Document ZQrGrdEV9pD2ynJO7j6yZqgY
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Schecter SUNY
0001
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BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED
Seventh Floor -- Bank of America Piara 300 South Fourth Street
Las Vagas, Nevada 69101-6026 (702) 365*4202
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Nevada Power v. Monsanto
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Schecter SUNY
Nevada P o w e r camp any v. Hon s ant O- C o ^ C ase No. C V - S -8 9-5 5S-LDG-LRL
I PRETRIAL WITNESS STATEMENT
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Ur. A r n o l d S c h e c t e r 68 Aldridge Avemia Binhamton, New York
13903
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SUMMARY OF TESTIMONY
Dr. S c h e c t e r is a s e n i o r m e d i c a l a n d s c i e n t i f i c a u t h o r i t y on
ru*ny a s p e c t s of, i n c l u d i n g but n o t limited to p u b l i c h e a l t h and |I
radical aspects of PCB residues including closely related PCDD and
* I1 p c d f residues inhuman tissues inindustrialized as well as less
industrialized nations Dr. Schecter hae devoted over 10 years'
time to the study of PCBs, PCDDs and PCDFs with patients. Dr.
Schecter has b e e n an advisor/consultant tothej WorldHealth
O r g a n i z a t i o n (WHO) , U.S. Environmental Protection A g ency ( EPA), and
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the Agency for Toxic Diseases and Subtance Registry for the Centers
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for Disease Control (CDC). in addition# DrJ Schecter conducts
o n g o i n g r e s e a r c h in t h e U n i t e d States, Russia# china, Vietnam, axwft.
Japan on PCBs, PCDDs and PCDFs. As a county Health) commissioner,
Dr. Schecter w a s the first to point o u t t h e dangers of PCBs, PCDDs
and PCDF's in P C B t r a n s f o r m e r fires.
Dr. S c h e c t e r r e c e i v e d a B.A in L i b e r a l A r t s and a b .s . in
Physiology and Neurophysiology from the university of Chicago, his
m .d . f r o m H o w a r d U n i v e r s i t y M e d i c a l School, a nd his M.F.H. f r o m
C o l umbia U n i v e r s i t y S c h o o l of Public Health. Drl S c h e c t e r rs p o st-
i
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graduate training has included r mini-resiaancy in Occupational
^av'uvHo Medicine at the Univarsity of Cincinnati College of Medicine and in ^
A Occupational Medicine at the University of Illinois Medical School
in Chicago, Illinois
at Mt. Sinai Medical Center in Nev York
? and at Nev York university Medical Center and various courses at
Occupational Medical national meetings.
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Currently, and for the past three years, Dr. Schecter A* a
h *>< a professor at the Department of Preventive Medicine, (SUNY\ Health*J2u/
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science Center in Syracuse, New York a*d-4n the Clinical Campus at
Binghamton, New York. Previously he trained and served on the
faculties of Harvard Medical School, SUNY Dovnstate Medical School
and the New Jersey Medical school. He is also a staff member at
our Lady of Lourdes Hospital in Binghamton, New York and the United
Health Services hospitals in Binghamton and Johnson City, New York.
Ac an extensively published author on FCBc, PCDDs and PCDFe,
Dr. Schecter's expertise ia relied upon by many persons researching
the issues surrounding these chemicals.
sSoma of Dr. Schecter*s membership affiliations are: the
-vaa.Cv<iV. ' Association of Teachers of Preventive Medicine; the American
College of Epidemiology; he is a Fellow in the American College of
Occupational and Environmental Medicine; a Fellow in the American
Colige of Preventive Medicine; a Fellow in the American College of
Physicians; a member of the Amercian Association for the
Advancement of Science; and a member of the Society for
Epidemiologic Research and belongs to other other scientific and
professional organizations.
In this litigation, Dr. Schecter is presented as an expert on
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the toxicology of PCBs, dioxins and dibenzofurans {PCB related
compounds). In the last eleven years, Dr. schecter's research has
focused on PCB, PCDD and PCDF residues found in patients' bodies
. 1 (U\'^"U-VGand movement of the PCBs, PCDDs and PCDFe through the human body; ~
A. -v . -- be-dy ^ or.^ r ss-. ^PCDgs~ and
p (z .Uu*<icachava. ? the bio logical halflives of PCBs, PCDDs and PCDFs; and the
movement of PCBs, PCDDs and PCDFs through the placenta and to the
fatue.
Dr. Schecter's research has also focused on the background
exposures of human population* to PCBs, PCDDs and PCDFs a* veil as
the bioaccumulation of PCBs, PCDDs and PCDFs in the general human
population. Dr. Schecter will testify to the impact of additional
PCBs, PCDDs and PCDFs when added to the background levels already
present in the human population.
Dr. Schecter is of the opinion that PCBs, PCDDs and PCDFs are
inherently dangerous to laboratory animals, wildlife and humans.
Ke is also of the opinion that levels of PCBs, PCDDs and PCDFs must
be reduced to lower the existing background human body burdens.
Dr. Schecter will also testify that the PCB equipment at Nevada
Power which is above and below the existing EPA standards is
defectively hazardous becasue of toxicity, persistence and
bioaccumulation.
The basis for Dr. Schecter'e testimony will be his education,
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research experience, training and understanding of the current
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literature on PCBs, PCDDs and PCDFs. Dr. Schecter will also review
publications from his published research as well as other research
and report generated by research on PCBs, PCDDs and PCDFs.
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Among the wore general sources of Dr- Sahecter*s information
vi 11 he general scientific literature on PCBs, PCDDs and f c d f s
along with recent NIOSH, EPA, CDC, Air Force a n d other government
agency research.
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Dr. Schecter may review m a t e r i a l s covered at
scientific meetings and information covered with or discussed with
;I other experts. Another category of information upon which Dr.
Schecter may rely includes pertinent research provided by state
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agencies and symposia and other publications dealing with
halogensted aromatic hydrocarbon toxicity.
At the request of Nevada Power attorneys, Dr l Schecter may
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also review learned treatises of other experts or any other
, i1 d o c u m e n t s related to the case which N e v a d a Power a t t o r n e y s p r o v i d e
for hie review.
Finally, Dr. Schecter may also be called: upon t o explain and
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define any scientific terms used by the defendants1 in documents
g a t h e r e d by Nevada Power d u r i n g d i s c o v e r y and' p r e s e n t e d t o him.
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