether the head of the toxicol ogy [17] section in the medical depart ment ever spoke with any [is] electric utility regarding the subject matter of PCBs? [19] A: I don't think so. [20] Q: During -- [21] THE WITNESS: You're talking about while I was [221 medical director? [23] MR. BRADLEY: I'm talking about while you were [24] employed at Mon santo. [25[ A: Yes. Page 56 [i] MR. BRADLEY: Including the time you were [21 associate director. [3] Q: (By Mr. Bradley) During the time you were at [4] Monsanto, do you know whether the head of the toxicology [5] section of the medical department at Monsanto ever spoke [6] with anyone from General Electric regarding PCBs? [7] A: No. [8] Q: During that time you were employed at [9] Monsanto, do you know whether the head of the toxicology [io] section of the medical department of Monsanto ever spoke [in with anyone from Westinghouse regarding PCBs? [12] A: I don't know. [13] Q: You began your work at Monsan to in '73 and Dr. [i4j Kelly retired in 74; is that correct? [15] A: Yes. [16] Q: Do you recall roughly how many months you'd [17] worked there before he retired? [18] A: About eighteen or nineteen months. [191Q: And during that eighteen or nineteen month [20] period, did Dr. Kelly explain to you what he knew about [21] PCBs? [22] A: My teacher was Wheeler. [23] Q: So I take it, you and Kelly didn't have those [24] kinds of discussions? [25] A: No. He left it up to him. Page 57 [1] Q: All right. [2] A: That was his responsibility. [3] Q: During those eighteen or nineteen months [4] before Dr. Kelly retired, did Dr. Kelly show you any [5] documents relating to PCBs? [6] A: No. m Q: Those were all shown to you by Dr. Wheeler, or [8j Mr. Wheeler? [9] A: Yes. [10] Q: Do you know whether Mr. Wheeler is still [ii] living? [12] A: No, he is not. [13] Q: When did he pass away? [14] A: Couple of years ago. [15] Q: During the time that you were employed at [16] Monsanto, was Mr. Wheeler always the head of the toxicol ogy [17] section of the medical depart ment at Monsanto? [is] MR. FEATHERSTONE: That's not how he has been [19) identified. [20] A: He was not. [21] MR. BRADLEY: Excuse me. Mr. Wheeler was head [22] of the industrial hygiene section? [23] A: Yes. [24] Q: (By Mr. Bradley) And during that period, [25] during the time you were employed at Monsanto, was Mr. Page 58 [i] Wheeler always the head of the in dustrial hygiene section [2] of the medi cal department at Monsanto? [31 A: He quit within three or four years after I [4] retired -1 mean after I joined the company. Page 53 - Page 58 Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022925 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 [5] Q: So he quit in 1976 or '7? [6] A: Yes. [7] Q: Who took his position when he quit? [8] A: Jack Garrett. 19) Q: When Jack Garrett became head of the [ioj industrial hygiene section in the medical department, did [ii] you then turn to Mr. Garrett regarding the subject matter [12] of PCBs? U31 A: Both he and Levinskas. [M] Q: What training did Mr. Garrett have in the [15] subject matter of PCBs prior to taking over the industrial H6] hygiene section? [17] MR. FEATHERSTONE: Object to the absence of [isj foundation. [19] A: He was the head of industrial hygiene section [201 and the subject of PCBs was part of his regular duties. [21] Q: (By Mr. Bradley) Were yo u respo nsible for the [22] appointment of Mr. Gar rett to the head of the industrial [23] hygiene section? [24] A: Yes. [25] Q: Did you nieet with Mr. Garrett prior -- Well, Page 59 [1] you were the one who promoted Mr. Garrett to the head? [2] A: Yes. [31 Q: Did you meet with him and talk with him about [4] the appointment prior to making the appointment? [5] A: Yes. [6] Q: Okay. And when you met with him, did you [7] discuss with him his knowledge of PCBs? [8] A: I knew he knew about PCBs by that time. [9] Q: How did you know that he knew about PCBs prior [io] to meeting with him regarding his appointment to be [iij industrial hygiene section head? [12] A: Just discussion. [13] Q: Discussion with Mr. Garrett? [14] A: Yes. And Levinskas. [15] Q: And when you made the appoint ment, what did [16] you know about Mr. Garrett's background in PCBs? [17] A: I knew it as it was applied to Monsanto. [isj Q: When you made the appoint ment, did you know [19] whether Mr. Garrett was on toxicologist? [20] A: No, he was not. [21] Q: Did he have a graduate degree in industrial [22s hygiene? [23] A: I don't know. [24] Q: You knew, though, that he worked with the [25] industrial hygiene section in Monsanto? Page 60 ID A: Yes. For many years. [2] Q: Are you familiar with the Monsan to product [3] known as 1016? [4] A: Yes. [5] Q: Did that product exist before you began your [6] employment with Mon santo? [7] A: I don't know. [8] Q: The PCBs manufactured by Mon santo were known [9] as Aroclors? [ioj A: Yes. [ii] Q: And the Aroclors all had different numbers, [12] correct? [13] A: Well, there were PCBs with dif ferent chlorine [14] attachments. [15] Q: There were, for example, Aroclors 1221, 1242, [16] 1254, 1260? Yes? [17] A: Yes. [isj Q: And the "12" denominated what? [i9j A: I don't know. [20] Q: Do you know what the second two digits [211 denominated? [22] A: That's the chlorine content. [23] Q: And 1016 was a product that con tained PCBs; is [24] that correct? [25] A: We just said that before, and I don't know Page 61 [1] anything about 1016. [2] Q; You don't know whether 1016 had any PCBs in [3] it? [4] A: No. It doesn't sound like it could. [5] Q: All right. No, sir, it doesn't. [6] MR. FEATHERSTONE: I move to strike that [7] comment. [8] Q: (By Mr. Bradley) During the time you were [9] employed at Monsanto, did you ever hear that PCBs might [io] cause harm to human health? [11] THE WITNESS: Might cause what? [12] MR. BRADLEY: Harm to human health. [13] A: Yes. [14] Q: (By Mr. Bradley) When did you first hear [15] that? [16] A: When I first heard of PCBs. [17] Q: What kind of harm did you hear PCBs might [isj cause to human health? [19] MR. FEATHERSTONE: Object to the form of the [20] questioning. [21] A: It is an irritant. [22] Q: (By Mr. Bradley) To the skin? [23] A: And to the eyes. [24] Q: What else did you hear about it? [25] A: I'm not through with irritation. Page 62 [i] Q: I'm sorry. [2] A: It's a respiratory irritation too. [3] Q: What's a respiratory irritant? [4] A: One that causes cough. [5] Q: All right. [6] A: And there is -- And so you can get irritation [7] of skin, eyes and respiratory track. It also, with some [8] question, produces liver effects, in terms of change in the [9] levels of enzymes and effects what we call liver function [ioj studies. You have a change in alkaline phosphate, SGOT, (ii) SGTP and GGTP. Those are all capitalized.There is a -- [12] MR. FEATHERSTONE: This is what you heard? [13] A: No.This is what I know, what I've read. [14] MR. FEATHERSTONE: He asked what you heard [15] when you joined, is the question. [16] MR. BRADLEY: Actually, I don't believe that's [17] the question at all. Why don't you read the question back. [is] (Whereupon, the reporter propounded the previous question.) [19] MR. FEATHERSTONE: The question is, what did [20] you hear. [21] THE WITNESS: As opposed to what I read? [22] MR. BRADLEY: The question is, what did you [23] hear. Not when you first started, but what did you hear [24] when you first heard that PCBs might cause harm to human [25] health. Page 63 [i] MR. FEATHERSTONE: Object to the form of the [2] questioning. 13) MR. BRADLEY: Well, I'll re-ask it. [4] Q: (By Mr. Bradley) Was there ever a point when [5] you learned that PCBs might cause harm to human health? [6] A: Yes. [7] Q: When did you first learn that? [8] A: I don't know. [9] Q: What kind of harm did you learn that PCBs [io] might cause to human health? [ii] A: Would cause irritation, as I've described. [12] That's common sense. It may cause change in the liver [13] func tion, it may have an effect on the nerv ous system. ]i4] Those are all of what we call acute effects. [15] Q: Did you ever learn that PCBs might cause [16] chronic effects to human health? [17] A: There is a question whether it does or not. [is] Q: What did you learn about that? [19] MR. FEATHERSTONE: Object to the form of the [20) questioning. Concannon & Jaeger (314) 421-1000 Min-U-Script Page 59 - Page 63 WATER PCB-SD0000022926 George Roush, Jr. March 17, 1993 Nevada Power Company v. Monsanto Company, et al. (2i) Q: (By Mr. Bradley) What did you learn about [22] whether PCBs cause chronic effects to human health? [23] MR. FEATHERSTONE: Object to the form of the (24] questioning. [25] A: I didn't say that it caused chronic effects. Page 64 [i] Q: (By Mr. Bradley) What did you learn that [2] indicated to you that PCBs may cause chronic harmful [3] effects to human health? [4[ MR. FEATHERSTONE: Object to the form of the [5] questioning. [6] A: Learned that at the Chicago sym posium as soon [7] as I joined, shortly after I joined. A lot of my knowlege [8] is related to what I learned there. [9] Q: (By Mr. Bradley) And what kind of chronic [10] effects did you learn PCBs might cause to human health? (ill MR. FEATHERSTONE: Object to the form of the 112] questioning. [13] A: PCBs in rodents causes liver damage, as we've [i4] described, and in a bigger dose, will produce a more [15] lasting effect maybe, and maybe it will go away. [16] Q: (By Mr. Bradley) Did you ever learn whether [17] PCBs causes a skin condition called chloracne? [is] A: Yes. [19] Q: Did you ever learn whether, if a worker has [20] chloracne, it might indi cate some kind of a more serious [21] chronic systemic poisoning? [22] MR. FEATHERSTONE: Object to the form of the (23] questioning. [24] A: No. [25] Q: In your discussions with Dr. Levinskas, did he Page 65 [i] ever indicate to you that if a worker has a skin rash [2] following exposure to PCBs, that that could indicate a [3] sys temic poisoning? [4] A: No. [5] Q: Are you familiar with the phrase "systemic [6] poisoning?" [7] A: Yes. [8] Q: What does that mean? [9] A: It means it's not superficial, in ef fect. So [10] if it involves -- If it's one of the organ systems, it's [ii] called a sys temic effect. [12] Q: Like the heart or the lungs or the liver? [13] A: Or the GI tract or the kidneys or whatever. [14] Q: Have you ever heard the name Dr. Lewis [15] Schwartz? [16] A: No. [17] Q: Did Dr. Kelly ever tell you that he [is] participated in a round table discus sion in 1937 regarding, [19] in part, chlorinated biphenyls? [20] A: No. [21] Q: Did Dr. Levinskas, or anyone else, ever tell 122] you that PCBs were alleged, or excuse me, it was alleged [23] that PCBs caused harm to the liver, as early as the 1940s? [24] MR. FEATHERSTONE: Object to the form of the [25] questioning. [1] A: I've read that. Page 66 [2] Q: (By Mr. Bradley) When did you read that? [3] A: I can't answer that question. [4] Q: Did you read any Monsanto docu ment that warned [5] purchasers of Mon santo products that it was known back in [6] the '40s that PCBs might cause harm to the liver? [7] A: There was a pamphlet that was put out that [8] said be careful of this and this and this. 19] Q: Did the pamphlet indicate that back in the [io] '40s, it was alleged that exposure to PCBs might harm the [ii] liver? [12] A: This document doesn't say that. It says, "Do [13] not get skin contact or inhalation exposure." [14] Q: Doesn't say it might cause liver problems? [15] A: But it talks about limiting air ex posure. [16] Q: What's the name of the pamphlet? [17] A: Safety Data Sheet, I think, of some form. [is] Q: Have you ever heard of a Mr. F.R. Kaimer, [19] K-a-i-m-e-r? [20] A: No. [21] Q: During the time you were employed at Monsanto, [22] did you ever learn whether any General Electric employees [23] were alleged to have severe cases of acne because of their [24] exposure to materials that contained, in part, chlorinated [25] biphenyl? Page 67 [1] A: No. [2] Q: During the time you worked at Monsanto, were [3] you ever - did you ever learn about a product called [4] Halowax? [5] A: Yes. [6] Q: What was Halowax? [7] A: I don't remember. [8] Q: Do you recall whether it con tained parts of [9] chlorinated biphenyl? [io] A: It was a question, of whether it did. [11] Q: It contained chlorinated Napthalene though, [i2j didn't it? [13] A: I think so. [14] Q: During the time you worked at Monsanto, were [15] you - did you ever learn that workers exposed to Halowax [16] developed chloracne? [17] A: I think so. That was a long time ago. (is) Q: During the time you worked at Monsanto, did [19] you ever learn that it was alleged that at least one worker [20] may have died because of exposure to Halowax? [21] A: I don't remember that. [22] Q: During the time that you were employed at [23] Monsanto, did you ever learn whether Monsanto undertook any [24] studies to determine whether Halowax contained PCBs? [25] A: I don't know. Page 68 [i] Q: Did you learn about Halowax from Dr. Levinskas [2] or Mr. Wheeler? [3] A: Reading. [4] Q: What were you reading? [5] A: Just on the general subject on PCBs, and that [6] may have come up then. [7] Q: Were you reading a study or were you reading a [8] report prepared by a Monsanto employee? [9] A: No. No. It was written. It was pub lished. [10] Q: During the time that you were employed at [ii] Monsanto, did Monsan to manufacture PCBs? [12] A: Yes. [13] Q: And during that time when Mon santo was [14] manufacturing PCBs and you were employed there, did [is] Mon santo give the workers fresh clothing before they began [16] their work shift? [17] A: Fresh clothing was a part of this safety data [is] sheet that I was telling you about. That was given to [19] cus tomers, too. [20] Q: Safety data sheet was given to customers? [21] A: Yes. [22] Q: Customers would be General Electric and [23] Westinghouse? [24] A: Yes. [25] Q: And did the safety data sheet tell GE and Page 69 [i] Westinghouse that employees work ing with PCBs should change [2] their clothing daily? [3] A: Yes. [4] Q: And during the time that you were employed at [5] Monsanto, did the Page 64 - Page 69 Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022927 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 workers working with PCBs change their [6] shoes daily? [7] MR. FEATHERSTONE: Object to the form of the [8] questioning, and also ob ject to the lack of foundation. [9] A: That's a detail I can't answer. They were (ioj told not to have PCBs on their clothes, so that means [in changing things. [12] Q: (By Mr.Bradley) Well,didMonsanto wash the [13] clothing for its employees? [14] MR. FEATHERSTONE: Objection. Lack of [15] foundation. No showing this witness has personal [i6] knowledge. [17] A: I don't know. [is] Q: (By Mr.Bradley) And do you recall whether [i9] Monsanto did anything else to provide clean apparel for [20] workers working with PCBs during the time that you were at [2i] Monsanto and Monsanto was manufacturing PCBs? [22] A: I just recall there was fresh gear. [23] Q: Well, did the gear include fresh gloves? [24] A: Yes. [25] Q: Did the gear include fresh pants? Page 70 [1] A: Yes. [2] Q: Fresh shirts? [3] A: Yes. [4] Q: Fresh shoes? [5] A: I don't remember. [6] Q: Fresh socks? [7] A: Yes. Fresh gloves, [8] MR. FEATHERSTONE: You already did gloves. [9] THE WITNESS: Huh? [ioj MR. FEATHERSTONE: We already did gloves. Hi] A: All right. [12] Q: (By Mr. Bradley) And the safety data sheet H3) that you gave to GE and Westinghouse and other customers [14] advised them to also have their workers have fresh [15] clothing? [16] A: Yes, [17] Q: Fresh apparel? [18] A: Yes. [19] Q: All right. [20] MR. FEATHERSTONE: Including -- "You," [2i] meaning the witness? The witness already said he didn't [22] have any contact with them. You mean Mon santo? [23] MR. BRADLEY: Monsanto. [24] MR. FEATHESTONE: All right. [25] A: Monsanto. Page 71 [i] Q: (By Mr.Bradley) Did Monsanto do anything to [2] insure -- Well, let me back off. When you sold PCBs to [3) General Electric during the time that you were employed at [4] Monsanto, you knew that they were going to be used in [5] trans formers and capacitors, didn't you? [6] A: Yes. [7] Q: You knew that GE and Westin ghouse would sell [8] those transformers to electric utility companies? [9] A: Yes. [ioj Q: And what, if anything, did Mon santo do to [in inform the electric utility companies about the safety data [12] sheets that describe the need to have fresh apparel? [13] A: They gave this information. I don't know who [i4] they gave it to. [15] Q: I'm going so show you what's been mark for [16] identification as Plaintiff's Exhibit 979 and ask you to [17] review that. 118] MR. FEATHERSTONE: Mr. Bradley, do you want [19] him to read the docu ment? [20] MR. BRADLEY: I do want him to do that. Well, [2i] let me ask this question first. [22] Q: (By Mr. Bradley) Have you seen that document [23] before? [24] A: I think so. [25] MR. BRADLEY: Then I do want him to review it. Page 72 [i] I'm happy taking a five or ten minute break while you [2] review that. [3] THE WITNESS: I want to take a break with you. [4] MR. BRADLEY: All right. [5] (Whereupon, a twenty minute recess was taken.) [6] Q: (By Mr. Bradley) Dr. Roush, have you had an [7] opportunity to at least skim Plaintiff's Exhibit 979? [8] A: Yes. [9] Q: And is that a document that you've seen [io] before? Hi] A: Yes. [12] Q: And was that a document that was maintained in [13] a file within Monsanto's medical department? [14] A: I didn't see it there, [15] Q: Where did you see it? [16] A: In my review of looking at Napthalenes. [17] Q: All right. And where did you grab -- Excuse [18] me. Where did you go to review materials relating to (i9) Napthalenes? [20] A: I'm sure it was at Monsanto. [21] Q: All right. So this is a document that you (22] would have reviewed at Monsanto? [23] A: I think so. [24] Q: All right. And would that have been in the [25] medical department library? Page 73 [i] A: Yes. [2] Q: Did Monsanto, in 1973 when you began [3] employment there, have a separate file on Napthalenes? [4] A: I don't know. [5] Q: After you began work with Mon santo in 1973, [6] did Monsanto ever have a file exclusively on Napthalenes? (7) A: I don't know. [8] Q: Do you -- Can PCBs get absorbed through the [9] skin? [ioj A: To a degree. [u] Q: Did Monsanto ever tell its cus tomers that PCBs [12] get absorbed through the skin? [13] A: Yes. We were told to wear leather gloves to [14] prevent its absorbtion. [15] Q: So the safety data sheets say wear gloves [16] because ifyou don't, PCBs get absorbed into the skin? in] A: Right, [is] Q: Yes? [19] A: It says wear gloves to prevent ab sorbtion. [20] Q: Did Monsanto ever inform electric utility [211 companies that PCBs get absorbed through the skin? [22] A: That wasn't my responsibility. My answer is, [23] I think it was. [24] Q: And who do you think informed utility [25] companies that PCBs get ab sorbed through the skin? Page 74 HI A: I don't know. [2] Q: Would that have come through the industrial [3] hygiene section of the medical department? [4] A: I don't think so. [5] Q: Would it have come through the medical [6] department at all? [7] A: I don't think so. [8] Q: Which department would it have come through? [9] A: From the business group that was working with [io] PCBs. [it] Q: Through the marketing and sales folks? [12] A: Well, there are those who had responsibility [13] for safety, as well. [14] Q: Andwhichones -- Which people had [15] responsibility for safety, as well? [16] A: I'm talking about the business group. Within [17] that business group, they did it. Concannon & Jaeger (314) 421-1000 Min-U-S cript Page 70 - Page ?4 WATER PCB-SD0000022928 George Roush, Jr. March 17, 1993 Nevada Power Company v. Monsanto Company, et al. [is] Q: Within marketing and sales there were people [19] [20] MR. FEATHERSTONE: He said busi ness group. [21] Q: (By Mr. Bradley) Is the business group the [22] same as marketing and sales? [23] A: But they also have the respon sibilities on [24] handling the product. [25] Q: But when you referenced the business group, Page 75 HI were you referring to the marketing and sales people? [2] A: And other things that make -- The business [3] group does a business on PCBs, included in that was [4] respon sibility to tell the customers what they needed to [5] know. [6] Q: And who then was responsible within Monsanto [7] for telling the cus tomers what it is that they needed to [8] know? [9] A: The business group. [10] Q: And who headed the business group during the [ii] time that you were at Monsanto? [12] A: I don't know. [13] Q: What would that person's title be? [14] A: I don't know. [15] Q: Was there a department within Monsanto called [i6] the Business Group? [i7] A: Well, each one of our businesses, those that [is] worked with Ag products would have one business group, [i9] those working with PCBs would be another group. [20] Q: All right. Was there a department or division [2i] within Monsanto that was working with PCBs? [22] A: Yes. [23] Q: And what was that department or division [24] called? [25] A: I don't know. That's what you asked me. Page 76 ID Q: All right. How did the -- Let me ask it this [2] way. Did the medical depart ment inform the business people [3] about -- Well, let me be more specific. Did Monsanto's [4] medical department inform Monsanto's business group working [5] with PCBs, that PCBs get absorbed through the skin? [6] A: Yes. [7] Q: And have you seen a document sent by the [8] medical department to the business group working with PCBs [9] that says PCBs get absorbed through the skin? [to] A: I think so. Hi] Q: How,normally,would Monsanto's medical [12] department give informa tion to the business group working [13] with the PCBs about potential health hazards of PCBs? [14] A: They would talk to them, explain what the [15] action is, and then they would have an agreement how they [i6] would contact the customer. [17] Q: And were the discussions fol lowed by [is] confirming letters, or any thing written? [19] A: It would be between that busi ness group. [20] Those who leave Mon santo and go, talk to that customer [21] would be the one who would carry that document. [22] Q: But after the medical department had a [23] discussion with the business group, would those be followed [24] by confirming letters between the medical department and [25] the business group regarding the subject matter of the Page 77 [1] discussion? [2] A: I don't know. [3] Q: Did you ever talk with the busi ness group [4] working with PCBs and let them know that PCBs get absorbed [5] through the skin? [6] A: That was before I joined Monsan to. They [7] already knew it. [8] Q: Did you talk with anyone within the business [9] department of Monsanto working with PCBs where they [ioj indi cated to you that they knew PCBs get absorbed through [ii] the skin? [12] A: Yes. [13] Q: Who did you speak with from the business [14] department at Monsanto working with PCBs where they [15] indi cated they knew that PCBs get absorbed through the [16] skin? [17] A: The safety data sheet said it. [is] Q: Did you talk -- [19] MR. BRADLEY: I'm sorry.Would you read [20] back the last two questions and answers? [2i] (Whereupon, the reporter propounded the previous two [22] ques tions and answers.) [23] Q: (By Mr. Bradley) So let me go back.Who did [24] you speak with within the business department who indicated [25] to you that the business department knew that PCBs get Page 78 HI absorbed through skin? [2] MR. FEATHERSTONE: You used "business [3] department." He said busi ness group. [4] MR. BRADLEY: Business group, yes. [5] MR. FEATHERSTONE: All right. [6] A: That safety data sheet was already written and [7] defined what the hazards were, as to what they should do to [8] protect themselves from it, and included in that would be a [9] discussion, a state ment, concerning the safety. [io] Q: (By Mr. Bradley) My question, though, is -- [ii] You indicated you'd spoken with someone within the busi ness [12] group of Monsanto working with PCBs where they indicated to [13] you that they knew PCBs got absorbed through the skin. So [14] my question to you is, who is it that you spoke with in the [15] business group of Monsanto's PCBs, working with Monsanto's [16] PCBs, that indicated to you that they knew PCBs get [i7] absorbed into the skin? [is] A: I had a copy of their safety data sheet that [19] told me that. [20] Q: All right. [21] A: I don't need to have someone else to go ask [22] them, "Is this yours?" [23] Q: So you didn't talk -- [24] A: Directly to them, because I knew it was taking [25] place because I had that safety data sheet. Page 79 [i] Q: All right.Did anyone from the busi ness group [2] of Monsanto working with PCBs indicate to you that they [3] knew that there were some studies suggesting that PCBs [4] might cause liver damage? [5] A: The studies that were done within / Monsanto was [6] the IBT studies that >,/ showed that PCBs will effect the [7] liver. [8] Q: My question, though, is did anyone from the [9] business group of Monsanto working with PCBs ever indicate [10] to you that they knew that PCBs might damage the liver? [in A: Not to me. [12] Q: Did anyone from the business group at Monsanto [13] working with PCBs ever indicate to you that they knew [14] anything about the alleged association between PCBs and [15] harm ful effects on human health? [16] MR. FEATHERSTONE: May I hear the question, [17] please, Mr. Court Reporter? [is] (Whereupon, the reporter propounded the previous question.) [19] MR. BRADLEY: I'm going rephrase the [20] question. to [2i] Q: (By Mr. Bradley) Did anyone within the [22] business group at Monsan to working with PCBs ever indicate [23] to you that they knew that PCBs might cause harm to human [24] health? [25] A: Not to to me, they didn't. Page 80 [i] Q: Did anyone within the business group of [2] Monsanto working with Page 75 - Page 80 Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022929 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 PCBs ever indicate to you that they [3] knew PCBs might cause harm to the environment? [4] A: No. [5] Q: Did you ever review any docu ments generated by [6] the business group at Monsanto working with PCBs that [7] indicated that that knew that PCBs might cause harm to [8] human health? [9] A: Yes. do] Q: What documents did you review? [ill A: There are a series of safety data sheets that ]i2] describe that. [i3] Q: Other than the safety data sheets, did you [i4] review any documents that would indicate that the business [15] group at Monsanto working with PCBs knew that PCBs might [i6] cause harm to human health? [17] A: No. [18] Q: Other than this safety data sheet, did you [19] review, have you ever reviewed any documents generated by [20] the business group at Monsanto working with PCBs that [21] indicates that PCBs might cause harm to the en vironment? [22] A: No. [23] Q: During the time that you worked at Monsanto, [24] did you ever review any document generated by the medical [25] department to the business group at Monsanto working with Page 81 [i] PCBs that described how - Excuse me - that indicated PCBs [2] may cause harm to human health? [3] MR. FEATHERSTONE: May I hear that one back, [4] please, Mr. Court Reporter? [5] (Whereupon, the reporter propounded the previous question.) [6] A: My safety data sheet is the only thing I've [7] got that talks about whether it will or will not produce [8] effects on human health. [9] Q: (By Mr. Bradley) Who generated the safety [io] data sheets? [ii] A: The safety man from the business group working [12] with someone from the medical department. [i3] Q: All right. And during the time you were [i4] employed at Monsanto, did you review any documents that [15] were generated by Monsanto's medical department to [16] Monsanto's business group working with PCBs that indicated [17] PCBs may cause harm to the environ ment? [is] A: No.Thatwasn'tourresponsibility. It was [19] not the medical department's responsibility. [20]Q; Whose responsibility was it? [21] A: Business group. [22] Q: Did the business group maintain its own [23] library? [24] A: I don't know. [25] Q: How did the business group learn about PCBs Page 82 [1] causing harm to the environment? [2] MR. FEATHERSTONE: Objection. [3] A: I can't answer that. [4] MR. FEATHERSTONE: No showing of personal [5] knowledge. [6] Q: (By Mr. Bradley) Are you familiar with a [7] series of studies performed by a Professor Jensen in Sweden [8] regard ing PCBs? [9] A: No. [10] Q: Are you aware of any studies at all that show [ii] that PCBs may cause harm to the environment? [12] A: I can't answer that question. [13] Q: Why can't you answer the ques tion? [14] A: I don't know what you mean by "damage to the [15] environment." [16] Q: Well, how about thinning of eg gshells? [17] A: I think that would be a reasonable one, but [is] that's so infrequent. [19] Q: Well, did you, while you were employed at [203 Monsanto, did you review any studies that indicated PCBs [21] may cause eggshells to be thinner? [22] MR. FEATHERSTONE: Object to the form, the [23] form of the question. [24] A: Yes, I've heard of that. [25] Q: (By Mr.Bradley) And did you relay that Page 83 [i] information to the business group at Monsanto working on [2] PCBs? [3] A: No. [4] Q: And during the time you were at Monsanto, did [5] you learn that PCBs were being found in marine [6] environ ments? [7] A: Yes. [8] Q: And did you relate that informa tion to the [9] business group? [io] A: They already knew it. Hi] Q: How do you know they already knew it? [12] A: They got that from Wheeler be cause Wheeler [13] knew that. [14] Q: Did you hear Wheeler tell the business group [15] about -- [16] A: No. in] Q: You're guessing that Mr. Wheeler told them [is] that? Is that what you're doing? [19] A: He worked closely with them. [20] Q: If you were going to find out who Mr. Wheeler [2i] worked with in the busi ness group at Monsanto working with [22] PCBs, what would you do? [23] A: Go and talk to one of the mem bers of that [24] business group. [25] Q: Which member of the business group would you Page 84 [1] talk to? [2] THE WITNESS: Byname? [3] MR. BRADLEY: Yes. [4] A: Mr. Papageorge. [5] Q: (By Mr. Bradley) Is there a business group at [6] Monsanto working with PCBs that's different from the [7] market ing and sales? [8] A: They don't have a marketing or anything on [9] PCBs now. [io] Q: Let's talk about the '70s. During the '70s, [ii] was there a business group at Monsanto working with PCBs [12] that was separate from Monsanto marketing and sales [13] departments? [14] A: I don't think so. [15] Q: During the time that you worked at Monsanto, [i6] did you review any documents that indicated that [17] Plaintiff's Exhibit 979 was given to the business group at [is] Monsanto working with PCBs? [19] A: I don't know. [20] Q: Do you know of any research in dicating PCBs [2i] may cause malignant melanomas? [22] A: I know one paper in which it talked about it. [23] There were two cases. [24] Q: And when did you review the paper? [25] A: I knew about it before it was pub lished. Page 85 ID Q: And when was it published? [2] A: I don't recall. 13] Q: When did you learn about it? [4] A: I can't answer that. [5] Q: You don't recall when you learned about the [6] malignant melanomas? [7] A: Yes. I had a direct call to tell me about it. [8] Q: Was that in the 1970s? 19] A: Whenever it happened. I don't remember that. [io] Q: Well, I know that you don't remember, but do [ii] you remember whether it happened in the 1970s? [12] A: It would be the late '70s or early '80s. [13] Q: Do you know whether that infor mation was given [14] to the business group at Monsanto working with PCBs? Concannon & Jaeger (314) 421-1000 Min-U-Script Page 81 - Page 85 WATER PCB-SD0000022930 George Roush, Jr, March 17, 1993 Nevada Power Company v. Monsanto Company, et al. [15] A: I think it was. 116] Q: And was it given to them in the form of a [i7j letter or a report? [is) A: I don't remember. U9] Q: Do you recall talking with anyone within the [20] business group at Monsan to working with PCBs about the [2i] malignant melanoma cases? [22] MR. FEATHERSTONE: Object to the form of the [23] question. [24] A: I informed them that we did have it, I recall, [25] that we did receive it, that document. Page 86 HI Q: (By Mr. Bradley) You informed someone at the [2] business group within Monsanto? [3] A: Yes. [4] Q: All right. And who was it that you informed? [5] A: I can't recall. [6] Q: Do you recall whether it was via phone? [7] A: We met with them. [8] Q: Did you meet with them in Monsanto's medical [9] department? [10] A: I don't -- Yes, I'm sure we did. [11] Q: And who was there? [12] A: I can't recall. [13] Q: Do you recall whether there was someone front [i4] the medical depart ment at that meeting other than you? [15] A: I don't think so. [16] Q: Do you recall whether there was more than one [17] person from the busi ness department at that meeting, [is] business group? [19] A: No. [20] Q: Two of you? [21] A: At least two. [22] Q: And you orally described what you learned [23] about malignant melanomas? [24] A: Yes. [25] Q: And did the business group in form Monsanto's Page 87 [i] -- At the time you learned about the malignant melanomas, [2] did Monsanto still have customers for its PCB products? [3] A: I think so. [4] Q: And did Monsanto inform its cus tomers about [5] what you learned regarding malignant melanomas and PCBs? [6] MR. FEATHERSTONE: Well, I object to the form [7] of the question and foun dation. He already testified that [8] was not his job, that was the job of the busi ness group. [9] MR. BRADLEY: You still have to answer the [ioj question. [ii] A: With what I know, I can't answer your [12] question. [13] Q: (By Mr. Bradley) Okay. [14] A: But we did respond. [15] Q: You did respond? [16] A: Yes. We told everyone. Everyone knew about [17] it. [is] Q: What do you mean that you responded? H9] A: That malignant melanoma has al ready [20] disappeared as a subject. It's been published. The [21] medical direc tor of Mobile called me and thanked me for the [22] fact that I helped them on it. And all ofthis that I've [23) said was given to Monsanto's business group. They knew (24) about my contacts and what had taken place. [25] Q: And did the -- Do you know whether Monsanto's Page 88 [i] business group, or Monsanto's medi cal department or any [2] department or group within Monsanto, ever told Monsanto's [3] customers about what you learned of malignant melanoma and [4] PCBs? [5] A: We haven't learned anything. We told them we [6] hadn't learned anything yet. [7] Q: Do you know of any studies or research [8] indicating PCBs may cause brain tumors? [9] A: No. [ioj Q: Do you know of any research or study [in indicating PCBs may have caused injury to workers? [12] THE WITNESS: Injuries to workers? [13] MR. BRADLEY: Yes. [14] A: Yes. [15] Q: (ByMr.Bradley)Andwhatkindof injury did [16] those workers suffer? [17] A: Almost -- The only thing they see is the [is] result of irritation. [19] Q: Doctor, is there a difference be tween [20] irritation and chloracne? [21] A: Yes. [22] Q: Do you know of any research study indicating [23] PCBs may have caused chloracne to workers? [24] A: There is a lot of literature that talks about [25] it causing acne but to say it causes chloracne is not Page 89 [i] clear. [2] Q: Did Monsanto ever inform its cus tomers that (31 PCBs -- Excuse me, let me start all over again. Did [4] Monsanto ever inform its customers that it's not clear [5] whether PCBs may cause chloracne? [6] MR. FEATHERSTONE: Well, same ob jection. [7] Absence of foundation for this witness to testify regarding [8] those questions. He's already identified for you, Mr. [9] Bradley, how it was Monsanto warned its customers. He said [ioj it came through the business group. Hi] THE WITNESS: You're asking about the [12] difference between chloracne and acne? [13] MR. BRADLEY: I' m asking you whether Monsanto, [i4] whether you ever saw any documents or you heard anybody [15] ever say that Monsanto warned its customers that it's [i6] un clear whether PCB, or whether chloracne may be - may [i7] result from exposure from PCBs. [is] A: There are accidents in which there is, I was [19] told there was chloracne. All this happened -- [20] MR. FEATHERSTONE: No. He's as king you [2i] whether you have seen any document or heard any statement [22] that Monsanto warned its customers that exposure to PCBs - [23] it's unclear that exposure to PCBs could cause chloracne. [24] I think I phrased that cor rectly. [25] MR. BRADLEY: Close enough. Page 90 [i] A: I don't know. [2] Q: (By Mr. Bradley) As a doctor, how would you [3] explain the difference be tween chloracne and skin [4] irritation? [5] A: Chloracne is a reaction that takes place in [6] the pores, largely associated with sweat glands, and the [7] material that causes the reaction gets into these pores and [8] causes a reaction around it and you've seen acne, kids' [9] acne. Its very similar, only it's got something that's in [io] it now. [ii] Q: Is chloracne, medically speaking, a more [12] severe condition than skin irritation? [13] A: Yes. Because it's more -- Last longer. [14] Q: Is there -- Excuse me. Are there different [15] degrees of severity of chloracne? [16] A: Yes. [17] Q: Medically speaking, how would you describe the [is] condition of a severe chloracne? [19] MR. FEATHERSTONE: May I hear that question, [2oj please? [21] (Whereupon, the reporter propounded the previous question.) [22] A: A severe case is one in which the reaction [23] between two pores, two nodules, become one, so there is a [24] coalescence of a lesion. [25] Q: (By Mr. Bradley) Does a patient with severe \ / ! I Page 86 - Page 90 Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022931 Nevada Power Company v. Monsanto Company, et aL Page 91 m chloracne run a risk of having scars? Let me ask it this [2j way. Will severe chloracne cause scarring? [3] A: It can. [4] Q: Do you know whether exposure to chlorinated [5] biphenyl has ever caused severe chloracne to workers 16] working with chlorinated biphenyl? [7] A: It's so infrequent that I can't answer the [8] question. [91 Q: Well, when you say it's infrequent, does that [103 mean it happens but it happens rarely? [ill MR. FEATHERSTONE: Object to the form. 112] Q: (By Mr. Bradley) What do you mean, it happens [13] infrequently? [14] A: It rarely happens. [15] Q: (By Mr. Bradley) Do you know when the first [16] case was of a worker experiencing severe chloracne from [17] exposure to PCBs? [is] A: No. [191 Q: Did you ever review any docu ments from [20] Monsanto to its cus tomers indicating that rarely, PCBs [21] could cause, have caused severe chloracne? [22] A: No. Not to my knowledge. [23] Q: You haven't reviewed anything? [24] A: I've reviewed it but it's not in our current [25] literature. Page 92 HI Q: Was it in any of the former litera ture that [2] you reviewed? [31 THE WITNESS: Before my time? Hi MR. BRADLEY: That you may have reviewed. [5] A: I don't know. [6] Q: (By Mr. Bradley) Do you know whether the [7] United States Environ mental Protection Agency classifies [8] PCBs as a probable human carcinogen? [9] A: I think it says "possible." It does say no] possibly, but that's only -- It doesn't talk about the [in animal data. That's only talking about the human data. [12] Q: Do you know when the United States [131 Environmental Protection Agency classified PCBs as a [143 possible human carcinogen? [15] A: Yes. [16] Q: When was that? [17] A: After that problem we were talk ing about, the [is] melanoma. [19] Q: So sometime in the late '70s? [20] A: Yes. [21] Q: Did you participate as a witness in any [22] Government hearings regard ing the Toxic Substances Control [23] Act? [24] A: No. [25] Q: Did you ever review material that Monsanto Page 93 [i] sent to its customers prior to your employment at Monsanto [2] describing the harm to human health that is caused by [3] exposure to PCBs? [4] MR. FEATHERSTONE: That caused? is 15] MR. BRADLEY: That's what was -- [6] MR. FEATHERSTONE: Object to the form. [7] A: We had published what we gave to our [8] customers, that - the irritant potential of it. We don't [9] think that there's much beyond that except for the question no] of liver effect. [ii] Q: (By Mr. Bradley) Did you review material [12] generated by Monsanto prior to your employment with them [13] that advised their customers that ex posure to PCBs caused [i4] liver problems? [15] MR. FEATHERSTONE: Object to the form. [16] A: Yes. [17] Q: (ByMr.Bradley)And what did you review that [is] said that? [19] A: Some of those safety data sheets say that. 120] Q: Other than the safety data sheets, did you [213 review anything that Mon santo gave to its customer - [22] A: No. [23] Q: - that indicated exposure to PCBs caused harm [24] to the liver? [25] A: No. Page 94 [i] Q: All right. Are chlorinated Napthalenes trace [2] constituents of a com mercial PCB mixture manufactured by [3] Monsanto? [4] A: I don't think so. [5] Q: Do you know whether nearly all Americans are [6] reported to have over five hundred parts per billion PCBs [7] in their adipose tissue? [8] A: I know we have PCBs in our fat, in our blood. [9] Q: Almost all of us? [10] A: The data is not there that will answer that, [ii] but it's very common. [12] Q: Do you know whether PCBs have ever been found [13] in human mother's milk? [14] A: Yes. [15] Q: Do you know whether PCBs pass through the [16] mother's placenta to the fetus? . [17] A: Not as well as by milk. Concannon & Jaeger (314) 421-1000 Min-U-Script George Roush, Jr. March 17, 1993 [18] Q: Do PCBs biodegrade? [19] A: Yes. [20] Q: Are you familiar with the term [21] biomagnification? [22] A: Yes. [23] Q: What is it? [24] A: By virtue of passing from one animal to [25] another, the material that we're taking goes with them and Page 95 [i] so over a life, over several generations, there can be an [2] increase. [3] Q: Do you know whether PCBs biomagnify in the [4] human food chain? [5] A: I've never heard, seen it described. [6] Q: Do you know whether PCBs can work [7] synergistically with other com pounds by impairing the [8] immune sys tem? [9] A: I've seen it described. [10] Q: Did Monsanto ever inform its cus tomers that [ii] PCBs can work synergis tically with other compounds by [12] im pairing the immune system? [13] A: No. Wouldn't know what to tell them. [14] Q: Have PCBs been shown to cause liver cancer in [15] experimental animals? [16] A: In about three out of ten cases, it is said [17] that there are some neoplastic lesions. [is] Q: And were those studies on those experimental [193 animals conducted during a period of time when Monsanto had [20] customers for its PCB products? [21] MR. FEATHERSTONE: Object to the form of the [22] question. [23] A: I was -- Monsanto was out of the business by [24] that time. [25] Q: (By Mr. Bradley) All right. Do you know Page 96 [i] whether chronic poisoning may occur with repeated exposures [2] to sufficient concentrations of PCB vapor? [3] THE WITNESS: What's the con clusion? [4] Q: Do you know whether chronic poisoning may [5] occur with repeated exposure to sufficient concentrations [6] of PCB vapors? 17] A: Never heard it described. [8] Q: As a doctor, do you know what chronic [9] poisoning is? [io] A: Yes. [in Q: What is chronic poisoning? [i2] A: Chronic poisoning is where the material is [13] given to the organism and instead of giving it to them so [i4] to produce acute effects, instead of that, it's given at a [15] lower dose where it doesn't produce enough to make the [i6] Page 91 - Page 96 WATER PCB-SD0000022932 George Roush, Jr. March 17,1993 Nevada Power Company v. Monsanto Company, et al. animal ill except over a period of some time. We usually [17] say over a month, that we see an effect in the animal. [is] Q: Did Monsanto ever tell its cus tomers that [19] chronic poisoning may occur with repeated exposures to [20] sufficient concentrations of PCB vapor? pi] A: We don't think it happens. [22] Q: Did Monsanto ever tell its cus tomers that [23] repeated exposures to PCB vapor may produce internal bodily [24] injury which may be disabling or could be fatal? [25] MR. FEATHERSTONE: I again, to the object, Page 97 [1] foundation for the question because this witness testified [2] who had the responsibility for advising customers. [3] THE WITNESS: I have difficulty with it. Can [4] you repeat that for me? [5] (Whereupon, the reporter propounded the previous question.) [6] Q: (By Mr. Bradley) Did Monsanto ever inform its [7] customers that repeated exposures to PCB vapor may produce [8] internal bodily injury which may be disabling or could be [9] fatal? [io] A: No. [i i] Q: Did Monsanto ever inform its cus tomers that [12] PCBs are highly toxic if taken internally? [13] MR. FEATHERSTONE: Same objec tions. [14] A: Yes. [15] Q: Did Monsanto ever inform its cus tomers that [16] PCBs are not very irritat ing to the skin but if absorbed [17] through the skin can produce toxic reactions internally? [is] A: No. [i9] Q: Did Monsanto ever inform its cus tomers that [20] periodic physical ex aminations should be conducted by [21] medical personnel for workers exposed to PCBs? [22] MR. FEATHERSTONE: Object to the lack of [23] foundation for this witness to respond to a question about [24] Monsan to ever informing customers, when he joined the [25] company in 1973. Page 98 ID THE WITNESS: I'm sorry. [2] A: No. [3] Q: (By Mr. Bradley) That didn't hap pen, at least [4] while you were employed at Monsanto? [5] A: That's right. [6] Q: And you didn't review any docu ments indicating [7] that Monsanto had given that information to customers prior [8] to your employment at Monsan to? [9] A: And even whether I believe it's necessary. [10] MR. FEATHERSTONE: That's not the issue, Dr. [ii] Roush. The issue is whether you know whether that was ever [12] communicated by Monsanto. [13] A: And I said I don't know. [14] MR. FEATHERSTONE: All right. [15] Q: (By Mr. Bradley) Do you agree that a skin [16] disease called chloracne could be an indication of a more [i7| serious systemic injury? [is] A: No. [19] Q: Do you know whether Monsanto ev"er informed its [20] customers that a skin disease called chloracne could be an [21] indication of a more serious sys temic injury if exposure to [22] PCBs was allowed to continue? [23] MR. FEATHERSTONE: Same objec tion. Lack of [24] personal knowledge for this witness to respond. [25] A: I don't think so. Page 99 [i] Q: (By Mr.Bradley)At least,that didn't happen [2] while you were employed there? [3] A: That's right. [4] Q: You didn't review any documents indicating it [5] had happened before you began your employment? [6] A: That's right. [7] Q: Do you know whether lower temperatures for [s] destroying Aroclors - and by "lower," I mean below eight [9] hundred degrees -- [io] THE WITNESS: Lower than what? [ii] MR. BRADLEY: Let me ask this ques tion. [12] Q: (By Mr. Bradley) Was there a period of time [13] when Monsanto in cinerated Aroclors to destroy them? [14] A: I don't know. [15] Q: Was there a time when Monsanto knew that if it [16] incinerated PCBs at low temperatures that that could cause [17] the PCBs to vaporize and furans to form? [18] A: I don't know. [19] Q: Would you agree that furans are one of the [20] most extremely toxic of any compound since the beginning of [21] chemistry? [22] A: No. [23] Q: When you began work for Mon santo, were you [24] made aware that there might be Congressional action taken [25] to restrict the manufacture of PCBs? [2] Q: When you began your employ ment with Monsanto, [3] do you know whether Monsanto employed any of its -- Excuse [4] me. Let me start all over again. When you began your [5] employ ment at Monsanto, do you know whether Monsanto [6] informed any of its customers that there might be [7] Congressional action that would restrict the manufacture of [8] PCBs? [9] A: Yes. [10] Q: And while you were at -- When you first went [ii] to Monsanto, do you know whether Monsanto informed any [12] electric utility companies that there was Congressional [13] action which might restrict the manufacture of PCBs? [14] MR. FEATHERSTONE: Wait a minute. You started [15] off by saying "might be Congressional action." Now, are [16] you changing it to there was Congressional action? Object [17] to the form of the questioning. !18] MR. BRADLEY: I'll re-ask it. [19] Q: (By Mr.Bradley) When you began your work at [20] Monsanto, did Monsan to inform electric utility companies [21] that there might be Congressional ac tion that would [22] restrict the manufac ture of PCBs? [23] A: Yes. [24] Q: Okay. And which electric utility company -- [25] Let me ask it this way. How did Monsanto inform electric Page 101 [i] utility companies, when you began working with Monsanto, [2] that there might be Congressional action that would [3] restrict the manufacture of PCBs? [4] A: I don't know. [5] Q: How do you know that Monsanto gave that [6] information to electric utility companies? [7] A: They knew it. I'm not sure how they got it. [8] Monsanto told them or else the Government told them, one or [9] the other. [io] Q: So all the electric utility com panies knew [in that in 1973? [12] A: Yes. [13] MR. FEATHERSTONE: How is he going to answer [14] that, Ralph, all the electric utilities? This is the [15] associate medical director of Monsanto. [16] MR. BRADLEY: All right. [17] Q: (By Mr. Bradley) While you were employed at [is] Monsanto, did you ob serve any Monsanto employees working in [19] a lab on, or with PCBs? [20] A: No. [21] Q: Did you ever go to Industrial Biotest [22] Laboratories? [23] A: Yes. [24| Q: When you were there, who did you meet with? Page 97 - Page 101 Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022933 Nevada Power Company v. Monsanto Company, et aL George Roush, Jr. March 17, 1993 [251 A: Dr. Calandra. Page 102 [1] Q: Did you meet with anyone else? [2] A: There was another man, his name was Richter. [3] Q: What was the purpose of your meeting with Dr. [4] Calandra? [5j A: Talk about the PCB study. [6| Q: Did the meeting occur at IBT headquarters? [7i A: Yes. [8j Q: While you were there, did you walk around the [91 IBT headquarters? [ioi A: No. Hi] Q: While you were there, did you observe any of [12] the rooms where the animals were kept? [13] A: No. [14] Q: Were there animals kept at the IBT [15] headquarters? [16] A: Yes. [17] Q: Did you ever hear of a room called the Swamp [is] Room? [19] A: No. [20] Q: Who, at Monsanto, if anyone, -- Let me ask [21] this. Do you know of anyone at Monsanto who also visited [22] the IBT labs? [23] A: Anyone else from Monsanto that visits had IBT? [24] MR. BRADLEY: Yes. [25] A: No. Page 103 [i] Q: I'm going on show you Plaintiff's Exhibit 1251 [2] and ask you what that document is? What is this Exhibit, [3] Dr. Roush? [4] A: This is a discussion of the findings of the [5] D3T cancer study, and upon completion of this study, we [6] agreed to take this to Washington and present this data to [7] the various agencies. [8] Q: And this is dated January 13,1976? [9] A: Yes. [10] Q: Had you seen this document prior to today? [ii] A: No. [12] Q: Does the document fairly and ac curately report [13] the results of the meeting that's reference in the [14] docu ment? [15] MR. FEATHERSTONE: Object to the form of the [16] question. [17] A: No. This reflects theNIOSH inter pretation of [is] the results. [19] Q: (By Mr. Bradley) Is your inter pretation any [20] different than their's? [21] A: Well, the discussion is between the D3T [22] studies, or the Calandra studies and the study that was [23] done someplace -- Didn't it say in here that -- No.Just [24] D3T and Kimbrough. [25] Q: Do you know a gentleman by the name of Paul Page 104 [1] Wright? [2] A: Yes. [3] Q: How did you first learn of Mr. Wright? [4] A: He was working for Monsanto when I joined. [5] Q: In 1973? [6] A: Yes. [7] Q: What department was he working in? [8] A: He was working for Levinskas, in toxicology. [9] Q: All right. Part of the medical department, [ioj toxicology section? [11] A: Yes. [12] Q: Did Mr. Wright then leave Mon santo? [13] MR. FEATHERSTONE: It's Wright. [14] A: No. Dr. [15] Q: (By Mr, Bradley) Dr. Wright never went to [16] work for IBT? in] A: He had worked for IBT before I joined. [is] Q: All right. When did Mr. - excuse me - Dr. [19] Wright work for Monsanto? [20] A: I can't give you the dates. [21] Q: Okay. Did you hire Dr. Wright? [22] A: No. [23] Q: Who hired Dr. Wright? [24] A: Dr. Levinskas. He worked for him. [25] Q: Okay. When did Dr. Wright work for IBT? Page 105 [1] A: Prior to my joining Monsanto. [2] Q: And afteryou joined Monsanto,Dr. Wright [3] continued as a Monsanto employee up to what date, do you [4] know? [5] MR. FEATHERSTONE: You have to answer that. [6] A: Yes. Not by a shake of the head. [7] MR. FEATHERSTONE: Is the answer no? You [8] shook your head no, because you don't know the date; is [9] that cor rect? [10] A: That's correct. [11] Q: (By Mr. Bradley) Do you know whether Dr. [12] Wright was a Monsanto employee in 1976? [13] A: Yes. [14] Q: Was he a Monsanto employee in 1975? [15] A: I don't know. [16] Q: 74? [17] A: I'm not sure of the dates. [is] Q: He was a Monsanto employee when you first [19] became a Monsanto employee? [20] A: Yes. [21] Q: Was there a point in time when Dr. Wright -- [22] I'm going to start my question all over again. Did Dr. [23] Wright not work for Monsanto for part of the 1970s, do you [24] know? [25] A: I don't know. Page 106 [i] Q: Do you know whether -- Off the record. [2] (Whereupon, a discussion was held between Counsel, off the [3] record.) [4] MR. BRADLEY: I'm now going to show you [5] Plaintiff's Exhibit 1421 and ask you to review that. [6] Q: (By Mr. Bradley) Have you had a chance to [7] review it? [8] A: Yes. [9] Q: All right. Is this an August 27th, 1976 [io] internal memorandum sent to you by Frederick Johannsen? [ii] A: Yes. [12] Q: Is this a fair and accurate copy of the [13] interdepartmental memorandum sent to you on that date? [14] A: Yes. [15] Q: And is this the sort of document that you [16] maintained in your files at Monsanto? [17] A: Yes. [is] Q: You did that as part of the regular practice [19] of Monsanto? [20] A: I wanted to know whether there was any cancer [21] related to that. [22] Q: Do you know whether the infor mation contained [23] in this exhibit was ever given to any Monsanto customers? [24] A: We gave this -- We didn't have [25] epidemiologists. This is a toxiologist doing this, and we Page 107 [i] gave it to a Dr. Mabube for review and he thought this was [2] not significant. [3] Q: So is it fair to say, then, that you did never [4] give this information to Mon santo customers? [5] A: No. [6] Q: That's not fair to say? [7] A: We did not. [8] Q: You did not. All right. [9] A: We then gave a paper on this sub ject. [10] Q: I'm now going to show you what's mark for [i 13 identification as Plaintiff's Exhibit 367 and ask you to [12] review that. Have you seen that docu ment before? [13] A: Yes. Long ago. Concannon & Jaeger (314) 421-1000 Min-U-Script Page 102 - Page 107 WATER PCB-SD0000022934 George Roush, Jr March 17, 1993 Nevada Power Company v. Monsanto Company, et aL [14] Q: Is that a report entitled, "Mor talities of PCB [is] workers at the Mon santo plant in Sauget, Illinois" by [i6] Judith A, Zack, Z-a-c-k, and David C. Musch, M-u-s-c-h, [17] dated December 14,1979? [is] A: Yes. [i9] Q: Is this a fair and accurate report proposed by [20] them? [21] A: Yes. [22] Q: Is this the sort of document that you [23] maintained in your files at Mon santo? [24] A: Yes. [25] Q: Did you do that as part of your business work Page 108 [1] at Monsanto? [2] A: Yes. [3] Q: I'm now going to show you what's marked for [4] identification as Plaintiff's Exhibit 350 and ask you to [5] tell me what that document is. Actually, I'm going to ask [6] you first to review it. Have you had a chance to review [7] it? [8] A: Almost.Yes. 19] Q: Is this a April 18th, 1975 letter to you from [io] J.C. Calandra, President, along with a review of a PCB [in meet ing? [12] A: Yes.This is the result ofa meeting, yes. [13] Q: All right. Is this a document that you've [14] seen before? [15] A: Yes. [16] Q: And is this a fair and accurate copy of the [17] document? [18] A: Yes. [19] Q: And is this the sort of document that you [20] maintained in your files at Monsanto as part of your [2i] regularly conducted business? [22] A: If it was appropriate, it would be. [23] Q: Do you see the first full paragraph there, [24] were it says, "Dear George, I fully appreciate that the [25] meeting on PCBs today was not completly satisfac tory and Page 109 [1] many nagging questions remain." [2] A: Yes. [3] Q: Would you agree that the meeting referenced [4] was not completely satis factory? [5] A: Yes. [6] Q: Would you agree that many nag ging questions [7] remained after that meeting? [8] A: Yes. [9] Q: What was there about the meeting that was not [io] completely satisfactory? [in A: The interpretation of whether these nodules [12] were hyperplastic nodules or whether they are [13] well-dif ferentiated carcinomas, or what inter pretation [i4] should be put on these. [15] Q: Was the question whether or not they were [16] malignant, cancerous? [17] A: Yes. [is] Q: All right. And was the nagging questions that [19] remained whether or not those lesions were malignant [20] cancers? [21] A: No. The question is how we're going to [22] respond to EPA on -- We were going to take this to [23] Washington and wanted to have it clear what it was that we [24] were taking to them. [25] Q: All right. I'm now going to show you Page 110 [i] Plaintiff's Exhibit 424 and ask you to review that [2] document. Have you had a chance to review that? [3] A: I think so. At least, go over it lightly. [4] Q: Is that a September 9, 1969 inter department [5] memo to E. Wheeler from W.R. Richard? [6] A: Yes. [7] Q: And those are both Monsanto employees? [8] A: Yes. [9] Q: And have you seen this document before? [10] A: No. [ii] Q: Would you turn to page four, towards the [12] bottom on the left-hand side. Do you see the name [ 13) R-o-u-s-h down there? [14] A: Yes. [15] Q: Do you know what that is,ifthat's referring [16] to you? [17] A: If it's 1969, it's not referring to me. [is] MR. FEATHERSTONE: Let's go off the record for 119] a second. [20] (Whereupon, a discussion was held between Counsel, off the [21] record.) [22] Q: (By Mr. Bradley) Is this the sort of document [23] that Monsanto would maintain in its files as part of its [24] regularly conducted business activities? [25] MR. FEATHERSTONE: Object to the form. Page 111 [l] A: The question is what they do with things like [2] this, is the important thing. This is an assessment. [3] MR. FEATHERSTONE: The question is whether its [4] kept in the files. [5] MR. BRADLEY: Yes. [6] Q: (By Mr. Bradley) They keep it in the files? [7] A: I don't know. [8] Q: Is this the sort of document that you would [9] expect them to keep in the files though? [10] A: I don't know. [11] Q: Did Monsanto have a policy for maintaining [12] records relating to PCBs during September of 1969, do you [13] know? [14] A: I don't know. [15] Q: All right. Dr.Roush, I -- Apparent ly, there [16] is another Roush that worked at Monsanto whose name was Don [17] Roush. Had you ever -- Do you know of a Don Roush who [is] worked at Monsanto? U9] A: I did not. [20] Q: I'm now going to show you Plaintiff's Exhibit [21] 1154 and I'm inter ested in knowing whether you've ever [22] reviewed that before? [23] A: No, I haven't seen it. [24] Q: All right. I'm now going so show you [25] Plaintiff's Exhibit 1425 and ask you to review that. Have Page 112 [1] you had a chance to review that? [2] A: Yes, sir. [3] Q: Is that an August 29th, 1975 inter departmental [4] from David Wood to you - or excuse me, to W.B. Papageorge? [5] A: Yes. [6] Q: Are you copied over on the righthand, as [7] indicated by the - [8] A: Yes. [9] Q: - information on the right-hand side? Is this [io] a document you've seen before? in] A: I must have seen it, my name's on there, but I [12] don't recall it. [13] Q: All right. I'm going to show you Plaintiff's [14] Exhibit 428 and ask you to review that. Doctor, I want to [15] know whether you've seen that document before? [16] THE WITNESS: This was in 1969. [17] MR. BRADLEY: Yes, I know that. [is] A: Yes. But I don't recall it. [19] MR. BRADLEY: All right. 120] A: I haven't read it either. [21] MR. BRADLEY: Take your time, then, to [22] determine, just to determine whether you've seen the [23] document before. [24] A: No. [25] Q: I'm now going to show you Plaintiff's Exhibit Page 113 [i] 517 and ask you to review it for the purpose of telling me m whether you've ever seen the document before? [3] A: I don't recall it. Page 108 - Page 113 Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022935 Nevada Power Company v. Monsanto Company, et al. [41 Q: I'm now going to show you Ex hibit 422 and ask [5] you if you have ever seen that document before? [6j MR. FEATHERSTONE: He wants you to look at it [7] to say whether you have seen it before. [8] A: No, I haven't seen this. This is 1959? [9] MR. BRADLEY: Hard to read it, but it's 1969. [io| THE WITNESS '69? in] MR. BRADLEY: Yes. Bruce, I need to put 422 [i2] here, and I'll make a note to get you a copy, though you [i3l already have it, but I'll make you a copy anyhow. [14] MR. FEATHERSTONE: Did you use 422 in some [i5] other deposition? [16] MR. BRADLEY: No.ButIused422in our [17] request to admit the authenticity. All of these exhibits, [is] up through 970, are exhibits that we provided to you. [19] Q: (By Mr. Bradley) I'm now going to show you [20] Plaintiff's Exhibit 709 and ask you to review it for the [2i] purpose of indicating whether you've seen the document [221 before. Have you had a chance to review that? [23] A: Yes. [24] Q: Have you seen that document before? [25] A: No. Page 114 [1] Q: All right. I'm now going to show you Exhibits [2] 359 and 340 together, and I'd ask you to review them [3] together for the purpose of telling me whether you have [4] seen these docu ments before. Have you seen that docu ment [5] before? [6] A: No. [7] Q: Would you turn, on Plaintiff's Ex hibit 359, to [8] page five, under -- Let me give you a context. If you [9] look back at page four, you'll see the word "toxicity" [io] underlined at the bottom of the page, and at the top of [in page five, it has "human" underlined. [12] A: All right. What's the question? [13] Q: My question is, do you agree, "The known toxic [i4] effects of PCBs in humans include an acne-like skin [15] eruptions (chloractie), pigmentation of the skin and nails, [16] excessive eye dis charge, swelling of eyelids and [17] dis tinctive hair follicles." [18] A: Yes. The only question I have there was that [19] acne-like lesion. Whose definition are we going to use? [20] Q: Do you agree, for a number of years, chloracne [21] of the face and neck has been reported among workers [221 exposed to chlorinated hydrocarbons? [231 A: Yes. [24] Q: Do you agree that workers ex posed to PCBs in [25] the process of insulating cables in the production of Page 115 [i] condensers and the manufacture of chlorobiphenyls have [2] reported these skin lesions along with systemic effects [3] such as digestive disturbances, edema of the face and [4] hands, burning of the eyes and impotence and hematuria? [5] A: Yes. [6] Q: What is hematuria? [7] A: Blood in the urine. Uria is urine, and hema [8] is blood. [9j Q: Did Monsanto inform its cus tomers that the [ioj known toxic effects of PCBs in humans include an acne-like nil skin eruption (chloracne),pigmenta tion of the skin and [12] nails, excessive eye discharge, swelling of eyelids and [i3i distinctive hair follicles? [14] MR. FEATHERSTONE: Same objec tion previously [15] stated about the ab sence ofpersonal knowledge for this [161 witness to answer the question. [17] A: This is from Japan, that you're really citing, [is] Yusho,Yu-s-h-o,and they got it because they were eating [19] the PCBs in the cooking oil. It hasn't been seen since. [20] Q: (By Mr. Bradley) Did Monsanto tell its [2ij customers that for a number of years, chloracnia of the [22] face and neck has been reported among workers exposed to [23] chlorinated hydrocar bons? [24] A: They were told about the, about lesions on [25] their face, about the skin problems. Page 116 [i] Q: But not chloracne? Or yes, they were told of [2] chloracne? [3] A: I don't think they were. [4] Q: All right. Were Monsanto cus tomers told that [5] workers exposed to PCBs in the process of manufacture of [6] chlorobiphenyls have reported skin lesions along with [7] systemic effects such as digestive disturbances, edema of [8] the face and hands, burning of the eyes, impotence and [9] hematuria? [io] MR. FEATHERSTONE: Same objec tion.Absence of [ii] personal knowledge of this witness about what Monsanto told [12] its customers. [13] A: I don't believe these things. I don't believe [14] this. [15] Q: (By Mr. Bradley) Is the answer, then, that [16] you don't - Monsanto, as far as know, didn't report that to [17] its customers? [is] A: I don't know whether it did or not. [19] Q: Now, on page four, under the sec tion that says [20] - or let me do it this way. Under the second full [21] paragraph under "Human," at the end of the last Concannon & Jaeger (314) 421-1000 Min-U-Script George Roush, Jr. March 17, 1993 sentence, [22] it has the references for 16 and 22. Do you see that [23] there? [24] A: Yes. [25] Q: It's on page five. Page 117 [l] A: Yes. [2[ Q: Now, there's a reference section, is there [3] not, at the end of this docu ment? [4] A: Yes. [5] Q: And 16 and 22 refer to -- Well, 16 refers to [6] an article by Dr. Kimbrough, dated 1974 and 22 refers to an [7] article by Dr. Schwartz in 1936; is that correct? [8] A: Yes. [9] Q: Turn now to page six. [io; A: Yes. [in Q: Under the section that begins "Animal." [12] A: Yes. [13] Q: And goes through page eight? [14] A: Yes. [15] Q: While you were at Monsanto, do you know [16] whether Monsanto ever told its customers about the animal [17] toxicity effects that are referred to on pages six, seven [is] and eight of this exhibit? [19] A: I don't know. [20] MR. FEATHERSTONE: Let's go off the record. [21] (Whereupon,a dicussion was held between Counsel, off the [22] record.) [23] [24] [25] Page 118 3 GEORGE ROUSH, JR. Subscribed and sworn to before me this____ _ day of, A.D., 19_________________________________ . Notary Pubiic Notary Public within and for the State of Missouri. MY COMMISSION EXPIRES THE______DAY OF A.D., 19___________________________ Page 119 STATE OF MISSOURI ) )SS COUNTY OF ST. LOUiS ) i, John T. Concannon, a Notary Pubiic within and for the State of Missouri, duiy commissioned, qualified and authorized to administer oaths and to take and certify to depositions, do hereby certify that pursuant to Notice in the civii cause now pending and undetermined in the District Court of the United States, within and for the District of Nevada, entitled NEVADA POWER COMPANY Plaintiff, -vs- MONSANTO COMPANY, et ai., Defendants, to be used in the trial of said cause in said Court, i was attended at the iaw offices of Messrs. Husch & Eppenberger, 100 N. Broadway, Suite 1300, in the City of St. Louis, State of Missouri, by Ralph A. Bradley, attorney for the Piaintiff; by Bruce A. Featherstone, attorney for the Defendant, Monsanto Company; by Laurie Basch, attornty for the Defendant, Westinghouse; and by GEORGE ROUSH wit ness, in said office on March 17, 1993. The said witness, GEORGE ROUSH, being of sound mind and being by me first carefully examined and duly cautioned and sworn to testify the truth, the whole truth and nothing but the truth in the case aforesaid, thereupon testified as is shown in the foregoing transcript, said testimony being by me reported in shorthand and caused to be transcribed Page 114 - Page 119 WATER PCB-SD0000022936 George Roush, Jr. March 17, 1993 into typewriting, and that the foregoing pages correctly Page 120 set out the testimony of the aforementioned witness, GEORGE ROUSH, together with the questions propounded by counsel and the remarks and objections of counsel thereto, and is in all respects a full, true and complete transcript of the questions propounded to and the answers given by said witness; and that said testimony, so transcribed, was subscribed to by the witness on theday of , A. D., 1993. I FURTHER CERTIFY that I am not of counsel nor attorney for any of the parties to said suit, nor related, nor interested In any of the parties or their attorneys. WITNESS MY HAND and Notarial Seal, given this _ day of __, A. D.t 1993, at St. Louis, Missouri. MY COMMISSION EXPIRES SEPTEMBER 12, 1994 JOHN T. CONCANNON, Notary Public, within and for the State of Missouri Page 121 April 28, 1993 Bruce A. Featherstone, Esq. Kirkland & Ellis 1999 Broadway * Ste. 4000 Denver, Colorado 80202 Re: Nevada Power Company -vMonsanto Company, et al. Dear Mr. Featherstone: This letter, incorporated as the fast page of Mr. Roush's deposition, taken on March 17, 1993, will serve as notice to you that his testimony is now ready for reading and signing of same. You will recall you indicated a preference for him reading his deposition, rather than waiving signature. Enclosed please find the original signature page of Mr. Roush's deposition, along with an eratta sheet. Please have Mr. Roush read and sign his deposition and return the original signature page to me. I will then return the signature page to the original transcript, and notify Mr. Bradley of any corrections the witness may have made. Thank you for your cooperation in this regard. Sincerely, JOHN T. CONCANNON Shorthand Reporter Concannon & Jaeger General Court Reporters 705 Olive Street - Ste. 604 St. Louis, Missouri 63101 JTC:md Nevada Power Company v. Monsanto Company, et al. Page 120 - Page 121 Min-U-S cript Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022937 This Page Intentionally Left Blank WATER PCB-SD0000022938 WATER PCB-SD0000022939 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 9 '3 17:14 '40s 50:15; 66:6, 10 '50s 50:15 '57 9:22 '57/58 12:22 '60s 50:15 '69 113:10 7 58:5 70s 84:10,10; 85:12; 92:19 72 14:6 73 19:15; 24:6,14; 54:3; 56:13 74 26:15; 39:20; 51:24; 56:14; 105:16 75 39:20; 51:24 78 22:25; 23:23 '80s 30:22; 85:12 '88 42:14 1 10 5:6 1016 60:3, 23; 61:1, 2 1154 111:21 12 60:18 1221 60:15 1242 60:15 1251 103:1 1254 60:16 1260 60:16 13 103:8 14 107:17 1421 106:5 1425 111:25 16 116:22; 117:5, 5 18th 108:9 19 14:17 1936 117:7 1937 65:18 1940s 65:23 1946 6:3,4 1951 6:14; 7:12 1952 8:8, 15, 18; 9:24 1953 8:6; 10:2 1954 10:5, 5 1957 8:2; 10:8,17, 25; 12:6 1959 12:21; 113:8 1969 110:4,17; 111:12; 112:16; 113:9 1970s 50:11; 85:8, 11; 105:23 1972 15:5,7 1973 17:13,14; 18:15; 19:22; 20:9; 21:23; 24:2, 17, 22; 25:10,14, 21; 39:9; 42:15; 45:9; 73:2,5; 97:25; 101:11; 104:5 1974 17:12; 27:5; 40:9; 117:6 1975 17:25; 25:19; 51:23; 105:14; 108:9; 112:3 1976 58:5; 103:8; 105:12; 106:9 1979 107:17 1980s 30:21 1988 5:10 2 22 116:22; 117:5, 6 27th 106:9 29th 112:3 3 340 114:2 350 108:4 359 114:2,7 367 1 07:11 422 113:4,11, 14, 16 424 110:1 428 112:14 5 517 113:1 6 63124 5:6 7 709 113:20 9 9 110:4 970 113:18 979 71:l6;72:7; 84:17 A ability 11:8 absence 58:17; 89:7; 115:15; 116:10 absorbed 73:8,12, 16, 21, 25; 76:5,9; 77:4,10,15; 78:1,13, 17; 97:16 absorbtion 73:14,19 accidents 89:18 accomodate 5:3 accumulated 37:24 accurate 19:25; 106:12; 107:19; 108:16 accurately 103:12 acne 66:23;88:25; 89:12; 90:8,9 acne-like 114:14, 19; 115:10 acquisitions 36:25 Act 92:23 action 76:15;99:24; 100:7, 13,15, 16, 21; 101:2 activities 110:24 Actually 62:16; 108:5 acute 16:14; 63:14; 96:14 address 5:5 addressed 28:20; 37:1; 52:8,11 adipose 94:7 adjacent 23:6 administrative 27:10 administratively 25:23 administrator 23:16 admit 113:17 advised 70:14; 93:13 advising 97:2 afternoon 5:2 Ag 75:18 again 7:4; 35:2,19; 37:10; 40:5;42:13; 45:13; 51:4; 89:3; 96:25; 100:4; 105:22 against 4:12 age 4:2 agencies 103:7 Agency 92:7,13 ago 4:9; 20:1; 29:7; 31:17; 57:14; 67:17; 107:13 agree 54:15; 98:15; 99:19; 109:3,6; 114:13, 20, 24 agreed 103:6 agreement 76:15 ahead 9:14; 20:22; 45:20 air 66:15 alkaline 62:10 alleged 65:22,22; 66:10,23; 67:19; 79:14 allowed 98:22 Almost 88:17; 94:9; 108:8 along 108:10; 115:2; 116:6 already 33:22; 70:8, 10, 21; 77:7; 78:6; 83:10,11; 87:7,19; 89:8; 113:13 always 50:6; 57:16; 58:1 Americans 94:5 among 114:21; 115:22 animal 92:11;94:24; 96:16,17; 117:11,16 animals 16:16,22; 95:15, 19; 102:12, 14 anybody 89:14 anyhow 113:13 anymore 45:6 anyone 26:3; 35:22; 40:9; 54:22; 55:2,9, 13; 56:6,11; 65:21; 77:8; 79:1,8,12,21; 80:1; 85:19; 102:1, 20, 21, 23 anywhere 29:24 apparel 69:19; 70:17; 71:12 Apparently 111:15 appear 20:11 appearing 30:2 applied 59:17 appointment 58:22; 59:4,4,10, 15, 18 appreciate 108:24 appropriate 34:9, 11; 108:22 April 108:9 area 7:6; 18:10; 21:25; 22:22 areas 43:22; 44:5 Aroclor 41:14,19; 42:19; 43:5,9; 44:9, 12,15 Aroclors 60:9,11, 15; 99:8, 13 aromatic 16:9 around 22:23; 25:18; 90:8; 102:8 artery 13:19 article 46:7; 117:6,7 articles 46:10,13, 17,21 assessment 111:2 assignment 40:15 Assistant 11:21 Associate 14:2,7; 18:3; 24:2,6; 25:1,5, 5; 41:17; 56:2; 101:15 associated 11:8,15, 17; 90:6 association 79:14 assume 4:23; 34:13 attachments 60:14 attempt 47:16 attend 5:13; 8:3; 52:17, 23; 53:3 attended 52:5,8,11, 13, 20, 21 attorney 4:17; 30:4, 5 attorneys 30:10 August 106:9; 112:3 authenticity 113:17 author 32:21 authority 25:1 aware 82:10; 99:24 away 6:8; 57:13; 64:15 B B-a-b-l-e-r 5:6 Babler 5:6 Bachelor's 5:15 Bachelors 6:19 back 6:17; 9:15; 10:5; 23:19; 27:2; 43:25; 45:1; 62:17; 66:5,9; 71:2; 77:20, 23; 81:3; 114:9 background 5:12; 59:16 basement 22:22; 23:5 basis 16:23 became 7:25; 10:18; 13:3, 5; 17:6; 26:16, 19; 40:8,14; 58:9; 105:19 become 13:4; 14:14; 90:23 began 5:18; 18:1,4, 7; 19:14; 20:8; 22:9; 24:16, 22; 25:14; 27:18,22; 39:9; 40:2; 42:16; 47:13, 22; 48:1,18; 56:13; 60:5; 68:15; 73:2, 5; 99:5, 23; 100:2,4,19; 101:1 beginning 5:12; 9:24; 47:10; 99:20 begins 117:11 behalf 4:4 believe 62:l6;98:9; 116:13,13 below 22:23; 99:8 Besides 24:12 best 20:7 Bethesda 8:14 beyond 93:9 Bible 27:6,12,15 bigger 64:14 billion 94:6 biodegrade 94:18 biomagnification 94:21 biomagnify 95:3 Biotest 101:21 biphenyl 66:25; 67:9; 91:5,6 biphenyls 28:16,20; 29:2; 34:14,18, 22; 35:6, 8, 23; 65:19 bit 54:19 blood 94:8; 115:7, 8 bodily 96:23; 97:8 book 32:13,14,17, 24; 46:3, 4 boss 17:6; 18:7 both 7:20; 23:8; 25:8; 58:13; 110:7 bottom 110:12; 114:10 BRADLEY 4:6,7; 7:5; 12:16; 15:6, 9; 20:2, 6; 22:16; 24:13, 16, 21; 27:4,17; 31:15,22, 25; 32:2, 8; 33:22; 34:2,9,11,13; 35:15,17, 20,21; 37:11; 39:18; 40:8; 41:12; 44:4,11; 45:14,20; 46:6, 9, 20; 47:11,13,16,22; 49:3, 15, 23; 51:5, 6; 53:3, 8; 54:2, 5, 8, 20; 55:23; 56:1, 3; 57:21, 24; 58:21; 61:8,12, 14,22; 2:16, 22; 63:3, 4, 21; 64:1, 9, 16; 66:2; 69:12,18; 70:12, 23; 71:1, 18, 20, 22, 25; 72:4, 6; 74:21; 77:19,23; 78:4, 10; 79:19,21; 81:9; 82:6, 25; 84:3, 5; 86:1; 87:9,13; 88:13,15; 89:9,13, 25; 90:2, 25; 91:12, 15; 92:4, 6; 93:5,11, 17; 95:25; 97:6; 98:3, 15; 99:1,11,12; 100:18,19; 101:16, 17; 102:24; 03:19; 104:15; 105:11; 106:4, 6; 110:22; 111:5, 6; 112:17,19, 21; 113:9,11,16,19; 115:20; 116:15 brain 88:8 branch 5:21 break 5:2; 72:1, 3 brought 4:12 Bruce 113:11 build 17:5, 21 building 19:8,11, 13,18, 22; 20:16,17, 18, 19; 22:7, 19, 20, 24; 23:20, 22, 23, 24 built 14:21; 17:1,15, 24; 25:18 burning 115:4; 116:8 business 74:9,16, 17, 20, 21, 25; 75:2, 3,9, 10, 16,18; 76:2, Concannon & Jaeger (314) 421-1000 Min-U-Script '3 - business WATER PCB-SD0000022940 George Roush, Jr. March 17, 1993 Nevada Power Company v. Monsanto Company, et at 4,8, 12, 19, 23, 25; 77:3,8, 13,24, 25; 78:2,3,4,11,15; 79:1,9,12, 22; 80:1, 6,14, 20, 25; 81:11, 16, 21, 22, 25; 83:1, 9, 14, 21, 24, 25; 84:5,11,17; 85:14, 20; 86:2,17,18, 25; 87:8, 23; 88:1; 89:10; 95:23; 107:25; 108:21; 110:24 businesses 75:17 12,15,22; 64:2,10; 66:6, 14; 79:4, 23; 80:3, 7,16, 21; 81:2, 17; 82:11, 21; 84:21; 88:8; 89:5, 23; 91:2, 21; 95:14; 99:16 caused 49:14,16; 50:18; 51:3; 63:25; 65:23; 88:11, 23; 91:5,21;93:2,4,13, 23 causes 62:4; 64:13, 17; 88:25; 90:7, 8 c causing 82:1; 88:25 chain 95:4 C 107:16 chance 106:6; 108:6; 110:2; 112:1; cabinet 38:12,16,19 113:22 cabinets 39:2 cables 114:25 Calandra 101.25; 102:4; 103:22; 108:10 call 62:9; 63:14; 85:7 called 7:14; 20:19; 30:23; 32:18; 64:17; 65:11; 67:3; 75:15, 24; 87:21; 98:16, 20; 102:17 came 18:23; 23:5; 26:2; 29:18; 35:12, 25; 51:10; 89:10 Campus 20:20 Can 22:18; 28:25; 31:18; 33:23; 40:4; 45:11,18, 21; 51:4, 16; 54:20, 22; 62:6; 73:8; 91:3; 95:1,6, 11; 97:3, 17 Cancer 8:13,17,19; 9:1, 24; 95:14; 103:5; 106:20 cancerous 109:16 cancers 109:20 capacitors 71:5 change 62:8,10; 63:12; 69:1,5 changed 20:l; 26:12 changing 69:11; 100:16 charge 24:24; 26:20; 27:24 chemical 53:18; 54:10,16 chemicals 15:20; 16:5, 7, 8; 29:15 chemistry 99:21 chemotherapy 8:24 Chicago 51:22,25; 52:1,17, 20, 23; 53:4, 25; 64:6 chloracne 48:23, 24; 49:2, 4,7,13,19, 25; 50:6,12,18; 51:3, 9; 64:17, 20; 67:16; 88:20, 23, 25; 89:5, 12,16,19, 23; 90:3, 5, 11, 15,18; 91:1, 2, 5,16, 21; 98:16, 20; 114:15, 20; 115:11; 116:1, 2 capitalized 62:11 chloracnia 115:21 carcinogen 92:8,14 carcinomas 109:13 cardiac 13:3,4, 5,5, 10, 12 cardiology 12:25; 13:2 careful 66:8 carry 76:21 case 29:9; 30:23; 31:2,14,16; 50:6; 90:22; 91:16 cases 66:23; B4:23; 85:21; 95:16 catheter 13:16,19 catheterization 13:11,12 catheterizations 13:6 cause 61:10,11, 18; 62:24; 63:5, 10,11, chlorinated 16:9; 34:18, 20,22, 23; 35:3, 5, 8,8; 65:19; 66:24; 67:9,11; 91:4, 6; 94:1; 114:22; 115:23 chlorine 60:13, 22 chlorobiphenyls 115:1; 116:6 chronic 16:12; 63:16, 22, 25; 64:2, 9, 21; 96:1, 4, 8,11,12, 19 Cincinnati 13:24; 14:1, 5, 12, 18 citing 115:17 claimed 53:17; 54:1 classified 92:13 classifies 92:7 clean 69:19 clear 4:20; 44:17; 89:1,4; 109:23 clinical 8:19; 18:16, 17,19; 23:25; 24:3; 25:7 Close 89:25 closely 83:19 clothes 69:10 clothing 68:15,17; 69:2,13; 70:15 coalescence 90:24 college 5:13,13,18; 6:1,4 coming 11:1; 15:21 comment 61:7 commercial 94:2 common 10: il; 63:12; 94:11 communicated 11:17; 98:12 companies 29:13; 30:15; 36:21; 71:8, 11; 73:21,25; 100:12, 20; 101:1,6, 10 Company 4:11; 11:9,12,18; 15:11; 55:2, 5; 58:4; 97:25; 100:24 compare 54:20 complete 45:2 completed 25:13; 53:25 completely 109:4, 10 completion 52:19; 103:5 completly 108:25 compound 99:20 compounds 95:7,11 comprehensive 44:14, 24, 25; 45:5 comprehensively 47:17 concentrations 96:2, 5, 20 concern 29:10 concerning 78:9 conclusion 96:3 condensers 115:1 condition 64:17; 90:12, 18 conducted 95:19; 97:20; 108:21; 110:24 confidentiality 31:16 confirming 76:18, 24 Congressional 99:24; 100:7,12,15, 16, 21; 101:2 considered 54:24 constituents 94:2 consultant 13:3, 5 consultation 28:6 consulting 42:8 contact 66:13; 70:22; 76:16 contacts 87:24 contained 60:23; 66:24; 67:8,11,24; 106:22 containing 16:2 contaminants 53:19; 54:10,16 contamination 29:10,14; 36:8,9,14, 16; 37:2; 39:6,14,22; 40:1, 20 content 60:22 context 36:1; 114:8 continue 98:22 continued 40:15; 105:3 continuing 16:23 Control 92:22 conversation 51:8 conversations 39:8 cooking 115:19 copied 112:6 copies 29:21 copy 78:18; 106:12; 108:16; 113:12, 13 Corp 5:22 corrected 31:7 corrections 31:10 correctly 89:24 correspondence 33:17,18 cough 62:4 Council 46:7 counsel 33:6,23; 41:10; 106:2; 110:20; 117:21 County 6:25 couple 16:11; 57:14 course 4:19 courses 14:10 Court 79:17; 81:4 covering 30:19 crux 34:6 current 91:24 customer 76:16,20; 93:21 customers 68:19, 20, 22; 70:13; 73:11; 75:4,7; 87:2, 4; 88:3; 89:2,4,9,15,22; 91:20; 93:1,8,13; 95:10, 20; 96:18,22; 97:2,7,11,15,19, 24; 98:7, 20; 100:6; 106:23; 107:4; 115:9, 21; 116:4,12,17; 117:16 D D-e-g-a-r-m-o 23:16 daily 69:2, 6 damage 64:13; 79:4, 10; 82:14 data 41:14,19; 42:18; 43:5,9; 44:12, 15; 48:4; 66:17; 68:17, 20, 25; 70:12; 71:11; 73:15; 77:17; 78:6,18, 25; 80:11, 13,18; 81:6,10; 92:11,11; 93:19,20; 94:10; 103:6 date 27:18; 50:10; 105:3, 8; 106:13 dated 103:8; 107:17; 117:6 dates 104:20; 105:17 David 107:16; 112:4 day 26:13 days 16:12 Dear 108:24 December 26:15; 40:9; 107:17 decisions 28:1,4 defined 78:7 definition 25:11; 114:19 Degarmo 23:15 Degree 5:15; 6:6,8, 9,11,13,15,18,19; 7:13; 8:21; 11:1; 37:15; 59:21; 73:10 degrees 7:22; 90:15; 99:9 denominated 60:18, 21 department 18:14; 19:11,14,17, 22, 24; 20:8; 21:23; 22:12; 23:23; 26:17,19,23; 27:5; 28:5, 6; 38:6; 40:10; 41:4, 17,18; 42:16, 18; 46:14,21; 48:2,8,10; 50:24; 51:2;55:17; 56:5,10; 57:17; 58:2,10; 72:13, 25; 74:3, 6, 8; 75:15, 20, 23; 76:2, 4, 8,12,22, 24; 77:9, 14,24, 25; 78:3; 80:25; 81:12,15; 6:9, 14,17; 88:1, 2; 104:7, 9 department's 81:19 departments 19:10, 13; 84:13 deposes 4:3 deposition 4:19; 5:11; 20:3, 4; 22:15, 18; 28:9,11,14,19; 29:1,6, 9,19; 30:1,6, 17, 20, 25; 31:5, 8, 13, 18, 20; 32:6,9, 15; 33:1, 25; 113:15 depositions 28:23; 29:22; 30:19; 32:3 describe 5:12;7:10; 18:13; 45:8; 71:12; 80:12; 90:17 described 63:11; 64:14; 81:1; 86:22; 95:5, 9; 96:7 describing 93:2 destroy 99:13 destroying 99:8 detail 69:9 determination 26:9 determine 45:5; 67:24; 112:22, 22 developed 67:16 diagram 19:21; 22:17 dibenzylfuran 53:9, 11,15 dibenzylfurans 53:18; 54:10,16,21, 24 dicussion 117:21 died 67:20 difference 35:2; 88:19; 89:12; 90:3 different 29:12; 30:15; 60:11,13; 84:6; 90:14; 103:20 difficulty 97:3 digestive 115:3; 116:7 digits 60:20 dioxins 45:25 diphenyl 53:12 diphenyls 34:20,23; 35:3,9 DIRECT 4:5; 85:7 direction 31:21 directly 8:22; 23:5; 26:3; 78:24 Director 18:3,4; 24:2, 6; 25:1, 5,6; 26:16,19, 23; 27:5; 28:5; 33:4; 40:9,14; 41:13,17,17; 55:22; 56:2; 87:21; 101:15 disability 11:16 disabling 96:24; 97:8 disappeared 87:20 discharge 114:16; 115:12 discuss 26:9; 35:22; 37:4; 38:4; 59:7 discussed 37:8 discussion 35:18; 41:10; 46:23; 59:12, 13; 65:18; 76:23; 77:1; 78:9; 103:4, 21; 106:2; 110:20 discussions 39:5, 13, 21; 47:23; 56:24; 64:25; 76:17 disease 98:16, 20 businesses - disease Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022941 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17,1993 distinctive 114:17; 115:13 disturbances 115:3; 116:7 division 75:20, 23 doctor 6:16;8:1; 12:7,10; 14:15; 21:14; 88:19; 90:2; 96:8; 112:14 document 42:18; 43:4; 66:4,12; 71:19, 22; 72:9, 12, 21; 76:7, 21; 80:24; 85:25; 89:21; 103:2,10,12, 14; 106:15; 107:12, 22; 108:5,13,17, 19; 110:2, 9, 22; 111:8; 112:10,15,23; 113:2, 5,21,24; 114:4; 117:3 documents 33:3,8, 15,19, 24; 45:9,15; 48:7; 57:5; 80:5,10, 14, 19; 81:14; 84:16; 89:14; 91:19; 98:6; 99:4; 114:4 Don 111:16,17 done 20:14; 25:12; 45:7; 79:5; 103:23 door 23:6 dose 64:14; 96:15 down 22:22; 110:13 Dr 4:7; 17:7; 18:6,7, 18; 21:5, 6,9; 23:15; 25:21; 26:6, 13,20, 23; 27:12,15; 33:21; 34:13; 37:25; 42:11; 44:5;45:10; 46:1; 47:12, 23:56:13,20; 57:4,4,7; 64:25; 65:14, 17, 21; 68:1; 72:6; 98:10; 101:25; 102:3; 103:3; 104:13, 15, 18,21,23, 24, 25; 105:2,11,21,22; 107:1; 111:15; 117:6, 7 draw 22:3,11 drawer 38:15 drawings 20:11 drawn 20:6 duly 4:2 during 4:19; 5:1; 11:21, 25; 15:25; 28:14; 31:5; 41:12, 16; 47:18; 48:9; 53:21; 55:1,4, 8,12, 15, 20; 56:3,8,19; 57:3,15, 24, 25; 61:8; 66:21; 67:2,14,18, 22; 68:10, 13; 69:4, 20; 71:3; 75:10; 80:23; 81:13; 83:4; 84:10,15; 95:19; 111:12 duties 58:20 E E 110:5 each 75:17 earlier 25:18 early 30:21;65:23; 85:12 eating 115:18 edema 115:3; 116:7 education 5:17 educational 5:12 effect 63:13; 64:15; 65:9,11; 79:6; 93:10; 96:17 effects 62:8,9; 63:14,16,22, 25; 64:3,10; 79:15; 81:8; 96:14; 114:14; 115:2, 10; 116:7; 117:17 eggshells 82:16, 21 eight 99:8; 117:13, 18 eighteen 56:18,19; 57:3 either 112:20 Electric 4:13; 55:5, 9,18; 56:6; 66:22; 68:22; 71:3, 8,11; 73:20; 100:12,20, 24, 25; 101:6, 10,14 else 12:3; 24:8; 26:3; 32:25; 48:5; 54:22; 61:24; 65:21; 69:19; 78:21; 101:8; 102:1, 23 employed 5:7; 45:16; 48:9; 49:25; 53:22; 55:4,8,12,15, 24; 56:8; 57:15,25; 61:9; 66:21; 67:22; 68:10,14; 69:4; 71:3; 81:14; 82:19; 98:4; 99:2; 100:3; 101:17 employee 48:12; 49:4,7; 51:2; 68:8; 105:3, 12, 14, 18, 19 employees 66:22; 69:1,13; 101:18; 110:7 employment 8:12; 42:16; 47:14; 48:19; 60:6; 73:3; 93:1,12; 98:8; 99:5; 100:2, 5 end 9:12; 47:10; 116:21; 117:3 ended 9:3 enough 4:24;89:25; 96:15 entitle 15:14 entitled 107:14 entry 20:16; 23:3 environment 36:12; 80:3, 21; 81:17; 82:1, 11, 15 Environmental 36:8,9,14; 37:1; 39:6,13, 22; 40:1, 20; 92:7, 13 environments 83:6 enzymes 62:9 EPA 52:2; 109:22 epidemiologists 106:25 episode 48:23,24; 49:1,3, 7,10,13,19, 24; 50:5,12,17; 51:3, 8,21 eruption 115:11 eruptions 114:15 essentially 12:18 estimate 20:7; 28:19 estimation 44:8 even 29:20; 98:9 eventually 17:21 everyone 87:16,16 everything 54:6 EXAMINATION 4:5; 21:17 examinations 24:3; 97:20 examining 23:18, 19, 24 example 60:15 except 93:9; 96:16 excessive 114:16; 115:12 exclusively 73:6 Excuse 43:7; 57:21; 65:22;72:17; 81:1; 89:3; 90:14; 100:3; 104:18; 112:4 Exhibit 20:3,4,15; 22:13,15, 18; 23:1; 71:16; 72:7; 84:17; 103:1,2; 106:5,23; 107:11; 108:4; 110:1; 111:20, 25; 112:14, 25; 113:4,20; 114:7; 117:18 exhibits 113:17,18; 114:1 exist 60:5 expect 111:9 experiencing 91:16 experimental 95:15, 18 Explain 20:14; 23:2; 56:20; 76:14; 90:3 exposed 67:15; 97:21; 114:22, 24; 115:22; 116:5 exposure 65:2; 66:10,13,15,24; 67:20; 89:17, 22,23; 91:4,17; 93:3,13, 23; 96:5; 98:21 exposures 96:1,19, 23; 97:7 extra 23:20 extremely 99:20 eye 114:16; 115:12 eyelids 114:16; 115:12 eyes 61:23; 62:7; 115:4; 116:8 F F.R 66:18 face 114:21; 115:3, 22, 25; 116:8 facility 23:25 fact 17:15; 54:10; 87:22 faculty 10:18,24; 11:19 Fair 4:23; 106:12; 107:3, 6,19; 108:16 fairly 103:12 familiar 60:2; 65:5; 82:6; 94:20 far 116:16 fat 94:8 fatal 96:24; 97:9 FEATHERSTONE 12:13; 15:5; 27:1,15; 31:15; 33:21; 34:8; 39:16; 41:9; 43:24; 44:3,10; 46:1, 5,19; 47:12, 20; 49:11,21; 50:3; 52:25; 53:6; 54:1,17; 57:18; 58:17; 61:6,19; 62:12,14,19; 63:1, 19, 23; 64:4,11, 22; 65:24; 69:7,14; 70:8, 10, 20; 71:18; 74:20; 78:2, 5; 79:16; 81:3; 82:2,4, 22; 85:22; 87:6; 9:6, 20; 90:19; 91:11; 93:4, 6,15; 95:21; 96:25; 97:13, 22; 98:10,14,23; 100:14; 101:13; 103:15; 104:13; 105:5,7; 110:18,25; 111:3; 113:6,14; 115:14; 116:10; 117:20 FEATHESTONE 70:24 fellowship 8:10,19, 20,25; 9:3; 12:25; 13:1 fetus 94:16 few 4:8; 23:7 field 10:20; 37:9 fifteen 34:12; 45:15; 47:12 figure 40:23 file 37:23,24; 38:12, 15,19; 39:2; 46:10; 72:13; 73:3,6 files 106:16; 107:23; 108:20; 110:23; 111:4, 6,9 find 34:9; 83:20 finding 36:11 findings 25:13; 103:4 finish 9:18; 10:6 finished 9:13,17; 10:8, 16 first 4:2; 5:25; 19:19, 21,23; 24:16; 35:11, 13, 14,18, 21; 36:1; 38:3; 48:16, 18,22, 23, 24; 49:1,3,7,10, 19, 24; 50:12,17,17; 51:2,8, 20; 53:14; 54:11; 61:14,16; 62:23,24; 63:7; 71:21; 91:15; 100:10; 104:3; 105:18; 108:6, 23 fit 19:5 Five 28:21,22; 29:7; 47:4; 72:1; 94:6; 114:8, 11; 116:25 floor 19:17,19,21, 23 folks 74:11 follicles 114:17; 115:13 followed 76:17, 23 following 12:17; 14:17; 65:2 follows 4:4 food 95:4 forearm 13:16 forgotten 15:4 form 44:3,10; 46:19; 47:20; 49:11,21; 50:3; 52:25; 53:6,7; 61:19; 63:1,19,23; 64:4,11, 22; 65:24; 66:17; 69:7; 82:22, 23; 85:16, 22; 87:6; 91:11:93:6,15; 95:21; 99:17; 100:17; 103:15; 110:25 formal 21:24 former 92:1 found 36:17;83:5; 94:12 foundation 54:18; 58:18; 69:8,15; 87:7; 89:7; 97:1,23 four 10:11,13; 29:12; 30:15,18; 38:15; 58:3; 110:11; 114:9; 116:19 Francisco 30:20; 31:25 Frederick 106:10 fresh 68:15,17; 69:22, 23, 25; 70:2,4, 6, 7,14,17; 71:12 full 108:23; 116:20 full-time 24:4 fully 108:24 function 13:21; 62:9; 63:13 functional 25:23 functioned 24:20 functioning 13:15 functions 25:8 furan 48:14;49:18; 50:9 furans 45:25; 49:10, 16,17, 24; 50:9,18; 51:1,3,7,8,10,13; 52:11; 54:12; 99:17, 19 G G 22:20, 24; 23:22 Garrett 23:11; 58:8, 9,11,14, 22, 25; 59:1, 13,19 Garrett's 59:16 gave 30:19; 31:1,6, 9; 32:3; 43:14; 70:13; 71:13, 14; 93:7, 21; 101:5; 106:24; 107:1, 9 GE 68:25; 70:13; 71:7 gear 69:22, 23, 25 General 4:13; 52:12; 55:9; 56:6; 66:22; 68:5, 22; 71:3 generally 31:18 generated 33:4; 80:5, 19, 24; 81:9,15; 93:12 generations 95:1 gentleman 103:25 GEORGE 4:1; 19:2; 24:24; 108:24 gets 90:7 GGTP 62:11 Gl 65:13 given 29:22; 31:21; 37:22; 52:14; 68:18, 20; 84:17; 85:13,16; 87:23; 96:13,14; 98:7; 106:23 giving 31:23; 96:13 glands 90:6 gloves 69:23;70:7, 8,10; 73:13,15,19 goes 13:20; 94:25; 117:13 good 43:20;45:22; 46:8 governed 31:16 Government 92:22; 101:8 grab 72:17 graduate 59:21 graduated 8:6 graduation 8:11 Concannon & Jaeger (314) 421-1000 Min-U-Script distinctive - graduation WATER PCB-SD0000022942 George Roush, Jr. March 17, 1993 Nevada Power Company v Monsanto Company, et al. ground 22:23 group 23:10;74:9, 16, 17, 20,21,25; 75:3,9,10,16,18, 19; 76:4,8,12,19, 23, 25; 77:3; 78:3,4, 12,15; 79:1,9, 12, 22; 80:1,6,15, 20, 25; 81:11,16,21,22, 25; 83:1,9, 14,21, 24, 25; 84:5,11,17; 85:14, 20; 86:2,18, 25; 87:8,23; 88:1,2; 89:10 guess 20:3 guessing 83:17 H hadn't 44:6; 88:6 hair 114:17; 115:13 half 19:19 hall 20:16 Halowax 67:4,6,15, 20, 24; 68:1 hand 19:20 handling 74:24 hands 115:4; 116:8 happen 98:3; 99:1 happened 85:9,11; 89:19; 99:5 happens 91:10,10, 12, 14; 96:21 happy 72:1 Hard 113:9 harm 61:10,12,17; 62:24; 63:5,9; 65:23; 66:6,10; 79:23; 80:3, 7, 16, 21; 81:2, 17; 82:1, 11; 93:2, 23 harmful 64:2; 79:15 hasn't 115:19 haven't 88:5;91:23; 111:23; 112:20; 113:8 hazards 11:8;76:13; 78:7 head 23:12; 28:5; 38:11;40:17,24; 55:16; 56:4,9; 57:16, 21; 58:1,9, 19, 22; 59:1,11; 105:6, 8 headed 18:21; 75:10 headquarters 102:6,9,15 Health 7:13,14,17, 18; 8:4, 21; 10:19, 20, 21, 24; 11:20; 61:10, 12,18; 62:25; 63:5, 10,16, 22; 64:3, 10; 76:13; 79:15,24; 80:8,16; 81:2, 8; 93:2 hear 35:11; 36:1; 43:24; 49:20, 23; 50:2, 17; 51:20; 61:9, 14, 17, 24; 62:20, 23, 23;79:16;81:3; 83:14; 90:19; 102:17 heard 34:14;48:14, 17, 21; 49:18; 51:1, 7; 53:8,15; 61:16; 62:12,14, 24; 65:14; 66:18; 82:24; 89:14, 21; 95:5; 96:7 hearings 92:22 heart 13:13,14,15, 17,18, 20; 65:12 heart's 13:21 held 41:10; 106:2; 110:20; 117:21 Help 9:23; 42:13; 52:24; 53:4 helped 87:22 Helping 11:14 hema 115:7 hematuria 115:4,6; 116:9 highly 97:12 hire 23:20; 104:21 hired 104:23 history 12:14 home 32:13 Hospital 6:25;7:1; 9:4, 7; 10:3 housed 19:7,14 Houston 29:4;30:6, 17; 31:9 Huh 70:9 human 61:10,12, 18; 62:24; 63:5,10, 16, 22; 64:3,10; 79:15, 23; 80:8,16; 81:2,8; 92:8,11,14; 93:2; 94:13; 95:4; 114:11; 116:21 humans 114:14; 115:10 hundred 94:6; 99:9 hydrocarbons 16:9; 114:22; 115:23 hygiene 18:21; 21:21; 23:11,17; 38:11;40:18, 24; 57:22; 58:1,10,16, 19, 23; 59:11,22, 25; 74:3 hygienists 18:22 hyperplastic 109:12 I IBT 33:14,16,19; 34:4; 52:14,16,18; 79:6; 102:6,9,14, 22, 23; 103:5,21,24; 104:16, 17, 25 identification 20:5; 22:15; 71:16; 107:11; 108:4 identified 57:19; 89:8 identify 33:24 identifying 20:12 ill 96:16 Illinois 107:15 immune 95:8,12 impairing 95:7,12 important 111:2 impotence 115:4; 116:8 impression 54:19 impressions 43:12 incinerated 99:13, 16 include 44:6; 69:23, 25; 114:14; 115:10 included 11:7; 43:23; 44:6; 75:3; 78:8 Including 29:16; 56:1; 70:20 increase 95:2 indicate 19:23; 37:18; 43:21; 44:5; 49:15; 64:20; 65:1,2; 66:9; 79:2,9,13, 22; 80:2, 14 indicated 17:4; 25:18; 38:12; 49:18; 64:2; 77:10, 15, 24; 78:11,12,16; 80:7; 81:1,16; 82:20; 84:16; 93:23; 112:7 indicates 80:21 indicating 84:20; 88:8,11, 22; 91:20; 98:6; 99:4; 113:21 indication 98:16,21 industrial 18:21,22; 21:21; 23:11,17; 38:11; 40:17, 24; 57:22; 58:1,10,15, 19,22; 59:11,21,25; 74:2; 101:21 industry 11:6 inform 71:11;73:20; 76:2, 4; 86:25; 87:4; 89:2,4; 95:10; 97:6, 11,15,19; 100:20, 25; 115:9 information 28:15; 37:21; 71:13; 76:12; 83:1,8; 85:13; 98:7; 101:6; 106:22; 107:4; 112:9 informed 73:24; 85:24; 86:1, 4; 98:19; 100:6,11 informing 28:7,8; 97:24 infrequent 82:18; 91:7, 9 infrequently 91:13 inhalation 66:13 Injuries 88:12 injury 11:16; 88:11, 15; 96:24; 97:8; 98:17, 21 inside 13:18 instance 50:6 instead 96:13,14 Institute 8:13,18; 9:1,24 institutions 7:23 Instructor 12:5 insulating 114:25 insure 71:2 interdepartment 110:4 interdepartmental 106:13; 112:3 interested 33:8; 45:14; 51:6; 54:8; 111:21 interim 6:17 intern 6:22, 24 Internal 9:11,17,18; 12:4; 46:23; 96:23; 97:8; 106:10 internally 97:12,17 interpret 25:12 interpretation 103:17,19; 109:11, 13 interrupted 5:17 into 5:19; 13:17; 19:6; 20:16; 23:6; 73:16; 78:17; 90:7 introduced 4:8 Investment 52:22, 24; 53:5 involved 27:25; 29:13 involves 65:10 irritant 6l:21;62:3; 93:8 irritating 97:16 irritation 61:25; 62:2, 6; 63:11; 88:18, 20; 90:4,12 Island 9:4,6; 10:2 issue 98:10,11 J J.C 108:10 Jack 23:11; 58:8,9 January 103:8 Japan 115:17 Jensen 82:7 job 14:22; 18:1; 24:1, 5,11,14; 27:8, 22; 43:20; 87:8, 8 Johannsen 106:10 joined 48:25; 53:13; 54:3; 58:4; 62:15; 64:7, 7; 77:6; 97:24; 104:4, 17; 105:2 joining 105:1 JR 4:1 Judith 107:16 K K-a-i-m-e-r 66:19 Kaimer 66:18 keep 36:22; 37:5,9, 13,19; 111:6,9 Keeping 36:16,18, 19 Kelly 17:7; 18:6,7, 18; 21:5, 6,9; 25:4; 26:6,13:47:23; 56:14, 20,23; 57:4,4; 65:17 kept 29:24; 38:13; 41:1; 102:12,14; 111:4 kidneys 65:13 kids 90:8 Kimbrell 45:24 Kimbrough 103:24; 117:6 kind 9:9; 15:20; 24:9; 25:9; 61:17; 63:9; 64:9, 20; 88:15 kinds 56:24 knew 15:24; 51:10; 56:20; 59:8, 8, 9,17, 24; 71:4, 7; 77:7,10, 15, 25; 78:13,16,24; 79:3,10,13, 23; 80:3, 7,15; 83:10,11,13; 84:25; 87:16, 23; 99:15; 101:7,10 knowing 33:8; 45:14; 51:6; 54:9; 111:21 knowledge 55:7; 59:7; 69:16; 82:5; 91:22; 98:24; 115:15; 116:11 knowlege64:7 known 34:16,18, 20; 35:3, 5; 60:3,8; 66:5; 114:13; 115:10 L lab 15:3,17; 16:24; 17:5,15, 22; 25:15, 17,18; 101:19 Laboratories 101:22 laboratory 14:21; 15:2; 17:2 labs 102:22 lack 54:17; 69:8,14; 97:22; 98:23 Lane 5:6 largely 90:6 last 28:25;35:2; 77:20; 90:13; 116:21 lasting 64:15 Late 30:22;85:12; 92:19 lawful 4:2 lawsuit 4:12 layout 18:13; 20:7; 22:12 learn 49:1; 53:1,1, 21,24; 63:7, 9,15, 18, 21; 64:1, 10,16, 19; 66:22; 67:3,15, 19, 23; 68:1; 81:25; 83:5; 85:3; 104:3 learned 50:8; 54:6, 9,12; 63:5; 64:6,8; 85:5; 86:22; 87:1,5; 88:3, 5, 6 least 29:1,18; 41:7; 52:23; 53:24; 67:19; 72:7; 86:21; 98:3; 99:1; 110:3 leather 73:13 leave 76:20; 104:12 led 52:16 left 13:22; 15:10; 16:24; 22:6; 56:25 left-hand 110:12 leg 13:19 lesion 90:24; 114:19 lesions 95:17; 109:19; 115:2,24; 116:6 letter 85:17; 108:9 letters 32:12;76:18, 24 levels 51:11, 13; 62:9 Levinskas 19:2; 24:24; 25:2, 3,21; 26:7, 20, 24; 41:22; 42:11; 43:13; 44:5; 45:10; 58:13; 59:14; 64:25; 65:21; 68:1; 104:8, 24 Lewis 65:14 library 19:5; 21:23; 22:1,9; 23:14; 36:25; 46:14, 22; 72:25; 81:23 license 12:6; 15:13, 14 licensed 7:25; 12:9; 14:14, 16 Lieutenant 5:25 life 95:1 lightly 110:3 limiting 66:15 literature 36:17,20, 23; 37:5,9,14,19; 47:17; 88:24; 91:25; 92:1 little 54:19 liver 62:8,9; 63:12; 64:13; 65:12,23; 66:6,11,14; 79:4,7, 10; 93:10, 14, 24; 95:14 ground - liver Min-U-Script Concannon. & Jaeger (314) 421-1000 WATER PCB-SD0000022943 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17,1993 living 57:11 located 23:15 long 8:3, 25; 9:6; 11:19, 23; 14:4; 15:3; 19:25; 39:17; 48:25; 67:17; 107:13 longer 27:12; 90:13 look45:l;113:6; 114:9 looking 72:16 lot 64:7; 88:24 Louis 5:6 Louisville 12:20,24; 13:2, 9, 23 low 99:16 lower 96:15; 99:7,8, 10 lungs 65:12 M M-u-s-c-h 107:16 Mabube 107:1 maintain 29:21; 81:22; 110:23 maintained 23:23; 72:12; 106:16; 107:23; 108:20 maintaining lli:il major 13:16, 19; 25:8 making 59:4 malignant 84:21; 85:6, 21; 86:23; 87:1, 5,19; 88:3; 109:16, 19 man 11:16; 17:6; 24:4; 81:11; 102:2 man's 11:8 management 11:18 manufacture 68:11; 99:25; 100:7, 13, 22; 101:3; 115:1; 116:5 manufactured 15:23; 60:8; 94:2 manufacturing 68:14; 69:21 many 20:l;28:ll, 19;47:1; 56:l6;60:l; 109:1,6 Marine 9:4,6; 10:2; 83:5 mark 71:15; 107:10 marked 20:2,4; 22:14, 16; 108:3 Market 30:23; 31:1, 13 marketing 74:11, 18, 22; 75:1; 84:7, 8, 12 markings 23:1 Marquette 7:1 Masters 7:14,15; 8:20 material 90:7; 92:25; 93:11;94:25; 96:12 materials 32:5,8, 11; 38:13; 48:3,11; 66:24; 72:18 matter 29:1,19; 31:12; 40:11; 45:17; 47:18, 24; 48:3; 52:8, 11; 55:18; 58:11,15; 76:25 may 12:22; 63:12, 13; 64:2; 67:20; 68:6; 79:16; 81:2, 3, 17; 82:11,21;84:21; 88:8,11,23:89:5,16, 16; 90:19; 92:4; 96:1, 4, 19, 23, 24; 97:7, 8 maybe 64:15, 15 McNicholas 34:10 mean 12:13; 25:25; 39:1; 43:1; 47:9; 52:19,21:58:4; 65:8; 70:22; 82:14; 87:18; 91:10, 12; 99:8 meaning 70:21 means 40:23; 51:11, 15,19; 65:9; 69:10 meant 49:4 measure 13:17 Medical 6:12,15; 7:3,15, 25; 12:7,9; 14:14,19, 20,23; 15:1,7, 10, 18, 22; 16:1, 4; 18:3, 4, 10, 14; 19:10, 14, 17, 22, 23; 20:8; 21:23; 22:12; 23:23; 24:2, 6; 25:1,6; 26:16, 19, 23; 27:5; 28:4; 33:4; 38:6; 40:9, 10, 14; 41:4,13,16,18; 42:16,17; 46:14,21; 48:2,8,10; 50:24; 51:1; 55:17, 22; 56:5, 10; 7:17; 58:2, 10; 72:13, 25; 74:3,5; 76:2,4,8, 11,22,24; 80:24; 81:12,15,19; 86:8,14; 87:21; 88:1; 97:21; 101:15; 104:9 medically 90:11,17 medicine 7:6,9,11, 14,19; 8:21; 9:5,9, 11, 17,19,10:22; 11:2, 4, 5, 7,9,12, 22; 12:1,4, 5; 14:3,8, 9,11, 24; 15:13,16 meet 35:22; 58:25; 59:3;86:8; 101:24; 102:1 meeting 52:9; 59:10; 86:14, 17; 102:3,6; 103:13; 108:11, 12, 25; 109:3, 7,9 melanoma 85:21; 87:19; 88:3; 92:18 melanomas 84:21; 85:6; 86:23; 87:1, 5 member 83:25 members 83:23 memo 110:5 memorandum 106:10, 13 met 36:6,14; 37:25; 38:3; 43:15; 59:6; 86:7 Mice 16:20 might 49:16; 50:18; 51:3:61:9,11,17; 62:24; 63:5,10,15; 64:10,20; 66:6,10, 14; 79:4,10, 23; 80:3, 7,15,21;99:24; 100:6, 13,15,21; 101:2 military 5:19,21,24; 6:2 milk 94:13, 17 Milwaukee 6:25, 25 mine 10:14, 21 minute 34:12;72:1, 5; 100:14 mixed 10:14 mixture 94:2 Mobile 87:21 moment 9:23 moments 4:8 Monsanto 4:12; 15:11,23, 24; 16:25; 17:4,11,14,15; 18:2, 5,8, 11,14, 19; 20:8, 20; 21:23; 24:23; 25:14; 26:12,17; 28:2; 29:12; 33:4; 35:12,13, 18, 22; 40:2; 42:7, 8; 45:16; 47:14,19, 23; 48:1,9, 12,19, 25; 49:4,7, 25; 50:11, 22; 52:18; 53:22; 54:3; 55:1,4, 8,12,16, 24; 56:4, 5, 9,10,13; 57:16,17, 25; 8:2; 59:17,25; 60:2, 6, 8; 61:9; 66:4, 5, 21; 67:2,14,18, 23, 23; 68:8,11,11, 13,15; 69:5,12,19, 21, 21; 70:22, 23,25; 71:1,4,10; 72:20, 22; 73:2,5,6,11,20; 75:6, 11, 15,21; 76:20; 77:6, 9,14; 78:12; 79:2, 5, 9,12, 22; 80:2, 6, 15, 20, 23, 25; 81:14; 82:20; 83:1,4, 21; 84:6, 11, 12,15,18; 85:14, 20; 86:2; 7:2, 4; 88:2; 89:2,4, 9, 13,15,22; 91:20; 92:25; 93:1, 12, 21; 94:3; 95:10, 19,23; 96:18,22; 97:6,11,15,19, 24; 98:4,7, 8,12, 19; 99:13,15, 23; 100:2, 3,5,5,11,11,20, 20, 25; 101:1, 5,8,15, 18, 18; 102:20,21, 23; 104:4, 12,19; 105:1,2,3,12,14, 18,19, 23; 106:16, 19,23; 107:4,15, 23; 108:1,20; 10:7, 23; 111:11,16,18; 115:9, 20; 116:4,11, 16; 117:15, 16 Monsanto's 46:14, 21; 51:2; 53:4;72:13; 76:3, 4,11; 78:15,15; 81:15,16; 86:8, 25; 87:23, 25; 88:1, 2 month 42:15:56:19; 96:17 months 56:16,18; 57:3 more 17:2,5; 25:23; 28:8; 37:21; 38:18; 44:21; 47:3, 6; 54:24; 64:14,20; 76:3; 86:16; 90:11,13; 98:16, 21 Mortalities 107:14 most 99:20 mother's 94:13,16 move 22:24; 61:6 moved 22:12,19; 23:22 moving 22:19 much 93:9 Musch 107:16 must 52:5; 112:11 nagging 109:1, 6,18 nails 114:15; 115:12 name 4:7; 29:3; 32:17; 65:14; 66:16; 84:2; 102:2; 103:25; 110:12; 111:16 name's 112:11 names 20:12; 30:9, 12, 14 Napthalene 67:11 Napthalenes 72:16, 19; 73:3, 6; 94:1 National 8:13,17, 25; 9:24; 46:7 nationally 26:7 nearly 94:5 necessary 98:9 neck 114:21; 115:22 need 34:9;71:12; 78:21; 113:11 needed 25:12; 31:10; 75:4,7 needs 11:6; 17:2, 5 neoplastic 95:17 nervous 63:13 Nevada 4:11; 55:2 New 14:19; 54:6,7 next 21:1,5,12; 23:10, 11; 26:2 NIH 10:15 nineteen 56:18,19; 57:3 NIOSH 103:17 nodules 90:23; 109:11, 12 Nor 54:22 normally 26:5; 76:11 note 113:12 nothing 4:3; 33:2; 41:1 number 16:8,10; 20:5; 22:15; 39:1; 114:20; 115:21 numbers 60:11 o Object 44:3,10; 46:19; 47:20; 49:11, 21; 52:25; 53:6; 54:17; 58:17; 61:19; 63:1,19, 23; 64:4,11, 22; 65:24; 69:7,8; 82:22; 85:22; 87:6; 91:11; 93:6,15; 95:21; 96:25; 97:22; 100:16; 103:15; 110:25 objection 50:3; 69:14; 82:2; 89:6; 98:23; 115:14; 116:10 objections 97:13 observe 101:18; 102:11 obtain 7:2; 8:12 obtained 10:10; 12:6 occasions 28:15; 32:3 Occupational 7:9, 11,14; 8:21; 10:22; 11:2,4, 5, 7,9,12, 22; 12:1; 14:2, 8, 9, 11 occur 28:23; 37:16; 96:1, 5, 19; 102:6 off 12:22; 41:9,10; 71:2; 100:15; 106:1, 2; 110:18, 20; 117:20, 21 office 18:10; 23:6; 36:2 oil 115:19 omitted 43:22 one 4:8; 9:2,8,20, 24; 10:3; 12:25; 13:14,16; 17:2; 18:16, 17,19,22; 19:11,17; 20:3,5,15; 22:13; 23:7; 29:3; 30:23; 31:1,1,13; 34:4; 35:2; 38:18; 41:3; 46:8; 50:6,6; 53:13; 59:1; 62:4; 65:10; 67:19; 75:17, 18; 76:21; 81:3; 82:17; 83:23; 84:22; 86:16; 90:22, 23; 94:24; 99:19; 101:8 ones 74:14 only 12:1; 41:3; 81:6; 88:17; 90:9; 92:10, 11; 114:18 open 21:3 opening 21:14 operation 19:16 operations 24:10 opinion 44:11 opportunity 72:7 opposed 26:6; 62:21 orally 43:11; 86:22 order 31:17 organ 65:10 organism 96:13 organization 24:19 Orleans 14:19 out 5:23; 6:1; 28:18; 30:20; 33:11; 34:9; 37:23; 40:23; 44:21; 52:14; 66:7; 83:20; 95:16, 23 outside 13:18 over 16:12; 22:20; 36:2; 39:4; 45:15; 58:15; 89:3; 94:6; 95:1,1; 96:16,17; 100:4; 105:22; 110:3; 112:6 overseas 19:16 own 21:2; 25:15; 81:22 oxygen 53:13 P P-a-t-t-e-y 32:18, 20 page 110:11; 114:8, 9,10, 11; 116:19, 25; 117:9, 13 pages 117:17 paid 52:18 pamphlet 66:7,9,16 pants 69:25 Papageorge 84:4; 112:4 paper 19:20; 84:22, 24; 107:9 paragraph 108:23; 116:21 part 7:19, 20; 10:18, 23; 19:23; 29:2; 43:8; 52:12, 24; 53:4; 58:20; 65:19; 66:24; 68:17; 104:9; 105:23; 106:18; 107:25; 108:20; 110:23 participate 92:21 Concannon & Jaeger (314) 421-1000 Min-U-S cript living - participate WATER PCB-SD0000022944 George Roush, Jr. March 17, 1993 Nevada Power Company v. Monsanto Company, et al. Participated 25:11; 48:4, 10; 65:18 participating 28:8 participation 31:19 particularly 33:2 parts 13:21;67:8; 94:6 pass 57:13; 94:15 passing 94:24 patient 90:25 Pattey 32:18,19,20, 21 Patty's 45:22 Paul 103:25 PCB 55:10;87:2; 89:16; 94:2; 95:20; 96:2, 6, 20, 23; 97:7; 102:5; 107:14; 108:10 PCBs 16:2; 29:14, 16, 18; 30:19; 31:23; 32:3, 10; 34:16; 35:3, 5, 11, 13,18; 36:1,5, 6, 10, 12,14; 37:2, 5, 9,13,19; 38:4,13; 39:6,14,22; 40:1,11, 14, 17, 21,25; 41:5; 45:11,17; 46:1,8, 11, 15, 21; 47:18,24; 48:3,11; 51:11,12; 52:8,9; 53:2, 5, 19; 54:7, 10, 16,21,24; 55:6,13,18; 56:6,11, 21; 57:5; 8:12, 15, 20; 59:7, 8, 9,16; 60:8, 13, 23; 61:2,9,16, 17; 62:24; 63:5,9,15, 22; 64:2, 10,13, 17; 65:2, 22, 23; 66:6, 10; 67:24; 68:5,11,14; 69:1, 5, 10, 20,21; 71:2; 73:8,11, 16,21, 25; 74:10; 75:3,19, 21; 76:5, 5,8, 9,13, 13; 77:4, 4,9,10,14, 15,25; 78:12, 13, 15, 16, 16; 79:2, 3, 6, 9, 10, 13,14,22, 23; 0:2, 3, 6,7,15,15, 20, 21; 81:1,1,16, 17,25; 82:8,11,20; 83:2, 5, 22; 84:6,9, 11,18, 20; 85:14,20; 87:5; 88:4, 8, 11,23; 89:3, 5,17, 22, 23; 91:17, 20; 92:8,13; 93:3,13, 23; 94:6,8, 12, 15,18; 95:3, 6, 11, 14; 97:12,16, 21; 98:22; 99:16, 17, 25; 100:8,13,22; 101:3, 19; 108:25; 111:12; 114:14,24; 115:10, 19; 16:5 people 21:19; 23:7; 48:8; 74:14,18; 75:1; 76:2 per 94:6 performed 82:7 perhaps 43:22, 23 period 27:7; 39:4; 47:18; 55:15; 56:20; 57:24; 95:19; 96:16; 99:12 periodic 97:20 person 86:17 person's 75:13 personal 69:15; 82:4; 98:24; 115:15; 116:11 personnel 97:21 phone 86:6 phosphate 62:10 phrase 65:5 phrased 89:24 physical 18:13; 20:7; 22:12; 97:20 physician 18:17,17; 23:20 physicians 14:9; 23:17 piece 19:20 pigmentation 114:15; 115:11 Pittsburgh 7:12,16, 21; 8:4, 7, 12; 9:15; 10:6, 19, 25; 11:20 place 23:21; 30:23; 31:1,13; 54:4; 78:25; 87:24; 90:5 placenta 94:16 Plaintiff 4:4 Plaintiff's 22:14,17; 71:16; 72:7;84:17; 103:1; 106:5; 107:11; 108:4; 110:1; 111:20, 25; 112:13,25; 113:20; 114:7 Plaintiffs 30:12 plant 11:15; 107:15 plants 24:9,18 please 27:2; 43:25; 79:17; 81:4; 90:20 point 8:1; 21:7; 26:11; 34:9,11; 37:7; 63:4; 105:21 poisoning 64:21; 65:3,6; 96:1,4,9,11, 12,19 policy 111:11 polychlorinated 28:16, 20; 29:2; 34:14; 35:23; 53:9, 11,15,18; 54:9,15, 21,23 pores 90:6,7, 23 position 58:7 possible 92:9,14 possibly 28:7; 92:10 post-graduate 8:10 potential 76:13; 93:8 Power 4:11; 55:2 practice 9:9; 15:14; 18:19; 106:18 practicing 11:12 preparation 48:11 prepare 32:6,9,14; 41:13,19; 43:4 prepared 22:17; 41:21; 42:3,11,18, 24; 45:10; 68:8 preparing 48:2 preparation 32:25 present 36:12; 103:6 presented 54:12 presently 5:7 President 108:10 pressure 13:18 prevent 73:14,19 previous 27:3; 28:15; 40:6; 44:1; 62:18; 77:21; 79:18; 81:5; 90:21; 97:5 previously 115:14 primarily 36:20; 53:1 primary 25:6 prior 30:2;41:25; 42:25; 48:11; 58:15, 25; 59:4,9; 93:1,12; 98:7; 103:10; 105:1 probable 92:8 problem 92:17 problems 11:15; 66:14; 93:14; 115:25 process 114:25; 116:5 produce 64:14; 81:7; 96:14,15,23; 97:7,17 produces 62:8 product 60:2,5,23; 67:3; 74:24 production 114:25 products 15:20,23; 16:2; 28:2; 66:5; 75:18; 87:2; 95:20 Professor 11:22; 14:2, 7, 24; 82:7 program 52:12 promoted 59:1 proposed 107:19 propounded 27:3; 40:6;44:1;62:18; 77:21; 79:18; 81:5; 90:21; 97:5 protect 52:24; 53:4; 78:8 Protection 92:7,13 provide 43:8; 69:19 provided 113:18 Public 7:13,14,17, 18; 8:4, 21; 10:19, 20, 21,24; 11:20 published 52:14; 68:9; 84:25; 85:1; 87:20; 93:7 purchasers 66:5 purpose 8:22; 102:3; 113:1, 21; 114:3 put 13:15,17,19; 66:7; 109:14; 113:11 Q questioning 49:12, 22; 61:20; 63:2, 20, 24; 64:5,12,23; 65:25; 69:8; 100:17 quit 58:3, 5, 7 quite 22:6 R R-o-u-s-h 110:13 Ralph 4:7; 101:14 Ran 15:2; 19:1 rank 5:23 rarely 91:10,14, 20 rash 65:1 Rats 16:18 re-ask 63:3; 100:18 reaction 90:5,7,8, 22 reactions 97:17 read 27:1;31:4; 40:4; 45:1,6; 62:13, 17, 21; 66:1, 2, 4; 71:19; 77:19; 112:20; 113:9 Reading 68:3, 4,7,7 really 34:6; 115:17 reason 29:8 reasonable 82:17 recall 16:7; 22:8; 27:18, 22; 29:5; 30:4, 18, 25; 31:4,12, 22; 32:2; 33:10,19,24; 34:1,2; 38:5,17,18; 39:8; 42:10; 43:18; 46:17, 20, 24; 47:1, 3, 6; 48:16,17, 21; 49:6; 50:10; 51:25; 52:7, 10; 53:14; 55:11; 56:16; 67:8; 69:18, 22; 85:2, 5,19, 24; 86:5,6,12,13,16; 112:12,18; 113:3 receive 5:15; 6:6; 85:25 received 6:19; 13:7 recent 51:14,15 Recently 50:19; 51:19 receptionist 20:23, 25 recess 34:12; 72:5 recognized 26:7 record 41:9,11; 106:1,3; 110:18,21; 117:20, 22 records 111:12 refer 117:5 reference 32:24; 103:13; 117:2 referenced 22:13; 31:17; 74:25; 109:3 references 116:22 referred 21:25; 117:17 referring 75:1; 110:15,17 refers 117:5,6 reflects 103:17 regarding 28:2,15; 32:3; 33:19; 35:18; 36:14; 37:12,19; 39:5; 40:1,14,17; 43:18; 45:16; 46:11; 47:24; 48:3; 49:24; 55:6,9,13,18; 56:6, 11; 58:11; 59:10; 65:18; 76:25; 82:8; 87:5; 89:7; 92:22 regards 49:19 regular 58:20; 106:18 regularly 108:21; 110:24 relate 8:20; 83:8 related 36:11; 64:8; 106:21 relating 33:15; 38:13; 40:10,25; 41:4; 51:8; 57:5; 72:18; 111:12 relationship 49:10, 24 relay 82:25 remain 109:1 remained 23:25; 109:7,19 remember 28:22; 30:9, 12,14; 33:12; 35:16; 50:21; 67:7, 21; 70:5; 85:9,10,11, 18 repeat 97:4 repeated 96:1, 5,19, 23; 97:7 rephrase 79:19 report 25:3,21; 26:24; 27:4,13; 68:8; 85:17; 103:12; 107:14,19; 116:16 reported 25:4;27:6, 8,12; 94:6; 114:21; 115:2, 22; 116:6 reporter 20:4; 22:14; 27:3; 40:6; 44:1; 62:18; 77:21; 79:17, 18; 81:4, 5; 90:21; 97:5 reporting 27:18, 23 represent 4:11 represented 4:16; 30:4,5 request 113:17 requires 50:5 Research 27:24; 46:7; 84:20; 88:7,10, 22 residency 9:5,10, 12, 17, 18; 10:6,10, 11, 13, 17 residential 5:5 respect 23:15 respiratory 62:2,3, 7 respond 87:14,15; 97:23; 98:24; 109:22 responded 87:18 responsibilities 11:9,11; 24:1, 5,11, 14, 20; 39:25; 40:13, 16; 41:4; 74:23 responsibility 25:6; 40:10; 48:2; 57:2; 73:22; 74:12,15; 75:4; 81:18, 19,20; 97:2 responsible 58:21; 75:6 restrict 99:25; 100:7, 13, 22; 101:3 result 88:18;89:17; 108:12 results 52:14,16; 103:13, 18 retire 5:9; 39:19; 42:13 Retired 5:8; 26:13; 39:14,15,16,17,23; 40:3; 42:2, 3,6; 47:14; 51:17,18; 56:14, 17; 57:4; 58:4 retirement 41:7,18; 42:17, 24 return 6:1 review 30:1; 32:5,9, 11,11,14,25; 33:3, 15; 41:23; 42:23,25; 43:2,4,8; 44:8, 12, 14,24, 25; 46:9,13; 47:17; 71:17, 25; 72:2,16,18; 80:5, 10, 14, 19, 24; 81:14; 82:20; 84:16,24; 91:19; 92:25; 93:11, 17, 21; 98:6; 99:4; 106:5,7; 107:1,12; 108:6, 6, 10; 110:1, 2; 111:25; 112:1,14; 113:1, 20, 22; 114:2 reviewed 31:9; 33:9, 20; 34:3; 42:5,10; 45:9,10,15; 46:18, 21,24; 47:1; 72:22; 80:19; 91:23, 24; 92:2,4; 111:22 reviewing 42:1; 48:7 Participated - reviewing Min-U-Script Concannon & Jaeger (314) 421-1000 WATER PCB-SD0000022945 Nevada Power Company v. Monsanto Company, et al. George Roush, Jr. March 17, 1993 Richard 110:5 Richter 102:2 right 5:1, 3, 18; 6:8, 19; 7:18, 22; 8:9, 23; 9:14; 12:12,19; 14:17; 15:9,22; 17:21; 20:6,19, 25; 21:2,6,8, 9,11,13, 16, 20, 22; 22:8,10, 11, 21; 23:4, 6, 6, 10, 13; 24:21; 25:9; 29:16; 31:8, 12,22; 33:18; 34:5, 7; 35:17; 38:24; 39:4,12,18; 40:16; 43:14; 44:17, 23; 45:4, 8,20,23; 46:5,9; 52:10; 54:5; 7:1; 61:5; 62:5; 70:11,19, 24; 72:4, 17, 21, 24; 73:17; 75:20; 76:1; 78:5, 20; 79:1; 81:13; 86:4; 94:1; 95:25; 98:5,14; 99:3,6; 101:16; 104:9,18; 106:9; 107:8; 108:13; 109:18, 25; 111:15, 24; 112:13,19; 114:1, 12; 116:4 right-hand 112:6,9 rings 53:12 risk 91:1 rodents 64:13 room 21:2; 102:17, 18 rooms 20:12;21:18; 23:18, 19, 24; 102:12 roughly 29:5; 30:18; 56:16 round 65:18 ROUSH 4:1,7; 20:3, 4; 22:14,17; 33:21; 34:13; 46:2; 47:12; 72:6; 98:11; 103:3; 111:15, 16, 17, 17 run 15:3; 91:1 s safety 48:4; 66:17; 68:17, 20, 25; 70:12; 71:11; 73:15^ 74:13, 15; 77:17; 78:6,9,18, 25; 80:11,13,18; 81:6, 9, 11; 93:19, 20 sales 74:11,18,22; 75:1; 84:7, 12 same 19:7; 34:21, 22,25; 35:9; 40:15; 50:3; 55:14; 74:22; 89:6; 97:13; 98:23; 115:14; 116:10 San 30:20; 31:25 satisfactory 108:25; 109:4, 10 Sauget 107:15 saw 89:14 saying 12:14; 100:15 scarring 91:2 scars 91:1 School 6:12;7:13, 15,16,18,19; 8:4; 10:18, 24; 11:19; 14:19, 20, 23; 15:1,7, 10, 18, 22; 16:1,4 Schwartz 65:15; 117:7 second 60:20; 110:19; 116:20 secretary 21:1,2; 23:8 section 18:16,17, 19,21,25; 21:18,21; 24:25; 25:7; 26:21; 38:8,10; 40:18,24; 45:22; 55:17; 56:5, 10; 57:17, 22; 58:1, 10,16,19, 23; 59:11, 25; 74:3; 104:10; 116:19; 117:2, 11 sections 18:20,24; 19:3,7 sell 71:7 sense 63:12 sent 76:7; 93:1; 106:10,13 sentence 116:21 separate 73:3; 84:12 September 110:4; 111:12 series 80:11; 82:7 serious 64:20; 98:17,21 seriously 38:25 sessions 52:7,10 seven 117:17 several 31:17; 95:1 severe 66:23;90:12, 18, 22, 25; 91:2, 5, 16, 21 severity 90:15 SGOT 62:10 SGTP 62:11 shake 105:6 Sheet 66:17; 68:18, 20, 25; 70:12; 77:17; 78:6,18, 25; 80:18; 81:6 sheets 48:4;71;12; 73:15:80:11,13; 81:10; 93:19, 20 shift 68:16 shirts 70:2 shoes 69:6; 70:4 shook 105:8 short 27:6, 21 short-term 16:11 shortly 54:13; 64:7 shouldn't 30:7; 43:23 show 36:25; 57:4; 71:15; 82:10; 103:1; 106:4; 107:10; 108:3; 109:25; 111:20,24; 112:13,25; 113:4, 19; 114:1 showed 79:6 showing 69:15; 82:4 shown 33:24; 57:7; 95:14 side 13:20; 21:17; 22:23; 23:17; 110:12; 112:9 sides 13:15; 23:8 Signal 5:22 significant 107:2 similar 90:9 situated 21:19 six 117:9, 17 sixteen 45:16 skim 72:7 skin 6l:22;62:7; 64:17; 65:1; 66:13; 73:9, 12, 16,21,25; 76:5, 9; 77:5, 11, 16; 78:1,13,17; 90:3,12; 97:16,17; 98:15, 20; 114:14,15; 115:2, 11,11, 25; 116:6 socks 70:6 sold 71:2 somebody 49:15; 50:7 someone ll:ll; 43:11; 50:22, 24; 78:11, 21; 81:12; 86:1, 13 someplace 103:23 something 13:14; 26:2; 43:8; 90:9 sometime 92:19 soon 22:6; 64:6 sorry 62:1;77:19; 98:1 sort 106:15; 107:22; 108:19; 110:22; 111:8 sound 6l:4 speak 52:3; 55:2, 5, 9, 13; 77:13, 24 speaking 90:11,17 specialty 7:2,6,8; 15:15 specific 76:3 specifically 36:13 spending 10:14 spoke 37:12;43:15; 55:17; 56:5,10; 78:14 spoken 78:11 sponsored 52:1 St 5:6 standard 32:24; 43:2 Stanton 9:4, 6; 10:2 start 5:11;89:3; 100:4; 105:22 started 20:10;62:23; 100:14 stated 115:15 statement 78:9; 89:21 States 92:7,12 stayed 16:13 Still 12:18; 23:19,23; 26:20; 42:8; 57:10; 87:2, 9 stopped 39:12 strike 61:6 students 11:1 studies 16:13,14; 25:12,13; 28:1; 32:12; 33:13,16; 34:3; 43:3; 46:24; 47:1; 62:10; 67:24; 79:3,5,6;82:7,10, 20; 88:7; 95:18; 103:22, 22 study 13:20;33:14; 34:4; 52:18,19; 68:7; 88:10, 22; 102:5; 103:5, 5, 22 subject 11:25; 29:1, 18; 31:12; 33:5; 37:13; 40:11; 45:11, 17, 24; 47:18, 24; 48:3; 52:8,11; 55:18; 58:11,15, 20; 68:5; 76:25; 87:20; 107:9 subsequent 20:1 Substances 92:22 substituted 18:18 suffer 88:16 sufficient 96:2, 5, 20 suggested 51:2 suggesting 79:3 suited 17:5 summary 41:13,19; 42:1, 3, 11, 18, 23; 43:4,9,12,14,16, 19, 22; 44:6, 9; 45:10 superficial 65:9 supplemented 18:18 sure 17:25; 19:5,25; 21:19, 24; 23:14; 30:7,7; 31:11; 45:2; 54:11; 72:20; 86:10; 101:7; 105:17 Swamp 102:17 sweat 90:6 Sweden 36:11; 82:7 swelling 114:16; 115:12 sworn 4:2 symposium 51:22, 25; 52:1,3,7,13, 17, 20, 23; 53:4,25; 54:4; 64:6 synergistically 95:7,11 system 63:13:95:8, 12 systemic 64:21; 65:3,5,11; 98:17, 21; 115:2; 116:7 systems 65:10 T table 65:18 talk 37:24; 59:3; 76:14, 20; 77:3,8, 18; 78:23; 83:23; 84:1, 10; 92:10; 102:5 talked 24:19; 33:5,7, 14, 23; 84:22 talking 46:1,3; 48:8; 49:2;55:21,23; 74:16; 85:19; 92:11, 17 talks 66:15; 81:7; 88:24 taught 11:1; 12:1,4; 14:9 teach 10:23; 11:3; 12:3; 14:10 teacher 56:22 teaching 7:1 telling 68:18; 75:7; 113:1; 114:3 temperatures 99:7, 16 Ten 28:13,18; 47:7; 72:1; 95:16 term 34:14;35:11; 36:1; 48:14,17, 22; 49:17,18; 53:8,15; 94:20 terms 12:13; 62:8 testified 87:7; 97:1 testify 89:7 testimony 29:22; 30:2;31:13, 23 textbooks 43:3 thanked 87:21 their's 103:20 themselves 78:8 therapy 8:19 thereafter 54:14 They're 7:20 thinking 19:4 thinner 82:21 thinning 82:16 thorough 44:8,12 though 31:23; 33:8; 51:14; 59:24; 67:11; 78:10; 79:8; 111:9; 113:12 thought 35:1; 43:16, 20; 44:5; 107:1 three 21:19; 29:12; 30:14; 58:3; 95:16 Throtall 17:10; 27:14, 18,25; 28:7 times 20:1;28:11, 14, 18, 19; 30:19 tissue 94:7 title 14:22; 18:1; 26:11; 27:8,11,22; 32:23; 38:3; 46:3; 75:13 today 4:16; 30:2; 103:10; 108:25 today's 32:6,9,15; 33:1 together 114:2,3 told 33:22;35:13; 43:15, 18; 49:6,9; 50:20; 69:10; 73:13; 78:19; 83:17; 87:16; 88:2, 5; 89:19; 101:8, 8; 115:24; 116:1,4, 11; 117:16 took 33:11; 36:2; 54:4; 58:7 top 114:10 topic 28:20; 30:19; 37:1 tough 45:18 towards 110:11 toxic 54:24; 92:22; 97:12,17; 99:20; 114:13; 115:10 toxicity 41:14,19; 42:19; 43:5,9; 44:9, 12,15; 54:21; 114:9; 117:17 toxicological 16:5; 28:1 toxicologically 26:8 toxicologist 26:8; 59:19 toxicologists 16:11; 24:19, 22; 25:10 toxicology 14:21; 15:2, 3,17, 19, 23; 16:1; 17:1, 5, 15, 22; 18:25; 21:18; 23:10; 24:25; 25:15,17; 26:5, 20; 28:6; 32:13, 14,17, 24; 38:8; 43:2; 55:16; 56:4, 9; 57:16; 104:8, 10 toxiologist 106:25 trace 51:11, 12; 94:1 track 62:7 tract 65:13 training 7:3,10; 12:18; 13:7; 58:14 transcribed 31:1 transcripts 29:21 transformers 71:5,8 true 4:9 truth 4:2, 3, 3 trying 40:23 Tuland 14:23 Tulane 14:19,20, 25:15:6,10,18, 22, 25; 16:4; 17:3 Co iicannoii & Jaeger (314) 421-1000 Min-U-Script Richard - Tulane WATER PCB-SD0000022946 George Roush, Jr, March 17, 1993 Nevada Power Company v. Monsanto Company, et al. tumors 88:8 turn 16:12; 58:11; 110:11; 114:7; 117:9 twenty 28:13,18; 72:5 Two 8:5; 11:24; 13:15,21; 15:8,25; 18:22; 22:15,18; 38:15; 53:12,13; 54:3; 60:20; 77:20, 21; 84:23; 86:20,21; 90:23, 23 two-year 11:25 u ultimately 6:9 unable 24:4 unclear 89:16, 23 under 24:25; 25:2; 114:8; 116:19, 20, 21; 117:11 underlined 114:10, 11 understood 4:23 undertake 28:1 undertook 67:23 United 92:7,12 University 5:14,16, 19; 6:6,12; 7:12, 16, 21; 8:3,6,11; 9:15; 10:6,19, 24; 11:20; 12:20, 23; 13:2, 9,22, 24, 25; 14:4, 11, 18 unrelated 39:3 up 10:14; 13:16,20; 29:18; 39:22; 41:7, 17; 56:25; 68:6; 105:3; 113:18 up-to-date 36:16, 18,19, 23; 37:5, 9, 13,19; 41:2 Upon 8:11; 103:5 Uria 115:7 urine 115:7,7 use 17:17; 113:14; 114:19 used 71:4; 78:2; 113:16 USHA 54:12,12 usually 31:7; 96:16 utilities 101:14 utility 55:5,18; 71:8, 11; 73:20, 24; 100:12,20, 24; 101:1,6, 10 V valves 13:14,18 vapor 96:2,20,23; 97:7 vaporize 99:17 vapors 96:6 various 28:1; 103:7 veins 13:16 via 86:6 vice-president 17:10; 27:10, 24 view 44:14 virtue 94:24 Visited 24:9,18; 102:21 visits 102:23 volume 32:23 w W.B 112:4 W.R 110:5 Wait 100:14 walk 102:8 wants 113:6 war 5:17 warned 66:4; 89:9, 15, 22 wash 69:12 Washington 6:12; 103:6; 109:23 way 11:15; 48:17; 50:11; 76:2; 91:2; 100:25; 116:20 wear 73:13,15,19 weeks 31:17 well-differentiated 109:13 Westinghouse 4:13; 55:13; 56:11; 68:23; 69:1; 70:13; 71:7 what's 20:19; 22:13; 28:19; 32:17,23; 34:25; 62:3; 66:16; 71:15; 96:3; 107:10; 108:3; 114:12 wheather 54:23 Wheeler 18:22; 36:2, 13; 37:8,12, 25; 38:1, 2; 39:5,13, 25; 40:12; 56:22; 57:7, 8, 10,16, 21; 58:1; 68:2; 83:12, 12,14, 17, 20; 110:5 Wheeler's 46:10 Whenever 85:9 Whereupon 20:4; 22:14; 27:3; 34:12; 40:6; 41:10; 44:1; 62:18; 72:5; 77:21; 79:18; 81:5; 90:21; 97:5; 106:2; 110:20; 117:21 whole 4:3; 52:9 Whose 81:20; 111:16; 114:19 windows 22:23; 23:7 Wisconsin 5:14,16, 19; 6:5, 7,18, 20 within 38:6,8; 40:9; 48:8; 50:24; 58:3; 72:13; 74:16,18; 75:6,15, 21; 77:8, 24; 78:11; 79:5, 21; 80:1; 85:19; 86:2; 88:2 WITNESS 7:4; 24:12,15; 31:24; 32:7; 35:19; 37:10; 39:15; 40:4; 45:12; 47:9; 49:2; 51:4; 55:21; 61:11; 62:21; 69:15; 70:9, 21,21; 72:3; 84:2; 88:12; 89:7,11; 92:3, 21; 96:3; 97:1,3,23; 98:1, 24; 99:10; 112:16; 113:10; 115:16; 116:11 Wood 112:4 word 114:9 words 31:4 work 11:8,8,16,17; 15:17; 16:24; 18:1,5, 8, 14; 19:14; 20:8; 21:22; 22:9; 24:22; 25:9,14; 36:6,9; 39:5; 42:7,8; 47:22; 48:1; 56:13; 68:16; 73:5; 95:6,11; 99:23; 100:19; 104:16,19, 25; 105:23; 107:25 worked 24:18; 40:20; 47:19; 55:1; 56:17; 59:24; 67:2, 14,18; 75:18; 80:23; 83:19, 21; 84:15; 104:17,24; 111:16, 18 worker 64:19; 65:1; 67:19; 91:16 workers 11:14; 67:15; 68:15; 69:5, 20; 70:14; 88:11,12, 16, 23; 91:5; 97:21; 107:15; 114:21,24; 115:22; 116:5 working 11:10,13; 16:16; 18:17,23; 24:17; 25:6; 36:3, 4; 40:2; 69:1, 5, 20; 74:9; 75:19, 21; 76:4, 8,12; 77:4,9,14; 78:12,15; 79:2, 9,13, 22; 80:2, 6, 15, 20, 25; 81:11,16; 83:1, 21; 84:6,11, 18; 85:14, 20; 91:6; 101:1,18; 104:4,7,8 workups 16:1, 5 Wright 104:1,3,12, 13,15, 19,21,23, 25; 105:2,12,21,23 write 6:18; 43:7 written 20:25; 43:8; 45:24; 47:18; 68:9; 76:18; 78:6 wrong 13:14 wrote 21:9 Y Y-u-s-h-o 115:18 year 9:2,8, 20,20, 24; 10:3,11,13; 12:22, 25; 22:24; 29:5; 42:10, 13 years 8:5; 11:24; 15:4,8,25; 29:7; 45:16; 47:12; 54:3; 57:14; 58:3; 60:1; 114:20; 115:21 yesterday 33:5, 25 yours 78:22 Yusho 51:20; 115:18 1 Z-a-c-k 107:16 Zack 107:16 tumors - Zack Min-U-Script Concaimon & Jaeger (314) 421-1000 WATER PCB-SD0000022947 This Page Intentionally Left Blank WATER PCB-SD0000022948 WATER PCB-SD0000022949