Document ZQrGrdEV9pD2ynJO7j6yZqgY

07/30/93 13 17 6 0 7 770 8623 Schecter SUNY 0001 SENT BY. 7-30-93 : 9:44AM : BRADLEY AND MERRELL- 607 770 8623: 1/ 3 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 MESSAGE FROM XEROX 7024: ffP S 3fi5dS5 DATE; h iy 3. M 3 __________ v>^ V / * ' Xtf. Avncid FAX#: fp l')'1 7 < F^fl: pho ne #: C L IE N T /M A T T E R : Nevada Power v. Monsanto CUENT/M ATTER NO.: 11927.2 DOCUMENT(8) DESCRIPTION: S U^'C__ NUMBER OF PAGES (Including cover page): ___ ' MESSAGE: TKS THJSOOFY 18 W T 0 O ) ONLY FOR THE AD0RE888f NAMSl ABOVE, rr MAY COKTAM WPCTMATION THAT ES PflVLEGED AM3 CONFIDENTIAL IFYOUHAVERSCBVeDTM eTBJBCOryiHBfVOlPVeASeNCm FVUSiyM BW IH.Y BY TBJEPHONE, DfiTTROY AU-COPIES. AND OO NOT DISSEMINATE THE INFORMATION TO ANYONE. THANKYOU FOR YOUR ASSISTANCE. IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (702) 365-4202 and ask for Robert Osterloh, Ext 615 07/30/93 13-.IS 6 0 7 770 8623 & 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 et a l , Ur. A r n o l d S c h e c t e r 68 Aldridge Avemia Binhamton, New York 13903 >JvW f J 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 [ 104r the Agency for Toxic Diseases and Subtance Registry for the Centers ^ tfrtpec/V 'to * 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 07/30/93 13:18 6 0 7 770 8623 Schecter SUNY ,, ..... JSMPu, 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. l2> U./5 Cr** Currently, and for the past three years, Dr. Schecter A* a h *>< a professor at the Department of Preventive Medicine, (SUNY\ Health*J2u/ a * tk' ' *** 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 07/30^93 13:19 607 770 8623 Schecter SUNY . . w *, o 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, e>uuktCc. W-eo-tt-U. cju+& C 2-'f <? ^ a.ud( research experience, training and understanding of the current /\ 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. 07/30/93 13:20 6 0 7 770 6623 Schecter SUNY 2)005 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. f\* 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 <K agencies and symposia and other publications dealing with halogensted aromatic hydrocarbon toxicity. At the request of Nevada Power attorneys, Dr l Schecter may i| 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 ii i 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. j;\cnv\fj\*prt\*:hedw,dii I ! I