Document a4qXJpqaLneKqRX1G3zOywa2b

338 1 Sayers 2 you recall that question? 3 A. 1 do. 4 Q. Would you describe for me exactly -- you 5 talked a little bit about a product that you had 6 purchased; is that correct? 7 A. Yes. 8 Q. How much of that product did you buy? 9 A. Oh, less than a liter. 10 Q. Would you describe what your 11 relationship was with Union Carbide or a Carbide 12 subsidiary in purchasing that customer? How would 13 you characterize it? 14 A. We were doing some work on ultraviolet 15 curing resins, and this was a photo initiator which 16 cured and cross-linked the product 17 Q. Were you anything more than just a 18 customer of Union Carbide? 19 A. Nothing more. 20 MR. BROWNSON: Objection, leading. 21 Q. Nothing more than that? 22 MR. BROWNSON: Objection, leading. 23 A. Nothing more. 24 Q. How would you characterize the nature of 25 your relationship with Union Carbide? Was it as a 340 1 Sayers 2 MR. WILL: And he refused the offer of 3 food and a break? 4 MS. JACOBS: Yes. 5 MR. WILL: Let's go back on the video 6 record. 7 THE VIDEOGRAPHER: The time is 5:36 8 p.m. We're back on the record. 9 Q. Mr. Sayers, it may seem like a long 10 time ago. Mr. Lanier asked you some questions II about the writing of your report. Do you recall 12 that? 13 A. Yes. 14 Q. First of all, did anyone from Union 15 Carbide ask or instruct you to write your report. 16 Exhibit 1? 17 A. No. It was at my own initiative. 18 Q. Your initiative to write it? 19 A. My initiative. 20 Q. You were asked some questions about the 21 information you had received from Dr. Timbrell 22 regarding chrysotile and the cause of cancer. Do 23 you remember that topic? 24 A. Yes. 25 Q. Did you go out and tell customers of 339 1 Sayers 2 customer or something else? 3 MR. BROWNSON: Objection, leading. 4 A. It was purely on a supplier-customer 5 relationship. 6 Q. Other than that purchase ofthat small 7 amount of product, is there any other relationship 8 between your current company and Union Carbide? 9 A. No, none. 10 MR. WILL: At this point let's go off 11 the record. 12 MR. BICKS: Just before we do, 1 put 13 on the record we went out and we found 14 Mr. Polk and offered to make available our 15 cafeteria to him, and he said that he 16 doesn't want to eat, that he's leaving. 17 THE VIDEOGRAPHER: The time is 5:34 18 p.m. We're off the record. 19 (Pause.) 20 MR. WILL: Could I just ask, has 21 Mr. Polk left, did he leave any instructions 22 where we can leave him? 23 MS. JACOBS: He left his hotel name 24 and the room number and said we should call 25 him. 341 1 Sayers 2 Union Carbide what Dr. Timbrell had told you? -7 J A. No, 1 didn't, because 1 wanted 4 Dr. Dernehl's comments on that. 5 Q. Do you have in front of you Exhibit 7? 6 A. Yes. 7 Q. For the record, that's the letter from 8 Dr. Demehl to Tom Hall of June 7, 1967; is that 9 correct? 10 A. That's right. II Q. Would you look at the bottom paragraph 12 of the first page of that letter. You saw that 13 paragraph at approximately the time this letter was 14 received; is that correct? 15 A. YeSi I believe 1 did. 16 Q. That bottom paragraph on the first page 17 spills over to the second page. Does that 18 specifically use the name Mellon Institute or 19 Mellon study? 20 MR. BROWNSON: Objection, leading. The 21 document speaks for itself. 22 A. There's no reference to Mellon in this 23 document. 24 Q. Now having been shown the Mellon study 25 today by your counsel, does it appear to you SPHERION DEPOSITION SERVICES (212) 490*3430 86 (Pages 338 to 341)