Document VJLMGZLQ3Y6RoBLgeyGJe8m2Z

146 1 Sayers 2 DuPont. Have you ever seen that letter before? 3 A. Never. 4 Q. It was given to us in the litigation. 5 It says, "We are responding to your concern about 6 the presence of asbestos" in some product "and 7 possible asbestos health hazards." Do you see 8 that? 9 A. Yes. 10 Q. Go to the second paragraph, please. 11 A. Yes. 12 Q. "The asbestos we use is a unique type 13 available from just one mine in California. It is 14 produced and processed by the Union Carbide 15 Corporation. They have run extensive medical tests 16 on this asbestos (Calidria, RG-144) and we have 17 their assurance it is non-carcinogenic." 18 Did 1 read that right? 19 A. You did. 20 Q. Sir, y'all have never been -- Union 21 Carbide -- 1 shouldn't include you. Union Carbide 22 to your knowledge has never been in a position to 23 assure people its Calidria was non-carcinogenic; 24 true? 25 A. 1 couldn't say that, because 1 left 148 1 Sayers 2 Q. In other words, you believed it? 3 A. Yes. 4 Q. You can't account for what they were 5 doing over in the United States and what they were 6 telling their customers over here, but you weren't 7 going to walk around telling customers this is 8 non-carcinogenic, were you? 9 A. No, we didn't. 10 Q. Did you know there's a difference in the II level of knowledge about asbestos over in the 12 United Kingdom versus the United States back in the 13 '50s and '60s? 14 MR. WILL: Object to the form of the 15 question and lack of foundation. 16 A. 1 couldn't have quantified it, no. 17 Q. Maybe I'm not using a good word. Were 18 you at least aware ofthe fact that the United 19 Kingdom was much more attuned or aggressive or 20 aware or informed about asbestos hazards than, in 21 general, the United States was? 22 MR. WILL: Object to form, foundation, 23 speculation. 24 A. 1 knew there was an awareness in the 25 U.K. My knowledge didn't extend to the United 147 1 Sayers 2 Carbide in '69 and l have no idea what happened 3 thereafter. 4 Q. As of 1969 Union Carbide had never been 5 in a position to assure people its Calidria was 6 non-carcinogenic; true? 7 MR. WILL: Objection to foundation. He 8 can answer with respect to his knowledge. 9 A. That is probably so. 10 Q. Well, sir, you specifically say in your II report something on this subject, don't you? You 12 know what I'm talking about? 13 A. Moral issues, I should imagine. 14 Q. Yes. You would imagine correctly. Page 15 15. "It therefore seems on the basis of present 16 evidence, we are not entitled under any 17 circumstances to state that our material is not a 18 health hazard." 19 Did I read that right? 20 A. Yes, you did. 21 Q. You believed that, didn't you? 22 A. That was stated on behalf of Union 23 Carbide U.K. Limited, not on behalf of their -- it 24 was a statement of fact on behalf of the London 25 office. 149 1 Sayers 2 States. 3 Q. This is a little bit out of order, but 4 I've got to ask you a couple questions because I'm 5 afraid if I'm going to lose track and not get back 6 to them. So excuse me for hopscotching around in 7 subjects; okay. 8 A. 1 understand. 9 Q. One of the nice things about a video is 10 we can go back and put it back together in a puzzle 11 where it will all makes sense. I've just to make 12 sure 1 cover everything. So 1 apologize to you. 13 You were making sales calls and offering 14 help to the paper industry on using Calidria within 15 paper products; is that right? 16 A. Yes. 17 Q. And we've seen some brochures and some 18 materials that the Union Carbide company had over 19 here in the States that helped promote use of 20 asbestos in paper products. Did you have access to 21 any of those materials? 22 A. 1 can guess to what you're referring. 23 Some of the documentation did come across, and that 24 helped us with our selling activity. 25 Q. One of the things 1 w as really SPHERION DEPOSITION SERVICES 38 (Pages 146 to 149)